Fort Ordnance

[Lenny Siegel <lsiegel@igc.org>]

I am circulating a draft of my comments on the Army's draft Unexploded
Ordnance document for Fort Ord, California, because they address a
number of central issues regarding risk management in range cleanup in
general. While many of us have devoted countless hours to the
development of regulatory frameworks for range remediation, the outcome
of those discussions will mean little if risk management strategies are
not improved. I believe that many people and organizations who have
disagreed over the proper allocation of decision-making authority may
nevertheless reach consensus on the best way to characterize and cleanup
former munitions impact areas.

Lenny Siegel

The Draft Phase 2 Engineering Evaluation/Cost Analysis (EE/CA) for
former Fort Ord is a generally competent application of standard Army
practice for unexploded ordnance (UXO) response, but it is woefully
inadequate for the challenge of addressing several thousand acres of
impact range in a populated area.

Before I explain, I want to first express my respect and appreciation
for the Department of Defense personnel and their contractors who have
been thrust on the front lines of UXO response without either adequate
weapons or strategy. They have done their best, often risking life or
limb, with the tools provided them. Only when the military takes UXO
remediation as seriously as comparable technical problems, such as
anti-submarine warfare will the cleanup "troops" be adequately prepared.
With the publication of the Proposed Range Rule and the upcoming release
of the Defense Science Board task force on UXO, I am optimistic that
indeed the Defense Department is ready to take on the task.

THE DRAFT EE/CA IS INADEQUATE

The most obvious problem with the EE/CA is that it does not define the
scope of the problem. I could find no place in the entire document that
places an upper limit on the acreage to be analyzed using the template
that it provides. There are no preliminary minimums and maximums
proposed for acreage subject to each level of proposed action, so it is
impossible to evaluate the overall economic or environmental impact of
the project. 

Thus, rather that propose a series of removal actions, the EE/CA merely
provides a decision-making tool, which must be combined with
site-specific data, before cleanup levels are established. To be
evaluated by the public and regulators, the EE/CA must ground its
approach by literally applying its analysis to every acre in the
suspected former impact area.

In fact, the EE/CA does not even ask what technologies might be
available, over the course of the project, to detect and remove UXO. It
assumes a traditional mag, flag, and detonate process, even though that
is technologically antiquated, costly, unreliable, and environmentally
destructive. Considering a range of cleanup depths does not meet the
requirement of considering a range of response alternatives.

Furthermore, the "plug in" risk factors that the EE/CA relies upon are
merely default numbers. To my knowledge, they have not been verified by
scientific study. If indeed they are being used simply because they're
"the only game in town," then the EE/CA should make that clear.

Similarly, the sweep efficiencies listed in Appendix B.B. seem
unrealistic (assuming the percentages refer to probability of
detection). Even under laboratory conditions, such as the tests at the
Jefferson Proving Ground, sweeps did not reach this level of
reliability. In the field, particularly in the Fort Ord geological
setting, those figures should be adjusted.

In summary, the Army's approach to UXO response is literally
one-dimensional: How deep is clean?

A GOAL-BASED RISK MANAGEMENT STRATEGY IS NECESSARY

Rather than plug in default standards and formulas, the Army should
first define the risk management goals of its UXO response at Fort Ord.
I suggest the following four, sometimes contradictory goals as a
starting point.

* UXO response should protect public safety and health.

* UXO response should not unnecessarily degrade natural habitat.

* UXO response should be cost-effective.

* Response should be maximize the future use potential of contaminated
areas.

To best achieve these goals, the cleanup document should include, either
directly or by reference, background or studies on the following
components:

1. UXO Migration. In most terrain and climates, buried UXO tends to
migrate to the surface. To what degree do erosion, percolation, and
other forces threaten the eventual surfacing of UXO at Fort Ord? At what
rate might such migration take place? One cannot determine a safe depth
without studying this variable.

2. False anomaly density. A major portion of the cost of UXO removal,
using conventional technology, is the removal (or at least the
inspection) of "false anomalies" such as shrapnel, other metal objects,
and even rocks. To determine the cost-effectiveness of mag-and-flag and
alternative technologies, it makes sense to test them in sample sections
of Fort Ord, determing the likely wast of effort due to "dry holes."

3. Toxic releases. Through use, subsequent detonation, and corrosion,
ordnance releases toxic substances into the environment. This has been
major issue at Camp Edwards, Massachusetts, and similar compounds - RDX,
at least - have been found at Fort Ord. It's impossible to develop a
complete remediation strategy for the impact area at Fort Ord without
collecting at least preliminary data on the extent and nature of toxic
contamination there.

4. Sensor behavior. The accuracy and depth of many UXO sensors vary
widely with terrain, vegetative cover, and soil moisture content. Before
considering tools for UXO detection at Fort Ord, it makes sense to test
them in field conditions there. In fact, it may make sense to test them
during different times of year.

5. Effectiveness of access controls. Land use-based cleanup standards
work only if institutional controls guarantee that intensity of use will
remain at the projected level. To assure that, it's first necessary to
consider the use of adjacent parcels, not just the ones being analyzed
for appropriate depth of clearance. People don't always stay out of
areas because of their zoning or other use designation. For example,
when I was a kid I used to play baseball near a creek in my
neighborhood. The creek's use was clearly not recreational, but I never
hesitated to scale or crawl under the 12-foot fence to retrieve a foul
ball.

Equally important, community input is essential before physical controls
are adopted as a part of any remedy. Will they be effective? Will they
be counter-productive, in that they effectively invite souvenir hunters
or daredevils? If indeed active security - the Army's historic approach
- is necessary to maintain public safety, then the cost of operating
those patrols over the life of the hazard should be considered as part
of the relative cost of the control-based alternative.

6. Timing of future use. It's not enough to present a map of proposed
future land use designations. Some permitted uses are not likely to
materialize for some time, and the data in the document should reflect
that.

7. Risk factors. Nationally, the Army and other agencies are working on
the development of better methods of assessing risk from unexploded
ordnance. The provisional status - that is, the lack of scientific
backing for the risk factors used in the EE/CA - should be noted. In the
absence of such backing, more conservative values may be necessary.

8. Technologies. Numerous technologies are now available for surface
detection and clearance. Army-sponsored demonstrations show that
existing technologies can be modified to improve results. And several
other analytical approaches and sensor technologies are on the horizon.
Those alternatives should be surveyed and evaluated in the cleanup
document.

CAREFUL TIMING IS ESSENTIAL

The Army already recognizes that range response at Fort Ord must be
spread over a period of years, because of both the magnitude and the
need to limit ecological damage. The appropriate risk management
strategy for Ford Ord's impact ranges, therefore, can and should take
into account the temporal dimension - that is, timing. Which technology
should be used to which depth, and when?

Those areas which post the greatest hazard today or which are required
soon for reuse should be remediated to the appropriate level using
conventional technology. To be cost-effective and ecologically
sensitive, certain areas should be scheduled for full remediation only
when alternative technologies are available. However, some of those
areas where full response is postponed should receive surface clearance
early in the process. Controls should be instituted as temporary
measures, and the Army should make a clear commitment to complete
remediation once better tools become available. In fact, it should
commit to developing those tools, and Fort Ord should be considered as a
site to test and demonstrate such innovative technologies.

A sufficient EE/CA (and maybe the document should have another name)
should identify parcels covering all impact areas at Fort Ord. It should
describe the likely hazards at each site; it should estimate the
presence of magnetic anomalies other than UXO; it should project
ordnance migration; it should consider the effectiveness of existing and
potential sensors; it should include data on toxic explosive
contamination; it should describe the proposed timing of future uses as
well as potential access enabled by adjacent uses and allowed by
institutional controls. With all that information in hand, it should
propose both immediate and long-term responses for each parcel,
describing the depth of clearance, treatment of other hazards such as
toxic substances, technology of choice, and extent (and cost) of
institutional controls.

Only when such a complete report is available can the public and state
and local agencies constructively evaluate the Army's plans. And only
then can a complete, safe, cost-effective cleanup be carried out.

Lenny Siegel
Director, SFSU CAREER/PRO (and Pacific Studies Center)
c/o PSC, 222B View St., Mountain View, CA 94041
Voice: 650/961-8918 or 650/969-1545
Fax: 650/968-1126
lsiegel@igc.org