Environmental Impact Statement for the Relocation of the U.S. Army Chemical School and the U.S. Army Military Police School to Fort Leonard Wood, MissouriRecord of Decision

DEPARTMENT OF DEFENSE

Department of the Army

Environmental Impact Statement for the Relocation of the U.S.

Army Chemical School and the U.S. Army Military Police School to Fort

Leonard Wood, Missouri--Record of Decision

AGENCY: Department of the Army, DoD.

ACTION: Notice of record of decision.

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Table of Contents

1. Decision

2. Proposed Action

3. Alternatives

4. Selection of the Army's Preferred Alternative

5. Impacts and Mitigation Commitments

6. Conclusion

1. Decision

In my capacity as the Assistant Secretary of the Army for

Installations, Logistics and Environment, and based on the analysis

contained in the Final Environmental Impact Statement (FEIS) for the

Relocation of the U.S. Army Chemical School and the U.S. Army Military

Police School and their associated units and support elements to Fort

Leonard Wood (FLW), Missouri, I have determined the FEIS adequately

assesses the impacts of the proposed action and related alternatives on

the biological, physical, and cultural environment. Therefore, in

accordance with the Defense Base Closure and Realignment Act of 1990,

Public Law 101-510, the Army will proceed with construction of

facilities at FLW to support the relocation of the Chemical School and

Military Police School and shall relocate the schools, their associated

units and support elements, and associated personnel to FLW in

accordance with the Army's Preferred Alternative and the general

implementation schedules described in the FEIS.

The Defense Base Closure and Realignment Act of 1990 (1990 Base

Closure Act), Public Law 101-510, requires the closing of Fort

McClellan (FMC), Alabama, and the relocation of the Chemical School and

Military Police School to FLW. In addition, the 1990 Base Closure Act

requires the Chemical Defense Training Facility (CDTF) to continue to

operate at FMC until the capability to operate a replacement facility

at FLW has been achieved.

The 1990 Base Closure Act also exempts the Commission's decision-

making process from provisions of the National Environmental Policy Act

(NEPA). The law also relieves the Department of Defense (DoD) from the

NEPA requirement to consider the need for closing, realigning or

transferring functions, and from looking at alternative installations

to close or realign. However, the Department of the Army must evaluate

the environmental impact of implementing actions that are necessary to

relocate specified missions and operations. The environmental and

socioeconomic impacts of facility construction and future training and

operations must be analyzed and documented. Therefore, my decision to

approve implementation was based on consideration of whether or not the

Army has adequately considered the environmental effects of

implementing the relocation decision. In addition, my review considered

whether the Army has developed and considered an alternative to avoid

or minimize environmental impacts and has or will comply with all

environmental laws and regulations during the implementation. The Army

will conduct fog oil training within the constraints of the existing

Missouri Department of Natural Resources Air Quality Permit #0695-010,

or other permits in existence at the time the training takes place,

until such time a permit is issued that will accommodate the full

implementation of the preferred alternative.

My decision considered: the mitigation commitments outlined in the

FEIS; transcripts of the scoping meeting; the public hearing on the

Draft EIS; all written comments received during the public comment and

the 30-day post-filing periods; and the National Academy of Sciences

Committee report (see paragraph 5.14). In addition, I have considered

the results of continued coordination with interested federal, state

and local agencies and public interest groups in making my decision.

I have reviewed the FEIS for the Relocation of the U.S. Army

Chemical and the U.S. Army Military Police Schools to Fort Leonard

Wood, Missouri, and associated correspondence received in response to

coordination of this document, and have decided that the plan as

recommended in the FEIS should be executed and that the construction

associated with the proposed action should proceed. I find the plan

outlined in the Executive Summary of the FEIS to be technically sound,

environmentally sustainable, socially and economically acceptable, and

in agreement with the 1990 Base Closure Act. Any new or additional

missions will be evaluated in compliance with NEPA and all other

federal, state, and local laws and regulations prior to deciding to

implement at FLW.

2. Proposed Action

The proposed action is described in the FIS in the context of three

primary elements including: (1) Training missions to be relocated to

FLW; (2) facilities required to support the relocated missions; and (3)

the population to be relocated to FLW as a result of the action. The

Military Police School and the Chemical School have the mission to

provide education and training of selected U.S. military, foreign

military and civilian personnel. Chemical School students are trained

to: detect and identify Nuclear, Biological and Chemical (NBC) agents;

protect themselves and others from harm caused by NBC agents; employ

smoke and other obscurants to increase soldier combat effectiveness and

survivability; and construct and detonate flame field expedient

deterrents to protect our troops in battle. Military Police School

students are trained in traditional police functions as well as

specialized military operations such as battlefield circulation, area

security, and prisoner-of-war handling.

The action also includes relocation of units and missions to FLW

that are required to support the Chemical School and Military Police

School. All activities evaluated in the FEIS are considered ``directed

relocations'' which are specifically identified by, or required to

implement, the 1990 Base Closure Act requirements. Additional

facilities (buildings, specialized training facilities, and designated

training land areas) are required at FLW to meet the needs of the

Chemical School and Military Police School. Implementation of the

action results in completion of approximately $200 million in military

construction projects, and an increase of approximately 9,000 persons,

including permanent party military personnel and dependent family

members, military and civilian student trainees, and civilian

employees.

3. Alternatives

In accordance with NEPA and Council for Environmental Quality (CEQ)

regulations, the Army developed and evaluated a reasonable range of

alternatives for implementing the mandated BRAC at FLW. Alternatives

were developed for each of the primary elements of the action including

relocation of training missions, provisions of required support

facilities, and relocation of related personnel. A summary of

alternatives considered in the FEIS is provided below.

[[Page 28678]]

3.1 Training Alternatives

The FEIS alternatives formulation process was initiated with a

review of over 70 Programs of Instruction (POIs) that define training

activities of the Chemical School and Military Police School. Training

activities were grouped into 11 categories, which included a total of

43 specific training goals. The EIS team then identified and considered

a total of 204 training method alternatives for accomplishing these

training goals at FLW. Volume IV of the FEIS provides information

regarding alternative training methods considered, and the rationale

that led to selection of those methods to be analyzed in detail in the

FEIS. This alternative formulation process resulted in further

considered of a No Action Alternative, and three training goal

implementation alternatives. The training implementation alternatives

included the: 1) Relocate Current Practice (RCP) Alternative; 2)

Optimum Training Method (OPTM) Alternative; and 3) Environmentally

Preferred Training Method (EPTM) Alternative.

Analysis of the No Action Alternatives as it relates to the

training element of the FEIS considered the impact of not implementing

individual training goals associated with the Chemical School and

Military Police School missions. Failing to implement any of the 43

training goals identified and considered in the FEIS was not reasonable

because training in each of these goals is essential to meeting mission

requirements. Therefore, the No Action Alternative is not evaluated in

detail in the FEIS. However, the No Action Alternative (the

continuation of ongoing and planned (pre-BRAC) activities at FLW) is

used as the environmental baseline against which the impacts of each

training implementation alternative were evaluated.

The RCP Alternative evaluates relocating all training methods to

FLW as they are currently (at the time of the BRAC decision) conducted

at FMC. The training methods defined in the RCP create a baseline

against which the alternative methods were evaluated. The OPTM

Alternative was formulated to identify and evaluate the impact of

implementing training methods which best met a combination of initial

environmental and training/operating efficiency screening criteria as

documented in Volume IV of the FEIS. The EPTM Alternative was

formulated to evaluate the impact of implementing the combination of

training methods which received the highest score based solely on

consideration of environmental screening criteria.

3.2 Supporting Facility Alternatives

Implementation of the planned BRAC action at FLW will require

facilities to support the training requirements of the relocated

schools and to support the housing, administrative and support

requirements of increased personnel. The Army's analysis for this

action included a detailed review of facility requirements for all

activities. This process resulted in identification of Chemical School

and Military Police School facility requirements in excess of 1.6

million square feet of space and numerous range and training area

requirements. Detailed analysis of existing facilities at FLW resulted

in identification of approximately 800,000 square feet of existing

facility space that could be used to meet approximately half of the

relocation requirements. This left a shortfall of an additional 800,000

square feet of facility space that must be met through new

construction.

The FEIS documents the rationale for consideration of a No Action

Alternative and three facility implementation alternatives. Each of the

implementation alternatives included a unique BRAC Land Use and

Facility Plan (LU&FP) which identified modifications to FLW's existing

approved land use plan required to meet needs of the relocated schools,

and a facility construction program which identified the type, extent,

and location of facility development associated with each alternative.

Under the No Action Alternative for this study element, FLW would

continue to implement its pre-BRAC land use and facility development

plan, but no new facilities would be provided in response to BRAC

actions. The analyses documented in the FEIS, demonstrates that FLW can

support approximately 50 percent of the identified requirements, and

that opportunities to lease space off-post are very limited. None of

the specialized training facilities such as the Chemical Defense

Training Facility, radiation laboratory, crime scenes and other unique

facilities for the two schools are available. Therefore, since BRAC

legislation directs the relocation, the No Action Alternative is not

reasonable, and, therefore, is not analyzed in further detail in the

FEIS, other than to serve as an environmental baseline against which

the impacts of each facilities implementation alternative are

evaluated.

The ``Army's Proposed LU&FP (Combined Headquarters and Instruction)

Alternative'' locates the headquarters for the three schools (existing

Engineer School at FLW, and the Military Police School and Chemical

School to be relocated) in Hoge Hall, Lincoln Hall and a new General

Instruction Facility (GIF) complex. The ``Alternative 1 LU&FP (Combined

Headquarters)'' is based on the concept of collocating the headquarters

for each of the three schools (existing Engineer School at FLW and both

schools to be relocated) in Hoge Hall and Lincoln Hall. However, three

separate ``school houses'' would be provided, thereby allowing the

individual specialty branches to retain more autonomy. The

``Alternative 2 LU&FP (Separate Headquarters)'' would locate the

headquarters for the Chemical School and the Military Police School in

separate buildings, but would consolidate general instruction and

library facilities in the ``800-area'' of the FLW post. The Engineer

School would remain in Hoge, Lincoln and Clark halls.

3.3 Population Relocation Alternatives

The third and final element of the alternative formulation process

involved consideration of the population to be relocated to FLW as a

result of the proposed action. The action is expected to result in a

total population increase of approximately 9000 persons to the FLW

area, including permanent party military personnel and their dependent

family members, military and civilian student trainees, and civilian

employees. The FEIS considered a No Action Alternative and three

implementation alternatives for this element including a: (1) Total

Early Move Alternative; (2) Total Late Move Alternative; and (3) Phased

Move Alternative.

The FEIS concludes the No Action Alternative, as it applies to

relocation of personnel, is not reasonable. However, the No Action

Alternative was used to compare population conditions and related

impacts at the current (pre-BRAC) level at FLW, to those expected to

occur under each of the BRAC action implementation scenarios. Regarding

the three implementation alternatives, the FEIS concludes the Total

Early Move and Total Late Move alternatives were not reasonable because

they resulted in facility utilization problems and disruption of

ongoing training programs. Accordingly, all implementation scenarios

considered in detail in the FEIS are based on the Phased Move

Alternative. The Phased Move Alternative would involve relocation of

personnel (and related missions and equipment) on a phased schedule.

This phrasing is expected to occur over a period of approximately 9

[[Page 28679]]

months, tied to the availability of renovated or new facilities and

completion of training classes at FMC, and startup of the relocated

classes at FLW.

4. Selection of the Army's Preferred Alternative

In accordance with CEQ regulations (40 CFR 1505.2), the FEIS and

this ROD identify the Army's Preferred Alternative which includes

implementation of (1) the Optimum Training Method (OPTM) Alternative;

(2) the Army's Proposed LU&FP (Combined Headquarters and Instruction)

Alternative; and (3) the Phased Move Alternative. As stated above, the

Army determined that the only reasonable method for relocating the

personnel associated with the Chemical School and the Military Police

School was as described under the Phased Move Alternative. Therefore,

that element is part of the Army's preferred method for implementing

the total action. The rationale for the selection of the Army's

Preferred Alternative relative to the training missions to be relocated

and required support facilities is summarized below, and further

documented in the FEIS.

34.1 Training Element Decision

For the training element of the proposed action, the FEIS impact

analysis documents that the RCP Alternative would result in

substantially higher adverse environmental impacts (taken as a whole)

than either the OPTM Alternative or the EPTM Alternative, and that the

RCP Alternative would result in a lower level of training effectiveness

than the OPTM Alternative. Therefore, the RCP Alternative was dropped

from further consideration prior to completion of the cumulative impact

analysis section of the FEIS. This focused the decision on how to

conduct training at FLW between the OPTM and EPTM alternatives.

The analysis indicates selection of the EPTM Alternative would

reduce the annual quantity of fog oil used, thereby reducing the extent

of impacts on the environment (including some reduction in the degree

of impact to air quality and threatened and endangered species).

However, significant adverse impacts to both air quality and threatened

and endangered species may still occur under both the OPTM and EPTM

alternatives, and the nature and extent of mitigation required under

the OPTM and EPTM alternatives are very similar. Furthermore,

implementation of the EPTM Alternative would reduce the overall

training effectiveness relative to the OPTM Alternative in six of 43

training goals as discussed in the FEIS. The most significant reduction

in training effectiveness under the EPTM Alternative would be

associated with Training Goal 7.4 (Fog Oil Training Field Proficiency

Test), where the reduced levels of fog oil usage would result in

soldiers that are not as highly trained under realistic field

conditions as the OPTM Alternative provides. Proficiency in deployment

and maintenance of smoke screen cover over specified areas under

battlefield conditions is critically important to the successful

performance of certain military missions, and to protect our troops and

defend our national interests and those of our allies. In consideration

of these factors, and all other information provided by the FEIS

analysis, I selected the OPTM Alternative as the preferred method of

implementing training activities to be conducted by the Chemical School

and the Military Police School at FLW.

4.2 Supporting Facility Element Decision

The FEIS analysis revealed the environmental impacts of the

Alternative 2 LU&FP (Separate Headquarters) were clearly more adverse

than either the Army's Proposed LU&FP (Combined Headquarters and

Instruction) or the Alternative 1 LU&FP (Combined Headquarters).

Furthermore, the Alternative 2 LU&FP did not provide any significant

operational advantages over the other two alternatives. Therefore, the

Alternative 2 LU&FP was dropped from further consideration prior to

completion of the cumulative impact analysis section of the FEIS. The

analysis also showed that the Army's Proposed LU&FP (Combined

Headquarters and Instruction) has less overall adverse environmental

impacts than the Alternative 1 LU&FP. In addition, the FEIS analysis

documents that the Army's Proposed LU&FP (Combined Headquarters and

Instruction): (1) is the most effective plan with regard to utilization

of existing available facilities at FLW to meet requirements; (2) has

the lowest construction cost of any of the implementation alternatives;

(3) provides the highest degree of collocation of similar facilities;

(4) provides the greatest long-term operational cost savings; and (5)

provides the highest potential for synergistic training activities at

FLW. In consideration of these factors, and all information provided by

the FEIS analysis, I selected the Army's Proposed LU&FP (Combined

Headquarters and Instruction) as the preferred method for providing

facilities required to support the relocation of the Chemical School

and the Military Police School to FLW.

5. Impacts and Mitigation Commitments

Fifteen natural, cultural, sociological, and economic resource

categories, plus a category to consider the operational efficiency of

planned actions, were established to provide a framework for

identifying baseline conditions and determining the impact of

alternatives in the FEIS. A summary of the type and extent of impacts

anticipated as a result of implementing the Army's Preferred

alternative at FLW is provided below for each analysis category.

Impacts discussed represent the cumulative impact of implementing all

elements of the Army's Preferred Alternative, in association with past,

present, and reasonably foreseeable future actions as discussed in

detail in the FEIS. Where appropriate, this subsection of the ROD

identifies mitigation measures that will be taken by the Army to avoid

or minimize adverse environmental impacts.

Several of the following impact discussions will refer to Volume

III, Appendix K (Summary of Monitoring Programs) which documents the

intent of monitoring programs that will be implemented by FLW to ensure

impacts associated with the Army's Preferred Alternative are consistent

with those predicted in the FEIS and in full compliance with applicable

laws, regulations and permit conditions. Specifically, Appendix K

describes monitoring program elements, associated adaptive management

strategies, and compliance schedules for six distinct monitoring

programs including: (1) Air Quality; (2) Soils and Vegetation; (3)

Human Health; (4) Endangered Species; (5) Biological Indicators; and

(6) Water Quality.

5.1 Land Use and Training Areas

The FEIS concludes implementation of the Army's Preferred

Alternative will not require change in the previously approved land use

pattern for the non-cantonment training areas at FLW. Existing non-

cantonment training areas will remain in use for training, and no

additional areas will be converted to this land use, although the type

of training conducted at several of the training areas will change. All

such changes are compatible with adjacent training activities.

Implementation will result in some adjustments to the existing land use

plan within the FLW cantonment area. However, these changes are minimal

in relation to the total land area involved, and each of

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these changes will result in improved functional relationships and

efficiency of post operations. The action will also modify existing

off-post land use patterns associated with development of additional

civilian residential and commercial activities in areas surrounding

FLW.

Land Use and Training Area Impact Mitigation Commitments

None of the land use or training area impacts identified in the

FEIS are significant, and no mitigation is required. The Army will

construct BRAC related facilities and conduct related training and

support operations in full compliance with the existing installation

Master Plan, and those modifications to the Master Plan described as

part of the Army's Preferred Alternative.

5.2 Air Quality

Recognizing that environmental agencies and members of the public

are concerned about impacts of proposed fog oil obscurant training on

the air quality within and around FLW, the Army conducted an in-depth

evaluation of this issue and has fully documented the results in the

FEIS. The FEIS air quality analysis was modified, in response to

comments received on the Draft EIS, to clarify several issues and to

provide additional details concerning impacts on air quality. This

additional information is presented in subsections 5.2.2.3 and 5.5.5 of

the FEIS, Appendix J (Air Permit #0695-010) to Volume III of the FEIS,

and in a separate ``Air Quality Technical Reference Document:

Relocation of the US Army Chemical School and US Army Military Police

School to Fort Leonard Wood, Missouri,'' which was included in each the

11 public repositories identified in the FEIS.

Due to the quantity of air emissions associated with the planned

fog oil obscurant training activities, the action is subject to permit

review in compliance with 40 CFR Part 51 and Missouri State Rule 10 CSR

10-6.060. Full implementation of the Army's Preferred Alternative for

fog oil obscurant training requires the use of up to 84,500 gallons of

fog oil per year and up to 1,200 gallons per day. Review of subsection

5.5.3.3.2 (and other air quality subsections of the FEIS) indicate

that, based on conservative assumptions for modeling, full

implementation of the action would result in exceeding the National

Ambient Air Quality Standards (NAAQS) for 24-hour PM-10 (see subsection

5.5.3.3.2 for details). Mitigation is thus required to comply with the

NAAQS and the terms of the existing Missouri Department of Natural

Resources (MDNR) Air Quality Permit #0695-010 for fog oil training at

FLW. Fog oil training will be constrained to the level allowed by the

permits in existence at the time the training occurs. Procedures to be

used to ensure the general public is not exposed to air which does not

meet the National Ambient Air Quality Standards because of fog oil

training are described in subsection 5.2.2.15.B of Volume I of the FEIS

and Appendix K of the FEIS.

The cumulative impact analysis included in the FEIS quantifies the

level of mitigation (through reductions in the quantity of fog oil to

be used) necessary to reduce PM-10 air quality impacts to acceptable

levels. The FEIS demonstrates that implementation of the Army's

Preferred Alternative, with fog oil training reduced to conditions and

use limits established by the current MDNR Air Permit #0695-010 (as

included in Appendix J. Volume III of the FEIS), will comply with the

National Ambient Air Quality Standards for PM-10.

Because the implementation of fog oil training at the mitigated

(existing MDNR Air Quality Permit #0695-010) level does not provide the

level of training considered optimum by the U.S. Army Chemical School,

the FEIS states that FLW intends to pursue a new or revised air permit

with MDNR after evaluating the assumptions used for the air dispersion

model in conjunction with site-specific (within and immediately

adjacent to FLW) meteorological data that is currently being collected.

The revised permit application may request consideration to use fog oil

quantities up to the maximum levels specified under full implementation

(non-mitigated) of the Army's Preferred Alternative (up to 84,500

gallons per year and up to 1,200 gallons per day). Any such permit

renewal process will be subject to full disclosure and comment per the

conditions and procedures established by MDNR. Additional details

regarding the cumulative impact analysis and other factors relating to

the air permitting process are fully documented in subsection fog

5.5.3.3.3 of the FEIS, and in the separate air quality technical

reference document as referenced above.

Air Quality Impact Mitigation Commitments

Until a new or revised air permit is issued by Missouri Department

of Natural Resources, the Army will comply with and adhere to annual

and daily fog oil use levels specified in the existing MDNR Air Quality

Permit #0695-010 (65,000 gallons per year and approximately 481 gallons

per day) and comply with all terms and conditions established in the

existing MDNR Air Quality Permit #0695-010 including air monitoring.

The air quality monitoring plan includes three types of monitoring

activities: (1) Ambient air quality monitoring of PM-10 and ozone; (2)

meteorological monitoring; and (3) smoke movement monitoring.

Ambient air quality and meteorological monitoring will be conducted

using a network of nine monitoring stations located on and near FLW.

This network include four previously established stations that are only

used to collect meteorological data. In addition, five meteorological

and ambient air monitoring stations have been added at FLW (one at each

of the four fog oil obscurant training areas, and a fifth at Forney

Army Airfield). Meteorological and air quality monitoring will be

conducted for at least 2 years prior to initiation of fog oil training

at FLW to establish baseline conditions, and will continue for at least

2 years after fog oil training is initiated at FLW. Smoke movement

monitoring will be conducted during mobile and field fog oil training

exercises to ensure that training will comply with the National Ambient

Air Quality Standards for PM-10. Additional details regarding the air

quality monitoring plan and related adaptive management response is

provided in Appendix K (subsection K.4.1, Volume III) of the FEIS.

Fort Leonard Wood will develop and implement a Public Awareness

Program (as defined in Appendix L, Volume III of the FEIS) to inform

the general public of potential health risks associated with exposures

to fog oil. FLW will continue to adhere to established policies and

procedures that are designed to ensure that the general public does not

enter active training ranges, including those lands to used to support

future smoke training activities. Procedures to be used to ensure that

the general public does not enter active smoke training ranges are

described in subsection 5.2.2.15.A of the FEIS and include: (1)

establishment of appropriate safety zones adjacent to smoke training

areas; (2) daily patrols of all closed or restricted training areas and

related safety zones to ensure that no unauthorized persons enter these

areas; and (3) appropriate signs along with physical barriers (such as

gates or cables) on roads leading into training areas.

5.3 Noise

Elements of the Army's Preferred Alternative that result in direct

and indirect effects to noise include: (1) Expansion of the amount of

exterior

[[Page 28681]]

training activities, including the amount of ammunition, grenades and

explosives to be used; (2) expansion of aircraft operations in and near

Forney Army Airfield; and (3) noise associated with the construction of

BRAC related construction projects. The FEIS concludes that the impacts

of these activities, in association with other past, present and

reasonably foreseeable future actions that could influence noise

levels, are not expected to exceed significance criteria.

Noise Impact Mitigation Commitments

No mitigation is required. However, continued coordination between

the installation and the Regional Commerce and Growth Association in

Pulaski County and adjacent cities will help to ensure that noise

sensitive land uses are avoided in those limited off-post areas that

have previously been (as a result of current, baseline operations at

FLW) and are expected to continue to be exposed to adverse noise

levels.

5.4 Water Resources

Under this evaluation category, the FEIS considers the potential

for impacts to regulatory flood plains, surface water and groundwater

resources. The FEIS concludes that implementation of the Army's

Preferred Alternative will not result in any adverse impact to

regulatory flood plains within or beyond the FLW boundaries. The FEIS

notes that the action may result in minor adverse cumulative impacts to

surface water quality within FLW boundaries; and that minor, adverse

impacts may occur as a result of sediment-laden surface water flowing

into karst features (sinkhole and related rock fractures and openings

that allow for rapid groundwater movement) that occur within

installation boundaries. However, implementation of numerous specific

surface water/sediment control projects (including the construction of

an impermeable liner under the proposed flame training range and

construction of several sediment retention basins) and adherence to

Best Management Practices (BMPs) that are defined as part of the

proposed action will ensure that these impacts do not reach significant

levels.

Water Quality Impact Mitigation Commitments

In addition to continuation of existing (pre-BRAC) water quality

monitoring at FLW (as defined in Volume III, Appendix H of the FEIS),

the Army will implement a BRAC Water Quality Monitoring Plan to ensure

compliance with the revised National Pollution Discharge Elimination

System (NPDES) Missouri State Operating Permit MO-117251; the Missouri

Clean Water Law, the Federal Water Pollution Control Act and all other

applicable laws, regulations and permits. Subsection K.4.6 of Appendix

K, Volume III of the FEIS describes all substantive elements of the

water quality monitoring program to be implemented at FLW. The Army

will also ensure BRAC construction projects are completed in accordance

with specified erosion and surface water control features. This

includes construction of berms around the flame training range,

construction of water retention ponds to collect water runoff from the

flame range, and construction of an impervious liner to control

groundwater flows beneath the flame training range. FLW will implement

management controls on training in order to avoid potential impacts

associated with in-stream vehicle crossings including: (1) Limiting

high mobility multipurpose wheeled vehicle (HMMWV) stream crossing

training to specifically designated training area with an obstacle

designed to replicate a stream crossing; and (2) limit other instream

crossings associated with maneuver operations and mobile and field

smoke training to areas which have been improved to minimize adverse

impacts. Finally, the Army will continue to conduct all accordance with

approved operating procedures, and use the FLW Installation Spill

Prevention and Response Plan to minimize adverse impact of any spill

that may occur in or near water resources.

5.5 Geology and Soils

The FEIS concludes that implementation of the Army's Preferred

Alternative will result in minor adverse impacts to soils and geologic

resources within FLW boundaries. These impacts include impacts to soils

as a result of erosion on lands disturbed for construction and training

activities, and the potential for impacts as a result of accumulation

of hydrocarbons released at the planned flame training range.

Geology and Soil Impact Mitigation Commitments

The rate of soil erosion will be reduced through the implementation

of BMPs during construction and continued implementation of the FLW

Integrated Training Area Management Plan. Planned construction has been

sited to avoid sensitive geologic areas. As stated above, the Army will

also continue to conduct all training in accordance with approved

operating procedures and use the FLW Installation Spill Prevention and

Response Plan to minimize the adverse impact of any spill that may

occur.

In accordance with Special Conditions 25 through 30 of the existing

MDNR Air Quality Permit #0695-010, the Army will also develop and

implement a Soils and Vegetation Monitoring Plan to monitor if there is

fog oil residue (total petroleum hydrocarbons or TPHs) remaining on

soil and vegetation. Additional information regarding this monitoring

requirement are provided in subsection K.4.2 of Appendix K, Volume III

of the FEIS.

5.6 Infrastructure

The FEIS documents that an increase in traffic volume and delays is

anticipated as a result of the BRAC action; however, the degree of this

traffic impact is not considered to be significant. The proposed action

includes planned improvements relating to utility system distribution

and collection systems. In consideration of these improvements, and the

fact that existing treatment and plant facilities have adequate

capacity to serve all current and reasonably foreseeable future needs,

no significant adverse impacts are expected to occur to on-post utility

systems. Energy, communication systems, and solid waste disposal

provided by outside sources will be adjusted by the suppliers in

accordance with all applicable laws and regulations concerning these

operations, and no significant adverse impacts to these systems were

identified by the EIS process. Energy consumption at FLW will increase,

but energy efficient facility construction, existing facility

renovations, and continued expansion of the natural gas system at FLW

will help to reduce energy usage, and no significant adverse impacts

are anticipated.

Infrastructure Impact Mitigation Commitments

The degree of traffic congestion problems will be reduced due to

improvements included as part of the proposed action construction

projects for the Combined Headquarters and Instruction facility plan

(e.g., improvements planned for the intersections of Nebraska Avenue

and First Street and Gate Street at Missouri Avenue). Realignment of

Nebraska Avenue and improving Gate Street will also help offset the

increased traffic volume expected to occur near the new consolidated

Headquarters area. FLW will ensure utility distribution and collection

systems are upgraded as required to accommodate the new facilities as

part of the BRAC

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construction program. All new buildings will meet applicable energy

conservation guidelines and standards.

5.7 Hazardous and Toxic Materials

The addition of BRAC activities to FLW will increase the volume of

hazardous materials used, handled, stored and transported on FLW over

current levels. This increase in hazardous materials will also result

in an increase in the amount of hazardous and special wastes being

removed from FLW for disposal through properly licensed and monitored

contract operations. The FEIS documents that all hazardous and toxic

materials, low-level radioactive materials, regulated medical wastes,

fuels, and special wastes will be handled, stored, transported and

disposed of in a manner which protects the environment and human

health, and in compliance with Army regulations and federal and state

laws and regulations.

The FEIS was expanded to include additional information regarding

the chemical characterization of liquid wastes generated by the

Chemical Defense Training Facility (CDTF), and to further quantify the

potential risks associated with the transportation of decontaminated

special waste by-products associated with the CDTF to off-post disposal

facilities. Information from that analysis is presented in subsection

5.2.2.8.5 (Volume I) and Appendix I (Volume III) of the FEIS.

Hazardous and Toxic Materials Impact Mitigation Commitments

No significant adverse impacts are anticipated, and no mitigation

is required. The Army will continue existing environmental management

programs that are designed to ensure that all such materials are

managed properly. These ongoing management programs and plans include

the FLW Hazardous Waste Minimization Program, Pollution Prevention

Plan, Hazardous Waste Management Plan and the Installation Spill

Prevention and Response Plan. In addition, the Army commits to the

disposal of wastes generated by the CDTF in compliance with guidelines

and criteria included in subsection 5.2.2.8.5.2, Volume I of the FEIS.

5.8 Munitions

Implementation of the Army's Preferred Alternative at FLW will

result in an increase in the type and quantity of live munitions,

obscurants and signals used at the post. The FEIS concludes that no

direct or indirect impacts on munitions storage or operational controls

are expected to occur as a result of this increase. The impacts of

additional munitions usage on the environment (such as impacts to

threatened and endangered species, human health, etc.) were evaluated

under the appropriate resource categories.

Munitions Impact Mitigation Commitments

Because there are no adverse impacts, no mitigation actions are

required under this evaluation category.

5.9 Permits and Regulatory Authority

The FEIS concludes that implementation of the Army's Preferred

Alternative will result in an increase in the number of permit

applications required to conduct training and a directly related

increase in the type and extent of compliance monitoring. This increase

in permit activity will require programming of additional fiscal

resources to prepare and manage all required permits. Compliance with

all permit terms and conditions will ensure that significant adverse

impacts to the environment do not occur.

Permits and Regulatory Authority Mitigation Commitments

The Army commits to the preparation and maintenance of all permits,

current or revised, required to implement and maintain the actions

included as part of the Army's Preferred Alternative (as well as all

ongoing mission permit requirements). Specific permits and regulatory

procedures identified in the FEIS (and summarized in subsection ES.7 of

the FEIS--Volume I) include: (1) MDNR Air Quality Permit #0695-010 for

fog oil operations; (2) compliance with Section 7 of the Endangered

Species Act; (3) National Pollution Discharge Elimination System

(NPDES) Permit; (4) Nuclear Regulatory Commission (NRC) Materials

License; (5) Land Disturbance Storm Water Permit; and (6) Nationwide

Permit (NWP) in accordance with Section 404 of the Clean Water Act

(CWA).

5.10.a Biological Resources (Federally-Listed Threatened and

Endangered (T&E) Species)

Federally listed Threatened and Endangered (T&E) species of concern

at FLW include Indiana bats, gray bats, and bald eagles. The FEIS

documents the results of studies conducted to evaluate impacts of

implementing the proposed action at FLW on these species. The U.S. Fish

& Wildlife Service (USFWS) issued a Biological Opinion (BO) on the

Armys Preferred Alternative on February 4, 1997. The BO concluded that

implementation of the Army's Preferred Alternative is likely to

adversely affect Indiana bats, gray bats and bald eagles. These adverse

effects are associated with obscurant training and planned construction

projects. The nature and extent of these effects are based on

conservative assumptions that over estimates risks and are fully

documented in subsection 5.5.3.11 of the FEIS (Volume I) and in the

referenced Biological Assessment (BA) and BO. The USFWS determined

these effect are not likely to jeopardize the continued existence of

the Indiana bat, gray bat, or bald eagle. No critical habitat has been

designated for these species in the action area, therefore, none will

be affected by the action.

Federally-Listed T&E Species Impact Mitigation Commitments

FLW will conserve T&E Species by: (1) Implementing all reasonable

and prudent measures (RPMs) that have been specified by the USFWS to

minimize take of Indiana bats, gray bats, and bald eagles; (2) adhering

to ``project design features'' that are specified as part of the

proposed action; (3) preparing and implementing an Endangered Species

Management Plan; (4) developing and implementing a biomonitoring plan

(as described in Appendix K, Volume III of the FEIS); (5) establishing

bat management zones around Freeman Cave; and (6) establishing a

Landscape-Scale Forest Management Policy for FLW. Compliance with RPMs

will be documented as required by the terms and conditions specified in

the BO.

5.10.b Biological Resources (Other Protected Species)

As defined in the FEIS for the proposed action, Other Protected

Species (OPS) include statelisted birds, mammals, and amphibians as

well as migratory birds including neotropical migrants (NTMs), raptors,

and shorebirds. Studies conducted to evaluate impacts of the proposed

action on representative species are described in subsection 5.2.2.11.B

and other applicable sections of the FEIS. Coordination with the USFWS

included consideration of NTMs. The FEIS concludes that implementation

of the Army's Preferred Action at FLW is likely to result in minor

adverse impacts to OPS. These impacts would be associated with direct

mortality of OPS as a result of vehicle operations, training

activities, and clearing associated with new construction. Impacts may

also be caused by increased forest fragmentation, and increased

disturbance to wildlife from training activities. Although these

impacts are

[[Page 28683]]

identified in the FEIS as adverse, they are not considered to be

significant as discussed in subsection 5.5.3.11.B.3 of the FEIS.

Other Protected Species Impact Mitigation Commitments

Although not required by regulation, FLW will prepare and implement

a Biological Indicators Monitoring Plan as described in subsection

K.4.5 of Appendix K, Volume IV of the FEIS to ensure significant

adverse impacts do not occur to OPS as a result of the planned action.

This Biological Indicators Monitoring Plan will be implemented at least

1 year prior to the commencement of smoke training at FLW and will be

conducted for a minimum of 2 years. Monitoring results will be jointly

reviewed with the regulatory agencies and the determination made if

additional monitoring is necessary using the Adaptive Management

Strategy as defined in Appendix K of the FEIS. FLW will also continue

to coordinate implementation of the planned action concerning measures

that can be implemented to minimize impacts to NTMs.

5.10.c Biological Resources (Wetlands)

Implementation of the Army's Preferred Action is expected to cause

minor adverse impacts to wetlands within FLW boundaries as a result of

physical degradation of wetland vegetation at specified stream

crossings and impacts to 0.14 acres of jurisdictional wetlands at the

CDTF construction site. However, these impacts are not considered to be

significant as discussed in subsections 5.5.3.11.D and 5.5.3.11.E of

the FEIS.

Wetland Impact Mitigation Commitments

FLW will continue to adhere to BMPs and other environmental

controls designed to minimize soil erosion and protect surface waters,

soils and aquatic resources and wetlands during training and

construction (subsections 5.1.4 and 5.5.1.3 of the FEIS). In addition,

the Army will comply with requirements of Section 404 of the Clean

Water Act prior to initiation of the construction phase of the range

road stream crossings and the proposed CDTF project.

5.10.d Biological Resources (Other Aquatic and Terrestrial Resources)

The FEIS concludes that implementation of the Army's Preferred

Action may result in minor adverse impacts to other aquatic and

terrestrial resources within FLW boundaries as a result of training and

construction activities. However, these impacts are not considered to

be significant as discussed in (subsections 5.5.3.11.D and 5.5.3.11.E

of the FEIS).

Other Aquatic and Terrestrial Resource Impact Mitigation Commitments

No significant impacts are expected to occur, and no specific

mitigation actions are required. However, continued compliance with

federal, state and local permits and regulations, including Missouri

Clean Water Commission requirements will be maintained through the

continued use of BMPs and other environmental controls as described in

subsection 5.3.2.5.A of the FEIS. In addition, as previously stated in

this ROD (section 5.5) the Army will also develop and implement a Soils

and Vegetation Monitoring Plan to monitor if there is fog oil residue

(total petroleum hydrocarbons or TPHs) remaining on soil and

vegetation. Additional information regarding this monitoring

requirement is provided in subsection K.4.2 of Appendix K, Volume III

of the FEIS. This will provide added assurance that fog oil training

does not result in any significant adverse impact to the general

environment.

5.11 Cultural Resources

Phase I archaeological surveys have been conducted at locations

where BRAC-related training and construction activities will occur on

FLW. The FEIS documents that implementation of the Army's Preferred

Alternative will not result in the alteration, renovation, or

demolition of any historic buildings or structures, and activities will

not impact any known significant (National Register eligible) cultural

resources. Coordination with the Missouri State Historic Preservation

Officer resulted in a finding of no effect for planned construction

activities.

Cultural Resources Impact Mitigation Commitments

Training activities will continue to be conducted in accordance

with FLW Regulation 210-14, and the FLW Historic Preservation Plan.

Therefore, if archaeological materials are identified during any future

construction or training activity, the Army commits to stopping the

activity, and contacting the FLW cultural resource specialist to

determine an appropriate course of action consistent with all

applicable cultural resource laws and regulations.

5.12 Sociological Environment

The FEIS documents that the majority of direct sociological

resource impacts will occur in Pulaski County, primarily in the St.

Robert/Waynesville area. Anticipated growth and the associated increase

in demands placed on the public service delivery systems in the area

can be adequately accommodated by existing community resources and

proper planning and programming for expansion. Impacts on school

enrollment will primarily occur within the Waynesville R-VI District,

which has made, or is in the process of making, plans to address the

expanded enrollment anticipated to occur as a result of the planned

action.

Sociological Environmental Impact Mitigation Commitments

No significant adverse impacts are excepted to occur under this

evaluation category, and therefore, no Army mitigation actions are

required. However, mitigation of minor adverse impacts will be

partially accomplished through the phased implementation of the planned

action. The construction program is scheduled to occur over a two year

period, and the BRAC-related population will be relocated to FLW in

phases over a 6-9 month period. In addition, the time between the

announcement of the action to the public, and implementation of the

initial phases of the action is sufficient to provide the opportunity

for infrastructure and land use planning and programming. Planning

assistance, in the form of grant funding under the auspices and

assistance of the DoD Office of Economic Adjustment, will also be

available to the local communities that are potentially impacted by the

planned BRAC action at FLW.

5.13 Economic Development

The FEIS documents the significant beneficial economic impacts of

implementing the Army's Preferred Alternative that will occur within

the nine-county economic Region of Influence (ROI) surrounding FLW.

Economic impacts described in the FEIS relate to incureased income,

employment and business volume. Other major indirect impacts include

expected increases in the area's real property tax base and local tax

revenues. The majority of the direct economic impacts are expected to

occur locally in Pulaski County, primarily in the St. Robert/

Waynesville area.

Economic Development Impact Mitigation Commitments

No adverse economic impacts are expected to occur, and therefore,

no Army mitigation actions are required.

[[Page 28684]]

5.14 Quality of Life/Human Health

Implementation of the Army's Preferred Alternative will result in

an increase in the type and amount of military training activities to

occur within the existing training range areas at FLW, which will

result in increased use of those areas. These increased use levels are

expected to result in an adverse impact by imposing additional

limitations on the recreational use (e.g., hunting, fishing and other

activities) of these areas while training occurs

Elements of the Army action identified in the FEIS that may result

in direct or indirect effects to human health include: (1) Fog oil

obscurant training; (2) training with toxic agents at the CFTF; and (3)

Flame Field Expedient training. The FEIS, and supporting documentation,

provides extensive analysis and consideration of the potential effects

of fog oil obscurant training on military trainers, students, and the

general population within the FLW cantonment area and beyond the

installation boundaries. Based on these analyses, the FEIS concludes

that trainers and fog oil training students will not be adversely

affected because they follow standard Army operating procedures while

conducting training exercises, including the use of protective masks

when exposed to relatively high concentrations of fog oil (in excess of

5 mg/m\3\). The FEIS concludes that human health effects are not

anticipated for the general population within the cantonment area, or

for those individuals beyond the facility boundary. This conclusion is

based on consideration of maximum potential exposure of those

populations as predicted by highly conservative fog oil dispersion

modeling. Also, conditions in the MDNR issued Air Quality Permit #0695-

010 for fog oil obscurant training are specifically designed to reduce

the potential for exposure to the general public. In the unlikely event

that the surrounding public is inadvertently exposed to fog oil, the

exposures are anticipated to be infrequent and of short duration,

thereby avoiding any potential for significant adverse impacts.

At the time the FEIS was published, the National Academy of

Sciences (NAS) Subcommittee on Military Smokes and Oscurants of the

Committee on Toxicology (``Committee'') had not completed their

evaluation of the human health effects of fog oil. The NAS Committee

report was, however, released before the completion of this ROD. A

careful review of the Committee report reveals that their conclusions

regarding the health effects of fog oil were very similar to those

describe in the FEIS. The committee developed an 8 hours per day, 5

days per week, Permissible Exposure Guidance Level (PEGL) of 5 mg/m\3\

for soldiers involved in training. The report noted that this level is

often exceeded around the generators when soldiers train, and therefore

recommended careful adherence to the Army's existing respiratory

protection policy.

The Committee recommended a Permissible Public Exposure Guidance

Level (PPEGL) of 0.5 mg/m\3\ (exposure for 8 hours per day, 5 days per

week), which is considered to be safe for sensitive individuals in the

general public. Extensive air modeling using deconservative assumptions

was completed during the preparation of the application for the air

permit for fog oil training at FLW. Modeling results demonstrated that

fog oil concentrations at the boundary of FLW and at the boundary of

the cantonment area will not exceed short-term and long-term exposure

standards developed by the Committee for the general public. Field and

scientific studies document that of fog oil from smoke training onto

vegetation is minute. As concluded in the FEIS, and supported by

conclusions of the NAS Committee on toxicology, adverse health effects

to the general public are not anticipated to occur to those living or

working within the FLW cantonment area, or those living outside the FLW

boundaries.

Adverse health impacts to the general public as a result of toxic

agent training at the CDTF are not anticipated. As documented in the

FEIS, this training activity is rigidly controlled to protect human

health and safety of the instructors, soldiers that are trained, and

the general public. The FEIS notes that this training activity has been

accomplished for the last 10 years at Fort McClellan without an

incident that threatened the health of any individual either inside or

outside of the CDTF facility.

Quality of Life/Human Health Impact Mitigation Commitments

No significant adverse impacts are expected to occur under the

``Quality of Life'' evaluation category and therefore, no mitigation is

required for the Quality of Life component of this evaluation category.

No significant adverse impacts are expected to occur to human

health as a result of implementation of the Army's Preferred

Alternative. However, in response to comments received from review

agencies and the general public on the Draft EIS, the FEIS identifies a

number of measures that will be implemented by the Army to ensure that

significant adverse impacts do not occur. The Army commits to

constructing and operating the CDTF and flame field expedient training

facilities in full compliance with the protective measures described as

part of the Army's Preferred Alternative. An impervious liner will be

constructed under the flame range area to ensure that groundwater

supplies are not adversely impacted by this training activity.

With regard to fog oil obscurant training, the Army commits to the

full development, coordination and implementation of the Human Health

Monitoring Plan as summarized in subsection 5.2.2.15.A and 5.2.2.15.B

of the FEIS. The Army commits to additional sampling, mutagenicity

testing and chemical analysis of fog oil smoke to confirm that no

significant chemical transformations occur. The methodology used for

testing and analysis may be modified with concurrence of USEPA if it is

determined that other methodologies are more suitable and will produce

more accurate data. The referenced testing and analysis is not expected

to further assist in making an informed choice among the training

alternatives analyzed in the FEIS. However, the results of this

additional testing will be used and evaluated in accordance with the

adaptive management strategy procedure described as part of the Human

Health Monitoring Plan (see reference above). As stated in subsection

5.2.2.15.B.1 of Volume 1 of the FEIS (top of Page 5-138) the Army

commits to completing this additional testing and analysis prior to

implementation of fog oil training at FLW.

If the results of the testing described above result in exceedance

of any established health criteria, the Army commits to developing and

implementing a supplemental air monitoring plan (beyond the

requirements of the Air Monitoring Plan to be implemented in accordance

with the MDNR Air Quality Permit #0695010 for fog oil training) for any

chemical constituents of concern.

The Army will develop a Public Awareness Program to inform the

public in the surrounding community and those living at, working at, or

visiting FLW about fog oil obscurant training, and the potential health

risks associated with exposures to fog oil. Appendix L has been

included as part of Volume III of the FEIS to describe the intent and

general scope of the Public Awareness Program. As stated in Appendix L,

the Public Awareness Program will be implemented a minimum of three

[[Page 28685]]

months prior the initiation of fog oil training at FLW.

5.15 Installation Agreements

The FEIS concludes that implementation of the Army's Preferred

Alternative will result in a requirement to develop new Intraservice

and Interservice Support Agreements among the various components to

conduct operations at FLW. No adverse impacts are anticipated, since

these agreements are designed to ensure that all parties are aware of,

and comply with all applicable procedures governing ongoing operations

at FLW.

Installation Agreement Impact Mitigation Commitments

No adverse impacts are expected, and therefore, no mitigation is

required.

5.16 Operational Efficiency

The collocation and consolidation of the U.S. Army Engineer School

(existing at FLW) with the relocated Chemical School and Military

Police School as specified in the Army's Preferred Alternative provides

for the maximum amount of interaction among the school staff and

students. This increased positive interaction will substantially

improve the synergism (operational efficiency and effectiveness) as

described in applicable sections of the FEIS.

Operational Efficiency Impact Mitigation Commitments

No adverse impacts are expected, and therefore, no mitigation is

required.

6. Conclusions

On behalf of the department of the Army, I have decided to proceed

with actions required to relocate the U.S. Army Chemical School and the

U.S. Army Military police School to FLW. I have carefully considered

the FEIS, supporting studies, all comments provided during formal

comment and waiting periods throughout the EIS process, and the NAS

Committee report. Based on this review, I have determined that the

Army's Preferred Action (including implementation of the Optimum

Training Method Alternative, the Army's Proposed Land Use and Facility

Plan (Combined Headquarters and Instruction), and the Phased Move

Alternative) strikes the proper balance between the necessary

protection of the environment, and the national defense interest of

maintaining the ability of the Chemical School and Military Police

School to complete mission essential training activities. Furthermore,

I have determined that the Army has identified and adopted all

practicable means to avoid or minimize harm to the environment that may

be cased by implementation of the planned action.

Dated: May 15, 1997.

Robert M. Walker,

Assistant Secretary of the Army (Installations, Logistics &

Environment).

[FR Doc. 97-13802 Filed 5-23-97; 8:45 am]

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