The FUDS Regulatory Context and Ongoing Monitoring Activities at Tierrasanta & Mission Trails

The Defense Environmental Restoration Program (DERP)

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Environmental-response activities initiated by the DoD at several military installations in the 1970s evolved into the Defense Environmental Restoration Program (DERP). The Formerly Used Defense Site (FUDS) component of DERP is managed and executed by the U.S. Army Corps of Engineers (USACE). Under FUDS, local USACE districts address response actions related to unexploded ordnance (UXO), discarded military munitions (DMM), and munitions constituents (MC) originating from UXO, DMM, or other military munitions.

The DERP/FUDS program follows the guidelines established in the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). The overall CERCLA process is illustrated in the flowchart below.

Remedial Response Process for HTRW and MMRP Projects

The Military Munitions FUDS Projects

The USACE provides overall coordination for the field actions and reporting activities related to military munitions and explosives of concern (MEC) and munitions constituents (MC) response actions in conducting project-related activities at the Tierrasanta and the Mission Trail project sites.

In conducting military munitions response activities, the USACE works closely with:

The California Department of Toxic Substances Control (DTSC)
Mission Trails Regional Park staff
Officials from the City and County of San Diego, and the community of Tierrasanta.

Significant FUDS military munitions project-related events at the Tierrasanta and Mission Trails project sites include:

1999:	The USACE completes a Final Ordnance and Explosives Long Term Monitoring Report for the Tierrasanta Community and the Murphy Canyon Naval Housing Area.
1999-2002:	The first Recurring Review is completed for the Tierrasanta site. The Review concludes that the ordnance and explosive (OE) clearance completed in 1994 was still protective of public safety.
2002-2003:	The initial Recurring Review is conducted for Mission Trails.
2004-2008:	Five-Year Recurring Reviews are being conducted for the Tierrasanta and Mission Trails project sites.

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Five-Year Recurring Reviews

Purpose:

The purpose of Recurring Reviews for OE response actions is to determine if a response action continues to minimize explosives safety risks and continues to be protective of human health, safety, and the environment.
Recurring Reviews also provide an opportunity to assess the applicability of new technology for addressing previous technical impracticability determinations.

The Recurring review will answer three general questions:

Is the response functioning as intended?
Are the assumptions used at the time of response selection still valid?
Does new information indicate that the previously selected response no longer minimizes explosive safety risks or is no longer protective of human health, safety, and the environment considering the best available technology?

Main Project Activities:

Establish the review team and begin community involvement activities.
Review existing documentation.
Identify/review new information and current site conditions.
Prepare a preliminary site analysis and work plan.
Conduct a site visit.
Prepare the Recurring Review Report.

Review Existing Documentation:

Review existing documentation to become familiar with the site history and implemented response actions.
The review will accomplish the following objectives:
Determine what actions were completed at the site.
Determine where unexploded ordnance (UXO) are suspected or were located, if applicable, and document the basis for this determination.
Identify and evaluate the basis for selection of the response action (e.g., land use, site accessibility, etc.).
Determine if there is an immediate threat to human health, safety, or environment that requires further response.

Identify/Review New Information and Current Site conditions:

Identify readily available information regarding the site that has become available since implementation of the response action or since the last Recurring Review.
Gather information pertaining to the following areas:
- Development at the site or in the vicinity of the site
- Erosion
- Recreational or other activities at the site or in the vicinity of the site
- Fire
- Storm Damage (uprooted trees, etc)
- Changes in land use at the site and in the vicinity of the site, both actual and potential
- Changes in accessibility to the site
- OE incidents and status of land use controls

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