[CPEO-MEF] natural attentuation -- the reality

[kendricka@ttnus.com]

[This message is refering to an e-mail sent to the military listserve on
July 27, 1999 by Arc Ecology.]

> Let's not throw the baby out with the bath water.
> 
> Following is the statement from the previous thread written by Arc
> Ecology, to which I am responding: 
>     "The Navy seems to believe indeed that "dilution is the solution to
> pollution. I am deeply concerned about these responses. First the Navy has
> stretched the concept of "natural attentuation" to absurdity. Second,
> their statements do not comply with EPA's policy on natural attentuation.
> Third, these statements represent an enormous breach of trust. DoD has
> reassured the public many times (at forums sponsored by CPEO!) that they
> will not abuse the concept of natural attentuation. Well they have -- or
> at least they plan to at Hunters Point Shipyard unless we stop them." 
> 
> First, I think it is important that all readers of this thread read and
> understand the USEPA position on Natural Attenuation (OSWER Directive
> 9200.4-17, 1997):
> 
>      "The term "monitored natural attenuation," as used in this Directive,
> refers to the reliance on natural attenuation processes (within the
> context of a carefully controlled and monitored clean-up approach) to
> achieve site-specific remedial objectives within a time frame that is
> reasonable compared to other methods. The "natural attenuation processes"
> that are at work in such a remediation approach include a variety of
> physical, chemical, or biological processes that, under favorable
> conditions, act without human intervention to reduce the mass, toxicity,
> mobility, volume, or concentration of contaminants in soil and ground
> water.  These in-situ processes include, biodegradation, dispersion,
> dilution, sorption, volatilization, and chemical or biological
> stabilization, transformation, or destruction of contaminants.  
>     Monitored natural attenuation is appropriate as a remedial approach
> only when it can be demonstrated capable of achieving a site's remedial
> objectives within a time frame that is reasonable compared to that offered
> by other methods and where it meets the applicable remedy selection
> program for a particular OSWER program.  EPA, therefore, expects that
> monitored natural attenuation typically will be used in conjunction with
> active remediation measures (e.g., source control), or as a follow-up to
> active remediation measures that have already been implemented."
> 
> After reading the OSWER Directive, please return to the original thread by
> ArcEcology and see if you agree with their statements.  As a senior
> environmental professional and consultant to the Navy, state and Federal
> regulators, and industry, I think their statement is both invalid and
> inflammatory.  
> 
> My 13 years of experience indicates that the Navy's position is consistent
> with the USEPA policy.  Monitored Natural Attenuation (MNA), like every
> other remedial alternative, can be both taken advantage of, and used
> improperly.  I can't count the number of pump & treat systems that are
> both costly and ineffective.  The fact is that most of the hazardous waste
> plumes are diffusion-controlled and therefore, are not responsive to
> permeability-limited technologies.  Furthermore, I have seen many sites
> were MNA has been shown to be VERY effective at protecting human and
> ecological receptors within relatively short time frames.  As with any
> potential remedial alternative, MNA must be investigated and evaluated by
> professional scientists and approved by all of the stakeholders.  MNA is a
> very viable alternative for many sites.  I only hope that a few alarmist
> comments don't hamper the work that needs to be done.
> 
> Andy Kendrick
> Tetra Tech NUS
> Pittsburgh, PA
> 412-921-8623
> KendrickA@ttnus.com
> 


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