Using routine, independent, scientific-data audits as an early-warning for potentially fraudulent toxic-site cleanup: PCE, TCE, and other VOCs at the former Naval-Ordnance Test Station, Pasadena, California

Two of the most prevalent Superfund-site contaminants are carcinogenic solvents PCE (perchloroethylene) and TCE (trichloroethylene). Because their cleanup is difficult and costly, remediators have repeatedly falsified site-cleanup data, as Tetra Tech apparently did recently in San Francisco. Especially for difficult-to-remediate toxins, this paper hypothesizes that scientific misrepresentations occur in toxic-site assessments, before remediation even begins. To begin to test this hypothesis, the paper (1) defines scientific-data audits (assessing whether published conclusions contradict source data), (2) performs a preliminary scientific-data audit of toxic-site assessments by consultants Ninyo and Moore for developer Trammell Crow. Trammel Crow wants to build 550 apartments on an unremediated Pasadena, California site - once a premier US Navy weapons-testing/development facility. The paper (3) examines four key Ninyo-and-Moore conclusions, that removing only localized metals-hotspots will (3.1) remediate TCE/PCE; (3.2) leave low levels of them; (3.3) clean the northern half of soil, making it usable for grading, and (3.4) ensure site residents have lifetime cancer risks no greater than 1 in 3,000. The paper (4) shows that source data contradict all four conclusions. After summarizing the benefits of routine, independent, scientific-data audits (RISDA), the paper (5) argues that, if these results are generalizable, RISDA might help prevent questionable toxic-site assessments, especially those of expensive-to-remediate toxins like PCE/TCE.