Re: Removal Site Evaluation Process

[Peter Strauss <pstrauss@igc.org>]

Perhaps Patrick can post or distribute his article. Never the less, 
removal actions (non-time critical) are abused. Recently a DOE Superfund 
site proposed to "re-engineer CERCLA" by transforming some of its 
Operable Units into removal actions. For example, cleanup for a 3,200 
acre Operable Unit, much larger than most Superfund sites, with 
groundwater containing tritium, depleted uranium, heavey metals and an 
assortment of solvents was propposed to be summarized in one not very 
detailed document. But for an active community, there would have been no 
public hearing and no tie in to the ROD. The importance of the ROD 
should not be overlooked. It is legally binding and and can be used by 
the regulators and the community to hold a responsible party's feet to 
the fire. I am not suggesting that all removal actions are bad - but 
the process seems to be used more and more, and it is incumbent upon 
communities and regulators to make sure it doesn't get out of control.

Peter Strauss
Please mail article to:
PM Strauss and Associates
317 Rutledge Street 
San Francisco, CA 94110