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complete the mission of cleaning up federal facilities in an efficient, equitable, and timely manner.

8. The Role of Negotiated Cleanup Agreements —Negotiated cleanup agreements in many instances play a critical role both in setting priorities at a site and providing a means to balance the respective interdependent roles and responsibilities in federal facilities cleanup decision making.

9. Consideration of Human Health and Environmental Risk and Other Factors in Federal Facility Environmental Cleanup Decision Making— Risk to human health and the environment is an important and well established factor that should continue to be a primary consideration in federal facility cleanup decision making, including setting environmental cleanup priorities and milestones. However:

a) Human Health and Environmental Risk—Risk assessments and other analytical tools used to evaluate risks to human health (including non-cancer as well as cancer health effects) and the environment all have scientific limitations and require assumptions in their development. As decision-aiding tools, risk assessments should only be used in a manner that recognizes those limitations and assumptions. Moreover, risk assessments ought not be used by any party as a basis for unilaterally setting aside legal requirements that embody public health principles and other important societal values.

FFERDC Final Report

b) In addition to human health and environmental risk, other factors that warrant consideration in setting environmental cleanup priorities and milestones include:

  • cultural, social, and economic factors, including environmental justice considerations;

 

 

 

 

 

  • short-term and long-term ecological effects and environmental impacts in general, including damage to natural resources and lost use;

 

  • making land available for other uses;

 

  • acceptability of the action to regulators, tribes, and public stakeholders;

 

  • statutory requirements and legal agreements;

 

  • life cycle costs;

 

  • pragmatic considerations, such as the ability to execute cleanup projects in a given year, and the feasibility of carrying out the activity in relation to other activities at the facility;

 

  • overall cost and effectiveness of a proposed activity; and

 

  • actual and anticipated funding availability.

 

The Committee believes that fiscal constraints do not justify failing to take actions to protect human health and environment, but may result in the need to set priorities about what cleanup actions can occur in any given year.

10. The Importance of Pollution Prevention and Pollution Control Activities —Effective pollution prevention and pollution control activities are essential to prevent future environmental cleanup problems. Therefore, in carrying out their mission, federal agencies should view such activities as a cost of doing business and fully comply with environmental laws and regulations that are designed to accomplish these objectives.

 

 

 

5. Cleanup Contracting—Federal facility environmental cleanup contracts should be managed as efficiently as possible by using contract mechanisms that specify, measure, and reward desired outcomes and efficiencies rather than simply reimburse for effort or pay for an end product. Federal agencies should strive to ensure that cleanup contracts and employment opportunities benefit local communities, particularly those that are lacking economic resources and have been disadvantaged by contamination. Contractors and agencies responsible for cleanup should work in partnership with local communities to achieve cleanup goals.

6. Fiscal Management—Funding mechanisms for cleanup should provide flexibility in the timing of expenditures and ensure that cleanup activities are conducted in a manner that is as efficient as possible.

7. Interdependent Decision-Making Roles and Responsibilities —Numerous institutions and people play very distinct and important roles in the decision-making process for federal facility cleanups. These include: facility level managers, national program managers, financial officers, and cabinet officials within the agencies responsible for conducting the cleanup; federal, state and tribal regulators; tribes as sovereign nations; local governments; local, state, tribal, and federal health officials; public stakeholders; and the President, Office of Management and Budget; and Congress. These roles are highly interdependent, reflecting both the site-specific and national dimensions of the federal facility environmental cleanup problem. The decision-making process must ensure that all of these roles are preserved and balanced if our nation is to

 

 

 

  FFERDC Guidance (pre 2000)  (CONT’D FROM P. 15)

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