Helping Our Peninsula's Environment

Fort Ord Burn Plan (RI/FS) Comments by Bill Mitchell (former EPA Division Chief)

March 25, 2002

I am a Technical Advisor to the Monterey Bay Toxics Project (MBTP). The MBTP asked me to review and provide comments on the merits of the Aproposed Plan - IA for Vegetation Clearance, Ordnance Explosive Remedial Action and Ordnance and Explosive Detonation, Ranges 43-48, Range 30A and Site OE-16 (IA PLAN), dated March 8, 2002.

As part of my review, I also examined the following five documents which are cited in the IA PLAN: (1) Final Interim Action Ordnance and Explosive Remedial Investigation/Feasibility Study (RI/FS); (2) Draft Final Interim Action Ordnance and Explosive Remedial Investigation/Feasibility Study (DRAFT RI/FS); (3) Final Ordnance Detonation Sampling and Analysis Plan, Former Fort Ord (DETONATION SAMPLING PLAN); (4) Technical Memorandum, Air Emissions From Incidental Ordnance Detonation During A Prescribed Burn on Ranges 43 - 48, Former Fort Ord (AIR SAMPLING PLAN); and (5) Final Fort Ord Ordnance Detection and Discrimination Study (ODDS) .

In addition, I also reviewed an August 24, 2001 report entitled A HEALTH CONSULTATION- Former Fort Ord Site, Marina, Monterey County, California (ATDSR REPORT). This report was prepared by the Agency for Toxic Substances and Disease Registry (ATDSR) of the Public Health Service (PHS) of the U.S. Department of Health and Human Services. The ATDSR report was prepared at the request of the Monterey Health Department for ATDSR to evaluate the spatial distribution and the impact that the emissions from a 1999 vegetation burn at Former Fort Ord had on the areas downwind of Former Fort Ord and to make recommendations concerning assessing the health impact of future prescribed burns at Former Fort Ord.

As you know, the IA PLAN recommends the prescribed burn/soil-covered detonation option as the preferred method for the UXO remediation effort of the ranges covered in the IA PLAN. Since the ATDSR report dealt specifically with this subject and since the Army received a copy of the report more than 5 months ago, I was surprised to find that it was not referenced in either the RI/FS issued on March 7, 2002 or in the IA PLAN issued on March 8, 2002. I was also surprised to find that none of the Army's documents mentioned the 1999 vegetation burn at Former Fort Ord or that an attempt had been made to collect samples from the plume .

Since this is the first time that I have submitted comments to you regarding the remediation of Former Fort Ord, I thought it would be helpful if I preceded my comments with a brief summary of my qualifications for commenting on these documents. So, here it is.

I retired from the Office of Research and Development of the U.S. Environmental Protection Agency (EPA) in July 2001 and established an environmental consulting business, Bill Mitchell and Associates, LLC. We specialize in issues associated with assessing and mitigating the impact that emissions from ordnance (conventional and chemical) and landmine disposal activities have on human health and the environment. During my 30 years at the EPA, I conducted basic and applied research in the following areas: characterizing and controlling the emissions from the disposal of materials containing explosives; developing and field testing pollutant and meteorological measurement systems for characterizing the air pollutant emissions from area sources and from 25 types of stationary sources; improving air pollutant dispersion models; developing QA/QC reference materials; and auditing and appraising the performance of environmental measurement programs on the national and international levels. I have approximately 115 publications and presentations, 31 of them deal with the emissions from detonating and burning explosives and ordnance items.

The Army's rational for selecting the prescribed burn approach as the preferred option seems to be based on the following line of reasoning. 

1. We have to remove this dangerous UXO which is hidden by vegetation.
2. The Central Maritime Chaparral community that predominate on the Ranges at former Fort Ord depend on fire for propagation, so a prescribed burn is the best way to uncover the UXO hidden in the vegetation.
3. We believe can conduct a prescribed burn in such a manner as to prevent wildfires and to fully protect human health and the environment.
4. The burn plume will not contain harmful concentrations of any of the toxic materials that might be released by the burning vegetation or by incidentally-detonated UXO.
5. Before we let people return to the area, we will (somehow) collect representative samples from the burn plume to confirm that the emissions were indeed harmless.
6. It will be very, very dangerous to move 90 to 95% of the UXO we expect to recover at or near the surface.
7. The Donovan Detonation Chamber will not be able to get beyond the access gates of any of the ranges, due to the 18 inch axle clearance of the trailer on which it is mounted.. Therefore, we cannot use it to destroy the 90 to 95% of the UXO that we will not be able to move safely.
8. So, we will have to BIP some of the UXO and pile up and detonate the remaining UXO with engineering controls. The concentrations of potentially toxic materials released by these detonations will be below harmful levels. But, to be safe we will (somehow) use ground-based samplers to collect representative samples from the detonation plumes.

Detailed comments on the IA PLAN and the other documents are presented below. To assist you in responding to them, I have placed them in the same numerical order as the ten "assumptions" above. However, before I move on to this detailed comments, I wanted to provide the Army with this general assessment of the documents I reviewed.

Basically, I was very disappointed by the shallowness of the analyses underlying the IA PLAN and the supporting documents. I found them to be biased, inconsistent, incomplete and sometimes technically flawed. It was obvious to me that the information contained in these six documents had been carefully selected and interpreted so as to produce the conclusion that the only acceptable and safe approach for remediating these ranges would be a prescribed burn followed by detonating the UXO either where found (BIP) or in a pile covered with soil, foam, sand bags, etc.

I was particularly disappointed by the inadequacies, biases and overall poor technical quality of the FINAL RI/FS report. The objective in conducting an environmental RI/FS is to evaluate the methods available for addressing the environmental situation under consideration in a manner which is as fully protective as possible of Human Health and the Environment. In my opinion, the Former Fort Ord RI/FS study was not the independent, arms length, reasonably thorough and balanced assessment that was required to address the complex issues associated with the remediation of Former Fort Ord.

For example, the FINAL RI/FS (and also the IA PLAN) defer to a later time any decision on how the Army will obtain representative samples from the vegetation and UXO detonation plumes and how it will get the vegetation plume samples analyzed and interpreted so as to allow people to return to the area shortly after the burn. It could easily take the weeks to get the samples analyzed and interpreted, and even then there might be questions regarding the toxicity of the emissions, including the long range toxicity of the ash deposited on surfaces by the plume. If people have to stay out of their homes and schools for three weeks, wouldn't that be a very negative impact on them rather than the minimal impact that the Army assumes in the FINAL RI/FS.

Here's a second example of the incompleteness of the FINAL RI/FS. The report notes that on the average there were 3,000 seedling per acre (identity not given) growing in areas that had been burned but only 29 seedlings per acre in the areas that had been cleared cut. But there is no data presented in either the FINAL RI/FS or by citation to show that the situations being compared are even slightly similar.

The fact that the Final Fort Ord Ordnance Detection and Discrimination Study report(ODDS) issued in January 2002 did not even mention the highly successful, third generation, helicopter-mounted aerial UXO detection system field proven by the Oak Ridge National Laboratories (POC: Dr. David Bell, 865-574-2855) is another example of the incompleteness of the supporting documentation underlying the IA PLAN. It seems to me that this system would be very applicable to addressing the UXO issues at Former Fort Ord. It has already demonstrated that it could reliably detect all or almost all of the hazardous UXO in and under the vegetation at Former Fort Ord and Dr. Bell is continually improving its capabilities.

Here's an example of the biases present in the FINAL RI/FS. Both the DRAFT RI/FS and the FINAL RI/FS note that the trailer on which the Donovan Detonation Chamber is transported will not be able to negotiate the roads on Former Fort Ord. Here are some problems associated with this assessment. The DRAFT RI/FS issued in October 2001contains an assessment of the applicability of the detonation chamber to the Former Fort Ord situation and the cost to operate it. However, the Army did not even ask the supplier of the detonation chamber to provide a quote until December 2001. This quote, which is not referenced in any of the Army documents, contained the following claim by the supplier "the detonation chamber is capable of traveling over most, if not all, of the ranges". Since this statement directly conflicts with the Army's conclusion, why was the supplier of the detonation chamber not contacted to resolve the conflict before the FINAL RI/FS was issued in March 2002?

Page 1 of the IA PLAN notes that the history of trespassing incidents (and the Army's inability to stop them) is the primary reason why the IA is needed. However, based on the information presented in the Army documents I reviewed, I did not get a sense that the areas being considered for the IA represented the type of imminent hazard to public health or safety that would justify an IA which involved a prescribed burn or massive defoliation of the ranges.

For example, the closest inhabited area to Range 30A lies 2,200 feet from it and the closest inhabited area to Ranges 43 - 48 lies 4,000 feet away. In addition, there have been no instances of trespass on either Range 30A or Site OE-16 (which is only protected from trespass by a temporary fence and warning signs posted every 500 feet). The nearest any trespassers have come to Range 30A was a trespass event which occurred 8,000 feet from Range 30A. In the last three years, there have only been five trespass events on Ranges 43 - 48, which covers 483 acres. Further the UXO on the ranges is completely hidden by vegetation Finally, page 7 of the DETONATION SAMPLING PLAN notes that the Army expects to find approximately 5 UXO per acre (one UXO item per 8,600 square feet) at or near the surface on these ranges.

To me, these "facts" from the Army's own documents show that the ranges currently present very little risk to the human health and the environment and that the access restriction in place are working well. Am I missing something? . Where is the high risk that is the basis for wanting to do an IA now?

It seems to me that simply increasing the surveillance of the site until a viable technology for detecting the surface UXO (such as the Oak Ridge National Laboratories' helicopter-based UXO detection system currently completing field validation) are available would adequately address the risks associated with these ranges.

Gosh, right now the Army is using computer-controlled aircraft flying at 65,000 feet to identify and track (even at night) the movements of individuals hiding in the mountains of Afghanistan. Surely, the Army could come up with a system that could effectively monitor the ranges of Former Fort Ord during daylight hours. (Who would trespass at night?)

So, if the OE (ordnance and explosives, hereafter called UXO) don't represent an imminent danger, is there a need for the IA on these ranges?

The Army claims that the UXO is lying under the vegetation and that the UXO is so dangerous that anyone who tried to remove the vegetation by mechanical or manual cutting would be in great danger from exploding ordnance. But, the Army presents no credible data to support this assumption? This lack of data seems unusual since these types of clearance techniques have apparently been used since 1994 to remove vegetation at Former Fort Ord and they have also been used extensively worldwide to remove vegetation covering UXO similar to that found on the Former Fort Ord ranges.

For the following reasons, I do not believe that the Army has a clue as to the number or the hazardousness of the UXO on these ranges.

First, almost all of the UXO sampling done to date has been conducted behind the firing points and along the roads and boundaries of the ranges (p.19, FINAL RI/FS). These are not areas where the highest quantities of UXO would be expected to be found! Second, the Army has surveyed only one small portion of one target area on one range (the rifle grenade range) to determine the number and type of UXO present (p.45, FINAL RI/FS). Third, the Army's experience in range clearance at other facilities, such as the Massachusetts Military Reservation where they have already found thousands of UXO after assuring the public that there were likely only a few hundred.

Fourth, while trying to find reasons to explain why the Donovan Detonation Chamber would not suitable for use at Former Fort Ord, the Army came up with the following assessment (p.53, FINAL RI/FS) concerning the results from a recent Time Critical (Surface UXO) Removal Action (TCRA) conducted on Ranges 44-45. "Our EOD experts believe that more than 95% of the UXO found will be too dangerous to move." However, when I examined the actual results from the TCRA (Table 2 of the FINAL RI/FS), I found that more than 70 % of the 2,457 UXO items uncovered during the TCRA were 35 mm target practice rockets B items which the IA PLAN states would be transported off-site for destruction in a popping furnace. Also, the Army asserted that only 10 % of the UXO expected to be found on Range 30A would be suitable for transportation, but elsewhere in the FINAL RI/FS the Army states that Range 30A has not been sampled in any meaningful way.

Although I am not an expert in ordnance, it seemed apparent to me that a good portion of the other items found during this TCRA and during other UXO surveys conducted at Former Fort Ord could be transported safely in a properly equipped vehicle. To confirm this, I prepared the attached summary table for the 2,940 UXO items listed in Tables 2, 3 and 4 of the FINAL RI/FS. I then asked two, Army-trained EOD experts (both of whom had been stationed at Former Fort Ord) to tell me how many of the items in the table could be transported in a properly-equipped vehicle. Both experts opined that approximately 85% of the UXO items in the table could normally be transported safely in a properly-equipped vehicle (e.g., a dump truck whose bed was lined with sand and sand bags). Both also volunteered that, if it could be moved by hand for placement in a pile for detonation, it could also be destroyed in the detonation chamber. They agreed that the only UXO items that could never be moved are those equipped with impact inertia fuses, point initiating base detonating fuses and mechanical timers.

NOTE: I am not claiming that every one of the remaining 2,500 UXO items could be moved. Rather, I am just pointing out that the Army cannot arbitrarily claim that 90 to 95% of the UXO items likely to be found at Former Fort Ord would be to dangerous to move. Some basis for this statement, hopefully derived from actual Former Fort Ord data is needed.

As I noted earlier, I believe that the information presented in the FINAL RI/FS was carefully selected so as to lead to the conclusion that the prescribed burn approach was the most natural, environmentally friendly and safe approach for clearing the vegetation from the ranges. Because of the "selective nature" of the data presented in the Army documents, I could not determine the validity of this conclusion. However, I am comfortable in stating that the arguments advanced to support the selection of the prescribe burn approach are inadequate and very incomplete.

The Army's case rests on the assumption that fire is the predominant herbaceous plants and shrubs found at Former Fort Ord are dependent on fire for their propagation, so employing mechanical and manual clearance techniques will interfere with this natural method of propagation and promote weed invasion (p.40, FINAL RI/FS). But, the only Former Fort Ord-related data advanced to support the regrowth-by-fire dependency assumption is this statement in the FINAL RI/FS: "on the average, there were 3,000 seedlings per acre (1 per 14 sq. ft.) after burns at Former Fort Ord but only 29 seedlings per acre after the mechanical clearance/windrow burns."

Is this a valid statistical comparison? Are we comparing apples to apples or is it apples to prunes? To show that similar situations are being compared, the Army needs to provide the following kinds of information: (1) the identities, density and maturity of the vegetation groups being compared; (2) the acreage and the number of sample grids surveyed; (3) the method used to count the seedlings; (4) the statistical distribution of the seedling counts (3,000 and 29 could be statistically equivalent numbers under some conditions); (5) the time between each burn/clearance and the seedling count; (6) the identity and expertise of the people who counted the seedlings; (7) the seasons in which each burn and mechanical clearance activity was conducted; and (8) the number of times each grid has was sampled and the duration of time between these resamplings.

In addition, the Army should provide independently generated information to show that the 1 seedling per 14 sq. ft. is what would have been expected had the vegetation been burned naturally. What are the normal temperatures expected/required to achieve effective germination of the seeds? Could the dense vegetation burn so hot as to destroy the seeds' ability to germinate? The AIR SAMPLING PLAN mentions that the temperatures across the burn will range from 285 to 700 degrees Centigrade.

One final point, the Army documents show that there are fairly large groups of manzanita and chapperral on the ranges which are less than five years old. Training activities ceased at least eight years ago at Former Fort Ord and these young stands of vegetation do not seem to be in areas where the Army conducted prescribed burns. So, it would be helpful if the Army would provide old reports which show that these young stands of vegetation actually are in places which were burned within the last six years. Otherwise, one has to assume that the vegetation at Former Fort Ord can use something other than fire to reproduce.

. Based on its experiences with prescribed burns conducted on Fort Ord in 1994, 1995, 1997 and 1998, the Army claims that it will be able to control the acreage burned and conduct the prescribed burn in a manner which is fully protective of human health and the environment. But little actual data from previous burns at Former Fort Ord are presented in either the IA PLAN or in the associated documentation to support this assumption. Also, as I noted in the General Comments, none of the Army documents mention the 1999 burn which was the subject of the ATDSR report. Why?

I am sure that after each burn, the Army collected the following types of information: (1) degree to which each burn was controlled; (2) the duration of each burn and the burn plume compared to what was expected; (3) the degree of completeness achieved for each burn (CARB wants the Army to assume that 15% of the vegetation will not burn completely); (4) the number of re-burns required; and (5) the degree to which the plume behavior conformed to the model prediction concerning shape, direction ,width, height duration, etc.

It is also highly likely that the Army has the following types of health-related data for each burn: (1) the number of instances of skin and respiratory illnesses reported in the 48-hour period after the burn was initiated compared to the 48-hours period before the burn was initiated; (2) the number of hospital admissions and deaths for these types of illnesses for the same time periods; (3) the amount of sooty materials found on and in residences impacted by each plume; and (4) the "toxicity" of the ash regarding inducing skin lesions, rashes, etc.

Since the Army has conducted at least six burns at former Fort Ord, the lack of any data is surprising Were these data not provided because they did not support the Army's case or, were they just never collected or compiled?

The information contained in the AIR SAMPLING PLAN is the primary source for the Army's conclusion that the materials released into the plume by UXO incidentally detonated during a prescribed burn at Former Fort Ord would not adversely effect human health or the environment. This conclusion is based on the following sources of data: (1) an EPA emissions factor database for OBOD developed in 1998; (2) the ISCST3 air pollution dispersion model; and (3) some "unsubstantiated, best guesstimates" from anonymous Army experts concerning the number and type of UXO that might detonate during a prescribed burn on the ranges involved in the IA. The Army also claims that it will be able to collect and analyze "representative" samples of the burn plume to ensure that human health and the environment are protected.

For the following reasons, I do not believe that the Army has proven that it can either collect representative plume samples or that the plume contents will not adversely impact human health or the environment. If the Army can refute each of the following statements or provide the data that is missing, I would be willing to reconsider my opinion.

First, as I showed under Assumption 2, the Army doesn't seem to know with any confidence the number and type of UXO present on the ranges nor their condition. There are also a large number of inter-related parameters that will determine which UXO's will likely explode in a fire. So, its meaningless to guess how many of each type might detonate during the fire without having a grasp of these parameters.

Second, the BangBox OBOD emissions factor database (which I developed for EPA in 1998) applies only to high order detonations and propellant burns (deflagration, not a combustion process). It does not apply to situations where ordnance items explosively rupture (due to thermally-induced decomposition of a high explosives) and spit chunks of energetic materials out. This latter type of detonation will be (at best) a low order detonation in which only a small portion of the explosive will be converted to the small, harmless molecules produced by a high order detonation.

Thermally-induced, low order detonations of the types of explosives found in most of the UXO at Former Fort Ord (RDX, TNT, HMX, Octol, and Composition B) will most likely produce large quantities of benzene, toluene, nitrogen oxides, and a host of nitroaromatic and nitramine compounds, including undestroyed energetic materials.

In a high order detonation, more than 99.9999% of the explosive is usually fully destroyed. In contrast, a low order detonation produces emissions of the parent energetics 100 to possibly 10,000 times higher than the high order detonation. The low order detonation also produces a much larger quantity of the energetic materials' daughter compounds. In addition, the subsequent Aburning' of the parent and daughter compounds will be a dirty, combustion process and not the deflagration process that occurs in a high order open burn situation.

How "unhealthy" could the emissions be? I truly don't know. It would be detonation-specific. Some of the myriad of parameters that will effect the quantity of the "truly hazardous" materials released are: the surface area of the UXO heated, the temperature differential across the UXO item, the rate of heating, the thickness of the UXO's casing, and the mass and composition of the UXO.

However, I think that the light-weight, sooty, black fluffy particulate material produced by the burning energetic materials and the burning vegetation will serve as perfect hosts to transport the undestroyed or partially destroyed energetic materials a great distance from the burn site before depositing it onto surfaces. This contaminated particulate could be a very toxic material in itself and be a short and long term hazard to those conducting the UXO remediation after the burn and those living on the Monterey peninsula

Third, although the AIR SAMPLING PLAN discussed the possibility that toxic metals in the vegetation could be released during the burn, it did not present data on the metals content of the vegetation on the ranges being considered for the IA or data showing that the metal content of the plants is fairly homogeneously distributed across Former Fort Ord. In addition, the Army does not seemed to have considered the possibility that energetics and related materials in the vegetation might also be released to the environment when the vegetation is burned. It is well known and well documented that many plants can assimilate TNT, RDX, HMX and other nitrogen-containing materials from the soil. Some plants only store these compounds in their cellular structures, but others use enzymatic-based reduction processes to extract the nitrogen from the energetic compounds. How much energetic and daughter compounds could be present in the vegetation on Former Fort Ord? I don't know. As was the case for the incidentally-detonated UXO, there are many factors which determine how much energetic is assimilated by a plant.

Fourth, the ISCST3 Model estimates may not apply to the vegetation burn scenario, because of the assumptions used and the high uncertainties in selecting appropriate burn rates, emission rates, and the rate of plume rise. (A discussion on how these and other parameters can affect the accuracy of the model's predictions can be found in the ATDSR REPORT).

The Army's modeling runs assumed there were 10 point sources (fires) burning at any one time spread over 90 acres. It also assumed that the temperature of the burning vegetation and the burn rate were the same for each point source. But, elsewhere in the AIR SAMPLING PLAN (and, also in the FINAL RI/FS), the Army states that the vegetation is not homogeneously distributed over the ranges by species, maturity, density and a host of other factors which will affect the burn temperature, pollutant emission rate and burn rate. In fact, on page 8 of the FINAL RI/FS the Army states that the burn temperature for low to moderately dense chaparral vegetation is approximately 285 degrees Centigrade whereas the burn temperature for dense chaparral is 700 degrees Centigrade.

The Army model runs also assumed a constant wind direction existed across the 8-hour burn period. However, the ATDSR REPORT, which used actual data from the Monterey airport, shows that during an 8-hour daylight period the wind direction changed more than 90 degrees on two consecutive days (Figures 1 and 2 in the report). Also, page 39 of the AIR SAMPLING PLAN states that smoke for two days during the burn and residual smoke from burning vegetation may remain in the air for several days thereafter and there is no mention of the land sea breeze which is a normal daily event on the Monterey peninsula.

It seems apparent to me that the Army modeling runs were not realistic.

Fifth, I have been told that there are clusters of poison oak plants present on the ranges being considered for the prescribed burn. But, there is no mention in any of the Army-prepared documents about this. The emissions from burning poison oak can be highly toxic to sensitive individuals. If these plants are in fact present, it should have been discussed somewhere.

The Army stated that it plans to collect (specific details not given) samples from the plume to ensure that the emissions are harmless before they allow people to return to their homes. But, the Army also noted that it expects to complete the entire prescribed burn in eight hours or less. Even if the Army could collect samples which would provide an adequate, even semi-accurate characterization of the toxicity of the materials released (doubtful), the results could not be available until weeks later under the best conditions. Also, the Army does not seem to have actual data on the toxicity of the plume or the ash which will be deposited over a wide area. This is critical deficiency in the health risk assessment, particularly with respect to the schools and playgrounds in the area and with respect to the risk involved in working in the burned areas. The ATDSR report mentioned that some samples were collected from the plume during the 1999 burn. Were these or any other plume samples analyzed for toxicity?

This validity of this assumption was addressed in my comments regarding Assumptions 1 and 2.

The biases, inconsistencies and distortions in regards to the Donovan Detonation Chamber's suitability for use at Former Fort Ord are very unsettling. It is very obvious that the Army did not seriously consider any option except blow-in-place and pile and detonate the UXO. As noted earlier, the Army did not even request a cost estimate from the supplier of the detonation chamber until December 2001.

Other examples of the Army's biases against using the chamber can be seen from an examination of the assumptions the Army used to determine that the Donovan detonation chamber was not a viable option for destroying the UXO. First, as was pointed out earlier, there is the assumption that the roads at Former Fort Ord are so hilly that the 18-inch axle clearance of the trailer (on which the detonation chamber is mounted) would prevent it from getting beyond any of the access gates. What were the qualifications off the Army individuals who decide this? Are they certified tractor trailer truck drivers? Have they inspected the trailer on which the detonation chamber is mounted? Did they ask the vendor for his opinion? Did they consider that roads can be leveled and new roads can be cut very easily. (In fact, based on the aerial maps in the FINAL RI/FS, the existing roads provide access to the ranges from several sides and there are roads leading to each Target Area on the ranges. These roads look wide enough to handle the detonation chamber.)

Second, the Army claims in the FINAL RI/FS that the detonation chamber cannot be used to destroy UXO larger in diameter than an 81mm mortar (p.65, FINAL RI/FS). The reader is left with the erroneous impression that items larger than the 81-mm mortar cannot be destroyed in the detonation chamber. As the Army is fully aware, the detonation capacity of the chamber is limited by the total NEW (net explosive weight of the UXO items and the donor charge) and not by the dimensions of the munition. In actuality, the NEW of one 81mm mortar (2.2 lbs) is 25 to 80 % greater than that of any of the other UXO items likely to be found at Former Fort Ord (Table 5 of the AIR SAMPLING PLAN) and, as the Army states on page 52 of the FINAL RI/FS, TWO, 81mm mortars can be detonated in the chamber at the same time.

Third, in the opinion of the Army's EOD experts, only 5 to 10% of the UXO likely to be found on Ranges 43-48 and only 10% of the UXO expected to be found on Range 30A and Site OE-16 could be safely transported the great distances between where it was found and the access gate. As discussed in regards to Assumption 2, this statement is not supported by any credible data.

This assumption is based on the BangBox emissions factor database I developed in 1998. But, as I noted in that EPA report and in my comments above regarding Assumption 5, the emission factors in this database only apply to open (air) detonation events. Further, the materials detonated in the BangBox studies were homogeneous, so their application to the destruction of non-homogeneous mixes of deteriorated UXO items under a soil cover is questionable. In this latter type of detonation, fireball formation is impaired, so the emissions of benzene and toluene and other potentially toxic compounds can be as much as 1,000 times higher than the equivalent weight open detonation. (See Mitchell, W. J. et. al, "Improving the Environmental Safety of Munitions Disposal by OB and OD". Proceedings of the Fifth Global Demilitarization Symposium and Exhibition, Reno, NV, May 1997).

This DETONATION SAMPLING PLAN states that the Army would use ground-based samplers and modeling to collect samples of the plumes released when the UXO are detonated during the remediation efforts that follow the burn. There is little detail given either in this document or in the FINAL RI/FS or in the IA PLAN. In fact, the FINAL RI/FS mentions that the details and approach to be used would be determined at a later time. This is not acceptable. The sampling equipment needed to collect a representative sample from these plumes doesn't exist as far as I know and no one to my knowledge has been able to collect defendable, representative samples from detonation plumes using ground based samplers for the potentially toxic emissions.

Since the Army doesn't know how much UXO actually lies on these ranges nor how it is distributed, etc., I find it hard to believe that they will be able to complete the removal of surface and near surface UXO in a year. Where is the performance data on which this assumption is based?

I did not bother to conduct an in-depth evaluation of the Cost Estimates in the IA PLAN and the supporting documents. These estimates are not credible in my mind because of the incompleteness and biases present in the documents.

Based on the information presented in the documents and other readily available information left out of them, I would conclude that the prescribed burn approach is the one that is least likely to be protective of human health and the environment in the short and long term.

It seems to me that simply increasing the surveillance of the site until a viable technology for detecting the surface UXO (such as the Oak Ridge National Laboratories' helicopter-based UXO detection systems currently completing field validation) are available would adequately address the risks associated with these ranges. (For the record, I was very disappointed, but not surprised to find the ORNL system was not even mentioned in the Final Fort Ord Ordnance Detection and Discrimination Study report issued in January 2002.

Since this system is probably developed enough to detect at least the larger UXO items the larger UXO items lying either on the surface or in the vegetation on the Former Fort Ord ranges, I would like to recommend that the Army invite the Oak Ridge National Laboratories (ORNL) staff to visit Former Fort Ord to see if their system can be used to determine where the UXO are located on the ranges. The point of contact at ORNL is Dr. David Bell (865-574-2855). The survey might just show that only small areas on the ranges need to be remediated at this time. (Possibly, some of the taller vegetation will need to be trimmed to four feet or so and several passes from different directions will be needed.)

I hope the information provided above has been helpful to you. If you have questions, please contact me via phone (919-544-3457), e-mail ([email protected]) or in writing at the address below.

Sincerely,

Bill Mitchell, President

Bill Mitchell and Associates, LLC

5621 Pelham Rd

Durham, NC 27713

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Fuze type

Type UXO

Total Number of UXO

% Of Total

Can be Moved

Time Relay

Hand Grenade

5

0.1%

YES

None

Rocket, 35 mm Practice; Pyrotechnic mixtures and flares

1793

61%

YES

Point Initiating, Base Detonating

Rocket, 66 mm HEAT; Projectile, 81 mm M43, M37, HEAT; Projectile, 84 mm HEAT; Projectile, 90 mm HEAT

300

10.2%

NO

Impact

Rocket, 66 mm Incendiary; Projectile, 44mm; Projectile, 22 mm subcal; Projectile, 22 mm TP

43

1.5%

YES

Impact Inertia

Projectile, 40 mm target practice

116

3.9%

NO

Powder train

Projectile, 40 mm smoke; Grenade Fuze

508

17.2%

YES

Point Detonating

Projectile, 37 mm M63; Projectile, 60mm HE; Projectile, Projectile, 81 mm TP

98

3.3%

YES

Mechanical Timer

Projectile, 60mm HE

9

0.3%

NO

Base Detonating

Projectile, 57 mm HE/HEAT; Rocket, 2.36 and 3.5 inch TP; Rocket, 2.36 inch AT

66

2.2%

YES