KDHE Home - Division of Environment - Bureau of Env. Remediation - Assessment and Restoration
 

	Program Staff  Introduction  Defense - State Memorandum of Agreement (DSMOA)  Formerly Used Defense Sites (FUDS)  Management Action Plan (MAP) for FUDS  Management Assistance Cooperative Agreement (MACA) Sunflower Army Ammunition Plant Identified Sites List Links
Jorge Jacobs, Unit Manager 1000 SW Jackson, Suite 410 Topeka, KS 66612-1367 Phone: (785) 296-8801 FAX: (785) 296-4823 Click here for a map to KDHE

Program Staff

[Top of Page]

Introduction

The Superfund Unit at the Kansas Department of Health and Environment (KDHE) works with the US Environmental Protection Agency (EPA) and the US Army Corps of Engineers (USACE) to investigate and clean up a variety of sites, including active and former military properties, Superfund sites, and other commercial sites. Three inter-agency agreements were created to facilitate these partnerships:  the Defense-State Memorandum of Agreement (DSMOA) with USACE; the Formerly Used Defense Site (FUDS) grant from EPA; and the Management Assistance Cooperative Agreement (MACA) with EPA.

Please refer to the Links section at the end of the page for further information on the terms used here.

[Top of Page] |

Defense-State Memorandum of Agreement (DSMOA)

The Superfund Unit provides state oversight of assessment and corrective action of environmental contamination at U.S. Department of Defense (DoD) and federal facility sites through the Defense/State Memorandum of Agreement (DSMOA).  The DSMOA Program is funded by Department of Defense grants.  Staff within the Superfund Unit work closely with project managers and scientists at federal agencies, primarily USACE and EPA. The Superfund Unit provides technical expertise and field oversight for federal environmental investigations and cleanups, and communicates state priorities and regulatory positions to the federal agencies.

Sites covered by the DSMOA in Kansas include a wide variety of active and former military facilities, such as:

• Air Force bases
• Army bases
• Army ammunition plants
• Nuclear missile silos
• World War II-era Army airfields and bombing ranges
• Anti-aircraft missile batteries

Investigation and remedial action performed at DSMOA sites follows the guidance of the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA) as amended by the Superfund Amendments and Reauthorization Act of 1986 (SARA).  This guidance is commonly called the Superfund Law.  Some active sites also have permits under the Resource Conservation and Recovery Act (RCRA) which requires investigation and remediation work to address environmental contamination.  USACE is responsible for investigating and cleaning up environmental contamination caused by military activities and facilities at Formerly Used Defense Sites (FUDS).  Army and Air Force bases commonly use USACE as their contracting agent for environmental work at their installations.

Once a site has been identified by USACE, EPA, or KDHE, a Preliminary Assessment (PA) is performed to investigate all records available for the site and determine if the site poses an environmental hazard.  If the PA finds potential hazards at the site, one or more phases of investigation are performed at the site, typically sampling soil, groundwater, and/or surface water for a variety of contaminants.  Once all contaminants are identified at a site, and their locations are determined, a plan is developed for cleaning up this contamination, and the site is cleaned up according to this plan.  Throughout all phases of investigation and cleanup, KDHE, EPA, and USACE work together to make sure all agencies are satisfied that all work is done properly and complies with all applicable regulations.  Comments from the public are also solicited at several points during this process, and information on the work is made available to the public.

Even though this process seems straightforward, it often takes many years to complete.  Many sites have complex sets of contaminants that are found in many areas and in several media (soil, groundwater, surface water, sediment), so planning and performing investigations at these sites is difficult and expensive.  Methods used to clean up the sites may take months or years, especially for groundwater contamination.  Finally, because of limited resources, the large number of sites on the DSMOA must be prioritized so that the sites posing the greatest hazards are cleaned up first.

	|
Abandoned propellant production buildings at former Army ammunition plant	Installing monitoring well at active Army base

[Top of Page] |

Formerly Used Defense Sites (FUDS)

The Superfund Unit also provides assessment and corrective action at Formerly Used Defense Sites (FUDS) through a grant from EPA. Staff within the Superfund Unit perform site assessments of FUDS and make recommendations to EPA and USACE when the need for more expansive site assessment and/or remediation at the sites is warranted.

FUDS are a subset of military facilities which are inactive and have been sold to private individuals or local government entities, and many FUDS are included in the DSMOA.  Some FUDS have been rebuilt or reused and turned into useful agricultural, commercial or residential properties:

• Former Army Airfields in Liberal, Independence, Garden City, Great Bend, and several other cities have been turned into Municipal Airports and industrial parks.
• Old practice bombing ranges are used as farmland or pasture land.
• Former missile sites have been used as residences, schools, industrial facilities, or farmland.

Because FUDS are no longer owned by the Government, USACE may be unable to secure a right-of-entry to these private properties in order to determine if any contamination caused by military activities at the site is still there.  In addition, FUDS may be assigned a low priority for funding by USACE, especially if little is known about the site.  In these cases, KDHE uses FUDS grant money from EPA to begin assessing these sites.

The process of investigating FUDS is the same as described above for military facilities on the DSMOA, but KDHE typically only performs the early phases of these investigations.  If a review of site records indicates a potential for contamination, KDHE will visit the site and collect samples of areas likely to confirm this.  All sample results are forwarded to EPA and USACE in a report, along with a recommendation on whether further sampling is necessary.  Because of limited funding through the FUDS grant, further investigation and sampling (and cleanup, if necessary) is typically conducted by USACE.

	|
On-site analysis of soil samples at former Army airfield hangar	Removal of underground fuel storage tank at former missile facility

Management Action Plan (MAP) for FUDS

In 2001, the US Army Corps of Engineers (USACE) started a pilot project with several states to create a Management Action Plan (MAP) for all of the Formerly Used Defense Sites (FUDS) in each state.  The objective of this project was to collect all of the information on each FUDS, including its location, size, history, and contaminants at the site, and place it in one comprehensive document.  The purpose of this document is twofold:  first, to verify all of the site information and serve as the main reference on FUDS in the state; and second, to prioritize and schedule the investigation and cleanup of each FUDS.  USACE, KDHE and EPA worked closely to make this project a success.

Kansas completed its MAP in November 2001 and was the first state to do so.  The MAP is based on a similar document called an Installation Action Plan (IAP) which the Department of Defense creates for each active military installation with contaminated sites.  The IAP is a proven method for organizing the investigation and cleanup of contaminated sites at Air Force bases, Army bases, and other types of installations, so the USACE decided to use it as the "blueprint" for creating the MAP.  The MAP is designed to be reviewed and updated each year, so that additional information on FUDS can be added, and site priorities and schedules can be changed if necessary.

By summarizing the amount of time and money needed to address all of the FUDS in Kansas, the MAP will help speed up the process of investigating and cleaning up these sites, and should also help USACE receive additional funding to do this work.

[Top of Page] |

Management Assistance Cooperative Agreement (MACA)

The Superfund Unit provides state oversight of assessment and corrective action at sites on the EPA National Priorities List (NPL) and sites under the EPA Superfund Removal Program through the Management Assistance Cooperative Agreement (MACA) and funding from EPA.  Environmental Geologists within the Superfund Unit work closely with project managers and scientists at EPA to provide technical expertise and field oversight of the federal environmental investigations and cleanups. The Superfund Unit also communicates state priorities and regulatory positions on these sites to the EPA.

Sites included in the MACA are industrial and commercial facilities at which releases of hazardous materials have occurred, such as:

• Chrome plating shops
• Some older, non-permitted landfills
• Hazardous waste recycling facilities
• Mines and smelters
• Metal fabrication and repair shops

Investigation and cleanup of sites on the MACA follows the CERCLA and SARA regulations as described above.  The investigation and cleanup work may be more difficult at these types of sites because they are often in cities and near residential areas, whereas many military facilities were built in more remote areas.  Superfund sites on the MACA often include more than one "responsible party", and assigning liability for cleanup costs can be difficult.  Sites on the NPL are usually the most highly contaminated and/or largest sites in the country, and investigation and remediation of these sites usually takes several years.  Smaller MACA sites which are not on the NPL are more common and can usually be investigated and cleaned up more quickly.

	|
Installing treatment system at groundwater contamination site	Unvegetated mine waste pile at Superfund site
	|
Removal of contaminated soil at former smelter	Chromium-contaminated soil at former plating facility

Identified Sites List

Contaminated sites managed by the Assessment & Restoration Section are included in the Identified Sites List (ISL) database. A fact sheet for each ISL site can be found at http://www.kdheks.gov/remedial/isl_disclaimer.htm. More detailed information is available from KDHE through a Kansas Open Records Act request. Please contact the program representatives listed on this web page for additional information.

Links

Check out these links for more information: 

• The US Army Environmental Center web page has information on environmental restoration projects.
• The US Army Corps of Engineers, Kansas City District works with KDHE on DSMOA and FUDS projects in Kansas.
• Ordnance and Explosives Fact Sheets are available from USACE for several sites in Kansas.  The sheets are in Adobe .pdf format.
• USACE Hazardous, Toxic, and Radioactive Waste (HTRW) Center of Expertise web site describes some of the types of investigations USACE performs.
• The US Environmental Protection Agency, Region 7 works with KDHE on DSMOA, MACA, and FUDS projects in Kansas.
• CERCLA, SARA and other federal regulations governing cleanup of our sites are explained here.
• An introduction to RCRA regulations is available here.

[Top of Page]