Resolution 93-75 - Laserfiche WebLink

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5. Include language requiring the EPA to uniformly identify and cite all PRPs. Presently, the agency tends to identify a handful of the most obvious "deep pocket" PRPs and then removes itself from this part of the process, leaving identified PRPs both to fund costly remediation and cost recovery efforts and bring other PRPs into the process. This policy is an important factor in driving up transaction costs and extending the amount of time required to move through the process. 6. Require that EPA risk assessments be reasonable, responsible, and based on common sense. Current agency methodologies and the unrealistic assumptions on which they are based often result in unreasonably conservative risk assessments. The EPA should be required to adopt a methodology based on probability distributions for exposure and risk. The EPA should officially acknowledge that certain sites cannot be completely cleaned up and that waivers along with certain institutional controls (e.g., land use restrictions) should be allowed. LGSR believes that the appropriate level of cleanup at a specific site must be substantiated and based on competent technical review. There is no sense in spending millions of dollars to determine that a site cannot be cleaned up to a pristine standard. 7. Authorize the EPA to implement policies flexible enough to allow regions to think creatively and independently to solve local problems. The provision requiring a state percentage participation at Superfund-led sites should be eliminated and the EPA should be encouraged to develop partnerships with local and state governments. Local government should have the option of acting as the lead agency on cleanup projects, instead of the state, when the local agency can demonstrate that this would protect the public health, speed up the process and minimize costs. The concept of cost-benefit analysis should be written into the law and emphasized in the development of Records of Decision (RODs). This will reduce administrative costs and allow more funds to be directed toward site remediation.