Report on the UXO Focus Group

[Lenny Siegel <lsiegel@cpeo.org>]

REPORT FROM THE UNEXPLODED ORDNANCE (UXO)
FOCUS GROUP MEETING

Lenny Siegel, Executive Director, Center for Public Environmental
Oversight (CPEO)
June, 1999

Participants in the CPEO UXO focus group, held in Benicia , California,
June 26-27, 1999 brought a wealth of diverse community-based experience
to the table. The seemed generally comfortable with the use of an
adapted National Contingency Plan for UXO risk management, but they did
not offer detailed comments on the Range Rule Risk Methodology (R3M)
because they did not have the opportunity to go through the details of
the draft R3M documents. When the R3M draft is made available for public
comment, CPEO will send out copies, highlighting the key sections, to
meeting participants. The following is an informal summary of many of
the comments offered at the meeting.

Participants did have a great deal to say about UXO risk management,
criticizing what they considered shortcomings of current risk management
practices. They felt that all areas where UXO might have been handled or
used should be surveyed, because ordnance has been found at many
unexpected places and records are incomplete. 

A number of people said that community relations efforts are undermined
by the military's compartmentalization of responsibility. Community
members, such as RAB members, are often told issues or locations are off
limits, because they are beyond site boundaries, deal with issues other
than environmental restoration, or involve other armed services.

A couple of people stressed the need for adequate data at each stage of
the process. One wondered, "Who decides if there is enough data?"
Several stressed the value of interviewing former base employees.
Another person stressed the need for a conceptual site model - a
hypothesis - when setting data quality objectives.

Some participants pointed out that it's important to assess, up front,
the risk of remediation activities, such as fires set to clear
vegetation. One pointed out that the process should weigh the risk faced
by clearance personnel vs. community risk. Also, the hazards posed by
residues of demilitarization should be considered.

Some participants asked for local technology tests - such as in parcels
seeded with known UXO - to verify the site-specific performance of
cleanup tools. One said stringent requirements will force the
development of better technologies.

In general, participants were skeptical of signs and fences as
deterrents. One felt that a child-oriented (cartoon) video produced at
his site would discourage reckless behavior.

There was some disagreement about the role of land use in establishing
cleanup goals. Some said land use should drive cleanup, but others
wondered whether the reverse is true. Gearing risk to a "residential"
scenario may lead to housing construction when it is still
inappropriate. That is, some didn't want complete cleanup to depend upon
plans to build housing. Some questioned the construction of any housing
use on land where UXO has been found or is suspected to be present.
Terms like "unrestricted" and "sensitive use" were proposed as
alternatives to "residential."

Some people felt that limited clearance would undesirably restrict the
use of large properties where many uses would otherwise be likely in the
long run. Cleanup should be better, regardless of use. Institutional
controls, such as deed restrictions, may be broken or ignored.

Intended land use is appropriate, however, for  setting project
priorities - clear the places first where the public wants to go.

People wanted to know: Who signs off that property is safe for the
intended purpose or for transfer?  That is, they wanted close-out
criteria. The Defense Explosives Safety Board should not only approve
workplans, but it should evaluate the effectiveness of the work..

If land has been transferred, there should be a mechanism for revisiting
remedies if they appear to be ineffective.

Participants said the public should be told the limits or uncertainty in
any risk assessment. They liked the focus on risk management, vs. risk
assessment.

There should be better access to information, said some, pointing out
that the Army presented two papers on their base at a national forum but
didn't provide the same information to the local community. At another
project, however, all documents are easily accessible on the Web. Closed
meetings, said a couple of people, are not acceptable.

One participant said that project managers are rewarded for saving
money. There should also be incentives for satisfying the public.

Participants were also concerned about the use of default depth
clearance goals on land subject to erosion or ordnance migration.

There was some opposition to early transfers at UXO sites.

Participants reported mixed success with RABs. A few are already using
TAPP [Technical Assistance for Public Participation] funds. One said
there should be scientists and elected officials on the RABs. The people
from Fort Ord charged the Army with dissolving their RAB because it was
effective in challenging the Army. Those without RABs wanted them.

One participant said that it's the duty of activists to "prove them
[Defense officials] wrong."

In summary, the R3M process could address many of the concerns expressed
at the Benicia meeting. To  satisfy community members, however, project
managers and other government officials need to work hard to build
trust.

-- 


Lenny Siegel
Director, Center for Public Environmental Oversight
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
http://www.cpeo.org