From: | Lenny Siegel <lsiegel@cpeo.org> |
Date: | Fri, 10 Mar 2000 16:11:01 -0800 (PST) |
Reply: | cpeo-military |
Subject: | [CPEO-MEF] Long-Term UXO Risk Management |
[The following message consists of the notes I prepared for a presentation this week, at Fort Ord, on Long-Term Risk Management at UXO sites. Please recognize, however, that many of the same approaches are applicable to short-term risk management - that is, how to protect public safety before remedies are implemented. - Lenny Siegel] As I see it, there is a hierarchy of responses for UXO. A. Removal B. Land Use Controls C. Access Controls D. Education REMOVAL (in the physical sense, as opposed to a CERCLA "removal action") is somewhat obvious. If we can find and remove UXO in a cost-effective way, we do it. But we're never sure that we've removed all of it. And sometimes decision-makers decide that removal is too costly, technically impractical, and/or environmentally destructive. This is at the top of the hierarchy because if there is no UXO there is no explosive risk. Removal decisions are the most controversial. Largely because of the resource implications, the armed services and others often disagree over the breadth and depth of clearance. But even when there are differences over removal decisions, the parties can and should work together in the other three areas. LAND USE CONTROLS are designed to prevent excavation or other activities that may expose or bring people into contact with buried ordnance. There are many possible mechanisms for restricting such activity, including zoning and deed restrictions. Ideally they work in two ways: 1. Regular review. Responsible officials should periodically review the property to ensure that no activity violates land use restrictions. This should occur much more frequently than the five-year review - perhaps quarterly. Though technically not a land use control, responsible officials should (on the same regular schedule) also determine whether geophysical processes such as freeze-thaw, tidal action, or erosion are likely to expose or bring people into contact with UXO. 2. Trigger mechanisms. Requests for building permits or one-call inquiries (for utility trenching etc.) should flag a warning, to be followed up by responsible officials. The proper response might be construction support, a form of removal. Or the proposed excavation might be denied. This should be in place for "open space" parcels as well as developing ones. At major installations, it should be possible to record parcel-specific information about UXO deposition and know removal activities in an easily accessible GIS data base. ACCESS CONTROLS are particularly important on undeveloped property where surface or near-surface (to one foot) ordnance is likely to be found. They should designed to prevent people from coming into contact with UXO. Visual contact is almost as dangerous as physical contact, since UXO attracts attention. If geophysical processes are likely at the site, then deeper ordnance is a cause for concern. At a minimum, access controls include signs and fences. Those should be checked periodically (quarterly?) for their integrity. In many cases - whether or note there are fences and signs - active patrolling should be used. That's what has kept people off of active bases. Ideally, patrolling can be carried out by law enforcement officials, park rangers, or others responsible for the new use. Often, patrolling should be accompanied with clear criminal penalties for trespassing in dangerous areas. There is not a great body of knowledge of how well access controls are likely to work, so community input in critical in planning them. EDUCATIONAL PROGRAMS should be designed to discourage people from entering dangerous areas and to warn people not to touch or even approach suspicious objects. These can include displays at trailheads, videos and comic books for kids, brochures, etc. As with access controls, we don't really know what educational approach works best. So again, the community should play a key role in devising it. *** Land use controls, access controls, and educational programs should all be monitored regularly to ensure viability, and the property should be monitored for geophysical activity as well. Any time breakdown occurs, additional removal should be considered. That is, one shouldn't wait for a five-year review. Therefore, long-term risk management requires a clear assignment of responsibility (in decision documents), funding (to be arranged or even endowed at the time of response selection), and public awareness. That is, there should be ironclad assurances that risk management activity will take place for the life of the UXO - usually that means indefinitely. The public should be kept fully aware so it can ensure that officials are taking necessary protective actions. If long-term risk management appears to be too costly, then additional removal should be considered, not only during the initial response decision-making process, but at each five-year review. It's quite possible that new technologies will lower the cost of removal, make removal more reliable, or even prove that earlier removals were sufficiently reliable to abandon some of the long-term management activities. -- 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 You can find archived listserve messages on the CPEO website at http://www.cpeo.org/lists/index.html. 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