Does Hazardous-Waste Testing Follow Technical Guidance, Thus Help Protect Environmental Justice and Health?

Does representative hazardous-waste-site testing tend to follow or to violate government technical guidance? This is an important question, because following such guidance promotes reliable risk analysis, adequate remediation, and environmental-justice and -health protection. Yet only government documents typically address this question, usually only when it is too late, when citizens have already exhibited health harm, allegedly from living or working near current/former hazardous-waste sites. Because no systematic, representative, scientific analyses have answered the preceding question, this article begins to investigate it by posing a narrower part of the question: Does representative US testing of volatile-organic-compound (VOC) waste sites tend to follow or to violate government technical requirements? The article (i) outlines US/state-government technical guidance for VOC testing; (ii) develops criteria for discovering representative US cases of VOC testing; (iii) uses the dominant US Environmental Protection Agency method to assess whether these representative cases follow such guidance; (iv) employs the results of (iii) to begin to answer the preceding question; then (v) discusses the degree to which, if any, these results suggest threats to environmental health or justice. Our initial, but representative, results show that almost all US VOC-waste-site testing (that we investigated) violates government technical requirements and systematically underestimates risks, and this may help justify less expensive, potentially health-threatening cleanups, mostly in environmental justice communities. We outline needed future research and suggest two strategies to promote following government technical guidance for hazardous-waste testing.

Health Misinformation about Toxic-Site Harm: The Case for Independent-Party Testing to Confirm Safety.

Health misinformation can cause harm if regulators or private remediators falsely claim that a hazardous facility is safe. This misinformation especially threatens the health of children, minorities, and poor people, disproportionate numbers of whom live near toxic facilities. Yet, perhaps because of financial incentives, private remediators may use safety misinformation to justify reduced cleanup. Such incentives exist in nations like the United States, where most toxic-site testing/remediation is semi-privatized or voluntary, conducted by private parties, commercial redevelopers, who can increase profits by underestimating health harm, thus decreasing required testing/remediation. Our objective is to begin to determine whether or not interested parties misrepresent health harm (at hazardous facilities that they test/remediate/redevelop) when they use traditional and social media to claim that these sites are safe. Our hypothesis is that, contrary to the safety claims of the world's largest commercial developer, Coldwell Banker Real Estate/Trammell Crow (CBRE/TCC), the authors' screening assessment, especially its lab-certified, toxic-site, indoor-air tests, show violations of all three prominent government, cancer-safety benchmarks. If so, these facilities require additional testing/remediation, likely put site renters at risk, and may reveal problems with privatized hazardous cleanup. To our knowledge, we provide the first independent tests of privatized, toxic-site assessments before cancer reports occur. Our screening assessment of this hypothesis tests indoor air in rental units on a prominent former weapons-testing site (the US Naval Ordnance Testing Station, Pasadena, California (NOTSPA) that is subject to carcinogenic vapor intrusion by volatile organic compounds, VOCs), then compares test results to the redeveloper's site-safety claims, made to government officials and citizens through traditional and social media. Although NOTSPA toxic soil-gas concentrations are up to nearly a million times above allowed levels, and indoor air was never tested until now, both the regulator and the remediator (CBRE/TCC) have repeatedly claimed on social media that "the site is safe at this time." We used mainly Method TO-17 and two-week sampling with passive, sorbent tubes to assess indoor-air VOCs. Our results show that VOC levels at every location sampled-all in occupied site-rental units-violate all three government-mandated safety benchmarks: environmental screening levels (ESLs), No Significant Risk Levels (NSRLs), and inhalation risks based on the Inhalation Unit Risk (IUR); some violations are two orders of magnitude above multiple safety benchmarks. These results support our hypothesis and suggest a need for independent assessment of privatized cleanups and media-enhanced safety claims about them. If our results can be replicated at other sites, then preventing health misinformation and toxic-facility safety threats may require new strategies, one of which we outline.

Data-Quality Assessment Signals Toxic-Site Safety Threats and Environmental Injustices.

Most hazardous-waste sites are located in urban areas populated by disproportionate numbers of children, minorities, and poor people who, as a result, face more severe pollution threats and environmental-health inequalities. Partly to address this harm, in 2017 the United Nations unanimously endorsed the New Urban Agenda, which includes redeveloping urban-infill-toxic-waste sites. However, no systematic, independent analyses assess the public-health adequacy of such hazardous-facility redevelopments. Our objective is to provide a preliminary data-quality assessment (PDQA) of urban-infill-toxic-site testing, conducted by private redevelopers, including whether it adequately addresses pollution threats. To this end, we used two qualitative, weight-of-evidence methods. Method 1 employs nine criteria to select assessments for PDQA and help control for confounders. To conduct PDQA, Method 2 uses three US Environmental Protection Agency standards-the temporal, geographical, and technological representativeness of sampling. Our Method 1 results reveal four current toxic-site assessments (by CBRE/Trammell Crow, the world's largest commercial developer); at all of these sites the main risk drivers are solvents, volatile organic compounds, including trichloroethylene. Our Method 2 results indicate that all four assessments violate most PDQA standards and systematically underestimate health risk. These results reveal environmental injustice, disproportionate health threats to children/minorities/poor people at all four sites. Although preliminary, our conclusion is that alleviating harm and environmental-health inequalities posed by urban-infill-toxic-site pollution may require improving both the testing/cleanup/redevelopment requirements of the New Urban Agenda and the regulatory oversight of assessment and remediation performed by private redevelopers.

Protecting Children from Toxic Waste: Data-Usability Evaluation Can Deter Flawed Cleanup.

Nearly 25 percent of US children live within 2 km of toxic-waste sites, most of which are in urban areas. They face higher rates of cancer than adults, partly because the dominant contaminants at most US hazardous-waste sites include genotoxic carcinogens, like trichloroethylene, that are much more harmful to children. The purpose of this article is to help protect the public, especially children, from these threats and to improve toxics-remediation by beginning to test our hypothesis: If site-remediation assessments fail data-usability evaluation (DUE), they likely compromise later cleanups and public health, especially children's health. To begin hypothesis-testing, we perform a focused DUE for an unremediated, Pasadena, California toxic site. Our DUE methods are (a) comparing project-specific, remediation-assessment data with the remediation-assessment conceptual site model (CSM), in order to identify data gaps, and (b) using data-gap directionality to assess possible determinate bias (whether reported toxics risks are lower/higher than true values). Our results reveal (1) major CSM data gaps, particularly regarding Pasadena-toxic-site risks to children; (2) determinate bias, namely, risk underestimation; thus (3) likely inadequate remediation. Our discussion shows that if these results are generalizable, requiring routine, independent, DUEs might deter flawed toxic-site assessment/cleanup and resulting health threats, especially to children.

Using routine, independent, scientific-data audits as an early-warning for potentially fraudulent toxic-site cleanup: PCE, TCE, and other VOCs at the former Naval-Ordnance Test Station, Pasadena, California.

Two of the most prevalent Superfund-site contaminants are carcinogenic solvents PCE (perchloroethylene) and TCE (trichloroethylene). Because their cleanup is difficult and costly, remediators have repeatedly falsified site-cleanup data, as Tetra Tech apparently did recently in San Francisco. Especially for difficult-to-remediate toxins, this paper hypothesizes that scientific misrepresentations occur in toxic-site assessments, before remediation even begins. To begin to test this hypothesis, the paper (1) defines scientific-data audits (assessing whether published conclusions contradict source data), (2) performs a preliminary scientific-data audit of toxic-site assessments by consultants Ninyo and Moore for developer Trammell Crow. Trammel Crow wants to build 550 apartments on an unremediated Pasadena, California site - once a premier US Navy weapons-testing/development facility. The paper (3) examines four key Ninyo-and-Moore conclusions, that removing only localized metals-hotspots will (3.1) remediate TCE/PCE; (3.2) leave low levels of them; (3.3) clean the northern half of soil, making it usable for grading, and (3.4) ensure site residents have lifetime cancer risks no greater than 1 in 3,000. The paper (4) shows that source data contradict all four conclusions. After summarizing the benefits of routine, independent, scientific-data audits (RISDA), the paper (5) argues that, if these results are generalizable, RISDA might help prevent questionable toxic-site assessments, especially those of expensive-to-remediate toxins like PCE/TCE.