aggiedent said:

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The one frustrating aspect of being a conservative republican is that subjects like this get so highly politicized. Am I one of the few people that think we should expect to be able to have clean water, air, and food; while maintaining a healthy economy too? And not have it be a political talking point?

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I do find this an interesting dichotomy in Texas. Texans are fiercely conservative politically, yet love their outdoors. All the while, allowing industry to rape and pillage our wonderful natural resources in the state.

Sooper Jeenyus said:

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If you're in the industry then you know what's involved in establishing those regulatory values you referenced in your 100 ppb example. It's actually quite a bit of science and modelling, no magic involved. I deal with these risk-based values every day; no need for backhanded insults.

Part of the problem with legacy sites is what we knew and what enforced at the time, that's true. You want something more to be done about it now? OK. But, for many of these places, that's going to be a hell of a large price tag and you and I are going to have to pay for it. I'm not saying the cause is unworthy, but that's where the money is going to have to come from. And you won't want the TCEQ or EPA overseeing the job, either. Trust me on that, if nothing else...

As for people witnessing releases, what did they do about it? Report it? Collect a sample? Hire someone to officially investigate the impact to their property? If not, why not? If you have a property that's been impacted by these pits, I'm happy to help. I'll get you a good environmental attorney and oversee the investigation, but it won't be free.

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Finn summed it up pretty well. And I do know in some cases what establishes thresholds - and that sometimes those threshold levels are absolutely arbitrary, set based on data that is outdated, or set based simply because of what technology at the time is capable of.

The function of the EPA/TCEQ should be to mitigate sites like this. And you don't seem to acknowledge that the entire system is set up so that as long as paperwork says things are fine, then they must be. The honor system works in a lot of applications, but not in applications where hundreds of millions of dollars are at stake - because hundreds of millions of dollars. I don't particularly advocate .gov spending, but this is one area where taxpayer dollars spent actually benefit taxpayers. I'm just spitballing here, but I would bet I could find a place to offset the spending in the federal budget in about 15 or 20 minutes in a program that does not really benefit taxpayers (assuming no offset in costs against the parent company, which may or may not be feasible in this case given the history of the pits)

Right, wrong, indifferent - that is the primary driving force and you cannot tell me that Waste Management is going to voluntarily come out and tell TCEQ and the EPA "hey guys, you know those dioxin pits on Halls Bayou? Yeah, well, they are leaking and we really think it's a great idea for us to go spend $250MM of our dollars to clean them because we own them. We know that is 100% an outflow of money, and that $250MM might not be the final bill to clean and remediate these pits - hell, it could cost a lot more than that. We just have all this extra money laying around and it's just a good thing for us to spend it on. I mean, our investors, management, etc. probably would love for us to take that massive financial hit, so let's get a plan together and get going on this cleaning up thing!" That is never going to happen. And, much like politicians, CEO's have limited life spans - if you can defray a cost during your tenure, you do it. Let the next guy deal with the issue long after you have retired and gotten your golden parachute for not spending that massive amount of money. Paperwork is easy and cheap to do, relatively speaking, and like statistics - you can make it say what you want to say.

Additionally - until I read the article, I didn't know what those pits were. I'm guessing that the overwhelming majority of people who have driven a boat down the ICW, hunted on Halls Bayou Ranch or any of the other areas close by or have spent time in West Bay are in a similar position in that they don't have an inkling of what those pits are. So if you don't know, why would it be any concern if you see drainage, leakage or any other form of release? We have levees all over the place here - some keep seawater back, some are for freshwater reservoirs, some are for industrial process water reservoirs, some are for irrigiation channels, some are apparently to hold back waste pits of dioxin. I doubt anybody has a clue what is what in 99.9999999% of circumstances.

I have no land that is being affected or potentially damaged by this. Other than the fact that I'm a taxpayer and Texan who has the same vested interest in ensuring our bay systems do not become wastelands that cannot be enjoyed and used because of things of this nature.

Been golfing all day. Used the golfboards, which was fantastic. Highly recommend.

Finn, I don't disagree regarding the optimal purview of the regulatory authorities. An environment which does not pose a health risk to humanity is in everyone's best interest. The cleanups likely won't put anyone out of business, though, because they no longer carry that sort of liability. Again, the taxpayer will pick up the tab for legacy sites and, again, I'm not suggesting it's an unworthy cause.

Schmellba, I'm not sure which thresholds you're referring to, but I'm not aware of any that are "absolutely arbitrary." Far from it. If you have examples, I'd love to hear them. And you're right, I'm not acknowledging the entire system is reliant on "paperwork" giving everyone a false impression because that isn't true either. You've got an impression of the whole system which isn't accurate. It isn't reliant on the "honor system." The data speaks for itself. Consider this: I'm a consultant monitoring these pits on behalf of the responsible party. What's my liability in this equation? You think I, or my firm, is willing to put our professional license on the line for one client who's giving you a few grand a year in annual monitoring and reporting? Moreover, you think I don't stand to make MORE money if there IS a significant issue that requires significant remediation?

I appreciate and share your concern for these types of issues but your idea of the systems that govern environmental regulation in Texas simply aren't accurate. I'll do you one better. I know you said you don't own potentially affected property, but you speak as though you have a dog in this particular fight. You decide you want to actually do something about it, let me know. I'll point you in the right direction.

One example of a relatively arbitrary threshold: arsenic concentration in potable water.

For the longest time the threshold or maximum allowable was 50ppb. It was t0ppb because that was the level that could be measured with equpiment at the time. Somebody went off an developed the capability to measure down to 0 ppb. So the maximum allowable is now set at 10ppb, an arbitrary number that is governed by measurement capabilities and allowing for a level of error.

I have a dog in the hunt because I grew up in amd live close to the pits. I have abaolitely zero desire to see an entire bay system rendered unuseable because of what I perceive to be little more than politics and finances holding up doing the right thing and,remediating the pits. I want my kids and hopefully grandkids to be able to enjoy the West, Chocolate and Christmas Bay syatems lime I did growing up and do now.

I have no issue with taxpayer money being spent on something like this, it is an actual good use of tax money. You obviously have significantly more in depth knowledge on these pits, i defer to you, but i am not ignorant of how much of the regulatory and reporting system operates either.

Whatever you may think of EPA or TCEQ, chemicals in drinking water is something the government takes very seriously. I understand your point regarding arsenic but you can't very well hold someone to a standard if you're incapable of validating it. I wouldn't consider that arbitrary.

If you'd like to know more about how these values are derived, look into how TRRP PCLs are calculated.

Sooper Jeenyus said:

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Whatever you may think of EPA or TCEQ, chemicals in drinking water is something the government takes very seriously. I understand your point regarding arsenic but you can't very well hold someone to a standard if you're incapable of validating it. I wouldn't consider that arbitrary.

If you'd like to know more about how these values are derived, look into how TRRP PCLs are calculated.

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I know a little bit about chemicals in potable water, wastewater and a few other things associated with the industry as a whole.

Just a question...

Some years ago I remember reading about technology involving Large Microwaves to clean up these type sites--essentially "microwave" the area to degrade the toxins.. Assume it didn't work out or only for certain situations. anyone know anything about this?

Working on a potential Superfund site issue now. Company is long sense out of business. Surrounded by a long time residential area and drained by a creek. All sorts of fun issues.