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Louisville District environmental division a watchful eye on past defense procedures

Published Nov. 1, 2009

Today, the U.S. Army leads the way in environmental stewardship, but some say that hasn’t always been the case, often citing toxic chemicals found decades later in the soil at Formerly Used Defense Sites.

In 1997, the Ohio Environmental Protection Agency and Ohio Department of Health conducted an initial environmental site assessment of the River Valley middle and high school campuses (later determined to be a FUDS) due to concerns raised about the number of leukemia cases among school graduates.

It was later determined that the school sat on top of the site of the former Marion Engineer Depot that opened during World War II and operated for 15 years.
Subsequent analyses found two potentially hazardous situations that required further study. The first was a radium-painted, dime-sized aluminum disk below the surface of the soil in front of the high school. The Army used these discs to mark the position of bridges and vehicles so that troops could see them during nighttime operations. The disc was removed and the surrounding soil didn’t test positive for radioactivity.

Further analysis of the grounds uncovered a former waste disposal area where the Army disposed of and burned fuels and solvents. The depot was one of the largest in the Army’s inventory and home to, or a storage point for, thousands of vehicles and other engineering equipment. And, there were a lot of parts.

To prevent parts from rusting while they were stored, manufacturers coated much of the equipment in cosmoline. When time came to use the parts, the Army dipped them in vats of trichloroethylene. Eventually, the leftover chemical residue in the vats was taken to trenches and burned. The trenches, revealed through Corps conducted interviews with Soldiers who worked at the depot, were located underneath what later became the schools’ athletic fields.

Why did the Army dump and then burn hazardous chemicals?
These types of disposal practices weren’t as restrictive as they are today, because the scientific and medical communities didn’t know about the dangers associated with the disposal and use of some chemicals used by the Department of Defense, according to Louisville District environmental division subject matter expert and risk assessor Dr. David Brancato.

Since there were no known health threats, there were no laws regulating the use of these chemicals. But scientific and medical research began uncovering the harmful effects associated with many of the substances used by DoD (and commercial industries), so Congress soon began passing laws that regulated their use.

In 1976, Congress passed the Resource Conservation and Recovery Act that regulated any person or facility engaged in the creation, transportation, treatment, and disposal of hazardous waste. However, RCRA didn’t address the necessary cleanup at contaminated sites. Then, in 1980, Congress enacted the Comprehensive Environmental Response Compensation and Liability Act, also referred to as Superfund.

“Superfund is intended to establish a mechanism of response for the immediate cleanup of hazardous waste contamination from accidental spills and from the chronic environmental damage such as is associated with abandoned hazardous waste disposal sites,” Brancato said.

What is the U.S. Corps of Engineers Role in cleaning up FUDS?
The Louisville District’s environmental division took the lead on the environmental investigation in March 1998. The division’s staff specializes in engineering, chemistry, risk assessing, geology and other disciplines. At Marion, the Corps’ goal was to figure out if anything on the property presented a risk to the community. If so, then the Corps job was to contain it or clean it up.

The Corps actually discovered the trenches by talking to Soldiers and civilians who worked at the depot more than half a century ago.

“Based on the interviews, we found where the trenching had occurred,” Brancato said. “It was a common activity in the past. Without regulations, if they had no use for material, if it was waste, then it was buried.”

Upon further study, the Corps did find contaminants in the subsoil through sampling, but the Ohio EPA and Ohio Department of Health determined that the school could still function, and that there was no definitive association between attendance of individuals who were graduates of River Valley who came down with leukemia and their attendance at the school. The study was based on years of air and groundwater monitoring by the Corps.

However, public opinion was already strongly set against local agencies and the Corps. Contentious town hall meetings, a higher leukemia rate among graduates than the national average, and a very interested media persuaded local officials that the school close anyway.

“Science and politics were at odds at that point,” Brancato said. “They didn’t necessarily believe the reports because the Ohio Department of Health did proceed with three studies of cancer incidents.”

Once the school closed down, the Corps moved ahead with efforts to clean the site so the city could sell the property and use it for other purposes. Thousands of tons of dirt were removed and a cap was placed around the trenching area and sealed. The seal ensures that the remaining soil in the area isn’t disturbed due to water infiltration. The Corps continues to inspect the cap annually, and the most recent inspection shows that the cap is working as designed.

What is land being used for today?
The Marion School District sold the site to local businessman Ted Graham, who is in the process of having it rezoned for industrial purposes, in accordance with the deed restriction. The property can’t be used for school or residential purposes. Graham was (and still is) a member of the Restoration Advisory Board, a group of community citizens, Ohio EPA and Board of Health members, and district officials who met monthly during the Corps’ investigation. Graham said he’s confident in the integrity and safety of the land he purchased.

“The government came in and cleaned it up by the book,” he said. “I haven’t heard any complaints from the community except for one or two dissidents, and you’ll never make them happy. My workers are confident they cleaned up the place and they feel safe working there.”

Can’t take the depot out of context
The American way of life depended on an Allied victory in World War II, and victory in Europe and the Pacific depended on an efficient war machine that destroyed either the enemy or its will to fight. The Army’s standard operating procedures at that time couldn’t account for what’s known today about the toxicology of certain chemicals or how they were disposed of. The Soldier who dug the trench or set flame to it had no reason to believe he was creating a situation that could potentially harm Americans more than half a century later.

“Now we have the National Cancer Institute, the International Agency for the Research of Cancer, all subsequent to the laws that were promulgated in the 1970s,” said Brancato. There was activity on installations that would not meet today’s standards based on RCRA and CERCLA. That knowledge base is changing the way we do business. Still, there is a tendency to forget the sacrifices these veterans made and the risk that the country was in at the time.”