Natural Attenuation (NA) -(A Modest Analysis)

[Sam Goodhope <Sam.Goodhope@OAG.STATE.TX.US>]

In reply to Ted Henry:

The analysis with respect to closing bases is much simpler:
 1) DoD funds LRA activities to develop economic redevelopment plans
for closing bases;
 2) Cleanup contractors (preferably linked w/ defense contractors that
used to build weapons or facilities) are hired and begin punching holes in
the ground;
 3) Based upon LRA redevelopment plans and after conferring with
local boosters, initial cleanup priorities are set;
 4) The cleanup contractor continues to punch more holes in the
ground and generates sufficient paperwork to ensure that the value of
the timber in the Headlands (California) continues to rise;
 5) After conferring w/ state and local regulators and taking into
account federal (i.e., DoD) risk assessment and risk management
guidelines, cleanup options (including the cost therefor) are developed
on paper;
 6) The RAB is swamped by the tsunami of paper, most of which is
incomprehensible to the average non-doctoral student of hydrogeology;
 7) State regulators bitch and moan about the quality of the paper, as
well as the preferred cleanup route already set by the BEC. However,
some feel that they don't moan too much for fear of losing DSMOA
money;
 8) DoD central takes more money out of the cleanup program after
focusing entirely on the "high" risk category. After all, why fund a
cleanup unless it really, really, really lowers a "risk"?
 9) More terrorists are discovered in other countries around the
world--more Cruise missiles are loosed;
 10) DoD central, looking for money to pay for the unexpected Cruise
launchings, transfers funds from the cleanup budget to the "Unforeseen
Anti-terrorist Activities and Miscellaneous Fund";
 11) The cleanup contractor continues to punch more holes....
 12) The BCT, after hearing from the BEC (who has heard from the BC
via the BEO), informs the LRA (and the RAB), that the EBS performed
prior to the FOST or FOSL (or, now, the FOSET) pursuant to CERFA (as it
amended CERCLA) overstated the nature and extent of the
contamination. What were previously "High risk" areas have been
transmogrified into "low risk" areas.
This is actually good news because now instead of waiting for years for
the contractors to finish punching holes into the ground and for DoD to
remove the bad stuff they put into the ground during the past 40 or so
years, the boosters can use the land immediately--if they are willing
(wink, wink, wink) to accept deeds w/ restrictive covenants (easily
ignored when one is consumed by visions of filthy lucre and Sugar Plum
fairies), capped and bermed landfills, and fenced off areas (a few
square feet out of every acre or so);
 13) The BEC uplinks the budget for next year's construction of fencing
(including the uplink for the out years) to the BEO, who sends it to the
BC, the BC is connected to the knee bone....yada, yada, yada...(Munsel,
Newsome, McCall)...Secretaries...Cohen...OMB...chop,
chop...Cohen....yada, yada, yada ...BEC ... yada... Cohen...
OMB...Congress....chop-chop...Cohen...., yada, yada, yada...BEC...report
to LRA about funding and the new studies from the National Academy of
Sciences that prove that natural attentuation is the only real way to
ensure a safe environment.
 14) Both Congress and the Administration claim credit for saving
billions of dollars over the next by pursuing a cleanup policy of
"Principled--But Closely Watched, Really--Natural Attenuation."
Furthermore, both Congress and the Administration claim credit for
funding and developing (in conjunction with local universities)
"Laboratories of BioOrganoMutative Adaptations" at each closing base
site.
 15) The local congressman and mayor at each closing base hold a
press conference: common theme-"It is critical to find out how we and
our local flora and fauna can adapt to what has heretofore been
characterized as "contamination." As we move into the 21st century, it
is important for our citizens and investors to realize that they can
peacefully coexist with hydrocarbons and those other things.
Remember, while God can make little green apples, he can't make little
DNAPLS. Only man can. And, by golly, only man--with the help of this
Laboratory we are dedicating today-- can develop solutions such as
natural attenuation and institutional controls to take care of DNAPLS and,
uh. whatever."