EC/CA Benefits

[Peter Strauss <pstrauss@igc.apc.org>]

As most of you who have followed remedial actions by the military have
come to realize, there is more dependance on the use of "non-time
critical removal actions". These actions require less documentation and
usually can be implemented in a shorter time than traditional
responses. However, since they are not tied to the requirements of a
Record of Decision (ROD), and do not have the same degree of public
scrutiny as actions supported by a full Remedial
Investigation/Feasibility Study, they are often criticized by
stakeholders. However, if followed closely, there could be some
benefits.

Those of us involved in trying to stimulate the use of innovative
technology have long decried the fact that RODs do not allow much
latitude in substituting conventional solutions with innovative
solutions. A recent work plan for a removal action at Lawrence
Livermore National Laboratory included a contingency plan in response to
the community's comments. Buried within the contingency plan is a Table
that summarizes Contingencies and Potential Responses. This is one that
caught my eye: Contingency: Improved technologies are developed.
Potential Responses: Conduct cost-benefit analysis and employ economy-
and technology-based actions that are acceptable. Of course, these
terms are not defined, but this is a step in the right direction to
foster the use of innovative technologies.

Peter