The FUDS process is a three-part program including:
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 Archives Search Report (ASR) and develops a preliminary Risk Assessment Code (RAC) score. The Former Five Points OLF has a RAC score of 1, the highest level. As an eligible site under the FUDS program, the risk presented by remaining MEC on privately owned properties within the Former Five Points OLF now can be addressed.
The Former Five Points OLF site is currently in the "Investigation phase". In order to characterize the risks associated with a FUDS, an Engineering Evaluation/Cost Analysis (RI/FS) will be conducted. The primary objectives of the RI/FS are to:
- compile existing information and data;
- collect additional data as necessary;
- identify and assess potential hazards;
- propose and evaluate response actions; and
- identify respective costs for each response action.
The purpose of the RI/FS is to evaluate potential risk from any ordnance that may remain on the site from military activities and develop alternative actions to reduce those risks. The investigation relies on evaluation of archival data, and information gathered during the Technical Project Planning (TPP) Process. This archival information will be utilized to prepare a qualitative Munitions and Explosives of Concern (MEC) hazard assessment (MEC HA).
The RI/FS Report will include recommended Response Action(s), based on identified potential hazards at the site, and analysis of the viability and cost-effectiveness of various available responses. The range of possible response actions includes those listed below.
1) No Department of Defense Action Indicated (NDAI)
This no-action alternative is included to provide a baseline comparison with other risk reduction alternatives. A declaration of NDAI would indicate that remedy will not be necessary to further reduce the potential safety risks posed by MEC. No risk reduction measure(s) resulting in increased public awareness or in the removal of subsurface MEC would be implemented. The NDAI alternative is appropriate for sites where no MEC has been found or where there is no evidence that ordnance was used. However, NDAI indicates that the FUDS program will review any new information regarding DoD activities if and when it becomes available. If munitions are discovered in the future, USACE will reconsider the status of the property.
2) Land Use Controls (LUCs) with 5-year reviews
LUCs protect property owners and the public from hazards present at a site by warning of the MEC hazard and/or limiting the access or use of a site. This alternative would include LUCs using institutional controls designed to increase public awareness, consisting of an informational kiosk at the Bowman Branch Linear Park, informational pamphlets informing residents and visitors to the area, and current and future land owners that the property was previously used as a bombing range and UXO was previously removed, but that residual MEC may be present. Also, under this alternative every five years the Army Corps of Engineers would re-evaluate the remedy effectiveness and determine if any modification to the remedy is necessary.
3) Subsurface Recovery with Surface Removal, LUCs and Five-Year Reviews
This alternative involves all activities necessary to fully locate, excavate and remove MEC to a depth conducive to the expected land use, public access and overall health and safety of the affected community. Activities may potentially include vegetation clearance as necessary to conduct geophysical surveys, completion of geophysical investigations, excavation of anomalies and destruction of UXO. This alternative includes surface clearance over the areas selected for this alternative, and excavation and clearance in impacted areas.
This alternative is only being considered for selection as a remedy for properties at the Five Points OLF where these subsurface removals had not been performed previously, and that have been determined to contain a residual MEC hazard in the Remedial Investigation.
This alternative also includes LUCs of the types described above, for the purpose of increasing public awareness of the potential hazards, as well as a 5-year review process that will monitor the effectiveness of the remedy.
4) Subsurface Removals
This alternative involves all activities necessary to fully locate, excavate and remove MEC to a depth conducive to the expected land use, public access and overall health and safety of the affected community. Activities may potentially include vegetation clearance as necessary to conduct geophysical surveys, completion of geophysical investigations, 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.
5) No Department of Defense Action Indicated (NDAI)
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 NDAI alternative is appropriate for sites where no MEC has been found, where there is no documented evidence of MEC 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.
The final element of the FUDS process is the Response Action, in which response alternatives recommended in the RI/FS document are implemented.
Upon completion of the response alternatives, recurring reviews will periodically occur, as the DoD continues to maintain responsibility for the site. The purpose of the reviews are to ensure the effectiveness of the implemented 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.