|From:||Lenny Siegel <firstname.lastname@example.org>|
|Date:||Mon, 11 Dec 2000 11:23:49 -0800 (PST)|
|Subject:||[CPEO-MEF] UXO Response Steps|
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 email@example.com 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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