Navy/Marine Corps Munitions Response RI-FS Guidance

Bryan HarreNaval Facilities Engineering & Naval Facilities Engineering & Expeditionary Warfare Center

MR RI/FS Guidance

Provide guidance on the Navy/Marine Corps RI/FSs for the MunitionsNavy/Marine Corps RI/FSs for the Munitions Response Program (MRP)

Additional training offered by CECOS class “AdvancedCECOS class Advanced Munitions Response Site Management Course”

htt // t il/ t / f / /https://www.netc.navy.mil/centers/csfe/cecos/ Draft RI/FS Guidance is available to RPMs on the

NAVFAC File Transfer SystemContact your RPM for a copyContact your RPM for a copy

Thanks to NAVFAC MR Workgroup, NAOC, and Battelle

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DoD/EPA UXO Management Principles (1)p ( )

DoD and EPA agreed that DoD will:• Conduct response actions when necessary to

address explosives safety, human health, and the environment

• DoD legal authorities include CERCLA, DERP, and DDESB

• A process consistent with CERCLA and these management principles will be the preferred response mechanismresponse mechanism

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DoD/EPA UXO Management Principles (2)p ( )

DoD munitions response actions must be i t t ith th NCPconsistent with the NCP

• Removal action alternatives will be evaluated under the criteria set forth in the NCPunder the criteria set forth in the NCP, particularly NCP §300.410 and §300.415

• Approved ESS required for TCRA, NTCRA, and remedial actions involving explosives safety hazards, particularly UXO

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DoD/EPA UXO Management Principles (3)p ( )

Permanent record of data gathered and a l dit t il f ti t d t l iclear audit trail of pertinent data analysis

and resulting decisions and actions are requiredrequired• To maximum extent practicable, permanent

record shall include sensor data that is digitally-recorded and geo-referenced

Explosives safety, cost, and/or technical li it ti li it th bilit t d tlimitations may limit the ability to conduct a response and thereby limit the reasonably anticipated future land uses

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anticipated future land uses

DON MR Policy in OP5

Use most appropriate available technologies to detect and remove MECtechnologies to detect and remove MEC consistent with future land use Munitions response actions for change-of-p g

use must be compatible with explosive hazards known or suspected to be present Real property known or suspected to

contain MEC and/or MPPEH will not ll b t f d l d f DONnormally be transferred or leased from DON

control until a munitions response consistent with the future land use has

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consistent with the future land use has been completed

Uniform Federal Policy for Quality Assurance Project Plans (UFP-QAPP)j ( Q )

Developed by EPA, DoD, DOE Required for use by DoD for Required for use by DoD for

environmental data collection, including those from an MR projectproject

Contains and describes in detailspecific data requirements or

th i f ti th t t bother information that must becollected to demonstrateconformance to requirements

• 37 required elements into 37worksheets

• Emphasis on systematic

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planning

DERP Management Guidance

Issued in March 2012I l t li Implements policy, assigns responsibilities andresponsibilities, and provides guidance and procedures for pmanaging DERP Establishes funding g

eligibility Requires FS to

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evaluate UU/UE

NERP Manual

Issued in August 2006 (currently under revision)

Summarizes the organization and responsibilities of DoD and DON offices and provides terminology

d d d iand procedures used in implementing the ER program

Discusses funding eligibility, priority setting reporting andpriority setting, reporting, and information management systems

Comprehensive reference for the DON user to properly identifyDON user to properly identify, investigate, and select protective and cost-effective remedies for ER program sites

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program sites

Scoping the RI/FS (1)

Goals of RI/FS scoping are to:• Agree on reasonably anticipated future land

use;Describe the type and content of studies• Describe the type and content of studies needed to initiate response actions and determine nature and extent of MEC/MC and associated hazard/risk;

• Determine if there is a need for remedial/ removal actions; and

• Determine appropriate response mechanisms and authorities

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mechanisms and authorities

Scoping the RI/FS (2)

What about project scoping?• The best way to ensure that a project• The best way to ensure that a project

meets its goals is to have project planning meetings with all the p g gstakeholders (e.g., land users, data producers, decision-makers)

• Scoping ensures that all needs are adequately defined

• The penalty for ineffective planning often is greater conflict and extensive

ki hi h lt i i d

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reworking, which results in increased cost and lost time

Underwater MRS Characteristics

Before you investigate, knowit ’ i tyour site’s environment

• Ocean, bay, river, lake, island• Depth currents wave action• Depth, currents, wave action,

tides, water clarity, turbulence• Local weather

Vieques Island Live Impact Area. Photo courtesy of US

Navy.

• Bottoms (soft, hard, sediments)• Habitat (sea grass beds, coral

reefs, open bottom, swamps, marshes)• Inhabiting biota (especially T&E

species) UXO laying proud on rock

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species) bottom. Photo courtesy of US Navy.

Available Terrestrial Templates

Six SOW templates available at NAVFAC MRP Portal: https://portal.navfac.navy.mil/portal/page/ portal/NAVFAC/NAVFAC_WW_PP/NAVFAC_NFESC_PP/environmental/ERB/MRP, each developed by MR Work GroupWork Group

SOW templatesrelevant to RI/FS:• RI/FS• UXO Quality

AssessmentAssessment• Small arms

RI/FS

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Systematic Planning Process and Project Quality Objectives (PQO’s)j Q y j ( Q )

Systematic planning

PQOs & data collection State the problem

planning requirements come from the

j t t i

Step 1

Step 2Identify the goal of study

Id if i f i iproject team in the form of DQO’s/PQO’s

Step 3

Step 4

Identify information inputs

Define study boundaries

Every project phase identifies them, e.g., PA

Step 5

Step 6

S

Develop analytic approach

S if f tg

and SI PQO’s were developed for your site Collect data

Step 7 Specify performance or acceptance criteria

Develop plan for obtaining data

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CSM Example – Waikane Valley

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Graphic courtesy of US Navy.

Managing Uncertainty

Uncertainty will always be there both going into and

The objective of the RI/FS process is notthere, both going into and

coming out the RI• MRS history may be unknown

RI/FS process is not the unobtainable goal

of removing all uncertainty, but rather t th i f ti

y ywith many unknown factors such as munitions quantities and types dud rates etc

to gather information sufficient to support an

informed risk-based management decision and types, dud rates, etc.

Anticipate not all RI planning assumptions will be valid

gregarding which

remedy appears to be the most appropriate

for a given MRSp• Even the most perfectly

planned project needs to id ti i

for a given MRS. Source: EPA RI/FS Guidance (1988)

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consider contingencies

Terrestrial RI Road Map

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Investigation Considerations –MECMEC

Topography/terrain• Instrument limitations, e.g.,

mountainous conditions will preclude use of wheeled cartspreclude use of wheeled carts

Large flat areas bestinvestigated with towed arraysinvestigated with towed arrays

Extreme terrain conditions. Photo

courtesy of Montanacourtesy of Montana National Guard.

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Towed EMI array. Photo courtesy US Navy.

Investigation Considerations –MEC (2)MEC (2)

Geology• Magnetometers are sensitive to iron-

bearing geology Vegetation

Density determinestype of investigationinstrument usedR l t l Removal not alwaysdesired or possible

Vegetation removal crew. Photo

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courtesy of US Navy.

Investigation Considerations –MEC (3)MEC (3)

Investigations generate ESQD arcsO d ff i ESQD b i On- and off-site ESQD encumbrance requires PTR closures,buildingbuildingevacuations,etc.• Can be

a publicaffairs andaffairs andlogisticschallenge

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Graphic courtesy of US Navy.

Detectors

TypesM t t d di t• Magnetometers and gradiometers

• Electromagnetic induction (EMI)• Ground penetrating radar (GPR)• Ground penetrating radar (GPR)• Multi/Dual-sensor systems• Other, e.g., sonic systems, infrared sensors, , g , y , ,

explosive “sniffers”, neutron backscatter Applications

• Terrestrial (hand-held, man-portable, or towed)

• Underwater

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Underwater

Advanced Sensors

Designed for classification• Measure complete decay signal• Fixed arrays for precise positioning• Multi-axis

transmit/i ilreceive coils

for completetargettargetillumination

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Photo courtesy of ESTCP.

RI Data Collection –Terrestrial MEC Processes

Grid layoutV t ti l

Anomaly reacquisition and Vegetation removal

Surface removalreacquisition and investigation MEC/MPPEH GSV

Geophysical survey d d t ll ti

MEC/MPPEH management Magazineand data collection

Data processing,l i d

Magazine inspections and security

analysis, and anomaly selection

y

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RI Conclusion

Has the project team:• Identified areal extent of contamination?• Agreed on reasonably anticipated future land

use?use?• Described the type and content of studies

needed to initiate response actions and determine nature and extent of MEC/MC and associated hazard/risk?

• Determined if there is a need for remedial• Determined if there is a need for remedial actions?

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Purpose of Evaluating Removal & Treatment Technologies During the FSg g

Develop and evaluate potential remedies th t tl d i ifi tl dthat permanently and significantly reduce the threat to public health, welfare, and the environment;environment; Select a cost-effective remedial action

alternative that mitigates the threat(s); andalternative that mitigates the threat(s); and Achieve consensus among DON, EPA, state,

and local authorities regarding the selectedand local authorities regarding the selected response action

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Response Remedial ProcessPotential Alternatives (1)

No action None Not applicable

Response Action

Remedial Technology

Process Options

DetectionMagnetometry

Surface removal

EM induction

Removal Pick up w/wo Hand excavationSurface removal Removal p

BIP w/wo engineering controls

Treatment Consolidated shot

C i d d i h bContained detonation chamber

Response Remedial Process Potential Alternatives (2)

pAction Technology Options

DetectionMagnetometry

EM inductionEM induction

Subsurface removal RemovalHand excavation

Mechanical excavation

Hand excavation

Treatment

BIP w/wo engineering controls

Consolidated shot

Contained detonation chamber

E i iFencing

Land use controls

EngineeringSignage

Deed restrictions

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Institutional Notices

Educational materials

Example Technology ComparisonTechnology Description EffectivenessHand excavation Digging individual anomalies

using commonly availableMedium: It can be thorough and provides good data onusing commonly available

hand tools.and provides good data on MEC collected.

Mechanized removal of

This method uses commonlyavailable mechanical

Medium: Used in conjunction with hand excavation when

individual anomalies

excavating equipment, such as a backhoe or excavator.

soil is hard. Method works well for excavation of single anomalies or larger areas of heavy ferrous metalheavy ferrous metalconcentration.

Mass excavationand screening

Armored excavation andtransportation is earth

High: Process works very well in areas of heavyand screening transportation is earth

moving equipment that has been armored to protect the operator and equipment f i t ti l

well in areas of heavy concentration of MEC. Can separate several different sizes of material, allowing for l titi il t bfrom unintentional

detonation.large quantities soil to be returned with minimal screening for MEC.

LUCs (1)

Any type of physical, legal or administrative mechanism that restricts the use of and accessmechanism that restricts the use of and access to real property, preventing exposure to hazardous substances above permissible levelsp• Compatible with selected remedy and land use

Consider life-cycle costs before implementing LUC database (DoD policy) Ensure public involvement Land-use changes In CERCLA cleanups, LUCs include engineering

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controls (ECs) and institutional controls (ICs)

Many Different Signs

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Screening of RAs (1)

Identifying, evaluating, and selecting i t dappropriate remedy

• Identify and review remedial technologylt ti / th d th t i talternatives/methods that are appropriate

to the site(s) and the threat it posesS lt ti / th d i th• Screen alternatives/methods using three broad criteria (effectiveness, implementability cost)implementability, cost)

• Select a reasonable number of alternatives for detailed analysis

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alternatives for detailed analysis

Detailed Analysis of RAs

Once a limited number of viablenumber of viable alternatives have been developedbeen developed and ARARs have been identified, the alternatives are evaluated

i t th EPAagainst the EPA 9 criteria

Remotely-operated subsurface MEC removal. Photo courtesy of US Navy.

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removal. Photo courtesy of US Navy.

CERCLA Evaluation Criteria –40 CFR Part 300.430(e)(9)(iii)40 CFR Part 300.430(e)(9)(iii)

Overall protectionThreshold Criteria

Overall protectionof human health

and the environment

Compliancewith ARARs

Primary Balancing CriteriaLong-term Reduction of Short term Ability tog

effectiveness& permanence

toxicity, mobility orvolume by treatment

Short-termeffectiveness

Ability toimplement

Cost

Modifying CriteriaState Community

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State acceptance

Community acceptance

Overall Protection of Human Health and the EnvironmentHealth and the Environment

General evaluation of the alternative’s ability t t d i t h h lthto prevent adverse impact on human health and the environment Must be met in order Must be met in order

for an alternative tobe eligible for selectionbe eligible for selection

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Brett and Kanan Harre. Photo courtesy of the

proud dad.

Analysis of Alternatives –ExampleExample

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RI Report (1)

Site characterization documented in a RI R tReport• Usually provided in preliminary/internal draft

for Navy review draft for full regulatoryfor Navy review, draft for full regulatory review, and final after comments are addressed

• RI report can be combined with the FS report to form a RI/FS report, but the RI and FS

t l b b itt d t lreports also can be submitted separately• Sample RI report included in student guide

and on course CD must be adapted for use

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and on course CD must be adapted for use with MR project

RI Report (2)

The RI report presents• Methods used for the RI• Updated CSM resulting from the investigation• Results of the risk/hazard assessment• Results of the risk/hazard assessment• Determination of whether further remedial action

is needed, and if so, recommended RA , ,Objectives

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FS Report

Results of the FS will be documented in a treport

• Usually provided in preliminary/internal draft for Navy review, draft for full regulatory review, and y , g y ,final after comments are addressed

• FS Report can be combined with the RI report to form a RI/FS report but the RI and FS reports alsoform a RI/FS report but the RI and FS reports also can be submitted separately

• The RI/FS report is a significant document, as it forms the basis for the selection of the remedy and the decision documents

Again thanks to the members of NAOC for

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Again, thanks to the members of NAOC for their review and comments!!