It started in 1981 in Holbrook, Mass., with neighborhood kids romping over pastureland to play undisturbed by the by cars and other distractions. Occasionally, kids threw handfuls of “moon glob” at each other, never connecting its existence to the nearby Baird-McGuire Plant, which manufactured herbicides and pesticides, floor wax and soap.
In 1982 the U.S. Environmental Protection Agency made the clean-up of Baird McGuire the one of its top priorities.
Who did they call? The U.S. Army Corps of Engineers’ Omaha District and its Environmental Branch, which took the “Superfund” assignment, hit the ground running, and more than 30 years later is renowned for its comprehensive expertise and clean up capabilities relative to hazardous, toxic and radioactive waste sites.
The EPA was given administrative responsibility for Superfund sites, and put the Omaha District in charge of design and construction in 27 states. Soon after, the District began work for the Defense Environmental Restoration Program that included Department of Defense Commands such as the Strategic Air Command, Tactical Air Command and Systems Command, their active installations, and Formerly Used Defense Sites – a key focus of the district.
“Yes, it’s been thirty years and we’re still chugging,” said Bob Dworkin, former Omaha District FUDS Program Manager, current rehired annuitant and expert on the FUDS program.
The FUDS Program concentrated on solidifying the inventory of former defense sites for which the Department of Defense has the responsibility to address environmental concerns. The scope and magnitude of the program are significant, with more than 10,000 properties identified for potential inclusion in the program. Information about the origin and extent of contamination, land transfer issues, past and present property ownership, and program policies must be evaluated before DoD considers a property eligible for Defense Environment Restoration Account funding under the FUDS program.
Environmental cleanup at FUDS properties is conducted in accordance with the Comprehensive Environmental Response, Compensation and Liability Act. The FUDS program is divided into three major categories: Installation Restoration, which cleans up HTRW contamination normally in soil and/or groundwater and Containerized HTRW, such as underground storage tanks, drums, and transformers; and Military Munitions Response, which cleans up Munitions of Explosive Concern and Munitions Constituents. The third major category is Building Demolition and Debris Removal, which is the demolition and removal of unsafe buildings and structures at FUDS properties.
In the FUDS Program’s early years, hundreds of building demolition and debris removal projects were completed nationwide, a majority in Alaska. Hundreds of underground storage tank removals were also completed, mostly through a single contract for a number of sites.
"The FUDS Program has been effective in ensuring that imminent threats caused by past DoD activities are addressed in a way to minimize risk to the public. Everyone who is involved makes a conscientious and sincere effort to protect stakeholders in those cases where DoD is responsible under the FUDS Program," said Dworkin.
The FUDS Program is growing in the military munitions response arena. Safety, public awareness, development, and property values all play a part in driving this growth. Interim risk management is just the beginning for many more years of growth.
In three decades, the program has evolved in many ways. FUDS policies evolved to follow the Comprehensive Environmental Response, Compensation and Liability Act of 1980, the Federal law designed to clean up sites contaminated with hazardous substances, pollutants, and contaminants. The FUDS Program has seen great progress in one of its main project categories, HTRW cleanup, which is seeing the light at the end of the tunnel. HTRW projects involve many contaminants of concern. One of the predominant recurring contaminants is trichloroethylene, or TCE, which was found in solvents used by DoD for cleaning purposes, and has been known to cause cancer and liver damage.
“What the public needs to know is the FUDS Program concentrates on ensuring its funding is spent only on environmental remediation for which the DOD is responsible. The FUDS Program is committed to ensuring the ‘polluter pays’ principle is strictly followed whenever possible,” said Dworkin.
The FUDS Program has had changes too. The program has placed increased emphasis on the thousands of properties where the main FUDS-related environmental issue is military munitions. Recently, the properties with munitions issues were prioritized in accordance with a law-driven prioritization process.
An Interim Risk Management initiative now puts safeguards in place for properties that cannot be actively addressed through the FUDS Program due to funding limitations. The Omaha District recently awarded a nationwide contract for the first round of IRM.
“As always, we face challenges,” said Dworkin. “Landowners, developers and other stakeholders are concerned about property values and addressing properties in a timely manner. Due to funding constraints, that doesn’t always happen.”
The FUDS Program does not have adequate funding to address every property immediately. Many projects are programmed to begin in the future. The IRM initiative is geared to address interim measures now instead of waiting until cleanup begins.
In addition to the IRM initiative, the Omaha District has accomplished considerable progress over the last 5 years to award FUDS Program contracts using a performance based concept with Multiple Award Task Order Contracts to accelerate remedial efforts. The District currently manages 10 projects that will enable the FUDS Program to obtain property closeouts in the next four to eight years in the states of Nebraska, Colorado and Wyoming.