Defense Science Board Report on Unexploded Ordnance

[Lenny Siegel <lsiegel@cpeo.org>]

DEFENSE SCIENCE BOARD RELEASES LANDMARK REPORT
ON UNEXPLODED ORDNANCE REMEDIATION

by Lenny Siegel

This week the Department of Defense (DoD) cleared for release a landmark
report, "Unexploded Ordnance Remediation," by a task force of the
Defense Science Board (DSB). The report is significant for two reasons:
First, it makes clear that the Defense Department finally takes the task
of remediating former domestic munitions impact ranges seriously.
Second, the Defense Department - particularly the Environmental Security
office - is already moving to implement a number of the task force's
recommendations. As soon as we receive the final version of the report,
we will let our readers know how to obtain copies. We hope to publish
the executive summary via this newsgroup. [All quotes here are from a
near-final version.]

The Defense Science Board is an official Pentagon advisory group. This
task force consisted primarily of retired generals and former Defense
political appointees. As the only member of the task force with a long
history of anti-war activism, I felt initially like a fish out of water.
Nevertheless, through our deliberations I was convinced that the other
participants considered unexploded ordnance (UXO) contamination a
problem that needed to be solved.

The task force explored the technology, organization, and financing of
UXO response. It was briefed on the debates over the regulatory
framework - the Military Munitions Rule and the pending Range Rule - but
it was not tasked to address legal issues. Perhaps that's why it was so
productive.

The DSB found that an estimated 15 million land acres, on about 1,500
sites, may contain UXO. "Because the suspect sites have not been
surveyed, there is great uncertainty about the actual size of the UXO
problem. However, even if only 5% of suspect acreage needs cleanup,
remediation costs would still be high (possibly exceeding 15 billion
dollars) and times would be long (possibly exceeding several decades to
complete) using current technologies." Actual cleanup, at former defense
sites and closing bases - excluding the Hawaiian island of Kaho'olawe -
is currently being funded at about $125 million a year. About $20
million more is dedicated to UXO research and development.

The task force found that the Defense Department, as a whole, lacks
specific cleanup-goals, objectives, or management plans for UXO. It
therefore recommended the establishment of a focal point within the
Environmental Security office to address the Department's unmet
management responsibilities. It suggested that the Deputy Undersecretary
of Defense for Environmental Security [DUSD(ES)] (currently Sherri
Wasserman Goodman) "take the policy lead for DoD UXO remediation
efforts, in coordination with other relevant DoD components."

LINE ITEMS

The report endorsed stable funding. It said the Environmental Security
office should "Identify the needed Congressional actions that will drive
UXO requirements for an improved DoD program, including the likely
FUDS/BRAC sites with high Congressional priority and those closed ranges
that should be converted to more productive uses.... Therefore, we
recommend the establishment of a closed range UXO remediation line item
in the Environmental Security budget. This line item will offer the DoD
and Congress the opportunity to determine the proper level of effort for
UXO response ... it will make it easier to apply relative risk
principles to the allocation of UXO project money without comparison to
totally different kinds of risks." It actually suggested two UXO line
items: one for remediation and one for research, development, test, and
evaluation (RDT&E).

RISK MANAGEMENT

DSB called for a two-stage risk management process, "the first stage
focusing on immediate responses to UXO risks, and the second designed to
provide subsequent responses to risk." Site managers, it said, should
prepare a "site master plan that establishes the end state for each
location that is identified for clean-up, including what should be left
in place and what should be cleaned to an agreed upon level to
accommodate future land use."

PRIORITY SYSTEM

It proposed that the Defense "Develop a risk-based priority system,
similar to the Relative Risk Site Evaluation Framework for hazardous
waste sites, to weigh the many competing UXO needs, based upon explosive
risks, other human health risks, ecological concerns, and other
pertinent factors, including current and future property use. Such
priority determinations should be made in consultation with
environmental regulatory agencies and the affected public."

TECHNOLOGY

As an entity of the Defense SCIENCE Board, the task force spent most of
its time learning about current and proposed UXO response technologies,
and it drew strong conclusions. The task force found that currently
fielded technology - primarily "mag and flag" as well as many current
research programs are not good enough to meet the challenge. It noted
that the high cost of subsurface range clearance is driven by the huge
number of "false alarms," which trigger an equally large number of
excavations of items other than UXO. DSB recommended a two-track
approach to technology development:

"The first track calls for the aggressive development and demonstration
of a baseline system-of-systems approach to reduce the false alarms by
about a factor of 10. In our view, it would be appropriate to conduct a
competitive effort by at least two industrial systems integration teams.
The development and demonstration efforts are expected to require 3-5
years to achieve the objective and would include demonstration of
integrated, ground and aerial precision navigation, aerial survey
detections of surface and near surface objects, vehicular and man
portable equipment to detect and categorize objects and the appropriate
computer architecture, data base and processing algorithms. The Task
Force emphasizes contractor integrated, to assure common communications,
navigation, data bases, etc. Over the next 3 to 5 years we would expect
these activities to average about $20M per year."

"The second track would involve an aggressive research and development
effort, running in parallel with the effort described above. The
objectives would be to explore some avenues which have received too
little attention in the past (e.g., seismic/acoustic, neutron
activation, synthetic dog's nose, motion of subsurface objects over
time, etc.) and also to conduct research on those pacing elements used
in the baseline approach which will benefit from continuing and
competitive research, such as the characterization of clutter at
different sites, clutter rejection algorithms, design of sensor arrays,
etc. The Task Force proposes that this second track be performed largely
by universities coupled with industry, and also funded at about $20M per
year.

"Since the current UXO-related R&D is funded at about $20M per year, the
proposed program can be judged as about a two-fold increase. The basic
justification for such an increase is that the DoD is spending about
$125M per year on UXO remediation using a very inefficient approach.
Current understanding of the physics and experimental data to date
suggest that by developing the proper tools, DoD will save about $60-70M
per year. As such, it would be a good and urgent investment.

"Once the baseline program demonstrates the required reduction in the
false alarm rate, the Task Force recommends that DoD rely on industry to
commercialize the technologies into systems for use in UXO remediation.
It will be important to continue the second track activities because of
its value to DoD range clearing and countermine operations, specifically
the detection of non-metallic landmines and the detection and
characterization of more deeply buried objects (5-20 feet)."

In keeping with its finding that there is no "silver bullet" - a single
technology capable of addressing all remediation needs - the task force
provided an appendix listing and briefly evaluating a number of
alternative technological approaches.

POLLUTION PREVENTION

To reduce future UXO clearance problems, the task force recommended that
render safe and disposal procedures be incorporated early in the design
of future munitions. It also called for better data collection and the
use of "fire-finding" instruments and taggants to aid in the detection
and identification of ordnance used in the future.

CONTRACTING

Since UXO clean-up is not a "DoD core competence," the task force
concluded that "invigorating private sector involvement is critical to
the success of the DoD UXO clean-up effort. But to encourage private
sector participation, a UXO remediation 'market' must first be more
evident." To promote greater private sector interest, particularly from
large firms which my be "deep-pocket" targets for litigation, the task
force recommended the use of existing regulations to "relieve private
companies of unreasonable third party liability and indemnification
burdens."

Because current contracting procedures provide little incentive for the
deployment of advanced technologies and integrated systems management,
the task force also recommended "employing
performance/objective/criteria-based contracting procedures that provide
incentives to the private sector to participate more efficiently and
aggressively in the UXO clean-up effort."

PERSONNEL

The task force noted the reliance of clean-up contractors on a small
number of retired military explosive ordnance disposal (EOD)
specialists. It supported, therefore, the creation of non-DoD training
programs for UXO technicians.

RESTORATION

The task force found that no standard currently exists to mitigate soil
contamination or to reforest areas where deforestation is part of
cleanup. It said, "water and air surrounding or contained within a UXO
site may need continuous monitoring to confirm the safety of the site
and to protect the communities surrounding it. It recommended that
remediation plans consider future restoration needs" and the development
of standards to address soil contamination and reforestation.

OTHER RECOMMENDATIONS

The task force also strong endorsed regulator and public involvement in
the range remediation process, the accelerated remediation of ranges on
Indian lands, actions in minimize public exposure, suitable processing
of range scrap (which sometimes contains residual explosives or even
live UXO), and the creation of a risk management strategy and a funding
stream for responses at closed ranges within active Defense
installations.

IMPLEMENTATION

The Defense Department has been aware of the recommendations of the
Defense Science Board for several months, and in fact many of the task
force's ideas grew from suggestions generated within the Department.
Consequently, many of its proposals are already being advanced. For
example, the Defense Department has convened a team to consider
performance-based contracting procedures and contractor indemnification.
Another team is developing an occupational skills standard for UXO
remediation technicians. In its formal release of the document, the
Pentagon is expected to summarize actions already underway.

I don't believe that the Department of Defense would have taken the UXO
threat seriously in the absence of pressure from Congress, regulatory
agencies, and the public at large, but the Defense Science Board report
makes clear that UXO remediation is gathering significant momentum
within the Department. Using the same type of analysis that gave the
U.S. the capability to detect submerged Soviet submarines, the Defense
scientists have come up with a long-term strategy to address the UXO
problem - that is, to protect, in a cost-effective way, the American
public from literally millions of "time bombs" within our midst.

Lenny Siegel
Director, Center for Public Environmental Oversight (AKA SFSU
CAREER/PRO)
c/o PSC, 222B View St., Mountain View, CA 94041
Voice: 650/961-8918 or 650/969-1545
Fax: 650/968-1126
lsiegel@cpeo.org