1997 CPEO Military List Archive

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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