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FY 2020 EPA Program Evaluations

Office of Enforcement and Compliance Assurance (OECA)

Activity 1:

Title

RCRA Data Analytics Evaluation

Lead National
Program/Region

Office of Enforcement and Compliance Assurance

Strategic Goal and
Objective Supported

Strategic Goal 3: Greater Certainty, Compliance, and Effectiveness
Strategic Objective 3.1: Compliance with the Law

Completion Date

FY 2020

Purpose and brief description: Since 2015, EPA has worked with The University of Chicago Energy &
Environment Lab (UChicago E&E Lab) to develop a robust machine learning model that forecasts the
likelihood that large quantity generator (LQG) hazardous waste facilities will violate RCRA regulations.
The model is based on 15 years of historical data generated from across EPA programs. When used in
combination with inspectors' experience, skills, and knowledge, the predictive model can help
regulators drastically increase the likelihood of finding violations - allowing better focus for scarce
inspection resources. Throughout FY 2017 - FY 2019, EPA coordinated across Regions to field test the
efficacy of targeting inspection resources using machine learning methodologies. The randomized
evaluation completed in FY 2020 benchmarked the ability of the model to identify facilities with severe
RCRA violations detected during inspection relative to status quo practices across Regions. Preliminary
results demonstrate that the model yields a substantial increase in efficiency of detecting hazardous
waste violations compared to current targeting practices, with no increase in operational cost. This is
the first rigorous, experimental field test that has been conducted by EPA's enforcement and
compliance program for a predictive targeting model.

Brief List of Results/ Conclusions/Findings: The University of Chicago will release a working paper
outlining how the model nearly doubled the violation detection rate and pursue publication in a top
economic academic journal.

How EPA Used the Results/Conclusions/Findings to make program improvements, support planning
and policy decision making, assess progress toward mission/objectives, and/or make changes to
strategies or measures: Based on this result, EPA released a new set of predictive analytics scores to
both Regions and states for their use in FY 2021 inspection plan targeting. Furthermore, EPA will
maintain and continue to refine the model with ongoing support from the UChicago E&E Lab with scores
for FY 2021 and subsequent years being released on the Enforcement and Compliance History Online
(ECHO) platform to support regional and state targeting efforts on an ongoing basis.

Link for findings; Not yet available

Office of Land and Emergency Management (OLEM)

Activity 1:

Title	Underground Storage Tank Inspection Frequency Study

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Lead National
Program/Region

Office of Land and Emergency Management (OLEM), Office of
Communications, Partnerships, and Analysis (OCPA)

Strategic Goal and
Objective Supported

Strategic Goal 1: A Cleaner, Healthier Environment

Strategic Objective 1.3: Revitalize Land and Prevent Contamination

Completion Date

August 2020

Purpose and brief description: The Energy Policy Act (EPAct) of 2005 enacted a requirement that all
regulated underground storage tanks (UST) containing petroleum or certain other hazardous substances
must be inspected for compliance with UST release prevention and detection requirements at least once
every three years. This study examines the impact of EPAct's inspection frequency requirement on UST
facilities' compliance with release detection and prevention requirements in Louisiana and Arkansas.

Brief List of Results/ Conclusions/Findings: Results suggest that increasing inspection frequency
improved UST facilities' compliance in both Louisiana and Arkansas. EPA also finds that the impact of
inspection frequency on compliance is heterogeneous based on a facility's compliance status at the last
inspection—larger impact for those facilities that were compliant than those that were noncompliant at
their last inspection.

How EPA Used the Results/Conclusions/Findings to make program improvements, support planning
and policy decision making, assess progress toward mission/objectives, and/or make changes to
strategies or measures: EPA's mission is to protect human health and the environment, both of which
are threatened by UST releases. The greatest potential hazard from a leaking UST is that petroleum or
other hazardous substances can seep into the soil and contaminate groundwater, the source of drinking
water for nearly half of all Americans. A release from an UST can also present other health and
environmental risks, including potential for fire and explosion. This study assesses the effectiveness of
EPAct's inspection frequency requirement towards mitigating releases and resulting deterioration of
human health and the environment. The study reaffirms EPA's commitment to on-site inspections and
EPA continues to work with states to ensure at least a 3-year inspection frequency. EPA is committed to
continued training for UST inspectors through our grants with ASTSWMO and NEIWPCC.

Link for findings: https://www.epa.gov/aboutepa/energy-policv-act-2005-increased-inspection-
frequency-and-compliance-underground-storage.

Activity 2:

Title

Estimating the Effects of Superfund Cleanups on Children's Blood Lead Levels

Lead National
Program/Region

Office of Policy (OP), National Center for Environmental Economics (NCEE)
and Office of Land and Emergency Management (OLEM), Office of
Communications, Partnerships, and Analysis (OCPA)

Strategic Goal and
Objective Supported

Strategic Goal 1: A Cleaner, Healthier Environment

Strategic Objective 1.3: Revitalize Land and Prevent Contamination

Completion Date

March 2020

Purpose and brief description: This study identified the effect of Superfund cleanups on children's
elevated blood lead levels across a wide swath of Superfund sites spanning different regions,
contamination levels, and potential exposure pathways. It quantified the average health impacts across
a substantial subset of the Superfund program.

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Brief List of Results/ Conclusions/Findings: The analysis of two decades of blood lead level
measurements from children across six states indicates that cleanup at lead contaminated Superfund
sites lowered the risk of elevated blood levels for children living within two kilometers of the sites by 13
percent to 18 percent.

How EPA Used the Results/Conclusions/Findings to make program improvements, support planning
and policy decision making, assess progress toward mission/objectives, and/or make changes to
strategies or measures: Information from this study supports EPA's contribution to the Federal Action
Plan to Reduce Childhood Lead Exposures and Associated Health Impacts and improved the Agency's
understanding of the potential scope of the childhood lead exposures and the effect of Superfund
cleanups on elevated blood lead levels.

Link for findings: https://www.sciencedirect.com/science/article/abs/pii/S00950696193033Q4.

Office of Research and Development (ORD)

Activity 1:

Title or Topic of
Study/Tool/Project

Evaluating health impacts of lead remediation at Omaha lead superfund site

Lead National
Program/Region

Office of Research and Development (ORD) and Region 7

Strategic Goal and
Objective Supported

Strategic Goal 3: Greater Certainty, Compliance, and Effectiveness
Strategic Objective 3.3: Prioritize Robust Science

Completion Date

FY 2020

Purpose and brief description: The Omaha Lead Superfund Site (OLSS) encompasses 27 square miles
within the eastern portion of greater metropolitan Omaha in Douglas County, Nebraska. The site was
contaminated by emissions from a lead smelter and refining facility (ASARCO) that operated for
approximately 125 years until its closure in 1997. Beginning in 1999 EPA sampled soils at residential
properties and childcare facilities in Omaha to define a "focus area" for clean-up operations; the focus
area was intended to delineate the area where soil concentrations for at least 1 in 20 homes exceeded
400 parts per million (ppm). EPA worked with Douglas County Health Department to link blood lead
surveillance data with EPA data on soil lead concentrations and remediation dates.

Brief list of results/conclusions/findings: Analyses suggested an important role for both a residence's
yard and its neighborhood soil lead concentrations in predicting Elevated BLL (>5 ng/dL), with
neighborhood soil lead concentration becoming more influential following remediation. Risk of Elevated
BLL (>5 or 10 ng/dL) was higher before remediation in models that examined this relationship across and
within children. BLL improvement was associated with soil-based intervention in some fully adjusted
difference-in-differences models.

How EPA used the results/conclusions/findings: These analyses showed that EPA's soil removal and
replacement actions at the OLSS were effective in reducing Elevated BLLs. This paper improved the
Agency's understanding of the importance of reducing residential and neighborhood soil concentrations
to achieve associated decreases in BLL.

Link for findings;

https://cumulis.epa.gov/supercpad/SiteProfiles/index.cfm?fuseaction=second.cleanup&id=0703481

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