Dear Mr. Siegel,
Thank you for this
thoughtful evaluation. The question “When Is Enough, Enough” arises
at many sites because the technologies selected, approved and installed can not
meet the cleanup goal for the site. Often, the technologies selected and
installed to remediate source areas and plumes are
inadequate and need to be re-evaluated sooner rather than later. For example,
there are many sites where there is fierce resistance to open up the Record of
Decision (ROD) and replace pump-and-treat with innovative technologies that effectively
treat the source area and plume. At other sites, dig-and-haul, or dig-and-treat,
or capping are selected to remediate soils rather than more effective in-situ
treatment technologies. How can we achieve groundwater security when we have
capped contaminated soil (source area in vadose zone) sitting above the ground water?
Is the water table static or dynamic?
The phrase “contaminant
degradation” ought to be given greater weight when evaluating technologies
selected for cleanup of degradable contaminants.
There are many effective
innovative technologies mature enough for use in cleanup of solvents, munitions
constituents, petrochemicals, etc. Unfortunately, ineffective solutions (technologies)
continue to gain favor over innovative and sustainable solutions. Therefore,
the tax payer who is footing the bill must continue to ask the question “When
is Enough, Enough.” Cleanup contracts are often not dynamic documents,
thus an ineffective solution may remain in place for a long time.
Respectfully,
Valentine Nzengung,
PhD (President & CEO)
PLANTECO Environmental
Consultants, LLC http://www.planteco.com
8(a) HubZone Certified,
SDB
337
South Milledge Avenue, Suite 202
Athens, Georgia
30605, USA
Telephone: (706)
316-3525 Fax: (706) 353-9270 Mobile: (706) 202-4296
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-----Original Message-----
From: military-bounces@lists.cpeo.org [mailto:military-bounces@lists.cpeo.org] On
Behalf Of Lenny Siegel
Sent: Tuesday, July 08, 2008 2:43 PM
To: Military Environmental Forum
Subject: [CPEO-MEF] VOCs: When Is Enough, Enough?
When Is Enough, Enough?
Community Perspectives on Groundwater Treatment at Department of
Defense
Facilities
Lenny Siegel
Center for Public Environmental Oversight
July, 2008
Summary
Groundwater treatment systems are in place and operating at hundreds of
Department of Defense facilities, controlling plumes, removing
contaminant mass, and destroying contaminants of concern such as
chlorinated solvents and petroleum products. A large number of these
systems are conventional groundwater extraction technologies, known
colloquially as "pump and treat," but an increasing number of
sites
employ innovative technologies such as biotreatment, in situ chemical
oxidation, and permeable reactive barriers. As cleanup programs mature,
the key question is no longer what the initial remedy should be.
Rather,
the Defense components responsible for cleanup, regulatory agencies,
and
the public are discussing how long these systems should remain in
operation - that is, "When is enough, enough?"
To help answer that question, Lenny Siegel, Executive Director of the
Center for Public Environmental Oversight (CPEO) evaluated community
perspectives on the cleanup of trichloroethylene (TCE) plumes at the
closed Twin Cities Army Ammunition Plant (TCAAP) in Minnesota (New
Brighton and Arden Hills)
and former Moffett Naval Air Station in the
San Francisco Bay Area (Mountain View
and Sunnyvale).
Specifically,
Siegel reviewed the decision to shut down treatment at TCAAP's Operable
Unit 3 (OU3) - the South Plume emanating from the former arsenal
- and
the debate over future treatment at Moffett Field's Site 26, the
Eastside aquifer. Trichloroethylene is the principal contaminant at
both
sites, and at both facilities there are larger plumes that normally
attract more public attention, as well as ongoing challenges over
installation reuse.
Both TCAAP and Moffett have strong, mature cleanup programs, overseen
by
both state and federal regulatory agencies. Both installations are on
the "Superfund" National Priorities List. Both have active
community
involvement programs, including Restoration Advisory Boards (RABs) that
meet regularly. Both communities bring their own expertise to the
table.
As a member of the community adjacent to Moffett Field, I have been
involved in the oversight of its environmental program for nearly two
decades. This puts me in the unusual position to reporting on the views
of a community that I have played a role in shaping.
...
To download the 8-page 2.4 MB report, go to
http://www.cpeo.org/pubs/Enough.pdf
--
Lenny Siegel
Executive Director, Center for Public Environmental Oversight
a project of the Pacific
Studies Center
278-A Hope St.,
Mountain View, CA
94041
Voice: 650/961-8918 or 650/969-1545
Fax: 650/961-8918
<lsiegel@cpeo.org>
http://www.cpeo.org
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