1995 CPEO Military List Archive

From: Lenny Siegel <lsiegel@igc.org>
Date: Mon, 09 Jan 1995 09:57:20 -0800 (PST)
Reply: cpeo-military

 I finally had the chance - on an airplane, of course - to read 
key sections of the National Research Council report, RANKING 
(National Academy Press, 1994). Though the committee that put 
together the report is not directly involved in either policy-setting or 
project implementation, the NRC is prestigious and its 
recommendations could influence the current discussion of priority-
setting in the cleanup of contaminated Federal facilities. Originally 
reported in the press as a call for opaque-box numerical mechanisms 
for setting cleanup priorities, the NRC proposal isn't quite that bad - 
if understood in its full context.

 The NRC examined the Hazard Ranking System, used by 
EPA to place facilities on the Superfund list, the Defense 
Department's Defense Priority Model, and the Energy Department 's 
Environmental Restoration Priority System, and it reviewed the 
approaches taken by several states. It concluded that those risk-rating 
methods were inconsistent and poorly defined. 

 It is important to recognize, however, that the different 
models are supposed to serve different functions. Moreover, a new 
approach - Risk-Based Site Evaluation, also known as the Rubik's 
cube method - has superseded the Defense Priority Model at the 

 The NRC recommended: "To the maximum extent possible, 
the overall priority-setting processes, including the mathematical 
models used, should be similar across the various Federal agencies." 
It added, "This uniform national priority-setting process should be 
more scientifically based, explicit, and open and accessible to the 
public..." It did not, however, urge the creation of a single, cross-
agency site list determining relative risk or cleanup priority.

 In fact, the NRC recognized that risk should be the sole factor 
in priority-setting: "For much of the priority-setting processes, 
concrete procedural descriptions were typically unavailable, so that 
most of the committee's information had to be sought by exploratory 
questioning of agency officials and experts who met with the 
committee. As a result, the committee's findings focus more on 
SETTING PROCESSES. The distinction is an important one. Most 
of the systems developed to date are used only to rank sites 
according to some numerical score; these scores are considered, 
along with other factors, to arrive at actual remedial priorities, which 
can be quite different from the numerical scores."

 In particular, the NRC committee suggests, "A 
comprehensive site evaluation model should include explicit 
considerations not only of human health and the environment, but 
also of socioeconomic impacts on the surrounding community. Such 
considerations are probably always part of the priority-setting 
process, but they generally are not made explicitly, and so are not 
open to public scrutiny and evaluation." One such consideration, 
mentioned by the NRC, is cost.

 The NRC panel of scientists actually recognized the 
significance of public participation: "The process of developing a 
model (or any major component of the model) should be as open as 
possible, involving both stakeholders and the technical community." 
It still tends toward numerical interpretations, however. The NRC 
recommends: "Value preferences should be explicit in the models, 
and coefficients reflecting these preferences should be developed 
with the affected parties in an open and well-defined process."

 Finally, the NRC recognized that the remediation process has 
multiple phases. It concluded, "The priority-setting process should 
have a common mechanism for identifying serious immediate 
hazards or emergency conditions and pulling them out of the longer-
term priority-setting process... A unified approach should also 
include a formal site-discovery program, which is currently lacking. 
It should also include a process for tracking site remediation progress 
and monitoring sites that may pose dangers far into the future."

 From the sections of the report that I have, it appears that the 
NRC ignored entirely the role of enforceable legal agreements in 
setting cleanup priorities. This was beyond its charge. Nevertheless, 
the report leaves the reader with the implication that experts - even at 
major polluting agencies such as Defense and Energy - should have 
the final say in determining what gets cleaned when.

 There is a danger that those who wish to cap cleanup 
spending will use the NRC's recommendations - or at least some of 
the headlines that accompanied the report's release earlier this year - 
to justify lower environmental budgets and to impose, unilaterally, 
the termination or curtailment of local remedial activities at many 
sites. But that isn't what the NRC recommended.

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