RE: Risk Reduction

[David James <james.david@epa.gov>]

Lenny Siegel started this thread by mulling over the possibility of doing cleanups based on our best guess of RELATIVE risk reduction, rather than our attempting to reach some notational "absolute" risk reduction.

I've been mulling over the same thing, for various reasons described below -- in fact I'm starting to think this will be the way we're all going to go eventually. A few points:

1)    I'm very glad Lenny Siegel is participating in this dialogue. Siegel served on the original FFERDC panel in the mid 1990's, and from what I can tell he's one of the reasons the FFERDC final report is as good as it is, and has been as influential as it has been.

2)    Siegel's 1998 booklet, "A Stakeholder's Guide to the Cleanup of Federal Facilities," [ order it at http://www.cpeo.org/pubs/index.html ] serves as a useful commentary and extension of the FFERDC reports. Folks who need a plain language handout explaining the regulatory process might look at this document before they reinvent the wheel.

3)    From the first day the messages on the EPA PIP National Dialogue have struck me as being salted heavily with folks with experience dealing with contamination by the Department of Defense, the Department of Energy, and their major contractors. The severity, complexity, and chronological depth of the contamination of federal facilities and what to do about it seems to have drawn in a disproportionate number of public participation folks from around the country. Maybe it's due in part because all of us know the PRP isn't going anywhere. 

4)     Siegel's suggestion makes the most sense in light of very complex, multi-contaminant problems such as are seen at federal facilities.  The money and staff devoted to cleanup at federal facilities is often determined by factors unrelated to the severity of the environmental problem. Another way of saying that is the "problemholders" are forced each fiscal year to engage in a grave budgetary triage. All subsites needing remediation cannot be addressed every year, and some projects have to be delayed -- and given that reality, there has to be a set of scoring criteria which can inform the difficult choices that must be made. Relative risk reduction, carefully applied, could help make sure that the worst problems -- those posing the greatest risk to affected populations -- are addressed before slower-moving crises are.

5)     I think of Superfund subproject triage as deeply analogous to wilderness preservation. There is a vigorous internal debate among advocates for healthy natural landscapes -- should we focus our limited time and money on enhancing the beauty and ecosystem functions of more-or-less pristine landscapes, or should we focus on restoring highly degraded landscapes to some minimum standard of functionality? The answer, of course, is always that it depends on the specifics of the trade-offs under consideration. But the aggregate of such repeated specific decisions give us the land we've got -- the decisions made have major consequences.

6)    Charles Powers, at Rutgers University, heads an interesting consortium of academic researchers who are struggling with precisely these issues at various DOE sites -- especially Hanford and the Savannah River Site (arguably the most polluted two sites in North America). The Consortium for Risk Evaluation with Stakeholder Participation -- CRESP -- has been very involved in DOE efforts to improve its use of risk in light of the priorities of affected stakeholders. I think many of the folks who've been following this dialogue will find CRESP's work interesting. Visit  

     http://www.cresp.org 

to learn more.  

---
David James
Atlanta
james.david@epa.gov