The Superfund Remedial Action Decision Process: A Review of Fifty Records of Decision

Abstract

Although the Superfund remedial action decision process is a complex process involving a variety of technical, political, and public health issues, the primary goal of remedial action is the protection of public health. We performed an in-depth analysis of 50 post-SARA Records of Decision in order to characterize the role of risk assessment in the decision-making process and determine whether decisions are being made in an effective and environmentally protective manner. Our findings indicate that the majority of decisions to remediate Superfund sites are based on the existence of contamination per se and not on actual public health risk. Although hypothetical risk is an essential consideration, this gray area is not well-defined in the current decision-making process.

The lack of assessment of the degree of risk reduction associated with the remedial alternatives evaluated and the lack of support indicating the effectiveness of the remedial alternatives selected also constitute major weaknesses in the majority of decisions. These inadequacies undermine rationales regarding the protectiveness and cost-effectiveness of the remedial alternatives selected. The fact that objectives beyond addressing public health risk are often unclear in the decision-making process also weakens rationales for costeffectiveness.