Natural Attenuation (NA)

[Steven Pollack <themissinglink@eznetinc.com>]

Saturday, August 15, 1998

If this was not so serious I would find it funny that Natural
Attenuation was being seriously discussed as an action under CERCLA or
RCRA. How is the attenuation, or dilution, of toxins protective of the
environment? The only sense I can make of this is that the polluters
and regulators are trying to give no action (na) a name, and official
designation, as to make it an action under CERCLA or RCRA. Then,
citizen suits could not be brought because remedial action would be
undertaken.

The guy who thought up NA must have been given several promotions for
creativity. I have thought up the next generation of cleanup options.

Human Imuno-Attenuation (HIA) Whatever does not kill you makes you
stronger. The premise is that anything which is not bioaccumulative will
be attenuated naturally through the immune system. NA, as enacted in
1999, effectively shifted the focus from the environment to the toxic
pile in what was being remediated under CERCLA and RCRA. Therefore it
is the toxin, and not human health, which is being remediated and
facilitated by HIA.

Deterministic Aggregation (DA) By recognizing that all toxins
potentially exist in the environment, the realization (extraction) of
the toxins and placement within discreet areas of the environment,
through operations, actually cleans up larger tracts of the environment
than it pollutes. Coupled with NA and Institutional Controls, we can
throw our arms up in victory in cleaning up the environment.

I really shouldn't joke........

Natural Attenuation does not clean up the environment, it pollutes the
environment and cleans up the toxic area. The solution to pollution is
not dilution because the toxic loading on systems which affect humans
increases over time. This dilution argument is more effective when
applied to a single site but falls short of protection of human health
and the environment when addressing thousands of sites within the
ecosystem.

Like I have said on so many issues, this is more properly a topic to be
decided through public policy, not the regulatory and military
community. There is less scientific certainty for these decisions and
more public interest for a clean environment. It would be one thing if
the public was calling for more lax environmental standards than the
regulatory/military community but the only opposition to current plans I
see is for higher standards. Therefore I cannot understand the
resistence of the government to the will of the public for higher
cleanup standards. When did your mandate become saving taxpayer money?
You don't even want to open up that discussion.

Steven Pollack
http://www.familyjeweler.com/rdx.htm