Re: No Further Action at Former Defense Sites

[Christine Shirley <cshirley@econet.org>]

> The state also flagged a number of target areas that it said
> were given NOFA determinations "based on no records available." 

This is indeed a problem.  Here's one reason why:  The Corps of Engineers uses
what they call a "risk assessment code (RAC) score sheet to determine whether
FUDS require further action from an ordnance and explosives perspective. The
higher the RAC score, the higher the cleanup priority.  When I looked
carefully at this score sheet I realized that "no information" equates to "No
Further Action" because scores are only given for the types of ordnance likely
to be found at a site as determined by "best available information."  If no
information is located about a site with respect to ordnance and explosives
then it is classified as "No Further Action" necessary.  In other words, the
RAC scoresheet assumes no information equals no risk.  Of course this
assumption does not hold in real life. 

I think we ought to rally the Corps of Engineers to modify their RAC score
sheet such that "no information found" in the files about the types of
ordnance and explosives used at a FUDS site _triggers a site visit_ with
ordnance detection equipment, and a report to local or state environmental
regulators.   

The most current RAC score sheet may be found on the web at:
http://w2.hnd.usace.army.mil/oew/policy/IntGuidRegs/9802.pdf

I urge anyone with interest to study the score sheet and offer their own
assessment. I'm willing to coordinate a community response for presentation
to the Army Corps -- just send me your ideas!