From: | Lenny Siegel <lsiegel@igc.org> |
Date: | Mon, 20 Oct 1997 13:48:14 -0700 |
Reply: | cpeo-military |
Subject: | Removal Site Evaluation Process |
>From Patrick Vasicek Lenny, The problem with the Remediation program is that many of the people (including program people in DOD) have never read CERCLA or the NCP. I wrote an article published in the Autumn 1993 Federal Facilities Environmental Journal on the Removal Site Evaluation Process. I suggest that everyone involved with cleanup read this article and then read the statute and regulation. Use of the Removal Site Evaluation Process does not exonerate one from completing the Remedial Site Evaluation Process. On the other hand, misguided use of the remedial process is the single biggest reason why cleanup and BRAC turnover progress in many states is so sluggish. I can speak for the Navy cleanup program in the Northwest. We always complete the remedial process, even on non-NPL sites, unless site closure is achieved (with regulatory concurrence) during the Site Inspection phase. We almost always use the removal processes, however. That is why our program is very nearly complete (we have closed 500 of our 600 sites). We spend a lot of time with public participation, so that we achieve and maintain consensus - as best we can. The public is our primary customer - it makes little sense to ignore their concerns (besides the fact that this behavior could invoke citizen's suits, etc.) So, I disagree with the statements that removal actions are risky. Removal actions and removal site evaluation tools are the most useful mechanisms to get to cleanup that CERCLA and the NCP have to offer. I strongly suggest that the activist community learn how to use these tools. Patrick R. Vasicek Engineering Field Activity, NW Naval Facilities Engineering Command |
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