July 25, 2000
EPA-SAB-EC-COM-00-005
Honorable Carol M. Browner
Administrator
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, NW
Washington, DC 20460
Subject: Executive Committee Commentary on Residual Risk Program
Dear Ms. Browner:
The Executive Committee (EC) of the Science Advisory Board (SAB) is writing to alert you to
potentially significant issues arising from with the Agency's efforts to implement the residual risk
requirements of the Clean Air Act Amendments of 1990.
In 1998, the SAB sent you a report (EPA-SAB-EC-98-013) on its review the Agency's
Report to Congress on the methodology to be used in assessing the residual risks associated with the
post-Maximum Achievable Control Technology (MACT) emissions of hazardous air pollutants (HAPs)
from 174 source categories across the country. The Board endorsed the Agency's plan but identified
the need to see the methodology applied to a specific case in order to determine whether the
methodology was viable in practice, as well as in principle.
This spring, the SAB reviewed an Agency interim workproduct that indicates how the Office of
Air and Radiation (OAR) plans to implement this methodology in practice. The results of that review
were sent to you in May in the "Advisory on the USEPA 's Draft Case Study of the Residual Risks
of Secondary Lead Smelters" (EPA-SAB-EC-ADV-00-005). In short, the Board found that the
Agency has made a good faith start in using the methodology to assess the residual risks from this
source category but went on to cite significant scientific problems that raise serious concerns about the
potential for the Residual Risk Program, as currently conceived, to successfully achieve its goals. In
particular, we understand that secondary lead smelters were selected as the first HAPs source category
for the residual risk exercise, in part, because it contains a limited number (24) of facilities, and because
it has a large monitoring data base, compared to most of the other 173 source categories. In light of the
relatively favorable knowledge base for this case study and the quite limited success that it has achieved
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to date, the SAB believes that the large number of data-poor categories will prove to be even more
intractable to this type of analysis than the secondary lead smelter category has been shown to be to
date. In summary, it is not clear that scientific analysis will be able to generate the type of information
envisioned in the CAAA. While decisions can be made in the absence of such scientific information,
they will not be sufficiently precise for the intended purpose.
While our concerns may turn out to be ill-founded, we recommend that the Agency and
Congress seriously re-consider the current Clean Air Act Amendments mandates and their
implementation strategy that depends on scientific analyses that will be resource-demanding, at a
minimum, and, quite possibly, impossible to carry out in a credible manner.
In summary, while we certainly endorse the concept of science-based decision making at the
Agency, we also recognize that no one is well served by asking science to take on an impossible task.
We would look forward to meeting with Agency leaders and Congressional personnel to
discuss these concerns and what might be done about them.
pcerely,
Dr. Morton Lippmann, Interim Chair
Science Advisory Board
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U.S. ENVIRONMENTAL PROTECTION AGENCY
SCIENCE ADVISORY BOARD
EXECUTIVE COMMITTEE
FY-2000
INTERIM CHAIR
Dr. Morton Lippmann, Professor, Nelson Institute of Environmental Medicine, New York University
School of Medicine, Tuxedo, NY
MEMBERS
Dr. Henry A. Anderson, Chief Medical Officer, Wisconsin Division of Public Health, Madison, WI
Dr. Richard J. Bull, MoBull Consulting, Inc., Kennewick, WA
Dr. Maureen L. Cropper, Principal Economist, DECRG, The World Bank, Washington, DC
Dr. Kenneth W. Cummins, Senior Advisory Scientist, California Cooperative Fishery Research Unit
and Adjunct Professor, Fisheries Department, Humboldt State University, Arcata, CA
Dr. Linda Greer, Senior Scientist, Natural Resources Defense Council, Washington, DC
Dr. Hilary I. Inyang, University Professor and Director, Center for Environmental Engineering,
Science and Technology (CEEST), University of Massachusetts Lowell, Lowell, MA
Dr. Janet A. Johnson, Senior Radiation Scientist, Shepherd Miller, Inc., Fort Collins, CO
Dr. Roger E. Kasperson, University Professor and Director, The George Perkins Marsh Institute,
Clark University, Worcester, MA
Dr. Joe L. Mauderly, Director & Senior Scientist, Lovelace Respiratory Research Institute,
Albuquerque, NM
Dr. M. Granger Morgan, Head, Department of Engineering & Public Policy, Carnegie Mellon
University, Pittsburgh, PA
Dr. William Randall Seeker, Senior Vice President, General Electric Energy and Environmental
Research Corp., Irvine, CA
Dr. William H. Smith, Professor of Forest Biology, Yale University, New Haven, CT
Dr. Robert N. Stavins, Albert Pratt Professor of Business and Government, Faculty Chair,
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Environment and Natural Resources Program, John F. Kennedy School of Government,
Harvard University, Cambridge, MA
Dr. Mark J. Utell, Professor of Medicine and Environmental Medicine, University of Rochester
Medical Center, Rochester, NY
Dr. Terry F. Young, Senior Consulting Scientist, Environmental Defense Fund, Oakland, CA
LIAISON FOR CHILDRENS HEALTH PROTECTION ADVISORY COMMITTEE
Mr. J. Thomas Carrato, Assistant General Counsel, Regulatory Affairs, Monsanto Company, St.
Louis, MO
LIAISON FOR SCIENCE ADVISORY PANEL
Dr. Ronald Kendall, Director & Professor, The Institute of Environmental & Human Health, Texas
Tech University/Texas Tech University Health Sciences Center, Lubbock, TX
LIAISON FOR ORD BOARD OF SCIENTIFIC COUNSELORS
Dr. Jerald L. Schnoor, Professor of Civil Environmental Engineering, Iowa University, Iowa City, IA
SCIENCE ADVISORY BOARD STAFF
Dr. Donald G. Barnes, Staff Director/Designated Federal Officer, Environmental Protection Agency,
Science Advisory Board (1400A), 1200 Pennsylvania Avenue, NW, Washington, DC 20460
Ms. Priscilla Y. Tillery-Gadson, Program Specialist, Environmental Protection Agency, Science
Advisory Board (1400A), 1200 Pennsylvania Avenue, NW, Washington, DC 20460
Ms. Betty B. Fortune, Office Assistant, Environmental Protection Agency, Science Advisory Board
(1400A), 1200 Pennsylvania Avenue, NW, Washington, DC 20460
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NOTICE
This report has been written as 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 balanced, expert
assessment of scientific matters related to problems facing the Agency. This report has not been
reviewed for approval by the Agency and, hence, the contents of this report do not necessarily
represent the views and policies of the Environmental Protection Agency, nor of other agencies in the
Executive Branch of the Federal government, nor does mention of trade names or commercial products
constitute a recommendation for use.
Distribution and Availability: This Science Advisory Board report is provided to the EPA
Administrator, senior Agency management, appropriate program staff, interested members of the
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public, and is posted on the SAB website (www.epa.gov/sab). Information on its availability is also
provided in the SAB's monthly newsletter (Happenings at the Science Advisory Board). Additional
copies and further information are available from the SAB Staff.
IV
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