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Short Changing Short-Term Risk: A Study Of Superfund Remedy Selection, John S. Applegate, Steven M. Wesloh
Short Changing Short-Term Risk: A Study Of Superfund Remedy Selection, John S. Applegate, Steven M. Wesloh
Articles by Maurer Faculty
Unlike most environmental statutes, CERCLA requires a lengthy period of labor-intensive activity to achieve its clean-up goals. This aspect of the Superfund program does not receive sufficient attention in policy and legal analyses of CERCLA, nor during site-specific remedy selection decision-making. The risks of the remediation period-to workers, to site neighbors, and to the natural environment-are substantial, as this Article illustrates. However, the confusing and sometimes dismissive treatment of remediation risk in the EPA 's detailed guidance for Superfund decision-makers invites the neglect of the short-term effectiveness criterion in the remedy selection process. A study of remedy selection documents in …