The U.S. Army Corps of Engineers Louisville District has recently determined No Further Action (NFA) is needed at the Grand Rapids National Guard Target Range (NGTR) near Grand Rapids, Michigan.
This determination closes the last open project at the Formerly Used Defense Site (FUDS) and puts the bookend on a 28-year environmental investigation.
“The project has had its share of challenges, but due to a great working relationship with the state regulator—Michigan Department of Environmental Quality—the project has moved forward and received concurrence,” said Angela Schmidt, U.S. Army Corps of Engineers Louisville District Risk Assessor.
The site currently forms the northern most portion of the Donald Lamoreaux County Park, but historically was used as a target range by the Michigan Militia, now known as the Michigan National Guard. They used the site for small arms marksmanship practice and non-explosive mortar training using 0.30, 0.38, and 0.45-caliber ammunition. Because of this, lead pellets (residual lead) were scattered among the target pit and the large berm behind it leaving debate over how residual lead should be addressed.
“When the Army turned the property over to be used as a park in the early 1970s – we had cleaned it all up except in a large berm where residual lead and pellets remained,” said Schmidt.
Concentrations found in previous studies by the Corps were misrepresented due to pieces of lead pellets being in some samples and causing exceedances of screening values.
“A lot of times when you have a strict exceedance of a screening value we are forced into action unnecessarily, but in this case by partnering and dissecting previous studies we were able to be very successful,” said Schmidt.
“We held a workshop with MDEQ in December and sat down and hammered it out,” she said. “We looked at data, at site conditions, at distribution of lead – we looked at all things collectively to come up with a common-sense, yet protective solution.”
After the re-evaluation USACE and MDEQ ultimately agreed that any residual lead in the surface soil was not in concentrations great enough to pose a significant threat to human health or the environment. No additional analysis or remedial actions were warranted and a NFA determination was made for the target range area.
“Lead is a stable compound, it is part of a natural environment, it has a slow decomposition rate and has little effect on the environment when it is in a solid form like an ore. Lead is naturally occurring and the berm is now covered in grass – it’s not bioavailable,” said Schmidt.
“By having a No Further Action here we’re preserving the natural resources,” said Schmidt.
The benefits include preserving the park by having no destruction or disturbance to the park or its operations or ecology, economic benefits of saving money from not conducting a removal action or having future land-use controls in place, societal benefits to the community that it can continue to be used as a park as intended, and additionally there are no disturbances to the environment by pulling clean fill dirt from another location.
“With cooperation, diligence, and everyone doing their job to the best of their ability we came together at the right time to be able to make this a No Further Action project,” said Schmidt. “The biggest thing was going back and looking at the site with a different set of eyes. We were worlds apart, but then once we worked together and formed a common strategy we had success.”