Federal Facilities/DSMOA Progam
Jorge Jacobs, Unit Manager
Phone: (785) 296-8801 Fax: (785) 296-4823
1000 SW Jackson, Suite 410
Topeka, KS 66612-1367
The Federal Facilities Unit works with the Environmental Protection Agency (EPA) and the US Army Corps of Engineers (USACE) to investigate and clean up a variety of federal sites, including active and former military properties under the Defense-State Memorandum of Agreement (DSMOA) with USACE.
Defense-State Memorandum of Agreement (DSMOA)
The Federal Facilities 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. The Federal Facilities Unit works closely with project managers and scientists at federal agencies, primarily USACE and EPA. The Federal Facilities 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
Formerly Used Defense Sites (FUDS)
The Federal Facilities Unit also provides state oversight of assessment and corrective action at Formerly Used Defense Sites (FUDS) through the DSMOA Program. Staff within the Federal Facilities Unit perform regulatory oversight of 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. Federal Facilities Unit staff work with USACE, EPA, other regulatory staff, and site owners to expedite assessments and any required remedial actions at these sites.
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.
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.html. 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.
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.
If you have any questions regarding the Federal Facilities Unit web page please call KDHE at (785) 291-3252.