Office of Solid Waste and Emergency Response
Climate Change Adaptation
Implementation Plan
June 2014
-------
Disclaimer
To the extent this document mentions or discusses statutory or regulatory authority, it does so for
informational purposes only. This document does not substitute for those statutes or regulations,
and readers should consult the statutes or regulations to learn what they require. Neither this
document, nor any part of it, is itself a rule or a regulation. Thus, it cannot change or impose
legally binding requirements on EPA, States, the public, or the regulated community. Further,
any expressed intention, suggestion or recommendation does not impose any legally binding
requirements on EPA, States, tribes, the public, or the regulated community. Agency decision
makers remain free to exercise their discretion in choosing to implement the actions described in
this Plan. Such implementation is contingent upon availability of resources and is subject to
change.
-------
Preface
The U.S. Environmental Protection Agency (EPA) is committed to identifying and responding to
the challenges that a changing climate poses to human health and the environment.
Scientific evidence demonstrates that the climate is changing at an increasingly rapid rate,
outside the range to which society has adapted in the past. These changes can pose significant
challenges to the EPA's ability to fulfill its mission. The EPA must adapt to climate change if it
is to continue fulfilling its statutory, regulatory and programmatic requirements. The Agency is
therefore anticipating and planning for future changes in climate to ensure it continues to fulfill
its mission of protecting human health and the environment even as the climate changes.
In February 2013, the EPA released its draft Climate Change Adaptation Plan to the public for
review and comment. The plan relies on peer-reviewed scientific information and expert
judgment to identify vulnerabilities to EPA's mission and goals from climate change. The plan
also presents 10 priority actions that EPA will take to ensure that its programs, policies, rules,
and operations will remain effective under future climatic conditions. The priority placed on
mainstreaming climate adaptation within EPA complements efforts to encourage and mainstream
adaptation planning across the entire federal government.
Following completion of the draft Climate Change Adaptation Plan, each EPA National
Environmental Program Office, all 10 Regional Offices, and several National Support Offices
developed a Climate Adaptation Implementation Plan to provide more detail on how it will carry
out the work called for in the agency-wide plan. Each Implementation Plan articulates how the
office will integrate climate adaptation into its planning and work in a manner consistent and
compatible with its goals and objectives.
Taken together, the Implementation Plans demonstrate how the EPA will attain the 10 agency-
wide priorities presented in the Climate Change Adaptation Plan. A central element of all of
EPA's plans is to build and strengthen its adaptive capacity and work with its partners to build
capacity in states, tribes, and local communities. EPA will empower its staff and partners by
increasing their awareness of ways that climate change may affect their ability to implement
effective programs, and by providing them with the necessary data, information, and tools to
integrate climate adaptation into their work.
Each Program and Regional Office's Implementation Plan contains an initial assessment of the
implications of climate change for the organization's goals and objectives. These "program
vulnerability assessments" are living documents that will be updated as needed to account for
new knowledge, data, and scientific evidence about the impacts of climate change on EPA's
mission. The plan then identifies specific priority actions that the office will take to begin
addressing its vulnerabilities and mainstreaming climate change adaptation into its activities.
Criteria for the selection of priorities are discussed. An emphasis is placed on protecting the most
vulnerable people and places, on supporting the development of adaptive capacity in the tribes,
and on identifying clear steps for ongoing collaboration with tribal governments.
-------
Because EPA's Programs and Regions and partners will be learning by experience as they
mainstream climate adaptation planning into their activities, it will be essential to evaluate their
efforts in order to understand how well different approaches work and how they can be
improved. Each Implementation Plan therefore includes a discussion of how the organization
will regularly evaluate the effectiveness of its adaptation efforts and make adjustments where
necessary.
The set of Implementation Plans are a sign of EPA's leadership and commitment to help build
the nation's adaptive capacity that is so vital to the goal of protecting human health and the
environment. Working with its partners, the Agency will help promote a healthy and prosperous
nation that is resilient to a changing climate.
Bob Perciasepe
Deputy Administrator
September 2013
-------
OSWER Climate Change Adaptation Implementation Plan Workgroup Members:
Andrea Barbery, Office of Underground Storage Tanks
Jennifer Brady, Center for Program Analysis
Richard Canino, Office of Emergency Management
Ann Carroll, Office of Brownfields and Land Revitalization
Steven Chang, Office of Superfund Remediation and Technology Innovation
Thornell Cheeks, Region 4
Anne Dailey, Office of Superfund Remediation and Technology Innovation
Michelle Davis, Region 10
Shannon Davis, Region 9
Ben Franco, Region 4
Elisabeth Freed, Office of Enforcement and Compliance Assurance
JeffGaines, Office of Resource Conservation and Recovery
Linda Gerber, Office of Underground Storage Tanks
Sara Goehl, Office of Emergency Management
Katie Matta, Region 3
Ellen Treimel, Federal Facilities Restoration and Reuse Office
Elsbeth Hearn, Region 1
Camille Hueni, Region 6
Carol Keating, Region 1
Jeffrey Kohn, Innovations, Partnerships, and Communications Office
Tiffany Kollar, Office of Resource Conservation and Recovery
Rachel Lentz, Office of Brownfields and Land Revitalization
NatMiullo, Region 8
Nicole Nakata, ASPH Environmental Health Fellow
Rebecca Ofrane, Region 2
Carlos Pachon, Office of Superfund Remediation and Technology Innovation
Scott Palmer, Office of Resource Conservation and Recovery
John, Podgurski, Region 1
Kristin Ryan, Region 10
Daniel Schramm, Office of the General Counsel
Mickey Young, Region 3
-------
Table of Contents
I. Climate Change Impacts to OSWER Programs 1
What We Do 1
Impact of Climate Change 1
Purpose of this Document. 2
Process for Developing this Document 2
II. Vulnerability Assessment 4
Climate Change Impacts 4
Identification of Vulnerabilities 5
III. Addressing Impacts of Climate Change 9
Focusing on Specific Vulnerabilities 9
Developing Priority Actions 10
Priority Actions 11
IV. Disproportionately Affected Populations 17
Disproportionate Impact. 17
Partnerships 18
Priority Actions 20
V. Measures and Evaluation 23
VI. Legal and Enforcement Issues 23
Appendices
Appendix A - Effect of Climate Change Impacts on Programs Vulnerabilities 24
Appendix B - Vulnerability Scorecard 27
Appendix C - OSWER Actions 31
Appendix D - Bibliography 35
-------
I. Climate Change Impacts to OSWER Programs
What We Do
Climate change is posing new challenges to the Environmental Protection Agency's (EPA's) ability to
fulfill its mission. The Office of Solid Waste and Emergency Response's (OSWER's) mission is to
protect human health and the environment, and preserve and restore land resources. OSWER strives to
protect the land from contamination through sustainable materials management and the proper
management of waste and petroleum products. When contamination does occur, OSWER and its partners
clean up communities to create a safer environment for all Americans. In addition, OSWER prepares for
and responds to environmental emergencies and promotes redevelopment of contaminated areas and
emergency preparedness and recovery planning.
Without proper protections and effective restoration, the presence of uncontrolled hazardous substances in
surface water, ground water, air, soil and sediment can cause human health concerns, threaten healthy
ecosystems, and inhibit economic opportunities on and adjacent to contaminated properties. Waste on the
land can also migrate to ground water and surface water, contaminating drinking water supplies. There
are multiple benefits associated with cleaning up contaminated sites: reducing mortality and morbidity
risk; preventing and reducing human exposure to contaminants; reducing impacts to ecosystems; making
land available for commercial, residential, industrial, or recreational reuse; and promoting community
economic development. In addition, materials management and sustainable land management practices
can significantly reduce greenhouse gas emissions.
Impact of Climate Change
Changes in climate and its impacts may test OSWER's ability to serve
these important functions. OSWER recognizes that anticipating and
planning for future changes in the climate and incorporating climate
considerations into its programs and operations is critical for OSWER to
continue to achieve its mission and fulfill its statutory, regulatory, and
programmatic requirements. There is some uncertainty, however, as to how
and when these changes to the climate will occur. OSWER will act
prudently to ensure its actions address pressing needs and will review its
vulnerabilities, actions and the state of climate science to make adjustments
Vision
OSWER will continue
to achieve its mission
to protect human
health and the
environment, and
preserve and restore
land resources, even as
the climate changes.
in the future.
Page 1
-------
Purpose of this Document
In June 2011, EPA issued a Policy Statement on Climate-Change Adaptation which recognized that
climate change can pose significant challenges to EPA's ability to fulfill its mission. It calls for the
agency to anticipate and plan for future changes in climate and incorporate considerations of climate
change into its activities. The Policy Statement also requires the development of an agencywide
adaptation strategy that would integrate climate adaptation into the agency's programs, policies, rules and
operations. OSWER participated in the cross-agency workgroup that developed EPA's Climate Change
Adaptation Plan, which was released for public review February 2013. In addition to the Agency Plan,
the Policy Statement also directed every EPA program and regional office to develop an Implementation
Plan that provides more detail on how it will meet the priorities and carry out the work called for in the
agencywide plan.
The purpose of this document is to describe OSWER's process for identifying climate change impacts to
its programs and the plan for integrating consideration of climate change impacts into the office's work.
OSWER will monitor the status of climate science, particularly as it relates to known or anticipated
impacts on OSWER's program areas, as well as the effectiveness of its program activities under changing
conditions, and update or adjust its direction as necessary. As its knowledge evolves, OSWER will
continue to refine its approach to climate change adaptation and build on the current plan.
Process for Developing this Document
OSWER's Climate Change Adaptation Implementation Plan was created by a workgroup of EPA
employees located throughout the United States representing each of OSWER's headquarters and regional
offices. Descriptions of OSWER offices and programs are listed in Table 2.
There were three primary stages in the development of OSWER's Climate Change Adaptation
Implementation Plan. First, a comprehensive set of vulnerabilities was developed, as described in Section
II. Next, evaluation criteria were applied to each vulnerability to guide the development of actions. These
scores are shown in Appendix C. Finally, specific actions were developed to address the vulnerabilities
that were identified as most critical, as described in Section III.
This plan also includes sections on vulnerable populations, working with tribes, legal and enforcement
issues, and measurement of progress.
Page 2
-------
Definition of Key Terms
Adapt, Adaptation: Adjustment in natural or human systems to a new or changing environment that
exploits beneficial opportunities or moderates negative effects.
Adaptive capacity: The ability of a human or natural system to adjust to climate change (including
climate variability and extremes) to moderate potential damages, to take advantage of opportunities, or
to cope with the consequences.
Mitigation: An intervention to reduce the causes of changes in climate, such as through reducing
emissions of greenhouse gases to the atmosphere.
Resilience: A capability to anticipate, prepare for, respond to, and recover, from significant multi-
hazard threats with minimum damage to social well-being, the economy, and the environment.
Risk: A combination of the magnitude of the potential consequence(s) of climate change impact(s)
and the likelihood that the consequence(s) will occur.
Vulnerability: The degree to which a system is susceptible to, or unable to cope with, adverse effects
of climate change, including climate variability and extremes. Vulnerability is a function of the
character, magnitude, and rate of climate variation to which a system is exposed, its sensitivity, and its
adaptive capacity.
Source: NRC. (2010). America's Climate Choices: Adapting to the Impacts of Climate Change. National
Research Council.
PageS
-------
II. Vulnerability Assessment
Climate Change Impacts
The global climate is changing and the impacts of this change are being felt across the United States and
the world. Many of these impacts will directly affect OSWER programs and activities. Listed below are
several climate change trends described by the U.S. Global Change Research Program: and their potential
impacts on OSWER programs.2
. "One of the clearest precipitation trends in the United States is the increasing frequency and intensity
of heavy downpours. The amount of rain falling in the heaviest downpours has increased
approximately 20 percent in the last century. " Flooding and inundation from more intense and
frequent storms may lead to contaminant releases through surface soils, ground water, surface waters,
sediments, and/or coastal waters at OSWER sites.
. "During the past 50 years, sea level has risen up to 8 inches or more along some coastal areas of the
United States, and has fallen in other locations. " Rising sea level may inundate OSWER sites in
coastal areas and increase flooding from storm surge, both of which could damage cleanups and
increase human and ecological exposures to contaminants.
. "The power and frequency of Atlantic hurricanes have increased substantially in recent decades. "
More powerful hurricanes may increase the area affected by these storms, putting sites and
communities that had not been previously impacted by flooding and storm surge in the past at risk.
More powerful storms may also increase storm debris that will need to be appropriately managed.
. "United States average temperature has risen more than 2°F during the last 50 years. " Increased
average temperature and increased extreme temperatures may result in more frequent and longer
lasting heat waves, increasing the risk of wildfires capable of spreading to OSWER sites and affecting
the performance of remedies.
. "Over the past 50 years, Alaska has warmed at twice the rate of the United States' average. The
higher temperatures are already contributing to . . . permafrost warming. " The melting of
permafrost may allow contaminants at OSWER sites in Alaska to migrate and may cause land shifting
and subsidence.
1 USGCRP. (2009). Global Climate Change Impacts in the United States. Thomas R. Karl, Jerry M. Melillo, and
Thomas C. Peterson (Eds.). Cambridge University Press.
2 This list is not intended to be exhaustive. A more complete list is included in subsequent parts of this section and
Appendix A.
Page 4
-------
. "In much of the Southeast and large parts of the West, the frequency of drought has increased
coincident with rising temperatures. " Decreased precipitation and increased frequency of drought
may impact water-intensive remedies and site stability, as well as increase the risk of wildfires.
. "Wildfires in the United States are already increasing due to warming. In the West, there has been a
nearly fourfold increase in large wildfires in recent decades, with greater fire frequency, longer fire
durations, and longer wildfire seasons. " Wildfires at contaminated sites could promote the spread of
contamination or impact remedies. Wildfire in the upland areas above contaminated sites could
reduce vegetative cover, thereby increasing surface water runoff and resulting in catastrophic flooding
that spreads contamination or impacts remedies.
In order for OSWER to fulfill its mission to protect human health and the environment, it is critical that
OSWER anticipate and plan for future climatic conditions. OSWER must appropriately integrate
consideration of climate into its program activities, policies, and regulations. Through adaptation
planning, OSWER can continue to protect human health and the environment but in a way that accounts
for effects of climate change.
Identification of Vulnerabilities
The first step in the development of OSWER's Climate Change Adaptation Implementation Plan was the
identification of OSWER's vulnerabilities to climate change. A vulnerability in this context reflects the
degree to which a system is susceptible to, or unable to cope with, adverse effects of climate change,
including climate variability and extremes. Using expert professional judgement and information from
peer-reviewed scientific literature, the OSWER workgroup used the aforementioned climate change
impacts as an initial screening tool to determine vulnerabilities to OSWER's processes, activities, and
functions. OSWER did not conduct a detailed quantitative assessment of vulnerabilities. In total, 27
unique vulnerabilities were identified (Table 1).
Page 5
-------
Table 1. OSWER Climate Change Vulnerabilities
rvina Land
o
(0
£
a
Proper Management of
Hazardous and Non-
Hazardous Wastes
Reducing Chemical
Risks and Releases
Restoring Land
Emergency Response
Tools, Data,
Training and
Outreach
Design and placement of RCRA Treatment, Storage and Disposal facilities, non-hazardous Subtitle D landfills,
Superfund remedies and municipal recycling facilities may need to change to accommodate climate change impacts.
Hazardous waste permitting requirements may need to be updated to reflect climate change impacts.
Current waste management capacity may be insufficient to handle surges in necessary treatment and disposal of
hazardous and municipal wastes, as well as mixed wastes generated from climate events.
Levels of necessary financial assurance at RCRA and CERCLA facilities may need to adjust for increased risks/liabilities
at specific facilities that may be directly affected by climate change impacts.
Remediation and containment strategies and materials used in construction may need to be strengthened to reflect
changing climate conditions.
Current equipment, scientific monitoring and sampling protocols on sites may no longer be effective and therefore
may require adjustments due to climate change impacts.
Current assumptions regarding protectiveness of remediation and containment methods may not reflect changing
climate impacts.
Spill Prevention Plans may need to be updated due to the significant increases in the incidence of flooding and storm
events.
Site characterization and design of cleanups may not reflect changing climate conditions.
Risk factors and rankings for risk-based cleanup strategies may need to be reassessed based on changing climate
conditions.
Changing climate conditions may impact continued remedy effectiveness.
Remedies that are "complete" or are long-term actions may no longer be protective and resilient as climate
conditions change at site.
Increased contaminant migration may lead to boundary changes at current sites or creation of new sites.
Changes in climate conditions may alter assumptions about contaminant form/volatility.
Current scientific monitoring and sampling protocols on sites may no longer be effective.
Safety procedures on sites may not reflect likelihood or intensity of surrounding conditions.
Availability of utilities and transportation infrastructure may be limited as a result of increased impacts to those
systems.
Current assumptions regarding protectiveness of remediation and containment methods may not reflect changing
climate impacts.
Periodic evaluations of implemented remedies may not incorporate all climate change impacts, including changes in
frequency and intensity that may impact remedy effectiveness.
Use of natural resources impacted by sites may change as a result of increased need, resource scarcity, or
compromised resources.
Current levels of administrative, enforcement, and emergency response staff may be insufficient to cover needs if
number of extreme events increase.
Sufficient capability and capacity for conducting necessary lab analysis following significant weather events may not
be available.
Current waste management capacity, including interim capacity, may be insufficient to handle surges in necessary
treatment and disposal of hazardous and municipal wastes, as well as mixed wastes generated from climate events.
Training needs (both current and future) are likely to increase in order to meet the increase demand for response
actions.
Existing emergency planning currently required or employed by OSWER may not sufficiently consider elevated risks
from multiple climate impacts.
Outreach and educational materials may need to be developed for owners and operators with facilities in areas of
changing environmental conditions.
Revised training protocols and SOPs that take into account climate change impacts and what to look for may need to
be developed.
Reliable data sources to use in site-specific analyses may need to be identified
Models, decision tools, site environmental data and information feeds may need to be updated to reflect changing
climate conditions
Page 6
-------
Each vulnerability is linked to at least one climate change impact, however most vulnerabilities are linked
to multiple impacts (Appendix A). For example, increased contaminant spread could occur because of the
greater incidence of flooding at contaminated sites from heavy precipitation, hurricanes, and sea level
rise, as well as, melting permafrost or wildfires. Several vulnerabilities, such as data collection for
mapping and training are linked to all the impacts of climate change.
As the vulnerabilities were identified, they were organized by four critical OSWER programmatic focus
areas and a cross-cutting category:
Preserving Land -Proper Management of Hazardous and Non-Hazardous Wastes;
Preserving Land -Reducing Chemical Risks and Releases;
Restoring Land;
Emergency Response;
Tools, Data, Training and Outreach.
Under each focus area a vulnerability may apply to more than one OSWER program office. For example,
five different OSWER offices identified contaminant migration from sites as a vulnerability for their
program. In addition, there were several vulnerabilities related to training and data needs that cut across
all program offices in OSWER, as well as across EPA.
Page?
-------
Table 2. OSWER Programs
Office of Superfund Remediation and Technology Innovation and
Federal Facilities Restoration and Reuse Office
The Superfund Remedial and Federal Facilities Program addresses long-term risks to human health and the
environment resulting from releases of hazardous substances at the nation's highest priority sites. Superfund sites
are found throughout the country. The Federal Facilities Program works with federal entities to ensure fast and
effective cleanup at federally-owned sites, and facilitates partnerships between the other federal agencies and the
surrounding communities. The Superfund Remedial Program works on non-federally owned sites.
Office of Brownfields and Land Revitalization
The Brownfields Program addresses environmental site assessment and cleanup of abandoned and potentially
contaminated sites through grants, cooperative agreements, and technical assistance to communities, states, and
tribes. Brownfields' sites have potential contamination that needs to be assessed and in some instances cleaned up
before redevelopment and reuse can occur. These sites generally are much less contaminated than Superfund and
RCRA Corrective Action sites. Funding to states and tribes helps develop and enhance their voluntary cleanup
programs for these sites.
Office of Emergency Management
The Superfund Emergency Response and Removal Program functions as the backbone federal response to
many emergency events; provides response support to state, local, tribal and potentially responsible parties when
their response capabilities are exceeded; and manages risks to human health and the environment. Removal actions
are typically responses intended to protect people from threats posed by hazardous waste sites.
The Oil Spill Program protects U.S. waters by preventing, preparing for and responding to oil spills. Section 311 of
the Clean Water Act and the Oil Pollution Act of 1990 provide EPA with the authority to establish a regulatory
program for preventing, preparing for and responding to oil spills that occur in navigable waters of the United States.
The EPA Chemical Emergency Preparedness and Prevention Program is the national regulatory framework to
prevent, prepare for and respond to catastrophic accidental chemical releases at industrial facilities throughout the
United States.
Office of Resource Conservation and Recovery
The Resource Conservation and Recovery Act (RCRA) Solid Waste Program encourages states to develop
comprehensive plans to manage nonhazardous industrial solid waste and municipal solid waste, sets criteria for
municipal solid waste landfills and other solid waste disposal facilities, and prohibits the open dumping of solid waste.
A core function of this program is to look for and incentivize more sustainable ways to manage our materials,
prolonging the life of materials as usable commodities for as long as possible.
The RCRA Hazardous Waste Program issues comprehensive, national regulations, defines solid and hazardous
wastes, and imposes standards on anyone who generates, recycles, transports, treats, stores or disposes of
hazardous waste. This program also monitors the movement of hazardous waste in and out of U.S. borders and
works to help ensure the waste that is exported is properly recycled or disposed of.
The RCRA Corrective Action Program directly implements the corrective action (CA) program in 13 states and
territories, and performs as lead regulator at an increasingly significant number of facilities undergoing CAs in 42
states across the country that are authorized for the RCRA CA Program. An essential element of EPA's hazardous
waste management program is the statutory requirement that facilities managing hazardous wastes must clean up
releases of hazardous constituents that could adversely impact human health and the environment. The CA program
is critical to preventing future Superfund sites and the associated resources and expenditures.
Office of Underground Storage Tanks
The Underground Storage Tanks (LIST) Prevention Program works with state, tribal and inter-agency partners to
set and implement standards which prevent and detect releases from underground storage tanks. EPA provides
resources to support the infrastructure of state and tribal UST programs and provides regulations, guidance and
policies to support program implementation. An essential element of the UST program is full implementation of the
Energy Policy Act of 2005.
The Leaking Underground Storage Tank (LUST) Cleanup Program works with state and tribal partners to clean
up releases from LUST sites, many of which impact ground water resources. Cleaning up LUSTs is a key part of
protecting our environment. EPA provides resources to support the infrastructure of state LUST programs so that
private and state resources can directly finance the field work necessary to address contamination at federally-
regulated tank releases. EPA also provides regulations, guidance and policy to support cleanup of tank releases.
PageS
-------
III. Addressing Impacts of Climate Change
Focusing on Specific Vulnerabilities
In a resource-constrained environment, in order to prioritize and focus OSWER's efforts to address the
impacts of climate change, each vulnerability was evaluated based on a set of criteria. Together, these
criteria allowed each OSWER office to use its best professional judgment to evaluate the areas that
needed the most or immediate attention and where its contribution would be most effective.
The first two criteria, referred to as the "Characterization Criteria", were designed to enhance the
understanding of the overall impact of a particular vulnerability. Because climate change is a long-term
problem, both the scale and timing of adaptation actions are important.
Characterization Criteria:
Scale of impact to human health, the environment or vulnerable communities because of the
vulnerability - The scores for this criterion reflect the potential for harm to human health, the
environment, or a vulnerable community, if the vulnerability is not addressed.
Likelihood of occurrence because of the vulnerability - This criterion is a reflection of what
impacts have already occurred at OSWER sites and programs.
The second set of criteria reflect EPA roles in addressing the impacts of these vulnerabilities and are
collectively referred to as "Opportunities for OSWER to make a difference". These criteria are intended
to identify those vulnerabilities for which action by OSWER would significantly advance adaptation
efforts and ones in which OSWER is more directly responsible for addressing.
Opportunities for OSWER to make a difference:
Does EPA have a unique or lead role or technical expertise in this area?
To what extent are climate impacts currently not considered in this area?
To what extent could additional EPA involvement build momentum or leverage current
activities?
Is there an opportunity to incorporate climate change into an ongoing effort (e.g., rulemaking,
changes to grant criteria, updates to guidance and training)?
Each OSWER office determined which vulnerabilities were applicable to its work and developed a score
for the vulnerability. When applying the criteria, offices did not rank vulnerabilities in relation to each
Page 9
-------
other, but instead considered each vulnerability independently. These scores were used to aid OSWER
offices in determining which vulnerabilities were most critical to focus actions.
The score sheet with the criteria is shown in Appendix B. To maintain transparency OSWER has included
all identified vulnerabilities regardless of the final score.
Developing Priority Actions
Using the vulnerability criteria as a guide, the following OSWER offices developed priority actions:
+ CPA - Center for Program Analysis
+ FFRRO -Federal Facilities Restoration and Reuse Office
+ OBLR - Office of Brownfields and Land Revitalization
+ OEM - Office of Emergency Management
+ ORCR - Office of Resource Conservation and Recovery
+ OSRTI - Office of Superfund Remediation and Technology Innovation
+ OUST - Office of Underground Storage Tanks
In addition, EPA regional offices play a central role in implementing OSWER programs. Regions work
closely with states, tribes, and other stakeholders to protect the environment and human health at a more
localized, geographically focused level than the OSWER national program. OSWER reviewed actions
proposed by Regional offices in their climate change adaptation plans and supports them as a crucial
element to advancing climate change. OSWER regional actions were primarily in support of EPA's
Strategic Goal 3: Cleaning Up Communities and Advancing Sustainable Development.
Continued Actions to Lessen Climate Change Impacts
While preparing for the potential impacts of climate change, leveraging materials and land
management programs to achieve measurable greenhouse gas (GHG) reductions remains a
focus of OSWER programs. It is estimated that approximately 42% of GHG emissions are
attributable to materials management activities and approximately 16% are related to land
management choices. To promote continued GHG reductions, OSWER is increasing efforts
for the advancement of life-cycle-analyses, the promotion of sustainable production and
material management, as well as promoting the use of green remediation principles that
reduce emissions during cleanups.
Source: USEPA. (2009). Opportunities to Reduce or Avoid Greenhouse Gas Emissions through
Materials and Land Management Practices.
Page 10
-------
Priority Actions
OSWER has identified 26 priority actions to begin over the next 3 years. These actions are in one or more
of the four programmatic focus areas and one cross-cutting category. The actions are found in a summary
chart in Appendix C and are listed below by programmatic focus area and office.
Preserving Land - Proper Management of Hazardous & Non-Hazardous Wastes
Proper treatment, storage, and disposal of hazardous waste protect the environment from harmful
contamination. To ensure these materials are properly managed, OSWER supports prevention by
activities such as permitting and inspections. Non-hazardous waste must also be properly managed, both
routinely and in times of emergency.
In the "Proper Management of Hazardous and Non-Hazardous Wastes" focus area, the vulnerability that
ranked the highest was the management of surges in waste, particularly from the impacts of extreme
events. ORCR is already involved in several efforts in this area and has identified several actions to
respond to this vulnerability. These actions are also applicable in the "Emergency Response" focus area.
As a crucial part of the RCRA program, ORCR has also identified a long-term action that will begin to
look at issues related to climate change and permitting programs. Even though, vulnerabilities related to
permitting did not receive high criteria scores, particularly in terms of likelihood of occurrence and
potential impacts.
Actions:
ORCR
Based on outreach to states and tribes, develop recommendations for these stakeholders to
incorporate climate change into RCRA Permitting Programs as appropriate (e.g., through robust
implementation of technical standards for facility location and design).
ORCR (also in the Emergency Response section)
Prepare Fact Sheets on proper management of wastes/debris associated with large natural
disasters (e.g., electronic, household hazardous wastes, white goods, etc.).
Continue collaborative development with the Office of Homeland Security, on an interactive
electronic waste management planning tool to aid federal, state and local emergency planners and
managers in development of waste/debris management plans.
Finalize a document describing the "4 Step Process for Waste Management Planning."
Update ORCR Homeland Security Website with updated waste management planning
information.
Page 11
-------
Preserving Land - Reducing Chemical Risks and Releases
EPA has several programs in place to prevent contamination from chemical releases. Prevention is
accomplished through effective operation and maintenance activities, containment strategies, as well as
inspection and monitoring of facilities that deal with hazardous materials.
The actions in this programmatic focus area address activities that prevent contamination from occurring.
Other vulnerabilities with high scores in this focus area will benefit from the actions to address
remediation and containment approaches as described in "Restoring Land".
Actions:
OEM
Incorporate sensitivity for climate change vulnerabilities into oil Spill Prevention, Control, and
Countermeasure (SPCC) and Facility Response Plan (FRP)3 inspector training.
Incorporate into SPCC and FRP guidance the statement of potential vulnerabilities to oil facilities
from catastrophic weather events due to climate change.
Incorporate sensitivity for climate change vulnerabilities in risk management plan (RMP) 4
inspector training and guidelines.
Restoring Land
Accidents, spills, leaks and past improper disposal and handling of hazardous materials and wastes have
resulted in tens of thousands of contaminated sites in the United States. Contaminated land can threaten
human health and the environment, impact our water and air quality, and potentially hamper economic
growth and the vitality of local communities. Numerous activities address the contamination, reduce risk
to human health and the environment, and move the contaminated site along the cleanup process to return
the site to use or reuse.
Two primary types of vulnerabilities were identified as the most critical in the "Restoring Land" focus
area. First, several offices identified increased contaminant migration as having a high potential impact,
3 The Spill Prevention, Control, and Countermeasure (SPCC) rule includes requirements for oil spill prevention,
preparedness, and response to prevent oil discharges to navigable waters and adjoining shorelines. The rule requires
specific facilities to prepare, amend, and implement SPCC Plans. The SPCC rule is part of the Oil Pollution
Prevention regulation, which also includes the Facility Response Plan (FRP) rule. A Facility Response Plan (FRP)
demonstrates a facility's preparedness to respond to a worst case oil discharge. Under the Clean Water Act, as
amended by the Oil Pollution Act, certain facilities that store and use oil are required to prepare and submit these
plans.
4 Under the authority of section 112(r) of the Clean Air Act, the Chemical Accident Prevention Provisions require
facilities that produce, handle, process, distribute, or store certain chemicals to develop a Risk Management
Program, prepare a Risk Management Plan (RMP), and submit the RMP to EPA.
Page 12
-------
high probability of occurrence, and often under the control of EPA programs. Second, remedy
effectiveness, which includes three separate vulnerabilities representing various stages of the cleanup
process (remedy selection, remedy effectiveness during cleanup, and remedy effectiveness after a cleanup
is complete), was also identified by several offices as having a high vulnerability score and a role for EPA
involvement.
Numerous OSWER offices involved in cleanup activities identified either a short- or long-term action
related to the vulnerabilities mentioned above. Due to the differences in how OSWER cleanup programs
are implemented, whether at the headquarters office, in partnerships with states, or through grants, the
actions differ across offices. There may, however, be areas where offices can share resources and
knowledge, for example, as we learn more about the effectiveness of particular remedies under extreme
climate conditions.
Actions:
ORCR
Develop recommendations for states and tribes to encourage climate change considerations be
incorporated into all of their RCRA Corrective Action Programs (e.g., regarding remedy
selection, etc.).
OUST
Work with the Association of State and Territorial Solid Waste Management Officials
(ASTSWMO) to gather information on if and how states currently:
alter remediation plans in response to changing climate impacts;
alter site assessments in response to flooding or drought conditions;
alter risk factors and rankings in response to flooding or drought conditions.
Share information among states, tribes, and EPA regions regarding:
new or modified investigation strategies and remediation techniques;
new or modified assessment techniques;
how climate conditions may impact risk-based cleanup factors and rankings.
OBLR
Work with regional staff to update the Analysis of Brownfields Cleanup Alternatives (ABCA)
language in the brownfield grant Terms and Conditions to include language that requires
recipients take potential changing climate conditions into consideration when evaluating cleanup
alternatives.
Page 13
-------
Develop an outreach strategy to promote the importance of climate change adaptation and
mitigation, explaining how it will affect all communities at varying degrees and why it is
important to consider when developing revitalization plans in their community.
OSRTI and FFRRO
Share vulnerability screening protocol for regional application.
Develop criteria to identify remedies where performance may be impacted by climate
change.
Develop a methodology to evaluate and ensure remedy protectiveness.
Prepare remedy-specific climate change adaptation fact sheets for remedies most likely to be
impacted and identify potential vulnerabilities and adaptation recommendations.
Identify existing Superfund program processes (Remedial Investigation/Feasibility Study, Record
of Decision, Remedial Design/Remedial Action, Five Year reviews, etc.) for implementation of
climate change adaptation protocols to ensure continuing protectiveness of current and future
remedies.
Prepare training materials, coordinate with the National Association of Regional Project
Managers (NARPM) co-chairs and Superfund forums to integrate the training into future
NARPM events, and provide web-based content and training.
Participate with OSWER and other EPA programs to initiate conversations as appropriate
regarding approaches for handling remedy impacts from climate change.
Emergency Response
OSWER responds to a variety of emergencies, varying greatly in size, nature, and location, including
natural disasters. OSWER staff act as response coordinators and on-site responders. In all cases, prompt
action is crucial and the first priority is to eliminate dangers to the public; dangers include contamination
from chemical releases in the air, water or soil and large amounts of waste. In addition to the
responsibilities of OSWER's Office of Emergency Management, many other OSWER and EPA program
offices play a role in addressing the impacts of emergency events.
The management of debris was a highly ranked vulnerability in this category, as well as in the "Proper
Management of Hazardous and Non-Hazardous Waste" focus area. Several actions are identified to
address this vulnerability.
The Emergency Operations Center (EOC) is a vital part of OSWER's response program. Actions are
identified to ensure EOC staff are provided with the most accurate and comprehensive information that
takes into consideration changes in climate.
Page 14
-------
Actions:
OUST
Work with ASTSWMO to gather information on if and how states currently respond to climate-
related emergencies (e.g., use of GIS mapping in flood-prone areas).
Analyze lessons learned from Hurricanes Katrina (2005) and Sandy (2012) to identify how EPA
can help states respond to UST-related hurricane impacts.
Share information among states, tribes, and EPA regions regarding emergency response and
preparedness (e.g., OUST's Flood Guide).
ORCR (also in the Proper Management of Hazardous and Non-Hazardous Wastes section)
Prepare Fact Sheets on proper management of wastes/debris associated with large natural
disasters (e.g., electronic, household hazardous wastes, white goods, etc.).
Continue collaborative development with the Office of Homeland Security, on an interactive
electronic waste management planning tool to aid federal, state and local emergency planners and
managers in development of waste/debris management plans.
Finalize a document describing the "4 Step Process for Waste Management Planning."
Update ORCR Homeland Security Website to incorporate facts sheets, 4 Step Process, and
updated waste management planning information.
OEM
Utilize the National Response Team multi-agency membership (e.g., National Oceanic and
Atmospheric Administration, Federal Emergency Management Agency, U.S. Coast Guard) to
monitor the state of preparedness. Based on these meetings, evaluate if additional resources and
planning exercises will be needed to address the impacts from changes in the frequency and/or
severity of extreme weather events.
Incorporate the use of FlexViewer technology as a preparedness tool for climate change impacts.
The EOC will build on-going development and use of FlexViewer technology to graphically
display information on notifications and incidents in headquarters and all 10 regional EOCs.
This technology will allow for improved and up-to-date Geographic Information System
(GIS) mapping of watersheds and coastal areas impacted by climate change.
Incorporate materials on the impacts of climate change as EOC training materials are updated and
exercises are planned.
Page 15
-------
Tools, Data, Training and Outreach
In order to make informed decisions about program direction, design, and implementation, OSWER must
use the best available data. As a result of climate change, assumptions about ecosystem conditions are
shifting more rapidly, affecting the ability to predict potential weather patterns and map the geographic
conditions at and around its sites.
Several vulnerabilities, including data collection and training, were identified as applicable and important
to all OSWER offices. One of the primary challenges to incorporating climate change into its activities
will be obtaining reliable projections of sea level rise, flooding zones, and other impacts of climate
change. These projections will help guide decisions such as remedy selection. Access to this data is
needed by all programs. In addition, training is a vital component of information dissemination and use;
therefore, OSWER must appropriately consider relevant training. To best address these vulnerabilities it
will be necessary for OSWER to work with regions and other EPA offices, including the Office of
Research and Development, to ensure consistency across the agency.
Actions:
CPA
Provide recommended data sources and parameters to OSWER offices and regions to ensure
consistent mapping data and protocols. Develop these recommendations by working with the
agency's climate change workgroup and EPA's Office of Research and Development.
Participate in agency climate change adaptation training development, as well as develop specific
training as needed for OSWER staff.
Work with EPA partners and external experts to monitor evolving assumptions related to climate
science. Develop a method for disseminating this information to OSWER offices that ensures
consistent assumptions are used across all activities.
Page 16
-------
IV. Disproportionately Affected Populations
Disproportionate Impact
While climate change will affect all parts of society, it will have disproportionate effects on particular
communities, demographic groups and geographic locations.5 Certain parts of the population, such as
children, the elderly, minorities, the poor, persons with underlying medical conditions and disabilities,
those with limited access to information, and tribal and indigenous populations can be especially
vulnerable to the impacts of climate change. These disproportionately affected groups may have less
ability to cope with or adapt to climate change due to economic, social, physical, or health constraints.
Also, certain geographic locations and communities are particularly vulnerable, such as those located in
low-lying coastal areas.
Populations that are already overburdened by environmental contamination, poverty, and environmental
health issues, may face greater adaptation challenges.6 Though Hurricane Sandy was not necessarily due
to climate change, the impacts resulting from associated flooding are similar to what could occur in a
climate related flooding or storm surge event. Many of the elderly and poor in New York and New Jersey
suffered significantly from flooding-associated power and heat loss, scarcity of food and supplies, and
difficulty in accessing medical care.7 These populations may have lacked the resources to evacuate
outside the affected areas and as a result could not as readily avoid the adverse conditions resulting from
the storm. During the recovery and reconstruction phases, vulnerable populations may also have a more
difficult time due to underlying factors such as economic and social resource base and health status that
can limit their access to resources as well as their ability to take action.
In addition, a community's location near a vulnerable ecosystem or a contaminated site may also result in
differential impacts depending on how that ecosystem or site is impacted by climate change. Degraded
ecosystems or those changed from human activities may place communities near them at higher risk for
the effects of climate change. The ecosystems that may have served as a natural buffer against storm
surge or may have provided valuable cultural, recreational, or other resources can no longer serve this
purpose due to their altered state.8 For example, an environmental justice community's resilience and
ability to adapt to climate change may be complicated by their location both near a hazardous waste site
5 USEPA. (2012). Climate Change Adaptation Plan: Public Review Draft.
6 ibid.
7 USEPA. (2012). Region 2 Adaptation Plan.
8 USGCRP. (2009). Global Climate Change Impacts in the United States, Thomas R. Karl, Jerry M. Melillo, and
Thomas C. Peterson (Eds.). Cambridge University Press.
Page 17
-------
and in an area prone to increased climate-related storm surge. It is important to recognize the factors that
may compound a community's vulnerability to climate change in order to implement effective strategies
to increase adaptive capacity.
Climate change may also pose unique challenges to tribes and other indigenous populations. Tribes are
particularly vulnerable to the impacts of climate change, due to the integral nature of the environment
within their traditional lifestyles and culture. Partly due to their dependence upon a specific area for their
livelihood, the degree to which those geographic areas embody climate-sensitive environments, and their
unique cultural, economic, or political characteristics and contexts, tribes and indigenous groups may be
especially sensitive to climate change related shifts in their environment.9 Their ability to cope with
climate-related hazards is further restricted by limited access to preparedness, response, and recovery
resources.10 While tribes and indigenous populations will likely be disproportionately vulnerable to
climate change, they are uniquely positioned to provide valuable community level, culturally relevant
data, information on climate change impacts, and relevant solutions.
For instance, Alaskan Natives are one population that is experiencing disproportionate impacts from
climate change. Temperature increases associated with climate change have led to the melting of
permafrost. In some cases, permafrost acts as a barrier to the transport of contaminants. With increased
temperatures, thawing could allow contaminants to migrate more freely to adjoining areas_and those
effects would only accelerate with continued changes in the climate.11 In several Alaskan coastal
communities, melting ice and erosion have caused landfills to fall into the ocean, affecting environmental
and human health.12
Partnerships
States, tribes, and local communities share responsibility for protecting human health and the
environment, and partnerships with EPA are at the heart of the country's environmental protection
system. These partnerships will be critical for efficient, effective, and equitable implementation of climate
adaptation strategies. Strong partnerships make the most effective use of partners' respective bodies of
knowledge, resources, and talents. Below is a summary of how OSWER currently works with
underserved populations and tribes.
9 USEPA. (2012). Climate Change Adaptation Plan: Public Review Draft.
10 Cutter, S.L. and C. Finch. (2008). "Temporal and spatial changes in social vulnerability to natural hazards."
Proceedings of the National Academy of Science 105(7): 2301-2306.
11 USGCRP. (2009). Global Climate Change Impacts in the United States, Thomas R. Karl, Jerry M. Melillo, and
Thomas C. Peterson (Eds.). Cambridge University Press.
12 The National Climate Assessment and Development Advisory Committee Report (Draft for public comment)
Page 18
-------
Ongoing Partnerships to Address Vulnerable Populations and Places
OSWER has identified three focus areas to address environmental justice (EJ) in its programs. These
focus areas are designed to integrate ongoing EJ activities and produce tangible outcomes in
overburdened and underserved communities impacted by OSWER programs. These focus area activities
listed below are designed to meaningfully advance EJ in OSWER programs, have EJ as the central focus,
and can produce meaningful, measurable outcomes in low income and minority communities.
Focus Area #1: Incorporate EJ considerations into OSWER programs, policies, and activities by
addressing disproportionately high, adverse human health and environmental impacts on
overburdened and underserved populations to the greatest extent practicable and permitted by law
Focus Area #2: Institute a continual learning process through training and the use of agency
environmental justice tools to help OSWER staff better serve overburdened and underserved
communities
Focus Area #3: Expand community engagement approaches and increase partnership building
which allows overburdened and underserved communities to meaningfully participate in decision
making activities and address local environmental concerns.
Ongoing Partnerships with Tribes
EPA values its unique government-to-government relationship with Indian tribes in planning and decision
making. This trust responsibility has been established over time and is further expressed in the 1984 EPA
Policy for the Administration of Environmental Programs on Indian Reservations and the 2077 Policy on
Consultation and Coordination with Indian Tribes. These policies recognize and support the sovereign
decision-making authority of tribal governments. OSWER works as a partner with many Tribal Nations to
implement OSWER programs. OSWER's partnership with tribes is based on its tribal strategy.13 The
long-term goal of the tribal strategy is to support and provide direction for OSWER's Indian program,
enhance outreach efforts with tribes on environmental protection in Indian country, and maintain
consistency with EPA's Indian Policy. OSWER short-term strategies include:
Ensure appropriate government-to-government consultation and communication with tribal
leaders in accordance with EPA's 2077 Policy.
Build tribal capacity. OSWER provides support through training, financial support, and technical
assistance to tribes to build capacity in assuming regulatory and program management
responsibilities. Additionally, OSWER develops guidance and provides for research in
13 USEPA, Office of Solid Waste and Emergency Response. (2008). Tribal Strategy: EPA & Tribal Partnership to
Preserve and Restore Land in Indian Country.
Page 19
-------
cooperation with tribes to clarify key issues and/or obtain relevant information for addressing
issues potentially affecting tribal health and the environment.
Facilitate meaningful communication, coordination, and cooperation within OSWER on tribal
issues and cultural awareness.
EPA engaged tribes through a formal consultation process in the development of the agency's Climate
Adaptation Plan. Tribes identified erosion, temperature change, drought, and various changes in access to
and quality of water as some of the most pressing issues. Tribes recommended a number of tools and
strategies to address these issues, including improving access to data and information; supporting baseline
research to better track the effects of climate change; developing community-level education and
awareness materials; and providing financial and technical support. At the same time, tribes challenged
EPA to coordinate climate change activities among federal agencies so that resources are better leveraged
and administrative burdens are reduced.
Priority Actions
Community Engagement
One of the principles guiding OSWER's efforts to integrate climate adaptation into its programs, policies,
and rules calls for its adaptation plans to prioritize helping people, places, and infrastructure that are most
vulnerable to climate impacts, and to be designed and implemented with meaningful involvement from all
parts of society. Within OSWER, community engagement is a critical component to how the office does
its job of protecting human health and the environment. Effective community engagement is about a
process of interactions that builds relationships over time and recognizes and emphasizes the
community's role in identifying concerns and participating in formulating solutions. It establishes a
framework for collaboration and deliberation. In the broadest sense, community engagement in
environmental decision-making is the inclusion of the community in the process of defining the problem
and developing solutions and alternatives.
For climate change decision-making processes to be effective they must be transparent and accessible and
communities must be well informed and engaged. Communities should therefore have access to clear and
understandable information. The local knowledge and input gained from meaningful engagement with the
full diversity of the community will help to strengthen OSWER's decisions about climate change
adaptation and the actions developed to address vulnerabilities, ensuring that these activities are well
suited to the community's particular needs and circumstances. OSWER will work in partnership with
communities to increase their adaptive capacity and resilience to climate change impacts. These efforts
Page 20
-------
will be informed by experiences with the impacts of previous extreme weather events (e.g., Hurricane
Katrina and Superstorm Sandy) and the subsequent recovery efforts.
Adaptation actions must recognize and be tailored to the specific issues at the regional, state, local, and
community levels.14 OSWER can provide federal leadership, guidance, information, and support which
are vital to planning for and implementing adaptive actions, however, adaptation planning must include
collaboration between multiple stakeholders including state and local governments, tribes, communities,
non-governmental organizations and others.
Vulnerable Population Actions
OSWER will give special attention to populations and places that are most vulnerable to climate related
impacts to its sites. OSWER will also continue to work to better understand the populations that surround
these sites in order to expand its knowledge on potential impacts and better protect vulnerable
communities and places.
Actions:
Work with the agency's climate change workgroup and EPA's Office of Research and
Development to ensure consistent mapping data and protocols to better understand the
intersections of climate impacts and population vulnerability and help to inform future policy and
office activities and ensure they take evolving climate science into account.
Review and update as necessary, existing community engagement tools and training to
incorporate climate change concerns in how we partner with communities, based on new
knowledge relating to climate change.
In addition, the Community Engagement Network being created by OSWER may provide a valuable
internal forum for sharing and gathering information about best practices for engaging communities in
climate change conversations.
Tribal Actions
Supporting the development of adaptive capacity among tribes is a priority for the EPA. Networks and
partnerships already in place will be used to assist tribes with climate change issues, including Regional
Tribal Operations Committees, the Institute for Tribal Environmental Professionals and the Indian
General Assistance Program. Transparency and information sharing will be a focus, in order to leverage
activities already taking place within EPA offices and tribal governments.
14 USGCRP. (2009). Global Climate Change Impacts in the United States, Thomas R. Karl, Jerry M. Melillo, and
Thomas C. Peterson (Eds.). Cambridge University Press.
Page 21
-------
Actions:
Work with the agency's climate change workgroup and EPA's Office of Research and
Development to share mapping data and protocols with its partners, including tribes to help
inform their adaptation activities.
Assist the Institute for Environmental Tribal Professionals (ITEP) in developing adaptation into
their normal climate change training.
Collaborative efforts on climate change will benefit from the expertise provided by tribal partners and the
Traditional Ecological Knowledge (TEK) they possess. TEK is a valuable body of knowledge in
assessing the current and future impacts of climate change and has been used by tribes for millennia as a
valuable tool to adapt to changing surroundings. Consistent with the principles in EPA's Indian Policy,
TEK should be viewed as a complementary resource that can inform planning and decision making.
Supporting Regions
While OSWER headquarters program offices are taking actions to address climate change adaptation,
much of the work with tribes and vulnerable populations will occur within the EPA regions, since climate
change has many impacts that transcend media and regional boundaries. OSWER plans to coordinate with
and support regional and program office actions by working to ensure that they have access to evolving
climate science and standardized data to inform policy and other activities. For instance, data could be
used for mapping impacts relating to vulnerable populations and tribes. Data driven mapping will help
ensure that adaptation actions can be prioritized and tailored to those populations who are most at risk for
disproportionate impact from climate change. Data can also be shared with tribes to help them create
adaptation strategies to address their climate change impacts.
Page 2 2
-------
V. Measures and Evaluation
The actions proposed in this plan expand OSWER's efforts to mainstream and integrate climate change
adaptation into its programs. OSWER will monitor the status of climate science, particularly as it relates
to known or anticipated impacts on OSWER's program areas, as well as the effectiveness of its program
activities under changing conditions, and update or adjust its direction as necessary. OSWER commits to
periodically publicly reporting on progress implementing these actions and what it has accomplished in
website updates or factsheets.
To measure and evaluate progress toward completing actions, the workgroup that developed this
document will continue to meet to discuss progress implementing actions and share information that may
assist other offices in their efforts. Collaborative tools may also be utilized to facilitate the discussion.
VI. Legal and Enforcement Issues
OSWER works closely with the Office of General Counsel (OGC) to ensure that its actions are legally
supported and in compliance with all applicable laws. OSWER will continue to work with OGC as it
plans for and develops programming related to adaptation and the impacts of climate change.
OSWER will partner with the Office of Site Remediation Enforcement (OSRE) to address enforcement
concerns related to climate change issues. OSWER and OSRE will work together to develop tools that
address climate change policy questions as well as site-specific issues.
Page 2 3
-------
Appendix A - Effect of Climate Change Impacts on OSWER Program Vulnerabilities
The If- symbol indicates climate change impacts that are expected to significantly contribute to the identified program vulnerabilities. Note: The likelihood of occurrence for
each climate change impact is taken from EPA's Climate Change Adaptation Plan. Additional sources are found at the end of the table.
Program Vulnerability
Climate Change Impact
Increased
extreme
temps1
Sustained
changes in
average temp1
-------
Program Vulnerability
Climate Change Impact
1! o.
-------
Program Vulnerability
Climate Change Impact
Increased
extreme
temps1
Sustained
changes in
average temp1
-------
Appendix B - Vulnerability Scorecard1
Program Vulnerability
Office
Characterization Criteria
Total
Score
o tS
01 15
8 1
V)
Likelihood of
occurrence
Scale 1-10
10(High) -l(Low)
Opportunities for OSWER to Make a Difference
Total
Score
Role for EPA
technical
expertise?
Scale 1-5
5(Yes)-l(No)
01 <">
.« > "°
1 8 i 2
c £ J- Q)
73 Q. £ 2
£ .1 i 1
< ° 8
Scale 1-5
5(Not) -
l(Fully)
c g 0) «> £?
° ° ~ ° S oO"
5 E o " =c
Scale 1-5
5(Very Likely)-l(Not Likely)
Preserving Land - Proper Management of Hazardous and Non-Hazardous Wastes
Design and placement of RCRA Treatment, Storage and
Disposal facilities, non-hazardous Subtitle D landfills,
Superfund remedies and municipal recycling facilities may
need to change to accommodate climate change impacts.
Hazardous waste permitting requirements may need to be
updated to reflect climate change impacts.
Current waste management capacity may be insufficient to
handle surges in necessary treatment and disposal of
hazardous and municipal wastes, as well as mixed wastes
generated from climate events.
Levels of necessary financial assurance at RCRA and CERCLA
Facilities may need to adjust for increased risks/liabilities at
specific facilities that may be directly affected by climate
change impacts.
FFRRO
ORCR
OSRTI
FFRRO
ORCR
FFRRO
ORCR
OSRTI
FFRRO
ORCR
OSRTI
6
6
6
15
6
20
15
15
10
10
10
5
5
5
10
5
10
5
5
5
5
5
1
1
1
5
1
10
10
10
5
5
5
12
10
18
14
13
8
15
18
12
8
15
4
2
5
5
5
1
4
5
4
3
5
2
3
3
2
3
3
3
3
2
3
3
3
4
5
4
4
3
4
5
3
1
4
3
1
5
3
1
1
4
5
3
1
3
Preserving Land - Reducing Chemical Risks and Releases
Remediation and containment strategies and materials used
in construction may need to be strengthened to reflect
changing climate conditions.
Current equipment, scientific monitoring and sampling
protocols on sites may no longer be effective and therefore
may require adjustments due to climate change impacts.
Current assumptions regarding protectiveness of remediation
and containment methods may not reflect changing climate
impacts.
Spill Prevention Plans may need to be updated due to the
significant increases in the incidence of flooding and storm
events.
FFRRO
ORCR
OSRTI
FFRRO
ORCR
OSRTI
FFRRO
ORCR
OSRTI
OEM
15
10
10
12
2
2
10
15
16
4
8
5
5
5
1
1
5
5
8
2
7
5
5
7
1
1
5
10
8
2
8
14
18
10
9
18
8
6
8
6
1
5
5
1
4
5
1
3
2
2
2
3
3
3
3
3
2
3
1
3
4
5
3
1
5
4
2
1
2
2
2
5
3
1
5
1
1
2
1
Page 2 7
-------
Program Vulnerability
Office
Characterization Criteria
Total
Score
Scale of impact
Likelihood of
occurrence
Scale 1-10
10(High) -l(Low)
Opportunities for OSWER to Make a Difference
Total
Score
i. is oi
O .y .2
IJI
*^ 01
Scale 1-5
5(Yes)-l(No)
Currently
considered?
Scale 1-5
5(Not) -
l(Fully)
Build
momentum or
leverage
current
activities.
Ongoing effort?
Scale 1-5
5(Very Likely)-l(Not Likely)
Restoring Land
Site characterization and design of cleanups may not reflect
changing climate conditions.
Risk factors and rankings for risk-based cleanup strategies
may need to be reassessed based on changing climate
conditions.
Changing climate conditions may impact continued remedy
effectiveness.
Remedies that are "complete" or are long-term actions may
no longer be protective and resilient as climate conditions
change at site.
ncreased contaminant migration may lead to boundary
changes at current sites or creation of new sites.
Changes in climate conditions may alter assumptions about
contaminant form/volatility.
FFRRO
ORCR
OSRTI
OBLR
FFRRO
ORCR
OSRTI
OBLR
OUST
FFRRO
ORCR
OSRTI
OBLR
FFRRO
ORCR
OSRTI
OBLR
FFRRO
ORCR
OSRTI
OBLR
OUST
FFRRO
ORCR
OSRTI
OBLR
11
10
10
10
15
10
10
10
6
17
15
12
15
18
10
18
10
17
20
20
20
15
16
6
6
6
6
5
5
5
10
5
5
5
1
10
10
7
10
10
5
8
5
10
10
10
10
5
8
5
5
5
5
5
5
5
5
5
5
5
5
7
5
5
5
8
5
10
5
7
10
10
10
10
8
1
1
1
7
13
18
13
13
14
18
11
7
14
15
18
11
14
15
18
12
12
13
18
10
7
14
10
14
8
1
3
5
2
4
3
5
2
1
3
4
5
2
3
4
5
2
4
3
5
2
1
4
3
3
1
2
2
3
4
3
3
3
4
3
4
3
3
4
4
3
3
4
3
2
3
4
3
4
5
3
3
3
4
5
4
3
4
5
3
1
5
4
5
3
4
4
5
3
3
4
5
2
1
3
1
3
2
1
4
5
3
3
4
5
2
2
2
4
5
2
3
4
5
3
2
4
5
2
2
3
1
5
2
Page 2 8
-------
Program Vulnerability
Office
Characterization Criteria
Total
Score
Scale of impact
Likelihood of
occurrence
Scale 1-10
10(High) -l(Low)
Opportunities for OSWER to Make a Difference
Total
Score
o»
I. IS 01
O 0 <"
o. 'E t
111
*^ 01
Scale 1-5
5(Yes)-l(No)
Currently
considered?
Scale 1-5
5(Not) -
l(Fully)
Build
momentum or
leverage
current
Ongoing effort?
Scale 1-5
5(Very Likely)-l(Not Likely)
Restoring Land (continued)
Current scientific monitoring and sampling protocols on
sites may no longer be effective.
Safety procedures on sites may not reflect likelihood or
intensity of surrounding conditions.
Availability of utilities and transportation infrastructure
may be limited as a result of increased impacts to those
systems.
Current assumptions regarding protectiveness of
remediation and containment methods may not reflect
changing climate impacts.
Periodic evaluations of implemented remedies may not
incorporate all climate change impacts, including changes
in frequency and intensity that may impact remedy
effectiveness.
Use of natural resources impacted by sites may change as a
result of increased need, resource scarcity, or
compromised resources.
FFRRO
ORCR
OSRTI
OBLR
FFRRO
OSRTI
OBLR
FFRRO
OSRTI
OBLR
FFRRO
ORCR
OSRTI
OBLR
OUST
FFRRO
ORCR
OSRTI
OBLR
FFRRO
OBLR
15
2
2
2
6
6
6
10
15
15
17
15
15
15
15
10
10
10
10
10
6
7
1
1
1
5
5
5
5
10
10
7
5
5
5
5
5
5
5
5
5
5
8
1
1
1
1
1
1
5
5
5
10
10
10
10
10
5
5
5
5
5
1
14
16
16
9
15
17
8
12
13
11
10
15
16
12
7
14
16
18
8
12
9
4
5
3
1
3
4
1
3
2
2
4
4
5
2
1
3
4
5
1
3
2
4
5
3
4
5
3
3
3
3
3
2
3
3
4
3
3
4
3
4
3
4
3
3
5
2
3
5
2
3
5
3
4
4
3
3
1
4
4
5
2
3
2
3
3
5
2
4
5
2
3
3
3
4
5
3
2
4
4
5
1
3
1
Page 29
-------
Program Vulnerability
Office
Characterization Criteria
Total
Score
e
£
i
01
IS
I/)
IS
§ £
£ 3
"3 0
5 8
Scale 1-10
10(High) -l(Low)
Opportunities for OSWER to Make a Difference
Total
Score
5
°E "
1 s
S ~
H
01 01
&
Scale 1-5
5(Yes)-l(No)
o»
> TJ
*= £
c a
£ -S
= g
u 8
Scale 1-5
5(Not) -
l(Fully)
E «
| 01
+
£ sr »
E S V
0 > »
E £ £
2 S £
00 (j
0"
t
£
01
M
c
'5
M
o
Scale 1-5
5(Very Likely)-l(Not Likely)
Emergency Response
Current levels of administrative, enforcement, and
emergency response staff may be insufficient to cover
needs if number of extreme events increase.
Sufficient capability and capacity for conducting necessary
be available.
Current waste management capacity, including interim
capacity, may be insufficient to handle surges in necessary
treatment and disposal of hazardous and municipal wastes,
as well as mixed wastes generated from climate events.
Training needs (both current and future) are likely to
increase in order to meet the increase demand for
response actions.
Existing emergency planning currently required or
employed by OSWER may not sufficiently consider elevated
risks from multiple climate impacts.
OEM
ORCR
FFRRO
ORCR
FFRRO
ORCR
ORCR
OUST
4
20
10
10
15
15
15
10
3
10
5
5
7
5
5
5
i
10
5
5
8
10
10
5
5
9
.
9
"
18
12
10
2
1
.
1
"
5
3
3
1
4
.
4
"
3
4
3
1
2
.
2
"
5
3
2
1
2
.
2
"
5
2
2
1. OSWER did not conduct a detailed quantitative assessment of vulnerabilities to determine scores. Using best professional judgement and information from peer-reviewed
scientific literature, the OSWER workgroup members determined values for each criteria. When applying the criteria, offices did not evaluate vulnerabilities in relation to each
other, but instead considered each vulnerability independently. These tables are not intended to be a ranking, but rather as a useful and informative guide for OSWER offices as
they determine which vulnerabilities to focus activities.
Characterization Criteria:
Scale of impact to human health, the environment or vulnerable communities because of the vulnerability.
Likelihood of occurrence because of the vulnerability.
Opportunities for OSWER to Make a Difference:
Does EPA have a unique or lead role or technical expertise in this area?
To what extent are climate impacts currently not considered in this area?
To what extent could additional EPA involvement build momentum or leverage current activities?
Is there an opportunity to incorporate climate change into an ongoing effort (e.g., rulemaking, changes to grant criteria, updates to guidance and training)?
Page 30
-------
Appendix C - OSWER Actions
Theme
reservina Land
Q.
Proper Management of
Hazardous and
Non-Hazardous Waste
Reducing Chemical
Risks and Releases
Vulnerability
Design and placement of RCRA Treatment,
Storage and Disposal facilities may need to
change to accommodate climate change
impacts.
Current waste management capacity may be
insufficient to handle surges in necessary
treatment and disposal of hazardous and
municipal wastes, as well as mixed waste
events.
(Actions also in Emergency Response)
Spill Prevention Plans may need to be updated
due to the significant increases in the
incidence of flooding and storm events.
Office
ORCR
OEM
Action
Based on outreach to states and tribes, develop recommendations for these
stakeholders to incorporate climate change into RCRA Permitting Programs as
appropriate (e.g., through robust implementation of technical standards for facility
location and design).
Prepare Fact Sheets on the proper management of wastes/debris associated with large
natural disasters (e.g., electronic, household hazardous wastes, white goods, etc.)
Continue collaborative development with the Office of Homeland Security on an
interactive electronic waste management planning tool to aid federal, state and local
emergency planners and managers in development of waste/debris management plans.
Finalize a document describing the "4 Step Process for Waste Managment Planning."
Update the ORCR Homeland Security Website with updated waste management
planning information.
Incorporate sensitivity for climate change vulnerabilities in oil Spill Prevention, Control,
and Countermeasure (SPCC) and Facility Response Plan (FRP) inspector training (e.g.,
reminding inspectors to consider vulnerabilities at the subject facility during
catastrophic weather events).
Incorporate in SPCC and FRP guidance the statement of potential vulnerabilities to oil
facilities from catastrophic weather events due to climate change.
Incorporate sensitivity for climate change vulnerabilities in risk management plan
(RMP) inspector training and guidelines, (e.g., example, reminding inspectors to
consider vulnerabilities at the subject facility during catastrophic weather events).
Timing
L
S
L
M
M
M
M
M
Page 31
-------
Theme
Restoring Land
Vulnerability
Increased contaminant migration may lead to
boundary changes at current sites or creation
of new sites.
Current assumptions regarding protectiveness
of remediation and containment methods may
not reflect changing climate impacts.
Changing climate conditions may impact
continued remedy effectiveness.
Remedies that are "complete" or are long-
term actions may no longer be protective and
resilient as climate conditions change at site.
Current assumptions regarding protectiveness
of remediation and containment methods may
not reflect changing climate impacts.
Increased contaminant migration may lead to
boundary changes at current sites or creation
of new sites.
Risk factors and rankings for risk-based
cleanup strategies may need to be reassessed
based on changing climate conditions.
Site characterization and design of cleanups
may not reflect changing climate conditions.
Office
ORCR
OSRTI/
FFRRO
OUST
OBLR
Action
Develop recommendations for states and tribes to encourage that climate change
considerations be incorporated into all of their RCRA Corrective Action Programs (e.g.,
regarding remedy selection, etc.)
Share vulnerability screening protocol for regional application.
- Develop criteria to identify remedies where performance may be impacted by climate
change.
- Develop a methodology to evaluate and ensure remedy protectiveness.
Prepare remedy-specific climate change adaptation fact sheets for remedies most likely
to be impacted and identify potential vulnerabilities and adaptation recommendations.
Identify existing Superfund program processes (RI/FS, ROD, RD/RA, Five Year reviews,
etc.) for implementation of climate change adaptation protocols to ensure continuing
protectiveness of current and future remedies.
Prepare training materials, coordinate with NARPM co-chairs and Superfund forums to
integrate the training into future NARPM events, and provide web-based content and
training.
Participate with OSWER and other EPA programs to initiate conversations as
appropriate regarding approaches for handling remedy impacts from climate change.
Work with ASTSWMO to gather information on if and how states currently alter
remediation plans in response to changing climate impacts.
Share information among states, tribes and EPA regions regarding new or modified
investigation strategies and remediation techniques.
Work with ASTSWMO to gather information on if and how states currently alter site
assessments in response to flooding or drought conditions.
Share information among states, tribes and EPA Regions regarding new or modified
assessment techniques.
Work with ASTSWMO to gather information on if and how states currently alter risk
factors and rankings in response to flooding or drought conditions.
Share information among states, tribes and EPA regions regarding how climate
conditions may impact risk-based cleanup factors and rankings.
Work with regional staff to update the Analysis of Brownfields Cleanup Alternatives
(ABCA) language in the brownfield grant T&Cs to include language that requires
recipients take potential changing climate conditions into consideration when
evaluating cleanup alternatives.
Develop an outreach strategy to promote the importance of climate change adaptation
and mitigation, explaining how it will affect all communities at varying degrees and why
it's important to consider when developing revitalization plans in their community.
Timing
L
M
M
S
M
M
L
L
L
L
L
L
S
S
Page 3 2
-------
Theme
Emergency Response
Tools, Data, Training
and Outreach
Vulnerability
Existing emergency planning currently required
or employed by OSWER may not sufficiently
consider elevated risks from multiple climate
impacts.
Current waste management capacity may be
insufficient to handle surges in necessary
treatment and disposal of hazardous and
municipal wastes, as well as mixed waste
events.
(Actions also in Proper Management of
Hazardous and Non-Hazardous Waste)
Current levels of administrative, enforcement,
and emergency response staff may be
insufficient to cover needs if number of
extreme events increase.
Existing emergency planning currently required
or employed by OSWER may not sufficiently
consider elevated risks from multiple climate
impacts.
Training needs (both current and future) are
likely to increase in order to meet the increase
demand for response actions.
Identification of reliable data sources to use in
site-specific analyses may need to be
identified.
Revised training protocols and SOPs that take
into account climate change impacts and what
to look for may need to be developed.
Models, decision tools, site environmental data
and information feeds may need to be updated
to reflect changing climate conditions.
Office
OUST
ORCR
OEM
CPA
Action
Work with ASTSWMO to gather information on if and how states currently respond to
climate-related emergencies (e.g., use of GIS mapping in flood-prone areas).
Analyze lessons learned from Hurricanes Katrina (2005) and Sandy (2012) to identify
how EPA can help states respond to UST-related hurricane impacts.
Share information among states, tribes and EPA regions regarding emergency response
and preparedness (e.g., OUST's Flood Guide).
Prepare fact sheets on the proper management of wastes/debris associated with large
natural disasters (e.g., electronic, household hazardous wastes, white goods, etc.)
Continue collaborative development with the Office of Homeland Security, on an
interactive electronic waste management planning tool to aid federal, state and local
emergency planners and managers in development of waste/debris management plans.
Finalize a document describing the "4 Step Process for Waste Managment Planning."
Update the ORCR Homeland Security Website with updated waste management
planning information.
Utilize the National Response Team multi-agency membership (e.g., NOAA, FEMA, U.S.
Coast Guard) to monitor the state of preparedness. Based on these meetings, evaluate
if additional resources and planning exercises will be needed to address the impacts
from changes in the frequency and/or severity of extreme weather events.
Incorporate the use of FlexViewer technology as a preparedness tool for climate change
impacts.
-The EOC will build on-going development and use of FlexViewer technology to
graphically display information on notifications and incidents in headquarters and all 10
regional EOCs. This technology will allow for improved and up-to-date GIS mapping of
watersheds and coastal areas impacted by climate change.
Incorporate materials on the impacts of climate change as EOC training materials are
updated and exercises are planned.
Provide recommended data sources and parameters to OSWER offices and Regions to
ensure consistent mapping data and protocols. Develop these recommendations by
working with the agency's climate change workgroup and EPA's Office of Research and
Development.
Participate in agency climate change adaptation training development, as well as
develop specific training as needed for OSWER staff.
Work with EPA partners and external experts to monitor evolving assumptions related
to climate science. Develop a method for disseminating this information to OSWER
offices that ensures consistent assumptions are used across all activities.
Timing
M
M
M
S
L
M
M
S
S
M
S
S
S
Page 3 3
-------
Theme
Vulnerable Populations
and Tribes
Vulnerability
All vulnerabilities should include consideration
of potential impacts to vulnerable populations
and tribes. To emphasize the importance of
this, consideration of impacts to vulnerable
populations was included in the
characterization criteria.
Office
All
OSWER
Offices
Action
Work with the agency's climate change workgroup and EPA's Office of Research and
Development to ensure consistent mapping data and protocols to better understand
the intersections of climate impacts and population vulnerability and help to inform
future policy and office activities and ensure they take evolving climate science into
account.
Review and update as necessary, existing community engagement tools and training to
incorporate climate change concerns in how we partner with communities, based on
new knowledge relating to climate change.
Work with the agency's climate change workgroup and EPA's Office of Research and
Development to ensure consistent mapping data and protocols that can be share with
its partners, including tribes to help inform their adaptation activities.
Assist the Institute for Environmental Tribal Professionals (ITEP) in developing
adaptation into their normal climate change training.
Timing
s
M
S
M
Key:
Timing:
S: Short-term, initiated within one year
M: Medium-term, initiated within two years
L: Long-term, initiated after 3 years
Offices:
CPACenter for Program Analysis; FFRRO -Federal Facilities Restoration and Reuse Office; OBLR - Office of Brownfields and Land Revitalization;
OEMOffice of Emergency Management; ORCR - Office of Resource Conservation and Recovery; OSRTI - Office of Superfund Remediation and
Technology Innovation; OUST - Office of Underground Storage Tanks
Page 34
-------
Appendix D - Bibliography
Council on Environmental Quality. (2010). Progress Report on the Interagency Climate Change
Adaptation Task Force: Recommended Actions in Support of a National Climate Change Adaptation
Strategy. Washington, DC.
IPCC. (2007). Climate Change 2007: Impacts, Adaptation and Vulnerability. Contribution of Working
Group II to the Fourth Assessment Report of the Intergovernmental Panel on Climate Change. M.L.
Parry, O.F. Canziani, J.P. Palutikof, P.J. van der Linden and C.E.Hanson (Eds.), Cambridge, UK:
Cambridge University Press.
IPCC. (2008). Climate Change and Water. Technical Paper of the Intergovernmental Panel on Climate
Change. B.C. Bates, Z.W. Kundzewicz, S. Wu and J.P. Palutikof (Eds.). Intergovernmental Panel on
Climate Change. IPCC Secretariat, Geneva.
IPCC. (2012). "Summary for Policymakers." In: Managing the Risks of Extreme Events and Disasters to
Advance Climate Change Adaptation. C.B. Field, V. Barros, T.F. Stacker, D. Qin, D.J. Dokken, K.L. Ebi,
M.D. Mastrandrea,K.J. Mach, G.-K. Plattner, S.K. Allen, M. Tignor, and P.M. Midgley (Eds.). A Special
Report of Working Groups I and II of the Intergovernmental Panel on Climate Change. Cambridge
University Press, Cambridge, UK, and New York, NY, USA.
NRC. (2010). America's Climate Choices: Adapting to the Impacts of Climate Change. National
Research Council, (http://americasclimatechoices.org/)
USEPA, Office of Solid Waste and Emergency Response. (2008). Tribal Strategy: EPA & Tribal
Partnership to Preserve and Restore Land in Indian Country.
(http://www.epa.gov/oswer/tribal/pdfs/oswer_tribal_strategy.pdf)
USEPA. (2012). Climate Change Adaptation Plan: Public Review Draft.
USEPA. National Water Program Strategy: Response to Climate Change. EPA 800-R-08-001,
September 2008. (http://water.epa.gov/scitech/climatechange/strategy.cfm.)
USEPA. (2012). National Water Program 2012 Strategy: Response to Climate Change. EPA-850-K-12-
004.
(http://water.epa.gov/scitech/climatechange/upload/epa_2012_climate_water_strategy_full_report_fmal.p
df)
USEPA. (2011). Policy Statement on Climate-Change Adaptation.
(http://www.epa.gov/climatechange/Downloads/impacts-adaptation/adaptation-statement.pdf)
USEPA. (2010). Community Engagement Initiative Action Plan.
(http://www.epa.gov/oswer/docs/cei_action_plan_12-09.pdf)
USGCRP. (2009). Global Climate Change Impacts in the United States. Thomas R. Karl, Jerry M.
Melillo, and Thomas C. Peterson (Eds.). Cambridge University Press.
(http://library.globalchange.gov/products/assessments/2009-national-climate-assessment/2009-global-
climate-change-impacts-in-the-united-states)
Page 3 5
------- |