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#172 - Superfund Part 5: Some Keys To A Successful Cleanup, 13-Mar-1990

Continuing our series on Superfund cleanups. Page numbers in our text
refer to pages in the latest report from Congress's Office of
Technology Assessment (OTA), COMING CLEAN, cited in our last paragraph,

During the long process of cleaning up a contaminated site, government
and the polluters will make many choices that will affect the quality
of the final result. Often they make choices that are not in your best
interests and are illegal, so you must watchdog every decision. To be
effective, you need to know how the Superfund process works (we
reviewed it in RHWN #160). The RIFS (remedial investigation,
feasibility study) is the place where the government (or the polluter,
when the polluter is selected to do the RIFS, which is more often than
not--see RHWN #166) gets to describe the problem and the range of
possible solutions. The final decision (formally contained in the ROD,
or record of decision) is limited to alternatives that were presented
in the RIFS, so the RIFS is key. The RIFS not only defines the problem
but it also defines the range of possible solutions.

Here are some points that may help you get what you want from the RIFS
and ROD:

Cost effectiveness should guide cleanup

What does cost effectiveness mean? The principle of cost-effectiveness
means that you first select the level of environmental and health
protection to be achieved; then, afterward, you select the lowestcost
alternative that is able to provide that level of protection. Using
cost-effectiveness to guide a cleanup means that cost alone is never
supposed to control Superfund cleanup decisions.

Cost-effectiveness analysis and cost-benefit analysis are not the same
thing. The SARA law (the federal Superfund amendments of 1986) required
EPA (U.S. Environmental Protection Agency) to use cost-effectiveness
analysis, but EPA has often substituted cost-benefit analysis (pgs. 65-
67; be sure to read footnote 64 on pg. 65). This is wrong and illegal,
yet EPA persists in doing it.

What's the difference between the two?

Cost-benefit analysis measures the costs of a project and the benefits
of the project, compares the two and decides which is greater. The
greater of the two determines whether the project goes forward or not.
This technique was first developed by the Army Corps of Engineers to
evaluate dams. To make comparison easy, everything is reduced to
dollars. Using this technique, it is easy to show that incineration is
expensive, landfilling is cheap, therefore landfilling is a "better"
alternative at a Superfund site, according to the principles of cost-
benefit analysis. The SARA law specifically says the EPA should not
make this kind of comparison for Superfund cleanups, but EPA continues
to make such comparisons routinely.

Cost-effectiveness analysis, on the other hand, requires the agency to
establish health and environmental goals, then to select the technology
that meets those goals by the cheapest means. If incineration and
landfilling could achieve identical health and environmental goals, and
if incineration were more expensive, then cost-effectiveness analysis
would dictate the selection of landfilling. But landfilling and
incineration do not give equivalent levels of health and environmental
safety because one is a permanent cleanup measure (incineration) and
the other is temporary (landfilling). Therefore the two technologies do
not provide the same level of protection and they cannot be compared
using cost-effectiveness analysis.

How clean is clean?

It has become standard within the EPA to consider a cancer risk of one
in a million as being "acceptable." The question, "How clean is clean?"
is often answered by performing a risk assessment on a few key
chemicals, called "indicator chemicals"; if the risk of them causing
cancer is one-in-a-million (10-6) or less, this is deemed "clean

However, there are instances in which the agency uses a cancer risk of
one in one hundred thousand (10-5) or even one in ten thousand (10-4)
to define "acceptable risk."

Be sure you are aware what level of risk is being used to decide how
clean is clean enough. Also, be aware that the "indicator chemicals"
may not represent the full range of hazards actually present in the
chemicals at the site. For example, a recent risk assessment for Love
Canal was done using seven "indicator chemicals" but there are more
than 200 chemicals buried in the Love Canal dump, so the seven
chemicals obviously can't truly represent the full hazard.

Make EPA give you evidence of what levels of contamination (and risk)
have been deemed acceptable at other sites with similar chemicals, what
cleanup levels have been set elsewhere to define "how clean is
clean." [You can find limited information about other sites in Are We
Cleaning Up?, cited in our last paragraph (below), but EPA officials
should have, or be able to get for you, information about all other

Watch out for risk assessment

Risk assessment is a technique used by government and by polluters to
reach a quantitative (numerical) estimate of the likelihood that you
will be harmed by exposure to chemicals at the site (after it is
cleaned up). Unfortunately, the people who do risk assessments often
fail to tell you how little they actually know about the ability of
chemicals to harm humans and the environment. Getting risk assessors to
talk about the unknowns is as important as their discussion of the
knowns. Here are a few points to remember:

a) A risk assessment should consider damage to creatures besides
humans. Although humans are generally the most sensitive species, there
are some creatures that are more sensitive than humans. These other
creatures need to be protected as well as humans do, since the
environment consists of interdependencies and interconnections that
give every creature a role to play in supporting life.

b) To be useful, a risk assessment needs to consider human diseases
besides cancer, including (1) reproductive problems [inheritable
genetic changes, birth defects, low sperm count, inability to conceive,
spontaneous abortion, low birth weight, and so forth], (2)
developmental disorders, (3) nervous system effects, and (4) damage to
the immune system. For example, a chemical exposure that caused rashes
in 20% of children, or caused pain in the joints of 20% of elderly
people would create a social disaster, yet would not be recognized by a
"standard" risk assessment focused only on cancer.

c) To be useful, a risk assessment needs to be explicit about the
unknowns, the gaps in available information, and the assumptions that
are used to fill those gaps. This can be the most valuable service a
risk assessment provides, because when you look for information about
most chemicals and their effects on human and animal reproduction,
their effects on human and animal development, their effects on human
and animal nervous systems, and their effects on human and animal
immune systems--you generally find that the unknowns are much larger
than the knowns. Thus a good risk assessment can show us how ignorant
we are about most aspects of most chemicals, and can give us good
reason to question whether the proposed level of "clean" is clean

Get: U.S. Congress, Office of Technology Assessment, CLEANING UP:
Printing Office, 1989). Available for $10 from U.S. Government Printing
Office, Washington, DC 20402-9325; request GPO stock No. 052-003-01166-
2. Phone (202) 783-3238. Charge it to Visa, Mastercard or Choice.

And: U.S. Congress, Office of Technology Assessment. ARE WE CLEANING
(Washington, DC: U.S. Government Printing Office, June 1988); available
for $3.75 from U.S. Government Printing Office, Washington, DC 20402-
9325; phone (202) 783-3238; request GPO stock number 052-00301122-1.

--Peter Montague


Descriptor terms: superfund; ota; epa; cost-benefit analysis; risk
assessment; remedial action; health effects; birth defects;
reproductive hazards; developmental disorders; immune system disorders;
nervous system;

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