policy memorandum from the Air Force (Yonkers, 2011) regarding the new milestone of accelerated site completion does not appear to clarify or simplify military remediation requirements.

An example of the array of challenges faced by the DoD is provided by the Anniston Army Depot, where groundwater is contaminated with chlorinated solvents (as much as 27 million pounds of TCE [ATSDR, 2008]) and inorganic compounds. TCE and other contaminants are thought to be migrating vertically and horizontally from the source areas, affecting groundwater downgradient of the base including the potable water supply to the City of Anniston, Alabama. The interim Record of Decision called for a groundwater extraction and treatment system, which has resulted in the removal of TCE in extracted water to levels below drinking water standards. Because the treatment system is not significantly reducing the extent or mobility of the groundwater contaminants in the subsurface, the current interim remedy is considered “not protective.” Therefore, additional efforts have been made to remove greater quantities of TCE from the subsurface, and no end is in sight. Modeling studies suggest that the time to reach the TCE MCL in the groundwater beneath the source areas ranges from 1,200 to 10,000 years, and that partial source removal will shorten those times to 830–7,900 years (Tetra Tech, 2011). Although Anniston is a strong candidate for a TI wavier, DoD officials have struggled to convince regulators of the need for alternative remedial objectives (at this and other complex military sites).

In part, the delays and transaction costs experienced at complex sites have led to the use of alternative contracting mechanisms for site remediation within the DoD, including performance-based contracting. In some cases, this has involved requesting guaranteed fixed-price proposals to achieve certain milestones within specified schedule deadlines. The intent of these contracting procedures is to accelerate remediation and reduce the overall life-cycle costs (Army, 2010). Anecdotal stories suggest that this process has indeed accelerated transition of sites to the status of remedy in place, but not to site closure.

It appears that future liabilities for the DoD are unknown because of the uncertain time frames to achieve remedial action objectives at the more complex sites. It is probable that these sites will require significantly longer remediation times than mandated, and thus, continued financial demands for monitoring, maintenance, and reporting. In addition, the tension between remedial strategies involving long-term containment compared to contaminant removal from the subsurface will likely continue, with a lack of efficient protocols that could potentially reduce overall life-cycle costs. Finally, consistent with DoD goals of achieving a greater level of environmental sustainability in all environmental programs (DoD, 2009), increased



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