The current system accounts only for the site itself, not the burden on the local community. 

There are hundreds of hazardous waste sites in need of clean-up all over Georgia. Georgia’s Environmental Protection Division (EPD) designates and manages these sites via their Hazardous Site Inventory (HSI). Management includes determining eligibility for, and then dispersing money from, the  Hazardous Waste Trust Fund. Fund money originated from fees collected across the state, and a Georgia Constitutional Amendment ensures that this money is allotted to its intended use.

Currently, the EPD process does not consider the full scope of the local community’s social, economic, and environmental circumstances when ranking the severity of hazardous waste sites and allocating money for cleanup. Ignoring the combined negative effects of these cumulative impacts makes the EPD less effective at fulfilling their mission of reducing harm to the environment and supporting healthy communities.

Over the past year we have worked to understand the current hazardous waste designation and ranking process and gaps in the current system. We created a Georgia specific socio-economic and environmental burden index and mapped it against HSI locations. Based on this work, we offer suggestions to change the ranking and allotment process, and actions individuals can take.

A regulated substance is a material that presents a health or environmental hazard to persons and property, including groundwater or soil. These materials must be stored, used, handled, and processed in a specific way to reduce risk.

When a suspected release of a regulated substance occurs, it must be reported to the EPD. It is then assessed to understand if it is above the US EPA’s reportable (safe) quantity. If the EPD determines the release is a risk, and it cannot be immediately cleaned up, it will add the release site to the Hazardous Site Inventory (HSI). The is a list of locations in Georgia that are known to have, or are suspected to have, regulated substances present on the site which have been misused, spilled, or improperly stored. Thus, these are sites that pose a threat to human health and the environment.

Sites on the HSI are required to meet the state’s clean-up standards. They must be properly cleaned, and the steps must be documented for them to be removed from the HSI. When the polluter cannot be held responsible for the cleanup, the EPD pays with the Hazardous Waste Trust Fund (HWTF), a collection of fees from citizens, business, and government groups who create, manage, and dispose of solid and hazardous waste, or break waste laws. For example, you pay a fee when you dispose of your tires, this goes into the HWTF.

The EPD writes in their RQSM manual that

“RQSM is not intended to provide a quantitative risk assessment for sites… nor is it intended to be used to rank or prioritize sites where releases have occurred for the purpose of determining which sites pose the greatest risks”.

Yet, after RQSM evaluation is conducted, the only existing processes to prioritize HWTF spending on cleanup activities is EPD discretion.

The EPD is not required to actively reach out to communities and collect their thoughts or concerns on HSI sites; they are only required to post a public notice in a local newspaper if a new HSI site is listed. This puts the burden on communities to stay informed and advocate for their health.

Solely analyzing the release without factoring in the context of the people that live around it, including existing disadvantages or environmental burdens, means the EPD is highly likely to miscalculate the actual risk to communities.

To visualize this, Science for Georgia and other partners created a Georgia specific Environmental Index to more accurately identify environmental and socio-economic impacts to Georgians, and to add in additional layers including the HSI.

If the EPD seeks to reduce harm and support communities, it is logical to consider which communities are most vulnerable when prioritizing their cleanup efforts. Fortunately, there are existing resources that can help them do exactly this.

The below image shows the Burden Index and the Abandoned Hazardous Waste Sites (those that are eligible for HWTF monies). The darker the blue, the higher the burden. Red indicates a level I site, and green a level V. Many of the sites are also located in highly burdened areas.

The EPD can address cumulative impacts of HSI sites by (1) more actively seeking public input and (2) utilizing several existing tools to understand overall socio-economic and environmental status of the surrounding communities near a HSI site.

The above-mentioned tool can provide insight. Federal agencies use the Climate and Economic Justice Screening Tool (CEJST) to help identify disadvantaged communities that could benefit from the White House’s Justice40 initiative. It assesses eight different categories of disadvantage (e.g., housing, health, legacy pollution), and it labels census tracts as either advantaged (0) or disadvantaged (1) based on indicators within these categories (e.g., housing cost, number of individuals with diabetes, history of pollution). If a population is at or above the 90^th percentile for any indicator in a category, while also being at or above the 65^th percentile for low income, it gets a 1.

After using the map tool to identify nearby hazardous waste sites, there are a few actions citizens can take to have their voices heard and advocate for cleanups. The two main avenues for action are the EPD and local government. The EPD is available via their main phone number to provide updates on any hazardous site, connect citizens to an HSI site’s project officer, or receive community concerns and requests about the importance of site clean-up. County commissions or city councils can also advocate on behalf of their citizens to the EPD for cleanups, or for reimbursement for their own cleanup activities in the case of landfill cleanups. These organizations may need convincing to take hazardous waste cleanup seriously though. In this case, it’s up to citizens to unite, research, educate one another, and demand action from their representatives when it comes to cleanups or changes to the EPD’s risk and spending prioritization methods. The more people who rally behind a request to these groups, the more likely it is to be successful.

The Environmental Justice Index map tool (Instant App) can help people identify communities near them that are overburdened, hazardous waste sites near them that are eligible for clean-up under current EPD prioritization, and areas where these two things do not align. The Environmental Justice in Hazardous Waste Clean-ups story map also explains more about environmental justice as well as why and how the EJ Index map tool was developed.

Learn all about the creation of the EJ Storymap here: AST: Environmental Justice in Hazardous Waste Clean-Ups – Science for Georgia

Hazardous Site Inventory (HSI): List of sites, or locations, in Georgia where regulated substances have been released above the legal limit. This is a list of sites that have not met the state’s clean up standards. Sites are put on this list and monitored based on their RQSM score, which identifies which sites require an immediate response. The EPD uses the RQSM scores to classify the sites into different groups to determine what actions need to be taken. Sites are removed from the HSI when the property owners can show they have properly addressed the issue and have taken actions to resolve them. The EPD director also has the authority to add and remove sites from this list. 

RQSM: Reportable Quantities Screening Method is an assessment used by the Georgia Environmental Protection Division to determine if hazardous and regulated substances have been released in sites and exceed the legal limit. Quantities of hazardous substances over the determined limit pose a threat to human and environmental health. This assessment factors in the toxicity, quantity, and physical state of the substances released, as well as their proximity to residential drinking water wells. 

Resource Conservation and Recovery Act: Federal law in the U.S. that regulates the disposal of solid and hazardous waste. The RQSM was based on this Act and adapted to meet the specific requirements of the Hazardous Site Response Act in Georgia.

Hazardous Site Response Act: Georgia legislation created to address environmentally impacted properties that are not being addressed by existing federal environmental programs. This act makes it so property owners must notify the Georgia EPD when hazardous substances are discovered in the soil or groundwater. 

Compliance Status Report: Documentation of the released hazardous substances by property owners to the EPD. This documents the investigation of the release, identifies responsible parties, determines the sources of the substances, and documents the extent of the contamination. For a site to be removed from the Hazardous Site Inventory the responsible party must submit a compliance status report. 

Voluntary Remediation Program Act: Program conducted by registered environmental professionals with the goal of reducing human and environmental exposure to contaminated properties. This act encourages voluntary protection of groundwater and encourages property owners to be proactive in addressing the cleanup of their land. The registered environmental professionals conduct investigations on the properties and provide suggestions for remediation. 

Clean up Standards/Risk Reduction Standards: The Georgia EPD is currently developing a Risk Assessment Guidance which will provide additional details. Each regulated substance has a risk reduction standard that must be considered when the cleanup process begins. See Comparison of Existing Contamination to Risk Reduction Standards 391-3-19-.07 | Environmental Protection Division (georgia.gov) for more in depth details.  

Corrective Action Plan: A proposed timeline and plan for how the site will begin to meet clean up standards if they are not already meeting them based on the information submitted in their compliance status report. This plan must include a property description, environmental history, current site contamination description, and proposed cleanup remedies. See https://epd.georgia.gov/corrective-action-plan-391-3-19-066 for exact details. 

Cradle to Grave: Beginning with waste generators, then moving to waste transporters, and finally waste disposal facilities. Those involved in the entire lifecycle of hazardous waste must comply with the RCRA regulations. 

Abandoned vs Not Abandoned Sites: A site ca be classified as not abandoned if the property owner can be identified and is willing or able to perform clean up. A site is classified as abandoned if a property owner cannot be located or is unwilling to perform cleanup. In the case of abandoned sites, the EPD and use the Hazardous Waste Trust Fund to remedy the area, and later seek repayment from the landowners.