Prioritizing Superfund Cleanups


Everybody loves a good Top 10 list. Movies, airports, presidents, you name it - people enjoy arguing about how things stack up against one another. 

Last week, EPA Administrator Scott Pruitt unveiled an idea for a Top 10 list that is sure to create controversy: a new ranking intended to prioritize Superfund hazardous waste cleanups. It is intended to be a list with a purpose -  identifying sites where Administrator Pruitt himself would get personally involved to move cleanup ahead. 

On one level, this might seem uncontroversial - until one realizes that Superfund sites are already ranked based on the relative threat they pose to the public, on what is called the National Priorities List. The sites on the National Priorities List are ranked using a data-driven methodology. How Pruitt will set his own priorities list is anyone’s guess. 

The 1,336 sites on the National Priorities List have all received scores using the Hazard Ranking System (HRS), adopted in 1982 to help set priorities for Superfund cleanup. HRS scores the relative threat of each given site to public health or the environment from 0 to 100. That score is determined by evaluating four pathways for exposure - groundwater, surface water, soil and air - using the information available from preliminary assessments and site inspections. It’s also a screening tool: if a site’s HRS score is greater than 28.5, then EPA considers the site to present a great enough threat to warrant federal cleanup and proposes to add the site to its National Priorities List. 

The Top 10 Superfund sites based on the hazardous ranking scores are: 

Score Name Location In a Nutshell
84.91 Big River Mine Tailings/St. Joe Minerals Corp. 70 miles south of St. Louis, MO Mining waste in the “Old Lead Belt”
76.81 Washington County Lead District Old Mines, MO 90 square miles of abandoned mines and waste
76.81 Washington County Lead District Richwoods, MO 45 square miles of abandoned mines and waste
75.6 Lipari Landfill Mantua Township, NJ 16-acre landfill closed in 1971
74.86 McCormick & Baxter Creosoting Co. Stockton, CA 29-acre former wood preserving facility
72.66 Helen Kramer Landfill Mantua Township, NJ 66-acre refuse area closed in 1981
72.42 Industri-Plex Woburn, MA Former chemical and glue manufacturing facility
71.78 Taylor Lumber and Treating Sheridan, OR Acting wood treating facility
70.82 Pearl Harbor Naval Complex Pearl Harbor, HI Active military facility over 12,600 acres
70.71 Kerr-McGee Chemical Corp. Jacksonville, FL Former wood-treating plant

If a Top 10 list for Superfund sites already exists, why create a new one? It’s unclear. But Administrator Pruitt, in discussing the matter, has repeatedly referred to a St Louis landfill and a public housing complex in Chicago, leading reporters to speculate that they may make the Administrator’s list - yet those two sites have received hazardous scores of 58.31 (rank 76) and 29.85 (rank 1,248) respectively, nowhere near the scores of the top 10 sites on the National Priorities List.

‘Black mayonnaise’ is the term commonly used to describe the sludge that coats the bottom of the Gowanus Canal in New York, a Superfund site that received a HRS score of 50.00 (rank 396) when it was added to the National Priorities List in 2010. Photo: Jeffrey, licensed under CC-BY-SA 2.0. 

Much will depend on how the Top 10 list is chosen. But in the absence of clear and transparent criteria for ranking the sites, Administrator Pruitt’s Top 10 could serve as a mechanism to boost sites that he believes are more important from the middle or the bottom of the list. Conversely, in promoting relatively low-priority sites, the Administrator could also sweep sites with high HRS scores to the side.. 

In either case, by ignoring a data-driven prioritization system based on a scientific understanding of the risks posed by hazardous waste sites, Pruitt is acting in a manner consistent with his emerging track record of rejecting environmental science. Administrator Pruitt continues to question whether carbon dioxide causes climate change despite overwhelming evidence amassed over decades; chose not to ban the pesticide chlorpyrifos even after EPA scientists recommended a ban because of potential harm to children and farm works; and has not reappointed scientists to the agency’s Board of Scientific Counselors, instead stacking the board with representatives from the very industries the EPA regulates

Boiling down Superfund cleanup to a Top 10 list is not an effective strategy to keep Americans safe from exposure to hazardous waste from contaminated sites - especially if that list is determined in ways that don’t square with the best scientific understanding of the risks those sites pose to public health. Science must remain at the heart of the Superfund program. And with more than 1,300 dangerous hazardous waste sites awaiting cleanup, there is no excuse for narrowing our view (or EPA’s funding) to focus on only the very worst of the worst.