© 1988, 1998 by Donald J. Stierman
Because of the relatively recent awareness of the hazards associated with casual disposal of chemical wastes, the number and location of sites, and, real (as opposed to felt, or perceived) risks of discarded chemical wastes remain poorly known. Citizens have grown to distrust public officials and the owners and operators of waste disposal operations for a number of reasons. On one hand, public officials have at times disregarded citizen concerns that were later proven valid. On the other hand, some citizen groups ignore technical data that contradict their fears, prejudice or political agenda.
Because poorly planned or operated waste disposal sites might become "SUPERFUND" sites of the future, this sort of approach taken before an operation is approved may save a great deal of money in the long run.
We are all part of the chemical waste hazard "problem." We all use products that generate hazardous chemical wastes. We all benefit from technical cost-cutting solutions to problems such as insect damage to crops, buildings and clothing (mothballs, anyone?), from chemical cleaners, from plastics and synthetic fibers. Even the cosmetics industry and solar technologies generate hazardous chemical wastes. But, even if a solution to newly generated waste was discovered today and implemented tomorrow, we would still be faced with the task of cleaning up the thousands of sites contaminated prior to legislation of the mid- to late-1970s. Coupled with our responsibility to deal with chemicals in a manner which poses as small a risk as is reasonable (recall that risk = hazard AND exposure), citizens have the right to participate in decisions regarding the risk to which they will be exposed. Meaningful citizen participation in decisions regarding the siting of new and/or cleanup of old waste disposal sites serves to decrease community antipathy by requiring regulatory agencies to conduct their (rather, our public) business in the open.
There is often considerable resistance to meaningful community participation. Many SUPERFUND sites are being litigated, and attorneys for all sides usually prefer to control the flow of information. In my opinion, the public is entitled to whatever information is available - after all, open discussion of waste disposal operations or SUPERFUND sites can hardly be a threat to national security, personal privacy or fair competition in business.
Enough already on the need and right to know (more to be written on this later). How do we go about cleaning up a SUPERFUND site?
A. Identify the problem.
Often, when a problem is identified (such as a local abandoned waste disposal site) citizens demand immediate action to mitigate the threat posed by this site. They expect fleets of trucks and excavation equipment to remove any contamination. This can waste both time and money. At Stringfellow, trucks hauled some waste away to the BKK landfill, which later became a SUPERFUND site.
1. Site history
setting (geology, hydrology, climate, land use history)
operations: what was received, when, and in what quantities.
legal status (ownership, permits and permit stipulations, tax records)
improvements (engineering plans, inspection reports)
Some tools:
topographic, geologic, soils maps
aerial photographs (archives)
files - city, county, state letters/permits/zoning decisions
health records: is there evidence (or reason for suspicion) that the site has affected public health?
newspaper reports (use with care!)
Beware of any report claiming to have examined "ALL AVAILABLE INFORMATION" unless that report includes a list of information sources - a complete bibliography. Information used to make critical decisions must be supported by reference citations sufficiently specific such that the original source can be checked.
The ease with which additional information is discovered provides a clue as to how thorough those who prepared such a report were in doing their jobs.
2. Identify critical unknowns
spatial distribution of contamination (map showing concentrations as a function of depth or thickness)
rate at which contamination is migrating, directions of migration
hydrogeologic factors that control migration of contamination
nature of the contamination (liquid, solid, gas)(physical and chemical attraction to materials it contacts)
health effects and health concerns (perceptions)
behavior of the contamination in the earth (changes effected by organisms, chemical reactions, dilution)
3. Plan an exploration program aimed at learning the answer to the "unknowns" listed in (2), above.
surface samples (mapping, chemical testing)
drilling, sample collecting and analysis
indirect (geophysical, soil gas) measurements to improve on the coverage (drilling is expensive)
4. INTERPRETATION AND INTEGRATION OF DATE INTO AN OVERALL CONCEPTUAL FRAMEWORK - need to understand what is going on.
A TEST: how do we know that we have drilled enough holes?
A. When we can confidently predict what a new hole will encounter prior to drilling that hole.
B. When a critical, aggressive investigator can honestly state that there are no significant questions that remain unanswered.
THE NEED FOR CRITICAL, AGGRESSIVE INVESTIGATORS: If an exploration effort is conducted in a casual manner, it may not be difficult to honestly state "nothing was found" despite the possibility that significant problems exist. Unfortunately, administrators are often under pressure to keep costs down, so it is easier to limit the "turning over rocks" part of a study, so as to eliminate the possibility of uncovering a problem too big to handle, than it is to discover and document a problem too large to handle with available resources. One major flaw in current U.S.E.P.A. management of waste disposal landfills is reliance on the integrity and skills of geologists working for and paid by the landfill operator. Opinions rendered by these geologists are reviewed by attorneys, much in the manner attorneys reviewed reports written by scientists employed by tobacco companies. The U.S.E.P.A. reviews documents prepared by consultants working for the landfill operator but seldom, if ever, conducts independent verification of any sort. Furthermore, there is reason to suspect that most of these U.S.E.P.A. reviewers are not the most experienced or skillful geologists. It is my opinion that, over time, the U.S.E.P.A. has become less technically competent and more political in its regulatory role. Should the USEPA wish to challenge me in this matter, I have their response to my technical comments on file and, based on these documents, would be happy to place the matter before a jury of 12 geologists selected from the U.S. Geological Survey or from the faculties of Ph.D.-granting geology departments.
Once the problem has been defined, solutions can be discussed and debated. Solutions may include and or all of the following::
REMOVAL
REMOVAL, TREATMENT AND RECLAMATION
IN SITU TREATMENT
WATER EXTRACTION AND TREATMENT
IMPROVEMENT OF ISOLATION IMPROVEMENTS
PURCHASE OF AND VACATING THREATENED PROPERTY
REPLACEMENT OF WATER LOST BY CONTAMINATION
DO NOTHING
OTHERS
I am pleased to report having worked with one engineer whose philosophy is "Discover and tell me the bad news now, then we can get right to work on solving the problem."
On the other hand, I heard another engineer tell citizens at a public hearing that he had measured the amount of water being pumped from a pit using two different methods and came up with the same answer both times. It was later demonstrated that this engineer's calculations understated the actual water flow by at least a factor of 4. Because his rate of pumping was also a boundary condition for his calculation of the effect on local monitoring wells, I wonder what additional errors were necessary in order to obtain the excellent agreement he reported between predicted and observed effects of pumping on those monitoring wells. As they say, figures don't lie, but liars figure. The lesson is, hire competent help, experts who can identify flaws in technical snow jobs.