A Risk-Management Strategy for PCB-Contaminated Sediments (2001) / Chapter Skim
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Making Decisions
Making Decisions
Pages 242-259
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From page 242... ...
Possible management options, both technical and nontechnical, have been explored, and the risks for each option have been assessed as shown in Table 7-3. Now a decision must be made on which management option or combination of options is most likely to achieve the risk-management goals established in stage one of the framework (Chapter 5)
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From page 243... ...
be difficult, not only for the designated decision-makers but also for the other affected parties who will have to implement and live with the decision. Affected parties might assume that the availability of a wealth of site-specif~c data, well-conducted human health and ecological risk assessments, and a thorough review of the risks associated with potential risk-management options will automatically lead to a determination of the most-effective and acceptable risk-management strategy.
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From page 244... ...
on contaminated marine sediments analyzed the regulatory and legal challenges posed by contaminated sediments and provided a summary of the current regulatory requirements for the management of contaminated marine sediments. The analysis and conclusions provided in this NRC report are equally relevant to the risk management of PCB-contaminated sediments and are discussed briefly below.
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From page 245... ...
Fish and Wildlife Service may be the trustee for a natural resource damage assessment and has very different regulatory concerns and needs. However, it may be necessary to complete the risk assessments and determine what management options before all applicable laws are identified.
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From page 246... ...
Site-specific remedies are chosen on the basis of exposure assessments during the feasibility study, and management options are identified on the basis of their capability to reduce risks of exposure to an acceptable level. The final selection of a risk-management strategy now involves choosing the most costeffective alternative, not necessarily the alternative that will have the broadest community acceptance.
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From page 247... ...
Decision analysis, and ultimately, decision-making, at PCB-contaminated sites might require several types of analyses to assess the costs, benefits, effectiveness, and risks associated with each potential management strategy. In this chapter, the committee presents a discussion of decision-making with a description of the RI/FS process as practiced by EPA.
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From page 248... ...
After a public comment period, the risk-management plan, modified as necessary to accommodate the comments received, becomes a Record of Decision if the site is on the Superfund National Priorities List. However, as heard by this committee during the public sessions, this process has not received general approval.
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From page 249... ...
Cost-benefit analysis is effective for evaluating management strategies as it combines risk and cost information to determine the most efficient allocation of resources; however, this type of analysis may be extremely difficult to use when the benefits and costs (risks as well as monetary) are not easy to estimate or calculate (NRC 1997~.
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From page 250... ...
Risk Ranking Any decision on how to manage a PCB-contaminated site should follow from an effort to achieve frank and open discussions among the affected parties after the risks identified for each risk-management option have been reviewed. As discussed in Chapter 7, it is helpful if the various risks for each of the options have been presenter!
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From page 251... ...
When considering possible risk tradeoffs, several comparisons may be made between the target risks and the competing risks based on whether the countervailing risks are to the same or different populations and of the same or different type (Graham and Wiener 1995~. Risk transfer occurs if the target risks are of the same type but moved from one medium to another for
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From page 252... ...
The practicality ranking reflects public acceptance; 0 means no tolerance for an activity, and 4 represents widespread acceptance. The cost ranking is inversely related to the cost of using the control or technology (excluding costs of monitoring and so forth)
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From page 253... ...
Another example might be the economic risks to farmers if their dairy cows are believed to produce PCBtainted milk. The concept of voluntary versus involuntary risks and risks to special groups, such as children and endangered species, must also be factored into consideration of risk tradeoffs.
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From page 254... ...
Aspects include risk and site assessment, economic assessment, and technical feasibility studies to estimate the outcome of possible management strategies (NRC 19971. Decision analysis also incorporates the results of the comparative risk-assessment analyses described above: costbenefit anchor cost-effectiveness analyses, risk ranking, and risk tradeoffs.
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From page 255... ...
Others might be willing to forgo eating fish from the area if habitat for the fish can be restored and a catch-and-release program is instituted. At other sites, it might be imperative to reduce the contamination in the sediment to address immediate human health or ecological risks, and some risk-management strategy using a combination oftechnologies and other options must be implemented quickly.
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From page 256... ...
The committee also recommends that before a management option is selected, a public comment period be allowed to provide an opportunity for those who may not have been involved in the framework process to express their concerns before a decision is made and a risk-management strategy implemented. FACILITATING THE PROCESS Decision-making with respect to PCB-contaminated sediments can be adversarial, in part because of the huge costs associated with many risk-man
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From page 257... ...
In the CERCLAprocess, this dissension can arise curing preliminary discussions at a site to identify potentially responsible parties who might be at substantial financial risk. For example, EPA has recently estimated the costs to General Electric of dredging hot spots in the upper Hudson River to be approximately $490 million.
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From page 258... ...
The risks posed by PCB-contaminated sediments and management efforts extend beyond human health and ecological effects to economic, cultural, and societal impacts that must be factored into any risk-management strategy. The committee appreciates that it might be more difficult for the regulatory agencies to factor in risks other than~human health or ecological impacts, let alone quantify them.
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From page 259... ...
When selecting a risk-management strategy for a site, decision-makers must be sensitive to affected parties' views on the short-term and long-term risks, not only from the PCBs themselves but also from the implementation of any management option. Risk tradeoffs might be required to achieve the risk-management goals.
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