Assistant Secretary of the Army (Installations and Environment) Army Munitions Response Topics Environmental Affairs Committee Society of Military Engineers

Assistant Secretary of the Army (Installations and Environment)

Army Munitions Response Topics

Environmental Affairs CommitteeSociety of Military Engineers

J. C. KingODASA(ESOH)

January 20091


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What is the Issue?


Agenda

• General Principles

• Current Topics

• Collaboration

• Lessons Learned

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General Principles

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Army Obligations• Moral obligation to protect human health and

the environment from DoD-related activities

• Legal obligation for responding to hazardous military munitions including unexploded ordnance (UXO), regardless of location

• Inherent obligation to sustain its mission by protection of the environment


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Philosophy• Risk reduction drives the program

– Worst first – Education considered quickest method of reducing risk– Management of residual risks

• Response actions based on current, determined or reasonably anticipated end use

• One face to the regulators and stakeholders– Early and continuous communication with regulators and stakeholders– Transparency of decision making process

• Munitions response activities must be integrated and designed to minimize impact on environment, while protecting people


Current Topics

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3Rs Explosives Safety Program

GOAL:

• Consistent nation-wide message

• Eliminate duplication of effort

• Rapidly respond, when information is needed

STATUS:

• Revising website to make more user friendly

• New materials developed, as necessary

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3Rs Explosives Safety ProgramWHAT YOU SHOULD KNOW:• If you have a specific requirement:

– Check website– Ask for assistance

• Current material allow adding local contact information and inserting relevant photos

• Local development of material discouraged, duplicates efforts and wastes resources

• DASA(ESOH) is working on ANSI compliant signage for sites

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RCWM ProgramGOAL:

• Formalize lines of authority and processes for efficiently and consistency

• Establish funding to avoid cannibalization of other programs

STATUS:

• SA signed implementation plan 20 Sep 07

• DASA(ESOH) revising Executive Agent (EA) responsibilities for SA approval

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RCWM ProgramWHAT YOU SHOULD KNOW:• Goal: realign current EA CWM responsibilities.

– ASA(ALT): Demilitarization of CWM stockpileSupport ASA(I&E) RCWM Program requirements for

assessment and destruction

– ASA(I&E) for RCWM program

• Policy for CWM response under development

• Roles and responsibilities to be resolved12


RCWM Program• ASA(I&E) to be EA for RWCM Program

• Direction for CWM-related responses (e.g., explosives and munitions emergencies, CWM, other) to be centralized to ensure consistency and attain efficiencies

• USACE to be single executor of CWM-related responses, exception explosives or munitions emergencies

• CMA to support USACE and explosive and munitions emergencies

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Explosives or Munitions Emergencies

• Military Explosive Ordnance Disposal (EOD) units respond to emergencies involving military munitions in the public domain

• Responses limited to addressing immediate threat• Required follow on is done as a remedial response• EOD reports are reviewed to identify:

– Patterns

– Additional MRS

– Effectiveness of education efforts


Technology TransferGOAL: Break the “Catch-22” of not fielding until

technology is “proven”

STATUS: Still experiencing resistance from managers and regulatory community

WHAT YOU SHOULD KNOW:

• Army wants to use “new” technology

• Looking for ways to “prove” technology or reduce contractor’s risk of attempting to use new technology

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Underwater Munitions

GOAL:

• Protect the public from imminent threats

• Comply with PL 109-364, Section 314 (Sec 314)

STATUS: Sec 314’s only deadline is reporting findings of archival research in DoD’s FY09 Environmental Programs Annual Report to Congress

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Underwater Munitions• Removal actions only required when imminent and

substantial threat

• Sec 314’s only deadline is for report on locations of sea disposal operations

• Sec 314’s other requirements will be addressed as Congressional funding allow

• Industry should not view recovery of underwater military munitions as a requirement

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MRSPP QA ReviewGOAL: Ensure consistency in MRSPP scoring

nation-wide

STATUS: QA Panel met four times in FY08 and reviewed over 1,050 applications of MRSPP• Disapproved 108 scores• Administrative corrections to over 200 scores

– Most fixed EHE or CHE to “no known or suspected hazard” when Tables 1 or 11 scored zero

– About 20 corrections did not change the MRS Priority 18


MRSPP QAWHAT YOU SHOULD KNOW:• MRSPP scoring improved significantly over time• QA Panel:

– Approval is primarily based on documentation provided

– Agreement is more likely when all remarks in the modules are populated

• Common issues:– Rationale and site inspection (SI) references not identified

in each remarks section

– Remarks and SI do not support selections made

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GOAL:

• Safely manage MPPEH in compliance with applicable policy and laws

• Minimize potential for future responses to such material

STATUS:

• Reconciled with other policy and guidance

• MPPEH implementing guidance and Technical Manual are being developed

MPPEH Policy

Material PotentiallyPresenting an Explosive

Hazard

Material RequiringDemilitarization for

Trade Security

Material Regulated under Environmental

Requirements (e.g., Haz Waste)


MEC Hazard AssessmentGOAL: Provide direction to the field on use of

MEC HA

STATUS: Voluntary use of MEC HA as a tool for comparison of response alternatives during two year trial period is approved


• OGC has concerns

• DoD will resolve concerns during trial period

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Collaboration

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CollaborationGOAL:

• Maximize efficiency

• Ensure compliance

• Improve protection of human health and the environment

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CollaborationSTATUS: Working with a variety of groups and in various venues

• Canadian National Defence• National Association of Ordnance Contractors• Interstate Technology & Regulatory Council• International UW Munitions Dialogue

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Collaboration


• Adversarial efforts are counter production

• Collaboration provides for continuous improvement and reduced uncertainty

• Need to collaborate early and often – especially at project level

• Regulations and policy are changeable

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Lessons Learned

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Lessons Learned• Need to:

– Work collaboratively with regulatory community – regulatory uncertainty can have significant cost and schedule impacts

– Implement, as early as possible, an aggressive, effective explosives Safety Education Program

– Determine land’s end use as early in the process as possible – use restrictions may be necessary

– Involve the local community early and continuously

– Reduce the “footprint” as quickly as possible


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Lessons Learned

• Must acknowledge:– Collaboration is better approach, than an

adversarial one – Current technology has limitations– Funding constraints– Need for consistent, transparent process


Contact

J. C. King, COL (Ret)Assistant for Munitions and Chemical Matters

Office of the Deputy Assistant Secretary of the Army for Environment, Safety and Occupational Health

[email protected]

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Documents

Assistant Secretary of the Army (Installations and Environment) Army Munitions Response Topics Environmental Affairs Committee Society of Military Engineers