The National Historic Preservation Act is Not Your Problem, But How You are Addressing it for Your CERCLA Project May Be - 12344
- Restoration Services, Inc. (RSI), Oak Ridge, Tennessee (United States)
The 1995 Environmental Protection Agency (EPA) and U.S. Department of Energy (DOE) joint 'Policy on Decommissioning of Department of Energy Facilities Under CERCLA was developed so that decommissioning could occur in a manner that ensures protection of worker and public health and the environment, that is consistent with Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), that provides for stakeholder involvement, and that achieves risk reduction without unnecessary delay'. The source of the 'unnecessary delays' the joint policy intended to avert could be attributed to numerous factors such as obtaining permits, conducting administrative activities, or implementing regulatory processes that could yield, among other things, differing preferred alternatives. Why, you might ask, more than fifteen years later, does DOE continue to struggle through CERCLA projects with unnecessary delays? From problem identification, to determination of nature and extent, to alternative analysis and ultimately remedy selection and implementation, reaching a compliant and effective clean-up end-point can be a process that seems to mimic geologic timescales. The source of these delays is often the failure to use all of the tools the CERCLA process offers. As one example, renewed commitment to follow the CERCLA process to address the regulatory reviews pursuant to the National Historic Preservation Act (NHPA) is called for. Project managers implementing CERCLA actions in any agency, not only DOE, do not need to be apprehensive about using the CERCLA process for NHPA review but should welcome it. It is critical that methods are used that address substantive NHPA requirements clearly and consistently, and that they are shared and communicated as frequently as needed to interested and questioning stakeholders. (author)
- Research Organization:
- WM Symposia, 1628 E. Southern Avenue, Suite 9-332, Tempe, AZ 85282 (United States)
- OSTI ID:
- 22293606
- Report Number(s):
- INIS-US-14-WM-12344; TRN: US14V1262115130
- Resource Relation:
- Conference: WM2012: Waste Management 2012 conference on improving the future in waste management, Phoenix, AZ (United States), 26 Feb - 1 Mar 2012; Other Information: Country of input: France; 15 refs.
- Country of Publication:
- United States
- Language:
- English
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