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 Pimentel

U.S. Environmental Protection Agency Region 9pimentel.emily@epa.gov

Presentation Overview

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 SettingPriorities

1. Prioritize remedial programs based on:• Sites with a known responsible party (owner),• Sites that are abandoned,• Other sites with complex policy issues.

2. Prioritize contaminated sites with a known release and a pathway that poses greatest threat of exposure.

3. Manage based on chemicals associated with industry-sectors.

4. 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

“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

For those of you whoare more visual!

RiskPerception

RiskAssessment

RiskManagement

Risk Communication Challenges 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

Risk 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

Recommendations for Setting Priorities for Remediation of Contaminated Sites

1. Prioritize remedial programs based on:

• Sites with a known responsible party (owner),

• Sites that are abandoned sites,• Other sites with complex policy issues.

2. Prioritize contaminated sites with a known release and a pathway that poses greatest threat of exposure.

3. Manage based on chemicals associated with industry-sectors.

4. Promote early risk reduction and site stabilization at all contaminated sites.

A Review of What Mexico Wants and Progress Made

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; PROFEPA began a list working with 17

states; DGGIMAR created a list of 31 sites.

Universe of Contaminated SitesAdvantages/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

Mexico’s List of Concerns Mining (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)

Universe ofContaminated Sites

Abandoned Sites

Sites with a Known Owner/Operator

Other Sites

Prioritize contaminated sites based on whether they are:• Known PRP• Abandoned• Complex sites

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.

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.