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ECONOMIC, LEGAL, AND PRACTICAL PROBLEMS IN HAZARDOUS WASTE 168 CLEANUP AND MANAGEMENT original typesetting files. Page breaks are true to the original; line lengths, word breaks, heading styles, and other typesetting-specific formatting, however, cannot be About this PDF file: This new digital representation of the original work has been recomposed from XML files created from the original paper book, not from the retained, and some typographic errors may have been accidentally inserted. Please use the print version of this publication as the authoritative version for attribution. up, the state has encountered many interesting problems involving policy, economic, legal, and practical matters: ⢠decisions about the necessary degree of cleanup; ⢠assessments of the cost-effectiveness of alternatives to achieve the desired degree of cleanup; ⢠assignment of financial responsibility; ⢠legal problems involving sovereign immunity, liability, and delays in cleanup when a case is in court; and ⢠management problems involving the Environmental Protection Agency and state government. This paper first discusses the "How clean is clean?" issue, then the economic, legal, and management problems. Finally, it describes the framework needed for long-term management of hazardous waste and explains what Florida is doing to lay the groundwork for a systematic approach to long-term hazardous waste management. HOW CLEAN IS CLEAN? Determining the extent of cleanup necessary at hazardous waste sites is difficult and sensitive. Everyone has a notion of how much must be done to ensure public safety. As secretary of the Florida Department of Environmental Regulation, I, like other regulators, enjoy philosophizing over the apparently endless subject of "How clean is clean?" It is intellectually stimulating and helps take us above the day-to-day problems. But cleanup of hazardous waste sites also requires that a regulator be a sort of glorified refuse shoveler with grimy hands. We have to contain and remove the wastes or contain and treat them or, in some cases, be satisfied to contain them. How should we decide? First, we need to estimate the risk from exposure to each hazardous waste site. State standards for a number of toxic, carcinogenic, or mutagenic substances in groundwater and drinking water provide guidance. Addressing risk when soils are contaminated is more difficult, but it can be done. Although we recognize that we must make certain assumptions about risk, often using inadequate information, it should also be a top priority to adopt standards nationally. Otherwise, we will be involved in handwringing ad hoc decisions every time a toxic chemical is detected in the environment. When there are no standards, a miniature standard-setting process should be used to establish target levels at each site. Sometimes we are left with nothing more than the limits of routine detection as a goalâbut at least this is a place to start. Then, with scientific data in hand we proceed as in any enforcement case
