EE/CAs and Removal Actions

[Ted Henry <thenry@umabnet.ab.umd.edu>]

In Peter's description of the clean-up process, it should be noted that
in addition to less citizen participation, regulatory oversight is also
much more limited during a removal action. Also, the military is not
guided by the typical considerations of whether an action should be a
removal or remedial action. Usually removal actions at non-military
sites are less than 2 million dollars in cost and less than 1 year(i
think) to implement. The guiding factors at APG and at least one other
site I am familiar with has tended to be (1) the sensitivity of the
site/issue and (2) the extent to which the Army sees lead agency status
as a requirement for the job. 

Ted Henry 

NOTE: The $2 million limit applies directly to Superfund-financed (that
is, EPA-led) cleanups.