Re: questions

[Lenny Siegel <lsiegel@igc.org>]

Federal facilities with incorporated into CERCLA through the Superfund amendments
(SARA) of 1986. The Federal Facilities Compliance Act gave the states and US
EPA the clear authority to enforce RCRA at Federal facilities. Many states,
however, assert a sovereign right to enforce their laws in their territory without
Federal delegation of authority.

IN addition, Executive Order 12088 (I think that's the right number) directs
Federl agencies to request the money they need to meet their legal
regulatory requirements.

SARA required (where practicable) the formation of Technical Review Committees.
CERCLA and the National Contingency Plan, which implements it and other
laws, required community relations plans. RABs were introduced administratively
in 1993 and 1994 (by DOD and EPA guidance). The Defense Authorization Act
for FY95 anchored the RABs in statute, and DOD is supposed to propose regulations
to implement that very soon.

THe FFERDC report goes over a good deal of this.

Lenny