294 



It is important to note that these flaws in the NLJ analysis do not completely 

 explain why the NLJ found cleanup activities take longer at minority sites in some 

 regions. The NLJ has raised an important issue that needs to be examined careful- 

 ly. For this reason, EPA is making a serious commitment to determine whether 

 racial inequities exist in the Superfund program. We are using the most current 

 and reliable data available to study the demography around Superfund sites, and 

 comparing these data with the historic performance of the Superfund program. By 

 this summer, we plan to link minority status with site variables such as time from 

 discovery to first removal activity, and tjrpe of remedy selected to determine wheth- 

 er there are biases in the program. 



In addition, the Agency is taking a proactive approach to equity by providing site 

 decision makers with demographic information early in the site identification proc- 

 ess. We believe that getting this information out early will provide opportunities for 

 EPA to improve communication with members of minority communities. 



Q. 38: What environmental equity strategies are being developed for the Great 

 Lakes region by the Office of Environmental Equity? 



A. 38: The Office of Environmental Equity is particularly concerned with the 

 health effects on minority and low-income human populations resulting from the 

 consumption of contaminated fish. In particulsu-, American Indians, African Ameri- 

 cans, and Asian Americans are believed to be at risk due to their high subsistence 

 and cultural fish consumption rates. In addition, fetuses and nursing infants of 

 mothers who consume contaminated Great Lakes fish are believed to be at risk. The 

 Office of Environmental Ekjuity is addressing equity concerns by coordinating with 

 the Agency for Toxic Substances and Disease Registry's (ATSDR) Great Lakes 

 Human Health Effects Research Program. The goal of this program is to: 



1) Identify human p>opulations residing in the Great Lakes Basin who may be at 

 significantly increased risk of adverse health effects due to higher consumption 

 rates of fish contaminated with pollutants from the Great Lakes and to prevent 

 unreasonable risk of health effects. The Office of Environmental Equity is co- 

 ordinating its involvement with EPA's Office of Water, Region 5 offices, and the 

 Great Lakes National Program Office. 



2) Enhance training and awareness of Federal, Tribal, State and local officials 

 dealing with minority and low-income populations believed to be at significantly 

 increased risk of adverse health effects due to their high subsistence fish con- 

 sumption rates; 



3) Support the collection of demographic and research data which identifies the 

 populations at significantly increased risk and documents the risk and severity 

 of different adverse health effects; 



4) Encourage the dissemination of outreach materials, public notices and public 

 hearings in multiple languages, as appropriate, to make information more ac- 

 cessible to non-English speaking populations living in the Great Lakes Region; 



5) Review and monitor all reports from the Great Lakes Program involving evi- 

 dence of potentially increased health risks to special populations; 



6) Provide consultation to the Great Lakes staff on equity matters. 



Q. 39: Under Superfund, how are submerged sites treated in the hazard ranking 

 system? How many submerged sites are currently on the National Priority List? 



A. 39: The evaluation of sediment contamination at Superfund sites is an area 

 that has received increasing attention as public concerns, health impacts, costs, and 

 challenges of remediation have evolved. The original Hazard Ranking System (HRS) 

 [the primary tool used to support the placement of sites on to the NPL] did not ex- 

 plicitly evaluate contaminated sediments. However, surface water contamination 

 was evaluated and sites with contaminated sediments could be scored under the sur- 

 face water pathway. In revising the HRS, the EPA has made the evaluation of con- 

 taminated sediments more explicit in the following ways: 



• Sediments are evaluated to determine if contaminant levels are above back- 

 ground. If concentrations exceed background levels, additional p>oints are as- 

 signed in the site scoring. 



• Sites that show contamination levels above background levels are also evaluat- 

 ed to determine if concentrations exceed levels that exceed risk/regulation 

 based cleanup goals. These goals include cancer gmd non-cancer risks. 



• Chemicals that have a tendency to bioaccumulate receive additional points 

 within the HRS scoring process. 



The first two bullets reflect evaluation processes that are consistent with the eval- 

 uations that are performed for all pathways in HRS scoring. The consideration of 

 bioaccumulation is also provided for the surface water pathway evaluations as they 

 evaluate water contamination. Thus, the revised HRS provides explicit consider- 

 ation for the evaluation of contaminated sediments. The evaluation of contaminated 



