The FUDS process is a three-part program including:
Inventory
During the Inventory phase, potential sites are evaluated for eligibility to be addressed under the FUDS program. The Inventory phase evaluates information on the origin of the contamination, the history of land transfer, and past and current ownership. As part of the Inventory phase, the US Army Corps of Engineers conducts an Inventory Project Report – Preliminary Assessment (INPR/PA) to determine FUDS eligibility. As an eligible site under the FUDS program, the risk presented by remaining MEC on privately owned properties within the former Camp Fannin now can be addressed.
Investigation
The Camp Fannin site is currently in the "Investigation phase". In order to characterize the risks associated with a FUDS, a Remedial Investigation/Feasibility Study (RI/FS) will be conducted. The primary objectives of an RI/FS conducted under the Military Munitions Response Program, such as the Camp Fannin RI/FS, are to characterize the risk posed by the UXO, MEC and MC, and gather data necessary to select a response action which reduces risk to human health, safety, or the environment.
Data will be gathered to support the analysis and design of potential remedial alternatives by assessing the following factors:
- Physical characteristics of the property;
- Characteristics/classification of soil, sediment, air, surface water, and groundwater;
- Characteristics of the MEC and/or MC (e.g., quantities, concentration, toxicity);
- The extent to which the source can be characterized;
- Actual and potential exposure pathways through environmental media;
- Actual and potential exposure routes (e.g., inhalation and ingestion); and
- Other factors such as sensitive populations that pertain to the characterization of the site or support the analysis of potential remedial action alternatives.
Response
The RI/FS process will generate a Proposed Plan (PP) documenting the preferred alternative. The PP summarizes the process used to analyze the viability and cost-effectiveness of various response alternatives, and the steps leading up to the selection of the preferred alternative. A range of example munitions response actions are listed below.
No Further Action (NFA)
This no-action alternative is included to provide a baseline comparison with other risk reduction alternatives. No technology is associated with this alternative. No risk reduction measure(s) resulting in the treatment, containment, removal of or limited exposure to MEC will be implemented. Therefore, potential MEC will not be removed and no restriction will be placed on access to the site. The NFA alternative is appropriate for sites where no MEC has been found, where there is no documented evidence of military munitions (MM) usage, or where the nature and extent of the MEC occurrence (e.g., small arms ammunition) poses minimal threat to those who may encounter it.
Land Use Controls (LUCs)
Land Use Controls (LUCs) encompass both Engineering and Institutional remedies that restrict or minimize exposure of site visitors to hazards associated with MEC. Engineering Controls, as the name implies, involves the use of physical deterrents such as signage, fencing or guard posts to minimize or preclude exposure to MEC. Institutional Controls involve a combination of educational initiatives such as Explosives Safety Awareness Training and legal processes such as Deed Restrictions or restrictive covenants to reduce exposure to MEC. Institutional Controls rely on behavior modification and site access control strategies to eliminate or minimize risk. LUCs are possibly appropriate as a stand-alone option where risk to the public has been documented as low and can be managed without the removal of MEC.
For some projects, because of the remoteness of the site, relatively low site usage, or the potential types MEC items that may be present, the most practical and effective access control involves LUCs consisting of establishment of warning signs informing the public of potential MEC items and the threat associated with those items. Access-control alternatives, such as dedication of property to appropriate land uses, land-use restrictions, training or educating facility users/managers and fencing or barriers may be considered/evaluated as potential LUCs.
Surface Removal with LUCs
Surface Removal with LUCs involves utilizing UXO-Qualified technicians who are trained to recognize, handle and dispose of MEC, to perform a visual inspection of a site, and to remove MEC that is visible on the ground surface. The UXO-Qualified technicians will then ensure the proper disposal of the recovered material. This alternative is effective in minimizing the risk of incidental contact with MEC in areas where intrusive activities such as digging are not likely. In order to perform a visual survey, site preparation activities may be required in some areas including the removal of brush, shrubs and surface debris. The investigation is usually conducted using a magnetometer.
Subsurface Removal with LUCs
Subsurface Removal with LUCs involves all activities necessary to fully locate, excavate and remove MEC to a depth based on the expected land use and the depth of the MEC. Activities may potentially include vegetation clearance as necessary to conduct geophysical surveys, completion of geophysical investigations, and excavation of anomalies and destruction of MEC. Technologies that may be used for this alternative include magnetic and/or electromagnetic geophysical investigative methods and management/disposal of MEC (including detonation of UXO). This alternative includes surface clearance over the entire site and excavation and clearance in impacted areas. The effort associated with implementing this alternative will vary, depending upon topography, vegetation and site access.
Long-Term Monitoring (LTM)
Long-Term Monitoring (LTM) involves observation of site conditions and testing environmental media over an extended time period, in order to document those conditions over time. LTM may involve sending a sampling team periodically to collect samples of soil, sediment, surface water or groundwater, and ship them overnight to a fixed-laboratory. A newer and less costly approach involves on-site and field portable analytical technologies, that have been recognized by state and federal regulatory agencies overseeing the FUDS projects. Some of these technologies include Immunoassay, test kits, laser-induced fluorescence, and fiber optic chemical sensors.
Recurring Review
Recurring reviews will periodically take place at pre-determined intervals after implementation of the preferred response alternative(s), as the DoD continues to maintain responsibility for the site. The purpose of the reviews is to document the effectiveness of the implemented munitions response actions in reducing the risk of encountering MEC. The Recurring Review Team will be familiar with the previous actions conducted on-site, as well as current and proposed land uses.
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