Challenge
Over the last 200 years, the U.S. Department of Defense (DoD) has used various locations across the nation to train military personnel and evaluate new weaponry to maintain the country's military preparedness. As requirements for training and testing evolved, the DoD either acquired land or relinquished it to private or public purposes.
Today, the DoD is tasked with cleaning up properties previously owned, leased, or controlled by the U.S. and under the authority of the Secretary of Defense before October 1986—sites known as Formerly Used Defense Sites (FUDS). The U.S. Army spearheads the FUDS program, executed by the U.S. Army Corps of Engineers (USACE) on behalf of both the Army and DoD and executed in accordance with the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) and the National Oil and Hazardous Substances Pollution Contingency Plan (NCP).
The first step in the cleanup process is to conduct a thorough analysis of the timeline of each land parcel’s ownership and usage. However, the location and verification of records from decades, and even centuries, ago posed a major obstacle for the project. While many of the properties were acquired as part of the effort to support World War II, some date back to the early 1800s and lack modern record keeping data. To assist with the property timeline analysis, USACE contracted Management Solutions, LLC (MSLLC) to conduct Findings and Determination of Eligibility (FDE) for 137 properties over 36 months. Once conducted, an FDE establishes whether a property is eligible for inclusion in the Defense Environmental Restoration Program FUDS program.
Approach & Impact
MSLLC is the first contractor to be awarded a task order for preparing FDEs on a large scale; the project spans eight geographic USACE Districts across the U.S., including Alaska. Under aggressive project timelines to complete the FDE process for all 137 properties, MSLLC assembled a team of researchers, including its in-house archeologist, to obtain and review records from a variety of sources, such as the National Archives, local area historians, researchers, and numerous state and local governmental agencies.
The MSLLC team works closely with local resources, historical societies, local universities, archaeologists, and historians who provide valuable information that allows the team to identify and fill in the historical data gaps. Currently, the team is on track to complete all 137 FDEs by the end of 2024. The next step in the FUDS process is to complete an Inventory Project Report (INPR) for each eligible property to determine that the individual areas are eligible for the FUDS program. Once the INPR is complete, the individual areas, or sites, advance through the CERCLA process.
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