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#161 - Superfund -- Part 2: EPA Avoids Systematic Search For Superfund Sites: 'We Have Enough.', 26-Dec-1989

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), cited in our last paragraph, below.

No one knows how many chemically-contaminated sites exist in the U.S.
because no one has ever carried out a systematic search for sites. This
may seem difficult to believe after 10 years of Superfund effort, yet
it is true. OTA says, "We do not know how many sites there are because
there has been no comprehensive or systematic search for them." (pg.
85) Furthermore, OTA concludes that a systematic search for sites will
never occur unless Congress specifically tells EPA (U.S. Environmental
Protection Agency) or someone else to conduct such a search; left to
decide for itself, EPA will never conduct a national search for sites.
"[T]he history of the Superfund program so far tells us that a
comprehensive site discovery program will not occur unless Congress
gives explicit direction to EPA, or some other authority, to
proceed." (pg. 85)

It is no secret within the government that there has never been a
systematic search for contaminated sites. In 1982 the General
Accounting Office (GAO) said "a national hazardous waste site inventory
does not exist." In 1985 GAO said, "A complete inventory of hazardous
waste sites does not exist." In late 1987 GAO said, "While still not
fully understood, the extent of the nation's potential hazardous waste
problem appears to be much larger than is indicated by EPA's inventory
of sites." (pg. 87)

Why should we care? Because, as OTA says, "[T]here is massive
documentation of substantial contamination of air, land, surface water,
and groundwater in virtually every part of the United States. For many
of the prevalent contaminants, there is undisputed information on
adverse health and environmental effects." (pg. 22) OTA points out that
ignoring potential sites only saves resources in the short term and
decreases protection of human health and the environment. (pg. 87) In
the long term, sites we ignore will come back to cost us more. Sites
tend to get worse as time passes; chemicals spread, contaminating
larger areas, so the cleanup problems are made worse, not better, when
we ignore sites. Ignoring sites is thus a waste of money and a danger
to the citizenry.

It seems self-evident that EPA would want to discover new sites, to
protect the environment and human health. Yet EPA said in 1981 that a
systematic search for sites was "against EPA policy." (pg. 87) EPA has
never requested funds from Congress for site discovery. EPA has no site
discovery program. EPA has no budget for site discovery. EPA does not
allow states to spend Superfund monies for site discovery. (pg. 88)

Why does EPA not want to discover new sites? Historically, EPA has
given two reasons for devoting zero resources to site discovery: (a)
they say the extent of the problem is known and all the really bad
sites have already been discovered; (b) they say the Superfund staff
has its hands full already, and the discovery of many new sites would
choke the system.

OTA has evaluated the question, "Have the worst sites all been
discovered already?" EPA ranks new sites by a technique called the
Hazard Ranking System (HRS), which assigns a numerical value to each
site; the more hazardous a site, the bigger its number. If the worst
sites have been discovered already, there should be a decline in the
HRS scores of recently-discovered sites. However, no such decline can
be seen in EPA's HRS data from 1983 through 1989, so OTA concludes that
recently-discovered sites are no less dangerous than older sites
discovered in the early 1980s. (pgs. 125-126)

In fact there is evidence that EPA officials themselves have recently
abandoned the idea that the extent of the problem is already known and
that all the really bad sites have already been discovered. GAO's 1987
report said, "EPA officials now recognize that many more hazardous
waste sites may exist, [but] they believe a higher priority is to meet
the deadlines imposed by [the 1986 Superfund amendments called SARA]
for assessing and evaluating those sites already included in the
CERCLIS inventory." (pg. 88) (CERCLIS is the list of sites that
eventually get evaluated to see if they belong on the official
Superfund list of sites that must be cleaned up; see RHWN #160, which
describes how the Superfund process works.)

In other words, EPA's current reason against a systematic site
discovery program is the bureaucratic argument that, "We know enough
without it to keep us busy for years." This argument ignores the
environmental mission of the Superfund program, and it preserves a
crisis atmosphere within the Superfund program. The crisis atmosphere
disrupts the program. So long as there is no systematic attempt to
discover sites and evaluate them to decide which ones are immediate
threats and then focus resources on the worst sites, each discovery of
a new site engenders frightening publicity that tends to push existing
work aside.

EPA has, on occasion, seemed to say that a systematic site discovery
program would be impossible. In 1985, William Hedeman, Jr., who was
then director of the Superfund program, said, "The national inventory
[CERCLIS, not the NPL (Superfund) list itself] has grown about 3000
sites a year. It is growing faster than we have the resources to assess
and inspect those that have come to our attention. I'm not sure,
frankly, what more we could do. Or how one would go about actively
investigating for the presence of new sites...." (pg. 87)

But OTA has described a technique that could be used to systematically
survey for chemical dumps: historical aerial photography, or HAP. The
entire U.S. land surface has been photographed from the air since the
1920s; especially since 1938, these photos have been taken about every
five years, for map making and soil conservation purposes. Areas
undergoing the most rapid development have been photographed most
exhaustively, every three to five years. The photographs are taken from
an altitude of 12,000 feet using stereoscopic cameras; the resulting
photographs give a 3-dimensional view of the land surface.

Since 1973, EPA has had an Environmental Information Photographic
Interpretation Center (EPIC) that has proven the value of historical
air photography for site discovery. In fact, in 1980, EPIC began a
program to evaluate 200 cities, to discover chemically contaminated
sites. (pg. 90) However, in August 1981 (as the Reagan administration
settled in) EPA's comptroller announced, "We already have more sites
than there is money for, so we do not need more" (pg. 89) and the 200
Cities Project was canceled. OTA reports on six small projects that
used HAP to discover sites (pgs. 96-97), and OTA concludes that HAP
works well and is "a very useful tool" for discovering new sites. (pg.

A systematic nationwide search for contaminated sites would allow us to
spend Superfund cleanup money wisely because it would enable us to know
that we were spending funds on the biggest problems first, yielding the
greatest possible reduction in hazards. Until such a search is
conducted, we will spend money not knowing whether it is well-spent.

Bad sites that are ignored will only get worse and thus more expensive
to clean up. OTA recommends new ways of looking at sites (which we will
discuss in a future issue) so that we can focus on today's real
problems before we focus on future problems. Right now we are spending
money on some sites that are not, today, hurting anyone; at the same
time, we are ignoring, or proceeding exceedingly slowly on, sites that
pose immediate dangers. A systematic search for sites is needed before
we can have a wise allocation of Superfund resources.

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.

--Peter Montague


Descriptor terms: superfund; remedial action; ota; historical aerial