Hazardous Waste Site Management Water Quality Issues (1988) / Chapter Skim
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6. HOW CLEAN IS CLEAN? AN ENVIRONMENTALIST PERSPECTIVE
6. HOW CLEAN IS CLEAN? AN ENVIRONMENTALIST PERSPECTIVE
Pages 110-119
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From page 110... ...
GREER The selection of cleanup levels for hazardous waste dump sites has been a priority issue within the environmental community since the original passage of the Superfund legislation. After lobbying the issue during the debate over the 1980 bill, the Environmental Defense Fund (EDF)
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From page 111... ...
It is important to note here that there are many in the industrial community who agree with environmentalists that a caseby-case approach to establishing cleanup levels at dump sites is not desirable public policy. They agree because uncertainty in the appropriate cleanup levels for a site substantially complicates both negotiations between private parties and the agency concerning voluntary cleanups and settlements with responsible parties at Superfund sites.
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From page 112... ...
As a result of successful work by the environmental lobby the 1986 reauthorized Superfund requires the use of all relevant and appropriate standards and criteria in establishing nationwide levels of cleanup. The law explicitly directs EPA to use requirements established by all federal environmental legislation including the Toxic Substances Control Act; the Safe Drinking Water Act; the Clean Air Act; the Clean Water Act; the Marine Protection, Research, and Sanctuaries Act; and the Solid Waste Disposal Act.
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From page 113... ...
Such issues as the role of the ever-decreasing analytical detection limit and the distinction between individual and population risk have rendered the EPA essentially incapable of responding to carcinogenic hazards, be they in dump sites, industrial discharges, or ambient air. An expeditious solution to the complexities of regulating carcinogens is, at a minimum, to regulate them to levels below current detection limits.
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From page 114... ...
. Although it is theoretically possible to achieve equal levels of protection for human health and the environment under each of these alternatives, the choices differ substantially in the extent to which they require sophisticated hydrogeologic transport and fate models and institutional controls on future development, as well as the extent to which they require remedial technologies that are not yet within our grasp.
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From page 115... ...
It overlooks the technical uncertainties associated with the accurate prediction of ground water movement into the well drawdown zone and the cost of contaminating future water supplies. Furthermore, it is an option that is only applicable to sites with contaminated community well fields; individual homes could not be expected to install treatment units.
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From page 116... ...
Thus, we had the ironic situation of the government paying large sums of money to private industry to move and dispose of toxic waste from existing Superfund sites for disposal in licensed dumps that were themselves well on the way to becoming future targets of Superfund action. Much of the justification EPA gave for selecting these removal and containment strategies was its peculiar definition of cost-effectiveness; EPA was considering only the up-front cost of constructing containment facilities and did not factor in long-term operation and maintenance costs or the cost of technological uncertainty in the performance of these structures.
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From page 117... ...
The statutory bias toward the implementation of permanent technologies is designed to encourage such methods as biological degradation, incineration, and other destruction technologies as well as chemical fixation and stabilization processes for metals. It is hoped that, in the Tong term, these types of treatments will be more elective in addressing the contaminant sources at the dump sites.
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From page 118... ...
In all these areas ~ think she comes across very strongly for no-nonsense standards, little flexibility, and the use of minimum engineering, essentially using the same techniques and the same standards at all sites. She suggests the use of existing standards such as the Safe Drinking Water and ambient stream standards, and calls for no offproperty containment and, again, the minimizing of dependence on ground water models, engineering calculations, and so on.
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From page 119... ...
There is enormous variability, and ~ just cannot help but wonder whether we have to allow some flexibility in the conditions, the standards, and the solutions that we apply to each of these sites and whether the type of program that Linda has proposed is economically and politically viable. Her suggestion essentially to use Safe Drinking Water standards, ambient water quality standards, and other existing standards as the appropriate guidelines or cleanup criteria tends to ignore that even within these standards a great deal of variability exists.
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