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Environmental Justice in CWA Effluent Guidelines

Environmental Justice in CWA Effluent Guidelines. Julie Hewitt US EPA/Office of Water/Office of Science and Technology SAB meeting – June 19, 2013. Outline. Brief background on effluent guidelines (ELGs) Past approaches to EJ analyses in ELGs Examples of specific EJ analyses

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Environmental Justice in CWA Effluent Guidelines

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  1. Environmental Justice in CWA Effluent Guidelines Julie Hewitt US EPA/Office of Water/Office of Science and Technology SAB meeting – June 19, 2013

  2. Outline • Brief background on effluent guidelines (ELGs) • Past approaches to EJ analyses in ELGs • Examples of specific EJ analyses • Thoughts on EJ analysis issues

  3. What are Effluent Guidelines? • National technology-based regulations for controlling industrial wastewater discharges to surface waters (direct dischargers) and sewage treatment plants (indirect dischargers). • Many are numerical limits but specific technology not required for compliance. Limits may vary by subcategory, tailored to industrial process • Industry-specific (e.g., pulp & paper, iron and steel). • Incorporated into facility-specific permits. Absent a national effluent guideline, permits requirements are established on a BPJ basis (same factors as guidelines). • Factors used in establishing national effluent guidelines • Availability of technology • Economically achievable • Non-water quality environmental impacts (including energy) • “Such other factors as the Administrator deems appropriate”

  4. Developing an Effluent Guideline • Data collection – questionnaires, plant visits, wastewater sampling • Technology assessment - wastewater characterization, technology performance, compliance costs • Regulatory analysis - economic and environmental impacts, derivation of effluent limits • Options analysis and decision • Notice of Proposed Rulemaking • Public Comments • Revised technology assessment, analysis, and regulatory options • Final rule

  5. Effluent Guideline Development- Working with Stakeholders • Frequent interaction and discussion with stakeholders leads to more complete databases and better-informed decision making. As a result, outreach is a critical component of effluent guideline development • industry • citizen/environmental groups • states (NPDES agencies, etc.) • other federal agencies • local governments

  6. Past Approaches to EJ Analysis • Qualitative inference • Impacts via lost jobs or plant closures • Impacts via cost pass-through to consumers • Compare demographics of areas with facilities to demographics of areas in general (e.g., counties) • Early rules take ‘eyeball’ approach • CAFO rule refinement: compare to rural rather than general population • Later rules use statistical tests of differences • GIS analysis of proximity • Impacts to subsistence fishing

  7. Examples of Specific EJ Analyses • Metal Products & Machinery (2003) • eyeball approach • 316(b) Cooling Water Intakes (2011, prop.) • statistical test of differences, GIS buffers • Oil & Gas Extraction (2001) • Synthetic Based Drilling Fluids subcategory • GIS with index of vulnerability • Pulp & Paper (1998) • dioxin levels in fish tissue and exposure via subsistence fishing in Native American communities

  8. MP&M: Eyeball Approach http://water.epa.gov/scitech/wastetech/guide/mpm/eeba_index.cfm

  9. 316(b): GIS and Statistical Tests • Benefit population: • individuals within 50 miles of a facility, plus • Anglers within 50 miles of a reach near a facility • Comparison of demographics of benefit population vs. state population • State-level observations used to calculate statistical test of differences (one-tail t-test) • Similar to MP&M, states vary • Benefit population is more economically disadvantaged but less racial minority on average than overall population, • Neither difference is statistically significant at 95% confidence level.

  10. SBDF: GIS with EJ Index • SBDF used only in Gulf of Mexico at the time • Zero discharge considered as an option • 15 disposal facilities in TX and LA, via underground injection or land spreading and treatment • Only option with EJ analysis, • Developed by R6: pop density, minority, income • Screening analysis • Does not take fate & transport into account • Buffers of 1 and 50 miles around disposal sites • Likely to have higher risk of exposure • Five facilities result in potential EJ concerns: • Four at 1 mile; two at 50 mile • Used to reject zero discharge as a viable option

  11. Pulp & Paper • Cluster rule issuing regulations under both CWA and CAA • Estimated cancer risk reduction due to reduced dioxin exposure via subsistence fishing for Native Americans on two rivers • Used average fish tissue consumption rates, applied to total tribal populations • Penobscot and Lower Columbia Rivers • An order of magnitude reduction for Penobscot; ten percent reduction for Lower Columbia • Detailed data on fishing was available for these two tribal areas, from surveys in the early 1990s

  12. Issues for EJ Analyses under CWA • Census data is readily available • Population proximity is readily available • Fate and transport requires modeling that can be difficult nationally • Exposure data is much less likely to be available • Subsistence fishing: exposure route is clear, but data on affected population is very limited • Location information can come into play

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