JV United States

Environmental Protection
M m Agency

EPA 542-R-23-002
November 2023

Engineering Forum issue Paper

The groundwater treatment plant and storage tanks at the American Cyanamid Superfund site, constructed on elevated land outside the
500-year flood plain, avoided floodwaters in 2021. Photo Credit: Mark Schmidt.

Conducting C imate Vulnerability Assessments

at Superfund Sites

Contents

1.

Purpose

2.

Background

3.

Performing a Climate Screening

4.

Climate Vulnerability Assessment

5.

Summary

6.

Acknowledgements

7.

Notice and Disclaimer

8.

Selected Resources

9.

Cited References

Appendix A. Determining if a Climate Vulnerability
Assessment Is Needed at Your Site

Appendix B. Previous Efforts Related to Climate
Change and Adaptation

The Technical Support Project Engineering Forum issue papers
provide information on remediation technologies or technical
issues of interest. The information is not guidance or policy.

"The degree to which a system is susceptible to, or
unable to cope with, adverse effects of climate change,
including climate variability and extremes; it is a function
of the character, magnitude, and rate of climate
variation to which a system is exposed; its sensitivity;
and its adaptive capacity."

— U.S. Environmental Protection Agency, 2021
https://semspub.epa.gov/work/HQ/100002993.pdf

The U.S. Environmental Protection Agency (EPA) Office of
Superfund Remediation and Technology Innovation
(OSRTI), in collaboration with the Technical Support Project
(TSP) Engineering Forum, developed this issue paper to
document the lessons learned in conducting climate
vulnerability assessments (CVAs) at sites on the National
Priorities List (NPL). While developed for Superfund, this
process is program neutral and may be used as a guide for
performing CVAs at contaminated sites managed under
other cleanup programs. Vulnerability assessments may be
performed at all site types, by all site leads and at all stages
of a cleanup. This issue paper may be used by all
stakeholders wanting to replicate the CVA process applied
in the Superfund Remedial Program.

1. Purpose


-------
2.	Background

In June 2021, OSRTI issued a memorandum, Consideration of Climate Resilience in the Superfund Cleanup Process
for non-Federal NPL Sites (EPA, 2021a). Consistent with the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA), the National Oil and Hazardous Substances Pollution Contingency Plan
(NCP) and associated EPA Superfund guidance, the memo recommends the following approach for EPA regions to
consider when evaluating climate resilience during the remedy selection and implementation process:

1.	Assess the vulnerability of a remedial action's components and evaluate the impact of climate change on
the long-term protectiveness of a selected remedy;

2.	Identify and evaluate adaptation measures that increase the system's resilience; and

3.	Implement adaptation measures necessary to ensure the long-term protectiveness of CERCLA remedial
actions.

As described in the memo, and in response to requests from remedial project managers (RPMs) for assistance in
determining site vulnerabilities to climate change, OSRTI offers climate vulnerability assessments as part of the
Optimization Program. A climate vulnerability assessment includes conducting a detailed review of the site and
remedy components, performing site-specific projections of climate conditions, and assessing how these changes
may affect remedy protectiveness. The focus of the assessment is guided by current or planned site
infrastructure, the extent to which site and remedy analyses incorporated forward-looking climate data, the type
of contamination and structure of waste at the site, and the Superfund remedy phase.

3.	Performing a Climate Screening

Before conducting a climate vulnerability assessment, a climate screening1 may be performed to identify potential
exposure to climate change. A screening is designed to identify potential future climate exposures at Superfund
sites to help inform decision-making. If a significant change in climate is identified and the site includes remedies
sensitive to the changes, a climate vulnerability assessment may be warranted.

A climate screening is a high-level assessment of climate exposure to changes in climate hazards such as:

•	Extreme temperature

•	Heavy precipitation

•	Drought

•	Inland flooding

•	Sea level rise

•	Storm surge

•	Wildfire

•	Landslides

Historic indicators of climate conditions provide a good understanding of what climate hazards are present at a
site. However, the rapid rate of climate change requires that we project future conditions to better inform key
remedy decisions such as selection, design, and operations, and to anticipate the impact on contaminant

1A climate screening is typically limited to analyzing climate projections at a site using publicly available screening tools and
considering at a high level potential remedy sensitivities. A climate vulnerability assessment includes a deeper analysis into
remedy vulnerabilities and existing adaptation measures, including conversations between independent experts and the site
team.

2


-------
movement. Publicly available climate screening tools are available to identify changes in climate exposure for
sites. A selection of commonly used climate exposure screening tools is listed in Section 8. Selected Resources.
Two future timeframes are often available for review: mid-century and late century. The timeframe used for a
climate screening is an important consideration—the timeframe should be associated with the anticipated
lifespan of the remedial infrastructure or actions. For example, sites with technologies such as groundwater pump
and treat may focus on mid-century projections, while those with engineered caps where waste is left in place
may focus on late-century projections.

In combination with the identified climate exposure, site managers should consider other site-specific
information, such as whether they are already taking action to reduce vulnerabilities at their site (e.g., a resilient
remedy is already in place that reduces the impacts of a given climate hazard). Questions an RPM may consider
when reviewing results of a screening are provided in Appendix A. Determining if a Climate Vulnerability
Assessment Is Needed at Your Site. At many sites, a climate screening will provide all the necessary information for
an RPM to determine if there are climate change concerns regarding remedy protectiveness. At sites where
further information and analysis is required, RPMs may request a site-specific CVA. The following section is based
on the lessons learned by the Superfund Remedial Program in piloting CVAs.

4. Assessing Vulnerability to Climate Change

Vulnerability is a function of exposure, sensitivity, and
adaptive capacity (see Text Box 1 for definitions). In the
context of climate change, a vulnerability assessment can
help to identify and prioritize climate risks to contaminated
sites.

Figure 1 shows how the climate vulnerability assessment
process for Superfund sites or other contaminated sites
incorporates these components. As illustrated, the process
focuses on assessing change in climate exposure and remedy
sensitivity to identify key climate vulnerabilities to climate
changes at the site. The remedy sensitivity analysis
documents the degree to which forward-looking climate data
has already been considered and any measures for improving
adaptive capacity that are already in place. Vulnerabilities
are flagged and documented if there is an exposure and a
potential sensitivity to the specific remedy (e.g., projected
extreme heat and drought conditions may cause water stress
for a vegetative cover, reducing the protectiveness of the
remedy).

The end goals of the vulnerability assessment are to:

•	Assess future changes in climate conditions at a site
so they may be factored into site decision-making;

•	Determine whether the adoption of adaptation measures is necessary to improve remedy resilience (e.g.,
planting a drought-tolerant species for the vegetative cover); and

•	Ensure remedy protectiveness is maintained under future changes in climate.

Text Box 1. Key Definitions
Vulnerability

The degree to which a system or site is susceptible
to, or unable to cope with, adverse effects of
climate change, including climate variability and
extremes

Exposure

Whether a site could experience a climate hazard
Sensitivity

The degree to which a climate hazard impacts
remedy protectiveness

Adaptive Capacity

The ability of a system to adjust to climate change
(including climate variability and extremes),
moderate potential damages, take advantage of
opportunities, or cope with the consequences

Resilience

The capacity of a system to maintain function in
the face of stresses imposed by climate change
and to adapt the system to be better prepared for
future climate impacts

3


-------
The purpose of this effort is to detail OSRTI's application of the vulnerability assessment process to Superfund
sites at various stages of the remediation process. This tailored process draws on best practices, lessons learned
(see Text Box 2), and the current state of the science.2 Assessments may be performed at all site types and by all
site leads (i.e., federal, state, or potentially responsible party). While developed for and applied to Superfund
sites, the process is program neutral and could be modified for other types of contaminated sites.

CLIMATE VULNERABILITY ASSESSMENT COMPONENTS

Exposure

Sensitivity

Adaptive
Capacity

CLIMATE VULNERABILITY ASSESSMENT PROCESS FOR SUPERFUND SITES

Engagement
and Scoping

Climate
Exposure

Remedy
Sensitivity &
Vulnerability

Identify
Adaptive
Measures

Draft
Findings

Final Report

Figure 1. Comparison of the climate vulnerability assessment process components and the climate
vulnerability assessment process implemented for Superfund sites.

Remedies at Superfund sites are already designed to maintain protectiveness under current climate conditions.
Following the 2017 hurricane season in which three major hurricanes (Harvey, Irma, and Maria) made U.S.
landfall, EPA evaluated information on the performance of remedies in areas recently impacted by the three
hurricanes. The study, completed with input from the TSP Engineering Forum, concluded that damage was limited
and adaptation measures to ensure remedy resilience are being implemented at Superfund NPL and Superfund
Alternative Approach (SAA) sites where remedies are in place (EPA, 2018). Additional information on this study is
summarized in Appendix B. Previous Efforts Related to Climate Change and Adaptation. Through the information
developed from CVAs, the Superfund Remedial Program seeks to ensure continued protectiveness of remedies
under future climate conditions.

The climate vulnerability assessment specifically evaluates the resilience of the remedy to the projected changes
in future climate conditions. The CVA therefore identifies changing climate conditions, how these conditions may

2 Many federal, state, and local agencies have also adapted the climate vulnerability assessment process to meet their
specific interests and needs, including the Federal Flighwav Administration, the National Park Service, the U.S. Department of
Agriculture, the U.S. General Services Administration, the U.S. Department of Flousing and Urban Development, and the U.S.
Forest Service. These agencies have served as benchmarks in piloting climate vulnerability assessments at Superfund sites
and in drafting this issue paper.

4


-------
affect remedy protectiveness, and what adaptation measures may be considered to ensure continued
protectiveness under future climate conditions.

Text Box 2. Lessons Learned from Developing and Applying This Process

During the initial piloting of climate vulnerability assessments through Fiscal Year 2023, OSRTI supported
climate vulnerability assessments at 26 sites, covering a variety of site types and EPA regions, under both the
Superfund and Resource Conservation and Recovery Act cleanup programs. Lessons learned from the initial
pilot assessments have informed the development of this formalized climate vulnerability assessment
process, including:

•	Determine a consistent list of relevant climate variables to include in each assessment

•	Use the Representation Concentration Pathways (RCP) 8.5, 90th percentile values for the vulnerability
assessment to screen for all potential risks, and provide RCP 4.5, 50th percentile data for select variables
to capture a range of possible futures to consider when determining next steps and making future
design decisions

•	Leverage available local data and resources when possible, supplementing with national datasets as
needed (see Step 2. Climate Exposure for more information on regional and national datasets)

•	Increase the understanding of what remedy types are typically sensitive to certain climate hazards

•	Assess the impact of climate change on contaminant movement and the conceptual site model

•	Emphasize the importance of engaging RPMs throughout the process to better understand the
local context

•	Consult with subject matter experts on the planned or constructed remedy at the site to assess potential
remedy sensitivities to the delta, or change, in future climate conditions

•	Determine subject areas that require additional evaluation; these include assessing climate change
effects on groundwater biogeochemistry relevant to groundwater contaminants, and how to
incorporate climate change into Superfund site assessments

•	Document previously performed climate change assessments and adaptation measures already in place

The following sections detail each step of the climate vulnerability assessment process as applied to Superfund
sites. Minor modifications may be needed to apply the process to other types of contaminated sites.

Step 1. Engagement and Scoping

Do I need to complete a climate vulnerability assessment for my site?

The climate vulnerability assessment includes a review of site components and site-level climate impacts. Ideal
candidates for an assessment include:

•	Sites that have performed a climate screening and determined more information and analysis are needed

•	Sites with remedies in a climatologically dynamic environment, such as coastal areas, those near
waterways, or those subject to extreme temperature and drought conditions

•	Sites that have or are currently experiencing damage or disruption from climate or severe weather-
related hazards

•	Sites that may not have incorporated future climate data into the remedial design

•	Sites requiring documentation of remedy resilience to address community or other site stakeholder
concerns

•	Sites from which a potential release of contaminants caused by climate change would have a
disproportionate impact

5


-------
Additional questions and considerations an RPM may use in determining whether a climate vulnerability
assessment is appropriate for their site can be found in Appendix A.

What should be the focus of a climate vulnerability assessment at my site ?

The focus of the assessment is guided by current or planned remedy infrastructure, the extent to which site and
remedy analyses incorporated forward-looking climate data, the type of contamination and structure of waste at
the site, the Superfund remedy phase, and the magnitude of the projected changes in climate. Example support
provided by the remedy phase includes:

•	Up through remedial investigation (Rl): integration of current and projected climate impacts into risk
assessments and the conceptual site model (CSM); considerations for potential remedy alternatives

•	Feasibility study: analysis of adaptation measures for each remedial alternative based on projected
climate impacts

•	Remedial design: incorporation of engineered adaptation measures to the remedy design

•	Remedial action (RA), long-term response action (LTRA), operation and maintenance (O&M): evaluation of
remedy performance under current and future climate and any necessary modifications

Who should be engaged throughout the vulnerability assessment?

As the characteristics of every site are unique, this process requires a collaborative effort with EPA, subject matter
experts, site managers, and other relevant staff to understand site specifics and ensure the results will be useful
to decision-making. The key engagement points with the site team are during the initial scoping and during the
presentation of preliminary vulnerability assessment findings.

The scoping call provides an opportunity for the site manager, regional technical staff, and climate, remediation,
and GIS technical experts to discuss and identify site needs related to climate impacts. The site manager typically
provides a site overview and identifies the primary climate concerns for current or planned remedies or
community concerns. A discussion regarding specific aspects of the site that may be vulnerable to changes in
climate leads to the identification of specific site documents requested of the RPM that the experts will review as
part of the remedy sensitivity analysis.

Step 2. Climate Exposure

The climate exposure analysis identifies the projected changes in climate conditions that the site is likely to
experience for the appropriate future timeframe. Understanding the magnitude of expected changes from the
baseline to a future time period is an essential input for reflecting on remedy sensitivity and vulnerability. The
climate exposure analysis uses the best available site-level climate projections and local data sources. The
parameters of the climate exposure analysis are detailed below, including timeframe, climate projection
scenarios, data sources, and climate hazard variables.

Timeframe for the Exposure Analysis

Climate projections are typically provided for a mid-century and late-century 30-year timeframe and compared
to a historical baseline. Climate projections are traditionally presented as a 30-year range to minimize year-to-
year natural fluctuations and capture long-term trends. Projections beyond late-century are increasingly
uncertain, typically providing diminishing value in informing site decisions.

Choosing an appropriate timeframe for climate projections depends on many factors such as specific conditions
and remedies at the site and decision-making needs. Consider the following factors to determine an appropriate
timeframe to use:

6


-------
•	Remedy lifespan - Certain remedies or infrastructure types are expected to last a certain number of years
before needing to be replaced and redesigned. The useful life of a given asset can help determine an
appropriate timeframe. For example, if the useful life is 30 years, mid-century projections would be
appropriate to use for informing decision-making.

•	Criticality-Assets that provide critical services or protection from severe consequences should be built to
last as long as necessary. Thus, both mid-century and late-century projections would be appropriate to
consider.

Climate Projection Scenarios Used for the Exposure Analysis

Climate projections are inherently uncertain and as a result
a range of emission scenarios are available to use. These
scenarios represent different potential futures, depending
on factors like the adoption of major policies to reduce
global greenhouse gas emissions.

The Superfund climate risk assessments use projections for
the 90th percentile of the high emissions scenario to better
understand the "worst case" scenario. If a CVA analysis
indicates a remedy (as designed or built) continues to be
protective under the worst-case future climate scenario, the
site team will have greater certainty regarding its continued
protectiveness.

While the worst-case scenario is useful for screening
purposes, additional climate data may be needed when
making design and adaptation measure decisions as it may
not always be feasible or effective to build to those
projections. To help inform future decision-making,
projections for the 50th percentile of the intermediate-low
scenario, which assumes significant reductions in
greenhouse gas emissions by mid-century, are included in
the appendix of each climate vulnerability assessment
report for select variables.3 Using a range of projections and
considering risk tolerance allows for the fine-tuning of
adaptation measures. Risk tolerance is the willingness to
accept potential climate impacts to a project or remedy. For
example, designing to a higher emissions scenario may lead to a more costly project. Risk tolerance is influenced
by factors such as asset criticality. If damage or failure to a remedy would have major health or environmental
consequences, risk tolerance is low, and it may be worth building to the more conservative projections. If there
are backup measures in place that would limit the severity of consequences, risk tolerance is higher, and it may be

3 Additional information on Representation Concentration Pathways can be found on EPA's EnviroAtlas website:
https://www.epa.gov/enviroatlas/changes-over-time.

Text Box 3. Climate Scenarios

Climate projection scenarios are updated
periodically based on the latest science. The
Superfund climate risk assessments originally
used Coupled Model Intercomparison Project
Phase 5 (CMIP5) scenarios until the release of
CMIP6.

CVAs incorporate climate projections under a
worst-case scenario to conservatively screen for
all potential climate risks at a site, accomplished
by using the 90th percentile of a high emissions
climate scenario.

For CMIP5, RCP 8.5 assumes greenhouse gas
concentrations continue to rise through 2100 and
represented the worst-case emissions scenario.

CMIP6 defines emission scenarios differently
through Shared Socioeconomic Pathways (SSPs).
These scenarios are future narratives that reflect
different socio-economic development strategies,
climate policies that may be undertaken by
society, and radiative forcing levels. SSP5-8.5 is
considered the worst-case scenario in the new
CMIP6 climate models and represents an
"unabated" future in which society is still heavily
reliant on fossil fuel and C02 emissions continue
to increase until late into the 21st century.

7


-------
worth the cost savings to build to the lower scenario. Discussion of risk tolerance helps to improve the
transparency and credibility of any subsequent decisions.

Data Sources Used for the Exposure Analysis

While there are a variety of climate data sources available, the Superfund Remedial Program used best-available
data from an ensemble of statistically downscaled global climate models (see Table 2 for specific sources) when
conducting pilot CVAs. This approach better accounts for uncertainty by including a range of global climate
models and it produces climate projections at a finer spatial resolution, which is important for a site-specific
assessment.

Superfund climate vulnerability assessments use the latest versions of LOCA (Localized Constructed Analogs) data
and CMIP (Coupled Model Intercomparison Project) for generating temperature and precipitation projections.4
LOCA consists of an ensemble of 32 statistically downscaled CMIP Global Climate Models (GCMs) at 6 x 6 km
spatial resolution and daily temporal resolution. The Fourth National Climate Assessment and other peer-
reviewed publications leverage LOCA downscaled climate projections over other datasets because of the robust
downscaling methodology, spatial and temporal completeness across the continental U.S., and larger model
ensemble. A larger model ensemble of climate projections creates a more comprehensive set of plausible future
climate change outcomes and associated impacts.5 From this ensemble, the high end of projections represents a
more extreme climate future and allows sites to take a risk-averse position when incorporating climate data.

For climate hazards and variables beyond temperature and precipitation derived from LOCA, the next best
available national or local-/state-level data sources are used (see Table 2 for specific sources). For example,
California has the Cal-Adapt platform, which provides publicly available climate change data and climate
projections for the state, including LOCA-derived average annual temperature and precipitation, but also
additional variables such as area burned by wildfire, snowpack, extreme precipitation events, and sea level rise
inundation. Furthermore, EPA Shared Enterprise Geodata & Services (SEGS) hosts a curated collection of climate
change data (EPA SEGS, 2023). Specific geospatial resources include current climate observations, future climate
scenario projections, including LOCA data for a select group of climate hazards, and associated guidance on using
climate change data.

Climate Hazards and Variables

To determine a list of climate hazards and variables to include in a climate vulnerability assessment, consider the
following questions:

•	What climate hazards have affected the site in the past?

•	What climate hazards may be of concern under future climate conditions?

•	Are there any data limitations on including a particular climate hazard or variable?

4	LOCA version 2 was released in 2023 to downscale CMIP6 data. More information on the change from LOCA version 1 to
version 2 can be found on the LOCA Statistical Downscaling website: https://loca.ucsd.edu/loca-version-l-vs-loca-version-2/.

5	Taking the average of many (>20) GCMs reduces uncertainty inherent in model projections by creating a probable range of
future climate rather than any one model value. Raw model outputs from GCMs have coarse resolutions and contain biases
(e.g., some models trend hotter or wetter than others, some models perform better in certain regions than in others), so
using LOCA downscaled data provides these assessments with finer resolution (~6 x 6 km, or 3.7 x 3.7 mi grid cells) and more
meteorologically accurate data.

8


-------
Table 1 summarizes the climate hazards included in the Superfund assessments as appropriate. This list builds on
conversations between site managers and technical experts to determine which climate hazards pose potential
threats to remedy protectiveness.

Table 1. Climate hazards included in each assessment depend on the site location.

Temperature

Precipitation
and Drought

Inland
Flooding

Wildfire

Storm Surge

Sea Level Rise

Landslides

All sites

-

All sites

t I::'1 '¦
—I;;'.,-1'1 -¦

All sites

All sites,
focus on
Western
sites

Coastal sites

*

Coastal sites

—h. . -¦1 ¦ .^^1'

All sites,
focus on
mountainous
terrain

Indicates geographic areas where hazards are likely to occur.

These conversations and additional research informed the selection of specific climate variables typically included
in the climate exposure analysis (see Table 2). This list is based on an understanding of climate hazards that have
affected sites in the past, climate hazards that may affect remedy protectiveness in the future, and data
availability; it does not include all climate hazards. Some climate hazards do not have national data sources
depicting future change. For climate hazards in areas where only historic data are available, this information may
be used in conjunction with future climate projections to better understand a potential change. For example, in
areas without future floodplain projections, FEMA historic floodplain maps may be used with return period storm
projections to develop an understanding of how a 100-year floodplain might change under future conditions. As
appropriate or requested, assessments may include additional variables such as runoff, snow-water equivalent
(i.e., the amount of water contained within snowpack when it melts), permafrost, groundwater table depth,
evapotranspiration, historic wildfire burn area, and post wildfire debris flow.

Table 2. Climate variables and data sources typically used in the climate exposure analysis for Superfund sites.

Hazard

Variable

Description

Example Data Sources

Temperature

Number of days above
95°F

Days each year when maximum
temperatures reach 95°F

LOCA downscaled
temperature projection
data

l-in-10-year
temperature

The maximum temperature with a
10% annual chance of occurrence

LOCA downscaled
temperature projection
data

Precipitation

Average total monthly
precipitation

Average amount of precipitation
falling each month

LOCA downscaled
precipitation projection
data

Largest annual 5-day
precipitation event

The largest amount of precipitation
to fall during 5 consecutive days in a
year

LOCA downscaled
precipitation projection
data

Return period storms

Amount of precipitation falling
during the l-in-100 year and 1-in-
500-year storm

LOCA downscaled
precipitation projection
data

NOAA Atlas 14
Precipitation Frequency
Data

9


-------
Hazard

Variable

Description

Example Data Sources

Drought

Consecutive dry days

Longest consecutive period of days
without precipitation

LOCA downscaled
precipitation projection
data

Flooding

Historic 100-year and
500-year floodplain6

The area that will be inundated by a
flood having a 1% (100-year
floodplain) or 0.2% (500-year
floodplain) chance of occurrence
each year

FEMA National Flood
Hazard Laver

Sea level rise

Sea level rise extent

Area inundated by sea level rise
under intermediate-low and high sea
level rise scenarios

NASA Interagency Sea
Level Rise Scenario Tool
NOAA Sea Level Rise
Viewer

Storm surge

Storm surge depth

East Coast: Storm surge heights
above ground level resulting from
hypothetical Category 1 through
Category 5 hurricanes
West Coast: Storm surge heights
above projected future water
surface elevation

East Coast: NOAA Sea, Lake
and Overland Surges from
Hurricanes (SLOSH) model
West Coast: Coastal Storm
Modeling System
(CoSMoS) I U.S. Geological
Survey (usgs.gov)

Hurricane

Historic hurricane tracks

Paths of historical hurricanes and
associated information (e.g., storm
category and effects)

NOAA Historical Hurricane
Tracks

Wildfire

Wildfire danger days

Days with 100-hour fuel moisture
above the 80th (High), 90th (Very
High) and 97th (Extreme) percentile
model values

Climate Mapper MACA v2
METDATA downscaled
projections for 100-hour
fuel moisture

Landslides

Landslide susceptibility

Susceptibility of terrain to landslides
based on elevation, geology, fault,
roads, and forest loss

NASA Landslide
Susceptibility Map

Output of the Exposure Analysis

The results of the climate exposure analysis are presented through graphs (Figure 2), maps (Figure 3), and charts
(Figure 4) to help visualize the projected change in climate conditions from present day to mid-century and end of
century. Maps in particular can help visualize geographic variability across a larger site.

6 The FEMA Federal Flood Risk Management Standard (FFRMS) outlines three approaches for federal agencies to manage
current and future flood risk. One approach is to use the 500-year floodplain instead of the 100-year floodplain in project
siting, design, and construction decisions.

10


-------
Total Precipitation by Month

Figure 2. Example output of average total precipitation each month for mid-century and end-of-
century based on RCP 8.5 90th percentile model projections.

Summer Wildfire Danger Days

60

50

to
>

CD

Historical 2010-2039 2040-2069

High ¦ Very High ^Extreme

Figure 3. Map showing the 100-year and 500-year Figure 4. Example output of summer wildfire
floodplain overlap with a theoretical Superfund site. danger days based on MACA RCP 8.5 projections.

Step 3. Remedy Sensitivity and Vulnerability

The evaluation of a remedy's sensitivity to climate hazards involves assessing the degree to which a specific
climate hazard may impact the remedy's protectiveness. The remedy sensitivity is then further analyzed in
conjunction with the expected climate exposure for the site to determine actual remedy vulnerabilities.

Relevant site documents are reviewed to understand the selected or implemented remedies and contaminated
media present at the site. Specific documents may include:

• Remedial Investigation/Feasibility Study (RI/FS) reports

Legend

i—i

Boundary
500-year
floodplain
100-year
floodplain

A"'"8 0.07 0.15 0.3

Miles

11


-------
•	Decision documents

•	As-built and design documents

•	Five-Year Review reports

•	Remedial Action Completion reports

•	O&M plans

•	Annual monitoring and sampling reports

•	Previous climate analysis

•	Relevant data from local waterboards, Army Corps., etc. as it relates to area levees, dams, or other water
management features

•	Corrective Measures Study

•	Corrective Action Plan

•	Risk Management Plan

•	Analysis of Brownfields cleanup alternatives

Sensitivities associated with site remedies, proposed remedies, or current contaminated media are evaluated
against the climate exposures identified for the site. The qualitative intersection between climate exposure and
remedy sensitivities, as determined by remedy experts applying professional judgement, identifies site specific
vulnerabilities (see Figure 5).



Remedy Vulnerability



Climate Exposure

High







Med







Low









Low

Med

High



Remedy Sensitivity

Figure 5. Qualitative depiction of remedy vulnerability. When significant changes in climate coincide with high
remedy sensitivity, a vulnerable remedy is identified.

Vulnerabilities of remedial structures that may affect the remedy's protectiveness may arise from the projected
increases in extreme events such as wildfires or storms, which are expected to occur at increasing intensities,
durations, and frequencies as long-term climate conditions continue to change. Examples of impacts from
extreme events that can influence a remedy's vulnerability include power interruption, physical damage, water
damage, and reduced access.

Vulnerabilities may also occur due to climate shifts that cause long-term chronic wear and could result in releases
to the environment. Specific examples of a vulnerability and the associated loss of remedy protectiveness due to
changes in climate are provided in Table 3.

12


-------
Table 3. Examples of specific vulnerabilities that can arise due to changes in
	climate and the associated impacts to remedy protectiveness.	

Vulnerability

Potential Impacts to Remedy Protectiveness

Increases in precipitation amount associated with
100-year storm event exceed system capacity

Leachate treatment system designed with the capacity
for a historic 100-year storm event may no longer be
protective during such events

Increases in streamflow that erode unarmored
portions of a cap

Migration of contaminants in the stream from cap
erosion

Changes in the water table that alter the direction of
groundwater flow, impacting plume capture

Migration of groundwater plume to residential
drinking water aquifers, or beneath residential
buildings introducing vapor intrusion concerns

Increased stress on vegetative caps from increased
summer temperatures

Loss of vegetative cover causing exposure of
contaminants after storm events or reduced viability
of evapotranspiration (ET) covers dependent upon
transpiration by vegetation

Desiccation of an unsubmerged sediment cap due to
sustained drought conditions

Failure of desiccated and cracked sediment cap after
storm event

Increased fluctuations in river and pond levels that
cause extended periods of exposed contaminated
sediment

Changes in contaminated media properties that
impact contaminant migration; for example, increases
in mercury methylation

Changes in pond water temperature impacting
benthic community

Increased uptake of contaminants by the local biota,
resulting in exposure to humans and fauna that
consume fish and wild plants

Increases in wildfire hazard and heavy precipitation
events increase landslide susceptibility and potential
for debris flows, threatening critical infrastructure

Groundwater pump and treat system used for
containment is damaged and requires lengthy repairs
or replacement, resulting in loss of plume capture

When assessing a remedy's vulnerability to future changes in climate, identifying changes in the climate hazards
relevant to the operating period of the remedy is essential. The following examples show how projections may
change given the site remedy's operating period:

•	Mid-century projection: Groundwater pump-and-treat systems are often designed to operate for 30
years or longer. Identifying sensitivities to mid-century climate hazard projections would be appropriate
for this system, while the end-of-century projections may not be relevant.

•	End-of-century projection: Reviewing end-of-century projections would be appropriate to evaluate
sensitivities for remedy components such as an engineered cap for which hazardous waste will remain on
site indefinitely.

•	Future projections not needed: Finally, short-term in situ groundwater treatment, such as thermal
treatment that would be implemented and completed within the next decade, may not need to be
included in a climate vulnerability assessment that focuses only on long-term changes to climate hazards.

In addition to the direct impacts changing climate hazards may have to a remedy's protectiveness (examples
provided in Table 3), impacts to ancillary systems on which the site may rely should also be considered. Examples
of ancillary system vulnerabilities that should be considered include:

•	Regional access concerns: Climate hazards, including wildfires and landslides, may impact transportation
infrastructure and inhibit access, particularly for remote sites with limited access roads.

13


-------
•	Regulated waterways: In addition to directly impacting sites near bodies of water, changes in climate,
such as increases in heavy precipitation or periods of drought, may be exacerbated by changes in the
management of the waterway by upstream dams.

•	Nearby stormwater controls: Stormwater runoff associated with increases in extreme precipitation may
be exacerbated by changes in nearby land use, such as development of adjacent vegetated areas that
previously mitigated runoff, resulting in impervious surfaces that hinder natural infiltration and generate
additional stormwater runoff that could impact the site; stormwater controls for a municipality designed
to provide capacity for a historic 100-year flood may no longer provide sufficient protection during future
100-year events.

•	Regional water management: In addition to decreases in infiltration of local aquifers, extended drought
conditions may increase regional water demand, resulting in greater groundwater pumping rates and
therefore decreasing groundwater levels. Lower groundwater levels may impact plume capture success
and require modification of pumping and monitoring wells. Lower groundwater levels may also induce
subsidence, which can affect the protectiveness of a cap or alter surface drainage patterns.

Step 4. Adaptation Measures

The Evaluation of Remedy Resilience at Superfund NPL and SAA Sites report (EPA, 2018) identified that significant
redundancies are often designed into Superfund remedies. For example, the existing stormwater management
system may have been designed with sufficient capacity to exceed historic stormwater runoff rates and provide
sufficient capacity for future projected runoff. While not always identified as "climate adaptation measures,"
these measures do provide adaptive capacity and hence are also reviewed as part of a CVA. Remedies determined
to demonstrate sufficient adaptive capacity to the identified vulnerabilities may require no modification at
present. Assurance of sufficient capacity is an iterative process. Monitoring the performance of the remedy and
reassessing the remedy's vulnerability to future climate change should be performed periodically as required to
ensure remedy protectiveness. When determining the appropriate adaptive capacity to future climate change
events, additional consideration may be given to the potential release of contaminants that would have a
disproportionate impact on nearby communities or ecological receptors. For example, at a site with contained
hazardous material located adjacent to a riverbank, potential adaptation measures may include:

•	Armoring along the base of the cap to add resilience to projected changes to streamflow conditions

•	Updating monitoring plans to require site inspections after storm events to assess the performance of the
armoring

For remedy components that lack sufficient adaptive capacity or are in a pre-design phase, additional
considerations regarding adaptation measures may be provided. Examples of considerations regarding improving
adaptive capacity for identified vulnerabilities include:

•	Designing waste management areas away from future flood zones

•	Completing wells above future expected flood stage and adding well-head housing

•	Procuring a backup power supply and remote access to groundwater treatment systems

•	Adding capacity to storm water management structures

•	Implementing additional monitoring of vegetative cap after extreme events and planning a transition
toward flood, drought, or salt tolerant plants; a mix of native plant species often provide resilience to
climate change

•	Maximizing thickness of the gravel layer in sediment cap to prevent water-related erosion associated with
increased flood events

14


-------
Step 5. Climate Vulnerability Assessment Presentation

The site team first receives a preliminary results presentation of the climate vulnerability assessment, which
typically includes the following information:

•	Charts and quantitative results from the climate exposure analysis

•	Discussion of remedy sensitivities and vulnerabilities

•	Identification of existing adaptation measures that ensure remedy resilience

•	Considerations for adaptation measures to maintain remedy protectiveness under future climate
scenarios

This presentation is an opportunity for the site team to provide feedback on the initial findings before the
assessment is finalized as a written report. The site team and independent experts may discuss inclusion of
additional climate exposure analyses in the written report as well as specific considerations regarding identified
vulnerabilities and potential adaptation measures. As the characteristics of every site are unique, additional site-
specific requests may include providing:

•	Model inputs of climate data to site team for use in water quality or fate and transport models

•	Geospatial shapefiles of climate hazards

•	Additional design considerations for adaptation measures

Step 6. Climate Vulnerability Assessment Report and Application of Results

The site team then receives a climate vulnerability assessment report, which begins with a description of the
scope and methodology of the assessment. Quantitative results from the climate exposure analyses document a
range of projected changes in climate conditions at the site. Remedy sensitivities are described and analyzed in
conjunction with the climate exposure. If there is a specific climate exposure and a potential sensitivity to the
remedy, the vulnerability is identified and considerations regarding potential adaptation measures are provided.
The text box below summarizes the main sections of the report.

j	Text Box 4. Example Climate Vulnerability Assessment Report Structure

| • Executive Summary

i • Introduction: scope and purpose of the assessment

i • Site Background: location and history, primary contaminants, remedial and removal actions, map of site
i	features

i • Climate Exposure: projections and data visualizations for relevant climate hazards
i • Remedy Vulnerability and Resilience: specific sensitivities for planned or in-place site remedies and
i	identification of vulnerabilities for which climate exposure and remedy sensitivities intersect; adaptive

i	capacity of the remedy and considerations for additional adaptation measures

i • References: documents reviewed and cited as part of the assessment
i • Appendix: additional climate projection data

15


-------
The goal of the climate vulnerability assessment report and the data discussed within it is to assist the RPM with
the following activities:

•	Investigation and assessing alternatives: Address concerns regarding the long-term protectiveness of the
remedial alternatives considered during the investigation and feasibility study.

•	Remedy selection: Identify known vulnerabilities for remedies selected in decision documents and
provide considerations on how to address them in design.

•	Remedy design: Ensure specific adaptation measures are incorporated into the design to provide
resilience to future climate impacts.

•	Remedy operation: Evaluate the remedy during periodic reassessment and implement adaptation
measures as needed to ensure long-term protectiveness; evaluate future reuse options for the site.

•	Community engagement: Provide documentation of existing remedy resilience and plan for proactively
addressing vulnerabilities to future climate conditions.

5.	Summary

This issue paper introduces the process for conducting a climate vulnerability assessment at a Superfund
site, including:

1.	Engagement and scoping: Determine whether a climate vulnerability assessment is necessary
at a site either through a screening or discussion with technical experts. If the climate
vulnerability assessment is required, scope the assessment.

2.	Climate exposure: Evaluate current and future climate conditions to understand how site
exposure to various climate hazards may change over time.

3.	Remedy sensitivity and vulnerability: Assess how future climate conditions could affect
remedy protectiveness and mobilization of contaminants.

4.	Adaptation measures: Consider the effectiveness of additional adaptation measures in
reducing risk.

5.	Climate vulnerability assessment findings: Present and discuss findings of the climate
vulnerability assessment with the RPM and other key staff.

6.	Climate vulnerability assessment report: Document findings and outline next steps.

6.	Acknowledgements

This issue paper was prepared by the U.S. EPA Office of Superfund Remediation and Technology
Innovation in collaboration with the Technical Support Project Engineering Forum.

7.	Notice and Disclaimer

The EPA Technical Support Project Engineering Forum authored this issue paper. This document has been
reviewed in accordance with EPA procedures and has been approved for publication as an EPA publication. The
information in this paper is not intended, nor can it be relied upon, to create any rights enforceable by any
party in litigation with the United States or any other party. This document is neither regulation nor should it be
construed to represent EPA policy or guidance. Use or mention of trade names does not constitute an
endorsement or recommendation for use by EPA.

16


-------
The preparation of this report was performed for the EPA Office of Superfund Remediation and Technology
Innovation under EPA contract EP-W-14-001 with ICF.

A PDF version of this issue paper, Conducting Climate Vulnerability Assessments at Superfund Sites, is available to
view or download at the U.S. EPATSP-Engineering Forum website: httos://www.eoa.gov/remedvtech/technical-
support-project-engineering-forum.

8. Selected Resources

Superfund Climate Resilience I US EPA is regularly updated with resources on climate resilience and adaptation.

Climate Exposure Screening Tools

•	EPA, 2023. EPA Climate Data Geoplatform. https://segs-epa.hub.arcgis.com/pages/climate-change

•	USGCRP, 2023. Climate Mapping for Resilience and Adaptation (CMRA) Assessment Tool.
https://resilience.climate.gOv/#assessment-tool

•	NOAA, 2023. U.S. Climate Resilience Toolkit Climate Explorer, https://crt-climate-explorer.nemac.org

•	FEMA, 2023. National Risk Index, https://hazards.fema.gov/nri/

Superfund Climate Vulnerability Assessment (Example Data Sources)

•	Temperature and Precipitation: Statistical Downscaling Using Localized Constructed Analogs (LOCA).
Journal of Hydrometeorology, 15(6), 2558-2585. Pierce, D.W. 2014. https://doi.org/10.1175/JHM-D-14-
0082.1

•	Flooding:

U.S. National Flood Hazard Layer. Federal Emergency Management Agency (FEMA)._
https://www.fema.gov/flood-maps/national-flood-hazard-layer

U.S. Atlas 14 Precipitation Frequency Data. U.S. Federal Government, National Oceanic and Atmospheric
Administration (NOAA), 2023. https://hdsc.nws.noaa.gov/pfds/

•	Sea Level Rise: Interagency Sea Level Rise Scenario Tool and NOAA Sea Level Rise Viewer. National
Aeronautics and Space Administration (NASA), https://coast.noaa.gov/slrdata/

•	Storm Surge:

Sea, Lake and Overland Surges from Hurricanes (SLOSH) model. National Oceanic and Atmospheric
Administration (NOAA). https://www.nhc.noaa.gov/nationalsurge/

Development of the Coastal Storm Modeling System (CoSMoS) for predicting the impact of storms on
high-energy, active-margin coasts. Natural Hazards, Volume 74 (2), p. 1095-1125. Barnard, P.L.
2014. http://doi.org/10.1007/sllQ69-014-1236-v

•	Hurricanes: Historical Hurricane Tracks. National Oceanic and Atmospheric Administration (NOAA).
https://coast.noaa.gov/hurricanes

•	Wildfire: Climate Mapper: Downscaled projections for 100-hour fuel moisture (MACA v2 METDATA).
Climate Toolbox. April 2022. https://climatetoolbox.org/tool/climate-mapper

17


-------
•	Landslide: Landslide Hazard Assessment for Situational Awareness (LHASA) Model. National Aeronautics
and Space Administration (NASA). July 2022. https://gpm.nasa.gov/landslides/proiects.html

Climate Change and Adaptation Reports

•	Consideration of Climate Resilience in the Superfund Cleanup Process for Non-Federal National Priorities
List Sites. U.S. Environmental Protection Agency (EPA). OLEM Dir. No. 9355.1-120. June 2021.
https://semspub.epa.gov/work/HQ/1000Q2993.pdf

•	Climate Adaptation Action Plan. EPA 231-R-210-01. U.S. Environmental Protection Agency (EPA). October
2021. https://www.epa.gov/system/files/documents/2021-09/epa-climate-adaptation-plan-pdf-
version.pdf

9. Cited References

Executive Order 14008 of January 27, 2021. Tackling the Climate Crisis at Home and Abroad.

https://www.federalregister.gov/documents/2021/02/01/2021-Q2177/tackling-the-climate-crisis-at-home-and-

abroad

Executive Order 13653 of November 1, 2013. Preparing the United States for the Impacts of Climate Change.
https://www.federalregister.gov/documents/2013/ll/06/2Q13-26785/preparing-the-united-states-for-the-
impacts-of-climate-change

U.S. Environmental Protection Agency. 2012. Adaptation of Superfund Remediation to Climate Change,
February.

U.S. Environmental Protection Agency. 2014a. Policy Statement on Climate Change Adaptation. June.
https://archive.epa.gov/epa/sites/production/files/2016-08/documents/adaptation-statement-2014.pdf

U.S. Environmental Protection Agency. 2014b. Climate Change Adaptation Plan. EPA 100-K-14-001. June.
https://www.epa.gov/sites/production/files/2015-08/documents/adaptationplans2014 508.pdf

U.S. Environmental Protection Agency. 2014c. Office of Solid Waste and Emergency Response Climate Change
Adaptation Implementation Plan. June. https://www3.epa.gov/climatechange/Downloads/OSWER-climate-
change-adaptation-plan.pdf

U.S. Environmental Protection Agency. 2018. Evaluation of Remedy Resilience at Superfund NPL and SAA Sites.
August. https://semspub.epa.gov/work/HQ/1000Q1861.pdf

U.S. Environmental Protection Agency. 2019a. Climate Resilience Technical Fact Sheet: Contaminated Sediment
Sites. EPA 542-F-19-003. October, https://www.epa.gov/sites/default/files/2019-
12/documents/cr sediment sites fact sheet update.pdf

U.S. Environmental Protection Agency. 2019b. Climate Resilience Technical Fact Sheet: Contaminated Waste
Containment Systems. EPA 542-F-19-004. October, https://www.epa.gov/sites/default/files/2019-
12/documents/cr containment fact sheet 2019 update.pdf

U.S. Environmental Protection Agency. 2019c. Climate Resilience Technical Fact Sheet: Groundwater
Remediation Systems. EPA 542-F-19-005. October, https://www.epa.gov/sites/default/files/2019-
12/documents/cr groundwater systems fact sheet 2019 update.pdf

18


-------
U.S. Environmental Protection Agency. 2021a. Consideration of Climate Resilience in the Superfund Cleanup
Process for Non-Federal National Priorities List Sites. OLEM Dir. No. 9355.1-120. June.
https://semspub.epa.gov/work/HQ/1000Q2993.pdf

U.S. Environmental Protection Agency. 2021b. Climate Adaptation Action Plan. EPA 231-R-210-01. October.
https://www.epa.gov/svstem/files/documents/2021-09/epa-climate-adaptation-plan-pdf-version.pdf

U.S. Environmental Protection Agency. 2023. Shared Enterprise Geodata & Services (SEGS): Climate Change.
Accessed August 4, 2023. https://segs-epa.hub.arcgis.com/pages/climate-change

19


-------
Appendix A. Determining if a Climate Vulnerability Assessment Is Needed at Your Site

If a vulnerability assessment is needed at the site and assistance is required to perform the assessment, remedial
project managers can submit requests for EPA Headquarters support through the Climate Vulnerability
Assessment Engagement Form (access through VPN required). The EPA Headquarters lead will review the request
and schedule a scoping call.

•	Candidates for an assessment include:

o Sites that have performed a climate screening and determined more information and analysis is
needed

o Sites with remedies that have or are currently experiencing damage or disruption from climate or
severe weather-related hazards

o Sites that may not have incorporated future climate data

o Sites requiring documentation of remedy resilience to address community or other site
stakeholder concerns

o Sites from which a potential release of contaminants caused by climate change would have a
disproportionate impact

•	The following list of questions can aid in the decision-making process:

o Has forward-looking climate data been evaluated for the site?

o Have there been previous climate-related impacts at the site?

o What is the capacity to respond if a release were to occur?

o Were selected remedies with vulnerabilities implemented? If still in place, are they expected to
remain in place for more than 10 years?

o Were adaptation measures incorporated into the remedial design, monitoring, and/or operation
and maintenance?

o When is the operation of the remedy anticipated to commence, and what is the timeframe for the
remedy to be in place?

o Are there other remedial actions planned (or operable units without a signed decision document)
that may have vulnerable infrastructure?

o Has the community raised concerns about climate impacts to the site?

20


-------
Appendix B. Previous Efforts Related to Climate Change and Adaptation

In June 2011, EPA issued a Policy Statement on Climate-
Change Adaptation (revised 2014; EPA, 2014a) that
recognized that climate change can pose significant
challenges to EPA's ability to fulfill its mission (see
Figure 6). It called for the agency to anticipate and plan
for future changes in climate and incorporate
considerations of climate change into its activities. In
response, OSRTI conducted a program-wide
vulnerability analysis in 2011—2012 that resulted in the
internal February 2012 report Adaptation of Superfund
Remediation to Climate Change (EPA, 2012). This
analysis considered to what degree Superfund sites
were vulnerable to flooding and sea level rise, and
selected candidate sites to use as case studies for
assessing how project managers evaluated and
responded to the effects of climate change on
Superfund remedial actions.

In 2013, federal agencies were directed by Executive
Order 13653 to consider how climate change may affect
their capacity to implement their core missions. Based
on the findings of the OSRTI February 2012 report, and
as part of the Agency and the Office of Land and
Emergency Management's (OLEM) response to the
executive order, EPA determined that the existing
regulatory framework included the authorities and
guidance needed to address the challenge, and no
changes were needed. Therefore, EPA focused on
developing technical resources, support, and training to
raise awareness among stakeholders, including
remedial project managers. The technical resources
were designed to be "program neutral" and could be
used at any contaminated site cleanup, regardless of
the regulatory framework under which it was
conducted.

OLEM participated in the cross-agency workgroup that
developed EPA's Climate Change Adaptation Plan. The
final Climate Change Adaptation Plan released in 2014
(EPA, 2014b) examined how EPA programs may be
vulnerable to a changing climate and how the Agency
can accordingly adapt so it can continue meeting its
mission of protecting human health and the
environment. In addition to the Agency's Climate Change Adaptation Plan, the 2011 Policy Statement also

Climate Change and Adaptation Milestones

2022 -i

"¦	¦



October 2021

P	

EPA Report:

June 2021

...¦ Climate

OSRTI Memo:

Adaptation

Consideration of

\ Action Plan

Climate Resilience in

\

the Superfund Cleanup

January 2021

Process for non-

Executive Order 14008:

Federal NPL Sites

Tackling the Climate



Crisis at Home and

¦

Abroad

¦	



August 2018



OSRTI Report: Evaluation



of Remedy Resilience at



Superfund NPL and SAA



Sites (Analysis of 2017



Hurricane Season)





June 2014



EPA Report: Climate



Change Adaptation Plan

2013-2014

OSWER Report: Climate

OSRTI Climate Change .

Change Adaptation

Adaptation Technical

Implementation Plan

Factsheets

	II

(revised 2019)
/



u	

	¦



November 2013



Executive Order 13653:

June 2011

Preparing the United

EPA Report: Policy

States for the Impacts

Statement on Climate-

of Climate Change

Change Adaptation

	¦

(revised 2014)

February 2012



OSRTI Report: Adaptation

¦	

of Superfund Remediation

2011 ¦

to Climate Change



Figure 6. Timeline of key Superfund-reiated climate
change and adaption milestones.

21


-------
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 agency-wide plan. In June 2014, the Office
of Solid Waste and Environmental Response (OSWER)7 released its Climate Change Adaptation Implementation
Plan (EPA, 2014c), which described OSWER's process for identifying climate change impacts to its programs and
the plan for integrating consideration of climate change impacts in the office's work. Furthermore, OLEM
continued to monitor the status of climate science—particularly as it relates to known or anticipated impacts on
OLEM's program areas, as well as the effectiveness of its program activities under changing conditions—and
update or adjust its direction as necessary.

As part of OLEM's commitment to developing and maintaining technical guidance, OSRTI released a series of
Climate Change Adaptation Technical factsheets (revised in 2019; EPA, 2019a; EPA, 2019b; and EPA, 2019c), which
incorporated input from the TSP Engineering Forum, focusing on adaptation measures that may be considered to
increase a remedy's resilience to climate change impacts. Following the 2017 hurricane season that included
three major hurricanes (Harvey, Irma, and Maria) making U.S. landfall, EPA sought to gather information on the
performance of remedies in areas recently impacted by the three hurricanes. The report (EPA, 2018) evaluated
the impacts from the hurricanes and summarized EPA's response, and incorporated input from the TSP
Engineering Forum. The study concluded that damage was limited, and resilience measures are being
implemented at Superfund NPL and Superfund Alternative Approach sites where remedies are in place.

In October 2021, EPA released its new Climate Adaptation Action Plan (EPA, 2021b) in response to Executive
Order 14008. The plan accelerates and focuses attention on priority actions the Agency will take to increase
human and ecosystem resilience as climate changes and the disruptive impacts increase.

7 EPA changed the name of the Office of Solid Waste and Emergency Response (OSWER) to the Office of Land and
Emergency Management (OLEM), effective December 15, 2015.

22


-------