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Overview of OSWER's Climate Change Adaptation Plan

Sponsored by: OSWER Center for Program Analysis Delivered: December 4, 2013, 4:00 PM - 6:00 PM, EST (21:00-23:00 GMT)

Instructors:

•

Jennifer Brady, Center for Program Analysis, Office of Solid Waste and Emergency Response ([email protected]) Moderators:

•

Jean Balent, U.S. EPA Technology Innovation and Field Services Division ([email protected]) Visit the Clean Up Information Network online at www.cluin.org

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OSWER’s Climate Change Adaptation Plan December 4, 2013

O S W E R C l i m a t e C h a n g e A d a p t a t i o n W o r k g r o u p m e m b e r s :

H e a d q u a r t e r s ♦

C e n t e r f o r P r o g r a m A n a l y s i s

: J e n n i f e r B r a d y ; ♦

F e d e r a l F a c i l i t i e s

: E l l e n T r e i m e l ; ♦

G e n e r a l C o u n s e l

: D a n i e l S c h r a m m ; ♦

I n n o v a t i o n s , P a r t n e r s h i p s a n d C o m m u n i c a t i o n s

♦

B r o w n f i e l d s

: R a c h e l L e n t z , A n n C a r r o l l ; ♦ : J e f f r e y K o h n ;

C o m p l i a n c e

: E l i s a b e t h F r e e d ; ♦

E m e r g e n c y R e s p o n s e

♦

R C R A

: R i c h a r d C a n i n o , S a r a G o e h l ; : T i f f a n y K o l l a r , S c o t t P a l m e r , J e f f G a i n e s ; ♦

S u p e r f u n d

: C a r l o s P a c h o n , A n n e D a i l e y, S t e v e C h a n g ; ♦

U n d e r g r o u n d S t o r a g e Ta n k s

R e g i o n s ♦

R 1

: A n d r e a B a r b e r y, L i n d a G e r b e r .

: E l s b e t h H e a r n , J o h n P o d g u r s k i , C a r o l K e a t i n g ; ♦

R 2

: R e b e c c a O f r a n e ; ♦

R 3

: M i c k e y Yo u n g , K a t i e M a t t a ; ♦

R 4

: T h o r n e l l C h e e k s , B e n F r a n c o ; ♦

R 6

: C a m i l l e H u e n i ; ♦

R 8

: N a t M i u l l o ; ♦

R 9

: S h a n n o n D a v i s ; ♦

R 1 0

: M i c h e l l e D a v i s , K r i s t i n R y a n .

Agenda

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Overview

•

Plan development process

•

Discussion of climate change impacts, proposed vulnerabilities and criteria for selecting actions

•

Discussion of proposed actions

•

Questions?

6

Overview

OSWER’s Climate Change Adaptation Plan is now available for public comment.

http://epa.gov/climatechange/impacts-adaptation/fed-programs/EPA-impl-plans.html

Comments will be accepted through January 3 in the Federal Register comment system.

http://www.regulations.gov (Docket# EPA-HQ-OA-2013-0568) REMINDER Comments and questions taken during this session will not be entered into the comment system. Please visit regulations.gov and enter your comment by January 3 if you would like it formally considered.

7

Plan Development Process

Agency Adaptation Plan Completed June 2012 Development of OSWER Climate Change Adaptation Plan by OSWER workgroup

Every program office and most Regions participated in the OSWER workgroup

Identified OSWER vulnerabilities and developed criteria Developed proposed actions OSWER Climate Change Adaptation Plan submitted for public comment Public comment period began in November 2013 and closes on January 3, 2014.

8

Climate Change Impacts

Potential climate change impacts considered in OSWER’s Plan, also called climate events, agreed upon by climate experts and included in EPA’s Climate Change Adaptation Plan, are: Increased extreme temperatures Sustained changes in average temperature Sea level rise Decreased permafrost in Arctic regions Increased flood risk Decreased precipitation days, increasing drought intensity Increased frequency and intensity of wildfires Increased heavy precipitation events Increased intensity of hurricanes Image credit: U.S. Global Change Research Program (www.globalchange.gov)

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Characterizing OSWER Vulnerabilities

The workgroup identified 27 unique vulnerabilities.

• Many of the vulnerabilities apply to more than one program.

• List of vulnerabilities was as comprehensive as possible.

• • For example, two types of vulnerabilities are: Surges in waste, particularly from the impacts of extreme events and Impacts to cleanup remedies. Complete vulnerability table found on page 6.

Design and placement of RCRA Treatment, Storage and Disposal facilities, non hazardous Subtitle D landfills, Superfund remedies and municipal recycling facilities may need to change to accommodate climate change impacts.

Hazardous waste permitting requirements may need to be updated to reflect climate change impacts.

Current waste management capacity may be insufficient to handle surges in necessary treatment and disposal of hazardous and municipal wastes, as well as mixed wastes generated from climate events.

Levels of necessary financial assurance at RCRA and CERCLA facilities may need to adjust for increased risks/liabilities at specific facilities that may be directly affected by climate change impacts.

Remediation and containment strategies and materials used in construction may need to be strengthened to reflect changing climate conditions.

Current equipment, scientific monitoring and sampling protocols on sites may no longer be effective and therefore may require adjustments due to climate change impacts. Current assumptions regarding protectiveness of remediation and containment methods may not reflect changing climate impacts.

Spill Prevention Plans may need to be updated due to the significant increases in the incidence of flooding and storm events.

10

Prioritizing Vulnerabilities

In order to prioritize and focus OSWER’s efforts, each vulnerability was evaluated based on a set of criteria, such as scale of impact and EPA’s technical expertise in that area.

A scorecard with a value assigned to each vulnerability for each criteria is found in Appendix B (p. 27).

  Each program developed a score for their program only.

Vulnerabilities were not scored based on their “value” relative other vulnerabilities, but based on only the criteria.

The programs were then able to use the scorecard as a basis for determining what vulnerabilities would be assigned actions.

The next several slides reviews many, but not all, of the proposed actions. The complete list of proposed actions are found in Appendix C (p.31).

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Proposed Actions: Preserving Land Proper Management of Hazardous & Non-Hazardous Wastes This slide includes actions directed at the proper management of non-hazardous and hazardous waste, both routinely and in times of emergency.    Based on outreach to states and tribes, develop recommendations for these stakeholders to incorporate climate change into RCRA Permitting Programs as appropriate.

Prepare Fact Sheets on proper management of wastes/debris associated with large natural disasters.

Continue collaborative development with the Office of Homeland Security on an interactive electronic waste management planning tool to aid federal, state and local emergency planners and managers in development of waste/debris management plans.

- The last two actions also address emergency response, discussed later in the presentation

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Proposed Actions: Preserving Land Reducing Chemical Risks and Releases These actions focus on activities that prevent contamination from occurring.

• • • Incorporate sensitivity for climate change vulnerabilities into oil Spill Prevention, Control, and Countermeasure (SPCC) and Facility Response Plan (FRP) Incorporate into SPCC and FRP guidance the statement of potential vulnerabilities to oil facilities from catastrophic weather events due to climate change. Incorporate sensitivity for climate change vulnerabilities in risk management plan (RMP) inspector training and guidelines.

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Proposed Actions: Restoring Land Cleaning up Sites Many offices in OSWER are involved in cleaning up sites and making sure that contamination is contained. The next two slides feature some of the proposed actions by these offices.

Brownfields

 Update the Analysis of Brownfields Cleanup Alternatives (ABCA) language in the brownfield grant Terms and Conditions to include language that requires recipients take potential changing climate conditions into consideration when evaluating cleanup alternatives.

Superfund

 Share vulnerability screening protocol for regional application. • Develop criteria to identify remedies where performance may be impacted by climate change.    • Develop a methodology to evaluate and ensure remedy protectiveness. Prepare remedy-specific climate change adaptation fact sheets for selected remedies. Identify existing Superfund program processes (Remedial Investigation/Feasibility Study, Record of Decision, Remedial Design/Remedial Action, Five Year reviews, etc.) for implementation of climate change adaptation protocols to ensure continuing protectiveness of current and future remedies. Prepare training materials.

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Proposed Actions: Restoring Land Cleaning up Sites

RCRA Corrective Action

 Develop recommendations for states and tribes to encourage climate change considerations be incorporated into all of their RCRA Corrective Action Programs.

Underground Storage Tanks

 • Work with the Association of State and Territorial Solid Waste Management Officials (ASTSWMO) to gather information on if and how states currently: alter remediation plans in response to changing climate impacts; • • alter site assessments in response to flooding or drought conditions; alter risk factors and rankings in response to flooding or drought conditions.  • • • Share information among states, tribes, and EPA regions regarding: new or modified investigation strategies and remediation techniques; new or modified assessment techniques; how climate conditions may impact risk-based cleanup factors and rankings.

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Proposed Actions: Emergency Response Several actions related to severe weather event response were highlighted in the earlier waste management slide. This slide features additional emergency response actions, focused on areas other than waste and debris management.

• • •

Underground Storage Tanks

Work with ASTSWMO to gather information on if and how states currently respond to climate-related emergencies (e.g., use of GIS mapping in flood-prone areas). Analyze lessons learned from Hurricanes Katrina (2005) and Sandy (2012) to identify how EPA can help states respond to UST-related hurricane impacts. Share information among states, tribes, and EPA regions regarding emergency response and preparedness (e.g., OUST’s Flood Guide).

• •

Emergency Response

Utilize the National Response Team multi-agency membership (e.g., National Oceanic and Atmospheric Administration, Federal Emergency Management Agency, U.S. Coast Guard) to monitor the state of preparedness. Based on these meetings, evaluate if additional resources and planning exercises will be needed to address the impacts from changes in the frequency and/or severity of extreme weather events.

Incorporate materials on the impacts of climate change as EOC training materials are updated and exercises are planned

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OSWER-Wide Actions

There is information and data that all programs will need to appropriately consider the potential impacts of climate change. Several actions are proposed to ensure this is done uniformly across OSWER.

 Ensure consistent data for mapping.  Remain informed on emerging climate science.  Identify training needs.

Image credit: U.S. Global Change Research Program (www.globalchange.gov).

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Tribes and vulnerable populations

 OSWER acknowledges that climate change impacts will have disproportionate effects on particular communities, demographic groups and geographic locations.

 Providing data and tools is a key component of OSWER’s proposed actions with both tribes and vulnerable populations.

 OSWER will continue to consider other ways in which we can assist or partner in these areas.

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Review – Public Comment Period REMINDER Comments and questions taken during this session will not be formally entered into the system. Please visit regulations.gov and enter your comment if you would like to have it formally considered.

Comments will be accepted through January 3 in the Federal Register comment system.

• • http://epa.gov/climatechange/impacts-adaptation/fed-programs/EPA-impl plans.html

http://www.regulations.gov

(Docket# EPA-HQ-OA-2013-0568)

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Questions?

Jennifer Brady [email protected]

202-566-1701

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Complete list of vulnerabilities

p.1 of 3

Proper Management of Hazardous and Non-Hazardous Wastes

 Design and placement of RCRA Treatment, Storage and Disposal facilities, non-hazardous Subtitle D landfills, Superfund remedies and municipal recycling facilities may need to change to accommodate climate change impacts.

   Hazardous waste permitting requirements may need to be updated to reflect climate change impacts.

Current waste management capacity may be insufficient to handle surges in necessary treatment and disposal of hazardous and municipal wastes, as well as mixed wastes generated from climate events.

Levels of necessary financial assurance at RCRA and CERCLA facilities may need to adjust for increased risks/liabilities at specific facilities that may be directly affected by climate change impacts.

Reducing Chemical Risks and Releases

 Remediation and containment strategies and materials used in construction may need to be strengthened to reflect changing climate conditions.

   Current equipment, scientific monitoring and sampling protocols on sites may no longer be effective and therefore may require adjustments due to climate change impacts. Current assumptions regarding protectiveness of remediation and containment methods may not reflect changing climate impacts.

Spill Prevention Plans may need to be updated due to the significant increases in the incidence of flooding and storm events.

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Complete list of vulnerabilities

p.2 of 3

Restoring Land

 Site characterization and design of cleanups may not reflect changing climate conditions.

  Risk factors and rankings for risk-based cleanup strategies may need to be reassessed based on changing climate conditions.

Changing climate conditions may impact continued remedy effectiveness.

    Remedies that are “complete” or are long-term actions may no longer be protective and resilient as climate conditions change at site.

Increased contaminant migration may lead to boundary changes at current sites or creation of new sites.

Changes in climate conditions may alter assumptions about contaminant form/volatility.

Current scientific monitoring and sampling protocols on sites may no longer be effective.      Safety procedures on sites may not reflect likelihood or intensity of surrounding conditions.

Availability of utilities and transportation infrastructure may be limited as a result of increased impacts to those systems.

Current assumptions regarding protectiveness of remediation and containment methods may not reflect changing climate impacts.

Periodic evaluations of implemented remedies may not incorporate all climate change impacts, including changes in frequency and intensity that may impact remedy effectiveness.

Use of natural resources impacted by sites may change as a result of increased need, resource scarcity, or compromised resources.

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Complete list of vulnerabilities

p.3 of 3     

Emergency Response

Current levels of administrative, enforcement, and emergency response staff may be insufficient to cover needs if number of extreme events increase.

Sufficient capability and capacity for conducting necessary lab analysis following significant weather events may not be available.

Current waste management capacity, including interim capacity, may be insufficient to handle surges in necessary treatment and disposal of hazardous and municipal wastes, as well as mixed wastes generated from climate events.

Training needs (both current and future) are likely to increase in order to meet the increase demand for response actions.

Existing emergency planning currently required or employed by OSWER may not sufficiently consider elevated risks from multiple climate impacts.

Tools, Data, Training and Outreach

    Outreach and educational materials may need to be developed for owners and operators with facilities in areas of changing environmental conditions.

Revised training protocols and SOPs that take into account climate change impacts and what to look for may need to be developed.

Reliable data sources to use in site-specific analyses may need to be identified Models, decision tools, site environmental data and information feeds may need to be updated to reflect changing climate conditions

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