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Recommendations for Developing Effective Risk Management
Policies for Contaminated Site Cleanup An Overview of Risk
Management Concepts and How Risk Management is Used to Set
Priorities in Two Contaminated Site Remedial Programs in the
U.S.Presentation byEmily PimentelU.S. Environmental Protection
Agency Region [email protected]
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Presentation OverviewRisk assessment and risk management
concepts and issues.Recommendations for setting remedial program
priorities.Overview of two US programs to remediate contaminated
sites.Summary of key points.
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Recommendations for SettingPrioritiesPrioritize remedial
programs based on:Sites with a known responsible party
(owner),Sites that are abandoned,Other sites with complex policy
issues.Prioritize contaminated sites with a known release and a
pathway that poses greatest threat of exposure.Manage based on
chemicals associated with industry-sectors.Promote early risk
reduction and site stabilization at all contaminated sites.
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SEMARNATs Goal:
To establish a process to identify and prioritize contaminated
sites that pose the greatest risk to human health and the
environment.
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Risk DefinedThe combination of the probability or frequency of
occurrence of a defined hazard and magnitude of the consequences of
the occurrence.
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Risk Assessment
The use of the factual base to define the health and ecological
effects of exposure of individuals, populations, or environments to
hazardous materials or situations.
United States NationalAcademy of Sciences
Risk Management Involves determining and accomplishing those
actions that will reduce risks to the greatest degree given any
particular level of resources.Balances risk reduction against
resources.Balances the risk of one action against the risk of
another. Risk Management Risk Assessment
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For those of you whoare more
visual!RiskPerceptionRiskAssessmentRiskManagement
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Risk Communication ChallengesDue to scientific uncertainty, it
is difficult to provide exact numbers to estimate risks.Two of the
most prominent sources of risk communication are the government and
industry, yet they are the most mistrusted.Media plays a big role
in providing information, but they often they simplify it, get it
wrong, or distort it.The public evaluates risk based on perception
and their own judgment of what is acceptable
risk.Scientist/EngineersDecision-makersStakeholders
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Major Concerns of Traditional Risk Ranking ModelsRisk alone
should not predominate decision-making.Risk assessment and
comparative risk models are not solely science-based; they
involvement judgments and a high degree of uncertainty.Risk
management projects often neglect public participation and social
values needed to make good decisions.A regulatory process for the
explicit considerationof social and political factors is typically
not provided
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Recommendations for Setting Priorities for Remediation of
Contaminated SitesPrioritize remedial programs based on:Sites with
a known responsible party (owner),Sites that are abandoned
sites,Other sites with complex policy issues.Prioritize
contaminated sites with a known release and a pathway that poses
greatest threat of exposure.Manage based on chemicals associated
with industry-sectors.Promote early risk reduction and site
stabilization at all contaminated sites.
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A Review of What Mexico Wants and Progress MadeSEMARNATs Goal:To
establish a process to identify and prioritize contaminated sites
that pose the greatest risk to human health and the
environment.Progress to date includes:Evaluated a variety of
programs;PROFEPA began a list working with 17 states;DGGIMAR
created a list of 31 sites.
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Mexicos List of ConcernsMining (exploration,
production)Petroleum (exploration, production, sales)Manufacturing
(cement, electronics, paper)Energy (production,
conveyance)Transport (trucks, railroads, bus, shipping)Agriculture
(pesticide use, solid waste)Landfill (Solid and hazardous waste)
Prioritize contaminated sites based on whether they are: Known PRP
Abandoned Complex sites
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Other SitesExamples of possible other site categories
Agriculture and Mining:Large landscape impacted;Prevention
practices being implemented today;Costly and length
process;Policies still require work.These sites are also important,
but need to: Create manageable work-loads so that resources are not
invested into a small number of sites. Allow time to develop
experience and policies to address the more complex remedial
program issues for these sites.
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SEMARNAT is Already Making Risk Management Decisions that Could
be Considered in the Other Sites Category:Prioritized remediation
of heavy metals in mine tailings adjacent to a small community in
Sonora.
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Prioritize Contaminated Sites With a Known Release and a Pathway
That Poses the Greatest Threat of ExposurePathways to surface
waterFreshwater wetlands, rivers, lakesCoastal marine, estuaries,
inter-tidal wetlandsPathways to airIndoor residentialOtherPathways
to groundwaterLarge potable drinking waster
sourcesOtherAdvantages/DisadvantagesRisk-based approach that
addresses both human health and ecological risksNon-specific
ranking approachOther ConsiderationsState inputPublic
InputSensitive or economically important ecosystems
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Manage Remediation Based OnIndustry Sector ChemicalsThere are a
lot of chemicals: Decide which ones are at levels that pose a
concernTypical Industry-Sector Chemicals Mining heavy
metalsPetroleum hydrocarbonsManufacturing heavy metals,
solventsEnergy heavy metals, hydrocarbons, solventsTransport
hydrocarbons, solventsAgriculture pesticides, organic
wastesLandfill metals, solvents, pesticides
Look for patterns:Chemical types and concentrations, Fate and
transport behavior, Similarities landscapeCreating industry-sector
groupings maximizes opportunity to create
templates/programs:assessments, presumptive
remediesAdvantages/disadvantages:Potential misses, but typically
small riskExpedite progress, thus overall prevents risksSaves
resources by being more effective
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Petroleum Refineries, Chemical-processing, ManufacturingAbove
and Underground Storage Tanks Federal/state owners/operatorsOil
productionAirportsRailroadsHarborsMiningHeavy metalsErosion
controlManage Remediation Based on Industry-Sector Create sub-lists
based on patterns of Behavior or Industry Sector Activity Interim
listing: Place a facility on notice if there is a potential concern
based on exposure pathways and chemicals being used Final listing:
List a facility if you obtain information that affirms your
concern
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Promote Early Risk Reduction and Site Stabilization at All
Contaminated SitesImmediate (Emergency) ResponseChemical or oil
spillsOther chemical releasesNear-term Risk Reduction-Stabilization
MeasuresProvide alternative drinking waterPlace a secure
barrierRemove wastes posing the highest risksPermanently or
temporarily move peopleBegin working on long-term cleanup remedy,
concurrently or after risk reduction or stabilization is done
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Promote Early Risk Reduction and Site Stabilization at All
Contaminated SitesEarly risk reduction and site stabilization
measures Expedite management of glaring risks. Government has more
flexibility to make decisions.Long-term Remedial ActionsRequire a
base-line risk assessment and an assessment of how the proposed
remedies reduce or eliminate risk based on a variety of
criteria.Requires greater investment of resources to formulate and
implement, often requiring long-term monitoring.Requires a more
formal decision-making processConsider land-end use and promote
land revitalization
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Border 2012 Program Binational Guidance on Contaminated Site
Clean-up and Revitalization
Process for Cleanup and Revitalization:Establish objectives and
a decision-making framework;Consider interim and final cleanup
needs;Optimize reuse through economic incentives and legal
protections for redevelopment;Provide for early and meaningful
public participation.Waste Policy Forum draft final work in
progress
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Promote Early Risk Reduction & Site Stabilization
ActionsSEMARNAT is Already Using This Risk Management Approach
Metales y DerivadosLead battery recycling smelterUS owner,
operated 1986-1994, abandoned 7000 -10,000 tons
lead-wasteIndustrial zone
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Promote Early Risk Reduction &Site Stabilization
ActionsSEMARNAT is Already Using This Risk Management
ApproachMetales y Derivados CleanupAccomplishmentsFour-phase
remedial planRemoval/Stabilization action -2000 tons of waste
disposedCapping remedy underwayDrums & Sacks RemovedInterim
TarpsAccess restricted
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Overview of US Programs to Address Contaminated SitesRCRA a
program for existing sites:Lists facilities but does not rank
them;Set goals to prioritize resources;Industry funded
cleanups;Federal oversight of State-led cleanups.Superfund a
program for abandoned sitesRanks sites to qualify access to
funding;Government funded cleanup, but with provision for
cost-recovery;Federal Facilities Agreement tool.
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Overview of RCRA ProgramRCRA is a program to manage solid and
hazardous waste.
Key hazardous waste components of the program:Defines a
hazardous wasteIssues operating permitsHazardous waste
generatorsTreatment, storage, or disposal facilities Tracks the
generation of hazardous waste (manifests)
RCRA has a four-phase Corrective Action (CA) Program:RCRA
Facility AssessmentRCRA Facility InvestigationCorrective Measures
Study (CMS), andCorrective Measures Implementation (CMI)
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Corrective Action ProgramWhen is corrective action (CA)
required?When applying for a permit,Upon discovering a release,
orUpon discovering other SWMU or releases.How many facilities are
subject to cleanup under RCRA? Currently about 6,900
facilitiesAbout 3,746 have CA underway or will need to. Facility
owner/operators (including federal, state, and local Gov) are
responsible for implementing corrective actionsFor more information
see web
page:http://www.epa.gov/epaoswer/hazwaste/ca/facility.htm#2020
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2020 Corrective Action Universe: 3,746 Facilities Sorted by EPA
Region, State, County, and CityRegion State County City EPA ID
Facility Name Remedy Construction3358 9 AZ Maricopa Phoenix
AZT050010180 Onyx Environmental Services Loc3359 9 AZ Maricopa Phx
AZD049318009 Clean Harbors Arizona Llc3360 9 AZ Maricopa Tempe
AZD085459535 Goodrich Turbomachinery Products3361 9 AZ Maricopa
Tolleson AZD980735500 World Resources Co.3362 9 AZ Maricopa Tonopah
AZT000624429 Aps Company - Pvngs3363 9 AZ Mohave Lake Havasu
AZD041458555 Mcculloch Facility3364 9 AZ Pima Davis Monthan
AZ4570024055 Usaf Davis Monthan Air Force Base3365 9 AZ Pima Marana
AZD980818165 Evergreen Air Center3366 9 AZ Pima Tucson
AZD980880819Esco remedy constructed3367 9 AZ Pima Tucson
AZD000819615 University Of Arizona3368 9 AZ Pima Tucson
AZD980892897 Safety Kleen Systems Inc3369 9 AZ Pima Tucson
AZT000623702 Ibm Corporation3370 9 AZ Pinal Coolidge AZD081705402
Heritage Environmental Srvcs Llc3371 9 AZ Pinal Oracle AZD980665814
University Of Arizona Page Ranch3372 9 AZ Pinal Red Rock
AZT050010453 Aps Saguaro Power Plant3373 9 AZ Santa Cruz Nogales
AZT000612135 Conn-Selmer Inc3374 9 AZ Yuma Yuma AZ5213820991 Us
Army Garrison Yuma Proving Ground3375 9 AZ Yuma Yuma AZR000037382
Barry M. Goldwater Range Wstrn Half3376 9 CA Alameda Alameda
CA1170090012 Cso-Sfba, Alameda Point Annex (Formally3377 9 CA
Alameda Berkeley CA4890008986 Lawrence Berkeley National
Laboratory3378 9 CA Alameda Berkeley CAD009110867 Courtaulds
Aerospace (Desoto)3379 9 CA Alameda Berkeley CAD027909886 Alcan
Ingot & Powders3380 9 CA Alameda Fremont CAD000051433 New
United Motor Manufacturing, Inc.3381 9 CA Alameda Fremont
CAD009152364 Henkel Surface Technologies3382 9 CA Alameda Livermore
CA2890012923 Sandia National Laboratories3383 9 CA Alameda Newark
CAD009147000 Fmc Corporation3384 9 CA Alameda Newark CAD056197601
Romic Environmental Technologies Corp3385 9 CA Alameda Newark
CAD066562521 Ashland Chemical Co3386 9 CA Alameda Newark
CAD074644659 Newark3387 9 CA Alameda Newark CAD980887418 Evergreen
Oil, Inc.3388 9 CAAlameda Oakland CA4170090027 Fleet And Industrial
Supply Ctr
This is public
informationhttp://www.epa.gov/epaoswer/hazwaste/ca/facility.htm#2020
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Prioritizing Resources: RCRANo ranking: To prioritize resources,
EPA established specific short-term goals for the 1,968
highest-priority facilities on the current RCRA Cleanup
Baseline.Other steps: Create solid waste management units (SWMUs)
to facilitate management
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Overview of Superfund ProgramWhy Superfund? Provides for
national emergency response Provides government witht the resources
to remediate abandoned sites or those that have a recalcitrant
PRPMakes responsible parties pay via a financial recovery
mechansimEstablished a strong incentive to prevent chemical
releases because of liability clauseA site must be listed in order
to qualify for use of Superfund fundingSuperfund sets priorities
for use of the fund based on ranking using criteria in the hazard
ranking system.
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Prioritizing Resources: SuperfundThe HRS score for a site is
determined by evaluating four pathways of potential human exposure:
Ground water migration (drinking water); Surface water migration
(drinking water, human food chain, and environmental); Soil
exposure (resident population and nearby population); and Air
migration (population, sensitive environments). Any site scoring
28.5 or above is eligible for the National Priorities LIst.
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Recommendations for Setting PrioritiesPrioritize remedial
programs based on: Sites with a known responsible party
(owner/operator);Abandoned sites;Create other sub-lists as
necessary to create a manageable work-load (ranking not always
necessary to set priorities).Prioritize based on a known release
and a pathway that poses the greatest threat of exposure.Facilitate
management based on chemicals associated with
industry-sectors.Promote early risk reduction and site
stabilization at all contaminated sites.
*Facilitate public involvement it will take longer, but will be
provide long-term benefits
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THANK YOU!
Set priorities to prevent new contaminated sites by listing
contaminated sites with a viable responsible party: you want a
program that will prevent new contaminated sites and you want to
work with PRPs while they have the resources to implement
corrective actions. Prioritize contaminated sites with a known
release and a pathway that poses greatest threat of
exposure:Pathway to surface water wetland, riversPathway to air
indoor airPathway to groundwater drinking water aquifersFocus on
chemicals of concerns: you want to invest time on the chemicals
that pose the greats risk to human health and the
environment.Prioritize remedial activities at contaminated sites
where early actions will reduce human or environmental risks: you
want to take actions as soon as possible to begin to reduce risks
and take the time to implement the longer-term remedies. Removal,
interim actions, long-term remedyPromote land revitalization since
this will increase cost-effectiveness and provide opportunities for
industry-government to increase land developmentFacilitate
transparency and public comment: it will take longer, but the
benefits will be great. You want to increase confidence in the
agencies that are conducting the work by sharing the basis for
decisions. Create a manageable workload: some of the most
worthwhile actions would be to make policy changes rather than
trying to cleanup legacy wastes (i.e. mining, agriculture). Select
a few sites to begin progress, based on the criteria of sites
posing the greatest risk. HRS: very long, complicated, and resource
intensivePROFEPA: does not consider human or ecosystem
risksPan-American: considers HH risk only.GTZ/Brazil: useful for
urban, but not agriculture or mining sitesUASLP: does not consider
ecological risksINE and DGGIMAR: created SISCO w/ 31
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Set priorities to prevent new contaminated sites by listing
contaminated sites with a viable responsible party: you want a
program that will prevent new contaminated sites and you want to
work with PRPs while they have the resources to implement
corrective actions. Prioritize contaminated sites with a known
release and a pathway that poses greatest threat of
exposure:Pathway to surface water wetland, riversPathway to air
indoor airPathway to groundwater drinking water aquifersFocus on
chemicals of concerns: you want to invest time on the chemicals
that pose the greats risk to human health and the
environment.Prioritize remedial activities at contaminated sites
where early actions will reduce human or environmental risks: you
want to take actions as soon as possible to begin to reduce risks
and take the time to implement the longer-term remedies. Removal,
interim actions, long-term remedyPromote land revitalization since
this will increase cost-effectiveness and provide opportunities for
industry-government to increase land developmentFacilitate
transparency and public comment: it will take longer, but the
benefits will be great. You want to increase confidence in the
agencies that are conducting the work by sharing the basis for
decisions. Create a manageable workload: some of the most
worthwhile actions would be to make policy changes rather than
trying to cleanup legacy wastes (i.e. mining, agriculture). Select
a few sites to begin progress, based on the criteria of sites
posing the greatest risk. HRS: very long, complicated, and resource
intensivePROFEPA: does not consider human or ecosystem
risksPan-American: considers HH risk only.GTZ/Brazil: useful for
urban, but not agriculture or mining sitesUASLP: does not consider
ecological risksINE and DGGIMAR: created SISCO w/ 31 sitesSet
priorities to prevent new contaminated sites by listing
contaminated sites with a viable responsible party: you want a
program that will prevent new contaminated sites and you want to
work with PRPs while they have the resources to implement
corrective actions. Prioritize contaminated sites with a known
release and a pathway that poses greatest threat of
exposure:Pathway to surface water wetland, riversPathway to air
indoor airPathway to groundwater drinking water aquifersFocus on
chemicals of concerns: you want to invest time on the chemicals
that pose the greats risk to human health and the
environment.Prioritize remedial activities at contaminated sites
where early actions will reduce human or environmental risks: you
want to take actions as soon as possible to begin to reduce risks
and take the time to implement the longer-term remedies. Removal,
interim actions, long-term remedyPromote land revitalization since
this will increase cost-effectiveness and provide opportunities for
industry-government to increase land developmentFacilitate
transparency and public comment: it will take longer, but the
benefits will be great. You want to increase confidence in the
agencies that are conducting the work by sharing the basis for
decisions. Create a manageable workload: some of the most
worthwhile actions would be to make policy changes rather than
trying to cleanup legacy wastes (i.e. mining, agriculture). Select
a few sites to begin progress, based on the criteria of sites
posing the greatest risk.
