By James FrisingerDecember 21, 2016
FORT WORTH, Texas -- Thousands of military properties nationwide, many dating to World War I and II, are no longer the property of the Department of Defense. They were transferred to cities and states or to private owners after being declared surplus. But some of these properties still had life-safety hazards from their use in training, gunnery practice and testing new weapons.
The Formerly Used Defense Sites (FUDS) Program emerged in the 1980s when concern grew about the debris and contamination left on sites transferred out of DOD's control, according to Suzanne Beauchamp, the FUDS account manager for the Army Corps of Engineers Regional Planning and Environmental Center (RPEC) in the Fort Worth District.
In 1986, Congress created the Defense Environmental Restoration Program (DERP). FUDS is authorized under DERP, and DOD gave the Army Corps the lead to execute the program for all former military properties that incurred contamination issues prior to 1986, Beauchamp said.
Cleaning up these sites -- and monitoring the residual risk until they are free of hazardous contamination -- are the mission of separate FUDS teams across the country. In addition, the RPEC FUDS team was asked to run a pilot to prepare for the national rollout of a new notification and safety education element of the program.
Over the decades, lands from more than 7,000 former military facilities nationwide were dispersed to a wide range of new uses, among them homes, cropland, ranches, city-owned and state-owned parks, according to DOD Environmental Programs Chief Chris Evans at Corps of Engineers Headquarters. Some are still Federal lands managed by the U.S. Forest Service or the U.S. Fish and Wildlife Service.
After taking a careful inventory, the FUDS teams determined that many sites had no chemical or munitions contamination issues. For the rest, the DOD made a commitment to clean them up. At the end of the day, Evans said, the Corps of Engineers mission is to ensure that the properties will be safe for their intended use, he said.
The RPEC FUDS team manages the inventory of 602 sites within the Southwestern Division military boundaries (Oklahoma, Louisiana, Texas and Arkansas). Those sites include 267 chemical contamination sites and 308 munitions sites. The team has met the remedial action objectives, or what is known as "response complete," on 253, or 94.7 percent, of the chemical sites and 126, or 40.9 percent, of the munitions sites, according to Beauchamp.
The DOD goal for the chemical sites is to achieve response complete on 90 percent of the sites by 2018, and 95 percent by 2021. Southwestern Division has already met the 2018 goal and should meet the 2021 goal by the end of next year, Beauchamp said.
The DOD also set an interim risk management goal for the FUDS program to notify landowners, at least once every five years, that they live on formerly used defense sites and provide guidance to them on what they should do if they find munitions on their property.
Interim risk management for FUDS -- also called the Public Notification and Safety Education Initiative -- monitors the long queue of sites awaiting cleanup nationwide. It ensures that new owners, for instance, are aware that risks remain. The RPEC team launched the pilot to test notification procedures in March 2015. The notification procedures were then rolled out by FUDS teams nationwide.
The new notification and safety education effort, implemented with Corps contractor Bristol Environmental Remediation Services, follows a set protocol:
-- Communications assessments are reviewed, media interest is calculated, and safety sheets are prepared for each site.
-- Congressional offices are notified in advance of each annual mass mailing to FUDS landowners.
-- State environmental regulators are advised (in Texas, for example, the regulating authority is the Texas Commission on Environmental Quality).
-- Letters are sent property owners to educate them on what actions to take to reduce the risks from remaining hazards.
-- Local first responders are forewarned in case the letters trigger calls from people reporting suspicious objects.
To date, 1,072 letters have gone out to landowners just within Southwestern Division military boundaries. One landowner who received a letter responded to make sure it wasn't a scam designed to reduce the price of the property in a future sale, but on the whole the letters but elicited little response.
"We thought there might be a big outcry. Instead, it was radio silence," Beauchamp said.
Every year, a fifth of FUDS owners will be notified, with the last round of letters scheduled to go out in 2019. Then the five-year notification cycle will repeat until the last of the FUDS are cleaned up.
By now thousands of landholders have been notified nationwide, but the number of calls to a national FUDS telephone number have yet to reach 200, Evans said.
Some responses have been proven useful, Beauchamp explained. Among them was a call from an owner who wasn't concerned about the munitions. The owner drew on an extensive knowledge of the site's history to provided a lot of helpful information.
A couple of corporations along the Houston Ship Channel also responded to request a copy of the site inspection report to determine whether they needed to institute any safety procedures to cover future digs.
"That's what we want with interim risk management," Beauchamp said. "'There might be something there, take appropriate precautions if you are working in this area.' -- I was pleased with that."
As of today, 1,852 sites are still awaiting cleanup, Evans said. In 2016, the RPEC FUDS team anticipates 15 decision documents, which should position the team to execute $11 million of remedial activities, provided the funding is available, said Beauchamp.
Ultimately, the program will ramp down when the last site is certified response complete, Evans said. This vision of "response complete in our lifetime" was the focus of a recent national FUDS conference in San Antonio, Texas.
"We're really trying to double down, to refocus, to make sure we are making good decisions day-to-day to see how we can get those sites cleaned up and get those to Response Complete," Evans said.
"We want this generation of Corps employees to see the end. That's quite a reach for us. This is an exciting time to be working on the FUDS program."
HOW FUDS PROGRAM RANKS CLEANUP ACTIONS
It will cost about $14 billion to clean up the rest of the sites, according to an estimate issued by the FUDS Program at Corps Headquarters. Since funding is only about $250 million a year, the overall effort could take decades.
To contend with the backlog, the DOD has adopted a long-term strategy to execute the cleanup. Each site was ranked for the level of risk.
-- For munitions contamination, the Munitions Response Site Prioritization Protocol (MRSPP) assigns risk from 1 (the highest) down to 8 (hardly any risk at all).
-- For hazardous waste contamination, the Installation Restoration Program is used, with risk categorized as high, medium or low.
The vast majority of sites are contaminated with munitions, not chemicals, Beauchamp said.
By 2012, site inspections were performed on all known sites. Inspections revealed that many were never used as munitions sites as planned, Beauchamp said. Others were used, but inspectors were unable to find anything. On these sites, there didn't seem to be anything to clean up.
Often the inspectors found debris but nothing explosive. These lands required a more thorough look -- a remedial investigation -- probing deeper into the soil, expanded grid sampling and examining any anomalies, Beauchamp explained.
Is it munitions debris, inspectors would ask themselves -- or something as harmless as horseshoes?
After assigning risk under MRSPP, the team must then decide if the site needs to be cleaned up, how to do it, and the method for confirming it has been cleaned, Beauchamp said. When a cleanup is warranted, a feasibility study must be performed and public comment sought. At the end, a decision document is prepared, which includes anticipated costs of any cleanup.
Cleanup priorities are evaluated in cooperation with environmental regulators in each state. This guidance helps the FUDS team write collaborative work plans.
"We want to make sure we address the sites with the highest potential for risk before ones that are low in risk," Beauchamp said.
Final work plans are forwarded to the Army and the DOD to select the next sites to be cleaned up.
"Regulators understand we only have so much money and that it may be 20 years before I get back to a site to go with remediation," she said. "Interim Risk Management is our effort to address that concern."