UXO RISK MANAGEMENT

[Lenny Siegel <lsiegel@igc.org>]

From: Lenny Siegel <lsiegel@igc.org>

UXO RISK MANAGEMENT
Notes by Lenny Siegel
October 29, 1996
Recently I had the opportunity to view an unexploded ordnance (UXO) 
clearance operation at Ft. Meade and to hear briefings on the current 
state of UXO characterization and remediation technology. What I 
learned suggests a risk management strategy consistent with processes 
embodied in the Defense Deaprtment's Draft Proposed Range Rule but not 
fully illuminated by it. It raises questions, however, about future 
land use policy, as embodied both in the DOD Cleanup Office's draft 
future land use policy and in the draft proposed Range Rule - where it 
is still the subject of discussions between Interior and DOD.
As suggested by presenters from the Huntsville Center of Expertise, 
some form of triage is an obvious place to start:
1. Some properties or parcels shouldn't be cleaned up in the 
foreseeable future. The cost, danger to the removal team, or ecological 
risk of clearing extremely rugged, remote terrain or deep underwater 
sediment will in many cases outweigh the benefits.
2. Some properties - such as buffer zones - may have so little UXO or 
other sensor "hits" that clearance and certification will soon be 
relatively cost effective. It may be possible to free up large areas quickly.
3. Other properties, simlar to to Spring Valley (DC), gas pipeline 
rights-of-way, or Laguna Seca Raceway (at Fort Ord) may be small enough 
and a high enough priority to justify clearance with existing technology.
4. The military will soon have the capability to conduct clearance 
cost-effectively not only on the surface, but down one or two feet. It 
may take several years, however, before we can cost-effectively clear 
large areas down to four or ten feet, levels required for many desired 
land uses.
In some areas the long-term use of most of the property is compatible 
with shallow clearance - wildlife refuge, grazing, etc. In others we 
may be forced by cost and technology to delay reuse or rely on 
stringent physical controls until deeper clearance is cost effective.
In either case, it makes sense to carry out shallow clearance within 
the next few years to reduce risks, AND to promise to come back later, 
once technologies for deeper clearance are perfected. There are three 
reasons: A) UXO may migrate to the surface; B) Small parcels within 
undeveloped properties may require development at a later date- as 
parking lots, visitor centers, utility buildings, etc.; C) The 
transferee or land use jurisdiction may have delayed reuse, or there 
are physical controls, not by choice, but because deep clearance could 
not take place.
The promise to come back is an essential risk management tool:
* Without it, the pressure to improve technology and train UXO 
specialists drops enormously.
* Without it, the public and land managers will demand impractical and 
costly removals up front, because they'll expect to be stuck with 
permanent or recurring problems. 
I don't know how the millions of acres will slice among the different 
categories. Indeed, it will take some time just to make the first 
"triage" cut. There may be other categories. But a strategic approach 
to UXO remediation requires the careful definition and consideration of 
the implications of each category of property.
I don't think that public stakeholders at Ft. Meade would have insisted 
on four-foot "mag-and-flag" or excavation for the entire property if 
given the risk management option I described above. Areas where their 
potential liability is great could have posed a problem, but buffer 
zones could have been cleared to shallow levels, fenced, and revisited 
later. Of course, such parcels might have had to remain in DOD 
ownership until new technologies were developed.