Re: [CPEO-BIF] RBCA again

[LSchnapf@aol.com]

Bob,

I apologize if I gave you the impression that I thought risk-based cleanups 
were a magic bullet. I know there are some real limitations to such approaches 
and they only work if the full-life cycle (planning, implementation, 
monitoring and enforcement) are appropriately performed. I also agree that there are 
lots of problems on the local level with monitoring much less enforcement. That 
is why concepts like the Guardian Trust make alot of sense. 

I was simply trying to countering the views that seemed to suggest to me that 
nothing short of dig and haul, or pump and treat is protective of human 
health. If properly planned, implemented, monitored and enforced, institutional 
controls can protect against exposure to contaminants. While we have made some 
progress since the failure of the Love Canal ICs, I do acknowledge that this is 
a very big "if".  

I just wanted readers to understand that we do not have to have "pristine" 
cleanups which can be an extremely wasteful use of resources and may not provide 
much additional protection. I have always found it curious how people could 
get hysterical  theoretical exposure to a few molecules of a buried hazardous 
substance which they are not exposed to but could in the future , but ignore 
the pesticide-laden food they eat or engage in other harmful habits that pose 
greater risk to themselves than the buried contaminants. 

All I am suggesting is that risk-based approaches can be a viable option 
depending on site conditions and should not be dismissed. However, to be 
protective, I agree that it is necessary for the environmental agencies, the community 
and the landowners to be involved and to make sure that adequate resources 
have to be established for the long-term maintanance and enforcement. Indeed, 
depending on the IC used, dig and haul may be more cost effective over time for 
some sites when the long-term costs of monitoring ICs are taken into account.  

Larry    

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