Re: National Stakeholders' Forum on MNA Report

[Aimee Houghton <aimeeh@cpeo.org>]

I'm curious whether anyone suggested that the SWRCB's
Containment Zone (CZ)Policy might be a viable model. CZ
requires a showing before monitored natural attentuation is
permitted: either that source removal has been
accomplished and cleanup has reached asymptotic levels
or that a cleanup is impracticable or that the "burden" of
cleanup is disproportionate" to the benefits.

In addition, the designation of CZ requires the discharger to
pay a "mitigation" fee. The amount of the fee may be as
high as 10% of the avoided cleanup costs (although only a
few of these fees have actually been imposed to date).

This seems like a model that might allow community groups
to get comfortable with natural attenuation (or at least more
so).

P.S. Pump and treat is becoming a disfavored remedy not
just because of the excessive cost; it just doesn't work in
many cases because of DNAPLs or other problems. DOD
or other dischargers shouldn't be required to "buy" a
community's trust by installing a system that's ultimately
ineffectual. The dollars should be spent more
constructively.

Thanks again for the report.