EE\CAs: Info. Request

[Peter Strauss <pstrauss@igc.org>]

This is another rrequest for information. As many of you can 
ascertain, I am a technical advisor to several community groups that 
have recieved Technical Assistance Grants from the EPA, to help them 
with with technical issuesinvolving cleanup at NPL sites. Two of the 
sites have recently proposed using removal actions to speed up cleanup 
and avoid some of the documentation that is involved in normal cleanup 
actions (i.e., feasibility study, proposed plan draft ROD, etc.). 
Rather, the "removal action" requires developing one document called an 
Engineering Evaluation\Cost Analysis (EE\CA). The National Contingency 
Plan requires that there be public notification of an EE\CA and an 
opportunity to comment. There is no requoirement for a public hearing, 
a response to comments, or a ROD. I have a few questions that some one 
may help me with:
1) Has anyone had experience with this mechinism?
2) What has been your experience regarding public particpation?
3) Do you have recommendations about how to improve public parrticpation?
4) Have there been other downsides to using EE\CAs rather than 
going the full nine yards?

All comments would be very much appreciated.
Thanks,
Peter