Now one of the things that I wanted to do. I would be remiss if I did not.
Highlight the fact that this is part of an ongoing seminar series.
So the Epa is sponsoring a Federal Facilities Academy, which is comprised of 12 classes.
In all, there will be 11 webinars that we are hosting live through the cleanup Information network. Stay!
Is one of them, and then we have a 3 day in-person, classroom, training, opportunity which is open to a limited audience.
So this slide does have the full schedule of the webinars. We've posted the flyer for the Full Academy series as well on the seminar home page i'll put that in the meeting chat in just
a moment as well. So you can download it from there and you can. if you're able to complete all of the online classes, and that in-person delivery, also receive a special certificate of completion for
the Federal facilities. academy, Now i'd like to walk through that explanation in just a little bit more detail, because we do know not.
Everyone can take everything, and not everyone is eligible to take all of the classes.
So, as I said, there are 11 webinars. Those are all open to the public, and one classroom delivery, which is part of the Academy which is open to a limited audience for the online webinars.
You may take them live online just as we're delivering one today, or you may replay a recorded version that will be posted on the clue in archive page both versions, whether it's live or replay the archive will count
for credit for the in-person classroom training, you must participate in that event in person, and that is open to a limited audience of only Epa states, tribes and other federal agencies.
So if you are not working from one of those organizations, you will be ineligible to take that in-person delivery.
But you can take all 11 webinars order to document your participation.
You can get an individual participation certificate for any and all of the online webinars.
I'll talk about how to do that at the end but essentially you fill out the feedback form, check a box to certify you were here, live or replayed the whole thing, and will issue a certificate for the
webinar. and then, if you either attend, play whatever combination all of those online 11 webinars and you participate in person for that classroom training delivery, you will then be eligible for the academy certificate
which acknowledges that you did both the online courses, and that in-person delivery.
And there were questions about When that In-person Delivery will be, we do have one currently scheduled for June of this year in Denver, and i'll be including a link to that Delivery in the meeting
chat in just a moment. So with those quick reminders, I think we are ready to get started with our class today.
So at this time I'd like to introduce your first Instructor Doug Maddox, who's coming to us from Epa's Federal facilities. restoration reuse office.
So, Doug, I can see that you are on camera so i'm gonna switch the view over to you, and then I will ask you to share your screen if you can.
I'll confirm, and we can see your slides and you can get started with the class today, and the slides are up and look good.
Go ahead, Doug. All right. so welcome everyone introduce myself first and then I'm gonna Emily Royal to come on camera and introduce yourself.
I'm the I mean epa headquarters Federal studies, Restoration Reuse office at headquarters. I've been there since about 2,002 prior to that I worked for the Navy and the Army corps
of engineers. so i've been doing munitions work for a while.
I'm an engineer by training and I do program policy is part of my job, which is a lot of what we're talking about here.
I also do a lot of technical support to our regional offices and and states, and whoever else needs it, and I'll probably run into quite a few of you.
Project team meetings and the like. so hey? emily Why don't you introduce yourself?
Sure. Good afternoon, I'm Emily Royal i've been with the Federal facilities.
Restoration Reuse office for a little under 2 years now coming from the State of Tennessee Division of water resources.
Before that I did private contracting, and i'm also an engineer by trade, chemical engineering, and i'm happy to help dug with his presentation today.
So Emily is kind of in training to learn all the munition stuff, and and help me out quite a bit.
I I don't i'll be around for a while longer, but not that long.
So we developed this course mainly, for our Rpm.
Is to kind of bring them up to speed and talk about what's the same with meunitions.
What's different with munitions and kind of give them that overview from a regulators perspective.
We've given this online version once also there's some modules in our in-person course, which is not as extensive.
We normally had an Rpm. doing our case study.
I get to do that today, and we had so a little bit of difficulties scheduling that So you're going to get to hear me talk a lot today. But let's why don't we get to it and I think first of
all, Emily, you can take this one sure. How many years of experience do you have with munitions?
Clean up. There should be a pole popping up. I am clearly in the to 2 years, and Doug is firmly in the more than 10 years.
So we'll wait a moment for for answers to come in just gentle reminder.
If you happen to be on a mobile device sometimes there's an additional pop-up, or you may have to manually navigate to that pole looking for the 3 dots more menu and you'll see an option
to launch that poll. but Emily looks like almost 80% of the audience has responded at this time.
Fantastic. let's see it all right let me go ahead and end that poll and share the results.
Okay, 60% in under 2 years. So there's a lot to learn good.
Well, that's great. So I I think we're hitting great audience, Even those who have been around for more than 10 years.
Hopefully. you will learn some stuff, and if I get it wrong please feel free to point it out.
We'll take questions I can't try to take questions as we go.
Emily's gonna help me my monitoring that if It's something I can answer quickly as we're going.
I will, if it. You know we do have a Q. and a session at the end, or we can try to get to as many as possible some questions we may not be able to answer.
Here. It may take some other other coordination or something, but we will get back to you on that.
We are tracking all the questions submitted so let's see get this going.
So this is our course. We're going to talk about you know our munitions.
Response. authorities under Circlea talk through a little bit of the structure of the Mmrp program.
If you already know that you know and just just follow along that's the first part. where then, we're going to take a short break after talking through that I am recovering from back certain ratio we had to stick a break in
the middle. So I can stretch. out a little bit we're gonna do a case study, talk through some very interesting issues that have gone on at Fort Oord over time, and then we're gonna come back into this presentation talk through some other specific
rags and guidance. Talk about detection technologies a little bit about what they are, and why, as well as some policy implications.
There. Ufp quap if you don't know what that acronym is, you will know it very soon working in this area.
Talk about some partnerships we have going on and then, end out with senior unique challenges and kind of why does Doug's phone ring quite a bit with with some of these challenges.
So let's keep going. This is a cartoon I saw quite a while ago. have used it in some presentations over the years, and then, as I went to a site, I realized huh?
That really does exist. If you have a small screen, I apologize.
If you have a bigger screen, if you can see the white flags, those are anomalies.
Some of them ended up being mortars that we found, So we do have really current.
And this was taken probably within the last 8, 8 to 10 years, and has been since cleaned up.
It was an area they built over and didn't realize that There was munitions areas there when they built a recreation area over top of it.
So here we are. let's talk a little bit about circle
My favorite topic, Removal actions under 104 we'll talk about some remedial actions.
Federal facility specific is 120 that's kind of the world.
I live in mostly, but we do get into other. We have some private munitions clean up and work that go on that we do get involved with.
If you were, you know, remember, on-site options are exempt from administrative and permitting requirements.
But we do Have to meet substantive requirements under circle If there's record ars or whatever the key point, it's no different.
It's the same process for munitions we're not doing.
There's not a different circle we're not doing circle alike.
I know that when I came on board and was doing this in the late ninetys even early.
2 thousands, you know. Dod was kind of doing a circle like process.
No they're we're doing circle it's the same process, different contaminant different challenges, different technologies.
But you know, same regulatory process. so you don't have to relearn that you just have to make it figure out how it fits, and where everything goes together.
And hopefully, this will help somewhat. So here we are first to talk about removal actions.
We tend to with circle you know back in the early days when I was he doing this work for the army All munitions work was a removal action that didn't really fit the way circle was designed it's it's more
of a combination of removal, and then, you know, doing, finishing out with a remedial action.
But for removal actions we have emergency that's pretty much what it sounds You got to respond.
You got to get there we will talk later a bit about the munitions rule and some exemptions related to emergencies.
Time critical removeals the key. There is less than 6 months to plan.
It may take years to implement but you really you're getting started quickly, and then the 9 time critical is greater than 6 months plan.
That's more of the when you talk about a removal action usually what we're referring to
So this is the world I mostly live in for remedial response.
We're trying to get a permanent remedy through our investigation.
In response. we start with our P. A. or si or rfs on, on out to record a decision.
So we're really looking to implement you know the type of remedy.
It may include land use controls, institutional control, soil of groundwater remediation.
But you have to meet Circle and Ncb. Criteria and Ncp.
Expectations which we will talk about next, but first we're going to talk about executive order.
12580. And my fun thing! this is the delegation of circle authority and a lot of functions.
It does get kind of complicated where things are delegated between.
You know, Federal landholding agencies, stat story functions delegated Dpa administrator.
But what really You need to understand is This is Why, at a cleanup site. The Dod save It's their land, you know their site is the lead date.
They're they're the lead. agency responsible for cleaning up the site, you know, and then they've got to address responsibility when transferring the property.
Delegation of authority is subject circle loan 20, which is the Federal facility. Section
So this Federal agency will conduct, you know, the circular response action, and at Npl.
Sites and national priority list sites which there are quite a few, I think almost two-thirds of the Dod sites have munitions components on them.
So we have quite a few munitions components on that we're actually looking through our databases and reconciling things and trying to track with the Ud making sure we're tracking everything but for npl sites we
have to concur and approve the renewal action That's the difference between that and a non npl site, and we have Federal facility agreements that are in place at these sites that we've come to agreement
and and their dispute provisions and on and on and you know Epa at the end of the day at Mpl. Sites.
If we don't agree, Epa can select the remedy and we also have under the dispute, we do all have the final authority for decision.
Usually we work, and most cases work jointly and work through it.
Even if we do have some disputes we we get to work through that.
That's part of what my office does is We work with our regional offices and the headquarters Dod offices.
Try to keep things moving and to get them solved quickly and honestly.
We want to get the work done. I get the sites cleaned up.
State and tribal governments are also consulted and involved.
They have their own independent authorities. Some are actually signatories to the Federal facility. agreement.
And in some cases depends on how it's set up we already have a couple of questions.
Yeah. When we hit a few questions you can answer them.
Does the Epa have geophysical capabilities internally related to Nmrp.
No, we don't do. We have some geophysics equipment and stuff like that with our environmental response teams.
Some of our contractors can have that Epa in-house.
No? Okay. And then, how do you fit munitions into circle under a risk range?
I'm gonna talk about risk and and where it stands circle it's so munitions are an acute risk.
And it's it doesn't fit well with has it ranking scoring.
We can't score a site for a munitions explosive hazard.
The ones that have been listed are either for you know components of the explosives or other contaminants or such like that.
So it's a little riskism and risk assessment I will cover some later.
It gets a little bit different because it's not in it's, not in a chronic, You know long-term type of risk that we're looking for, and we don't have any cleanup levels for munitions,
Ok, so to be continued. Those are all the questions for now.
Okay, great. Those are really good questions. And we could probably spend a lot of time on each talking through.
So if I don't get your questions answered all the way we can certainly talk afterwards.
We can ask her in the Q. and a i'm very available to help you work through.
You know some of these problems and help you understand them better.
So back to Circle and and Cp. National Constituency.
Plan. Ncp. expectations that we're going to treat principal threats.
We'll say this very clearly. munitions can be a principal threat. Waste talk about it later.
We did have some issues trying to resolve this it's a site specific call
But you know they can be in a lot of cases they are
So the other Ncp. expectation is we want to use a combination treatment and land use controls.
Ics were appropriate. treatment is really preferred.
And you know, luxury sees if we need to use them where they're appropriate.
Also encourages use of innovative technologies which I think the Dod I mean, i'm a more preprogram is done really well with investigative technologies developing some of the more advanced sensors and capabilities.
I will talk through that somewhat in the last section of this.
This course. So talk a bit now about duties military munitions. response program.
Mmrp. i'm gonna go through some definitions talk through.
You know some of the key regulatory drivers, I mean, we really looking at circle for the main cleanup driver.
We do do some work under record, and others and we'll talk a little bit about all the other policy, and guidances are out there.
So first, what is the Mmrp program? duty has their defense.
Environmental Restoration program. It really has 2 parts. This is the insulation Restoration program is Irp is basically anything.
But munitions clean up. It's the typical chemical to kind of clean up the Mmrp.
Program started up separate to that, and we are. The Mmrp program is somewhat lagging.
As far as you performance metrics, and where they are, and getting, you know, sites cleaned up and getting to records of decisions and stuff compared to the installation restoration program.
I think, before pfas hit us and and other chemicals.
We thought Mmrp. would be taking over a lot more of the budget and other things by now, but that seemed that seems to have slowed it down a bit.
So you know, in in 2,001. Dod was directed to establish the Mmrp.
Program to address munitions, response sites. we will talk through definition.
Definitions are very important. I'll talk through Uxo Dmm. and Mc. and what what those mean?
But really the Mmr Prep. program is only looking on actually installations where the sites are closed.
Formulas defense sites. fuds I know a lot of you familiar with that acronym base realignment enclosure locations.
Actually that's Ford order is one of them and I'll talk through a case study on that later.
Mmrp. does not address munitions clean up on operational ranges at all.
So what agencies are involved with munitions? Response: pretty much.
Everybody who does clean up Epa if it's an npl site will definitely be at the table.
If it is a non npl site, we may or may not be there.
And Dod certainly states tribes if there's tribal interest Federal land managers, if they're owned, you know, department material department of Ag, A lot of other stakeholders can be involved at any given time
dependent on who owns the land What the land is going to be used for, and such here's a pre snapshot of oversight and regulatory offices.
I'll start at the bottom our regional office. I know there's several, many epa folks on the line, and that's kind of our first involvement at the the sites the other 4 our bullets are epa
headquarters offices. The first is my office photo slowly.
Restoration reuse office fifth row we've been around for 25 to 30 years.
We're all we're all under the office of land and emergency management.
The officer. resource, concentration recovery Oh, rocker they handle.
That's the record office. So anything permitting maybe there's a record corrective action, or something it may would would come to them as far as headquarters offices super fun remediation and technology innovation that's our sister office
for super fun circle of cleanup they're quite a bit bigger than us, because they actually do execute some of the work with an epa.
Our Federal facilities. Enforcement Office, Vo is under our office of enforcement and Compliance Assurance at headquarters.
All the the ffa's the Federal facility agreements and all, and any disputes that arise at Federal facilities, sites would would come up and work through this feasibility's enforcement office so
Dods organization. I apologize. If this has changed.
We actually did run this presentation through Dod headquarters.
Folks before we gave it the last time. So basically duty, as far as Mmrp.
You will hear about Office Secretary Defense, which also includes the Dod Explosive Safety Board.
They review and approve a lot of the the work, the safety side of the work.
Dod components. Those are the Army Navy, Air Force, Marine Corps and delay.
They have secretary at office of staff. Dod likes to kind of reorganize things quite a bit.
We do try to stay current with them from my office. We have quarterly meetings.
I was just working on setting up the next one today with the Dod components and talk about kind of program-wide issues and try to resolve them and see.
Do we need new guidance? Do we need new policy?
Do we need to modify something is something coming out of another agency that's going to affect what we do. Can we work to, you know?
Try to make that workable as far as explosive safety under.
So Ddo Dod Explosive Safety Board is all of Dod.
There are component explosive safety offices, Eustace Nosa for Navy and Air Force Safety Center.
So to definitions. and this has recently come. One of the services came to me recently and asked, Hey, can we make sure that the Epa people really know what these terms mean?
Because I think I think the quickest way to get to a problem is to think you know what you're talking about.
But your awards are actually implying something else so i'm gonna go over some of the key definitions here.
If you look at some of the reference material that we provided there are a lot of letters and memos that have the key terminology.
If you're writing some letters and other issues, and if you want to run it, pass me by all means.
I can certainly help with that. So So the first one military munitions, it should be pretty, self-explanatory. all types of conventional and chemical ammunition products and their components produced or used by the armed forces
for a national events and security that's pretty easy okay munitions constituents.
Okay, that's means any materials are originating from unexploded orance discarded mill traditions or other military munitions.
That is the say, the rdx, and the soil or tnt, or something like that.
So you're all still with me. so now we have this new I want to say newer term.
This was changed in the late later 2,006 or so we army came up with this term and was adopted dod wide.
So we have munitions, and explosives of concerned mech and that's the the term we use now. it's kind of the overarching term.
It involves includes 3 different parts, unexploded ordinance, discarded military munitions, and then munitions.
Constituents present, and high enough concentrations to close an explosive hazard.
That would be like big bulk. explosives. that would be the soils with more than 10% explosives, constituents in them stuff like that.
That's usually the much lesser used part of this this definition but it's still there.
So you excel unexploded ordinance.
This is milk. This is kind of important to understand the difference here, because it's really a safety hazard connotation between things, and i'm going to go through them in this order.
Uxo would be the more hazardous Why? Because it's been prime fuse, armed otherwise preferred for us, and they has been fired, dropped, launch projected, or placed?
In such a manner as to constitute a hazard to operations, inflation, personnel, or material.
But then it remained unexploded, either by malfunction, design, or any other cause. Hmm.
So you fired it and it didn't go off and you have no idea why it's very dangerous.
You could go and pick it up, and it could go off.
You could go pick it up, and it does nothing but you don't know.
So any of this, you know there are ways to tell. if things have been fired.
And and it takes from trained personnel to understand what they can do with those.
So sometimes you say things cannot be moved that would likely be unexploded.
Ordinance. term discarded military munitions means military munitions that have been abandoned without proper disposal.
These could be fused, but there haven't been fired they haven't been put into a condition set to explode.
Yet. Now, if someone say duty tried to blow up some discarded military munitions, and it didn't blow them up. It just kind of kicked them out, So it had hoped and burned open detonation.
Area we would probably call that unexploded ordinance because it's been placed.
It it's been hit with such a charge you don't know the condition of it anymore.
And you it's really an unknown is it really dangerous is it not.
We don't know so Emily we've got a quiz we do.
And hopefully, this is fresh on your mind. What is the difference between Youxo and Dm.
M. there is done. Uxo has been fired and emplaced, and Dm.
Has not Dm. has been fired in place to Uxo has not, or Uxo is Mac, and Dm.
Is not so. Take a few seconds, thank real hard get your answers in so Emily.
I'm watching. we've got about almost half the audience having voted remember.
Class gets more fun if you play along with these opportunities, and there are no penalties for a wrong guess.
It's very important, Right? all right, I think we might give them a few more seconds.
I think we can get to 75% of you having voted So if you're hedging just go ahead and go with your gut on this, we're almost there 72 we can get a few more in all right I think i'm gonna go
ahead and lock it down, and we can take a look at how they've voted.
Let's see, fantastic. 70% got it right Uxo has been fired.
And Dm. has not. There we go. awesome, all right, guys.
So most of you were paying attention for that. one I did just turn my video off because I want to try to ease the burden of having to look at me the whole time and maybe not have to have video running If you're on a
lighter bandwidth so let's go to the next slide.
This is one of the questions I get asked quite a bit so I wanted to make you aware of this when we're talking about Dod, and what's there?
Their Mmrp. site. Inventory Dods worked really hard over the years.
Epa assisted in States, did in the mid 2 thousands with trying to get a really good handle on their inventory.
Dod really require them to inventory their sites and then prioritize their sites.
This is part of the inventory, you know a number of them.
And then talking about funding. that's obligated to clean up these.
The first link is the annual report to Congress it's usually about posted up not too long after the fiscal year ends.
I Didn't Look to see what the latest was up there, but the second link is actually the inventory, and you can search it by state.
Pull up your site. get some basic information in there. There could be some polygons in there of the site and all that, and then get the contact info of who to get more info.
From. So this is in, you know. good to look at, to see, you know. Am.
Are you actually working your amusement site? or if the site you have is is what phase it is under with Dod.
So this is a second part of that. The first was a them inventory in their sites; the second was coming up with a prioritization scheme for their site.
So duty established the protocol and looking at evaluating the primary hazards at the munitions response sites.
There's 3 modules in there. They only have they have to score at least one.
The first is the one where I spend the majority of the time in an exposure has a excuse me.
Explosive hazard, evaluation, module, and the second is chemical warfare, material evaluation.
The third is health, hazard, evaluation, module for more from constituents.
This is the tool they use to do the national level ranking supposed to review an update.
Each Muse response priority, at least annually, to reflect any new information that that affects the Mrs priority.
You should see this as they go, the scores go from one to 8, one being the most dangerous 8 being the least.
One would be only chemical warfare. The explosive hazard evaluation starts at 2.
So if you had a 2 for a you know regular explosive munitions site, that would be a pretty high priority.
We've I think most of those are at least in progress the 2 is a 3, 1, 2 threes.
4 is even, and some of them they may actually pair together.
They may have lower priority sites but they're adjacent to higher priority sites, and in for you know, ease of response, and, you know, being fiscally responsible, they may do some of the lower party sites along with some of the higher
priority sites. But you can see this information, and when you get involved in your site, Doug, we have a couple of questions sure hit it.
Does the inventory include Fud sites they have an Mmrp component?
Yes, and they're actually listed out. and you know actually next time I do this I might view a few screenshots to show that when you do a search by state, you it will actually come up with army formerly use defense,
sites air force navy on down it'll be it'll be split out that way.
If it's not mmrp it won't be in there.
There are a lot of fuds that are just chemical contamination, and they would not be listed there.
Okay. But but fud one thing, though, Floods does have their own database.
Of all fud sites. So those kind of overlap with the the Mmrp component.
Okay? And then one more question: Does the Epa rely completely upon contractor geophysics for input review, etc.
Geophysicists. my apologies Wow! somewhat somewhat.
We do have experience Rpms that have done this part of my job is also reviewing
This. I actually helped write the Ufp clap and other things, and have been around geophysics for a long time.
But for specific geophysicists support. Yes, we do have regional support contracts that support each region, and we just redone a lot of those we've had some periods of time where the regions did not have coverage and I actually
had to had to help fill in somewhat. We are also even looking at a national level contract that our regions can buy into for very much more specific support along with lines of advanced classification.
Ufp Clap Review, and those types of things and any others. I mean.
Oh, that's it for now. Okay, thank you cool so we're gonna keep on the one thing to go along with this munitions response prioritization program.
They do have a primer document that's more of an explanation of the document, How it's used and going through.
I recommend reading that first, and that's in our references are easily available on duty's website.
So some of our unique challenges we have no promulgated promulgated regulatory standards or safe levels.
And for this i'm talking about uxo munitions the explosive hazard we don't have.
There's no how clean is clean you know we don't have a kind of a risk talking about risk it's an acute hazard.
Direct interaction may cause serious injury or death. There these are discrete, hazardous items.
We're not talking about, plumes there may be plumes associated with constituents, but that's not what i'm talking about here.
And they can be an attractive nuisance.
I am not a fan of signs and fences for long-term responses.
I've had several teenagers raised several of them and I think they would all be attracted to that's military stuff cool.
There's a danger sign let's go check it out we've had a lot of trespass issues, and and that's really somewhat dangerous.
The problem with coming up with a standard how many uxo Prayer Acre is safe.
You can't there's no answer to that question none really but how do you know you've gotten them all?
And and what is there a statistical way of understanding?
That is, it gets very complex we'll talk a little bit about risk assessment.
Later. there's been some strides forward you back a few more forward in more recent years, and trying to get things standardized in that.
So the other thing with meunitions and we stuck with the Fordor team here.
These are actual munitions found at fortord you'll have a variety of site conditions.
We might have different great, very greatly in size and and topography.
I do know. At Florida they were repelling down some very streets, deep areas to try to survey.
They had some munitions in a very steep hillside. I think, at Ford, or there were over 300 types of munitions that were found cleaning up there, and this is just some of them let's not even not even a
quarter of the ones that were found. These are all boards they used in public meetings, and such.
So some of our other challenges technology limitations how can we find them.
We're relying on fine when they're in the ground finding the metal that's there. We don't have explosive detectors.
We don't have munitions detectors we have metal detectors, and how good are they you know, and there's different types.
There's analog there's digital we've worked with Dod developing some advanced classification.
We can tell between items that are underneath, but that comes with a cost.
Munitions, cleanups can be many organisms, orders of magnitude.
Crater than traditional contaminants. it could be less if depending.
If you're looking at a huge crown water plume versus cleaning up a smaller area.
We've worked with Dod, trying to refine some of these detection technologies to get to be able to leave some non hazardous items in place, and do we know the certainty of that and and how can we accept
that. So we got another quiz right? Derp is an acronym. For what? deterring explosives, restoration program defense, environmental restoration, program, dangerous environment response program defensive engagement.
Response program. So get your answers in we'll wait a little while.
Does look as the like. The audience is a little bit more confident in their choices.
I would have thought so glad, to hear it and we're looking at about two-thirds having voted right now.
And remember, if you're a button or your cursor is floating between 2 circles, just go with one.
Trust your gut in state, ladies, and gentlemen and i'm gonna go ahead if it's all right.
We do. i'm gonna close these polls down absolutely look all right.
So there are the results. 94% got it correct? Well done.
Happy to hear it. The world's environmental restoration program all right.
So I think we were on schedule yeah we're doing real time wise.
We can Okay, 5. So let's let's go ahead and take a 5 min break, and then we will come back and get started.
I've got a video of some stuff blowing up so we can make it a little interesting to wake you up. all right. Thanks.
So very much so, ladies and gentlemen we'll go ahead and take a quick 5 min break.
You will hear on the webinar during that time i'm gonna start a helpful timer on the screen, though, and we should see you back here for the resumption of the class at approximately 5 min.
All right. It does look as though our 5 min break has concluded. i'll check to see if we have dogmatics back with us.
I am back wonderful doug so i'm gonna take it over i'm gonna try.
Let's see if we could do this screen that didn't work.
Okay, Gene can you see that cannot i'm gonna go ahead and help you out here, because remember, you have to override me.
I'm gonna stop sharing there. we go and there we go thank you.
So we're gonna first, sure. So the first thing I wanted to start off with a just a quick video just show you kind of the power of explosives.
And how a site can switch quickly from a removal to an emergency.
So this was Camp Menden. Say we were involved with It ended up.
It was a removal action. A lot of unstable explosives.
Propellants were found there in storage. We worked with Dod and the State to get things on track.
We had a very nice contained burn unit set up to process these tens of millions of pounds of material.
Unfortunately, during that process a couple of the monkers leaked and got wet.
Some of the material got very, very, very unstable when it was wet.
One of the bunkers detonated, and then we were unable to go into any of the the government.
Those 2 other bunkers that had that material luckily It was the small amount we didn't have that much material.
This type material, clean running igniter at the site. But this is what was the result, and safe to move out of the closet.
And so we were called out when we had to set it off, disposing of it on time in a timely manner.
It definitely reduces the hazard to pretty much everybody around. far.
No. so you can see that's about £150,000.
That explosive weight going off. The reason was, no one could enter the bunker.
No one could handle the materials, because it got so completely unstable.
So thought that was an interesting video. So we're gonna go back now to doing our presentation.
Give me 1 s where We're actually shifting gears. Now we're going to talk through case study of Ford order.
Again. I apologize normally we'd have our one of our Pms doing that that didn't get worked out and time for this. So i'm going to talk through this case study so ford orange out is kind of
located outside of on the central coast of California, adjacent to Monterey Bay, south of San Francisco, Santa Cruz.
To the North Monterey in carmel or to the South. I have to say.
I've walked over the site. it's a very beautiful piece of property, with some amazing views.
The yellow dotted line you can see is is actually the site You can sell the cities around there.
The pink area. the impact are area track 3 is what We're going to talk through a little bit today for our case study and some interesting things that had happened there.
A lot of there. The firing points were around the perimeter firing in, so the majority of them, you know, the Mac has been found in this part of the site.
There are a lot of other areas on the bays that were used for munitions training.
This was not only the only site, although it was the most heavily contaminated Ford order was put on the Npl.
List in 1,990. There were a lot of different reasons for that.
It was officially closed in 94 under the second round of brack, and it was the largest Us.
Base to be closed at that time, so my office has been involved with the site with region 9 for quite a number of years.
So let's go to the next slide so it is a little bit of background on it.
Started in 1,917, as a horse garrison again closed in 94.
This was really training training and staging for ancient free troops.
A lot of acres, a lot of acres in fact, 4 dords, approximately the size of the city and the county of San Francisco, and that's very big types of maturity of mac artillery
projectiles, rockets, hand grenades, practice landmines, pyrotechnic bombs, and demo materials pretty much if it was in the inventory, and it was army.
Based, it was likely used here at some point in time They did come up with the the 3 reuse the 3 E's economy, a education, and environment.
This was very popular. land is very, very expensive area, so there was a really strong desire to clean it up and reuse it.
The proper value is very high, actually 401, 2,020 excellence and site reuse award which is sponsored out of our office in the bracket pale category.
We do that every year. and there was a privatized cleanup here, although we're not going to go through that partial.
But you know, 7 army funded the Ford order, Use authority to clean up, to conduct, met clean up on over 3,000 acres.
They finish that cleanup in 2,020 there's a lot of land use control implementation that's going on going, I think, at the time this was one of the earliest and biggest privateized cleanups in the country.
So what we're going to talk about a bit is the the impact area.
This is It's a 6,500 acres part of the four-door national monument threatening and endangered species.
This central maritime chaparral, which is what we will focus on a little bit.
The rod was signed in 2,008. After a lot of back and forth I was involved in that one.
We a lot of the language and stuff that we take for granted now that that's, you know it agrees to was not that way in 2,008.
So this involved some prescribed burns and vegetation Cutting will show you some pictures as we move along a little bit.
Why that was needed in this area. The entire area got a technology aided surface clearance of Mac.
And then they did subsurface remediation in selected areas, roads, trails, other areas that were selected.
It was about 10% of the area that got the subsurface controls.
There were a lot of institutional controls. language controls, construction, support, access controls, habitat management.
And then they did some digital surveys post cleanup.
So why do they need to do? prescribed Burns the first part of that? This is Meno.
And then the news many times over the last 15 plus or so years it's home.
This impact area is home to the largest growth of the central maritime chaparral in California, and which is also the home of multiple endangered plants and wildlife.
So pride burns, are required to protect and preserve the endangered species.
Habitat, because many of these species are fire dependent.
And to protect these species, prescribe burn season is limited to summer and fall from July to December, and it's very, very hard to get it to fit within that sometimes.
So why are we doing it for the cleanup reason is really, if you look in the upper left photo some of that vegetation is over 6 feet tall, and it's extremely dense.
Mac is underneath there hard to see. hard to get to
You know the the post burn? You can clearly see the Mac that that's on the surface in those areas.
You know, these prescribe Burns make it the ground surface accessible.
They also, you know, reduce overgrown vegetation which in turn reduces the risk of wildfires.
California's pretty tough state to get burns approved in but it was, you know.
We did get Burns approved and and done for this reason, because we can actually protect the habitat and clean up some of the major problems.
There. let's see. So to do these burns we had to do some fuel break cutting you can see the before and after photos we left the oak tree standing there were limbed up, and They ended up They survived the fire.
This is the primary containment line. There were a primary, secondary, and tertiary for each burn area to ensure community safety.
Some of the parcels actually identified. it could not be cannot be burned, and they had to be cut due to the proximity of neighborhoods or airports.
So we're. gonna try do this and gene I think I shared the screen wrong to do this But we'll we'll give it a I'm gonna actually restare if you give me all give me a second 2 sure
stone. let's see if this is gonna open hi I'm Nicole Hawkins Sandy hope promise I know this. Here, there we go skip ahead.
Here we are. So my name is Bill Collins i'm the environmental coordinator for the armies-based real line enclosure office at former Fort.
We're out here today, conducting a prescribed burn on 265 acres of the form of 4.
It's part of the ford national monument It's done to help support the ongoing munitions.
Cleanup of the area on one. the burn is done the uxo unexploded ordinance technicians will be able to safely enter the site and look for any explosive hazards while you're transitioning back
we have a couple of questions Sure, Go ahead. Oh, well, signs are not ideal.
They may be the only option to warn folks about the hazard.
There are those who take them to heart. Will you be covering other options?
2 signs or clean up, I mean, Yeah, my my personal preference is, if you can clean it up and not have the to the need to put signs in stuff.
I I personally, you know we'll follow the ncp expectation for treatment, signs and fences are useful in some circumstances.
I agree. I don't like them kind of as a default, or do I like just land use controls as a default?
You know, I think cleanup is, should certainly be evaluated.
Okay? What is the depth of surface versus sub-surface?
Anything visible from the surface. So when you talk about surface clearance if it's an item that's sticking out, and you can see it, that would be taken care of.
We do it detectorated surface clearance sometimes just to look at it.
There's actually a picture coming up i'll show you when if there's brush or other things on the ground, you can.
You can survey to see if there's anything there that rings off, and you can see then, if it's underneath the brush or not.
But that's really it's got to be seen from the surface.
Okay, then, conventional munitions, such as military flares may contain as much as 45% P.
Fast Has any soil testing for P. fast been conducted at Fort Ward as highly persistent biocumulative contaminants.
They would expect to be a concern for ecological systems and receptors.
So I am not the rpm and I can't answer that.
But I would. Certainly we can get back to you on that I Don't answer incorrectly.
Okay, Pfas is kind of a evolving thing at sites. so it's certainly I think being discussed and looked at.
Okay, and then so does fire not trigger the Uxos to explode.
It, can they? can and that's but again as far as a safety concern?
You know they're going to be you know you will not no one will be near them when they do that.
But as opposed to trying to cut through the brush and move it and have them go off when someone's nearby.
I mean that's the real reason for for doing the the burn and in in certain circumstances like that.
Okay. So that was our last question at this time so you can go back all right.
So here's the before and after picture you can tell that they kept it contained to an area.
It is very difficult. I do recall over the years, many, many, many delays with having to do this.
You have to have the absolute correct conditions to do this to ensure which way the smoke's gonna go, and how you can contain the fire and not too much wind, and on. and on.
So it's It was not not an easy thing to get set up and do so.
Moving on. This is the picture I mentioned before this is an area where they actually had cut down some brush.
They're using those are shawnsted magnetometers.
They're using to do, a surface, clearance and they're trying to see. You can see some of the cut brush and other things that are on the surface, and and they're trying to see you know is there something underneath
there and then they can flag it for for being dealt with later.
Analog. I will talk a difference between analog and digital detection methods.
Later and the utility and use of each, and the kind of pros and cons is from a policy perspective.
So the next digital geophysical mapping used a lot of different methods here, basically same technology, different platforms.
Here, you're able to Geo reference your geophysical mapping area.
You do not get that with this type of work right Now here you're getting a sound, and maybe a flag in the ground, or finding an item There's no real record of this you will get that from the Dj the
Dgm work, which would also include some of the advanced classification, which I think is the next slide.
This is one of the earliest versions. of metal Mapper, which is in advance geophysical classification agc system, and i'll talk through these a little bit.
What this is is a more easiest way to describe it.
A three-dimensional look at your object, in the ground i'm looking at characteristics and how things decay from from the electromagnetic pulse and all.
And and you can tell, we can tell very reliably between different size items and different shape.
Items like a flat plate, looks entirely different. Then a cylindrical, heavily walled object, which we would think would be ammunition.
I worked with Dod Epa did in States partnering on this to technology for a better part of 10 years to ensure. This is not a black box, and it really does work.
This is one of the sled mounted early on systems it wasn't the most durable we're easiest to get out to a site. They're cart mounted now 2 by 2 arrays metal mapper and
tempads that that are much more useful getting into into place.
We have a question for you. This is follow up post clearance.
Bgm always required. It depends. It depends on what you're end. use of. the site is gonna be. And what end point you would be wanting to get to you know, and depends on what technology you use to clear this site
originally. So i'd say it depends and I think you need to look at the level of data quality and uncertainty minimization you need.
If you were trying to get say to an unrestricted, you ue scenario or no further action, wherever you would call it, I would say yes.
If you know, you're having land use controls coming into place and and and all. and you've done a really good job with Qqc.
Throughout process. Possibly not If you used analog technologies, and you want to get to a better endpoint, you might want to. You know there are.
There are uses for analog technologies. You could maybe thin out the area, and you know, and remove a lot of anomalies and then go back and map the area out and dig. So you could even use a combination of of
those. Okay, i've got 2 more for you sure do all sides get sampled for perforate.
Depends on what was done there. If it was if it was an in the munitions that were used or propellants that were used there, then it should be one of the analytes when they're sampling Okay, has any equipment, like this
trigger to uxo no and that's we've not had anything, you know.
The mag system is passive, the em is not enough to set it off.
There are, there are new newer munitions that could be.
I guess there could be an issue with We don't normally see those on these type of cleanup sites.
That would certainly be a discussion to be had with your munitions.
Experts on your project team, but but no it's not not very common that it would be an issue.
Okay getting some more for you. Are they still using metallic seeds for quality assurance?
Yes, so seating, and we can talk about this a little bit and again, We're getting a little deep here, but the the way we do quality.
Now is, you can test your instrument out and Then at the site, as you're doing your geophysics like this.
We are actually the contracts are going to place their seats, and these are either simulated objects like a pipe.
That's the same size as you munition you know they're called industry standard objects, or you can even have inert munitions.
Some dod have some of those. they're exact same thing you're looking for You're gonna place they contract or replace those make sure their people are finding, and then the government dod will place quality assurance seeds in as
well to make sure that things are being found and they're being found at the depths that they should be able to be found, and that's all part of the geophysical systems verification.
Process. Are there any more questions? That was the last question, for now?
Right all right, and that you know at that point you know we're starting to get a little deeper with those questions.
But those are really great questions. i'm glad you're thinking along those lines of data quality, because now that's I am a regular, and I need good data quality.
Be able to make good decisions. here's a typical geophysical map that you could get out of.
I think this was a Dgm. This was not in advance classification surveyor.
There you could get a similar map for that. This is a you know 61 survey, and it's sometimes called a false color scale.
But basically you you set it up that's certain higher numbers of anomalies will trigger different colors in this area.
The pink, reddish color is the higher density areas.
So you can kind of see, hey? This is where we may be focusing in on on some of the work, and and how you want to, you know.
Spend your where you want to spend your time and money for removal.
A little couple of pictures of some digging some anomalies I don't know about this one, you know they they provided this, but I usually don't see that many you know 2 teams right next to each other digging but
I guess it could be done that's up to the site team and the safety folks to do that. What they're doing is is digging at the the location using instrumentation to make sure that There's nothing left there one thing to
keep here. There may not just be one munition per location.
The there could be several and some of the more advanced classification system.
We could tell. We may not, if it's too dense of an area, so you can keep that in mind.
Quick question, sure: How did the density maps correlate to range fans for site?
So what you would do. And this is really we partner, with Dod on a training class for where we teach how we go about investigating a site, you know, going through the Rfs process.
And we're really trying to you know you have your range maps and all.
And you, you would hope, if they use the range as intended, and as they had drawn up, you know that's 1 point of weight of evidence of those maps and stuff.
How do they correlate to the actual data you get?
I have seen some where they didn't and i've seen a lot where they did.
You would expect, you know maybe these you know unfortunately at fourd or you've got criss-crossing ranges firing inwards, so they're overlapping so it's very hard to tell which is is
from what? but you would expect that the target impact area you would have a much higher density
And then it would taper off through the range fan area back to the firing point, and maybe the fire input could have some little higher density areas if there was some disposal done are there any more that was all for now
cool great. So this is just a slide showing you what some of the munitions look like at Fort Award again.
They had everything ranging from small arms up to 155 projectiles, a bunch of mortars here. That's a 40 grenade high explosive on the upper right so a lot
is different stuff. The key point here is some of this stuff, you know.
Look at the lower left may not look like a munitions item when it's in the ground.
You know. i've Got lots of pictures of things that look like just rocks sticking out, and they're not their bombs. So be very careful.
If you're on a museum site and work with your experts on identifying it, so institutional controls education and outreach.
So you know, trespassing is a huge huge issue.
At Fort Order, especially, you know, when people are trying to get off a beaten track like I, said.
Ford is a beautiful place. i've walked a lot of the areas over the many years there's a lot of biking and outdoorsing outdoor stuff.
There that goes on there. they do have to use you know it's, kind of a layered approach land use restrictions, access restrictions, or signage, and fencing.
There's construction support that if certain things are going on there.
They have to first go through this training. You can click on that link and you can.
You can run through the training and see they're even looking There's helicopter used for habitat management.
They're also looking into drones and cameras. There was a ton of education and outreach with local school. there.
This is a very population dense area around this They do a lot have done a lot of school outreach outreach public events. They've had open houses and tors.
And you know they just keep trying to to work through that so we've got a few pictures of signs here.
You know signs and fences work Well, in some areas some other sites they really don't work well on.
I know vehicles another npl site. we put up some fences and a temporary before, and they're just they're gone by the next weekend.
So haven't had the problem at at fort or here's. some of the outreach material the 3 R's recognize retreat.
Report is dod's website. 3 rs mill I believe that's in our references as well they have a ton of just different outreach materials.
Pamphlets, coloring, books, anything that they can.
You know, train folks, different languages, pointing to different sectors, marine industry.
On and on again. there's one of the boards in the upper right.
You can see the different munitions I think that's the same board we had in the previous picture.
So so far I think there's the numbers as of about a year ago.
Estimating it complete in 2,030 they've had over 79,000.
Mac Items recovered of those 12,000 plus or high explosive, over 300 types of munitions found for the privatized area.
Again, almost 5,000 munitions item, and just all tons of debris and and other things that were gone through.
Like, I said, This is this is pretty valuable property.
I do think maybe some more money was spent trying to develop it and make it safe for those uses that may not have necessarily been done elsewhere.
So some of the lessons learned from this. You know, munitions cleanup is really resource, intensive.
It is long-term efforts are required in a lot of cases.
Lux Ic's 5 year reviews are brought in I get asked the question.
A lot can you get to unrestricted use you know on the exposure? maybe?
It's hard it's not easy and it involves some really upfront planning and a lot of good quality through your investigation, collaboration and innovation.
Innovative thinking is key. A lot of things basically started out of fort, or some risk of assessment work.
And looking at things and working through project team things we're still using some of that today, and some of our newer methodologies.
And then again, local knowledge and perspectives are important. There are a lot of people interviewed through this whole Ford project and getting really good information about what was done, where things may have been disposed.
How they actually did activities versus what was planned.
So you really cannot discount that first line information. So any other questions on this, on especially, thank Judy Hong, who's done this in person?
May Clancy did this last time for us out of there out of Uk region. 9 and Melissa brought Son and Stan Cook also contributed to the presentation.
We have one question I order. We have a couple questions. The density map showed higher density up to a border.
Are there policies for stepping out of the investigation area?
Simple answer to that is, you know, as a regular circle follows the extent of contamination.
Okay, and yes, that now maybe it was done as a separate parcel, you know.
Maybe Dod want it for whatever reason we wanted to have this Mrs.
Versus this Mrs. but certainly it will all be covered under circle and cleaned up or addressed somehow.
How it is done, as far as which rod covers what and and as long as you know, I have an opinion as long as it's all done cleaned up and managed safely, that you know we're gonna work through it
and get it done the easiest and quickest way we can.
That makes sense. I hope that answers that question. one more are the Dgm surveys conducted on a transect that cover every square foot of the investigation area, whereas the mapping system able to interpolate Yeah, that's a little a little more
technical question. So that map was a 100% coverage and you can do. If you're say looking for a target area, you can do what's called transsex, and you can space them out.
So that hey? if you're looking for a certain size, start we're looking for a mortar target, that's 150 meters in diameter, or something along those lines, we have some standard prox approximate sizes of
those types of targets we can design a transect survey to find those targets.
And then the Bsp system, visual sample plan can kind of craig the numbers and kind of give you that that map showing the approximate.
So the more data you have obviously the more accurate it is.
So you want to keep in mind what you're looking for and and keep in mind if you're doing transex, keep in mind that the object of your investigation.
You know what is, what is, What are you looking for? Are you trying to find targets?
Then maybe you can do transaction. you can say at the end of the day.
You don't find any targets okay we don't have any targets here.
But you didn't do your resolution. of your investigation was not enough to say, Hey, we there aren't any munitions here, because you've left gaps.
So if you really you know it depends on the intent of your investigation.
And again that's the two-day course it's 3 days online and and 2 days we did record the trained the first day.
The presentation materials. We're gonna try to make that available that folks can watch.
And we're actually starting to try to do the two-day course in person, maybe at the end of June we're still working on that.
So contact me if you're interested in that as Well, because that that's going to be covered in much grander detail in that course.
Can you talk about any problems with past prescribed burns?
I think the problems we've seen really are trying to get them done in a timely manner to the the problem really is meeting the meeting.
The conditions. There were a few fire jumps that were were handled, you know, and that that's kind of the thing.
If conditions change as things are going that's why they're very very strict conditions to begin with, and trying to forecast.
I can't remember the number of times things got that canceled a few years in a row.
But really it would be more of a, you know. jumping a fire line which there were.
There were some minor occurrences of that. is there a policy for gathering data where terrain is problematic.
For an example, heavily wooded areas or slopes so we'll talk a little bit about technology and when to use what in the next presentation.
So let's hold that until I get through the next part of the presentation.
So if I haven't answered that at the end please Re-ask.
Okay, and no further questions of this time. Cool: All right. So I am gonna try to switch presentations here.
Yeah, we're back here. We go Okay, we're done with the Fordor case study.
So I've got probably about 1520 min left of talking through some more specific things.
I'm gonna get some technology as well and talk through hopefully answer some of those questions.
So little bit about epa guidance, so recre resource. conservation, Recovery Act is a waste management.
Statute and it's the source. of the military munitions Rule, which was published in 1,997. you know, for recrea authorized States may exercise the record authorities there you know and some States are not authorized and epa
has retains that authority. There are a lot of things under record characteristic tests, management standards for hazardous waste.
The last ones this management standards for open burning.
Open that nation owe D. that's been a big topic to your lately. We, my office is participating, but we are not driving that that is, out of our officer resource conservation recovery or rocker at a
headquarters are working through alternative technology for O, do look at putting out some guidance soon, and then actually working on possible rule making. i'll talk about that in a little while.
The military munitions rule the big part of this. It avoids imposing records, subtitle c.
Statutory authority on operational ranges. We exempted munitions used for their intended purpose, and remain on operational ranges from the regulatory definition.
Sorry of solid waste. Okay, So if there is an operational range. They fire down range and things don't go off.
They don't necessarily have to clean it up right away because they're gonna continue to use it.
If things go off range they have to clean them up.
If they dispose of things on the range that was not covered under this either.
Also the munitions rule identifies. when the most remissions would become waste under some management and talks through other relationships. Oh, my computer's not working.
Here we go. There are some exemptions, under there. I don't really need to go through other the third one munitions used in training R and d testing evaluation, and then range clearance of active in that bill term so terminology, is kind.
Of important. The old term, active or inactive ranges, was around when I started this job, and it would quickly change to.
So if you see active slash, youactive, that means operational ranges.
And active just means. Maybe they're not using it now but they're still retaining as an operational range.
So Dod has the the authority to kind of say, these are our operational ranges, and we're using them so other things that would be subject to recrea abandoned munitions on range disposal
landfilling of munitions. Those things are not covered under the munitions rule.
Exemption. One thing it did Munitions rule did try to clarify was for emergency response.
I've had i'll interaction with folks in and out with our post ordinance disposal folks military specialists.
So any those folks respond responding to an explosives or munitions emergency.
They can take the action. They don't need to get a permit They don't need to make notifications.
However, you know that that is, granting them the authority to do the what action needs to be taken to immediately resolve the situation.
These are some guidelines. So we wrote these, and it took a very long time to get issued.
These are still fairly current epa munitions. Response guidelines is probably our most straightforward guy.
In some munitions 30, something pages. This is the framework to our regional officers overseeing responses.
And this is again a little bit older technologies that locations other than operational ranges.
So basically, when you're responding you know doing our nmrp program to clean up, and it's how to work with Dod and where we fit in in the process, this is in our references as well sorry under
this talking through general regulatory authorities, recurcla explosive safety principles, psych characterization, geophysical detection, techniques and and preference.
For I mean epa we've a really big preference for digital methods.
We want a record. There was a document from 2,001.
The Uxo management principles that Epa and Dod signed where we agreed we should do D.
Should be going in this way, taking about 20 years. But I think Dod agrees with us, too, that digital and geo-reference data is the way to go then talking through some luck.
And I see issues and enforcement put all that into a 30 page document.
So some of the current policy issues that are ongoing i'll talk through these for a little while munitions as the hazard waste hazardous substance. it's not so much an issue now on a on
a closed site that's being cleaned up there's not a big disparity anymore.
There's a section in enclosure in the dirt manual that Dod has that talks about their opinions on it.
Our epa munitions response guidelines talks about our opinions, and that you know these things are not necessarily a waste when they're on and operational range.
But when the range closes or it's put to a use in compatible, you know those things at some point are not exempt anymore.
They become a hazardous waste and a circle hazardous substance.
You know we don't have a big necessarily disagreement with that anymore.
Back in the mid 2 thousands at Fort Ward. We did so That's mostly resolved principal threat waste determination.
This is a site specific determination at a site, but munitions in themselves are dangerous, and poses severe hazard to personnel in a lot of cases.
Uxo and or Dm. can be a principal threat waste, and should be identified as such.
Again. it's a site specific determination, we've kind of worked out, some language with Dod that goes into records of decision about how that you know should be discussed, and if any more is found, it should be evaluated to
see if it's a principal threat and needs to be be treated there.
I think the biggest number one question I get asked is this third bullet?
Can we get to unlimited use, unrestricted exposure?
U ue some of the duty services call it No, further action. Basically, you're completely done with a site, and you're walking away.
Have you cleaned it up to the level that you want to clean it up to?
Can we get there? When I started this job at Epa or about 20 years ago, I would have said no and the reason being we were not at the level of technologically technology and procedures.
And Qaqc. and the way of minimizing uncertainty at a site and maximizing our use of these technologies and quality, assurance and and all.
We have made very great strides in the last 20 years.
I think, working with Dod on technology, on working on Qqc.
I will talk through the Ufp clap. use a little bit later.
So my answer now is maybe it depends really on the type of site there's so many factors that fill into this I can tell you what has happened at a few sites in the past few years. where They've had 20 years of work they've done analog
investigations. they've done some cleanup they've had some contractors.
They had to get rid of the you know, and you know poor practices.
And then they come to us and say, Well, we think we got it all. so we're ue right.
No May. in those cases I we were not convinced, and the question was, well, what what can we do?
And I said, Well, the answer is the good news is you've already done.
A lot bad news is so when you go back, and do you know more to convince us, you know there's probably a lot less.
There. So I think the the answer there is started from the beginning.
I could definitely I could plan a better looking ahead investigation and clean up to try to get to that endpoint than I can to try to fit what everything everything that has been done into that That's much more difficult situation and again it depends on
land land type. Do you have a lot of hot rocks?
Is your geology interfering with your instrumentation?
How good was your Qqc. How did you have any failures?
What technology are you using, You know, on and on and on we do have some examples coming out in the new Ufp clap module. I'll talk about a little bit talking through this kind of scenario. and what we would look for
someone had mentioned post geographical survey verification survey i'm, shaking my head.
Now I don't have video on but Yes, in a case like this where you're trying to get to you e I would want that. I would ask for that as something to help you know.
Minimize the uncertainty again. Depends on the site and what you're gonna do there risk hazard assessment.
This has been an interesting one over the years risk it's an acute munitions, and i'm talking about the explosive risk, not the chemical.
There are ways of doing risk assessment for chemists, chemicals.
Our Dx tnt other things. We have established methods for that for doing the explosive threat.
The from from the munitions fordor to actually started out one of these and their smart team.
And what what we saw back in in that timeline early 2 thousands, late ninetys early, 2,000, or several different methods for trying to do this.
None of them were actually great. Epa partner with dod came up with a Mech hazard assessment in the mid 2 thousands That's still out today.
That's really a relative tool to compare and contrast alternatives in your feasibility.
Study and shows you kind of the risk reduction between doing different alternatives.
There's no absolute risk methodology per se and it's it's difficult to do so.
Dod undertook. probably 6 is 7 years ago.
They develop their own internals, originally called the remedial action, alternative tool.
And now it's the risk management methodology. they issued it draft for trial at Fuds sites only because that's a lot of what the army corbin engineer does I think 2017 timeframe and
kept extending that it's in it's a different kind of tool.
It's similar to input factors to Mac ha They do come out with an acceptable unacceptable answer.
The regulators were not involved in development of that tool i've been through it a lot.
We actually just worked through one of our national work groups and gave a lot of comments on the tool.
Dod came out with a a second draft version which we reviewed and submitted a bunch of comments, and that was last month.
So hopefully they can take those comments back. Get a newer version out at some point.
We might get to a a joint tool that everybody agrees to It's very difficult work, I think, though, you can use either tool work through it in your project team and come to a good decision at your site.
There shouldn't be a lot of surprises running these tools there's not a lot of different syndrome for cleanup and endpoints and linux controls you shouldn't run the tool and go huh that one's
actually safe. you should you really should know and this is a way of proving it and going through the process.
Let's see detection technology all right so we talked about this a little bit.
There's really 2 ways, of finding Mac ux o dm magnetic, which is passive electromagnetic conduction, which is active.
That's the you know. the the 2 ways ground penetrating radar and other methods really don't work. Well, there is a technology document put out by shirt up.
Espn that's dood's research arm he was around 2,006, with looking at different historical methods of this, and and talking through what what is the best?
But this is really where we are. these types of magger em.
There's digital systems which is digital g physical mapping where you record all the data.
It's. geo-reference and then you can analyze the data and identify the anomalies to go back and dig.
Compare that with analog systems whereas also you know previously called Megan Flag, Megan Digg.
There's no record of it and the real-time analysis identifies the anomalies by sticking a flag in the ground where they come back, and dig.
Later that's highly dependent on the user factors we cannot control How well is this hearing going this day?
Did he actually sweep and cover the whole area we don't know for sure.
So we really have pushed a lot from the regulatory side and actually even within Dod.
Now to minimize the use of analog systems to where they really have to be used, and and someone mentioned before the terrain in our training that we teach that I just, I seem to only i'm one of the regulators on the
train. I seem to always get stuck with the steep terrain breakout group where we end up having news analog systems which is good for me, because I can talk through the limitations and all that But really you can't get
a push car you can't get the the top picture here you can't get that on a 40 degree slope versus that, so it's kind of a hey?
We get what we can get data wise. But you have to really understand the limitations of it in my mind.
If you're thinking that you can want to get to a ue scenario, you should not be using analog systems.
That's just too much uncertainty you're in the 40 to 70% detection range.
For buried objects not anywhere near. good enough for me for that kind of final decision.
But again, if it's all you got maybe that's good enough to get you to the use, you need along with some language controls.
What we came out with Dod was working on advanced geophysical classification.
This is an electromagnetic technology I think That's the tempad system on the on the top and the the Mpv.
The smaller handled system on the bottom right where this technology is looking at it's more of a threed look of the response.
The different sensors, and you can tell based on the decay and all of you know. you can tell very easily between like a flat plate, a piece of wire and a pipe type, object you know, ammunition's
kind of cylindrical thick walled object. and you can really cut down on the amount of dangerous digs that you need to do and really dig what you need to do. Maybe You dig everything but you don't have to dig if you have a high
confidence. The other items are not bad, but maybe you need to get rid of them.
Anyway. you can dig those under different protocols you know There's a lot of things for that.
So as we were, he is the the startup You see the the strategic environmental research development program is duty's, basic research program and the environmental security technology certification program.
You have. Tcp is their kind of field test pilot testing program.
So this was developed under shirt up, and then fielded under Es Tcp.
When they were starting to develop it and feel that they actually developed a an advisory group. And I was part of that with mothers, with Epa and several State experts.
We were really concerned with. This is still dependent on the geophysicist interpretation of the data.
And and how well do we know? Hey, Are they trained?
Is the contractor keeping track of that what's their quality through the you know It's a lot of base on the contractor.
So we we we started asking a lot of questions and you d's.
Response was to come up with this Well, a new acronym which they they love, and it's that cap is ud advanced geographical classification accreditation program.
So they actually a credit. They have accreditation program. They base this on the the Lab technology certification program.
To and That's actually the folks that they brought in to to help set this up, and to really you know anyone who's doing work for Dod.
That's doing advanced geophysical classification has to be a credit period.
If they are doing that work. If they lose their accreditation they're done, they can't do the work anymore until they get recredited. So it's a two-year accreditation.
There was a there's basically a paperwork shirt of occasion kind of, and making sure they have quality systems in place and all that.
And then there's actually the field test portion. of it which they're now for certificate recertification. they're looking at just synthetic data sets and all But it's a really good way for
regulators and stakeholders to understand they really are doing the work.
They they know what they're doing and here is why here's the data to show that they know what they're doing.
They've been tested out they know what they're doing they've been certified and they have to re certify.
So that is actually a good thing. So I mentioned this before the Ufp.
Quap. And here's our quiz see if we can get above 90% people on this.
So what does Ufp. Quap stand for? uniform Font Program for quality Assurance and proposed plans. Understated Facts Project for Quality Assumption Project Plans Uniformed Federal Policy for Quality Aggregated
pilot programs or uniform Federal policy for Quality Assurance Project plans.
Get your answers in and I I don't think that's been covered in this presentation.
Yet, so it has not. Do not be shy with wrong answers. All right.
It looks like about three-quarters of the audience have submitted their responses.
So i'm gonna go ahead and they're they're pretty confident in their end.
Let me lock this one down and share those results. Good! all right.
9% nice. This has been out for a while so i'm glad to hear folks have been paying attention that's great get it to work there.
We go. So what is it? it's a tool to guide project teams through the systematic planning process?
This was developed. This was originally developed for a chemical type of investigation.
This is a worksheet based tool there are 37 worksheets.
In the original version. We've we've streamlined them there's new versions that were put out, and then we started looking at it.
Hmm! This was really, really working well in the chemical side of the cleanup program. we're cutting down on the number of regulator reviews.
People are understanding where the the you know, the quality indicators are in their project, and where to find things, how how the project is being run.
It really does work well there's a bit of a learning curve. There was a bit of learning curve with contractors learning how to write them and do them well, and for regulators to understand them.
I think this is the number. One thing i'm still helping out with our folks is looking at youfp clap and and and trying to explain why some things are some way.
So what we did, we we looking at doing quality assurance for munitions and geophysics.
Work is a whole lot different than chemical q a qc I don't know if we have any chemists on here.
I'm an engineer, I dabble in some chemistry.
But I understand, and I understand it's a lot different it is way different.
So we we actually We did this in a little bit backwards order.
There is an Agc. managed to physical classification clap.
We did first. so Dod had actually taken upon themselves to start developing their own clap.
Templates to use. So those were in existence, and but everybody was.
As we were developing this Agc technology, folks were having difficulty trying to apply this.
So we did take this on as a group and developed one, and then we went back and developed module.
One. which is this Rafs Cloud Ufp. quack that one has been out.
It was updated once already we'll probably have some minor updates again later. this year is being used primarily.
Dod requires ufp quab format for all of their projects.
Epa is requiring it throughout our private cleanups as well. you know we've just issued some new our contracts, and and how we do our work, but we are using it as well.
It works really well. We left the numbering of the worksheets the same, but there are quite a quite substantial difference in in content.
So the Rfs. the Module one is actually what our class that we just held our fourth online version of it due to Covid.
And we're hoping to get and in person course this summer in really is based on this ufb clap.
And then how we go about doing the work the module 2 is under draft Right now we're kind of incorporating this agc crap into this this is going to be the remedial action clap this one
we're hoping that it'll be really cispring for some review.
Actually, it is out for you right now. Some some folks wider review later this summer.
Hopefully. it issued, maybe by the end of the year. This is the one I mentioned that you you you E scenario.
We tried to incorporate a Ue scenario in this on how you could actually get to that, and what quality indicators and body assurance you would need along the way to get to that.
And those are just examples. But, boy, they took a while to work through.
We have a team of epa state and duty, and some contractors assisting us to work through it. It took a while to get to an agreement, even on an example where we were making up the example.
So certainly something to look for coming out in the near future.
So we partner a lot with Dod to try to maximize the transparency and collaboration I have.
The phone numbers. Everybody who does this at dod we certainly I don't.
I I hope, at Dod and try to resolve issues.
We want to keep the work going when you get the sites cleaned up correctly.
You know, I did mention the Uxo management principles earlier in the training.
This was in March of 2,000 we're dpn Dod agreed.
We need to work together. we need to work together. Well, we need to use digital geophysical methods.
It has taken a while to get that fully implemented. but I really do think it is.
There. So a couple of the other groups we have a munitions response dialogue.
If over the years we've had different variations of this due to funding and other reasons. So this is where we are now to Dialogue group, it's co-chaired by Dod Officer Secretary events Brian
Jordan is the new person there. I'm the representative for Epa and the Co-chair.
And then we have a State co-chair, which right now is Tracy White, from the State of California.
Colorado. Excuse me, we have several of. I think we have 9 other States participating on this group.
Epa, every duty, service, federal land management agencies.
And we really talk through a lot of issues that are related nationally to this munitions cleanup program topic of the last year and a half 2 years has been this risk management, methodology that deity has been pushing forth.
And we have the subgroup working through. what are our big issues to it, which resulted in Dod making some big edits to it, and then sending it back out to the groups to review and submit comments which we all just
did, and hopefully, we'll get a revised version back in a couple of months to look at and try to move that forward and get it to be a better, more useful tool didn't mention this before But the intergovernmental data
quality task force. The Id Qtf is the group it's chaired by out of my office.
My boss and Dod office secretary defense doe has been involved as well, and it's really trying to a group working to standardized data quality across Federal government and cleanups.
This is the group that developed the the Ufp clap so you can blame them.
I picked it up when we started doing munitions and now on our lead representative for it.
Still, as we're working on other things so other munitions sites that can can cause us some issues. I'm not spending a lot of time on them, because I don't do a lot with that i'll hit the second
one first operational ranges. For the most part, you know, munitions use for their intended purposes are exempt.
There may be issues on operational ranges that that need to be addressed.
There could be previous landfills, disposals other things We do try to work with Dod to be responsive and respectful of what they're, you know, their national security mission is, and getting neat.
What needs to be done. but if something needs to be cleaned up, it needs to be cleaned up. there have been cases where we've had to take action and do some things on on ranges, it's not very often I do
suggest to regulators. If this is starting to be an issue for Epa, please bring it to our attention at headquarters.
Nothing gets elevated more quickly than an issue with an operational range.
I have found over the years, and we can certainly help advise you, and what what the best path forward to do.
Keep in mind any work that would be done. say if there was an old landfill that was really impacting groundwater going off site. Just an example it needed to be.
That's not derp eligible do these own programs. So they'd have to have a different funding source for that which can also cause some issues within Dod you know, even if they you know recognize the need to do something the
funding can be kind of an issue. So going back up the open, burn open that nation.
So sites are usually permitted sites. There is a lot of stuff going on right now.
Our officer resource, conservation, and recovery, or rocker doing the record.
Folks have an explosive team that are working on Ovid and permitting.
They have a work group with Dod, which I sit in and listen in on.
I think there will be. they're working on some clarification guidance, and also possibly even the new rulemaking. it's been a long time since anything was issued regarding ood was an alternatives technology document that was issued
I want to say, 2 years ago, losing track of time during Covid, and working out of my house only.
But that is a great document to read. Certainly something you could even consider as you're looking at treatment, you know if you have munitions that can be moved on your site.
You surely can look at that to see what are they? All alternatives?
There are for treating, and those kind of wastes let's see.
So here we are. we at Npl sites we oversee Dods clean up.
We're usually in the circle of process however, there are some reasons to be under, You know.
Record. there were permits and stuff, and being cleaned up, we have had to issue some orders and work under safe drinking order. Act.
For say the but circular really is the preferred it's a cleanup statute.
It works well for working through that, and again, the thing to keep If you're new to this, is it's the same process.
You there's a different name for the mmrp program. but the fundamental law and that and statute that they're following is, you know, is circa to get to the end. point.
So here we are, I think we've got about 13 or so minutes. I know if you want to put questions in I know Emily's doing me the great service of going through and looking at questions.
Do not hesitate to reach out to me if we can't get to all your questions today.
Give me a call shooting emails. Probably the best and we'll try to get back to you. So Emily.
Do we have any other questions we have some great questions i'll go ahead and start.
If munitions are demilitarized on site, the filler drummed and disposed, off-site as waste, and the metal casings recycled with this be exempted from record can we repeat
that. Yes, if I i'm gonna pull it up go back to the question, Yeah.
Do you need help finding it. Emily no i've got it if munitions are demilitarized on site.
The filler drummed and disposed offside his waist, and the metal casings recycled.
With this be exempted from recreation? I mean I think so.
But I again, I don't know that i'm gonna give that the definitive answer right now because that's not my normal realm of record.
So let it Let me get back to them specifically on that That's why I don't get a wrong answer.
You know my limits. This is the Epa guidance on Munitions Address.
Whether the finalings of ammunition at a non-dod fud site constituent constitutes a release of hazardous substances under circle specifically with the finding of a single mech on federally owned property trigger a
circle 120 notification of a release that might prompt, including the site on the Ff.
Has waste compliance docket hmm wow that's a really loaded question.
It might mean. Certainly so. the answer the answer i'll give You is munitions that are no longer on a operational range.
There's no exemption to them and if they're discarded.
Then, if there's explosive, in them they would be a hazardous waste, and then potentially also a hazardous substance.
But I think you can. You can take it from there as to whether that would would trigger the docket.
But there's no exempt anything once you're off in operational range.
Okay, and if you have that, that one seems to be I think there's a situation in mind. as far as the hazard's ways compliance stock it goes there's a person in my office that that works on that too,
and that maybe if that's a site specific question we can get he and I on the line to talk you through it all right.
What depth of investigation is considered cleared is clearance, excavation of the depth of investigation or repeated clearance.
A common practice. So this is another thing about terminology.
So surface clearance, you know, versus, a clearance to death you know, or a cleanup once you Yeah, that it depends on how good you're your Qac war.
Were, you know. Are you saying how deep I guess the question is It's hard to understand, too, how deep can you see for geophysical instruments.
I guess the role of thumb is about 11 times the diameter.
If you can't see it you can't tell if it's there or not. so you certainly couldn't say if you had small munitions going to a deeper depth you certainly could not say that it was cleared you
know, and that you were good to go. In that case you may have to cut off lifts of property, or you know of the land to get to be able to get closer to do it.
And those cases a lot of the times with the smaller munitions that go a little deeper.
We can find that you're stuck with land use controls you know it's very difficult to clean that up.
Okay, and again i'm gonna encourage people if I really didn't answer your question.
Well, and you want to resubmit it to me.
Certainly do It's gonna say that while your contact information is still on the screen. Yeah, that's how you type your email right Now, if you need to have you found the soil from Bud sites to be contaminated with flood exposure within
our artillery and mortar ranges not not as much no, nohere near like now. we're going to exclude small arms range from that which is just firing bullets into you know firms and stuff like that there I would certainly if it
was a, you know, an area that was used to take a look i've not seen, heavily content.
The most heavily contaminated sites I see with explosives and metals and all that are usually from my area.
Obod, maybe some disposal sites, and then and then for explosives.
Anything manufacturing or decommissioning, or something like that?
Would be the much higher level contamination doesn't mean you shouldn't take a look.
Okay, if digs show vertical and placement, ie.
Highest em response. Can a deeper depth of investigation be justified?
So what this is referring to I think is If you say you have a long cylindrical object, and it's pointing vertically when you're looking down on it with your sensor, you will be able to
find that there's so much more metal in that look downward versus it being horizontal, and you're looking at it crossways.
I don't know that munitions end up in the environment any given way.
Certainly. So we usually do the the maximum you know the minimum depth where you can find everything we'll usually look at that least favorable orientation for you know of the horizontal physician where that's
the least amount of metal when you're looking kind of crossways down from the surface onto it, and we'll look at that as kind of the depth of detection.
You can certainly find them deeper. but reliably so no what if it's at 45 degrees. it's not going to be that deep. so I wouldn't use that as saying it's cleaned up okay can you speak
to the challenges specific to underwater sites yeah it's more expensive and more difficult.
We are So Dods R. and D. had spent considerable time and effort with land-based systems and sensors.
A lot of that work is transitioned into underwater type of work.
I actually sit on these panels. reviewing their technology development and all and provides regulator input there's a lot that's pushing towards looking at underwater. sites keep in mind when you go underwater
everything's more expensive and more difficult. things do not land the same way.
If they're shooting into water based targets maybe more disperse.
So maybe your statistical tools don't work as well for transact design. So there's a lot of questions that that go there.
Duty has been doing some and investigations and and clean up so far that I've we've been involved with.
But again it's it's somewhat early days for those there are technologies out.
We can survey and find things underwater and clean them up.
But again it's definitely more difficult. Okay, i'm aware of a bombing range that is being closed by the State.
Not epa i'm trying to understand Why, it's associated with an active, delisted air.
Force base any thoughts it sounds to me like that might actually be.
A garbage may actually be a potential party to it, based on the So the National Guard units the Air Guard or the Army National Guard.
They have State as well as Federal duties, and I have seen where the State has been responsible for them.
It depends on what they did there. I think that could have something to do with it. if not that one's probably a good site specific question to send me more info on, And we can talk about it.
Okay, I realize that it's very important to remove Mac and ux.
So. some military ranges also include small arms munitions with lead bullets, while some responsible parties have pushed for not removing lead bullets in the past.
Once the range is closed anywhere in it remaining lead. bullets have levels of flood, making them hazardous waste blood bullets also weather and release, blend to the soil and water mainly as lead carbonates over decades
just centuries. so if light bullets remain lead, concentration and soil will increase over time.
Is Epa developing policy to clarify the cleanup of lead.
Bullets on small arm spranges. We are not actively working on any new guidance.
There are some out there's best management practices tierc document.
We did write our Federal facilities Work group did write and pretty extensive paper. I don't know if we call it guidance, but it's certainly useful information on munitions constituent cleanup and in that was quite a
bit information on small arms ranges, and there we have made it through the questions.
All right. right. 3 min left. Well, folks I want to I want to thank you all for attending again any further questions concerns or anything.
Please don't don't hesitate to reach out to me and or Emily.
Yes, and or Emily. All right. Well, if it's okay with you. Doug: I think I will take it away with just a few final reminders for our audience before we close things out in our session today. So the first, thing.
That I would like to do is just to remind everybody we may have had.
A few attendees join us a little bit late and missed this part.
We're just reminding everybody that today's session was part of an ongoing webinar series.
So this was the third one in the series we'll be back again next month for our next delivery on May the eleventh, which will cover a land use, and on-site off-site determinations I did want to remind everybody that this is part
of that ongoing Federal Facilities Academy which includes 11 online webinars which are open to the public.
And then one in person, or probably an in-person delivery, which is 3 days long, and is open to a restricted audience of Epa States, tribes, and other federal regulators.
And we do have information about that classroom delivery.
If you need it, you can certainly send a message into me in the Q. and A.
But we've already included it. as a resource on the seminar home page for our session, which i'm going to talk about in just a moment.
If you enjoyed our session, I encourage you to visit us at the cleanup information network at Kluen Org, and connect with us on that site.
And of course, please be sure that you're subscribed to our Free Monthly Newsletter tech direct which I send out on the first of each month, and will highlight free online training opportunities such as today's session, if
you happen to have a resource that you think will be a valuable addition to tech direct, you are also welcome to send it to me at balance.
Gene at Epa Gov. as I highlighted at the start of our session there is a web page that has been created in dedicated for today's webinar shown in red on the top of this text there are
a series of tabs or sections that as you scroll through that page You'll have access to things such as the webinar slides and references there's information about our speakers, including contact information if you want to follow
up with any of them, and then links to our online feedback form.
So i'm going to ask you all to make sure that you have either bookmarked or you reference this page, because that is how you can request the participation certificate based off or filling out the feedback form on the
seminar home page. If you happen to be one of the lucky people replaying the recorded version of today's webinar, that website is still available, and you can still submit feedback.
So, as we were highlighting in the beginning of our class today, you can receive a participation certificate for any or all of the online webinars that you attend, whether you're there live or replay the recorded version simply
fill out the online feedback form associated with the webinar, and make sure that you check the box at the bottom of the form, certifying that you attended either the entire live delivery or replayed the entire recording as long as
you check that box. It included a valid email address.
Once you submit your feedback form, you will have access to a participation certificate. something like this one that you can save for your own records will also email a copy of it to you.
But sometimes those get blocked by junk or spam filters, so I encourage you to download it from the confirmation page, and just hate it right when you submit your forming.
If you happen to have a number of people, join it your location, each person can actually fill out that feedback form on their own, even if they didn't register individually.
So if you happen to be the one who signed up for the session, please get them that link to the seminar feedback form so they can fill it out and get their own certificate for their own records and
So again our session was recorded. We had a well over 170 individuals to join us for today's live broadcast.
We hope that you will carry on with the seminar.
And again, please bookmark the url shown in Red here. If you happen to be watching the recorded version, you'll be able to type that Url in or write about now, somewhere over my head in the recorded version online in the archive there
should be a button that will allow you to jump straight to this page, so you can fill out the feedback form.
So with that, I want to thank both of our instructors and organizers from the Federal Facilities office here for putting on our session, and all of you who took time out of your busy days to join us for the session
we hope that this was a valuable expenditure of your time, and you will join us for a future webinar.
With that i'll go ahead and formally conclude today's life broadcast.