REPLIES TO TED HENRY

[Lenny Siegel <lsiegel@igc.org>]

REPLIES TO TED HENRY

I am combining a few thoughts in one message to lessen the traffic:

1. It's important to distinguish land use controls brought about by 
findings of technical impracticability from those resulting from 
pressure simply to reduce budgets. That is, if under the national 
contingency plan, no sufficient remedy is selected, then land use 
controls are necessary. But it's wrong to allow responsible parties to 
force land use controls as a way of enabling the selection of less 
protective remedies.

2. Tipton Field, the Ft. Meade airstrip, was (I think it's done now) 
cleared down to four feet below the surface using traditional 
"mag-and-flag" technology and limited techniques of risk analysis. 
Based upon potential exposures, some areas were cleared that did not 
need to be to support the use, while other areas - creekbeds, for 
example - probably needed more attention that they got. The four-foot 
default clearance level is as much based upon the range of the 
magnetometers as it is on a clear understanding of the risk. In this 
case, however, the military did spend many millions of dollars on the 
project.

3. The Defense Department Relative Risk Evaluation framework is both 
scientific and transparent. Bases are supposed to involve regulators 
and the public (RABs) in evaluating sites. I have argued that DOD 
should evaluate the relative risk reduction of project, not the 
relative risk of sites, but it has decided otherwise.

The Senate Armed Services Committee and others have criticized the 
armed services for finding too many "high risk" sites for the system to 
usefully sift out those projects not needing immediate funding. It 
would have looked better if the system had been rigged to have few high 
risk sites, but the terms are relative, not absolute. Creating more 
categories is not a good solution because it would require precise 
answers based on vague data. In fact, the strength of the DOD system is 
that it recognizes that it's difficult to accurately assess risk, 
particularly before you start digging or pumping.

Lenny