| TABLE OF CONTENT PREFACE AND ACKNOWLEDGMENTS............................. iii (2007) | |||||||||||||
Abstract | |||||||||||||
| This paper was supported jointly by the Office of Science and Risk Policy and the Office of the Deputy Assistant Secretary for Planning, Policy and Budget within the Department of Energy's Office of Environmental Management (EM). It is addressed to the senior manager who participates in determination of compliance agreements and in discussions of end-state choices within the context of regulatory requirements. It is one of a series of reports by the Joint Institute for Energy and Environment (JIEE) that seeks to probe alternatives to EM's status quo and identify new strategic options available to EM. By design, this series adopts a perspective more general than the project-specific focus often found describing the cleanup program and more behavioral than the technical discussions that typically underlie waste cleanup planning. The central argument presented herein is that due to a unique set of circumstances, DOE should seek regulatory flexibility through designing a "customcleanup, " based on risk to human health and the environment. Such a custom-cleanup would be freed from the rigid guidance commonly applied to cleanup activities under CERCLA and RCRA. These circumstances include the commitment by DOE to spend the needed dollars to manage risks and accomplish other local ends, the considerable data base already available for these sites, and the extensive set of stakeholder relationships already in place. Review of the legislative history of RCRA and CERCLA suggests that doing this would be well within the spirit of the legislation and that were DOE to pursue this option it would not require exemption from the legislation. Doing so should permit a better cleanup at lower cost. This is not, however, to say that obtaining regulatory flexibility would be a simple task. ... | |||||||||||||
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