RI-FS Guidance (Harre) · 2020-02-24 · DoD/EPA UXO Management Principp()les (2) DoD munitions...
Transcript of RI-FS Guidance (Harre) · 2020-02-24 · DoD/EPA UXO Management Principp()les (2) DoD munitions...
Navy/Marine Corps Munitions Response RI-FS Guidance
Bryan HarreNaval Facilities Engineering & Naval Facilities Engineering & Expeditionary Warfare Center
MR RI/FS Guidance
Provide guidance on the Navy/Marine Corps RI/FSs for the MunitionsNavy/Marine Corps RI/FSs for the Munitions Response Program (MRP)
Additional training offered by CECOS class “AdvancedCECOS class Advanced Munitions Response Site Management Course”
htt // t il/ t / f / /https://www.netc.navy.mil/centers/csfe/cecos/ Draft RI/FS Guidance is available to RPMs on the
NAVFAC File Transfer SystemContact your RPM for a copyContact your RPM for a copy
Thanks to NAVFAC MR Workgroup, NAOC, and Battelle
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DoD/EPA UXO Management Principles (1)p ( )
DoD and EPA agreed that DoD will:• Conduct response actions when necessary to
address explosives safety, human health, and the environment
• DoD legal authorities include CERCLA, DERP, and DDESB
• A process consistent with CERCLA and these management principles will be the preferred response mechanismresponse mechanism
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DoD/EPA UXO Management Principles (2)p ( )
DoD munitions response actions must be i t t ith th NCPconsistent with the NCP
• Removal action alternatives will be evaluated under the criteria set forth in the NCPunder the criteria set forth in the NCP, particularly NCP §300.410 and §300.415
• Approved ESS required for TCRA, NTCRA, and remedial actions involving explosives safety hazards, particularly UXO
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DoD/EPA UXO Management Principles (3)p ( )
Permanent record of data gathered and a l dit t il f ti t d t l iclear audit trail of pertinent data analysis
and resulting decisions and actions are requiredrequired• To maximum extent practicable, permanent
record shall include sensor data that is digitally-recorded and geo-referenced
Explosives safety, cost, and/or technical li it ti li it th bilit t d tlimitations may limit the ability to conduct a response and thereby limit the reasonably anticipated future land uses
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anticipated future land uses
DON MR Policy in OP5
Use most appropriate available technologies to detect and remove MECtechnologies to detect and remove MEC consistent with future land use Munitions response actions for change-of-p g
use must be compatible with explosive hazards known or suspected to be present Real property known or suspected to
contain MEC and/or MPPEH will not ll b t f d l d f DONnormally be transferred or leased from DON
control until a munitions response consistent with the future land use has
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consistent with the future land use has been completed
Uniform Federal Policy for Quality Assurance Project Plans (UFP-QAPP)j ( Q )
Developed by EPA, DoD, DOE Required for use by DoD for Required for use by DoD for
environmental data collection, including those from an MR projectproject
Contains and describes in detailspecific data requirements or
th i f ti th t t bother information that must becollected to demonstrateconformance to requirements
• 37 required elements into 37worksheets
• Emphasis on systematic
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planning
DERP Management Guidance
Issued in March 2012I l t li Implements policy, assigns responsibilities andresponsibilities, and provides guidance and procedures for pmanaging DERP Establishes funding g
eligibility Requires FS to
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evaluate UU/UE
NERP Manual
Issued in August 2006 (currently under revision)
Summarizes the organization and responsibilities of DoD and DON offices and provides terminology
d d d iand procedures used in implementing the ER program
Discusses funding eligibility, priority setting reporting andpriority setting, reporting, and information management systems
Comprehensive reference for the DON user to properly identifyDON user to properly identify, investigate, and select protective and cost-effective remedies for ER program sites
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program sites
Scoping the RI/FS (1)
Goals of RI/FS scoping are to:• Agree on reasonably anticipated future land
use;Describe the type and content of studies• Describe the type and content of studies needed to initiate response actions and determine nature and extent of MEC/MC and associated hazard/risk;
• Determine if there is a need for remedial/ removal actions; and
• Determine appropriate response mechanisms and authorities
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mechanisms and authorities
Scoping the RI/FS (2)
What about project scoping?• The best way to ensure that a project• The best way to ensure that a project
meets its goals is to have project planning meetings with all the p g gstakeholders (e.g., land users, data producers, decision-makers)
• Scoping ensures that all needs are adequately defined
• The penalty for ineffective planning often is greater conflict and extensive
ki hi h lt i i d
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reworking, which results in increased cost and lost time
Underwater MRS Characteristics
Before you investigate, knowit ’ i tyour site’s environment
• Ocean, bay, river, lake, island• Depth currents wave action• Depth, currents, wave action,
tides, water clarity, turbulence• Local weather
Vieques Island Live Impact Area. Photo courtesy of US
Navy.
• Bottoms (soft, hard, sediments)• Habitat (sea grass beds, coral
reefs, open bottom, swamps, marshes)• Inhabiting biota (especially T&E
species) UXO laying proud on rock
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species) bottom. Photo courtesy of US Navy.
Available Terrestrial Templates
Six SOW templates available at NAVFAC MRP Portal: https://portal.navfac.navy.mil/portal/page/ portal/NAVFAC/NAVFAC_WW_PP/NAVFAC_NFESC_PP/environmental/ERB/MRP, each developed by MR Work GroupWork Group
SOW templatesrelevant to RI/FS:• RI/FS• UXO Quality
AssessmentAssessment• Small arms
RI/FS
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Systematic Planning Process and Project Quality Objectives (PQO’s)j Q y j ( Q )
Systematic planning
PQOs & data collection State the problem
planning requirements come from the
j t t i
Step 1
Step 2Identify the goal of study
Id if i f i iproject team in the form of DQO’s/PQO’s
Step 3
Step 4
Identify information inputs
Define study boundaries
Every project phase identifies them, e.g., PA
Step 5
Step 6
S
Develop analytic approach
S if f tg
and SI PQO’s were developed for your site Collect data
Step 7 Specify performance or acceptance criteria
Develop plan for obtaining data
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CSM Example – Waikane Valley
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Graphic courtesy of US Navy.
Managing Uncertainty
Uncertainty will always be there both going into and
The objective of the RI/FS process is notthere, both going into and
coming out the RI• MRS history may be unknown
RI/FS process is not the unobtainable goal
of removing all uncertainty, but rather t th i f ti
y ywith many unknown factors such as munitions quantities and types dud rates etc
to gather information sufficient to support an
informed risk-based management decision and types, dud rates, etc.
Anticipate not all RI planning assumptions will be valid
gregarding which
remedy appears to be the most appropriate
for a given MRSp• Even the most perfectly
planned project needs to id ti i
for a given MRS. Source: EPA RI/FS Guidance (1988)
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consider contingencies
Terrestrial RI Road Map
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Investigation Considerations –MECMEC
Topography/terrain• Instrument limitations, e.g.,
mountainous conditions will preclude use of wheeled cartspreclude use of wheeled carts
Large flat areas bestinvestigated with towed arraysinvestigated with towed arrays
Extreme terrain conditions. Photo
courtesy of Montanacourtesy of Montana National Guard.
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Towed EMI array. Photo courtesy US Navy.
Investigation Considerations –MEC (2)MEC (2)
Geology• Magnetometers are sensitive to iron-
bearing geology Vegetation
Density determinestype of investigationinstrument usedR l t l Removal not alwaysdesired or possible
Vegetation removal crew. Photo
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courtesy of US Navy.
Investigation Considerations –MEC (3)MEC (3)
Investigations generate ESQD arcsO d ff i ESQD b i On- and off-site ESQD encumbrance requires PTR closures,buildingbuildingevacuations,etc.• Can be
a publicaffairs andaffairs andlogisticschallenge
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Graphic courtesy of US Navy.
Detectors
TypesM t t d di t• Magnetometers and gradiometers
• Electromagnetic induction (EMI)• Ground penetrating radar (GPR)• Ground penetrating radar (GPR)• Multi/Dual-sensor systems• Other, e.g., sonic systems, infrared sensors, , g , y , ,
explosive “sniffers”, neutron backscatter Applications
• Terrestrial (hand-held, man-portable, or towed)
• Underwater
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Underwater
Advanced Sensors
Designed for classification• Measure complete decay signal• Fixed arrays for precise positioning• Multi-axis
transmit/i ilreceive coils
for completetargettargetillumination
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Photo courtesy of ESTCP.
RI Data Collection –Terrestrial MEC Processes
Grid layoutV t ti l
Anomaly reacquisition and Vegetation removal
Surface removalreacquisition and investigation MEC/MPPEH GSV
Geophysical survey d d t ll ti
MEC/MPPEH management Magazineand data collection
Data processing,l i d
Magazine inspections and security
analysis, and anomaly selection
y
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RI Conclusion
Has the project team:• Identified areal extent of contamination?• Agreed on reasonably anticipated future land
use?use?• Described the type and content of studies
needed to initiate response actions and determine nature and extent of MEC/MC and associated hazard/risk?
• Determined if there is a need for remedial• Determined if there is a need for remedial actions?
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Purpose of Evaluating Removal & Treatment Technologies During the FSg g
Develop and evaluate potential remedies th t tl d i ifi tl dthat permanently and significantly reduce the threat to public health, welfare, and the environment;environment; Select a cost-effective remedial action
alternative that mitigates the threat(s); andalternative that mitigates the threat(s); and Achieve consensus among DON, EPA, state,
and local authorities regarding the selectedand local authorities regarding the selected response action
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Response Remedial ProcessPotential Alternatives (1)
No action None Not applicable
Response Action
Remedial Technology
Process Options
DetectionMagnetometry
Surface removal
EM induction
Removal Pick up w/wo Hand excavationSurface removal Removal p
BIP w/wo engineering controls
Treatment Consolidated shot
C i d d i h bContained detonation chamber
Response Remedial Process Potential Alternatives (2)
pAction Technology Options
DetectionMagnetometry
EM inductionEM induction
Subsurface removal RemovalHand excavation
Mechanical excavation
Hand excavation
Treatment
BIP w/wo engineering controls
Consolidated shot
Contained detonation chamber
E i iFencing
Land use controls
EngineeringSignage
Deed restrictions
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Institutional Notices
Educational materials
Example Technology ComparisonTechnology Description EffectivenessHand excavation Digging individual anomalies
using commonly availableMedium: It can be thorough and provides good data onusing commonly available
hand tools.and provides good data on MEC collected.
Mechanized removal of
This method uses commonlyavailable mechanical
Medium: Used in conjunction with hand excavation when
individual anomalies
excavating equipment, such as a backhoe or excavator.
soil is hard. Method works well for excavation of single anomalies or larger areas of heavy ferrous metalheavy ferrous metalconcentration.
Mass excavationand screening
Armored excavation andtransportation is earth
High: Process works very well in areas of heavyand screening transportation is earth
moving equipment that has been armored to protect the operator and equipment f i t ti l
well in areas of heavy concentration of MEC. Can separate several different sizes of material, allowing for l titi il t bfrom unintentional
detonation.large quantities soil to be returned with minimal screening for MEC.
LUCs (1)
Any type of physical, legal or administrative mechanism that restricts the use of and accessmechanism that restricts the use of and access to real property, preventing exposure to hazardous substances above permissible levelsp• Compatible with selected remedy and land use
Consider life-cycle costs before implementing LUC database (DoD policy) Ensure public involvement Land-use changes In CERCLA cleanups, LUCs include engineering
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controls (ECs) and institutional controls (ICs)
Many Different Signs
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Screening of RAs (1)
Identifying, evaluating, and selecting i t dappropriate remedy
• Identify and review remedial technologylt ti / th d th t i talternatives/methods that are appropriate
to the site(s) and the threat it posesS lt ti / th d i th• Screen alternatives/methods using three broad criteria (effectiveness, implementability cost)implementability, cost)
• Select a reasonable number of alternatives for detailed analysis
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alternatives for detailed analysis
Detailed Analysis of RAs
Once a limited number of viablenumber of viable alternatives have been developedbeen developed and ARARs have been identified, the alternatives are evaluated
i t th EPAagainst the EPA 9 criteria
Remotely-operated subsurface MEC removal. Photo courtesy of US Navy.
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removal. Photo courtesy of US Navy.
CERCLA Evaluation Criteria –40 CFR Part 300.430(e)(9)(iii)40 CFR Part 300.430(e)(9)(iii)
Overall protectionThreshold Criteria
Overall protectionof human health
and the environment
Compliancewith ARARs
Primary Balancing CriteriaLong-term Reduction of Short term Ability tog
effectiveness& permanence
toxicity, mobility orvolume by treatment
Short-termeffectiveness
Ability toimplement
Cost
Modifying CriteriaState Community
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State acceptance
Community acceptance
Overall Protection of Human Health and the EnvironmentHealth and the Environment
General evaluation of the alternative’s ability t t d i t h h lthto prevent adverse impact on human health and the environment Must be met in order Must be met in order
for an alternative tobe eligible for selectionbe eligible for selection
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Brett and Kanan Harre. Photo courtesy of the
proud dad.
Analysis of Alternatives –ExampleExample
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RI Report (1)
Site characterization documented in a RI R tReport• Usually provided in preliminary/internal draft
for Navy review draft for full regulatoryfor Navy review, draft for full regulatory review, and final after comments are addressed
• RI report can be combined with the FS report to form a RI/FS report, but the RI and FS
t l b b itt d t lreports also can be submitted separately• Sample RI report included in student guide
and on course CD must be adapted for use
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and on course CD must be adapted for use with MR project
RI Report (2)
The RI report presents• Methods used for the RI• Updated CSM resulting from the investigation• Results of the risk/hazard assessment• Results of the risk/hazard assessment• Determination of whether further remedial action
is needed, and if so, recommended RA , ,Objectives
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FS Report
Results of the FS will be documented in a treport
• Usually provided in preliminary/internal draft for Navy review, draft for full regulatory review, and y , g y ,final after comments are addressed
• FS Report can be combined with the RI report to form a RI/FS report but the RI and FS reports alsoform a RI/FS report but the RI and FS reports also can be submitted separately
• The RI/FS report is a significant document, as it forms the basis for the selection of the remedy and the decision documents
Again thanks to the members of NAOC for
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Again, thanks to the members of NAOC for their review and comments!!