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US Army CorpsUS Army Corpsof Engineersof Engineers
One Corps Serving The Army and The Nation
FUDS
MMRP Site Inspections at FUDS –Challenges, Status, and Lessons
Learned
MMRP Site Inspections at FUDS –Challenges, Status, and Lessons
Learned
June 20, 2007Denver, CO
2
US Army CorpsUS Army Corpsof Engineersof Engineers
One Corps Serving The Army and The Nation
FUDS
FUDS Program Overview
FUDS FUDS Program Overview Program Overview
• Formerly Used Defense SitesFUDS are properties that were formerly owned, leased, possessed by, or otherwise under the jurisdiction of the DoD or military prior to 1986
• GoalReduce risk to human health and the environment through implementation of effective, legally compliant, and cost effective response actions
• Customer– Property owners and communities affected by
these sites• Engineer Regulation 200-3-1 (ER 200-3-1)
– www.usace.army.mil/usace-docs/eng-regs/er200-3-1/entire.pdf
3
US Army CorpsUS Army Corpsof Engineersof Engineers
One Corps Serving The Army and The Nation
FUDS
• Congress established the Formerly Used Defense Sites (FUDS) Program in 1986
• US Army Corps of Engineers manages FUDS Program for Department of Defense (DoD)
• Local geographic Corps districts manage FUDS within their boundaries
Formerly Used Defense Sites(FUDS)
Formerly Used Defense SitesFormerly Used Defense Sites(FUDS)(FUDS)
4
US Army CorpsUS Army Corpsof Engineersof Engineers
One Corps Serving The Army and The Nation
FUDS
Scope of FUDS ProgramScope of FUDS Program
NH 11
MA 112
CT 22RI 42
NJ 44
DC 27
DE 11MD 43
OK55
TX217
AR14
LA22
NC 39TN 24
AL27
MS35
GA45
SC31
FL170
NV40 UT
19
CA482 AZ
102NM143
WA69
MT19
ND4
SD33WY
22
WI25ID
18
MN20
OR29
IA13NE
55CO30 KS
72MO27
ME63
VT 6
NY91
PA68
WV10 VA
41
IN17
OH32
IL64
KY 5
MI66
HI68
AK130
•Northern Mariana Islands 19•Palau (PT) 0•Puerto Rico (PR) 25•U.S. Virgin Islands (VI) 6•American Samoa (AS) 8•Guam (GM) 16
Total Number of Properties Requiring Response Actions: 2,965Data: FY04 DERP Annual Report to Congress
5
US Army CorpsUS Army Corpsof Engineersof Engineers
One Corps Serving The Army and The Nation
FUDS
Scope of FUDS ProgramScope of FUDS Program(Data Source: 2006 Report To Congress)(Data Source: 2006 Report To Congress)
• Properties:• Total in Inventory 9,908• Eligible for FUDS Program 6,868• No DoD Action Indicated (NDAI) 3,824• Requiring Response Actions 3,044
• Projects:• Total in Properties Requiring Response Actions 4,653• No DoD Action Indicated (NDAI) 799• Total with costs incurred or planned 4,229• Total with costs in FY06 & Beyond 3,333
• FY07 Cost To Complete (CTC) - $18.7B• MMRP $12,647M (1,364 projs)• HTRW $ 3,144M ( 837 projs)• OTHER $ 37M
• CON/HTRW $ 247M (900 projs)• BD/DR $ 50M ( 91 projs)• PGM MGT $ 2,628M
• FY07 Approved Workplan - $253.7M (CRA)
6
US Army CorpsUS Army Corpsof Engineersof Engineers
One Corps Serving The Army and The Nation
FUDSThe FUDS ProcessThe FUDS ProcessThe FUDS ProcessFUDS CERCLA (Superfund/NCP) Implementation Strategy
Preliminary Assessment (PA)Inventory Project Report and Archive Records Search
No DOD Action Indicated(NDAI)
Time Critical Removal Action (TCRA)- Action MemorandumNon-TIme Critical Removal Action - Engineering Evaluation/Cost Estimate
No DOD Action Indicated Time Critical Removal Action - Action MemorandumNon-TIme Critical Removal Action - Engineering Evaluation/Cost Estimate
No DOD Action Indicated Treatability Studies, Operate Pilot Scale Systems
Response Complete (RC)Cleanup objective as defined in ROD is done
Long Term Management (LTM)of site may be required for the response action
Five Year ReviewsDetermine if implemented response is still protective
Remedial Action (RA)Construction and Operation Phases
Remedial Design (RD)Detailed designs, plans, specifications for remedial action
requires an approved Explosive Safety Submission
Record of Decision (ROD)/Decision DocumentIdentifies the remedial alternative chossen, detailed assessment of RI/FS data
Proposed Plan (PP)Summarizes the propseed remedial alternative
Remedial Investigation/Feasibility Study (RI/FS)RI charcterizes site to develop a Conceptual Site Model (CSM)
FS uses the CSM to develop and evaluate alternatives for remedy selection
Site Inspection (SI)Identify sites for further or further action and chacterize release
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US Army CorpsUS Army Corpsof Engineersof Engineers
One Corps Serving The Army and The Nation
FUDSThe FUDS Process –
.zip file versionThe FUDS Process The FUDS Process ––
.zip file version.zip file version
1. Inventory Project Report – Preliminary
Assessment (INPR / PA)
2.2. Site Inspection (SI)Site Inspection (SI)
3. Remedial Investigation / Feasibility Study
(RI/FS)
4. Decision Document
5. Remedial Action
6. Site Management
Inventory Phase
Response Phase
Investigation Phase
8
US Army CorpsUS Army Corpsof Engineersof Engineers
One Corps Serving The Army and The Nation
FUDSIntroduction to the MMRP
Site InspectionsIntroduction to the MMRPIntroduction to the MMRP
Site InspectionsSite Inspections
• DoD established goal of completing all MMRP SIs by end of FY10 (Navy, Air Force, Army, and FUDS)
• USACE ER 200-3-1 requires Corps to use Remedial Process framework for MMRP and to work IAW with CERCLA/NCP
• FUDS Inventory of sites needing SI is based on the 2004 Annual Report to Congress
9
US Army CorpsUS Army Corpsof Engineersof Engineers
One Corps Serving The Army and The Nation
FUDSMMRP FUDS – SI PhaseMMRP FUDS MMRP FUDS –– SI PhaseSI Phase
• CERCLA Site Inspection Phase initiated FY05 • USACE anticipates SIs for approximately 1000
projects (765 completed by FY10)• Budget for SIs: $125M for FY05 - FY10• Conducted only on FUDS eligible projects • Address potential MEC and MC hazards• If separate HTRW concerns are observed
during SI, FUDS geographic District is notified
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US Army CorpsUS Army Corpsof Engineersof Engineers
One Corps Serving The Army and The Nation
FUDS
Program Objectives - The Performance Work
Statement
Program Objectives Program Objectives -- The The Performance Work Performance Work
StatementStatement
• Objective– “The objective of the MMRP SI is to determine
whether the individual project sites within the FUDS program warrants further response action or no Department of Defense action indicated (NDAI)”
• Regulatory Guidelines– CERCLA and NCP– Engineer Regulation 200-3-1 and DoD
Management Guidance for the Defense Environmental Response Program (DERP)
11
US Army CorpsUS Army Corpsof Engineersof Engineers
One Corps Serving The Army and The Nation
FUDSProgram Objectives –
ER 200-3-1Program Objectives Program Objectives ––
ER 200ER 200--33--11• Confirm presence of MEC or MC contamination identified in the
PA phase on ranges or other MMR areas identified in the ASR or range inventory efforts
• Collect appropriate information necessary to: i. Eliminate from further consideration those releases that pose no
significant threat to public health or the environmentii. Determine potential need for removal actioniii. Collect or develop additional data, appropriate for Hazard Ranking
System (HRS) scoring by EPA; and iv. Collect data, as appropriate, to characterize release for effective
and rapid initiation of remedial investigation and feasibility study (RI/FS)
• Secondary objective – Collect data to complete the Munitions Response Site Prioritization
Protocol (MRSPP)
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US Army CorpsUS Army Corpsof Engineersof Engineers
One Corps Serving The Army and The Nation
FUDSSI Project Delivery Team
MembersSI Project Delivery Team SI Project Delivery Team
MembersMembers
• Military Munitions Center of Expertise (MM CX)– Overall program management of the SIs and subject matter
expertise regarding MEC and MC• HTRW CX
– Subject matter expertise regarding MC• MM and Chemical Warfare Materiel (CWM) Design
Centers– SI execution, separated by US Army Installation
Management Agency (IMA) regions • FUDS Geographic Districts
– Conduct overall project management activities• Regulators and Stakeholders
– Provide input and help develop the Data Quality Objectives (DQO)
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US Army CorpsUS Army Corpsof Engineersof Engineers
One Corps Serving The Army and The Nation
FUDS
Design Center Execution Responsibilitiesvs. IMA Regions
Design Center Execution Design Center Execution ResponsibilitiesResponsibilitiesvs. IMA Regionsvs. IMA Regions
• HNC MM DC – Southeast and Pacific• NWO MM DC – Northwest• NAB MM DC – Northeast• SPD Range Support Center -Southwest
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US Army CorpsUS Army Corpsof Engineersof Engineers
One Corps Serving The Army and The Nation
FUDSSite Prioritization For
Completing SISite Prioritization For Site Prioritization For
Completing SICompleting SI
• FY05 sites prioritized based on MM CX request to Divisions– Requested a variety of MMRP projects (bombing
ranges, artillery ranges, OB/OD, small arms)– Requested projects needed to provide a wide
range of concerns (coastal ranges, desert ranges, heavily vegetated, with variety of terrains)
• FY08-FY10 sites being scheduled now based on District/Division/HQ/Regulator input
15
US Army CorpsUS Army Corpsof Engineersof Engineers
One Corps Serving The Army and The Nation
FUDSFUDS MMRP SI Current
StatusFUDS MMRP SI Current FUDS MMRP SI Current
StatusStatus
• Four Task Orders awarded 26 May 05• Execution is 18 months per project funded• Fixed-Price Performance Based Contract
– Four payment milestones
• All FUDS MMRP projects are identified in the Task Orders
• 328 projects have been awarded to date
16
US Army CorpsUS Army Corpsof Engineersof Engineers
One Corps Serving The Army and The Nation
FUDSChallengesChallengesChallenges
• Numerous property owners– A pride of lions, a covey of quail,
a business of ferrets; an entropyof property owners
• Volume and schedule– 765 FUDS SI’s
• Each SI comprised of 2 TPP workshops, 4 deliverables, field work
– Complete by 2010
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US Army CorpsUS Army Corpsof Engineersof Engineers
One Corps Serving The Army and The Nation
FUDSChallengesChallengesChallenges
18
US Army CorpsUS Army Corpsof Engineersof Engineers
One Corps Serving The Army and The Nation
FUDSLessons LearnedLessons LearnedLessons Learned
• Launching national initiative while program framework is still evolving– ‘You SI with the program you’ve got,
not the program you want’• Inconsistencies in FUDS program
– ER 200-3-1, May 2004– Property eligibility; project category
• Volume of deliverables– Straining resources at all levels– Incorporating ‘global’ changes
• Effective communications – Swift and thorough dissemination is
critical– EKO
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US Army CorpsUS Army Corpsof Engineersof Engineers
One Corps Serving The Army and The Nation
FUDSLessons Learned – cont’dLessons Learned Lessons Learned –– cont’dcont’d
• Performance Based Contract– One of largest PBCs– Control vs responsibility; culture
change• Rights of Entry
– Can never start too early– Simplified ROE form
• Programmatic tasks embedded in initial project schedules
• Public Involvement– Engage primary stakeholders
early
Corps
Stakeholders
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US Army CorpsUS Army Corpsof Engineersof Engineers
One Corps Serving The Army and The Nation
FUDSOrdnance SafetyOrdnance SafetyOrdnance Safety
• DO NOT TOUCH!DO NOT MOVE!
• Note/record location
• Call 911 or local law enforcement
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US Army CorpsUS Army Corpsof Engineersof Engineers
One Corps Serving The Army and The Nation
FUDSQuestions?Questions?Questions?
Betina Johnson – Huntsville MMRP CX(256) [email protected]
Dwayne Ford – Fort Worth District(817) [email protected]