|From:||Lenny Siegel <LSiegel@cpeo.org>|
|Date:||Fri, 19 Aug 2011 11:03:44 -0700 (PDT)|
|Subject:||Re: [CPEO-MEF] Defense Department memo establishes "response complete" milestones|
The new Defense Environment Restoration Program memo on "response
complete" goals is a significant step forward. The previous set of
goals, which allowed installations to meet their requirements simply
by putting remedies in place, appears to have encouraged satisfaction
with long-term extractive remedies such as pump-and-treat, known in
Defensespeak as Remedial Action-Operation.
A site could be deemed successful even if large quantities of contamination remained in the groundwater, because pumps were in place and operating. The remedy-in-place goal doesn't necessarily achieve remedial objectives, and it can lead to long-term monetary and energy costs, as well as unnecessary greenhouse gas emissions and the wasting of large quantities of water.
The response complete milestone, on the other hand, should stimulate efforts to optimize remedial operations or even to switch to more innovative, efficient, sustainable technologies. Many military installations use such technologies, but some have appeared unwilling to reconsider a regulator-approved remedial decision, even if operations are expected to continue indefinitely.
But for some sites, such as large, recalcitrant chlorinated solvent plumes in groundwater, the 2018 and 2021 dates may be too early or even counterproductive. For example, the new milestones won't accomplish anything if they are met by relaxing remedial objectives. It's quite likely, however, that most large, recalcitrant chlorinated solvent plumes will end up in the 5% or 10% of sites that don't meet the metric.
For those sites, there is a need for an alternative metric that encourages the adoption of better, faster cleanup technologies and strategies without imposing unrealistic deadlines. There should be a mandate to implement such approaches soon, with the expectation that it still may take decades to complete the responses.
Finally, it is fully understandable that the memo does not create a milestone for cleaning up former munitions ranges (MMRP at FUDS). It is more important to define better the former munitions range footprint than to rush the completion of responses that should, at current funding rates, take decades.
Lenny Siegel On Aug 19, 2011, at 10:06 AM, Lenny Siegel wrote:
On July 18, 2011 the Defense Department issued a memorandum establishing new internal goals for the Defense Environmental Restoration Program (DERP). See http://www.denix.osd.mil/mmrp/ upload/Goals-Memo-Final-Signed.pdf.The goals apply to all sites at active installations, but only to Installation Restoration Program (IRP) sites - that is, not to Military Munitions Response Program (MMRP) sites - at Formerly Used Defense Sites (FUDS). There is no mention of Base Realignment and Closure sites.Before this memo, DERP goals were based upon EITHER the achievement of "remedy in place" or "response complete" (RC). The Defense components are approaching those existing goals, sometimes by installing extractive systems that are expected to operate for many years. A majority of existing response complete sites, however, were relatively minor sites that leap-frogged directly to response complete without the selection and implementation of a remedy. Remember, under the DERP accounting system, there are generally many "sites" on a single active installation.The two new goals are:"90% of IRP and MMRP sites at active installations, and IRP sites at FUDS properties will achieve RC by the end of Fiscal Year (FY) 2018.""95% of IRP and MMRP sites at active installations, and IRP sites at FUDS properties will achieve RC by the end of FY2021."The memo includes a definition of response complete:"The RC milestone signifies that the Department of Defense (DoD) has met the remedial action objectives for a site, documented the determination, and sought regulatory agreement. RC signifies that DoD has 1) determined at the end of the Preliminary Assessment/Site Inspection, or Remedial Investigation that no additional response action is required, 2) achieved Remedy-in-Place (RIP) and the required Remedial Action Operations (RA-O) has achieved the remedial action objectives, or 3) where there is no RA-O phase, then the Remedial Action Construction (RA-C) has achieved the remedial action objectives. Long-term management may occur after RC is achieved."It continues:"DoD achieves RC when no contaminants pose a threat to human health and the environment for the current land use. DoD may establish land use restrictions and conduct long-term periodic reviews, monitoring, and maintenance at a site once it has achieved RC. These activities may last either for a specified period or indefinitely to ensure protection of human health and the environment."-- 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 <firstname.lastname@example.org> http://www.cpeo.org _______________________________________________ Military mailing list Military@lists.cpeo.org http://lists.cpeo.org/listinfo.cgi/military-cpeo.org
-- 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 <email@example.com> http://www.cpeo.org _______________________________________________ Military mailing list Military@lists.cpeo.org http://lists.cpeo.org/listinfo.cgi/military-cpeo.org
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