Re: CERCLA Exemptions

[Peter Strauss <pstrauss@igc.org>]

At 10:39 PM 2/20/98 EST, WJASmith@aol.com wrote:
>Peter,
>
>You are correct that Oakland Army Base is not listed on the NPL, but I 
believe
>the majority of CERCLA sites are not. The DOD has generally committed to
>following CERCLA policies for its sites.
>
Bill,

I'm not sure that you are correct that DoD has generally committed to
following CERCLA policies for its sites. Can anyone clarify? Also, by
definition, a CERCLA site is one listed on the NPL.

An issue that I was responding to is whether lead contamination, if derived
from fuel, is exempted from CERCLA. Petroleum contamination is exempted,
except in circumstances where petroleum is a co-contaminant and its
remediation affects the remediation of other contaminants. At Moffett,
although the RAB is presented with documents regarding the petroleum
contamination, it is clear that the corrective action plan for petroleum is
not regulated under CERCLA and will not be part of the CERCLA ROD.

Peter