RAB Scope

[Lenny Siegel <lsiegel@cpeo.org>]

In response to Laura Olah's question about the scope of RABs. The key
phrase, in both the RAB Rule and the Army RAB guidance, seems to be
"restoration activities." That is, RABs are established to oversee
activities that are funded either through the Defense Environmental
Restoration Accounts (DERA) or the Base Realignment and Closure (BRAC)
environmental cleanup account. This is primarily an organization
decision. The military personnel and civilian employees that establish
and support RABs only work on restoration.

It doesn't matter whether restoration is taking place under CERCLA,
RCRA, or state hazardous waste laws. "Compliance" activities, however,
are generally beyond the scope of RABs.

However, smart installations are flexible enough to encourage the
discussion of other related issues. The Air Force, in fact, has
converted some RABs into Community Advisory Boards that review pollution
prevention plans at their bases.

There are some restoration activities that are not funded through DERA
or BRAC, including Defense Petroleum sites funded through surcharges on
fuel sales and contributions from private responsible parties, such as
Shell at the Rocky Mountain Arsenal. As far as I know, those have not
been carefully defined.

Lenny
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