Toxic Detraction

Hopefully it will herald the dawn of cost-benefit analysis in environmental efforts for a change.

We WILL miss opportunities for beneficial efforts if we knee-jerk spend without analysis, because we will always have some limit on total funds available. Unfortunately this process is frequently short-cut by those with a political agenda they are satisfying through headline mongering. Leading to dragging those voters miss-informed, to the polls to vote on issues thoroughly clouded.

This makes very good introductory reading on making best case, limited resource decisions.

One has to be careful also of reviews, in a buracracy...........What will happen is, efforts halt....due to an impact study...........efforts halt do to buracracy conflict of interests..........ect, ect,ect...........efforts halt due to budget for cleanup evaporated, due to the amount of funds spent on litigation and studies, clean-up never occurred, but good intentions were there.

phoenix911

Hazardous waste clean ups/remediations under a Federal, State or lcal enforcement agencies auspices are exempt from environmental impact reviews.

with no oversite review......now that's scary....again good intentions.

The last two posts I had, is damned if you do and damned if you don't. I should work in government

I actually spent a calendar quarter or so working for the EPA, right out of college.

It was Alice in Wonderland decisionmaking, and the halt leading the lame intellectually. I was overjoyed to get a job in the steel industry.

You can have the government job.

PS There's a reason they call it "going postal."

milo

kinda the point was trying to get across, only (2) different government agencies counterdicting each other on what you should do.

One positive outcome of the cleanup effort is that pollutants that are removed do not migrate off site to pollute clean environments or water supplies. Also, the cleanup of smaller "brownfields" through CERCLA has resulted in the development of previously abandoned inner city areas.

Also, large industrial sites, like the many that prompted CERCLA, are not where people generally like to live.

First and foremost the remediation of sites is to address public health and environemental impact issues before they potential release expands to a point where it wouuld cost orders of magnitude more and then pose a direct public health issue. The problem with purely cost-benefits analysis in the engineering industry is the lack of review of the risk and costy should a release occur and/or expand. It is a common practice to argue for risk based closure and use a cost basis for that argument. The thing about a hazardous waste site is that as time progresses many of the problems also progress unless some measures are taken to mitigate such progession. The issue of superfund clean up is hat frequently, because of the superfund clean up adjacent properties can not receive loan as the hazardous waste clean up site will show up in a phase I ESA, and banks will not loan money if the land is devalued because of a hazardous waste site. So the adjacent properties remain under-improved until a clean closure of the site is completed. So the only people who move in to the neighborhood are the ones who won't mind the potential contaminantion because it will direct attention away from their own polluting activities. I have seen numerous Superfund sites where the nearest adjacent properties end up being bought by metals recyclers and automobile recylcers, which eventually become contaminated sites themselves. Thus it becomes a circular process in urban areas. Brownfields recovery is more effective in rural areas where adjacent properties are unused or open space, and will not be occupied by other polluters.

All of your objections are true, but solveable elsewhere in the system.

The creation of a category of "contained" or "sealed" in place with rules attached should be effective where that is the most effective means. If that creates problems in the financial sector, that could be where we tackle those problems.

And I do not hold myself as authoritative on these issues, but we have all seen the laws of unintended consequences work in engineering as well as legislative.

My only point is that clean-up / remediation is not necessarily the best solution in ALL cases. And that the patchwork legal system we have based on civil governmental lines (another area where a System wide solution begs) may mean the remidiation you do "here", just ends up in a landfill "there".

Or dumped at sea, or...

there are acceptable remediation practices that consist of as you say capped or sealed in place. These would be things like clay caps and vitrification. However, clean closure resolve the owners of liability for any future releases and on going monitoring. This is actually good, sihnce the closure of such facilities would be done on the cheap and poorly if the owners could just bury them and not be liable or have to monitor. The remediation that you most often see EPA involved in related to large scale releases of hazardous materials where the owners are incapable of financial responsibility. Thus CERCLA pays for the clean up, and the EPA spends a ton of money trying to recover some portion of the expenditure from the RPs. The biggest problem I have seen in the system is the concern over the financial solvency businesses that improperly disposed of the waste. The government, using funds from the chemical industry, bails them out when they have gotten to dirty and were saving a few bucks by dumping PCE down the hole in the back. If they were cost sutting by improper waste disposal, then maybe they should be held financially accountable no matter the impact on the business, and a cleaner business will come along to replace them. Simple capitalistic evolution, the weaker businesses die off and stronger better businesses arise to take their place.

I believe that you are mistaken. There is one group that HAS benefited greatly from expenditures under CERCLA & SARA (that's the original "Superfund" & the Superfund Amendments & Reauthorization Act).

THE LAWYERS...

I recall perusing a study by the Rand Corporation around 15 years ago, that found something like 40% of Superfund dollars expended went right to the lawyers defending the PRPs (potentially responsible parties) .

This somehow was "justified" by the PRP's defense under the "joint and several liability clause" in CERCLA...

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Just my $0.02...

Hmm, so we could save 40% just by not paying for the legal teams of the polluters. Maybe someone should start a grass roots campaign and a bill to revise superfund payment for such legel expenditures by PRPs.

40%......that's just about the standard take for an attorney.

Why do you think there are so many commercials on television for class action law suits by attorney's......

To change that you need to change the law..........and with that being said. tell me what base occupation mostly makes up Washington D.C.?.....good luck

Actually just have to change CERCLA, as it is a loophole in CERCLA that the defendants, PRPs, attorneys are getting reimbursed through the fund for the legal fees incurred in fighting the legal efforts of the EPA to collect reimbursement for the clean up of the hazardous waste contamination they left at a facility. Class action law suits are taken on at risk to the attorney to file a suit against a responsible party on the benefit of multiple potentially damaged or injured parties, these Attorneys of PRPs in CERCLA cases are getting paid by the government to fight against the lawsuits brought against them by the government to pay for a portion of the clean up of their contamination. It is like a public defender program for the Rich, except instead being assigned some under qualified over burdered Public Defender, they get reimbursed for the defense efforts and can hire anyone they want. Maybe if we assigned them a public defender, who is on the State Payroll, like we do in criminal cases for the middle class and poor, the cost would drop substantially.