Re: CERCLA Exemptions

[Lenny Siegel <lsiegel@cpeo.org>]

I'm not sure there is a definition for "CERCLA site," but the CERCLIS
data base in much larger than the NPL. DOD uses the CERCLA process, for
which it is lead agency, for all of its hazardous waste remediation
sites. The scope of this universe is in dispute.

The fact that DOD uses CERCLA doesn't mean that regulators cannot
oversee the cleanup under other authorities. That was the issue in the
Rocky Mountain Arsenal case. In fact, most state-only oversight is
either done under RCRA or state laws. But even at those facilities, DOD
follows the RCRA process.

Sound complicated and uncertain? It is.

LS
Lenny Siegel
Director, SFSU CAREER/PRO (and Pacific Studies Center)
c/o PSC, 222B View St., Mountain View, CA 94041
Voice: 650/961-8918 or 650/969-1545
Fax: 650/968-1126
lsiegel@cpeo.org