Re: NPL LISTING?

[Peter Strauss <pstrauss@igc.org>]

From: Peter Strauss <pstrauss@igc.org>

Laura,
This is an interesting question, and one that DOD is at least partially 
trying to address at military bases that have RABs. I am not sure 
where the proposed rule is in its revision cycle, but as I understand 
it, DOD has prroposed to prorvide technical assistance to some RABs for 
limited purposes. However, the issue should be looked at for all 
NPL-like sites, whether they are listed or not. I have also been 
informed that no new sites in Santa Clara Cty (Region IX) will be added 
to the NPL. So the issue becomes how can we determine whether a site 
is dirty enough (or risky enough) to warrant outside, independent 
technical assistance.
I would suggest that as a first cut, there must be an interested 
community group that can manage a grant, and can demonstrate the need 
for assistance. Second, there must be some thrreshold value of human 
health risk or ecological risk. Third, there is a matter of timing: 
technical assistance (in the small doses one can expect from a TAG) is 
most effective when they coincide with decisionmaking. If too late in 
the cleanup process, they are not very effective.
As you may know, I have been involved in prorviding technical 
assistance to a number of communities. I think that before technical 
assistance is granted to non-NPL sites, the agencies must see what the 
value is. Therefore, I think it is important to trry to document the 
benefits of the TAG process. Perhaps one of the EPA policy-makers 
wants to take this on as a prroject? 
Peter Strauss