No Further Action at Former Defense Sites

[Lenny Siegel <lsiegel@cpeo.org>]

No Further Action at Former Defense Sites

The Department of Defense counts over 9,000 "formerly used defense
sites*" (FUDS), military installations that were closed and transferred
out of military hands prior to the 1988 base closure law. The Army Corps
of Engineers has systematically screened those properties for toxic,
radioactive, and explosive contamination, and its has found that a
majority of those facilities require no further action (NOFA). That is,
they are legally clean.

Since they still came up with a few thousand potentially dirty
properties, I never questioned the Corps' conclusions. But state
environmental regulators, whose figurative noses are much closer to the
dirt than mine, are not convinced. The Association of State and
Territorial Solid Waste Management Organizations (ASTSWMO) survey its
members, and 39 states responded. Over half of those responding
"indicated that they had reason to believe that the Army Corps of
Engineers has not made sound environmental decisions regarding NOFA
determinations at FUDS.... Even more unsettling is that nearly 80% of
the respondents indicated that they have not and may not be able to
conduct their own independent assessments of these sites due to lack of
resources."

ASTSWMO reported that six states - Alaska, California, Colorado,
Montana, Rhode Island, and Washington - have assessed some of the FUDS
within their boundaries. Of the 66 FUDS declared requiring no further
action by the Army Corps, the states found that 32 actually required
further action. Contamination at those sites "included high levels of
PCB, unexploded ordnance, leaking underground storage tanks, asbestos,
high levels of TCE, and groundwater contamination."

California reviewed 48 of those 66 FUDS, finding 21 requiring further
action, including the Mojave Airport, the Madera Bombing Range, Alcatraz
Island, and the Santa Rosa Federal Center, location of the Uakima Indian
School. The state also flagged a number of target areas that it said
were given NOFA determinations "based on no records available." The
Madera Bombing Range, for example, covers 3,840 acres, and "has both
agricultural and residential usage and has many private landowners."

Respondents to the ASTSWMO survey concluded, "the system for classifying
FUDS as NOFAs needs to be re-examined. At a minimum, [Army Corps of
Engineers] staff should be required to consult with State agencies prior
to formalizing a NOFA determination at formerly used defense sites."

As I see it, the problem with FUDS does not lie with the Army Corps, but
with political inattention. The FUDS program geared up after the
characterization of active and closing bases, and it has never been
fully funded based upon risk. While FUDS may not be more contaminated
than active or closing bases, many pose more of a risk to human health
and safety because the military does not and cannot control the use of
or access to the land.

*In general, the Defense Department uses the term "sites" to denote a
known or suspected contamination area within a facility, but it calls
entire former facilities "formerly used defense sites."

-- 


Lenny Siegel
Director, Center for Public Environmental Oversight
c/o PSC, 222B View St., Mountain View, CA 94041
Voice: 650/961-8918 or 650/969-1545
Fax: 650/968-1126
lsiegel@cpeo.org
http://www.cpeo.org