Re: [CPEO-MEF] Natural Attenuation

[wjasmith@aol.com]

The responses to the message listing different types of natural attenuation, 
or even active bioremediation, as synonyms for no action focused on the 
theory of operation and have missed a major point - implementation.

Generally a more detailed site characterization is required to properly 
implement a natural attenuation or in situ bioremediation alternative than a 
more active alternative such as pump and treat.  Site characterization 
continues during more active alternatives such as pump and treat as the 
contaminants are continuously extracted and monitored while the system is 
operated.  Such continuous characterization is generally not a part of 
natural attenuation alternatives and bioremediation alternatives.  At many 
sites selected for natural attenuation, site characterization is actually 
less complete than would be the case for an active remedial alternative.

In practice, many facilities fail to properly characterize the site before 
selecting natural attenuation or in situ bioremediation and include 
inadequate monitoring in their natural attenuation and bioremediation 
alternatives.  Until the government and industry learn to police
unscrupulous 
operators and properly implement natural attenuation and bioremediation 
alternatives, the public will continue to equate natural attenuation and 
bioremediation alternatives with no action.  

The petroleum industry abused land farms (plowing petroleum sludge into
soil) 
for decades until the EPA effectively banned them.  I hope that the future
of 
natural attenuation and bioremediation alternatives will be different.


Bill Smith
Sierra Club San Francisco East Bay Military Conversion Task Force
WJASmith@AOL.com
Voice and Fax:  (510)522-0390



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