EPA Guidance For Superfund National Policy Managers

On October 7, 1999, the Director of EPA's Office of Emergency and Remedial Response, Steven Luftig, issued a final guidance to Superfund national policy managers at all EPA regions entitled "Ecological Risk Assessment and Risk Management Principles for Superfund Sites." Its stated purpose is to help Superfund risk managers make ecological risk management decisions that are based on sound science, consistent across regions, and present "a characterization of site risks that is transparent to the public." The guidance includes six principles which are to be considered by risk managers when making ecological risk management decisions. The principles are as follows:

1. Superfund's goal is to reduce ecological risks to levels that will result in the recovery and maintenance of healthy local populations and communities of biota. Therefore the response actions selected should result in the recovery and/or maintenance of healthy local populations or communities of ecological receptors that are or should be present at or near the site.
   
2. Coordinate with federal, tribal, and state natural resource trustees. EPA investigations of risk and trustee investigations of resource injuries should be coordinated to most efficiently use federal and state monies and to avoid duplication of efforts.
   
3. Use site-specific ecological risk data to support cleanup decisions. The site-specific information can include plant and animal tissue residue data, toxicity test data, bio-availability factors, and population-or community-level effects studies.
   
4. Characterize site risks. Site risks are to be characterized in terms of (a) magnitude, i.e., the degree of the observed or predicted responses of receptors to the range of contaminant levels; (b) severity, i.e., how many and to what extent the receptors may be affected; (c) distribution, i.e., areal extent and duration over which the effects may occur; and (d) the potential for recovery of the affected receptors.
   
5. Communicate risks to the public. Managers are to clearly communicate to the public the scientific basis and ecological relevance of the assessment endpoints used in site risk assessments and the relationship between the effect or exposure measures used to determine if there are any adverse effects to any of the assessment endpoints.
   
6. Remediate unacceptable eco-risks. Working within the framework of the National Contingency Plan, the goal is to eliminate unacceptable ecological risks due to any release or threat of a release.

The guidance then includes four questions that risk managers and risk assessors should address to facilitate the reaching of sound decisions. They are as follows:

1. What ecological receptors should be protected? Superfund risk assessments should use site-specific assessment endpoints that address chemical specific potential adverse effects to local populations and communities of plants and animals.
   
2. Is there an unacceptable ecological risk at the site? Site specific biological data should be developed in order to determine if there are unacceptable risks.
   
3. Will the cleanup cause more ecological harm than the current site contamination? Even though an ecological risk assessment may demonstrate that adverse ecological effects have occurred or are expected to occur, it may not be in the best interest of the overall environment to actively remediate the site.
   
4. What cleanup levels are protected? The risk assessor can use the same toxicity tests, population or community-level studies, or bioaccumulation models that were used to determine if there was an unacceptable ecological risk to identify appropriate cleanup levels.