Re: Definition, VCPs, and Brownfields

[Lenny Siegel <lsiegel@cpeo.org>]

I'm not sure if anyone else has tried to clarify this issue yet, but
it's my understanding that hazardouse wastes include both intentional
and non-intentional releases. Dry cleaners that have released PCE into
the soil and groundwater are hazardous waste sites. If they are
abandonned, they may also be brownfields.

Much of the pollution we're now trying to clean up seemed logical at the
time it occurred.

Lenny

Peter B. Meyer wrote:

> 1. Keith's note references a "contaminated former refinery site" -- and
> thus gives an example of a polluted property that is not, in law, a haz
> waste site -- which is typically defined in terms of INTENTIONAL
> deposits of hazardous wastes. Any old dry cleaner's shop that did what
> seemed to be logical at one time - throwing the used up cleaning fluids
> out the back door to be absorbed into the ground - is a brownfield, but
> is not a haz waste site. Yes, hazardous materials were deposited, but
> they were not clearly understood to be hazardous and the disposal
> practice was not regulated at the time.


-- 


Lenny Siegel
Director, Center for Public Environmental Oversight
c/o PSC, 222B View St., Mountain View, CA 94041
Voice: 650/961-8918 or 650/969-1545
Fax: 650/968-1126
lsiegel@cpeo.org
(PLEASE NOTE THAT WE ARE PHASING OUT
MY OLD E-MAIL ADDRESS: lsiegel@igc.org)
http://www.cpeo.org