Re: [Fwd: Re: More than a "Do-Nothing" Remedy]] (fwd)

[Peter Strauss <pstrauss@igc.org>]

Career/Pro wrote:
>
> > Date: Fri, 30 Jan 1998 14:45:03 -0500
> > From: Richard Hugus <rhugus@cape.com>
> >
> > Why is CAREER/PRO making an effort to sponsor a project to inform the
> > public about natural attenuation?
> >
> > At the Massachusetts Military Reservation the Air Force (AFCEE) is in the
> > middle of conducting a rollback of previously agreed-upon standards of
> > containment and eventual cleanup of large plumes of contaminated
> > groundwater. Natural attenuation and the currency being given to it gave
> > the Air Force the perfect means of doing this, not a month after EPA
> > published its guidance on the subject. Soon it will be the remedy of 
choice
> > everywhere. On Cape Cod natural attenuation of solvent plumes will work
> > through disperal and dilutiuon only-no bio-degradation. Disperal and
> > dilution does not reduce the mass of contaminants. It is not a cleanup. 
It
> > IS a do-nothing approach.

I am a technical advisor to several groups at various federal facilities.
 Unfortunately, each group has had to come to grips with, and often
fight, agency plans to implement natural attenuation. If it includes
significant amounts of dispersion and dilution, it is a do-nothing
approach to cleanup. On the other hand, there are plumes that undergo
significant chemical and biological destruction.
It seems to me that it is important for all stakeholders to understand
the policy and technical implications of natural attenuation. This does
not mean that one is selling it - rather trying to understand the
circumstances when one should strongly oppose it and others where it may
be acceptable with safeguards built into the remedy (e.g., strongly
worded contingency plans, monitoring etc.).
Peter Strauss