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 by
Emily Pimentel
U.S. Environmental Protection Agency Region 9
pimentel.emily@epa.gov
Presentation Overview
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Risk 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.
Recommendations for Setting
Priorities
1.
Prioritize remedial programs based on:
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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.
SEMARNAT’s Goal:
To establish a process to identify
and prioritize contaminated sites
that pose the greatest risk to
human health and the
environment.
Risk Defined
“The combination of the
probability or frequency of
occurrence of a defined hazard
and magnitude of the
consequences of the
occurrence.”
Risk Assessment
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“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.”
Risk Management
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United States National
Academy of Sciences
Risk Assessment
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
For those of you who
are more visual!
Risk
Perception
Risk
Assessment
Risk
Management
Risk Communication Challenges
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Due 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/Engineers
Decision-makers
Stakeholders
Major Concerns of Traditional
Risk Ranking Models
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Risk alone should not predominate decisionmaking.
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 consideration
of social and political factors is typically not provided
Recommendations for Setting
Priorities for Remediation of
Contaminated Sites
1.
Prioritize remedial programs based
on:
•
•
•
2.
3.
4.
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.
A Review of What Mexico Wants
and Progress Made
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SEMARNAT’s 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;
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PROFEPA began a list working with 17
states;
DGGIMAR created a list of 31 sites.
Universe of
Contaminated Sites
Abandoned Sites
Sites with a
Known Owner/Operator
Other Sites
Universe of Contaminated Sites
Advantages/Disadvantages
Abandoned
• No funding
• No owners to work with
• Spend resources looking for owners
• Spend resources conducting ranking
• Little incentive for states to participate
Known
owners
• Known owners to work with
• Available funding
• Opportunity to prevent new
contamination
• Greater Incentives for states to
participate
Other sites
• Agriculture
• Mining
• Sites that may represent complex
legacy issues
• Site that may still require new policies
to address root cause
• Resource intensive
Prioritize contaminated
sites based on whether
they are:
• Known PRP
• Abandoned
• Complex sites
Mexico’s List of Concerns
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Mining (exploration,
production)
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Petroleum (exploration,
production, sales)
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Manufacturing (cement,
electronics, paper)
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Energy (production,
conveyance)
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Transport (trucks,
railroads, bus, shipping)
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Agriculture (pesticide use,
solid waste)
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Landfill (Solid and
hazardous waste)
Other Sites
Examples of possible “other site” categories
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Agriculture and Mining:
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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.
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.
Prioritize Contaminated Sites With a
Known Release and a Pathway That
Poses the Greatest Threat of Exposure
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Pathways to surface
water
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Indoor residential
Other
Pathways to
groundwater
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Large potable drinking
waster sources
Other
Advantages/Disadvantages
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Pathways to air
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Freshwater wetlands,
rivers, lakes
Coastal marine,
estuaries, inter-tidal
wetlands
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Risk-based approach that
addresses both human
health and ecological risks
Non-specific ranking
approach
Other Considerations
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State input
Public Input
Sensitive or economically
important ecosystems
Manage Remediation Based On
Industry Sector Chemicals
There are a lot of chemicals: Decide which ones are at levels that pose a concern
Typical Industry-Sector
Chemicals
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Mining – heavy metals
Petroleum –
hydrocarbons
Manufacturing – heavy
metals, solvents
Energy – heavy metals,
hydrocarbons, solvents
Transport –
hydrocarbons, solvents
Agriculture – pesticides,
organic wastes
Landfill – metals,
solvents, pesticides
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Look for patterns:
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Chemical types and
concentrations,
Fate and transport behavior,
Similarities landscape
Creating industry-sector
groupings maximizes
opportunity to create
templates/programs:
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assessments,
presumptive remedies
Advantages/disadvantages:
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Potential misses, but typically
small risk
Expedite progress, thus overall
prevents risks
Saves resources by being
more effective
Manage Remediation Based on
Industry-Sector
Create sub-lists based on patterns of Behavior or Industry Sector Activity
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Petroleum Refineries,
Chemical-processing,
Manufacturing
Above and Underground
Storage Tanks
Federal/state
owners/operators
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Oil production
Airports
Railroads
Harbors
Mining
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Heavy metals
Erosion control
• 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
Promote Early Risk Reduction and
Site Stabilization at All
Contaminated Sites
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Immediate (Emergency) Response
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Near-term Risk Reduction-Stabilization
Measures
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Chemical or oil spills
Other chemical releases
Provide alternative drinking water
Place a secure barrier
Remove wastes posing the highest risks
Permanently or temporarily move people
Begin working on long-term cleanup
remedy, concurrently or after risk
reduction or stabilization is done
Promote Early Risk Reduction and
Site Stabilization at All
Contaminated Sites
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Early risk reduction and site stabilization
measures
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Expedite management of “glaring” risks.
Government has more flexibility to make decisions.
Long-term Remedial Actions
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Require 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 process
Consider land-end use and promote land revitalization
Border 2012 Program Binational
Guidance on Contaminated Site
Clean-up and Revitalization
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Process for Cleanup and Revitalization:
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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
Promote Early Risk Reduction &
Site Stabilization Actions
SEMARNAT is Already Using This Risk Management Approach
Metales y Derivados
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Lead battery recycling
smelter
US owner, operated 19861994, abandoned
7000 -10,000 tons leadwaste
Industrial zone
Promote Early Risk Reduction &
Site Stabilization Actions
SEMARNAT is Already Using This Risk Management Approach
Metales y Derivados Cleanup
Accomplishments
 Four-phase remedial plan
 Removal/Stabilization action
-2000 tons of waste disposed
 Capping remedy underway
Drums & Sacks Removed
Access restricted
Interim Tarps
Overview of US Programs to
Address Contaminated Sites
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RCRA a program for existing sites:
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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 sites
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Ranks sites to qualify access to funding;
Government funded cleanup, but with provision
for “cost-recovery”;
Federal Facilities Agreement tool.
Overview of RCRA Program
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RCRA is a program to manage solid and hazardous waste.
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Key hazardous waste components of the program:
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Defines a hazardous waste
Issues operating permits
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Hazardous waste generators
Treatment, storage, or disposal facilities
Tracks the generation of hazardous waste (“manifests”)
RCRA has a four-phase Corrective Action (CA) Program:
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RCRA Facility Assessment
RCRA Facility Investigation
Corrective Measures Study (CMS), and
Corrective Measures Implementation (CMI)
Corrective Action Program
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When is corrective action (CA) required?
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When applying for a permit,
Upon discovering a release, or
Upon discovering other SWMU or releases.
How many facilities are subject to cleanup
under RCRA?
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Currently about 6,900 facilities
About 3,746 have CA underway or will need
to.
Facility owner/operators (including federal,
state, and local Gov) are responsible for
implementing corrective actions
For more information see web page:
http://www.epa.gov/epaoswer/hazwaste/ca/f
acility.htm#2020
2020 Corrective Action Universe: 3,746
Facilities Sorted by EPA Region, State,
County, and City
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Region State
3358 9 AZ
3359 9 AZ
3360 9 AZ
3361 9 AZ
3362 9 AZ
3363 9 AZ
3364 9 AZ
3365 9 AZ
3366 9 AZ
3367 9 AZ
3368 9 AZ
3369 9 AZ
3370 9 AZ
3371 9 AZ
3372 9 AZ
3373 9 AZ
3374 9 AZ
3375 9 AZ
3376 9 CA
3377 9 CA
3378 9 CA
3379 9 CA
3380 9 CA
3381 9 CA
3382 9 CA
3383 9 CA
3384 9 CA
3385 9 CA
3386 9 CA
3387 9 CA
3388 9 CA
County City
Maricopa Phoenix AZ
Maricopa Phx AZ
Maricopa Tempe AZ
Maricopa Tolleson AZ
Maricopa Tonopah AZ
Mohave Lake Havasu AZ
Pima Davis Monthan AZ
Pima Marana AZ
Pima Tucson AZ
Pima Tucson AZ
Pima Tucson AZ
Pima Tucson AZ
Pinal Coolidge AZ
Pinal Oracle AZ
Pinal Red Rock AZ
Santa Cruz Nogales AZ
Yuma Yuma AZ
Yuma Yuma AZ
Alameda Alameda CA
Alameda Berkeley CA
Alameda Berkeley CA
Alameda Berkeley CA
Alameda Fremont CA
Alameda Fremont CA
Alameda Livermore CA
Alameda Newark CA
Alameda Newark CA
Alameda Newark CA
Alameda Newark CA
Alameda Newark CA
Alameda Oakland CA
This is public information
EPA ID
T050010180
D049318009
D085459535
D980735500
T000624429
D041458555
4570024055
D980818165
D980880819
D000819615
D980892897
T000623702
D081705402
D980665814
T050010453
T000612135
5213820991
R000037382
1170090012
4890008986
D009110867
D027909886
D000051433
D009152364
2890012923
D009147000
D056197601
D066562521
D074644659
D980887418
4170090027
Facility Name
Remedy Construction
Onyx Environmental Services Loc
Clean Harbors Arizona Llc
Goodrich Turbomachinery Products
World Resources Co.
Aps Company - Pvngs
Mcculloch Facility
Usaf Davis Monthan Air Force Base
Evergreen Air Center
Esco
remedy constructed
University Of Arizona
Safety Kleen Systems Inc
Ibm Corporation
Heritage Environmental Srvcs Llc
University Of Arizona Page Ranch
Aps Saguaro Power Plant
Conn-Selmer Inc
Us Army Garrison Yuma Proving Ground
Barry M. Goldwater Range Wstrn Half
Cso-Sfba, Alameda Point Annex (Formally
Lawrence Berkeley National Laboratory
Courtaulds Aerospace (Desoto)
Alcan Ingot & Powders
New United Motor Manufacturing, Inc.
Henkel Surface Technologies
Sandia National Laboratories
Fmc Corporation
Romic Environmental Technologies Corp
Ashland Chemical Co
Newark
Evergreen Oil, Inc.
Fleet And Industrial Supply Ctr
http://www.epa.gov/epaoswer/hazwaste/ca/facility.ht
m#2020
Prioritizing Resources: RCRA
No 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 (SWMU’s) to
facilitate management
Overview of Superfund Program
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Why Superfund?
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Provides for national emergency response
Provides government witht the resources to
remediate abandoned sites or those that have a
recalcitrant PRP
Makes responsible parties pay via a financial
recovery mechansim
Established a strong incentive to prevent chemical
releases because of “liability” clause
A site must be “listed” in order to qualify for use
of “Superfund” funding
Superfund sets priorities for use of the fund based
on ranking using criteria in the hazard ranking
system.
Prioritizing Resources:
Superfund
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The 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.
Recommendations for Setting
Priorities
1.
Prioritize remedial programs based on:
•
•
•
2.
3.
4.
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!