Re: Fort Ordnance

[Peter Strauss <pstrauss@igc.org>]

In response to my reply to this message, Laura Olah asked that I post 
some information on what an EE/CA is. Here goes a short explanation. If 
anyone has questions, I would be happy to answer them.

The Superfund process prescrbes certain procedures that a responsible 
party must follow. This is usually referred to as the RI/FS process 
(remedial investigation/feasibility study), followed by a proposed plan 
and a Record of Decision (ROD). The content and scope of the RI and the 
FS are also prescribed, and these documents are usually quite detailed. 
There are two major exceptions in EPA regulations that allow one to not 
follow this process. The first is for time critical removal actions that 
present an imminent threat to human health or the environment. From a 
procedural standpoint, because these actions are usually necessary, they 
should not be controversial. The second exception is for "non-time 
critical" removal actions. Obviously, they do not present an immediate 
threat. In recent years, deeming activities at a Superfund site as 
non-time critical removal actions has become more and more popular. 
Their popularity stems from the fact that the RI/FS does not have to be 
completed, and is instead replaced with a far less detailed document 
called an Engineering Ebvaluation/Cost Analysis, hence EE/CA. Public 
scrutiny over EE/CAs is not as great as an RI/FS, (i.e., no requirement 
for a public hearing) and there is no Record of Decision (ROD). The ROD 
is legally binding at Superfund sites. In my previous work, this last 
point has been a major issue.
Peter Strauss