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implemented as soon as site data and information make it possible to do so." 40 CFR 3 .. o a 1 . The NCP provides program management principles-, including; "'Sites should generally be remediated in operable units when early actions are ,necessary or appropriate to achieve significant rise reduction quickly, when phased analysis and response is necessary or appropriate to achieve significant risk reduction quickly, when phased analysis and response is necessary or appropriate given the size or complexity of the site, or to .p it. the completion of the total site cleanup." CFR 30.43a1 ii. Extensive guidance is given for remedial investigations and related work. "The purpose of the remedial investigation feasibility study RI FS is to assess site conditions and evaluate alternative s to the extent ne cessary to select a remedy. 4 0 CFR 300.43 a ) (2). An R FS generally includes project seoping, data collection, risk assessment, treata ility studies, and analysis of alternatives. Id. The NCP addresses numerous topics for an RI FS, including Project Scoping 4 CFR. 30 ,43 , Community .Relations (40 CFR 3 .43 c , Remedial Investigations (RI) (40 CFR 300.430(d)) and Feasibility Studies (40 CFR 300.430(e)). The Remedial Design /Remedial Action (RD/RA stage includes the development of the actual design of the selected remedy and the implementation. of the remedy through construction. A period of operation and. maintenance may follow the Remedial Action activities. 40 CFR 300.435(a).' MERLA Minnesota has its. own cost recovery s.tatute,. the Minnesota Environmental Response and Liability Act "M RLA" ,. found at Minn. Mart. § § 115 B..01., et sect. M RLA is - imilar to C RCLA in some respects although there are many differences. M RLA allows cost recovery for response actions neces -sary as a result of releases or threatened releases of hazardous substances, but also allows recovery of lost profits and other damages in certain circumstances. M RLA allows a prevalIing plaintiff to recovery attorneys' fees. Howe er, M RLA is su.bj ect to certain defenses on retroactivity depending. upon the date of the releases of hazardous substances. But,. the City is in a better position. that private parties to pursue claims for historical release s. Also, the City is allowed to recovery any "reasonable and necessary response cost s, "" whereas private parties could recover only removal costs. Minn. Stat. § 115. , 04 , subd. 1. Cinder Minn. Stat.. § 115B.04, subdr 1, "any person" who is responsible for a release or threatened release of a hazardous substance from a fact fity is strictly liable, j pint and severally, for, among other things, "all reasonable and necessary response costs incurred by the state, a political subdivision of the state or the United states" and "all reasonable and necessary removal costs incurred by any person." Minn. Stat. § 115 B.-04, su d. 1 1 and . A responsible person RP , however; may assert as a defense against such claims that the hazardous substance released from the facility in question was placed or carne to be located 'n or on the facility before April 1, 1982 and Ire. addition to the provisions presented in the 1CP, the EPA has provided a library full of other guidance documents. addressing removal actions,, remedial actions, and the types of documents one needs to prepare to address different steps in either- type of process. In general, the EPA tends to refer to removal actions as immediate, short - term responses, whereas remedial actions are long terry. actions: