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

[Sam Goodhope <Sam.Goodhope@OAG.STATE.TX.US>]

Dear Dr. Lone Ranger:

I know that everybody, or nearly everybody directly involved in the DoD
cleanup that I know and that I have worked with during the past 8 years
on DERTF, FFERDC (the genesis of the RAB concept) , and at closing
bases has good intentions. Furthermore, it is clear to me that they are
good and talented people. Indeed, I very much value their dedication.
They are trying to take care of a set of very difficult problems left to them
by a unthinking, uncaring and Leviathan bureaucracy during the past
decades. I want to make it abundantly clear that my quibble is not with
these good people.

There remains the problem of the perceived cynicism in my earlier
posting. I apologize to anyone that might have been offended by such
cynicism. Nonetheless, the cynicism that is most dangerous to our
citizens/taxpayers and the environment is not the cynicism you may
detect in my jest, but, rather it is the cynicism in palming off vague and
untested solutions such as natural attenuation and slanted, biased risk
reduction concepts (based more on ephemeral junk science than on long
term and comprehensive concern about the health and welfare of our
citizens) on our citizens/taxpayers.
DoD central (not the environmental folks), certain Congressional staff
members with undue influence on the Hill, and certain lobbyists for the
insurance and chemical interests (who have rightly perceived the DoD

cleanup issues as stalking horse issues for their own private sector
cleanup issues) have been successful during the past 7 years in
changing the rules of engagement on cleanups by dumbing down the
level of protection for our citizens/taxpayers.
But, enough is enough, and I am quite thankful (as a lawyer about to go
back into private practice) for the ripe opportunities left at each and
every base for me and my honorable cohorts by the true cynics. The
lemming-like plunge to natural attenuation and risk-base cleanups simply
does not remove the molecules that, heretofore (before budget limitations
became the drivers for cleanup analyses), were found to be harmful to
humans/taxpayers. Leaving more and more crap at each facility does
not solve the problems of how to best protect our citizen/s taxpayers, it
simply ensures that there will be more and more litigation in the coming
years as we try to assign liability and pay for truly cleaning up bad stuff.
To be more blunt: you can only use desktop analyses and untested
science to sweep so much dirt under the rug. Sooner or later, your
mother-in-law or mom comes by and picks up the "Natural Attenuation
and Risk Reduction" threadbare rug bought at K-Mart.