|From:||Lenny Siegel <firstname.lastname@example.org>|
|Date:||Mon, 09 Jan 1995 09:57:20 -0800 (PST)|
NATIONAL RESEARCH COUNCIL ON RANKING I finally had the chance - on an airplane, of course - to read key sections of the National Research Council report, RANKING HAZARDOUS-WASTE SITES FOR REMEDIAL ACTION (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 Moreover, a new approach - Risk-Based Site Evaluation, also known as the Rubik's cube method - has superseded the Defense Priority Model at the Pentagon. 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 SITE-RANKING METHODS than the broader PRIORITY- 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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