[CPEO-MEF] UXO Response Steps

[Lenny Siegel <lsiegel@cpeo.org>]

The Defense Department's decision to develop a Directive and Instruction
governing responses at Closed, Transferred, and Transferring Ranges
provides an excellent opportunity to define an improved practical
approach to investigating and remediating unexploded ordnance (UXO).
This approach can incorporate best practices from today's widely varied
projects as well as emerging technologies undergoing development or
demonstration by the Department and its contractors. Since the documents
are not being proposed as rules or regulations, they may remain
unencumbered by constant comparison with the nation's hazardous waste
laws and regulations. Any project based upon the Defense Department
documents will have to be harmonized with the regulatory framework, but
the preparation of the documents should make it easier to consider where
UXO response is similar to toxic cleanup and as well as where it
diverges.

The following proposed steps do not address all issues that properly
belong in the Directive and Instruction. However, they are intended to
get to the heart of the matter. They amplify on the principle, included
in the Defense Department outline, of exposing "the minimum number of
people to the minimum amount of explosives for the minimum amount of
time." Some of the steps may not be applicable at all sites,
nevertheless, they are offered as a standard framework to guide
personnel responsible for developing and implementing UXO response
projects.


STEP 1. Remove or treat any UXO that is found in populated, unrestricted
areas as soon as feasible.

This is generally what Defense Department explosive ordnance disposal
(EOD) personnel do now, but there needs to be agreement as to what
constitutes an emergency requiring immediate action, followed by
reporting, and what can wait for local officials or regulators to review
planned disposal activity.

STEP 2. Determine the boundaries of property known or suspected of
containing unexploded ordnance.

The Defense Department believes that Closed, Transferred, and
Transferring Ranges cover more than 15 million acres of land within the
United States, but not all such property actually contains UXO. It's
logical, therefore, to screen wide areas for the possible presence of
UXO or other explosive hazards, but it's also important to recognize the
public's concern that live ordnance is often found where "it's not
supposed to be."

A. Find and review written records pertaining to the property

B. Interview former troops, civilian personnel, and neighbors about past
military activity.

C. Consult public safety officials and the local news media to determine
if UXO has been found on the property.

D. Utilize wide-area survey techniques, such as aerial
electromagnetometry, to determine which land is free of electromagnetic
anomalies.

STEP 3. Develop a site-specific conceptual model for both ordnance and
explosive waste on the area believed to contain UXO. (Such models are
also necessary for areas containing explosive chemicals without UXO, but
that is beyond the scope of this strategy.)

A. Pull together records on previous responses on the property.

B. Using regular transects, as opposed to random grids, survey the
property for UXO. If necessary, add transects until adjacent sweeps
provide consistent data.

C. Removing localized UXO if necessary, sample soil and groundwater for
explosive contaminants and model their fate and transport.

D. Measure and project geological factors likely to uncover UXO or cause
it to move, modeling the fate and transport of the UXO itself.

E. Create precise three-dimensional digital maps of the property and
both toxic and UXO contamination, with provisions for the repeated
addition of new data.

F. Identify current and planned use of the property, as well as cultural
and ecological concerns.


STEP 4. Plan a multi-phase (if necessary) response designed to minimize
human contact with UXO, as well as reduce toxic exposures. There are
four types of risk-reducing response for UXO, all of which are likely to
be components of the risk management strategy at each site. Generally,
the responses which provide the greatest long-term protection (listed
first) are those that take the most time to implement.

A. Find and clear UXO. If there's no UXO, there is no opportunity for
contact. With today's technology, it may make sense early in a project
only to clear UXO from the surface and the top foot of soil, making it
safe to walk upon the surface. Communities should be assured, however,
that the Defense Department will return to conduct deeper clearance when
technologies improve. Where natural processes tend to unearth buried
UXO, inspection should be frequent until deep clearance is completed.

B. Restrict use of the property. In particular, unsupervised excavation
should be prevented. As with land use controls in general, restrictions
should be layered, including deed restrictions, local ordnance, and site
management plans. Permit and one-call systems should be designed to warn
construction and utility workers of the potential presence of UXO.

C. Limit access to the property. Where UXO has not been cleared, or
where clearance still leaves an unacceptable risk of contact,
unauthorized personnel should be kept out through a combination of
active patrols, the threat of prosecution for trespassing, warning
signs, and fences. The Defense Department should conduct research to
develop practical standards for such access restrictions - such as the
height and construction of fences - but those controls should be adapted
to each site based upon consultation with the local community.

D. Educate site neighbors, including children, about the serious risk
associated with contact with UXO. Most reported UXO-related injuries
involve deliberate disturbance of UXO, including its transportation
off-site. This risk can be reduced dramatically through education, but
many communities may be unwilling to cooperate if they think education
is being pursued as a substitute for clearance.

STEP 5. Structure site records and models to allow for continuous
feedback. Any reported encounter with UXO should not only be integrated
into the site's digital map, but if unanticipated it should trigger a
review of the risk management strategy.

-- 


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


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