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---December 27, 1989---
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[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. 95)

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: SUPERFUND'S PROBLEMS CAN BE SOLVED (Washington, DC: U.S. Government 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, Ph.D.

Descriptor terms: superfund; remedial action; ota; historical aerial photography; hap; site discovery;

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