Re: Definition, VCPs, and Brownfields

["Peter B. Meyer" <PBMEYE02@athena.louisville.edu>]

Emery wanted me to open up the issue of "hazardous waste sites," and
Keith offered a correction I acknowledge -- and opened up with issue
Emery wanted raised.

1. Keith's note references a "contaminated former refinery site" -- and
thus gives an example of a polluted property that is not, in law, a haz
waste site -- which is typically defined in terms of INTENTIONAL
deposits of hazardous wastes. Any old dry cleaner's shop that did what
seemed to be logical at one time - throwing the used up cleaning fluids
out the back door to be absorbed into the ground - is a brownfield, but
is not a haz waste site. Yes, hazardous materials were deposited, but
they were not clearly understood to be hazardous and the disposal
practice was not regulated at the time.
     Other brownfields involve past spills of materials used in
production -- toxics that had immediate value as raw materials, not
wastes. These were not intentionally dposited either, but resulted in
contaminated properties. (Lots of writing - and the Rio Summit's Agenda
21, for that matter - makes the distinction between hazardous industrial
raw materials and hazardous wastes in terms of regulation of transport
and trans-border shipping. I find the distinction inappropriate, but
accept it in order to communicate.)

2. Keith is presumably correct about current practice in Pennsylvania.
He lives and works there. My comment was based on complaints I heard two
years ago from some PA officials about abuse of the "clean"
certification process and excessive demands for the oversight services
of the Department of Environmental Protection (at the time the services
were free; they may no longer be).  I stand corrected. Thanks, Keith,
for the update.

Peter
--
Peter B. Meyer
The E.P. Systems Group, Inc.
P.O. Box 2736
Louisville, KY 40201
 502/896-9448 or 502/852-8032
 Fax: 502/852-4558