The U.S. Army Corps of Engineers (Corps) is in charge of addressing cleanup at the more than 9,000 U.S. properties that were formerly owned or controlled by the Department of Defense (DOD) and have been identified as potentially eligible for environmental cleanup. The Corps has determined that more than 4,000 of these properties have no hazards that require further Corps study or cleanup action. However, in recent years, hazards have surfaced at some of these properties, leading state and federal regulators to question whether the Corps has properly assessed and cleaned up these properties. In this context, Congress asked us to (1) analyze federal coordination requirements that apply to the cleanup of these properties, (2) assess recent DOD and Corps efforts to improve coordination, and (3) identify any issues regulators may have about coordination with the Corps.
Recommendations for Executive Action
|Department of Defense||To help ensure consistent coordination with regulators during all phases of FUDS investigation and cleanup, the Secretary of the Department of Defense should direct the Secretary of the Department of the Army to follow through on its plans to develop and incorporate clear and specific guidance in the Corps' FUDS Program Manual as to how, when, and to what extent coordination with regulators should take place, including during preliminary assessments of eligibility. Moreover, in view of the states' concerns and hazards posed by ordnance and explosive waste, the coordination guidance should address these types of projects as well, not just those involving hazardous waste. In developing the guidance, the Army should work with regulators to develop a consensus on how, when, and to what extent coordination should take place.|
|Department of Defense||In addition, in view of the need for federal agencies to ensure that cleanup efforts are done properly and that scarce resources are best utilized, DOD and EPA should work together to clarify their respective roles in the FUDS cleanup program for properties that are not listed on the National Priorities List. The agencies should agree on a time frame to establish a memorandum of understanding that will lay out an overall framework for how they will work together, including their roles and responsibilities, during the assessment and cleanup of FUDS properties.|
|Department of Defense||As a starting point, the Secretary of the Department of Defense should direct the Secretary of the Department of Army to assess the impact of the Corps' recent efforts to improve coordination through actions such as directives and the Management Action Plan pilot program and incorporate the successful components as requirements into its FUDS Program Manual.|
|Department of Defense||As a starting point, the Secretary of the Department of Defense should direct the Secretary of the Department of Army to assess practices individual Corps districts have used to coordinate with regulators and develop a list of best practices for dissemination throughout the Corps that districts might use to improve their coordination.|