Military Services Differ on MMRP Approach

As the DoD established metric / goal for the Services (i.e. Army, Navy, Air Force and Marines) to complete their Military Munitions Response Program (MMRP) Preliminary Assessments (PAs) nears, it's an ideal time to look at how each DoD Service has approached this first phase of the program. As it turns out, each DoD Service has taken a different approach in addressing their munitions response (i.e. UXO) sites. A summary the approach taken by each is provided below:

Army  The Army started back in 2002-2003 with a range inventory. The Army's Phase III inventory (as they called it) covered "Closed, Transferring, and Transferred Ranges and Sites" (now known as other than operational ranges). The Army's Phase I inventory was a survey completed by the installations while the Phase II inventory defined the operational range areas for each Army installation. Because the Army's inventory was a cursory look at the ranges (i.e. limited research augmented with a site visit to the installation), the Army decided to conduct what they call a Historical Records Review (HRR) as a follow on to the Phase III inventory. The HRR involves a more in-depth archival research effort as well as additional data collection activities on site. The HRR phase is being followed by the Site Inspection (SI) phase, which involves a visual site survey (site walk) and limited munitions constituent (MC) sampling.

Army (FUDS)*  In the past the USACE managed FUDS program developed Archive Search Reports (ASRs) for their ordnance and explosive waste (OEW) sites (a term no longer in use). Since the MMRP was adopted, the FUDS program went through an effort of augmenting the information gathered and presented in the ASRs (for most sites) into a Preliminary Assessment (PA) report format. One problem that the FUDS program faced early on (and still does to some extent) is a change in definitions between when the FUDS program started and the program eligibility requirements under the MMRP. One example of this is small arms ranges. For years, the FUDS program dismissed small arms ranges as "No Further Action" sites as small arms did not pose an explosive safety hazard. While this statement is correct, there are other issues associated with small arms ranges that need to be addressed including the potential for lead and other constituent contamination at ranges. MC at FUDS was, to a large extent, ignored. An interesting paper developed several years ago by the USACE better explains their Preliminary Assessment of Eligibility (PAE) and SI process followed for FUDS.

Navy  The Navy also started with a range / site inventory effort. The Navy's inventory was initially conducted using a survey completed by their installations. The Navy then opted to do Preliminary Assessments (PAs) for their MMRP eligible sites according to the survey. The Navy selected a single contractor to do all the PAs to, according to the Navy, have some consistency across the program. The Navy has gone through some growing pains over the past few years since the PA program began including updating their definition of what they term an eligible MMRP site as a result of their July 2005 MMRP policy letter . Reportedly, the Navy experienced a growth in the number of sites from the initial survey process as a result of doing more detailed archival research during the PA phase.

Marine Corps  Several years before the MMRP was even being discussed at the Pentagon, the Marines had ASRs done for most of their active installations that had ranges. There does not appear to be any driver for the ASRs other than the Marines wanted more information about their ranges in order to effectively manage their real property assets. The Marine Corps is reportedly in the process of updating some of the information initially presented in the ASRs since the reports were completed several years before the MMRP began.

Air Force  The Air Force has decided to conduct what they call Comprehensive Site Evaluations (CSEs) at their MMRP sites. The CSEs are being conducted in two phases. The CSE Phase I effort involves a review of archival records, a visual site survey, and site interviews. The Phase II CSE effort involves a sampling (geophysical and environmental). The Air Force claims that a CSE Phase I is equivalent to a PA and the CSE Phase IIs is equivalent to a SI. For more information and details on the two CSE phases, download the two Air Force CSE Charts.

Each of the Services contend that they are meeting the DoD metric / goal for this first phase of the program. They also contend that their specific approach is equivalent to PA as defined by The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). How accurate those claims are depends largely upon ones interpretation of a PA under CERCLA as the approaches taken by the Services vary in terms of the level of detail and types of data provided. It is undoubtedly confusing for the public who just want to know, "do I have any UXO issues in or near my backyard or the areas I visit".

* The USACE is an Army organization but since the FUDS program is managed differently than the other Army MMRP sites, they are listed separately.