Re: Natural Attenuation (NA) (A Modest Reply)

[Dr. Susan L. Gawarecki <loc@icx.net>]

I guess I'm a lone ranger when it comes to the type of cynical analysis
that Sam Goodhope presents, but I think he's way off base.

After having worked for 3 environmental consulting firms over a 10-year
period on many military base projects, I have found that the vast
majority of base personnel and their contractors are truly interested in
cleaning up the contamination. These are by-and-large people of good
will and with solid technical credentials.

In many cases what hampers them from accomplishing cleanups are
unreasonable demands by federal and state regulators, in some cases
reflecting personal or political agendas rather than appropriate
approaches to cleanups. Often the regulators are unwilling to sign off
on proposed remedies, as making a decision leaves them open to second
guessing by their bosses and the public. Consequently, cleanups can
drag on for years, often with extended studies added on because
regulators don't feel like there is enough data or good enough data to
to make the perfect decision. Internal factors, such as budget
restrictions and DoD technical reviews, can also delay or derail
progress.

Regarding economic redevelopment--this is an absolute necessity for
communities losing the huge economic engine that a military base
represents. The specialists in that aspect--the "boosters"--aid their
communities in the ways they feel are important, just as
environmentalists do. These are people who generally have the best
interests of their community in mind and who devote a great deal of
unpaid time to volunteer economic development efforts. I would
certainly rather see development proceeding on brownfield areas rather
than destroying more of our agricultural or wooded areas. So what if
they make money on redevelopment?--they create jobs as well. Being
unemployed is a much greater health risk than being exposed to ppm
levels of most of the common contaminants at these military bases.

Federal and state regulations drive the requirements for cleanups at
sites. Immense quantities of paper are involved. The technical aspects
can indeed be daunting for a lay person to understand--that's why there
are specialists in hydrogeology, risk assessment, etc. But that doesn't
excuse the lay environmental activist from developing at least a basic
understanding of these disciplines. Too many activists prefer to rely
on rhetoric and fear-mongering--and then they wonder why their opinions
are disregarded. Too many activists attack the motives, scruples, and
morals of the military and contractor personnel involved with
cleanups--and then they wonder why they can't get any cooperation from
them.

EPA has published policy (OSWER Directive 9200.4-017) on natural
attenuation. Entities wanting to rely on NA as part of a remedy must
justify it in accordance with this guidance. Understanding of the
biological and physical processes is still evolving in this field--one
of the reasons for such intense interest. It doesn't hurt that there is
less expense in monitoring the natural degradation of contamination than
in implementing active remediation projects.

There seems to be an attitude that DoD and other government polluters
should be made to "pay and pay" for their past environmental sins.
Don't forget that those are your tax dollars at work, and there is in
actuality a limited amount that DoD will apply to cleanup. The trick is
in getting the best bang for the buck--maximize your risk reduction
across the board. If NA will accomplish in thirty years what a pump and
treat system would accomplish in ten years at ten times the price,
that's not a bad trade off, particularly if there are no ground water
users.

The other aspect rarely considered is that if immense quantities of soil
are to be excavated and treated and/or disposed of, there are
requirements for disposal sites, treatment sites, uncontaminated fill
material, transportation of the soils and fill--all with negative
impacts on other communities, roads, established ecosystems, and
uncontaminated borrow areas. If natural processes can be exploited to
remediate much of the contamination in place, the overall environmental
impact can be greatly reduced.

I would like to see citizen activists turn away from the cynicism and
criticism and begin to support practical and implementable solutions.

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\ /
/ Susan L. Gawarecki, Ph.D., Executive Director \
\ Oak Ridge Reservation Local Oversight Committee, Inc. /
/ 136 South Illinois Avenue, Suite 208 \
\ Oak Ridge, Tennessee 37830 /
/ Phone (423) 483-1333; Fax (423) 482-6572; E-mail loc@icx.net \
\ VISIT OUR UPDATED WEB SITE: http://www.local-oversight.org /
/ \
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