Follow-up from Monitored Natural Attenuation Forum

[Center for Public Environmental Oversight <cpeo@cpeo.org>]

[The following posting is a participant's report on the National
Stakeholder's Forum on Monitored Natural Attenuation. The report is by
Martin Jeffries who is a Luke AFB (Arizona) RAB member, and was presented 
to the RAB on 9/30/98. -jg]

FORUM ON NATURAL ATTENUATION
Aug. 30/Sept. 2 in San Francisco

I came away from this conference on Monitored Natural Attenuation (MONA) with
more questions than answers. Stakeholders such as ourselves (RAB Members),
Tribal Representatives, TABS, Regulators and Military were all there from all
over the nation. It appeared to the Stakeholders that the EPA and Military
were promoting this as a new way to go. At first we felt it was a cost
driven approach; a sort of wait and see if nature will make the pollution
just go away approach. The Monitored part means we will watch while we wait. 
The Military and the EPA have invested lots of time and study on this whole
hew idea and plan to move ahead with it. New acronym, DAD, Decide-Announce-
Defend At this forum the Regulators were defending their decision and in the
process we, Stakeholders, became better educated and just maybe a little more
understanding of this as an option. 

So, what is MONA? First off let me say the acronym MONA is the Stakeholders
version of EPAs acronym MNA. We, the Stakeholder felt MONA should be a
female acronym because a female is better looking and generally gets stuck
with cleaning up the dirty stuff left behind by others. That is what
Monitored Natural Attenuation is, another method of clean up. Let us take
fuel hydrocarbons as an example we know that in time they will biodegrade so
the theory is that left alone the natural microbes will eat away at a fuel
spill in the soil. That is if the soil will support the microbes, if the
source of the spill has been cut off and if the spill has not migrated to the
ground water. In other words if all conditions are ideal then nature will do
the clean up for us. In my opinion a very controversial approach, a very
uncertain approach presented to us as a alternate approach. Remember, DAD,
Decide-Announce-Defend. 

So, if we are to use MONA we are going have to do a real risk assessment. 
For example, what are the advantages and disadvantages, just when would it be
an appropriate approach, how would we predict effectiveness, what will we do
if we find it isn't working, and who will be responsible 10 or 20 years down
the road. Then we have to ask, do we have good reliable data on the soil &
water, is the supporting documentation fair, what are the costs long term, do
we have the cost of other options to compare, are we sure we know the source
and is it controlled, what is the time frame and is this based on containment
or clean up, will institutional controls be necessary and can we predict
their effectiveness 20 years from now and if this is being sold to us
Stakeholders as clean up when will we know it is 100% cleaned up. 

Yes I'm asking a lot of questions and that is our charge as RAB members as we
represent the Community Stakeholders. So, how might this effect us here at
LUKE. Let us look at our site SS-42 where we are using the soil vapor
extracting equipment, in my opinion successfully. In the last couple years
we have removed over 50,000 pounds of fuel residues and at some point we may
be asked to look at finishing the job with MONA. Biodegregation is happening
right now alongside the vapor extractor and it will continue if we turn off
the vapor extractor, then we would call it MONA. 

The purpose of all clean up efforts is to protect human health and our future
environment. We, here at LUKE, are proud of what we are doing and have
accomplished so far and I was pleased to be able to stand up in front of
people from all over this nation and tell them that we consider LUKE an
environmental success story. At this point I'm going to play the devils
advocate and use our spill and plume SS-42 as a reference (talking about it
only as a hypothetical case). With MONA alone could it have taken 50 or 100
years for the microbes to eat up the 50,000 pounds of residue we have removed
to date? With this new approach would we RAB members have bought into such
an unknown? Then we look at our model and say at what point could we turn
off the vapor extraction and complete the job with MONA. But then I ask how
sure are we of our model and if the water table changes is our model reliable
anymore because we are talking 20 years or more for MONA to work. Our plume
may be stable today but if the water table changed would it still be stable
and who would be watching it. You say institutional controls but they are
historically unreliable on long term cases. 

Another question is if the hydrocarbons are vented or biodegrade are there
any daughter products left behind and are they benign or toxic. Also in what
way will these new daughter products migrate, into the air or into the ground
water? So far we have assumed this spill only contained fuel and no
chlorinated solvents. If any solvents are present then we know we are
growing bad stuff and a completely different approach is in order. 

My conclusion is we must know a lot more about what we are doing before we
can even consider MONA. We have to give a lot of thought to the long term
risks of short term actions we take today. 

I ask myself if we cut corners today and just a little contamination gets
into our environment will it make our children and grandchildren just a
little sick ten years from now. That is what I want us all to think about
when we do RISK ASSESSMENT. Is this a political solution based on cost, I
wonder? Private industry and small business were forced to clean up or go
bankrupt and many did have to go bankrupt, now it's time for the king to
clean the courtyard and the barriers have been lowered and the king wants
nature to take care of it. 

I am not convinced! I am a show me sort of a guy and feel MONA might only be
applicable in extremely limited cases. 

I am not against regulation, as I feel good regulation fairly enforced pushes
the envelope on technology and this creates new solutions (our composting &
vapor extracting are good examples). 

But MONA is a policy being promoted that I think is a step backwards for the
sake of costs. In my opinion it will bring more problems not more solutions. 
Having said all that, we RAB members here at LUKE enjoy a trusting
relationship with the Environmental Flight & Belle Matthews. So, it will be
their job to educate us as they have in the past and sell us on this new
approach. 

 That is my report.

 Martin "JEFF" Jeffries