From: | Lenny Siegel <lsiegel@igc.org> |
Date: | Fri, 23 Aug 1996 02:16:12 -0700 (PDT) |
Reply: | cpeo-military |
Subject: | GAO ON RELATIVE RISK |
From: Lenny Siegel <lsiegel@igc.org> WHAT G.A.O. REALLY SAID ABOUT RELATIVE RISK EVALUATIONS In July, when Congressman William Clinger (R-Pennsylvania) released a General Accounting Office report on federal facilities cleanup, he called the situation "mind-boggling," warning that it confirmed his "worst fears that the government is not doing a good job with its own hazardous waste mess." Initial press coverage of the report caused concern among some of the people who work on these issues - such as members of the Federal Facilities Environmental Restoration Dialogue Committee (FFERDC) - because it seemed to call for a one-size fits all system for ranking the risk of contamination at all federal facilities. ("Federal Facilities: Consistent Relative Risk Evaluations Needed for Prioritizing Cleanup," GAO/RCED-96-150, June, 1996.) In fact, careful reading of the entire report suggests first that the situation is NOT alarming and secondly, that federal agencies are moving in the right direction in their application of risk evaluation to cleanup priority setting. I. NPL Listing GAO actually looked at two forms of relative risk evaluation. The first was the assessment of contaminated federal facilities to determine whether they belong on the "Superfund" National Priorities List (NPL) of the nation's most contaminated properties. It reiterated that federal land management agencies - within the Interior Department, for example - had not yet inventoried their universe of contaminated sites. In addition, GAO found that information collected for the purpose of NPL listing is incomplete for 1,040 of the 2,070 facilities enumerated in the EPA's Federal Facilities docket. (Of the remaining 1,030, 154 facilities are on the NPL, while 873 didn't qualify. Three have been de-listed.) GAO broke down the 1,040 without final site assessment decisions as follows: Agency Need PA Need SI Need NPL Scr. Unknown Total Agriculture 17 24 5 42 88 Defense 84 138 119 222 563 Energy 2 7 5 14 28 Interior 18 37 16 57 128 Transport. 2 21 3 10 36 All others 35 13 9 140 197 TOTAL 158 240 157 485 1,040 GAO's terms/headers for the columns above were: Agency Awaiting prelimary assessment Awaiting site inspection Awaiting final NPL screening Status unknown (The status of some facilities is unknown because the name in EPA's evaluation records cannot always been reconciled with the names in the federal facility docket.) Total There are several reasons why assessment, inspection, and/or NPL screening have not been carried out at those facilities. Most important is funding: "According to EPA officials, the agency's budget permits the agency to perform final evaluations for only five facilities per year." As the above table shows, there are already 157 facilities awaiting such screening. More resources are required, but it is likely that most of the worst sites - the ones that have attracted the most public attention - have already been rated. Some sites that have scored high enough, on EPA's hazard ranking system, to be NPL-listed have been kept off the NPL for policy reasons. This has led decision-makers to move ahead more slowly in evaluating similar sites: "In July, 1995 legislation was enacted requiring EPA, during fiscal year 1995, to seek a state's concurrence before including a site on the NPL. This provision, which effectively gave governors the authority to veto EPA's listing decisions, may significantly affect the consistency and comprehensiveness of the NPL. As of February 1996, EPA had sought state governor's concurrence to list 14 federal facilities. The governors refused to concur with seven listings, approved four, and reached no decision on three. Futhermore, according to EPA officials, the impact of requiring a state's concurrence is greater than those numbers would indicate because EPA's regions will not move a facility forward in the Superfund process if a governor's veto is expected. EPA's 1996 appropriations language continues the requirement that EPA obtain a state's concurrence for the remainder of the fiscal year or until CERCLA is reauthorized." In addition, GAO found that EPA may give NPL-listing a low priority at facilities where other factors, such the presence of a RCRA Corrective Action cleanup program or base closure, are driving the cleanup. I have long believed that NPL listing accelerates the cleanup of federal as well as privately owned properties, and I support budget and policy initiatives to add properties that qualify to the list. Nevertheless, it is misleading to suggest that because facilities are awaiting NPL screening or have been deferred that federal cleanup programs are a mess. Cleanups, in general, are proceeding at seriously contaminated properties whether or not they are on the NPL. At a handful of major non-closing bases, such as the Badger Army Ammunition Plant, in Wisconsin, it is possible that the failure to list the property has made it hard to line up remediation funding. Furthermore, while some federal agencies support the policy decisions that have kept facilities off the NPL, the backlogs and deferrals are not the result of mismanagement, but of deliberate policy decisions by Congress and governors in key states. II. Priority-Setting GAO is generally favorable to the Defense and Energy Departments' new methods of using relative risk evaluation to help set cleanup funding priorities. It even acknowledges FFERDC's recommendation, consistent with Defense Department practice, that other factors besides risk warrant consideration in setting priorities. But it notes that the "high" risk category is too broad. 54% of the roughly 7,500 sites that Defense has evaluated are ranked high, creating difficulty for allocating resources among those sties. That's a valid concern. GAO reported its previous call for a national priority-setting process, and it noted the National Research Council's recommendation for a "unified national process" - a recommendation that has been overinterpreted in some circles. In its current report, GAO states, "We believe that a consistent approach for relative risk evaluation is an essential element in the process for setting cleanup priorities nationally." In context, however, this does not necessarily mean a national ranking system. GAO positively reviewed the regional approach to priority-setting initiated by the Naval Facilities Engineering Command, Southwest Division, in 1992. Navy staff and West Coast regulators (states and U.S. EPA) meet regularly (at least annually) to reconsider cleanup priorities, using the relative risk ranking as a tool. However, GAO cited an EPA official who said that this approach might not scale up to cover larger areas. Furthermore: "The EPA official believes that the next step fo the West Coast team would be to involve community advisory boards in the priority-setting process." A more challenging next step is to figure out how to apply this successful consultative process to the other armed services, which organize their cleanup programs by national command, not geography. If, when Congress looks seriously again at the Superfund law, it seeks to require the "consistent" process that GAO recommends, then it will be important to ensure that it considers under that rubric successful models of regional consultation, such as the Navy's West Coast program, as opposed to black-box, top-down uniform ranking systems. Lenny Siegel | |
Prev by Date: MOFFETT FIELD REUSE Next by Date: Rep. Cox (R-Ca) vows cleanup @ El Toro | |
Prev by Thread: MOFFETT FIELD REUSE Next by Thread: Rep. Cox (R-Ca) vows cleanup @ El Toro |