Re: Highlights of the DERTF Conference

["Sam Goodhope" <Sam.Goodhope@OAG.STATE.TX.US>]

(Apologies about the delay in posting--it's a technical thing. --Aimee)

Reply to David Rubenson @ Rand

I have nothing against "new" ideas, but each new idea only seems to
bring us less cleanup, e.g., (1) looking at future land use to lower the
cleanup hurdle, (2) using risk assessment, reduction, and management
as "the" driver in not only choosing remedies, but in sequencing cleanups
across thousands of facilities, (3) involving the communities (in the RAB
process) in order to inform them that the boosters have decided upon
certain uses which only require the lowest level of cleanup, (4) DoD
unilaterally setting priorities across the nation in fifty states according to
internal decision-making processes. Other "new" ideas at a different
level, say, such as TERCs, are good beginnings, but I imagine their
benefits are marginal at best. 

I do not believe that we have to transport all the baggage from private
sector CERCLA/RCRA/state law or protocols into the federal facilities
area--there is obviously too much waste (caused, I believe, by the
insurance companies)--but until there is truly a felt need up and down
the chain of command (and not just in the DoD and service environmental
offices) to comply with existing laws that protect our citizens and
environment, I think it unwise to take any position but full enforcement of,
and ensuring compliance with state and federal laws.