Superfund: EPA Should Take Additional Actions to Manage Risks from Climate Change

Administered by EPA, Superfund is the principal federal program for addressing sites containing hazardous substances. EPA lists some of the most seriously contaminated sites—most of which are nonfederal—on the NPL and has recorded over 500 contaminants, including arsenic and lead, at those sites. Climate change may make some natural disasters more frequent or more intense, which may damage NPL sites and potentially release contaminants, according to the Fourth National Climate Assessment.

GAO was asked to review issues related to the impact of climate change on nonfederal NPL sites. This report examines, among other objectives, (1) what available federal data suggest about the number of nonfederal NPL sites that are located in areas that may be impacted by selected climate change effects and (2) the extent to which EPA has managed risks to human health and the environment from the potential impacts of climate change effects at such sites. GAO analyzed available federal data; reviewed laws, regulations, and documents; interviewed federal officials and stakeholders; visited three nonfederal NPL sites that experienced natural disasters; and compared EPA actions to manage risk to GAO’s six essential elements of enterprise risk management.

Available federal data—from the Environmental Protection Agency (EPA), Federal Emergency Management Agency, National Oceanic and Atmospheric Administration, and U.S. Forest Service—on flooding, storm surge, wildfires, and sea level rise suggest that about 60 percent of all nonfederal National Priorities List (NPL) sites are located in areas that may be impacted by these potential climate change effects. Additional information on these sites can be viewed in an interactive map and downloadable data file, available here (see figure).

EPA’s actions to manage risks to human health and the environment from potential impacts of climate change effects at nonfederal NPL sites align with three of the six essential elements of enterprise risk management GAO previously identified, partially align with two essential elements, and do not align with one essential element. For example, EPA has not taken actions consistent with one essential element because it has not aligned its process for managing risks with agency-wide goals and objectives, which do not mention climate change. Without clarifying this alignment, EPA cannot ensure that senior officials will take an active role in strategic planning and accountability for managing these risks.

GAO is making four recommendations to EPA, including that it clarify how its actions to manage risks at nonfederal NPL sites from potential impacts of climate change align with current goals and objectives. EPA agreed with one recommendation and disagreed with the other three. GAO continues to believe that all four are warranted.

In 2017, Hurricane Harvey dumped an unprecedented amount of rainfall  over the greater Houston area, damaging several Superfund sites that  contain hazardous substances. At one site on the San Jacinto River in  Texas, floodwater eroded part of the structure containing such  substances, including dioxins, which are highly toxic and can cause  cancer and liver and nerve damage. That same year, the Fourth National  Climate Assessment (NCA) stated that many temperature and  precipitation extremes have become more frequent, more intense, or  longer in duration. The NCA reported that climate models are consistent  with these trends continuing, which may make certain natural disasters  more frequent or more intense. Further, the NCA reported that some  climate change effects, including sea level rise and increased coastal  flooding, could lead to the dispersal of pollutants, which could pose a risk  to public health.

The Superfund program—the federal government’s principal program to  address sites with hazardous substances—was established by the  Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA). EPA is responsible for administering the  program. EPA coordinates the cleanup of Superfund sites by identifying  sites potentially requiring cleanup action and placing eligible sites on its  National Priorities List (NPL), which includes some of the most seriously  contaminated sites. As of September 2019, there were 1,336 active sites  on the list, and 421 sites that EPA had determined need no further  cleanup action (deleted sites). About 90 percent of these active and  deleted NPL sites are nonfederal sites, where EPA generally carries out  or oversees the cleanup conducted by one or more potentially  responsible parties (PRP). The other NPL sites—approximately 10  percent—are located at federal facilities, and the federal agencies that  administer those facilities are responsible for their cleanup.

CERCLA authorizes EPA to take various types of cleanup actions to  prevent human and environmental exposure to contamination from  nonfederal NPL sites, including remedial actions, which are long-term  cleanups. As part of the Superfund cleanup process, EPA identifies,  analyzes, and selects remedial actions that seek to protect human health  and the environment and meet site-specific remediation goals. In  September 2015, we found that annual EPA expenditures for remedial  actions at nonfederal NPL sites could be considerable—about $400  million for all such sites. EPA is also required to conduct or oversee  reviews at least every 5 years at sites where remedial actions are  complete but contaminants remain, including at deleted sites, if  contaminants remaining on those sites exceed certain levels. Under  EPA’s regulations, the agency may take additional remedial actions to  address releases at deleted sites if warranted under future conditions.

Climate change may impact Superfund sites in various ways. For  example, extreme precipitation events may impact Superfund sites that  have contaminated sediments in aquatic environments. Specifically, in a  2007 report, the National Research Council noted that buried  contaminated sediments at Superfund sites may be transported during  storms or other high-flow events, becoming a source of future exposure  and risk. As a result of the significant risks posed by climate change and  the nation’s fiscal condition, in February 2013, we added Limiting the  Federal Government’s Fiscal Exposure by Better Managing Climate  Change Risks to our list of areas at high risk for fraud, waste, abuse, and  mismanagement, or most in need of transformation. In March 2019, we  reported on progress to address this high-risk area.

You asked us to review issues related to the impact of climate change on  nonfederal NPL sites. This report examines (1) what available federal  data suggest about the number of nonfederal NPL sites that are located  in areas that may be impacted by selected climate change effects; (2) the  extent to which EPA has managed risks to human health and the  environment from the potential impacts of climate change effects at  nonfederal NPL sites; and (3) the challenges, if any, EPA faces in  managing these risks.

To determine what available federal data suggest about the number of  nonfederal NPL sites that are located in areas that may be impacted by  selected climate change effects, we reviewed the NCA and our prior work  on the Superfund program, climate change, and federal data on potential  climate change effects. We reviewed agency documents and  interviewed officials from agencies including EPA, the Federal Emergency  Management Agency (FEMA), the National Oceanic and Atmospheric  Administration (NOAA), and the U.S. Forest Service. Based on our review  of the NCA, we identified potential climate change effects and, based on  our review of EPA documents, determined which of these effects may  impact nonfederal NPL sites. For these potential effects, we identified  available national-level federal data sets from FEMA, NOAA, and the U.S.  Forest Service on flooding, storm surge, and wildfires, respectively, which  are based on current or past conditions. The NCA reported that flooding,  storm surge, and wildfires will be exacerbated by climate change in some  parts of the country, but we did not identify federal data on the extent to  which these effects would vary from current or past conditions. We also  reviewed NOAA data on sea level rise, which provide information on the  geographic extent of inundation from potential sea level rise of up to 10  feet.

In presenting the results of our analysis, we refer to flooding, storm surge,  wildfires, and sea level rise as potential climate change effects. To the  extent that data were available, we analyzed a range of these potential  climate change effects. For example, we used the maximum extent of  storm surge from Category 1 hurricanes (the lowest possible category) as  well as Category 4 or 5 hurricanes (the highest possible categories), as  modeled by NOAA. The full range of our results can be viewed in an  interactive graphic, which is available here. We focused on a range because, for three of the four effects, we had data on current hazards,  which may become more intense and frequent in the future, according to  the NCA. Additionally, CERCLA directs EPA to give preference to  remedies that would result in the permanent and significant decrease in  toxicity, mobility, or volume of the contamination. According to EPA  officials, remedies at nonfederal NPL sites may have to be operational  indefinitely, during which time the potential effects of climate change may  become more extreme.

We obtained data from EPA’s Superfund Enterprise Management  System—EPA’s system of record for the Superfund program—on the  location and other characteristics of active and deleted nonfederal NPL  sites. We analyzed these data using mapping software to identify  nonfederal NPL sites located in areas that may be impacted by selected  potential climate change effects. To do so, we determined whether there  are areas that may be impacted by flooding, storm surge, wildfires, and  sea level rise within a 0.2-mile radius of the primary geographic  coordinate of each nonfederal NPL site, which we used to represent the  site boundaries. We reviewed this analytical approach with EPA  officials. To assess the reliability of all of the data for our analysis, we,  among other things, assessed the timeliness and accuracy of the data  and related controls and found the data from EPA, FEMA, NOAA, and the  U.S. Forest Service to be sufficiently reliable for our purposes. (See app. I  for more detail on steps we took to assess the reliability of the data.)

To determine the extent to which EPA has managed risks to human  health and the environment from the potential impacts of climate change  effects at nonfederal NPL sites, we examined relevant provisions in  CERCLA, EPA’s implementing regulations, executive orders, and EPA  documents on the cleanup of nonfederal NPL sites. We also reviewed  relevant documents, articles, studies, and other sources that we identified  by searching the websites of relevant agencies and organizations and  article databases, as well as through recommendations from officials and  stakeholders we interviewed. From our prior work, we identified six  essential elements of risk management that we reported could help  agencies anticipate and manage risk.

We compared EPA’s actions to manage risks to human health and the  environment from the potential impacts of climate change effects with  these essential elements of risk management. We analyzed information  on EPA actions by reviewing documents from EPA, the U.S. Global  Change Research Program, and the National Research Council and our  prior work on the Superfund program and climate change that we  identified during our search of documents, articles, and other sources. We  interviewed EPA officials at headquarters and all regional offices. We also  interviewed four stakeholders and representatives of two associations  with knowledge of the nexus between Superfund sites and climate  changes effects to obtain their views about the extent to which EPA has  managed these risks. We identified these stakeholders, such as a law  professor and state environmental officials, from our search of  documents, articles, and other sources and through referrals during  interviews.

In addition, we selected three nonfederal NPL sites from different EPA  regions to illustrate the extent to which EPA is managing these risks: the  American Cyanamid site in Bridgewater, New Jersey (Region 2); the Iron  Mountain Mine site near Redding, California (Region 9); and the San  Jacinto River Waste Pits site in Channelview, Texas (Region 6). We  selected these sites based on (1) EPA regional diversity, (2) variety in  potential climate change effects, and (3) whether they had been affected  by an extreme weather event within the last 10 years. The results from  these illustrative examples are not generalizable to nonfederal NPL sites  that we did not select. We toured each of these sites, reviewed relevant  documents, and interviewed EPA officials and site stakeholders, including  state and local officials, representatives of PRPs, and community  organizations.

To determine the challenges EPA faces in managing risks to human  health and the environment from the potential impacts of climate change  effects at nonfederal NPL sites, we reviewed documents from EPA and  other relevant entities, including from the National Research Council,  which we obtained from EPA officials and stakeholders or identified from  our search of documents, articles, and other sources. We also  interviewed EPA officials at headquarters and all regional offices and  stakeholders. We grouped all challenges we identified into three  categories for reporting purposes: institutional, resource, and technical  challenges. Appendix I describes our objectives, scope, and methodology  in more detail.

We conducted this performance audit from April 2018 to October 2019 in  accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.

CERCLA established the Superfund program to clean up contaminated  sites to protect human health and the environment from the effects of  hazardous substances. CERCLA requires the President to establish  procedures and standards for prioritizing and responding to releases of  hazardous substances, pollutants, and contaminants into the environment  and to incorporate these procedures and substances into the National Oil  and Hazardous Substances Pollution Contingency Plan (National  Contingency Plan).

Under CERCLA, PRPs are liable for conducting or paying for the cleanup  of hazardous substances at contaminated sites. EPA and PRPs can  undertake two types of cleanup actions: removal actions and remedial  actions. Removal actions are usually short-term cleanups for sites that  pose immediate threats to human health or the environment. Remedial  actions are generally long-term cleanups—consisting of one or more  remedial action projects—that aim to permanently and significantly  reduce contamination. Remedial actions can take a considerable amount  of time and money, depending on the nature of the contamination and  other site-specific factors.

EPA’s Office of Superfund Remediation and Technology Innovation,  which is part of the Office of Land and Emergency Management,  oversees remedial actions at NPL sites, including nonfederal NPL sites.  At each nonfederal NPL site, the lead official who is responsible for  compliance with the National Contingency Plan is the remedial project  manager. Management of nonfederal NPL sites is the responsibility of  the EPA region in which a site is located. EPA has 10 regional offices,  and each one is responsible for executing EPA programs within several  states and, in some regions, territories. Figure 1 illustrates EPA’s 10  regions.

The Superfund process begins with the discovery of a potentially  hazardous site or notifications to EPA regarding the possible release of  hazardous substances that may pose a threat to human health or the  environment. EPA’s Superfund remedial cleanup process for nonfederal  NPL sites includes the actions shown in figure 2.

Site assessment. EPA, states, tribes, or other federal agencies  evaluate site conditions to identify appropriate responses to releases  of hazardous substances to the environment. During this process,  EPA or other entities, such as state or tribal agencies, collect data to  identify, evaluate, and rank sites using agency criteria.

Site listing. EPA considers whether to list a site on the NPL based on  a variety of factors, including the availability of alternative state or  federal programs that may be used to clean up the site. Sites that  EPA proposes to list on the NPL are published in the Federal  Register. After a period of public comment, EPA reviews the  comments and makes final decisions on whether to list the sites on  the NPL.

Remedial investigation and feasibility study. EPA or the PRP will  generally begin the remedial cleanup process for an NPL site by  conducting a two-part study of the site. First, EPA or the PRP  conducts a remedial investigation to characterize site conditions and  assess the risks to human health and the environment, among other  actions. Second, EPA or the PRP conducts a feasibility study to  assess various alternatives to address the problems identified through  the remedial investigation. Under the National Contingency Plan, EPA  considers nine criteria, including long-term effectiveness and  permanence, in its assessment of alternative remedial actions.

Record of decision. EPA issues a record of decision that identifies  its selected remedy for addressing the contamination at a site. A  record of decision typically lays out the planned cleanup activities for  each operable unit of the site as well as an estimate of the cost of the  cleanup.

Remedial design and remedial action. EPA or the PRP plans to  implement the selected remedy during the remedial design phase,  and then, in the remedial action phase, EPA or the PRP carries out  one or more remedial action projects.

Construction completion. EPA generally considers construction of  the remedial action to be complete for a site when all physical  construction at a site is complete, including actions to address all  immediate threats and to bring all long-term threats under control.

Postconstruction completion. EPA, the state, or the PRP performs  operation and maintenance for the remedy, if needed, such as by  operating a groundwater extraction and treatment system. EPA  generally performs reviews of the remedy at least every 5 years to  evaluate whether it continues to protect human health and the  environment.

Deletion from the NPL. EPA may delete a site, or part of a site, from  the NPL when the agency and the relevant state authority determine  that no further site response is needed.

Contaminants and Remedies at Nonfederal NPL Sites

Nonfederal NPL sites may include a variety of contaminants, and EPA  may select different types of remedies to clean up the sites. EPA had  recorded more than 500 contaminants at nonfederal NPL sites as of fiscal  year 2014, the most recently available data. According to the Agency for  Toxic Substances and Disease Registry, the highest-priority  contaminants—based on a combination of their prevalence, toxicity, and  potential for human exposure—are arsenic, lead, mercury, vinyl chloride,  and polychlorinated biphenyls. For example, in 2016, the Agency for  Toxic Substances and Disease Registry reported that exposure to arsenic  in drinking water is associated with various health effects, such as  pulmonary and cardiovascular disease, diabetes, and certain cancers.  Contaminants may be found in different media at nonfederal NPL sites. In  2017, EPA reported that groundwater and soil were the most common  contaminated media, including at the nonfederal NPL sites it analyzed.

To clean up a nonfederal NPL site, EPA may select various on-site or off- site remedies. For example, EPA may select on-site remedies that  include treatment as well as those that do not, such as on-site  containment, monitored natural recovery, and institutional controls. In  2017, EPA reported that about a quarter of the decision documents for  sites it analyzed included on-site treatment. EPA may also treat or  dispose the contamination off-site. Examples of off-site treatment and  disposal include incineration and recycling. EPA reported that sites it  analyzed may have various combinations of remedies, including  treatment, on-site containment, off-site disposal, and institutional controls.

Available Federal Data on Flooding, Storm Surge, Wildfires, and Sea Level Rise

Various federal agencies provide nationwide data on flooding, storm  surge from hurricanes, wildfires, and sea level rise. Data on flooding,  storm surge, and wildfires are generally based on current or past  conditions. NOAA models the extent of inundation for various heights of  sea level rise compared to the most recently available data on average  high tide.

FEMA provides flood hazard and risk information to communities  nationwide. Among other information, FEMA provides data on coastal and  riverine flooding in the National Flood Hazard Layer, a database that  contains the most current flood hazard data. Federal law requires FEMA  to assess the need to revise and update the nation’s flood maps at least  every 5 years. Among other uses, the flood hazard data are used for  flood insurance ratings and floodplain management. The National Flood  Hazard Layer identifies areas at the highest risk of flooding, which are  those that have a 1 percent or higher annual chance of flooding. In  some locations, the National Flood Hazard Layer also identifies areas  with 0.2 percent or higher annual chance of flooding, which FEMA  considers to be a moderate flood hazard, as well as other flood hazards.  The National Flood Hazard Layer also identifies areas with minimal flood  hazard, including those with less than 0.2 percent annual chance of  flooding, and unknown flood hazard, including areas FEMA had not  assessed for flood hazards. In 2018, the Technical Mapping Advisory  Council noted that FEMA has produced modernized data (i.e., digital  maps) for areas of the United States where 98 percent of the population  resides, but has not determined the flood hazard for 40 percent of  streams. In general, flood hazards are based on existing conditions in  the watershed and floodplains. However, in certain cases, FEMA may  include flood hazard information that is based on future conditions,  according to FEMA regulations.

NOAA provides estimates of hurricane storm surge using a model called  Sea, Lake and Overland Surges from Hurricanes. Estimates are  available for eastern U.S. coastal areas from Texas through Maine and  other areas affected by storm surge, including Hawaii, Puerto Rico, and  the U.S. Virgin Islands. As of June 2019, NOAA had not modeled storm  surge for the West Coast of the United States or other Pacific islands.  The model takes into account a specific locale’s shoreline, incorporating  bay and river configurations, water depths, bridges, roads, levees, and  other physical features. It estimates the maximum extent of storm surge  at high tide by modeling hypothetical hurricanes under different storm  conditions, such as landfall location, storm trajectory, and forward speed.  NOAA models storm surge from Category 1 through Category 5  hurricanes for the Atlantic coast south of the North Carolina–Virginia  border, the Gulf of Mexico, Puerto Rico, and the U.S. Virgin Islands and  Category 1 through Category 4 hurricanes for the Atlantic coast north of  the North Carolina–Virginia border and Hawaii. According to NOAA’s  website, the model is to be used for educational purposes and awareness  of the storm surge hazard at a city or community level. In accordance with  federal law, the model is also used for other purposes, such as hurricane  evacuation studies. According to NOAA’s website, the agency updates  the model for portions of the shoreline each year to account for, among  other changes, new data and the addition of flood protection devices,  such as levees. The model does not account for future conditions such as  erosion, subsidence (i.e., the sinking of an area of land), construction, or  sea level rise.

The U.S. Forest Service maps wildfire hazard potential based on  landscape conditions and other observations. According to the U.S.  Forest Service, the primary intended use of the wildfire hazard potential  map is to identify priority areas for hazardous fuels treatments from a  broad, national- to regional-scale perspective. The U.S. Forest Service  maps an index of wildfire hazard potential for the contiguous United  States, based on, among other factors, annual burn probabilities and  potential intensity of large fires. The U.S. Forest Service categorizes the  wildfire hazard potential index into five classes of very low, low, moderate,  high, and very high. For example, the U.S. Forest Service designates as  “high” those areas with wildfire hazard potential index from the 85th to the  95th percentile, and “very high” above the 95th percentile. The U.S.  Forest Service also categorizes areas as nonburnable (including  agricultural and developed lands) and water. According to the U.S. Forest  Service, areas with higher values of wildfire hazard potential represent  vegetation that is more likely to burn with high intensity under certain  weather conditions. However, areas with moderate, low, and very low  wildfire hazard potential may still experience wildfire, particularly if they  are near areas that have higher wildfire hazard potential. Wildfire hazard  potential is not a forecast or wildfire outlook for any particular season as it  does not include any information on current or forecasted weather or fuel  moisture conditions.

NOAA models the extent of inundations from various heights of sea level  rise (up to 10 feet above average high tides) for the contiguous United  States, Hawaii, the Pacific islands, Puerto Rico, and the U.S. Virgin  Islands and provides the results in a web mapping tool called the Sea  Level Rise Viewer. NOAA’s guidance on the Sea Level Rise Viewer  states that data are not available for Alaska. The uses of the sea level  rise data include planning and education but not site-specific analysis,  according to a NOAA document. NOAA labels areas as not mapped if  elevation data of sufficient quality for the areas are not available. NOAA  does not model natural processes, such as erosion, subsidence, or future  construction, or forecast how much sea level is likely to rise in a given  area. Rather, for various heights of local sea level rise, NOAA determines  extent of inundation based on the elevation of an area and the potential  for water to flow between areas.

Enterprise risk management is a tool that allows agencies to assess  threats and opportunities that could affect the achievement of their goals.  In a December 2016 report, we updated our 2005 risk management  framework to reflect changes to the Office of Management and Budget’s  Circular A-123, which calls for agencies to implement enterprise risk  management. We also incorporated recent federal experience and  identified essential elements of federal enterprise risk management.

Our December 2016 report states that beyond traditional internal controls,  enterprise risk management promotes risk management by considering  the effect of risk across the entire organization and how it may interact  with other identified risks. Additionally, it addresses other topics, such as  strategy determination, governance, communicating with stakeholders,  and measuring performance. The principles of enterprise risk  management apply at all levels of the organization and across all  functions, such as those related to managing risk to human health and  the environment from the potential impacts of climate change effects at  nonfederal NPL sites. The six essential elements of enterprise risk  management that we identified in our December 2016 report are as  follows:  1.  Align risk management process with goals and objectives.  Ensure that the process maximizes the achievement of agency  mission and results. Agency leaders examine strategic objectives by  regularly considering how risks could affect the agency’s ability to  achieve its mission.  2.  Identify risks. Assemble a comprehensive list of risks—both threats  and opportunities—that could affect the agency’s ability to achieve its  goals and objectives.  3.  Assess risks. Examine risks, considering both the likelihood of the  risk and the impact of the risk to help prioritize risk response.  4.  Respond to the risks. Select risk treatment response (based on risk  appetite), including acceptance, avoidance, reduction, sharing, or  transfer.  5.  Monitor risks. Monitor how risks are changing and whether  responses are successful.  6.  Communicate and report on risks. Communicate risks with  stakeholders and report on the status of addressing the risks.

About 60 Percent of Nonfederal NPL Sites Are Located in Areas That May Be Impacted by Selected Climate Change Effects, According to Available Data

Available federal data on flooding, storm surge, wildfires, and sea level  rise suggest that about 60 percent (945 of 1,571) of all nonfederal NPL  sites are located in areas that may be impacted by one or more of these  potential climate change effects. These data, however, may not fully  account for the number of nonfederal NPL sites that may be in such areas  because (1) federal data are generally based on current or past  conditions; (2) data are not available for some areas; and (3) the NCA  has reported that climate change may exacerbate flooding, storm surge,  and wildfires in certain regions of the United States. In addition, EPA does  not have quality information on the boundaries of nonfederal NPL sites,  which could affect its ability to identify the number of sites that may be  impacted by one or more of these potential climate change effects.

About 60 Percent of Nonfederal NPL Sites Are Located in Areas That May Be Impacted by Selected Climate Change Effects; Additional Sites May Be Impacted in the Future

Available federal data suggest that 945 of 1,571 nonfederal NPL sites, or  about 60 percent, are located in areas that may be impacted by selected  climate change effects—that is, 0.2 percent or higher annual chance of  flooding or other flood hazards, storm surge from Category 4 or 5  hurricanes, high and very high wildfire hazard potential, and sea level rise  of up to 3 feet. The locations of these sites are shown in figure 3; the full  results of our analysis and additional information on these sites is  available in the interactive map and downloadable data file, which can be  viewed at https://www.gao.gov/products/GAO-20-73.

Our analysis, however, may not fully account for the number of  nonfederal NPL sites that may be impacted by the effects of climate  change for various reasons. First, we represented the areas of nonfederal  NPL sites based on a 0.2-mile radius around their primary geographic  coordinates, which may not accurately reflect their area (i.e., they may be  larger or smaller). We did not analyze site-specific information for these  nonfederal NPL sites, including the extent of contamination and location  of remedies. Such site-specific analyses would be needed to determine  whether there is a risk to human health and the environment at  nonfederal NPL sites as a result of these potential climate change effects.

Further, according to the NCA, EPA documents, and interviews with EPA  officials, there may be other climate change effects that could impact  nonfederal NPL sites, such as potential increases in salt water intrusion  (the movement of saline water into freshwater aquifers), drought,  precipitation, hurricane winds, and average and extreme temperatures;  we did not analyze these effects because we did not identify relevant  national-level federal data sets.

We identified 783 nonfederal NPL sites—approximately 50 percent—in  areas that FEMA had identified as having 0.2 percent or higher annual  chance of flooding, which FEMA considers moderate flood hazard, or  other flood hazards, as of October 2018. Of these 783 sites, our  analysis shows that 713—approximately 45 percent of all sites—are  currently located in areas with 1 percent or higher annual chance of  flooding, FEMA’s highest flood hazard category. We provide information  on the number of sites in areas with moderate or other flood hazards  because, according to the NCA, heavy rainfall is increasing in intensity  and frequency across the United States and is expected to continue to  increase, which may lead to an increase in flooding in the future. The full  results of our analysis—which include information on the sites in areas  that may have 1 percent or higher annual chance of flooding, 0.2 percent  or higher annual chance of flooding or other identified flood hazards,  unknown flood hazard or no data, and minimal flood hazard—are  available in our interactive map, which can be viewed here. For example,  there are a number of nonfederal NPL sites in EPA Region 7, where  states experienced record flooding in early 2019. Specifically, as seen in  figure 4, there are 51 sites that are located in areas with 0.2 percent or  higher annual chance of flooding or other identified flood hazards, of  which 42 are located in areas with 1 percent or higher annual chance of  flooding.

Nationwide, the number of nonfederal NPL sites in areas that may be  impacted by flooding currently may be higher than 783. Specifically, 217  nonfederal NPL sites are located in areas that FEMA has not assessed  for flood hazards or that we did not analyze because the data were not  available in a form we could use with our mapping software.

We identified 187 nonfederal NPL sites—12 percent—in areas that may  be inundated by storm surge corresponding to Category 4 or 5  hurricanes, the highest possible category, based on NOAA’s storm surge  model as of November 2018. Of these sites, 102 are located in areas  that may be inundated by a storm surge corresponding to Category 1  hurricanes. We analyzed areas that may be inundated by a storm surge  corresponding to the highest possible category because, according to the  NCA, a projected increase in the intensity of hurricanes in the North  Atlantic could increase the probability of extreme flooding because of  storm surge along most of the Atlantic and Gulf Coast states, beyond  what would be projected based solely on relative sea level rise. However,  the NCA stated that there is uncertainty in the projected increase in  frequency or intensity of Atlantic hurricanes, and other factors may affect  the potential for flooding because of storm surge, such as changes in  overall storm frequency or tracks. The full results of our analysis, which  include information on the number of sites in areas that may be inundated  by storm surge from Category 1 and from Category 4 or 5 hurricanes, are  available in our interactive map, which can be viewed here. In EPA  Regions 2 and 3, where states experienced damage from two major  hurricanes in 2017, there are 87 nonfederal NPL sites located within  areas that may be inundated by storm surge from Category 4 or 5  hurricanes. Figure 5 shows these 87 sites, of which 54 sites may be  inundated by storm surge from Category 1 hurricanes.

Nationwide, the number of nonfederal NPL sites in areas that may be  impacted by storm surge may be higher than 187 because NOAA has not  modeled areas along the West Coast and Pacific islands other than  Hawaii. Further, our analysis did not include other potential impacts  from hurricanes, such as rainfall. Figure 6 shows an example of the  impact of rainfall caused by a hurricane at the American Cyanamid NPL  site.

We identified 234 nonfederal NPL sites—15 percent—located in areas  that have high or very high wildfire hazard potential—those more likely to  burn with a higher intensity, based on a U.S. Forest Service model as of  July 2018. For this analysis, we combined the high and very high wildfire  hazard potential categories; we did not identify the number of sites in  each of these categories separately. We did not analyze areas that  currently have moderate or lower wildfire hazard potential because those  with moderate or lower wildfire hazard potential are less likely to  experience high-intensity wildfire and the extent to which wildfire hazard  potential may change in the future is unknown. The full results of our  analysis on the number of sites in areas with high or very high wildfire  hazard potential are available in our interactive map, which can be viewed  here. As seen in figure 7, there are 22 nonfederal NPL sites in areas with  high or very high wildfire hazard potential in EPA Region 9, a region that  experienced wildfires in 2018, including the highly destructive Carr Fire.

Nationwide, the number of nonfederal NPL sites in areas that currently  have high wildfire hazard potential may be higher than 234 because  wildfire hazard data are only available for the contiguous United States  (i.e., there are no data for Alaska, Hawaii and other Pacific islands,  Puerto Rico, and the U.S. Virgin Islands). According to the NCA, the  incidence of large forest fires in the western United States and Alaska has  increased since the early 1980s and is projected to further increase in  those regions as the climate changes. However, the NCA noted that  analyses regarding the effect of climate change on the incidence of  wildfire in other parts of the United States are not readily available, so it is  unknown how climate change will affect the number of nonfederal NPL  sites in areas rated with high or very high wildfire hazard potential  nationwide. As figure 8 shows, wildfires can pose risks at nonfederal NPL  sites, such as the Iron Mountain Mine site near Redding, California.

We identified 110 nonfederal NPL sites—7 percent—located in areas that  would be inundated by a sea level rise of 3 feet, based on our analysis of  EPA and NOAA data as of March 2019 and September 2018,  respectively. Our analysis shows that if sea level in these areas rose by 1  foot, 97 sites would be inundated. If sea level in these areas rose by 8  feet, 158 sites would be inundated. We also identified 84 nonfederal NPL  sites that are located in areas that may already be inundated at high  tide. We provide the number of sites in areas that may be impacted by  these sea level rise heights because, according to the NCA, global  average sea levels are very likely to continue to rise by at least several  inches in the next 15 years and by 1.0 to 4.3 feet by 2100. Further, the  NCA states that a rise of as much as 8 feet by 2100 cannot be ruled out.  The full results of our analysis, which include information on the number  of sites in areas that may already be inundated at high tide and that would  be inundated if sea level rose by 1 foot, 3 feet, and 8 feet, are available in  our interactive map, which can be viewed here. There are 23 nonfederal  NPL sites located within areas that may be impacted if sea level rose by  up to 3 feet in EPA Region 6, a region that has experienced land loss  because of sea level rise and coastal flooding, according to the NCA. In  addition, as seen in figure 9, 16—or 70 percent—of these sites may  already be inundated at high tide.

Nationally, the number of nonfederal NPL sites that may be inundated by  various heights of sea level rise will vary from the results of our analysis  because different parts of the United States may experience higher or  lower sea level rise than the global average. For example, the NCA states  that sea level rise will be higher than the global average on the East and  Gulf Coasts of the United States and lower than the global average in  most of the Pacific Northwest and in Alaska. As can be seen in figure 10,  sea level rise and other coastal hazards may impact nonfederal NPL  sites, such as the one in the San Jacinto River Waste Pits site in Texas,  parts of which are already under water.

EPA Does Not Have Quality Information on the Boundaries of Nonfederal NPL Sites

EPA does not have quality information on the boundaries of nonfederal  NPL sites, which could affect its ability to identify the number of sites that  may be impacted by one or more of these potential climate change  effects. According to EPA officials, EPA has not validated data on site  boundaries and EPA’s regional offices do not use a consistent geographic  standard, which makes it difficult to produce a national data set. In  general, EPA officials told us that information on the boundaries of NPL  sites has not been a focus at a national level and is not yet subject to  quality standards. For example, EPA officials told us that boundary  information for each NPL site represents the remedial project manager’s  professional judgment and remedial project managers may determine and  record the boundaries of sites differently.

EPA has taken some initial actions to improve the quality of information  on the boundaries of nonfederal NPL sites. In November 2017, the Office  of Superfund Remediation and Technology Innovation issued a directive  to all regional Superfund division directors recommending national  standards for collecting and maintaining geographic information, including  site boundaries. EPA’s 2017 directive notes that using national  standards to collect geographic information, including site boundaries,  promotes EPA’s reporting and analytical efforts to support program  implementation and evaluation. In addition, in May 2018, EPA’s Office of  Land and Emergency Management developed technical guidance for all  its regions and programs for collecting, documenting, and managing  geographic information on Superfund sites, including their boundaries.  EPA officials told us that in 2019 and 2020, the agency plans to move  toward recording site boundaries in a consistent format across regions  and instituting procedures to validate and update them at least annually.

However, EPA officials told us that there is no schedule in place for  completing this effort and they are uncertain when they will complete it  because of competing priorities. By developing a schedule for completing  the standardization and improvement of the quality of the information on  the boundaries of nonfederal NPL sites, EPA could more reasonably  ensure that it would have quality information with which to fully identify  nonfederal NPL sites that are located in areas that may be impacted by  climate change effects.

EPA Has Taken Some Actions to Manage Risks from the Potential Impacts of Climate Change Effects at Nonfederal NPL Sites

EPA’s actions to manage risks from the potential impacts of climate  change effects align with three of the six essential elements of enterprise  risk management. Specifically, for the six essential elements, EPA’s  actions do not align with one essential element, aligning its enterprise risk  management process with goals and objectives; partially align with two  essential elements, assessing risks and responding to risks; and align  with three essential elements, identifying risks, monitoring risks, and  communicating about and reporting on risks. Table 1 shows the alignment  of EPA’s actions with the essential elements of enterprise risk  management.

Aligning Risk Management Process with Goals and Objectives

This essential element calls for agencies to align their risk management  processes with the goals and objectives of the agency, but EPA has not  taken action to clearly align its process for managing risks to human  health and the environment from the potential impacts of climate change  effects at nonfederal NPL sites with agency-wide goals and objectives.  For example, the 2018 to 2022 EPA strategic plan does not include goals  and objectives related to climate change or discuss strategies for  addressing the impacts of climate change effects. Moreover, neither the  fiscal years 2018 to 2019 nor fiscal years 2020 to 2021 national program  manager guidance for EPA’s Office of Land and Emergency Management  mentions climate change among its goals and priorities. In contrast to  the current strategic plan, the 2014 to 2018 EPA strategic plan included  addressing climate change as one of four strategic goals and specifically  discussed climate change as an external factor or emerging issue in the  context of planned, current, and completed cleanups, including at  nonfederal NPL sites. In addition, the fiscal years 2016 to 2017 national  program manager guidance for the office that oversees the Superfund  program listed climate change adaptation as one of four national areas of  focus for the office.

According to an EPA official, when the 2018 to 2022 strategic plan was  drafted, senior agency officials were not aware of the potential risks to the  Superfund program mission from the impacts of climate change effects.  According to this official, senior EPA officials have expressed support for  certain activities related to climate change, such as the work of the Cross- EPA Work Group on Climate Adaptation, but have not issued related  documents or policy statements. Without clarifying how the agency’s  ongoing actions to manage these risks at nonfederal NPL sites align with  current agency goals and objectives, EPA will not have reasonable  assurance that senior officials will take an active role in supporting these  actions, which would help EPA achieve its mission of protecting human  health and the environment.

EPA’s actions to identify risks to human health and the environment from  the potential impacts of climate change effects at nonfederal NPL sites  align with this essential element of enterprise risk management.  Specifically, EPA identified climate change effects that may impact  nonfederal NPL sites—and pose risks to human health and the  environment—in studies and climate change adaptation and  implementation plans. For example, in a 2012 study of adaptation of  Superfund remediation to climate change, EPA identified eight climate  change effects that may impact certain NPL site remedies: flooding, sea  level rise, extreme storms, large snowfall, wildfires, drought, extreme  heat, and landslides. In 2014, EPA issued an agency-wide climate  change adaptation plan, which identified climate change effects that may  impact NPL sites. The same year, EPA issued a climate change  adaptation implementation plan for the office that oversees the Superfund  program that identified nine climate change effects that may impact NPL  sites.

Each of the 10 EPA regional offices identified relevant regional climate  change effects in their 2014 climate change adaptation implementation  plans. For example, the Region 3 plan states that increased flooding  and sea level rise may increase risks of releases of contaminants, salt  water intrusion may impact the performance of remedies, and increased  temperatures may impact vegetation that prevents erosion. Additionally,  five regional offices have conducted or are conducting additional  screening-level studies to identify which climate change effects, if any,  may impact each of the NPL sites in these regions. For example,  Region 10 conducted a study in 2015 that identified, among other effects,  sea level rise and wildfires as potential climate change effects that may  impact NPL sites in the region.

EPA’s actions to assess risks to human health and the environment from  the potential impacts of climate change effects at nonfederal NPL sites  partially align with this essential element. In a 2012 study of adaptation of  Superfund remediation to climate change, EPA assessed the impacts of  eight climate change effects on certain remedies to determine the risk  they presented to the agency’s mission to protect human health and the  environment. EPA issued climate change adaptation implementation  plans for the office that oversees the Superfund program and all regions,  as described above, which assessed potential impacts of climate change  effects. In addition, five EPA regional offices assessed or are assessing  potential impacts of climate change effects on NPL sites in their regions  as a whole, and one of these regions assessed both the impacts and  likelihood of climate change effects, consistent with this essential  element. Specifically, Region 4 identified the sites most likely to face  major climate change risks and then examined these sites in greater  detail. Additionally, Region 3 has developed a mapping tool on climate  change vulnerability that provides site-level assessments of sea level rise,  among other potential impacts.

EPA provides training and direction to remedial project managers—the  lead EPA officials at nonfederal NPL sites—on conducting site-level risk  assessments that incorporate information on potential impacts of climate  change effects. Since 2014, EPA has offered optional training to remedial  project managers and others on integrating climate change into the  Superfund cleanup process. From 2013 through 2015, EPA issued fact  sheets as guidance for assessing the potential impacts of climate change  effects for three types of remedies. According to EPA officials, these  fact sheets constitute the direction that EPA provides to remedial project  managers on assessing risks from climate change effects. EPA plans to  update these fact sheets in 2019 and is also in the process of developing  a compilation of resources for assessing potential flood risks in coastal  areas to inform cleanup and reuse decision-making, according to an EPA  official. In addition, EPA provides resources on climate change on the  Superfund program website, such as links to tools and data on drought  and coastal flooding. EPA also offers technical assistance on  incorporating climate change information into risk assessments to  remedial project managers through groups such as the Contaminated  Sediments Technical Advisory Group and the Cross-EPA Work Group on  Climate Adaptation.

EPA officials in four regions provided us with site-specific examples of  how they used climate change information to assess risks from the  potential impacts of climate change effects, but officials from other  regions stated that they have not always integrated climate change  information into their risk assessments. For example, according to a  record of decision for the site, EPA Region 2 incorporated the potential for  increased storm flow intensities into the model of the Passaic River used  in the remedial investigation and feasibility study at the Diamond Alkali  site in Newark, New Jersey. Conversely, officials in six regions told us  that they have not used climate change projections for flooding or rainfall  in site-level risk assessments. In addition, officials in Region 6 told us that  they do not incorporate potential impacts of climate change effects or  changes in the frequency of natural disasters into their assessments.

EPA officials have not consistently incorporated climate change  information into their assessment of site-level risks because they do not  always have the climate data they need to do so, according to our review  of EPA documents and interviews with EPA officials and stakeholders.  For example, officials in three regions told us that they have not used  rainfall or flood projections because the data are not available or they  were unsure which data to use. In addition, in the record of decision for  the Diamond Alkali site in New Jersey, Region 2 officials stated that they  did not integrate sea level rise information into their storm flow modeling  for the Passaic River at the site because of the uncertainty in expected  future sea level rise values, especially at the regional and local levels. We  reported on similar challenges with climate data in our 2015 report on  climate information, which found that existing federal efforts do not fully  meet the climate information needs of federal, state, local, and private  sector decision makers, and we made a related recommendation in that  report.

Further, current EPA practice for assessing risks at NPL sites does not  always include consideration of climate change, according to agency  documents we reviewed and officials from three regions and a  stakeholder we interviewed. EPA’s climate change adaptation plan noted  that EPA and its partners will need to alter their standard practices—such  as their standard methods for estimating the frequency of floods or runoff  of pollutants into rivers—to account for a continuously changing climate.  The Region 4 climate change adaptation implementation plan, for  instance, noted that preliminary assessments and site investigations are  typically based on historic information, not future projections and  therefore may not fully address risks. Officials in two regions told us that  they do not have direction on how to alter their practices to account for  climate change. For example, officials in Region 2 said they do not have  instructions that identify a particular set of expectations, data, or maps  that they should use when considering future risks from flooding. Officials  in Region 5 told us that they do not have any formal direction on how to  address risks from climate change and are waiting for EPA headquarters  to provide information on how to do so.

According to EPA documents and a headquarters official, EPA believes  that its existing direction, including general guidance on conducting risk  assessments and the fact sheets for assessing potential impacts of  climate change effects for three types of remedies, discussed above,  provide a robust structure for considering such impacts. However, without  providing direction to remedial project managers on how to integrate  information on the potential impacts of climate change effects into site- level risk assessments at nonfederal NPL sites across all regions and  types of remedies, EPA cannot ensure that remedies will protect human  health and the environment in the long term.

EPA’s actions to respond to risks that potential impacts of climate change  effects may pose to human health and the environment at nonfederal  NPL sites partially align with this essential element. In two national  studies EPA conducted in 2012 and 2017, EPA examined potential  impacts of some climate change effects on selected remedies at NPL  sites, including nonfederal NPL sites, and generally found that it has  taken actions to respond to risks through its existing cleanup processes.  In 2012, as noted above, EPA studied the vulnerability of selected  remedies to some climate change effects and found that existing  processes—such as EPA’s Five-Year Review and operation and  maintenance—could adequately address the potential impacts of climate  change effects. In addition, EPA studied the impacts of three hurricanes  in 2017 on sites with selected remedies in place, including nonfederal  NPL sites, and found that the agency has generally taken resiliency  measures to respond to risks at these sites.

EPA also provided guidance and training to remedial project managers on  responding to risks to human health and the environment from the  potential impacts of climate change effects and recently added  requirements for certain potential site contractors to describe their  capacity to respond to such risks. EPA provided guidance in its fact  sheets on integrating climate change information into risk response  decisions at nonfederal NPL sites and optional training on integrating  climate change into the Superfund cleanup process. In addition, EPA  provided relevant information and resources for EPA officials on resiliency  measures on the agency website. In 2016, EPA issued performance work  statements to potential contractors for environmental services and  operations and for remediation environmental services that required  contractors to describe their ability to conduct climate change vulnerability  analyses and adaptation, as needed, to ensure the resiliency of remedies  to climate change impacts. According to an EPA headquarters official,  EPA is currently working on developing technical guidance on how  remedial project managers can integrate requests for climate change– related analysis into their task orders for contractors.

With respect to site-level responses, EPA officials from three regions  provided us with examples of site decision documents that described how  climate change information will be incorporated into remedy selection and  design. For example, the record of decision for the Portland Harbor site in  Oregon states that a containment cap will be constructed to withstand  more frequent floods with higher peak flows more common with climate  change. Officials from Region 3 told us that they take into account a  number of factors, including climate change impacts, if any, when they  design and select site remedies.

However, according to our interviews with regional officials, they have not  consistently integrated climate change information into remedy selection  and design. For example, officials from two regions stated that they are  not aware of any remedial project managers in their regions who are  taking action at nonfederal NPL sites to respond to climate change or  consider future conditions. EPA officials have not consistently taken the  potential impacts of climate change effects into account in site-level risk  response decision making because they do not always have sufficient  direction to do so, according to our interviews with EPA officials. EPA  officials from three regions told us that they are unsure how to translate  data on potential impacts of climate change effects into the design of  remedies. For example, officials from Region 10 told us that EPA does  not have direction for remedial project managers on how to integrate  response to climate change impacts into remedial design. These officials  noted that it is up to remedial project managers to be aware of this issue  and it is done on an ad hoc basis. Further, EPA headquarters officials  who review proposed remedies told us that additional guidance from EPA  on managing the risks from potential impacts of climate change effects  would be useful.

According to EPA documents and another EPA headquarters official,  EPA has determined that existing direction—guidance and processes— for risk response provide a robust structure to integrate climate change  information into remedy selection and design. However, without providing  direction for remedial project managers on how to integrate information  on potential impacts of climate change effects into site-level risk response  decision making at nonfederal NPL sites, EPA cannot ensure that  remedies will protect human health and the environment in the long term.

EPA’s actions to monitor risks to human health and the environment from  the potential impacts of climate change effects at nonfederal NPL sites  through its Five-Year Review process align with this essential element. In  2016, EPA introduced a new recommended template for the Five-Year  Review that includes a section for officials to document their  consideration of whether any newly available information related to  climate change may call into question a remedy’s protectiveness.

Officials in three regions told us they use the Five-Year Review process  to identify and evaluate newly available information on climate change  effects that may impact nonfederal NPL sites. For example, in the 2014  Five-Year Review report for the Publicker Industries site in Pennsylvania,  Region 3 considered newly available information on projected sea level  rise in the region to determine if those projections called into question the  protectiveness of the existing remedies at the site. Officials in that region  told us that they rely on their biological and technical assistance group to  identify any new relevant climate change data to incorporate into their  Five-Year Reviews. Region 7 officials also told us that they assess any  potential changes in future conditions, especially flooding, during the  Five-Year Review process. Officials from two other regions told us that  they monitor changes in site conditions that may be related to climate  change during the Five-Year Review process. For example, Region 2  officials developed additional guidance to help remedial project managers  and site project teams consider changes in site conditions related to  climate change in the Five-Year Review process. Region 6 officials told  us that during the Five-Year Review process, they take into account any  current flood hazard information from FEMA as well as current sea levels,  but they do not monitor projections about sea level rise.

EPA’s actions to communicate about and report on risks to human health  and the environment from the potential impacts of climate change effects  at nonfederal NPL sites align with this essential element. For example, as  described above, EPA reported on the potential impacts of climate  change effects—which may pose risks to human health and the  environment—on NPL sites in its 2014 national climate change  adaptation plan and the climate change adaptation implementation plans  for the office that oversees the Superfund program and all regions. In  addition, publicly available site-level documents, such as the records of  decision described above, may include information on risks from climate  change and EPA’s actions to manage these risks. EPA officials may also  communicate this information in response to questions from the public.  EPA officials from four regions told us that they have not received many  direct questions on risks from climate change from the public. However,  members of the public can comment on climate change risks through  EPA’s existing public engagement mechanisms, and some have done  so. For example, EPA officials in Region 7 received questions on the draft  record of decision for the West Lake Landfill site in Missouri during the  public comment period and responded to those questions in the final  version of the document, describing how they addressed risks of  increased flooding from climate change in the remedy selection  processes.

EPA has also communicated with stakeholders and the public on risks to  human health and the environment from the potential impacts of climate  change effects in other ways. For example, officials from Region 10  convened a workshop in 2017 to discuss climate change impacts on  sediment cleanup and upland source control for the Lower Duwamish  Waterway site in Washington with other federal agencies, state and local  officials, universities, companies, and community groups. In addition, EPA  provides an online mapping tool that can help members of the public  identify sites located in areas that would be impacted by up to 6 feet of  sea level rise or in flood hazard areas as determined by FEMA.

EPA Recognizes Various Challenges in Managing Risks from the Potential Impacts of Climate Change Effects at Nonfederal NPL Sites

EPA recognizes institutional, resource, and technical challenges in  managing risks to human health and the environment from the potential  impacts of climate change effects at nonfederal NPL sites, according to  agency and other documents that we reviewed and EPA officials and  stakeholders we interviewed.

According to agency and other documents we reviewed and officials and  stakeholders that we interviewed, EPA faces institutional challenges in  managing risks to human health and the environment from the potential  impacts of climate change effects. As discussed above, officials from  three regions told us that they do not have the direction they need to  manage these risks. For example, EPA officials in Region 2 told us that  during Five-Year Reviews, engineers may analyze several different maps  on flooding potential and must use their professional judgment to  determine how resilient to design the remedy, because there is no  standard guidance on how to do so. Further, EPA officials in two regions  and stakeholders we interviewed stated that it may not be clear whether  EPA could require PRPs to consider climate change impacts in the  cleanup process. However, according to EPA headquarters officials,  considering climate change is consistent with the National Contingency  Plan and the CERCLA criterion that requires officials to consider the long- term effectiveness of remedies when evaluating cleanup alternatives.

Another institutional challenge that EPA faces is that its ability to manage  these risks may depend on actions of other entities that are outside of  EPA’s control, according to EPA documents we reviewed and EPA  officials we interviewed. For example, EPA officials from Region 1 told us  that they are not certain whether a hurricane barrier built by the U.S.  Army Corps of Engineers that protects the New Bedford Harbor site in  Massachusetts is designed to withstand future storms. Managing risks  may also require internal coordination within EPA, which presents another  challenge. For example, an EPA headquarters official told us that it can  be challenging for regional Superfund program staff to connect with EPA  experts on climate change, who may be in different program offices. In  April 2019, EPA restructured its regional offices, consolidating cross- cutting issue areas in the immediate office of each Regional Administrator  and Deputy Regional Administrator. Although it is too early to evaluate  the effect of this restructuring, EPA headquarters officials told us that the  restructuring may help address this challenge. Furthermore, EPA officials  from three regions told us that they face challenges related to the  sensitive nature of climate change. For example, officials in Region 6 told  us that when they engaged with the local community during the decision  making process for the San Jacinto River Waste Pits site in Texas, they  avoided using the term climate change because of concerns that the  charged term would alienate some community members.

Documents from four EPA regions and headquarters officials and officials  from three regions we interviewed stated that insufficient or changing  resources—specifically funding and staffing—makes managing risks to  human health and the environment from the potential impacts of climate  change effects challenging for EPA. For example, according to two  regional climate change adaptation implementation plans and EPA  officials, assessing these risks may require more resources than  assessing risks based on current or past conditions. In addition, designing  or modifying existing remedies to respond to these risks could increase  costs, according to EPA documents we reviewed and EPA officials we  interviewed.

EPA officials from three regions told us that staffing constraints can make  it difficult to manage risks. For example, EPA officials from Region 9 told  us that the need for remedial project managers to respond to other  emergencies, such as overseeing hazardous materials removal after  fires, means that they have less time to oversee cleanup of nonfederal  NPL sites. Officials from Region 10 told us that they had a climate  change advisor who helped integrate climate change into all aspects of  the region’s work, but that person retired, and the region was unable to fill  the position because of resource constraints. As noted above, according  to an EPA headquarters official, EPA’s recent restructuring of its regional  offices may help address this challenge.

EPA faces technical challenges in managing risks to human health and  the environment from the potential impacts of climate change effects in  terms of available expertise and data, according to documents we  reviewed and EPA regional officials we interviewed. In its 2014 agency- wide climate change adaptation plan, EPA reported that site  vulnerabilities may be difficult to assess because of limited scientific  understanding. EPA officials told us that they need additional expertise  and training to better manage risks. For example, an EPA official in  Region 2 told us that it would be useful to have training on assessing  risks for projects located in floodplains. As noted above, EPA has  developed training for officials on managing risks from climate change,  such as a course on building resilient Superfund remedies that EPA  offered at the annual National Association of Remedial Project Managers  meeting in August 2019. The course’s focus is to help remedial project  managers incorporate consideration of adaptation and build resilience  into Superfund remedies at extreme weather event–impacted sites,  according to the course agenda.

According to EPA documents and EPA officials from two regions,  appropriate climate change data may not be available to inform  assessments that help manage risk. For example, the Region 4 study of  the vulnerability of NPL sites stated that climate model projections of  temperature and precipitation patterns are not available at a spatial  resolution that is useful for assessing vulnerabilities at the site level. In  Region 6, officials told us that when the U.S. Army Corps of Engineers  modeled flooding for the San Jacinto River Waste Pits site in Texas, it  had to rely on past flooding data because the only information available  was on historical storms. In addition, the level of uncertainty inherent in  climate change data may make it challenging for EPA to incorporate that  information into risk management processes, according to agency  documents we reviewed and some agency officials we interviewed. As  noted above, we made recommendations to address similar challenges  with climate data in a prior report.

Climate change may result in more frequent or intense extreme events,  such as flooding, storm surge, and wildfires, among other effects, which  could damage remedies at nonfederal NPL sites and lead to releases of  contaminants that could pose risks to human health and the environment.  Our analysis of EPA, FEMA, NOAA, and U.S. Forest Service data has  shown that more than half of nonfederal NPL sites—based on a point  coordinate with a 0.2-mile radius as a proxy for the site boundaries—are  located in areas that may be impacted by selected climate change  effects. To help ensure the long-term protectiveness of remedies, it is  important for EPA to understand how climate change effects may impact  nonfederal NPL sites, and the agency has taken steps to do this.  However, EPA does not have quality information on the precise  boundaries of nonfederal NPL sites, which could make it difficult to  determine the nonfederal sites located in areas that may be impacted by  climate change effects. The agency has taken initial steps to develop this  information but does not have a schedule in place for completing this  effort.

EPA has taken actions to manage risks to human health and the  environment from the potential impacts of climate change effects at  nonfederal NPL sites. These actions align with three of the six essential  elements of enterprise risk management. However, EPA has not clarified  how its actions to manage risks from these effects at nonfederal NPL  sites align with current agency goals and objectives, which could limit its  senior officials’ ability to manage these risks. Further, EPA officials do not  always have direction to ensure that they consistently integrate climate  change information into site-level risk assessments and risk response  decisions, according to EPA documents and officials. Without providing  such direction for remedial project managers, EPA cannot ensure that  remedies at nonfederal NPL sites will protect human health and the  environment in the long term.

We are making the following four recommendations to EPA:

The Director of the Office of Superfund Remediation and Technology  Innovation should establish a schedule for standardizing and  improving information on the boundaries of nonfederal NPL sites.  (Recommendation 1)

The Administrator of EPA should clarify how EPA’s actions to manage  risks to human health and the environment from the potential impacts  of climate change effects at nonfederal NPL sites align with the  agency’s current goals and objectives. (Recommendation 2)

The Director of the Office of Superfund Remediation and Technology  Innovation should provide direction on how to integrate information on  the potential impacts of climate change effects into risk assessments  at nonfederal NPL sites. (Recommendation 3)

The Director of the Office of Superfund Remediation and Technology  Innovation should provide direction on how to integrate information on  the potential impacts of climate change effects into risk response  decisions at nonfederal NPL sites. (Recommendation 4)

We provided a draft of this report to EPA for its review and comments. In  its comments, reproduced in appendix II, EPA stated that it recognizes  the importance of ensuring Superfund sites cleanups are resilient in the  face of existing risks and extreme weather events. EPA added that it has  taken actions to include vulnerability analyses and adaptation planning in  its Superfund activities. We acknowledge that EPA has taken some action  to manage risks. However, EPA has not clarified how its risk-related  actions align with agency goals and objectives. Further, it has not  provided direction to ensure that officials consistently integrate climate  change information into site-level risk assessments and risk response  decisions.

Regarding our recommendations, EPA agreed with one and disagreed  with the other three. We continue to believe that all recommendations are  warranted.

In response to our recommendation that the Director of the Office of  Superfund Remediation and Technology Innovation establish a schedule  for standardizing and improving information on the boundaries of  nonfederal NPL sites, EPA noted that it agrees with our finding and  acknowledges a lack of consistent standards to identify site boundaries at  the national level. According to EPA, it has taken initial steps to develop  an approach to standardize and improve information on nonfederal NPL  site boundaries. EPA stated that it expects to establish a schedule for this  effort by the second quarter of fiscal year 2020, with the aim to have  collected an initial set of site boundaries for all NPL sites by the fourth  quarter of fiscal year 2021.

In response to our recommendation that EPA clarify how its actions to  manage risks to human health and the environment from the potential  impacts of climate change effects at nonfederal NPL sites align with the  agency’s current goals and objectives, EPA said that it believes managing  risks from exposure to contaminants in the environment is integral to  EPA’s current strategic goal 1.3, Revitalize Land and Prevent  Contamination. We agree that protectiveness is a key part of strategic  objective 1.3. However, this strategic objective does not include any  measures related to climate change or discuss strategies for addressing  the impacts of climate change effects. An essential element of enterprise  risk management is to align risk management processes with goals and  objectives. Consequently, we believe that our recommendation is still  warranted.

In response to our recommendations that the Director of the Office of  Superfund Remediation and Technology Innovation provide direction on  how to integrate information on the potential impacts of climate change  effects into risk assessments and risk response decisions at nonfederal  NPL sites, EPA said that it strongly believes the Superfund program’s  existing processes and resources adequately ensure that risks and any  effects of severe weather events are woven into risk assessments and  risk response decisions at nonfederal NPL sites. However, as we noted in  our report, EPA’s current direction does not address all types of cleanup  actions or climate change effects. Further, EPA officials from some  regions told us that current EPA practice for assessing risks at NPL sites  does not always include consideration of climate change and that they  have not consistently integrated climate change information into site- specific remedy selection and design. EPA noted that it may issue a  memorandum to reinforce the tools and resources available to NPL site  teams and would determine whether to issue this memorandum by the  end of January 2020.

EPA also provided technical comments, which we incorporated as  appropriate.

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If you or your staff have any questions about this report, please contact  me at (202) 512-3841 or gomezj@gao.gov. Contact points for our Offices  of Congressional Relations and Public Affairs may be found on the last  page of this report. GAO staff who made key contributions to this report  are listed in appendix III.

This report examines (1) what available federal data suggest about the  number of nonfederal National Priorities List (NPL) sites that are located  in areas that may be impacted by selected climate change effects; (2) the  extent to which the Environmental Protection Agency (EPA) has managed  risks to human health and the environment from the potential impacts of  climate change effects at nonfederal NPL sites; and (3) the challenges, if  any, EPA faces in managing these risks.

To determine what available federal data suggest about the number of  nonfederal NPL sites that are located in areas that may be impacted by  selected climate change effects, we reviewed the Fourth National Climate  Assessment (NCA) to identify potential climate change effects. Based on  our review of the NCA, we identified the following potential climate  change effects: sea level rise, which may lead to increased frequency and  extent of extreme flooding from coastal storms; greater frequency and  magnitude of drought; increased intensity and frequency of heavy  precipitation events, which may lead to increased local flooding; salt  water intrusion; increased incidence of large wildfires; increased  frequency and intensity of extreme high temperatures and sustained  increases in average temperatures; decreased permafrost; and increased  intensity—including higher wind speeds and precipitation rates—and  frequency of very intense hurricanes and typhoons. We reviewed EPA  documents (such as EPA’s climate change adaptation implementation  plans) to identify potential climate change effects that may impact  nonfederal NPL sites and interviewed EPA officials.

Through a review of federal agencies’ documents and databases and  interviews with officials about their data and research on these effects, we  identified available national federal data sets on three current hazards:  flooding, storm surge, and wildfires—which the NCA reports will be  exacerbated by climate change—from the Federal Emergency  Management Agency (FEMA), the National Oceanic and Atmospheric  Administration (NOAA), and the U.S. Forest Service. We also identified  data on sea level rise from NOAA.

In this report, we refer to (1) flooding, (2) storm surge, (3) wildfires, and  (4) sea level rise as potential climate change effects. We used the most  recently available data for each of these climate change effects; these  data do not provide estimates of the projected changes in the future. To  the extent that data were available, we analyzed a range of these  potential climate change effects. For example, we used the maximum  extent of storm surge from Category 1 hurricanes as well as Category 4  or 5 hurricanes, the highest possible categories, as modeled by NOAA.  We focused on a range because, for three of the four effects, we had data  on current hazards, which may become more intense and frequent in the  future, according to the NCA. Additionally, the Comprehensive  Environmental Response, Compensation, and Liability Act of 1980  (CERCLA) directs EPA to give preference to remedies that would result in  the permanent and significant decrease in toxicity, mobility, or volume of  the contamination. According to EPA officials, remedies at nonfederal  NPL sites may have to be operational indefinitely, during which time the  potential effects of climate change may become more extreme.

The range of estimates we provide in our report is as follows:

For flooding, we used data from FEMA’s National Flood Hazard Layer  as of October 2018. FEMA identifies a variety of flood hazards, and  for reporting purposes, we grouped flood hazard zones into four  categories: (1) 1 percent or higher annual chance of flooding, (2) 0.2  percent or higher annual chance of flooding or other flood hazards,  (3) unknown flood hazards, and (4) minimal flood hazard.

For storm surge, we used data from NOAA’s model on Sea, Lake and  Overland Surges from Hurricanes as of November 2018 for Category  1 and Category 4 or 5 hurricanes.

For wildfire, we used data from the U.S. Forest Service’s 2018 wildfire  hazard potential map, which the U.S. Forest Service released in July  2018. We used areas with high or very high wildfire hazard potential in  our analysis. The U.S. Forest Service based the 2018 map on wildfire  likelihood and intensity data from 2016, spatial fuels and vegetation  data from 2012, and point locations of past fire occurrence from 1992  to 2013.

For sea level rise, we used NOAA data, last updated in September  2018. We downloaded inundation data on 0, 1, 3, and 8 feet of sea  level rise and “not mapped” areas.

We obtained data from EPA’s Superfund Enterprise Management System  on the location and other characteristics of active and deleted nonfederal  NPL sites. In our analysis, we used a 0.2-mile radius around the primary  geographic coordinate point of each nonfederal NPL site, which may not  accurately represent their actual areas because the sites vary in size and  shape. The EPA data we used in our analysis on the location of  nonfederal NPL sites are current as of March 2019. We also obtained  EPA data on contaminants and types of remedies that are current as of  fiscal year 2014 to determine the number of contaminants EPA has  identified in nonfederal NPL sites. We did not conduct further site-specific  analyses, such as those related to the extent of contamination and  location of remedies. We reviewed documents from the Agency for Toxic  Substances and Disease Registry on the health effects of hazardous  substances in nonfederal NPL sites and interviewed officials from that  agency.

To analyze whether nonfederal NPL sites are located in areas that may  be impacted by flooding, we used ArcGIS mapping software to intersect  the area of a 0.2-mile radius around the primary coordinate of the sites  with the categories we defined from the National Flood Hazard Layer. If a  site overlapped with areas in more than one of the four reporting groups,  we categorized the site in the group representing the highest flood  hazard. For the purposes of our report, we considered the highest flood  hazard to be, in descending order, 1 percent or higher annual chance of  flooding, other flood hazards (including 0.2 percent or higher annual  chance of flooding), unknown flood hazard or no data, and minimal flood  hazard. To analyze whether nonfederal NPL sites are located in areas  that may be impacted by storm surge, wildfires, and sea level rise, we  used MapInfo mapping software to intersect the area of a 0.2-mile radius  around the primary coordinates of sites with each of these layers. Overlap  indicates that a site is potentially in an area that may be impacted.

To assess the reliability of FEMA’s National Flood Hazard Layer, we  reviewed FEMA’s methodology, guidelines, and standards; interviewed  FEMA officials to assess the timeliness and accuracy of the data as well  as any limitations of the data; conducted data testing to check for missing  data and inconsistencies; and reviewed internal controls. We also  reviewed a prior GAO report on the methodology FEMA uses to map  flood hazards. To assess the reliability of NOAA’s data on Sea, Lake and  Overland Surges from Hurricanes, we reviewed NOAA’s methodology for  developing the model, interviewed NOAA officials to assess the  timeliness and accuracy of the data as well as any limitations of the data,  and reviewed internal controls. To assess the reliability of the U.S. Forest  Service’s wildfire hazard potential data, we reviewed the agency’s  documentation of the methodology, interviewed U.S. Forest Service  officials to assess the timeliness and accuracy of the data as well as any  limitations of the data, and reviewed internal controls. We also reviewed  our past reports that cited the 2014 versions of these data. To assess  the reliability of NOAA’s data on sea level rise, we reviewed the  methodology NOAA used for developing the model, interviewed NOAA  officials to assess the timeliness and accuracy of the data as well as any  limitations of the data, and reviewed internal controls.

To assess the reliability of EPA’s data, we reviewed agency manuals and  data dictionaries to understand data elements, interviewed EPA officials  to assess the timeliness and accuracy of the data and related internal  controls, conducted data testing, discussed inaccuracies with EPA  officials; and obtained corrected data. For example, we compared the zip  code of each nonfederal NPL site to its coordinate to check the accuracy  of site locations. We shared potential errors with EPA officials, who  corrected the coordinates of six sites. As a result of the steps described  above, we found data from EPA, FEMA, NOAA, and the U.S. Forest  Service to be sufficiently reliable for our purposes.

To determine the extent to which EPA has managed risks to human  health and the environment from the potential impacts of climate change  effects on nonfederal NPL sites, we examined relevant provisions in  CERCLA, EPA’s implementing regulations, and executive orders. We  also reviewed EPA documents, including climate change adaptation and  implementation plans; vulnerability studies; training materials; and site- specific documents, our prior work, and relevant documents from other  organizations, such as the National Research Council. We identified  these documents by conducting a search of (1) websites of relevant  agencies and organizations and (2) article databases. We also reviewed  documents provided to us by agency officials and stakeholders that we  identified as described below. We interviewed EPA officials at  headquarters and all regional offices to identify information on agency  actions for managing risks. In addition, to obtain their views of EPA’s  actions, we interviewed former EPA officials, representatives of two  associations representing state officials (the Environmental Council of  States and the Association of State and Territorial Solid Waste  Management Officials), a professor of environmental law, and a private  consultant who has worked on Superfund issues, which we identified in  the search described above and recommendations from other  interviewees. We generally contacted all stakeholders that we identified  who appeared to be currently working on issues related to Superfund and  climate change and who agreed to speak with us. We also interviewed  stakeholders at the three sites we selected as illustrative examples in  order to obtain their views of EPA’s actions.

We selected three nonfederal NPL sites as illustrative examples of how  EPA has managed risks to human health and the environment from  potential impacts of climate change effects and challenges EPA may face  in managing these risks. The three sites we selected are the (1) American  Cyanamid site in Bridgewater, New Jersey; (2) Iron Mountain Mine site  near Redding, California; and (3) San Jacinto River Waste Pits site in  Channelview, Texas. To select these sites, we initially identified 43 sites  based on information in EPA documents, news articles, and interviews  with EPA officials and other stakeholders as described above. We  selected relevant sites in three different EPA regions that illustrate a  variety of potential climate change effects and that had experienced an  extreme weather event in the past 10 years. To gather more in-depth  information about these sites, we reviewed EPA and other documents;  toured the sites; and interviewed EPA officials and relevant stakeholders  at these sites, including state and local officials, representatives of  potentially responsible parties, and community organizations. The results  from these illustrative examples are not generalizable to nonfederal NPL  sites that we did not select.

We compared EPA’s actions to manage risks to human health and the  environment from the potential impacts of climate change effects with  essential elements for managing risk as identified in our prior work on  enterprise risk management. These essential elements are as follows:  (1) align the risk management process with goals and objectives, (2)  identify risks, (3) assess risks, (4) respond to the risks, (5) monitor the  risks, and (6) communicate and report on the risks. We assessed  information on EPA’s actions to determine the extent to which the  agency’s actions aligned with these elements. In assessing EPA’s actions  against these essential elements, we used “aligned,” “partially aligned,” or  “not aligned” to reflect the extent to which EPA took actions aligned with  each essential element. If EPA provided evidence that it had taken major  actions in alignment with that essential element, we determined the  actions were aligned. If EPA provided evidence that it had taken some  actions in alignment with that essential element, we determined the  actions were partially aligned. If EPA took only a few or no actions in  alignment with that essential element, we determined the actions were  not aligned. Two GAO analysts independently reviewed the information  on EPA’s actions and then reached consensus on the extent to which  EPA’s actions were aligned with each element.

To identify the challenges EPA faces in managing these risks, we  reviewed EPA documents; our prior work; and relevant documents from  other organizations, including the National Research Council, that we  obtained as described above. We interviewed EPA officials at  headquarters and all regional offices and stakeholders in order to obtain  their views on the challenges EPA faces. The views of stakeholders we  interviewed are illustrative and not generalizable to all stakeholders. We  reviewed the challenges that we identified in these documents and  interviews and grouped all the challenges into three categories for  reporting purposes: institutional, resource, and technical. Two GAO  analysts independently reviewed the information and then reached  consensus on the challenges and their grouping in the three categories.

We conducted this performance audit from April 2018 to October 2019 in  accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.

Appendix II: Comments from the Environmental Protection Agency

Appendix III: GAO Contact and Staff Acknowledgments

In addition to the contact named above, Barbara Patterson (Assistant  Director), Ruth Solomon (Analyst in Charge), Breanne Cave, Charles  Culverwell, Cindy Gilbert, Richard Johnson, Gwen Kirby, Krista Mantsch,  Patricia Moye, Eleni Orphanides, Ernest Powell Jr., Dan Royer, and Kiki  Theodoropoulos made key contributions to this report.

Climate change may increase the frequency and intensity of certain natural disasters, which could damage Superfund sites—the nation’s most contaminated hazardous waste sites.

Federal data suggests about 60 percent of Superfund sites overseen by EPA are in areas that may be impacted by wildfires and different types of flooding—natural hazards that may be exacerbated by climate change.

We found that EPA has taken some actions to manage risks at these sites. However, we recommend it provide direction on integrating climate information into site-level decision making to ensure long-term protection of human health and the environment.