From: | Lenny Siegel <lsiegel@igc.org> |
Date: | Tue, 29 Oct 1996 18:49:43 -0800 (PST) |
Reply: | cpeo-military |
Subject: | UXO RISK MANAGEMENT |
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. | |
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