Mr. Big Bob Splains Superfund CERCLA

I taught enviro law many years ago–

I knew from reading it as a lawyer that CERCLA/Superfund was a bureaucrat’s dream and the citizen’s nightmare, but no doubt an annuity for lawyers and consultants and agency apparatchiks.
Bob Greene, sidekick at this website, is a chemist, and a compliance man in industry, so he knows CERCLA/Superfund, among other things, from the inside and is an expert.
I asked him to comment and I want his comments to be more prominent.
CERCLA is Comprehensive Enviro Response, Compensation and Liability Act of 1980.
Superfund is basically clean up bad site law.
Not surprising, he has done some work on clean up.
EPA can’t manage the Superfund programs very well. …
The Richmond Times-Dispatch ran the same article with an interactive map. It also had a picture of old 55-gallon drums instead of the cute shot of burning tires. http://www.timesdispatch.com/special-section/superfund/toxic-superfund-sites-are-still-with-us/article_d2af1523-96bf-5da8-9ae2-48d5b2b7c9bb.html
The interactive map shows that most of the sites are in the constructed remediation phase with many of those in the 5-year evaluation phase, with multiple evaluations. Also, being Virginia, a goodly number of the sites are US Government locations.
Although advertised differently when our leaders had this great idea, the whole process is not particularly fast. It turns out to be a full and long-term employment act for lawyers, bureaucrats, consultants and us lowly industrial environmental types. The process from goes from identification, making the National Priorities list, identifying the potentially responsible parties (and it is a wide net), more meetings than you can bear, coming up with a Record of Decision, implementation of the cure and then long-term monitoring. Most of the Virginia sites are in the monitoring phase. Since most have groundwater contamination, they can go own forever.
For a good number of the sites, particularly leaking landfills, the best solution may be to put an impermeable cap on the landfill and then intercept and pump/treat groundwater. This is not a short-term proposition.
For a good number of these sites, the owners declare bankruptcy, so the EPA casts a wide net for the “polluters,” anyone who has done business with these folks.
The whole process moves along with people who want to contain costs (potentially responsible parties, PRP’s) and people who couldn’t care what it costs (bureaucrats, consultants and lawyers). You couldn’t design a more inefficient, wasteful program if you tried.
End of comment.
Thanks Mr. Bob.

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