Re: Fort Ordnance

[Peter Strauss <pstrauss@igc.org>]

Lenny,

Like Laura, I have not read the subject document, but I think your 
comments were well thought out. Let me add a few points for any further 
discussion.
1. If, as you say the EE/CA does not define the area to be covered 
and does not define technologies, how can the Army justify doing an EE/CA 
rather than a feasibility study (FS) normally required under CERCLA. The 
FS would have had to address these issues. This highlights the fact that 
 too many facilities are relying on EE/CAs to shortcut the process, and 
they are getting away with it.

2. It may be useful to know that at Lawrence Livermore National 
Laboratory, Site 300, DOE agreed to hold public meetings after each 
EE/CA. There is no regulatory requirement for a public meeting following 
a non-time critical removal action, which does not have a ROD associated 
with it.

Peter Strauss