WHITE HOUSE ISSUES CLEANUP REPORT

[Lenny Siegel <lsiegel@igc.org>]

WHITE HOUSE ISSUES CLEANUP REPORT

The Federal Facilities Policy Group, headed by Alice Rivlin (Director, 
Office of Management and the Budget) and Kathleen McGinty (Chair, 
Council on Environmental Quality), has at long last issued a report, 
IMPROVING FEDERAL FACILITIES CLEANUP (October, 1995). The Policy Group 
is made up of those two White House offices and high level 
representatives from nine other Federal Agencies and Department.

When Rivlin and McGinty first formed the Policy Group nearly two years 
ago, other stakeholders in the Federal facilities cleanup process 
expressed concern that this high level group would ignore the work of 
multi-stakeholder forums, such as the Federal Facilities Environmental 
Restoration Dialogue Committee (FFERDC), exaggerate the cost of 
cleanup, and impose radical solutions. After appearing to founder for 
many months, the Policy Group has issued a report that documents the 
magnitude of known Federal cleanup obligations, reaffirms the work of 
FFERDC and others, and re-packages a series of existing policies and 
recommendations.

The Policy Group summarizes the extent of contamination at five Federal 
departments and agencies. The following is extracted from that summary. 
I consider the figure for the Defense Department to be, at the very 
least, several billion dollars below the best estimates, and the data 
on the Agriculture and Interior Departments to be preliminary. 
Furthermore, as the table notes, counting facilities for Agriculture 
and Interior does not make sense because much of their contamination 
consists of relatively small sites, such as abandoned mines, on large 
landholdings, such as national forests.

Agency # Facilities # Active Sites Estimated cost to complete

Energy Department 137 10,000 $200 to $350 billion

Defense Department 1,769 11,785 $26.2 billion

Interior Department NA 26,000 $3.9-$8.2 billion

Agriculture Department NA 3,000 $2.5 billion

NASA 17 575 $1.5-$2 billion

Most of the findings and recommendations of the Policy Group are 
non-controversial, in contrast to some of the proposals - such as a 
government-wide ordinal ranking of cleanup sites - that it originally 
considered. Overall, I find the approach reasonable.

It lists sixteen Principles of Reform, adapted from two similar lists 
put forward by FFERDC and the Environmental Commissioners of the 
States. The Group likes stable funding, stakeholder involvement, 
technology development, and improved management. It supports the 
improvement of risk-based systems of establishing priorities, but it 
shares FFERDC's concerns about the limitations of such systems. It 
repeats administration policies for the legislative and administrative 
reform of hazardous waste laws.

The report, however, fails to deliver on the promise embodied in its 
title. The bulk of the report is dedicated to reducing the enormous 
cost of cleanup, a laudable goal, but not the only area where cleanup 
needs improvement. That slant would be easier to swallow if the report 
were instead entitled, "Reducing the Cost of Federal Facilities Cleanup."

There are a few areas where the report itself could use improvement.

1) It overestimates the costs savings likely to result by tailoring 
remedy selection to non-residential land uses. It cites a dramatic 
example at Fernald, Ohio, where the Energy Department says that 
"cleaning to reuse" cut life-cycle cleanup by $1 billion. No doubt 
there are other, similar examples, but in general cleanup costs are 
driven by the threat that contamination poses to water supplies. Even 
soil contamination is treated to protect water supplies.

2) The Group is ready to let the neighbors of facilities help decide 
how to stretch cleanup dollars - that is, to decide what projects may 
be put off, but it does not propose that communities offer advice in 
other areas, such as determining whether facilities should be kept off 
the "Superfund" National Priorities List or if lead regulatory 
authority should be transferred to state agencies from the 
Environmental Protection Agency.

3) It supports the Defense Department's proposal to allow the transfer 
of closing bases before cleanup remedies are in place. 

4) Though it discusses in detail the Energy Department's challenges in 
remediating radioactive wastes, it makes no mention of the Defense 
Department's enormous potential cost and technological difficulty in 
dealing with millions of acres of munitions impact ranges.

The 100-page report is being distributed by the White House Office of 
Management and the Budget, but it is my understanding that only a small 
amount of copies were printed.

Lenny Siegel