Munitions Response Site Prioritization Protocol An Introduction 8 February 2006 Alaska Forum on the Environment

ADEC CS-FFERP MMRP Lead Presenter Jason L. Weigle ADEC CS-FFERP MMRP Lead 907-269-7528 jason_weigle@dec.state.ak.us 8 February 2006 Alaska Forum on the Environment

Alaska Forum on the Environment Today’s Presentation Munitions Response Site Prioritization Protocol Background Terminology Application Community Involvement 8 February 2006 Alaska Forum on the Environment

Munitions Response Site Prioritization Protocol In the earlier presentation today, we saw a little of the history and events that lead to the creation of the MRSPP. For those of you who missed this mornings presentation, the next few slides are intended to summarize the origin of the MRSPP and what it will be used on. 8 February 2006 Alaska Forum on the Environment

The National Defense Authorization Act of Fiscal Year 2002 Requires DOD to: Create an inventory of MMR sites in the US and Territories [10 USC §2710(a)] Create a protocol with which to prioritize sites within each facility/state/region and across the United States [10 USC §2710(b)] Put in the US Code January 24, 2002 8 February 2006 Alaska Forum on the Environment

Alaska Forum on the Environment Site Eligibility 10 USC §2710(a) list: sites that have demonstrated UXO, DMM, or MC contamination or are suspected of having MEC contamination that was or is under component control. Exceptions: Any location outside the United States Sites where the presence of military munitions results from combat operations Operating storage and manufacturing facilities Operational (Active or Inactive) ranges 8 February 2006 Alaska Forum on the Environment

Munitions Response Site Prioritization Protocol Close to 3400 MRA/MRS Over 2000 Installations 28 million acres Statistics as of September 2004 (DENIX) MRS numbers and acreage are moving numbers. As sites are added and removed from the system and the acreages to be investigated changes (during processes we will discuss shortly), the numbers will fluctuate. The numbers represented here are really no more than point estimates. Image: USAEC 8 February 2006 Alaska Forum on the Environment

Munitions Response Site Prioritization Protocol Proposed Rule released 2003 Final Rule Promulgated in Federal Register on October 5, 2005 Preamble (70 FR 58016) MRSPP Final Rule (70 FR 58028) Codified 32 CFR §179 Advance notice for federal rulemaking issues in 2002 Proposed rule released in August of 2003 Due to the number and substance of the comments, several portions of the proposed rule were changed. The final rule was issues on October 5, 2005. 8 February 2006 Alaska Forum on the Environment

Military Munition Terminology The next few slides are intended to help bring those who may have missed the first presentation up to speed on critical definitions that we will be using to discuss the MRSPP. 8 February 2006 Alaska Forum on the Environment

Munitions and Explosives of Concern (MEC) Three Categories: UXO DMM MC Chemical Warfare Materiel MEC - Specific categories of military munitions that may pose unique explosive safety risks, such as unexploded ordnance (UXO), discarded military munitions (DMM), or munitions constituents (MC) present in high enough concentrations to pose an explosive hazard. (32 CFR §179.3) UXO – munitions that have been fuzed and fired and did not function properly DMM (discarded military munitions) – munitions that have not been disposed of properly or have been removed from storage for reasons other than disposal (AO) MC – Any material or substance coming from a MEC item, including explosive and non-explosive portions. Includes breakdown elements of MCs CWM - CWM is generally configured as a munition containing a chemical agent that is intended to kill, seriously injure, or incapacitate a person through its physiological effects. For the purposes of this protocol, white phosphorous is not considered an CWM, but rather falls into the conventional UXO, DMM, or MC 8 February 2006 Alaska Forum on the Environment

Alaska Forum on the Environment MRA/MRS Munitions Response Area (MRA) Any area on a defense site that is known or suspected to contain UXO, DMM, or MC. Examples are former ranges and munitions burial areas. An MRA is comprised of one or more munitions response sites. (32 CFR §179.3) Munitions Response Site (MRS) A discrete location within an MRA that is known to require a munitions response. (32 CFR §179.3) These are two critical items when it comes to military munitions responses. Breaking MRAs and MRSs up into different areas can help reduce workload and remediation time and expenses. 8 February 2006 Alaska Forum on the Environment

Camp Marmot Active Range Range D MRA 1 Range A MRA 2 Range B MRS A3: Range Remainder Active Range Range D MRA 1 Range A MRS A1: Target Area MRS A2: Firing Point MRS B1: Rifle Range Target Area This slide is an illustration of how the concept of MRAs and MRSs work. Camp Marmot - began operation as an Army training facility in 1936. MRA 1 Range A: This MRA is one of two active ranges on the base. The range was closed in 2000; the base wants to use this land to expand the cantonment area. The MRA contains one large firing range, which was used to train for both indirect and direct fire systems. In analyzing the area, the Project team decided to break the MRA into MRSs for investigation: Target Area - UXO, MCs; Firing Point - DMM, MCs; Range Remainder - UXO or DMM Range B is the known site of a small arms training range (.30 cal and smaller) that was closed in the 1960s. The area is currently being used for storage of vehicles and other materials. After analyzing the data for the site, the project team decides to reduce the acreage of the site down to just the target area, and to look for lead and other metals as MCs for this site. Thus a reduction of acreage took place as part of the investigation for this site. Range C is the location of a suspected range that is now a wilderness area on the base. The Munitions Response Historical Records Review discovered that the range had been designated on an installation map of the 1950’s but no official records existed of it ever being used. In interviewing base personnel of that time period, it was discovered that the area was used as a hand grenade training range, and the HE grenades were used as part of the training at the site. A site visit located what appeared to be mounds and pits that could have been used for this type of training. A surface sweep of the range using magnetometers indicated that most of the fragmentation is located in a tight grouping around the disturbed areas. From the information gathered and the sensitive fusing of HE hand grenades, the project team decided to bound the hand grenade range based on metal fragmentation and creates a new MRS based on a suspected probability of UXO or DMM at the site. Range D – active range, no consideration under MRSPP; active range program Hopefully this illustration has shown you the power of MRA/MRS and how MRHRR and project team interaction can be applied to determining what work may be needed for remediation of a site. MRA 2 Range B MRS C1: Hand Grenade Range MRA 3 Range C 8 February 2006 Alaska Forum on the Environment

Munitions Response Site Prioritization Protocol The Protocol Now that we’ve covered the background and basics of the protocol, it’s time to delve deeper into the protocol itself. 8 February 2006 Alaska Forum on the Environment

Modules Factors Data Elements MRS Priority The protocol in a nutshell: Evident (H) Potential (M) Confined (L) CWM Configuration Sources of CWM Location of CWM Ease of Access Status of Property Types of Activities/Structures Ecological and/or Cultural Resources Population Density Population Near Hazard Explosive Hazard Source of Hazard Location of Munitions Contaminant Hazard Receptors Significant (H) Moderate (M) Minimal (L) HHE Module CWM Hazard CHE Module Accessibility EHE Module MRS Priority Migration Pathway Identified (H) Limited (L) The protocol in a nutshell: Combination of a CSM and risk assessment – although it’s really neither. Three scoring modules Explosive Hazard Evaluation (EHE) Module Chemical Warfare Materiel Hazard Evaluation (CHE) Module Health Hazard Evaluation (HHE) Module Three major factor groups: Hazard, Accessibility/Pathway, Receptor Data elements within each factor are scored using site specific data The overall score determines the hazard RATING The highest rating between modules determines the priority for the site Setup looks complicated; however, it was set up in this manner to keep one module or factor from outweighing the rest of the protocol. [DISCUSS ORIGINAL HHE MODULE AND ISSUES] Munitions Response Site Prioritization Protocol Training Manual, December 2005

Starting Off - Basic Information Installation name (Property name for FUDS) Location Site name (Project name for FUDS) Federal Facility Identification Number Contact person name and information Priority or alternative module rating assigned and date of evaluation CERCLA phases completed or in progress Date and score of previous evaluations if priority changes Summary of additional information, as necessary Map and/or cross section of the MRS if available People involved in performing the evaluation Most of the data for scoring the MRSPP should already have been collected or will be collected as part of the PA/SI Different branches of the military are approaching this slightly different – Army/Navy/Marines: approaching from traditions CERCLA process; Air Force – CSE Phase I/II In general, this chart shows the basic information that should be collected for each MRA/MRS. This data will be cataloged as part of the prioritization protocol using Table A from the scoresheet set. MRSPP Primer is a draft document that is being developed by the ODUSD(I&E) Office of Environmental Management for project teams to use in completion of the Protocol. It is still being developed and should be set for release sometime later this month. MRSPP Primer, Scoresheet ‘Table A’ 8 February 2006 Alaska Forum on the Environment

30 Tables EHE: 10 CHE: 10 HHE: 8 (max) Priority Ranking Table ‘A’ Protocol consists of thirty tables that must be completed to score the site. HHE – tables should only be completed if a complete pathway exists – discuss in a few slides.

Circle all applicable numbers Highest one determines table value Circle all munitions types present at the MRS Record only the largest single classification score in the Munitions Type box DO NOT ADD MULTIPLE SCORES TOGETHER! Scoring tables Follow Directions Circle all applicable numbers Highest one determines table value Document assumptions: very important, especially in QA review (discuss momentarily) Document any MRS-specific data used in selecting the Munitions Type classifications here

Alaska Forum on the Environment Handout - Cheat Sheets from Primer: Factor Groups and Data Elements for EHE Module Purposes of the Protocol: Munitions in water less than 120 feet deep – incomplete barrier (8)…deeper than 120 feet, complete but not monitored (5). Population Density – within county (borough or census area): 2000 Census – Anchorage 153; Ketchikan Gateway Borough 11.4; Juneau 11.3; Fairbanks NSB 11.2; Kenai Peninsula 3.1; Bristol Bay Borough 2.5; MatSu 2.4; Population near hazards - within 2 miles of MRA/MRS boundary Types of activities - within 2 miles of MRA/MRS boundary ECO/Cultural – on the MRA/MRS Ecological Resources – Threatened/endangered species or ESA critical habitat or sensitive ecosystems (wetlands, etc.) Cultural Resources - Cultural resources. Recognized cultural, traditional, spiritual, religious, or historical features (e.g., structures, artifacts, symbolism) on the MRS. Requirements for determining if a particular feature is a cultural resource are found in the National Historical Preservation Act, Native American Graves Protection and Repatriation Act, Archeological Resources Protection Act, Executive Order 13007, and the American Indian Religious Freedom Act. (32 CFR Part 179, Appendix A) 8 February 2006 Alaska Forum on the Environment Munitions Response Site Prioritization Protocol Training Manual, December 2005

1a. Enter the Explosive Hazard data element scores 1b. Add to determine factor values 30 10 40 2a. Enter the Accessibility Factor data element scores 2b. Add to determine factor values 25 05 03 33 3a. Enter the Receptors Factor data element scores 3b. Add to determine factor value 05 02 01 13 86 4. Add the three factor values 5. Select the Module Rating that corresponds with the module value 6. Record the Module Rating in the EHE Module Rating box B

MRSPP – Alternative Ratings Evaluation Pending No Longer Required No Known or Suspected Explosive Hazard (CWM Hazard, MC Hazard) Evaluation Pending – not enough info to score module (Discuss metrics for evaluation pending) No longer required No Known or Suspected Explosive Hazard (CWM Hazard, MC Hazard) 8 February 2006 Alaska Forum on the Environment

Alaska Forum on the Environment CWM, explosive configuration, either UXO or damaged DMM Munitions Response Site Prioritization Protocol Training Manual, December 2005 CWM Configuration: first point should read “CWM, explosive configuration, either UXO or damaged DMM”. 8 February 2006 Alaska Forum on the Environment

Alaska Forum on the Environment The third module, the HHE module, is perhaps the most difficult one to fill out. The HHE module is based off of the DOD Relative Risk Site Evaluation Protocol which has been used for risk assessment at FUDS and other sites. In general, the HHE is similar, with a few exceptions. 8 February 2006 Alaska Forum on the Environment Munitions Response Site Prioritization Protocol Training Manual, December 2005

Health Hazard Evaluation (HHE) HHE Module Groundwater (human) Surface Water (human, ecological) Sediment Surface Soil Contaminant Hazard Receptors Migration Pathway This is the process flow chart for the HHE module. As you can see there are four media groups that are analyzed. However, calculations only need to be conducted if contamination is attributable to a MRA/MRS and the media is present at the site or is influenced by the site. For each media, human and/or ecological receptor analyses must take place, again depending on whether there is a pathway for that media to come into contact with that receptor. And finally, for each site and similar to the other two modules, each pathway is analyzed for hazard, pathway, and receptors. 8 February 2006 Alaska Forum on the Environment

Example for groundwater – shows how to fill out scoresheet 1. List the names and maximum concentrations of all MC and associated contaminants 2. List the associated comparison values from Appendix B of Primer 3. Calculate the ratio for each contaminant Lead 22.0 µg/L RDX 38.0 µg/L 4.00 µg/L 61.0µg/L 5.50 0.623 4. Calculate the sum of the ratios 6.123 5. Circle the CHF Value that corresponds to the sum of ratios M 6. Record the value 7. Circle the value for the Migration Pathway Factor Example for groundwater – shows how to fill out scoresheet H 8. Record the value 9. Circle the value for the Receptors Factor 10. Record the value H

Alaska Forum on the Environment For the protocol - rearrange letters in a ‘worst-first’ pattern For example previous example was M-H-H, which would be an HHM for the rating – thus a B score. 8 February 2006 Alaska Forum on the Environment Munitions Response Site Prioritization Protocol Training Manual, December 2005

Highest rating/priority – driving priority for the site Munitions Response Site Prioritization Protocol Training Manual, December 2005 Highest rating/priority – driving priority for the site If one or more modules are Evaluation Pending, scored modules will be used to determine priority until others are completed (EP flags site for additional clean-up under metrics for EP completion)

Alaska Forum on the Environment MRSPP - Sequencing The sequencing of a MRS for action will be based primarily on the MRS’s relative priority DoD policy states that a MRS with higher relative risks will be addressed before an MRS with lower relative risks Once an MRS's priority is determined, the Component may consider other factors in sequencing a site. These other ‘risk-plus’ factors Do not change or influence the MRS Priority May influence sequencing decisions 8 February 2006 Alaska Forum on the Environment

Alaska Forum on the Environment Sequencing Factors Munitions Response Site Prioritization Protocol Training Manual, December 2005 8 February 2006 Alaska Forum on the Environment

Alaska Forum on the Environment MRSPP – The Fine Print Priorities will be reviewed by an internal DOD QA panel to ensure consistency; priority rankings can be changed by panel Priorities at all sites must be reviewed annually Site must be re-scored if site conditions have changed or if new information becomes available Data age for chemical, geophysical investigations Priority can be changed by QA panel if Protocol is thought to be misapplied or misinterpreted – including data in the bottom documentation blocks can be helpful in showing how/why protocol was applied in that manner and where the information came from. Greater than 10 years – needs to be regathered. 8 February 2006 Alaska Forum on the Environment

Alaska Forum on the Environment MRSPP Scoring tables in MRSPP Appendix A HHE Scoresheets and Relative Risk Comparison Values located in MRSPP Primer (under production; based on EPA Region IX Preliminary Remediation Goals) 8 February 2006 Alaska Forum on the Environment

Opportunities for Input 8 February 2006 Alaska Forum on the Environment

Alaska Forum on the Environment MRSPP The Protocol requires Components to offer stakeholders opportunities to comment and participate in the application of the Protocol and sequencing recommendations How these opportunities are ‘offered’ varies from Component to Component 8 February 2006 Alaska Forum on the Environment

Protocol Requirement for Stakeholder Involvement Each Component shall – See 32 CFR §176.5 for specific regulatory language Notify leaders of stakeholder organizations of the opportunity to participate in the application of the Protocol and seek their involvement Publish an announcement in local community publications about stakeholder participation in the initial application of the Protocol and request information pertinent to prioritization or sequencing Include a copy of all public notices and announcements in the for the MRS Administrative Record, Information Repository, or project file 8 February 2006 Alaska Forum on the Environment

Protocol Requirement for Stakeholder Involvement Each Component shall (cont’d) – Incorporate stakeholders’ input in prioritization and sequencing decisions and document the decisions in the Management Action Plan (MAP) Include information provided by stakeholders that influenced the priority or sequencing decision in the MRS Administrative Record, Information Repository, or project file Provide stakeholders with information on prioritization or sequencing changes and request their comments 8 February 2006 Alaska Forum on the Environment

Alaska Forum on the Environment Final Thoughts Evolving process Contractor implemented A lot of people will be going into the field who are not from Alaska or understand how Alaska works – be gentle! MRSPP is a good opportunity to get information on sites – be active! 8 February 2006 Alaska Forum on the Environment

Questions? 8 February 2006 Alaska Forum on the Environment Boomer the Otter Adak Ordnance Awareness Program 8 February 2006 Alaska Forum on the Environment