Conducting Natural Hazard Vulnerability Screenings and Assessments at RCRA Facilities


United States
Environmental Protection
M % Agency

EPA 530-R-25-001
January 2025

RCRA Technical Issue Paper:

Conducting Natural Hazard Vulnerability

Screenings & Assessments at RCRA Facilities

The BASF Northwarks RCRA facility in Wyandotte, Michigan, adjacent to the Detroit River, has complex hydro logic conditions with
widespread groundwater contamination, making it vulnerable to flooding and other potential climate impacts.

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Table of Contents

1.	Summary	1

Climate Vulnerability Screening	1

Climate Vulnerability Assessment	1

2.	Purpose	2

3.	Background	2

Climate Vulnerability Screening	3

Climate Vulnerability Assessment	3

4.	How to Conduct a Climate Vulnerability Screening	4

Step 1: Identify climate hazards of interest	4

Step 2: Select a future time period	6

Step 3: Identify the "worst-case" scenario	6

Step 4: Collect climate data	7

Step 5: Assess exposure	7

5.	How to Conduct a Climate Vulnerability Assessment	8

Step 1. Engagement and Scoping	9

Who should be engaged throughout the climate vulnerability assessment?	9

What should the climate vulnerability assessment focus on?	10

Step 2. Climate Exposure	10

Step 2A: Identify climate hazards of interest	11

Step 2B: Select a time period	11

Step 2C: Identify climate projection scenarios for the exposure analysis	11

Step 2D: Collect climate data	12

Step 2E: Assess exposure	13

Step 3. RCRA Facility Sensitivity and Vulnerability	15

Step 4. Adaptation Measures	17

Step 5. Climate Vulnerability Assessment Preliminary Results	18

Step 6. Climate Vulnerability Assessment Documentation and Application of Results	18

Example Climate Vulnerability Assessment: Bay Road Holdings RCRA Facility	20

6.	Glossary of Terms as Used in this Document	21

7.	Selected Resources	22

Climate Exposure Tools (from Table 3 and Table 4)	22

Other Climate Vulnerability and Adaptation Resources	22

8.	Acknowledgement	23

9.	Notice and Disclaimer	23

10.	Cited References	23

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1. Summary

Natural hazards and climate change can cause damage to Resource Conservation and Recovery Act (RCRA)
facilities and disruptions to operations and cleanups, potentially leading to hazardous waste releases. The
subsequent impacts to human health and the environment drive the need to integrate natural hazard
and climate adaptation considerations into the RCRA permitting and hazardous waste cleanup processes.

This technical issue paper introduces a process for conducting a climate vulnerability screening
(screening) and, if necessary, a climate vulnerability assessment (CVA) at a RCRA facility to identify and
assess natural hazard and climate vulnerabilities. In most cases, the facility (or the regulator) will first
conduct a high-level screening to determine if there are any potential climate hazards of concern at the
facility. If a screening provides insufficient information, or indicates that climate hazards may plausibly
impact the protectiveness of facility operations or a cleanup remedy, as appropriate1 the regulator may
request or require a CVA. A CVA includes more detailed analyses to understand the types of impacts and
vulnerabilities for a facility's hazardous waste management and cleanup activities and discusses potential
adaptation measures. The issue paper walks through the following components for these two types of
assessments.

Climate Vulnerability Screening

Purpose: Identify natural hazards and climate hazards of concern

1. Climate exposure: Evaluate current and future climate conditions to understand how the RCRA
facility's exposure to various natural hazards and climate hazards may change overtime, and
identify any such potential hazards which could warrant further assessment.

Climate Vulnerability Assessment

Purpose: Evaluate vulnerabilities and existing adaptation measures, and identify additional adaptation
measures if needed to improve resilience.

1. Engagement and scoping: Determine who should participate in the CVA process, as well as the
scope of the process.

2. Climate exposure: Evaluate current and future climate conditions to understand how the RCRA
facility's exposure to various climate hazards may change over time.

3. Sensitivity and vulnerability: Assess how future climate conditions could affect the
protectiveness of the facility's hazardous waste management and cleanup activities and
consider potential releases of hazardous waste or hazardous constituents.

4. Adaptation measures: Consider the effectiveness of additional adaptation measures to reduce
risk of damage and disruption of the RCRA facility's hazardous waste management and cleanup
activities and prevent release due to climate change.

5. Climate vulnerability assessment preliminary results: Present and discuss findings of the CVA

with the larger collaborative group.

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

1 See U.S. EPA Office of Resource Conservation and Recovery: Inteeratine Climate Change Adaptation Considerations into the Resource Conservation and
Recovery Act Corrective Action Process (February 2024) and Implementing Climate Resilience in Hazardous Waste Permitting Under the Resource
Conservation and Recovery Act (RCRA) (June 2024).

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2. Purpose

EPA Office of Resource Conservation and Recovery (ORCR) developed this issue paper to lay out a suggested
screening and CVA process for use at RCRA treatment, storage, and disposal facilities (referred to as TSDFs or RCRA
facilities).

Building on a pilot study conducted by the Office of Superfund Remediation and Technology Innovation (OSRTI),
where CVAs were conducted at sites on the National Priorities List and at facilities subject to the RCRA program, this
document adapts the resulting OSRTI issue paper Conducting Climate Vulnerability Assessments at Superfund Sites
(2023) for the RCRA program. While this issue paper focuses on RCRA facilities, the screening and CVA processes
described should be equally useful for addressing climate risk at RCRA hazardous waste generators or facilities that
treat, store, or dispose of polychlorinated biphenyls (PCBs). Anyone interested or involved in climate change
screening or assessment is encouraged to use this issue paper as a resource.

3. Background

s \

Climate change can increase the frequency and intensity of extreme weather events, such as heavy precipitation
and storms; or can cause more gradual changes such as sea level rise. Additional examples include seasonal
changes in precipitation or temperatures, increasing risk of floods, increasing intensity and frequency of
hurricanes and wildfires, and thawing of permafrost in northern regions. These hazards can cause physical
damage and operational impacts to hazardous waste management and cleanup activities, potentially leading to
the release of hazardous waste or constituents from RCRA facilities. The subsequent impact of a release to human
health and the environment drives the need to integrate climate adaptation considerations into RCRA permitting
and hazardous waste cleanups.

To integrate climate change adaptation into the RCRA program, ORCR
issued two memoranda, Integrating Climate Change Adaptation

Considerotions into the Resource Conservotion ond Recovery Act -i;

Corrective Action Process (February 2024) and Implementing Climgte T "Z

Resilience in Hgzgrdous Woste Permitting Under the Resource =gr:

Conservotion ond Recovery Act (RCRA) (June 2024). that lav out

approaches for EPA regions and states to consider when addressing SSaS

climate change considerations in the RCRA permitting and cleanup ZZZZ T

processes.2 In these two memoranda (Figure 1), ORCR calls for a high- l=ErE£EEEEErEeEE5r:r

level screening process and, if necessary, a more detailed CVA process to ,—,

assess climate hazards at RCRA facilities. These memoranda also address ¦

RCRA authorities that support consideration of potential adverse climate
change impacts on RCRA facilities, and approaches that can be used, as
needed, to ensure that such activities will be protective of human health

and the environment in the face of such impacts. Figure l. orcr climate memos.

This issue paper was developed to cover the technical aspects of when and how to conduct a screening and CVA
to identify potential impacts from natural hazards and climate hazards, and evaluate climate resilience at RCRA
facilities.

2 While this issue paper focuses on RCRA facilities, ORCR has also produced a similar memorandum for PCB facilities titled Implementing Climate Resilience in
PCB Cleanup. Storage. Treatment and/or Disposal Approvals (June 2024).

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Text Box 1. Key Definitions
Climate 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; 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.

Climate 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.

Evaluating climate vulnerability involves three components:

• Exposure: Whether and to what degree a facility could experience a climate hazard or extreme weather
event.

• Sensitivity: Whether and to what degree a facility would experience impacts from an exposure.

• Adaptive Capacity: The ability of a human or natural system to adjust to climate change (including climate
variability and extremes) by moderating potential damages, taking advantage of opportunities, or coping
with the consequences.

Climate Vuinerabiiity Screening

In most cases, the facility (or the regulator) will first conduct a high-level screening to determine if there are any
potential natural hazards and climate hazards of concern at the facility. A screening is focused on understanding
the exposure component of vulnerability. A screening will help to identify what hazards the facility may be
exposed to and how those hazards are projected to change. The potential impacts of those hazards—and whether
a more detailed CVA analysis is necessary—should be considered. If a screening provides insufficient information
to understand exposure, or indicates that hazards may plausibly impact the protectiveness of facility operations
or a remedy, the regulator may consider whether to request or require a CVA.

Climate Vulnerability Assessment

A CVA provides a more detailed evaluation of all three components of
vulnerability: exposure, sensitivity, and adaptive capacity. The
exposure analysis can be used as is from the screening or a facility may
choose to dive deeper into site-specific data (e.g., completing
hydrologic modeling for the site using future precipitation projections
rather than precipitation data as an input). Sensitivity and adaptive
capacity allow for site-specific knowledge and information to be
incorporated into the analysis, including understanding the specific
impacts or sensitivities of remedies and operations to natural hazards
and climate hazards of concern and whether existing protective

measures are sufficient. A CVA concludes with site-specific adaptation measures that could be implemented to
address key natural hazard and climate vulnerabilities identified in the analysis and increase facility resilience.

Table 1 further clarifies the key differences between a screening and a CVA.

Text Box 2. Useful Resource:

EPA released a climate risk
worksheet, Assessing Your Project's
Climate Risk, in 2024 to support
technical assistance providers and
applicants with conducting basic
climate risk assessments. This
resource may be useful while
working through this issue paper.

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Table 1. Comparison of a climate vulnerability screening and climate vulnerability assessment.

Key Questions

Data or Tools

Scenario

Screening

What climate hazards are the facility
exposed to? How are these climate hazards
projected to change? Is a more detailed
analysis needed to understand site-level
exposure and the implications for remedy
protectiveness?

state data.

to conservatively

cerns.

Depth of Analysis

iate exposure to
ds of concern.

Results

Identifies key climate hazards of concern
and can inform whether a more detailed
CVA is necessary. Results can also be used to
inform discussions about adaptation
measures.

What are the sensitivities of specific remedies and/or
operational procedures and conditions set forth in
permits and orders to climate hazards of concern? Are
existing protective or operational measures sufficient
for projected changes in climate hazards? What
additional adaptation measures may be needed?

Federal, state, and additional local and/or site-level
data and modeling.

Uses at least two scenarios to provide a range of
climate projections to inform decision-making.

Provides a deep dive into whether the facility is
vulnerable, considering facility and remedy design.
Seeks out additional data on sensitivities to the
potential climate hazard. Considers whether existing
measures are sufficient to address current and future
climate hazards and what additional adaptation
measures may be needed to address key climate
vulnerabilities.3

Provides detailed site-specific climate vulnerability
results, including exposure, sensitivity, and adaptive
capacity. Also suggests site-specific adaptation
measures as appropriate.

4. How to Conduct a Climate Vulnerability Screening

Text Box 3. Key Questions for a Screening:

1 What climate hazards is the facility exposed to?

1 How are these climate hazards projected to
change?

1 Is a more detailed analysis needed to
understand site-level exposure, the
vulnerability of the facility or remedy, and need
for adaptation measures?

A screening is recommended as a first step to identify
potential natural hazards and climate hazards of concern
and understand the facility's current and future
exposure to those hazards. Should the screening identify
a climate hazard that may impact the facility, and there
is not enough information available to determine if the
facility is resilient, a more detailed site-specific CVA may,
as appropriate, be required. EPA Regions and authorized
states and territories can consider potential adverse
climate change impacts in assuring that RCRA requirements are met and that RCRA permits and cleanups are
protective of human health and the environment in the face of those impacts. Given this, many RCRA facilities
may already have the measures or procedures they need in place.

The following sections outline the steps for conducting a screening to analyze the exposure component of
vulnerability and determine whether a more thorough CVA is necessary.

Step 1: Identify climate hazards of interest

The purpose of a screening is to quickly understand which hazards may pose a threat to the facility. Therefore, it
is better to be inclusive and consider a more comprehensive list of hazards in the screening stage to identify which
climate hazards are of greatest concern and may require additional analysis in a CVA.

3 Adaptation measures may be documented in the facility's contingency, emergency, preparedness and prevention planning.

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To determine an appropriate list of hazards, 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?

Table 2 summarizes the climate hazards to consider in RCRA screenings and CVAs, as appropriate and if data is
available. The national EPA workgroup responsible for identifying data sources for evaluating climate hazards that
could impact RCRA and PCB facilities and cleanups developed this list of climate hazards of greatest concern to
the RCRA program. Using the table below and the guiding questions above, identify climate hazards of interest
for the screening. Climate hazards included in each screening or assessment depend on the site location. Climate
hazards are listed with the geographic region of primary focus but may be relevant to sites in other regions
depending on specific sensitivities.

Table 2. Climate hazards (and their site locations) to consider in screenings and CVAs.

Icon

Climate Hazard

Geographic Region

P?c

^ Flooding

All sites

Extreme Precipitation

y

All sites

>\y

Drought

All sites

-e

6|»*s

Extreme Heat

All sites

a



| Subsidence

All sites

jrrZ_j£?z_

Groundwater Levels

All sites

VV°A Extreme Weather Events
(e.g., hurricanes)

All sites

(focus on south and east coasts)

i



Landslides

b

All sites

(focus on mountainous terrain)

n



Sea Level Rise

Coastal Sites

Si

Saltwater Intrusion

Coastal Sites

i

Storm Surge

Coastal Sites
(including Great Lakes data when
developed)



Wildfire

Western and Southern sites

r

Jjr Extreme Cold

Northern areas

)))

5 Permafrost Thaw

Permafrost areas of Alaska

5

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Step 2: Select a future time period

Many screening tools offer multiple time periods for future projections. Climate projections are typically
provided for mid-century (e.g., 2040-2059) and late-century (e.g., 2080-2099) time periods, which are averaged
over 20 or 30 years and can be compared to a historical baseline (e.g., 1985-2014 for tools that use 30-year
periods or 1995-2014 for tools that use 20-year periods). Climate projections are traditionally presented as 20 or
30-year averages to minimize year-to-year natural fluctuations and capture long-term climate trends. Projections
beyond late century are increasingly uncertain, typically providing diminishing value for informing site decisions.

Choosing an appropriate time period for the screening depends on many factors such as specific conditions and
remedies (if relevant) at the facility and decision-making needs. The following factors are examples of what to
consider when determining an appropriate time period to use:

• Permit timeframe - What is the timeframe of the permit or permit renewal? If 10-30 years is the
timeframe covered by the permit renewal and associated storage and disposal infrastructure, the mid-
century time period for the climate projection may be the most appropriate.

• Hazardous waste cleanup timeframe - 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 time period. For example, in 2024, if the useful life of a pump-and-treat
system is 30 years, it may be appropriate to use a mid-century time period for the climate projection to
inform decision-making.

• Long Term Care timeframe - What is the timeframe that a waste-in-place solution (e.g., landfill in post-
closure care or contamination capped in place) is expected to cover? For example, in 2024, if waste is
being left in place with operation and maintenance or monitoring projected to last 50 years, an end-of-
century time period for the climate projection may be appropriate.

• Criticality - For assets that provide critical services or protection from severe consequences, design and
construction should last as long as necessary. Thus, both mid-century and late-century time periods for
climate projections may be appropriate to consider.

Step 3: Identify the "worst-case" scenario

Most climate change tools or datasets will also require the user to select a scenario. Climate scenarios have been
developed for use in climate modeling, such as in the most recent fifth and sixth phases of the Coupled Model
Intercomparison Project (CMIP). CMIP5 and CMIP6 climate models were run using a consistent set of scenarios
representing possible climate futures, as employed by the Intergovernmental Panel on Climate Change (IPCC).
CMIP5 scenarios are based on representative concentration pathways (RCP) that depend solely on greenhouse
gas concentrations in the atmosphere. CMIP6 scenarios were built from shared socio-economic pathways (SSPs),
which account for factors like population change, economy, education, urbanization, and technological
development that affect greenhouse gas emissions (USDA, 2024). For more detailed information about these
scenarios, see Section 5: Step 2C.

A screening should use climate projections for the "worst case" climate scenario (this may be labeled as high
emissions, RCP 8.5, or SSP5-8.5, which is explained in Text Box 6) to conservatively screen for all potential climate
risks to the facility (IPCC, 2014; IPCC, 2021). If a screening indicates that facility hazardous waste management and
cleanup activities, hazardous waste operations, or remedies (as designed or built) continue to be protective under
the worst-case climate scenario, it provides greater certainty regarding facility resilience or protectiveness of the
cleanup actions. If not, further analysis can be done in a CVA.

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Step 4: Collect climate data

Using available federal or state climate data, collect climate data for the appropriate climate hazards, time
period, and worst-case scenario identified in the prior steps. Table 3 provides website links for a set of
recommended screening tools that were intentionally designed to be easy to use, and most provide data for
multiple hazards within one single tool. For certain hazards or geographic regions, there may be data limitations.
If there is not an authoritative nationwide data source (such as those listed in Table 3) to address a specific
hazard, work with state or local partners to catalog potential data sources. If there are no usable data sources for
certain hazards or regions, document and discuss the climate hazards qualitatively in the climate screening and
consider whether site-level modeling or local data from a CVA could be helpful.

Note; A national RCRA and PCB climate hazard mapping tool is under development to support climate screening
for RCRA and PCB sites.

Table 3. Climate exposure screening tools, and the relevant climate hazards.

Tool

Climate Hazards

Climate Mapping for Resilience and Adaptation
fCMRA) Assessment Tool

Flooding, storm surge, precipitation, drought, extreme heat,
wildfire

National RCRA and PCB Climate Hazard Mapping
Tool (under development)

Under development

U.S. Climate Resilience Toolkit Climate Explorer

Storm surge, sea level rise, precipitation, extreme heat

NOAA Sea Level Rise Viewer

Sea level rise

Step 5: Assess exposure

For each hazard potentially present around the RCRA facility, move through the following decision tree {Figure 2).
This will help determine if the screening provides sufficient information, or whether a more detailed, site-level
CVA is necessary. Document all decisions and findings from the screening, and determine if all necessary resilience
measures are or will be appropriately addressed.

Figure 2. Decision tree to use for climate screening.

In addition to the questions laid out in the decision tree above, consider requesting or requiring a CVA when:

• The RCRA facility has or is currently experiencing damage or disruption from one or more climate
hazards, that the facility has not yet adequately addressed via adaptation measures.

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•	There is concern of a potential impact to the facility, but national screening tools did not have sufficient
information to adequately assess. If site-level modeling or local data sources are available that could
address data gaps, consider doing further analysis.

•	There are any potential secondary or cascading impacts from climate hazards (such as flash flooding
after wildfires) that may be relevant at the site.4

•	Additional information is needed to answer community concerns about a potential release of
contaminants caused by climate change.

•	There is a significant potential receptor, either ecological or human health-related, which requires a
higher level of scrutiny. For example, a drinking water aquifer for a large population center.

If, after completing the climate screening process, more information is needed, or if the screening indicates that
the protectiveness of a permit or remedy may be impacted, consider requesting or requiring, as appropriate, the
facility to proceed with a CVA.5

5. How to Conduct a Climate Vulnerability Assessment

A CVA provides a deeper dive into whether the facility is
vulnerable to natural hazards and climate hazards, considering
different facility and remedy designs. The CVA builds on the initial
screening by collecting additional site-specific or local data on
climate exposure as needed, and analyzing the sensitivities of
specific remedies and/or operational procedures and conditions
set forth in permits and orders. The CVA typically also concludes
with a discussion on whether existing measures are sufficient to
address current and future climate hazards and what additional
adaptation measures may be needed to address key climate
vulnerabilities.

The end goals of the CVA are to:

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

•	Determine whether adaptation measures are necessary to improve resilience, either for the whole
facility, a remedy or component of a remedy (e.g., planting a drought-tolerant species for the vegetative
cover); and

•	Suggest adaptation measures.

RCRA facilities are already required to conduct hazardous waste management and cleanup activities in ways that
ensure protection of human health and the environment and prevent releases of hazardous waste under local
climate conditions. The CVA analyzes changing climate conditions in more detail, examines how these conditions
may affect the facility's hazardous waste management and cleanup activities, and what adaptation measures may
be considered to ensure continued protectiveness.

Text Box 4. Key Questions for a CVA:

¦	What are the sensitivities of specific
remedies, units, or operational
procedures and conditions set forth in
permits and orders to climate hazards
of concern?

¦	Are existing protective or operational
measures sufficient for projected
changes in climate hazards?

¦	What additional adaptation measures
may be needed?

4	A good resource for examining secondary climate hazards is Chapter 7 of ITRC's Sustainable and Resilient Remediation website, https://srr-l.itrcweb.ore/.

5	See U.S. EPA Office of Resource Conservation and Recovery: Inteeratine Climate Change Adaptation Considerations into the Resource Conservation and
Recovery Act Corrective Action Process (February 2024) and Implementing Climate Resilience in Hazardous Waste Permitting Under the Resource
Conservation and Recovery Act (RCRA) (June 2024),

8

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Figure 3 shows how the CVA process for RCRA facilities incorporates the three components of climate
vulnerability. The following sections detail the suggested steps of the CVA process as applied at RCRA facilities.
Minor modifications may be needed to apply the process to other types of sites.

CLIMATE VULNERABILITY ASSESSMENT COMPONENTS

Exposure

Sensitivity

Adaptive
Capacity

CLIMATE VULNERABILITY ASSESSMENT PROCESS FOR RCRA FACILITIES

Engagement &
Scoping

Climate
Exposure

Facility Remedy
Sensitivity &
Vulnerability

Adaptation
Measures

Draft Findings

Documentation
& Application of
Results

Figure 3. Comparison of the climate vulnerability assessment process elements and the climate vulnerability assessment process for RCRA
facilities.

Step 1. Engagement and Scoping

Who should be engaged throughout the climate vulnerability assessment?

As the characteristics of every facility are unique, this process requires a collaborative effort with state or EPA
personnel, subject matter experts, and facility personnel to understand the facility's hazardous waste
management and cleanup activities and to ensure the results will be useful in decision-making. It may be helpful
to engage with interested Tribes and community members to better understand the local climate hazards. While
the CVA itself will most likely be conducted by a smaller team of experts (the CVA team6), the OSRTI pilot study
found that there are key engagement points between the CVA team and the larger group of collaborators. The
first key engagement point is the initial scoping meeting, and the second is during the presentation of preliminary
vulnerability assessment findings. Depending on the specific needs of a facility, additional engagement points may
be needed to discuss the final report or present findings to a broader audience.

The scoping meeting provides an opportunity for the RCRA regulator, facility, state or EPA technical staff,
community and/or Tribal members, and climate, remediation, and GIS technical experts to discuss and identify
the facility-specific needs related to climate impacts. The regulator or the facility may provide a facility overview
and identify the primary climate concerns for current or planned facility hazardous waste management and
cleanup activities, and community concerns. A discussion regarding specific aspects of those activities that may be

6 In putting together the CVA team, consider including, for example, someone who specializes in climate data, and/or someone from the facility who is
familiar with the engineering designs.

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vulnerable to changes in climate may lead to the identification of specific site documents that the CVA team will
review as part of the sensitivity analysis.

What should the climate vulnerability assessment focus on?

The focus of the assessment is guided by current or planned facility hazardous waste management and cleanup
activities, the extent to which forward-looking climate data has been incorporated, and the magnitude of the
projected changes in climate. The CVA may offer different types of support, depending on whether there is a
permit renewal pending or an ongoing cleanup. For example, a facility applying for a permit may focus on the
projected increases in climate hazards that would impact the storage and disposal of hazardous waste. For RCRA
hazardous waste cleanup, below are some examples of support that the CVA could provide:

• RCRA Facility Assessment (RFA) and RCRA Facility Investigation (RFI) Phases: During these phases potential
climate hazard impact information can be incorporated into risk assessments and the conceptual site
model (CSM).

• Corrective Measures Study (CMS): The CMS may include analysis of adaptation measures for each cleanup
alternative based on projected climate impacts.

• Corrective Measures Implementation (CMI): In the CMI phase, remedial plans and other hazardous waste
cleanup activities may be designed to incorporate engineered climate adaptation measures so that the
selected remedy and its operation are resilient to anticipated climate hazards. During this phase, a system
for periodic evaluation of remedy performance may include reassessing climate change preparedness.

Step 2. Climate Exposure

The climate exposure analysis identifies projected
changes in climate conditions that RCRA facilities
may experience. Understanding the magnitude of
expected climate changes from the historical
baseline to a future time period is an essential input
for identifying the facility's vulnerability. The
exposure analysis follows the same steps as a
screening to collect climate data. If a screening has
already been completed for the facility, then that
exposure data can be used as the foundation for the
CVA. If data gaps are identified during the screening,
address them through site-level modeling or local
data sources. In addition, climate data is relatively
coarse and should be ground-truthed with team
members who know the facility and surrounding are;
best. The CVA exposure analysis is an opportunity to
build on the initial screening by collecting additional
localized data and expanding data collection as apprc

scenarios. The following sections detail the steps for completing the exposure analysis.

Text Box 5. Climate Projection Time Periods
Many climate projection tools offer multiple time
periods for future projections. Choosing an
appropriate time period depends on the specific
conditions and actions in place or planned for a
facility. For permitting actions (e.g., permit renewals)
or hazardous waste cleanups where the action or
environmental performance standard will be
complete in the next few decades, it may make sense
to use mid-century data.

Where the performance standards will not be attained
by—or where a long-term care approach goes
beyond—the mid-century mark, the use of end-of-
century data is preferred. For example, hazardous
waste cleanup facilities using groundwater pump and
treat may focus on mid-century projections, while
facilities with engineered caps where waste is left in
place may focus on late-century projections.

te, such as including additional time periods or climate

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Step 2A: Identify climate hazards of interest

If a screening has already been completed, focus the CVA on a shorter list of hazards of greatest concern and/or
hazards where local or site-level data and modeling may be able to address data gaps from the screening process
to provide additional insights.

If a screening has not yet been completed, refer to Section 4. Step 1 for a complete list of potential climate
hazards of interest for RCRA facilities that could be used in the CVA.

Step 2B: Select a time period

If a screening has already been completed, consider whether the selected time period is still appropriate for the
CVA or if alternative or additional time periods should be used in the analysis to provide additional insights.

If a screening has not yet been completed, refer to Section 4. Step 2 for details on selecting an appropriate time
period and a complete list of potential climate hazards of interest for RCRA facilities that could be used in the
CVA.

Step 2C: Identify climate projection scenarios for the exposure analysis

As introduced in Section 4. Step 3. climate scenarios
illustrate possible climate futures based on factors like the
implementation of significant policies to reduce global
greenhouse gas emissions. The SSPs from CMIP6 are the
latest advancement in projected climate scenarios (see Text
Box 6 for details), however some federal tools have not yet
been updated with this data, in which case RCPs from
CMIP5 are commonly used as well.

The screening from Section 4 used the worst-case scenario,

RCP 8.5 or SSP5-8.5, depending on the data source, to
conservatively identify any potential climate hazards. 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 be feasible
or effective to design and build for the worst-case scenario.

The CVA team should collect projections for a middle-of-
the-road scenario (RCP 4.5 or SSP2-4.5) as well as the
worst-case scenario (RCP 8.5 or SSP5-8.5) to provide a
range of possible climate futures to inform decision-making.

By considering multiple scenarios, the team can assess a
range of possible future climates and select a scenario
aligned with their risk tolerance for the decisions they are
making. Risk tolerance is the willingness to accept potential
natural hazard and climate impacts to a facility or remedy.

For example, designing for a worst-case climate scenario
may lead to a more costly project, but would be protective of that worst-case scenario. If damage or failure of a
remedy would have major health or environmental consequences, risk tolerance is low, and it may be worth

Text Box 6. Climate Scenarios

Climate projection scenarios are updated
periodically based on the latest science. RCRA
climate risk assessments should use CMIP6
generation climate projection data, or the latest
available equivalent.

CMIP6 uses Shared Socioeconomic Pathways
(SSPs), scenarios which are distinct, future
narratives that reflect different socioeconomic
development strategies, climate policies that
may be undertaken by society, and radiative
forcing levels.

SSP2-4.5 is considered a middle-of-the-road
scenario in which social, economic, and
technological trends do not shift markedly from
historical patterns.

SSP5-8.5 is considered the worst-case scenario
that represents an "unabated" future in which
society is still heavily reliant on fossil fuel, and
CO2 emissions continue to increase until late into
the 21st century.

While climate screening focuses on a worst-case
scenario to conservatively screen for all potential
climate risks at a site, CVAs also include the
middle of the road scenario to allow for the fine-
tuning of adaptation measures.

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building to the worst-case climate projections. If there are backup measures in place that would limit the severity
of consequences, risk tolerance is higher, and it may be worth the cost savings to build to a middle-of-the-road
scenario. Discussion of risk tolerance helps to improve the transparency and credibility of any subsequent
decisions.

Step 2D: Collect climate data

The CVA team should use the best available data at the time of the assessment for the hazards, time periods, and
scenarios identified in Steps 2A. 2B. and 2C. Table 4 provides a list of suggested best available, national datasets
as a starting point.

If there is not a national dataset available for a hazard of interest or the data is incomplete, the CVA team should
look for state or local data sources, work with key partners, or complete site-specific modeling. Example
alternative sources include:

• The CVA team can also turn to state and local climate reports (city, county, state, etc.) or local contacts
(e.g., state climatologist) to identify potential data sources and feasibility of analyzing additional variables.
For example, California has the Cal-Adapt platform, which provides publicly available climate change data
developed for the state's climate change assessment.

• For EPA staff, EPA Shared Enterprise Geodata & Services (SEGS) hosts a curated collection of climate
change data (EPA, 2024a), as well as GIS resources specific to land program needs (EPA, 2024b).

• The CVA team might conduct its own site-specific modeling, such as hydrologic or hydraulic modeling
replacing historical precipitation data inputs with projected precipitation amounts.

• If, for example, future flood data is not available, the CVA can follow one of FEMA's Federal Flood Risk
Management Standard recommendations of using the historic 500-year floodplain over the historic 100-
year floodplain to at least capture a larger floodplain (FEMA, 2024).

Using any combination of data sources outlined above, the CVA team should establish a set of specific climate
variables for each relevant hazard identified in Step 2A. Table 4 provides recommended tools and example
variables available through these sources to help conduct a more tailored CVA and build on any initial data
collected during the screening. The CVA team should work together to choose specific variables of interest and
consequence to the facility.

Finally, the CVA team should collect the data for the indicators established above across the time period(s) of
interest as well as across multiple future scenarios (ideally SSP2-4.5 and SSP5-8.5). Often, publicly available tools
and data sources have summarized climate indicators over pre-determined time periods or future scenarios (e.g.,
SSPs). In the event the CVA team is using a best-available source that does not align with the time period or future
scenario(s) of interest established above, the CVA team should still use the data, and qualify any assumptions.

Table 4. Climate hazards, and the tools typically used in the climate exposure analysis, alongside example variables.

Icon

Climate Hazard

Tool

Example Variables

Flooding

¦ FEMA: National Flood Hazard
Laver

Historic 100-year and 500-year floodplains7.

C^)

Extreme Precipitation

¦ CMRA: Assessment Tool

¦ U.S. Climate Resilience Toolkit
Climate Explorer

Days with total precipitation greater than 1",
2", or 3", days exceeding 99th percentile
precipitation, maximum number of
consecutive wet days.

7 When making design decisions, follow the FEMA Federal Flood Risk Management Standard (FFRMS) recommendations, and use best available science, 500-
year floodplain data or the Freeboard Value Approach, instead of the 100-year floodplain to better account for future flood risk.

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yffc Drought

¦ CMRA: Assessment Tool

Maximum number of consecutive dry days,
days per year with no precipitation.

Extreme Heat

¦ CMRA: Assessment Tool

¦ U.S. Climate Resilience Toolkit
Climate Explorer

Days with maximum daily temperature above
90°F, 95°F, 100°F, and 105°F, annual single
highest maximum temperature, average daily
maximum temperature.

Extreme Weather
Events (e.g.,
hurricanes)

¦ NOAA: Historical Hurricane
Tracks

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

[•

Landslides

¦ NASA: Landslide SusceDtibilitv
Map

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

- -i Sea Level Rise

¦ NASA: Interagency Sea Level
Rise Scenario Tool

¦ NOAA: Sea Level Rise Viewer

Area permanently inundated by sea level rise
under IPCC-defined sea level rise scenarios.8
Inland extent/relative depth of inundation
from 0-10 feet above mean higher high water.

Storm Surge

¦ USGS: Coastal Storm
Modeling Svstem (CoSMoS)

¦ NOAA: Sea, Lake and
Overland Surges from
Hurricanes (SLOSH) model

Flood depth and/or extent due to future sea
level rise and the 100-year storm.

Storm surge heights above ground level
resulting from hypothetical Category 1
through Category 5 hurricanes.

Wildfire

¦ Climate Toolbox: Climate
MaDDer

Days with 100-hour fuel moisture below the
20th (High), 10th (Very High) and 3rd
(Extreme) percentile model values, percent
area burned per year.

Extreme Cold

¦ U.S. Climate Resilience Toolkit
Climate Explorer

Days with maximum daily temperature under
32°F, days with minimum daily temperature
under 32°F, heating degree days.

No national data tool is available for the following climate hazards; use the best available local dataset:

• Groundwater Levels

• Permafrost Thaw

• Saltwater Intrusion

• Subsidence

Step 2E: Assess exposure

Using the collected data, assess exposure and document all findings, which will provide the foundation for
discussion of specific facility sensitivities and vulnerabilities to these projected changes in the next step. The
results of the climate exposure analysis can be presented through maps (Figure 4), charts (Figure 5), and graphs
(Figure 6) to help visualize the projected change and uncertainty in climate conditions from present day to mid-
century and end of century. As demonstrated in Figure 4, mapped visualizations can help characterize geographic
variability in exposure across a larger site.

8 Users are required to choose a sea level rise scenario. While exact sea level rise projections vary by tide gauge location, each sea level rise scenario Is
defined by an amount of global mean sea level rise from the beginning to the end of this century (I.e., 2000 to 2100): 0.3m for the low scenario; 0.5m for the
intermediate-low scenario; lm for the intermediate scenario; 1.5m for the intermediate-high scenario; and 2m for the high scenario.

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100-year
floodpiain
500-year
floodpiain

Projected Wildfire Danger Days at Bay
Road Holdings Snperfund Site

Months June-November

Bee

Observed	Near-Future Mid-Century

High ¦ Very High ¦Extreme

Figure 4. FEMA 100- and 500-year floodplains at Bay Road	Fi§ure 5* wildfire danBer daVs from luneto November at Bay

Holdings in East Palo Alto, California.	Road HoldinSs in East Pal° Alt0- California based on RCP 8.5 100-

hour fuel moisture projections.



Total Precipitation by Month

Jan Feb Mar Apr May
Baseline (1976-2005)

Jun Jul Aug Sep Oct
Mid-Century «	Late-Century

Nov

Dec

Figure 6. Total precipitation by month based on RCP 8.5 90th percentile projections at Bay Road Holdings in East Palo Alto, California.

14

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Step 3. RCRA Facility Sensitivity and Vulnerability

The evaluation of a RCRA facility's sensitivity to hazards involves assessing the degree to which a specific hazard
may impact different elements of the facility's permitted operations, cleanup activities, or remedies. The
sensitivity of each element is then further analyzed in conjunction with the expected climate exposure for the site
to determine the vulnerability.

Relevant facility documents are reviewed to understand the different elements of the facility operations,
equipment, contaminated media, or remedies that may be affected. Specific documents may include:

• Previous climate analysis

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

• RCRA permit

• Permit, permit modification or permit renewal applications

• RFA and RFI documents

• CSM

• CMS

• CMI documents, including as-built and design documents

• Operation and maintenance documents

• Annual monitoring and sampling reports

The climate exposure for each potential climate hazard impacting the facility is evaluated against the sensitivity of
the different hazardous waste management and cleanup activities. The qualitative intersection between climate
exposure and sensitivities, as determined by the CVA team applying professional judgment, identifies the
potential vulnerabilities (see Figure 7).

Vulnerability of a Facility or Remedy

High

£
Cs

Med

Low

£
<5

Low

Med

High

Facility or Remedy Sensitivity

Figure 7. Qualitative depiction of vulnerability for one element of a
facility operation or cleanup activity. When significant changes in
climate coincide with high sensitivity, a vulnerability is identified.

Vulnerabilities of hazardous waste management and cleanup activities that may affect the permit or 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 facility or 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
contaminant releases to the environment. Specific examples of a vulnerability and the associated loss of remedy
or permit protectiveness due to changes in climate are provided in Table 5.

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Table 5. Examples of specific vulnerabilities that can arise due to changes in climate and the associated impacts to permit or remedy
protectiveness.

Vulnerability

Potential Impacts to Permit or 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
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.

More frequent extreme storm events result in flooding in
areas where tanks of hazardous waste are stored.

Saturated soil and standing water may lead to instability and
degraded containment infrastructure, leading to tank failure.

More frequent and extreme temperature fluctuations
outside a landfill cap's designed temperature range.

The extreme temperature fluctuations affect the cap's
integrity, leading to cracking and erosion.

More frequent and extreme temperature fluctuations at a
facility storing chemicals in above ground tanks.

Extreme heat may lead to evaporation of chemicals, leading
to increased tank pressure or excessive release of vapors for
vented tanks. Extreme cold can freeze vents or crack piping.

As described in Section 4. Step 2, identifying changes in the climate hazards relevant to the operating period is
essential when assessing the vulnerability of hazardous waste management and cleanup activities to future
changes in climate. Mid-century projections may provide the most appropriate information for facilities applying
for a RCRA permit renewal, or when analyzing the sensitivities associated with a groundwater pump-and-treat
system. Reviewing end-of-century projections may be more appropriate when evaluating sensitivities for
remedies including long-term institutional or engineering controls, or for land-based units, that involve an
engineered cap for hazardous waste which will remain on site indefinitely. Finally, future climate projections may
not be needed for short-term remedies, such as in situ groundwater thermal treatment that would be
implemented and completed within five years.

In addition to the direct impacts changing climate hazards may have on TSDF units or a hazardous waste cleanup
remedy's protectiveness (examples provided in Table 4), impacts to ancillary systems on which the facility may
rely may also be considered. Examples of ancillary system vulnerabilities that can be considered include:

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

• Nearby stormwater controls: Stormwater runoff associated with increases in extreme precipitation may
be exacerbated by changes in nearby land use, such as the 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

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to provide capacity for a historic 100-year flood may no longer provide sufficient protection during future
extreme 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

EPA OSRTI's assessment of impacts to Superfund sites after the 2017 hurricane season (EPA, 2018) identified that
significant redundancies are often designed into Superfund remedies, and it is likely that RCRA permits and
hazardous waste cleanups have also included some redundancy. OSRTI found that, 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. Furthermore, current or planned regional resilience measures, such as sea walls or other flood barriers,
should be documented in a CVA and considered when assessing a facility's vulnerability. Permits or remedies
determined to demonstrate sufficient adaptive capacity to the identified vulnerabilities may require no
modification at present. Assurance of sufficient capacity, however, is an iterative process. Monitoring the
performance of the permitted operations or remedies and reassessing the vulnerability to future climate change
should be performed periodically as required to ensure 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:

•	A nature-based solution, or armoring along the base of the landfill cap, to provide 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 TSDF units or hazardous waste cleanup remedies that lack sufficient adaptive capacity or are in a pre-design
phase, considerations regarding adaptation measures may be provided. Examples of considerations regarding
improving adaptive capacity for identified vulnerabilities include:

•	Designing storage or 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 or key storage 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

Additional resources describing potential adaptation measures for certain climate hazards can be found in Section
7.

17

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Step 5. Climate Vulnerability Assessment Preliminary Results

The CVA team should present the preliminary results of the CVA in some documented form (such as a
presentation or report), which typically includes the following information:

•	Charts and quantitative results from the climate exposure analysis

•	Discussion of the sensitivities and vulnerabilities of different facility and remedy components

•	Identification of existing adaptation measures that ensure resilience of the facility and remedy
components

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

Presentation of the preliminary results is an opportunity for the extended group of collaborators to provide
feedback on the initial findings before the assessment is finalized. The collaborators and the core CVA team may
discuss inclusion of additional climate exposure analyses in the documentation 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 for the permit writer or hazardous waste cleanup project manager to 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 Documentation and Application of Results

The permit writer or hazardous waste cleanup project manager should then receive a CVA in a documented form.
This documentation should include a description of the scope and methodology of the assessment. Quantitative
results from the climate exposure analyses should document a range of projected changes in climate conditions at
the facility. Sensitivities of permitted operations or hazardous waste cleanup remedy elements are described and
analyzed in conjunction with the climate exposure. If there is a specific climate exposure and the facility
operations or remedy elements may be sensitive, the vulnerability is identified and considerations regarding
potential adaptation measures are provided. The text box below summarizes the main points to include in the
documentation.

Text Box 7. Example Climate Vulnerability Assessment Documentation Structure

¦	Introduction: scope and purpose of the assessment

¦	RCRA Facility Background: location, relevant history, hazardous waste management activities, primary
contaminants and remedy if relevant, map of site features

¦	Climate Exposure: projections and data visualizations for relevant climate hazards

¦	Facility or Hazardous Waste Cleanup Vulnerability and Resilience: specific sensitivities for facility
hazardous waste management and cleanup activities and identification of vulnerabilities where climate
exposure and sensitivities intersect; adaptive capacity of those activities and any necessary adaptation
measures

¦	References: documents reviewed and cited as part of the assessment

The goal of the CVA documentation and the data discussed within it is to assist the RCRA regulator with the
following activities:

•	Determining if additional permit language or conditions, or unit design modifications, are needed to
protect against accidental releases.

•	RCRA Facility Assessment & Investigation: Highlight potential climate hazards during the RFA and RFI

stages.

18

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Assessing Remedy Options: Address concerns regarding the long-term protectiveness of alternatives
considered during the CMS.

Remedy selection and design: Identify known vulnerabilities for selected remedies and considerations
how to address them in design; record in CMI documents.

Operation and Maintenance: Evaluate the remedy during periodic reassessment and implement
adaptation measures as needed to ensure the remedy is prepared for changing climate conditions.
Community engagement: Provide documentation of existing facility/remedy resilience and plan for
proactively addressing vulnerabilities to future climate conditions.

19

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Example Climate Vulnerability Assessment: Bay Road Holdings RCRA Facility

As part of the CVA technical support piloted by EPA OSRTI, a CVA was performed at the Bay Road Holdings
RCRA facility by an independent third party. The site description and summary of CVA results are provided
below; for additional information, the final CVA report is available online.

The Bay Road Holdings LLC Site (formerly Romic Environmental Technologies Corporation) is located in East
Palo Alto, California. Operations at the facility included solvent recycling, fuel blending, wastewater treatment,
and hazardous waste storage and treatment. The primary contaminants in the soil and groundwater are
volatile organic compounds (VOCs). At the time of the CVA, the existing and proposed remedy to address the
contamination remaining at the facility included:

• Maintaining the existing soil cover to prevent direct contact with contaminated soil.

• Light Non-Aqueous Phase Liquid (LNAPL) removal in areas with measurable LNAPL thicknesses.

• Enhanced Reductive Dechlorination recirculation system to address groundwater contamination.

• Excavation where it is more practical to remove rather than treat contaminated soils.

• BioBarrier injection wells to minimize offsite migration of the groundwater plume.

• Monitored Natural Attenuation (MNA) once groundwater concentrations are reasonably close to
media cleanup objectives or groundwater concentrations are stable or significantly decreasing.

• Ongoing groundwater and surface water monitoring to evaluate conditions over time.

• Administrative Controls such as land use restrictions and financial assurance.

The table below highlights the key climate exposure and sensitivity findings, and select report figures are
included in this issue paper (see Figure 4, Figure 5, and Figure 6).

Table 6. Key climate exposure and sensitivity findings.

Hazard Climate Projections

Remedy Sensitivities

¦ More frequent and intense storm events
increase the risk of flooding.

¦ Damage to groundwater recirculation system
equipment from intense storm events.

Coastal
Hazards

¦ Sea level rise and storm surge are projected to
increase coastal flood risk.

¦ Groundwater levels are projected to rise under
future sea level rise.

¦ Inundation of existing protective cover.

¦ Saltwater intrusion affecting aquifer chemistry
and reducing effectiveness of enhanced
bioremediation, BioBarrier, and MNA.

¦ Emergent LNAPL during storm surges.

The CVA found that the remedy components at greatest risk to climate hazards are those that rely on
maintaining consistent biogeochemical conditions in the aquifer. Based on the current amendment dosage
rate and total substrate demand, the enhanced reductive dechlorination system will achieve its remedial goals
in 10 to 19 years, which will approach the timeframe of the mid-century climate projections. With a projected
sea level rise of approximately 2 ft. in mid-century and 7 ft. in late century, saltwater intrusion may increase
salinity and sulfate concentrations, both of which can make biological treatment of chlorinated solvents more
difficult. This may affect the groundwater recirculation system, BioBarrier, and MNA. The CVA noted that
tracking the rate of saltwater infiltration and adjusting the remedies accordingly will be critical for meeting the
cleanup objectives of the site, and aggressive remedial approaches to clean up the site before the projected
changes in site conditions should be considered. Finally, the CVA documented proposed adaptive measures
that would make the remedy more resilient to climate impacts, including the construction of a floodwall
between the site and San Francisco Bay and the placement of several feet of fill during site redevelopment.

The EPA site team shared the CVA report with the site's responsible party, and initiated a third party
optimization review of the current remedy to evaluate the groundwater plume with 3-dimensional data
visualization analysis (3DVA). The optimization review found the current system is unlikely to result in cleanup
goals being achieved in a reasonable timeframe. The results from the CVA and optimization have spurred
additional action at the site, with the responsible party exploring remedial alternatives that are resilient to
future climate hazards and aggressively expedite the cleanup timeframe.

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6. Glossary of Terms as Used in this Document

Adaptive Capacity

The ability of a human or natural system to adjust to climate change (including climate variability and extreme
weather events) by moderating potential damages, taking advantage of opportunities, or coping with the
consequences.

Adaptation Measure

An institutional or engineering measure taken to prepare for and adjust to both the current and projected impacts of
climate change. Also known as a resilience measure.

Climate Change

Changes in average weather conditions that persist over multiple decades or longer. Climate change encompasses
both increases and decreases in temperature, as well as shifts in precipitation, changes in frequency and location of
severe weather events, and changes to other features of the climate system.

Climate Hazards

Climate hazards may include, and are not limited to, flooding, sea level rise, storm surge, shoreline erosion,
subsidence, groundwater levels, drought, wildfires, landslides, saltwater intrusion, extreme heat, extreme cold,
extreme weather events, permafrost thaw.

Climate Vulnerability Screening (Screening)

A high-level assessment to answer the questions of whether there are any potential climate hazards at a facility (see
Table 1) and whether a CVA is needed.

Climate Vulnerability Assessment (CVA)

A detailed assessment to answer the questions of the magnitude of potential climate hazards at a facility, whether
regulated units or remedies are resilient, and if not, what adaptation measures are necessary (see Table 1).

Hazardous Waste Cleanup Program (formerly Corrective Action Program)

The RCRA Hazardous Waste Cleanup Program, under which owners and operators of RCRA treatment, storage and
disposal facilities investigate and clean up releases of hazardous waste and constituents into soil, groundwater,
surface water and air, as necessary to protect human health and the environment.

Exposure

Whether and to what degree a facility could experience a climate hazard or extreme weather event.

Extreme Weather Event

A meteorological occurrence that is rare at a particular place and time of year. Definitions of "rare" vary, but an
extreme weather event would normally be as rare or rarer than the 10th or 90th percentile of a probability density
function estimated from observations. By definition, the characteristics of what is called extreme weather may vary
from place to place in an absolute sense.

Indicator

Reliable measure of past, present, or future condition. Tracked over given area and time (US EPA, 2021). Used to
communicate and inform decisions.

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.

Sensitivity

Whether and to what degree a facility would experience impacts from an exposure.

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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; 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.

7. Selected Resources

This section includes resources on performing screenings and assessments and identifying potential adaptation
measures.

Climate Exposure Tools (from Table 3 and Table 4)

•	Climate Mapping for Resilience and Adaptation (CMRA) Assessment Tool:
https://resilience.climate.gOv/#assessment-tool. as part of an interagency partnership under the U.S.
Global Change Research Program (USGCRP)

•	Climate Toolbox, Climate Mapper: https://climatetoolbox.org/tool/climate-mapper

•	EPA National RCRA and PCB Climate Hazard Mapping Tool: https://www.epa.gov/rcra/climate-hazard-
screening-tool

•	FEMA National Flood Hazard Layer: https://www.fema.gov/flood-maps/national-flood-hazard-laver

•	NASA Interagency Sea Level Rise Scenario Tool: https://sealevel.nasa.gov/task-force-scenario-tool/

•	NASA Landslide Susceptibility Map: https://gpm.nasa.gov/landslides/proiects.html

•	NOAA Historical Hurricane Tracks: https://coast.noaa.gov/hurricanes/#map=4/32/-80

•	NOAA Sea Level Rise Viewer: https://coast.noaa.gov/slr/

•	NOAA SLOSH model: https://www.nhc.noaa.gOv/nationalsurge/#data

•	U.S. Climate Resilience Toolkit, Climate Explorer: https://crt-climate-explorer.nemac.org. with various
partners including USGCRP

•	USGS CoSMoS: https://www.usgs.gov/centers/pcmsc/science/coastal-storm-modeling-svstem-cosmos

Other Climate Vulnerability and Adaptation Resources

•	EPA ORCR Memorandum Integrating Climate Change Adaptation Considerations into the Resource
Conservation and Recovery Act Corrective Action Process: https://rcrapublic.epa.gov/files/14962.pdf

•	EPA ORCR Memorandum Implementing Climate Resilience in Hazardous Waste Permitting Under the
Resource Conservation and Recovery Act (RCRA)\ https://rcrapublic.epa.gov/files/14964.pdf

•	EPA ORCR Memorandum Implementing Climate Resilience in PCB Cleanup, Storage, Treatment and/or
Disposal Approvals: https://www.epa.gov/system/files/documents/2024-
06/implementing_climate_resilience_in_pcb_approva ls_policy_memo_final.pdf

•	EPA Assessing Your Project's Climate Risk: A Worksheet for Applicants and Technical Assistance Providers:
https://www.epa.gov/svstem/files/documents/2024-06/cdti risk assessment worksheet final 5-21-
2024.pdf

•	EPA OLEM Programs Climate Screenings and Vulnerability Assessments: https://segs-
epa.hub.arcgis.com/pages/olem-programs-climate-screening-vulnerabilitv-assessments?preview=true

•	EPA Handbook on Indicators of Community Vulnerability to Extreme Events: Considering Sites and Waste
Management Facilities:

https://cfpub.epa.gov/si/si public record Report.cfm?dirEntrvld=358458&Lab=CPHEA

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

22

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• EPA EJScreen Environmental Justice Screening and Mapping Tool (Version 2.3):
https://eiscreen.epa.gov/mapper/

• EPA 2024-2027 Climate Adaptation Plan: https://www.epa.gov/svstem/files/documents/2024-06/epas-
2024-2027-climate-adaptation-plan-508-compliant.pdf

• EPA Superfund Climate Resilience website, including climate adaptation profiles and technical factsheets:
https://www.epa.gov/superfund/superfund-climate-resilience

• Interstate Technology and Regulatory Council (ITRC) Sustainable Resilient Remediation: https://srr-
l.it rcweb.org/

8. Acknowledgement

This issue paper was prepared by the U.S. EPA Office of Resource Conservation and Recovery, building
upon previous work by the U.S. EPA Office of Superfund Remediation and Technology Innovation.

9. Notice and Disclaimer

This technical issue paper has been reviewed in accordance with EPA procedures and has been approved for
publication as an EPA publication. The information in this issue 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. Terms used in this paper that
may be similar to terms in the RCRA regulations are not intended to communicate any legal, regulatory, or
authority meaning. Use or mention of trade names does not constitute an endorsement or recommendation for
use by EPA.

The preparation of this report was performed by ICF and EMS for the EPA Office of Resource Conservation and
Recovery under EPA contract 68HERH2D001 with EMS.

10. Cited References

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

EPA. 2021. 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/100002993.pdf

EPA. 2024a. Shared Enterprise Geodata & Services (SEGS): Climate Change GeoPlatform. Accessed June 28, 2024.
https://segs-epa.hub.arcgis.com/pages/climate-changes

EPA. 2024b. Shared Enterprise Geodata & Services (SEGS): OLEM Programs Climate Screenings and Vulnerability
Assessments. Accessed June 28, 2024. https://segs-epa.hub.arcgis.com/pages/olem-programs-climate-screening-
vulnerabilitv-assessments?preview=true

FEMA. 2024. FEMA Policy: Federal Flood Risk Management Standard (FFRMS) FEMA Policy 206-24-005.
https://www.fema.gov/sites/default/files/documents/fema floodplain-management ffrms-policv 072024.pdf

IPCC. 2014. Summary for Policymakers. In: Climate Change 2014: Mitigation of Climate Change.
https://www.ipcc.ch/site/assets/uploads/2018/02/ipcc wg3 ar5 summarv-for-policvmakers.pdf

IPCC. 2021. Summary for Policymakers. In: Climate Change 2021: The Physical Science Basis, pp. 3-32,
doi:10.1017/9781009157896.001.

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USDA. 2024. Climate Hubs: What are climate model phases and scenarios?

https://www.climatehubs.usda.gov/hubs/northwest/topic/what-are-climate-model-phases-and-scenarios

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