RE: [CPEO-MEF] natural attenuation -- the reality

[kendricka@ttnus.com]

Your response is very fair.  Some have been so emotional and unfounded that
they have been worth archiving for future laughs.  

For most of the environmental teams that I am working with, the stakeholders
consist of the Navy, the Base, the EPA, and the State.  They have been
empowered to make decisions, and typically do have the power to approve or
reject an alternative.  

NA started because our industry (Environmental) spent mill-bill-trillions of
dollars and many years investigating sites, and then even more time and
money designing and operating active remediation systems (e.g., pump &
treat) that were significantly less effective than anticipated.  That or
they dug it up and put it in a landfill.  As you mentioned, it is designed
to be used in conjunction with other remedial alternatives or source control
activities.  NA is not the Silver Bullet.  The majority of the NA sites that
I am working are spending significant money evaluating the site-specific
geochemistry, determining site-specific fate and transport mechanisms, and
performing numerical and/or qualitative modeling to show that the
contaminant(s) will not reach a human or ecological receptor prior to
naturally attenuating below action levels.  NA does not eliminate the
performance of the Feasibility Study -> Proposed Plan -> Public Comment
Period -> Responsiveness Summary -> Record of Decision.  And ARARS are still
required.  You may not need to "do" something (e.g., spend time and
tax-payer money) to be protective to human health and the environment.  

You are right that there are still has many issues to be worked out, not the
least of which is answering the question "what is a reasonable time-frame".
Unfortunately, operating an active but ineffective remediation system for 30
years is not a reasonable time frame.  

Andy Kendrick
Tetra Tech NUS
Pittsburgh, PA 
kendricka@ttnus.com

> -----Original Message-----
> From:	pstrauss@igc.org [SMTP:pstrauss@igc.org]
> Sent:	Monday, November 08, 1999 4:35 PM
> To:	cpeo-military@igc.topica.com
> Subject:	Re: [CPEO-MEF] natural attentuation -- the reality
> 
> Andy,
> 
> If it were only so! You stated that "As with any potential remedial
> alternative, MNA must be investigated and evaluated by professional
> scientists and approved by all of the stakeholders". 
> 
> Stakeholders can give their opinion, write comments, speak at public
> meetings - yet they ultimately cannot approve or disapprove a remedy. 
> While natural attenuation may be appropriate for some sites, usually
> combined with other remedial or source control activities, there is no
> dispute among fair-minded people MNA still has many issues to be worked
> out, not the least of which is answering the question "what is a
> reasonable time-frame".  Unfortunately, EPA guidance on this question 
> is not clear.
> 
> Peter Strauss 
> 
> 
> 


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