UXO Remedy Selection

[Lenny Siegel <lsiegel@cpeo.org>]

UXO Remedy Selection

I would like to draw attention to what I consider a flaw in the way that
the Army currently selects remedies for property contaminated with
unexploded ordnance. Smart project manager may work around the flaw, but
the official methodology invites poor decisions. The pending Range Rule
Risk Methodology (R3M) may alleviate the problem, but only if the
weakness is clearly identified.

In essence the current process develops a clearance depth based upon the
intended land use for each parcel of property, as well as the estimated
penetration depth of ordnance known to have been fired in the vicinity.
Other factors, such as cost and anticipated disruption of habitat, may
reduce the planned depth of clearance, as well. Then, and only then, is
the actual remediation technology - a mix of characterization and
excavation - selected.

This linear mode of thought discourages consideration of innovative
technologies as a way to make clearance more complete, cost effective,
or environmentally sensitive. A depth goal that seems unrealistic with
conventional technologies - notably mag and flag - may make more sense
with a technology that reduces the number of "dry holes" - spots where
items other than UXO and UXO-like objects are excavated. Under the
National Contingency Plan adaptation envisioned by R3M, remedial
technologies could be considered at the same time depth goals are
established, not after they are sunk in stone.

Similarly, small adjustments in land use plans could also make clearance
more complete and cost effective if feedback were encouraged. I'm not
suggesting that communities give up college sites or recreational areas
to save the Army money, but sometimes it may be possible to move a small
infrastructure development - such as a pipeline - a short distance from
a high-cost remediation area to one where cleanup expenses are likely to
be much less.

Once again, the key is to build feedback loops into the decision-making
process. If a decision late in the process changes the factors that led
to a previous decision, one should be able to go back and try again.

-- 


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