EFFICACY OF CERCLA REMEDIES IN LIGHT OF FIVE-YEAR REVIEWS
ELIZABETH K. HOCKING
Reviews of several remedies selected and implemented under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), as amended, revealed deficiencies in remedy protectiveness although the remedy had only been in place for five years. Many of these deficiencies should have been foreseeable, and therefore preventable, at the time the remedy was selected.
Analysis of successes and deficiencies noted in the CERCLA five-year reviews highlights the pivotal role that monitoring plans and land use controls have in ensuring remedy protectiveness. The analysis demonstrated that remedy protectiveness assessments and remedy modification justifications depend on robust site and remedy monitoring plans as well as on adequately developed conceptual site models.
Comprehensive understanding and inferences regarding past, present, and future land and resource use at the remedy selection stage can enhance remedy protectiveness because stakeholders can determine if land use controls are necessary and if they can be implemented and enforced. The findings from this analysis of five-year reviews of remedy protectiveness are applicable to initial remedy selection decisions and subsequent enhancements of their effectiveness through time.
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