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I think that's the end of the technical reminders that I had for our broadcast today. So with that, I wanted to call up one of my co-moderators and this series organizer, Jr. Reynolds, Jr. From EPA's Office of Superfund and Emergency Management to provide an overview to the Federal Facilities Academy. Jr. I'm going to turn the floor over to you.

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Hey, good afternoon. Good morning, everyone. I'm Jr. Reynolds, and.

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First of all, I want to welcome you and thank you for participating in the Federal Facility Academy webinars. This is the first of 11 courses. Hopefully, you're all able to attend all 11 courses.

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Uh, we kick off today with military munitions Policy Overview with two awesome instructors.

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Those of you that are federal, state, tribal, or local agencies involved in federal cleanup, you're eligible to receive a certificate by not only completing these 11 webinars, but a one, three day course. We have a virtual option.

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which will be 3 through 5 November, and a in-person option, which would be 18 through 20 August in San Francisco. And that information will be available on TrainX.

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And I believe that is all I have, Gene, unless you have anything to add.

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No, thank you so much, JR. So with that, I'm going to take control back and just walk through a quick overview of the classes in the series, and how you can receive credit for participating. So as Jr. Just highlighted, the series is composed of 11 online webinars that are open to the public, which will be hosted live through Cluwin and one classroom delivery.

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That has a limited target audience. For those online webinars we'll be hosting open to the public via cluing, you can participate either live, online, or replaying archived version of each session. For that in-person classroom training opportunity that's open to a limited audience, you must participate in the live event itself to receive credit. That session will not be recorded or available for an archived.

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Playback. For each one of the clue in webinars, you'll be able to obtain an individual certificate of participation after the lab deliveries or based on your replay of each archive. I'll provide instructions on how you can get one of those at the end of each of the webinars.

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If you are replaying an archived version, we provide instructions at the end of each archive on how you can get your certificate. If you're able to complete all 11 webinars, either live.

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We're playing of the archived versions or some mix-match of those, and also qualify and complete that three-day in-person training opportunity that is open to a limited audience. You can then receive an Academy certificate for completing the entire series of 12 events, the 11 webinars and that three-day in-person training opportunity.

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If you have additional questions about the series and how to obtain credit or earn a certificate, please feel free to reach out to us.

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With those quick technical reminders, I think we're ready to officially get started with our presentation materials. So I'm going to call up our very first speaker, and as I do that, I'm going to get his video source up and get his presentation materials up on the screen.

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I do.

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And Doug, I think I see you up there, so let me go ahead and swap out the materials and make sure that you have control that is… that's working for you. And I just wanted to introduce the audience to you, Doug. You are a professional engineer here in EPA's Office of Superfund and Emergency Management, where you have worked on munitions cleanup.

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Uh, and been with EPA for over 25 years, and the cumulative total of 33 years of federal government service. You've worked at EPA, the Army Corps of Engineers, and Navy. You've got a background in degrees in mechanical engineering and environmental engineering, and as noted, you are a registered professional engineer in Virginia.

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Doug, you are also going to be joined by a speaker, John Elliott Harrington, who's here from EPA Region 4, where he serves as a remedial project manager, and he has more than 10 years of experience in environmental investigation, cleanup and remedy implementation at very complex sites. He serves as co-lead for the ammunition support group with EPA's Federal Facilities Forum, and he's also a co-lead of the technology supporting.

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Pardon me, technology subgroups supporting ITRCs underwater munitions Guidance team.

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I'm gonna let the speakers tell you more about themselves, because we have a jam-packed agenda. So, Doug, let me turn the floor over to you to officially begin with today's presentation.

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Okay, thanks, Gene. So these webinars, we do them live on the even years. So this is the first since 2024. One thing I don't know if they mentioned before all the archives from 2024. You don't have to wait to watch them this year. You can watch the archived ones from.

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2024, and then do an update later this year when they're available again to see that. We've been doing this training.

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Um, you know, for quite a while online. I've been with EPA in this position, doing munitions cleanup since 2002, and like Gene said, prior to that, I worked at DOD, at Army Corps and Navy.

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I was in the Federal Facilities Restoration Reuse Office. We went through a very big reorg this fall. The Federal Facilities Restoration Reuse Office, the Serenity Officer Superfund Remediation and Technology Innovation, and our Office of Emergency Management all came into one office. So you're hearing this new term.

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The Office of Superfunded Emergency Management. That's the new Superfund office. We're all together. We've been kind of moved around. I am still doing mostly the same job. I'm doing munitions and then a few other things with DOD support and all, but as far as military munitions, you know, that's definitely where I still am.

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for my view. Department of War, Department of Defense colleagues, I'm gonna mess up those acronyms, because that's a relatively new switch. Please, yeah, I know I'm going to do it. You know, need to remind me when we go. You can give me a hard time if you see me in the future. I will try to get it straight as much as I can.

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Over the last 20-plus years, as I've been working with DOD during this, you know, we've started out in some areas a lot further apart. We've… come to the middle as we're working through these sites, and we're really close on most issues. Again, we have our issues. I have a lot of collaborative groups we work on, which I will get to kind of near the end and highlight those efforts.

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There's very few areas where we're diametrically opposed, and we go to dispute all the time, and we have to do that. We do… we are able to work through and get to realistic solutions and safe solutions at these sites as we go forward.

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So enough of the intro. I think Gene, we wanted to start out with a poll first.

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We sure do. So at this point in time, I'm going to call up a poll and launch it now on the screen. If you have any difficulties accessing the poll in Zoom, I'll just point out that you can use the Q. And a. To share your response. Simply, we're asking how many years of experience do you have with munitions cleanup?

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Is it A 0 to 2, B2 to 5, C, 5 to 10, or D more than 10 years?

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If you have no experience, you would pick option A. And this is just to help our presenters understand the demographics of the audience, so they can share information in a relevant way. I'm looking at about 2/3 of the audience right now, having submitted their response. If you are participating in a group, do your best to find a representative answer. We will not be quality controlling your responses and verifying.

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We do just want to get a sense of your background. I'm going to go ahead and close this one out in three, two, one, and let's share those results. So, Doug, more than half the audience is indicating that they have zero to two years of experience in this area.

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Well.

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And then a relatively even split from 2 to more than 10 years with the remainder.

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Great. That was actually very helpful. I'm glad we kept that in. Um, you're in the right spot. Actually, even the folks with experience, even if you watch this last time, we've updated some things, and yes, we put in 3 videos of things blowing up to keep you entertained later on. But I think this is a great start.

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Um, to an introduction in munitions, uh, response, and that's kind of how I've framed it. We have a lot of RPMs who are moving from just doing your typical our chemical cleanups and stuff, and coming into MMRP. And this is definitely, of course, I want them to start out looking at.

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So let's move on. To the next slide… So, this is what we're going to talk about. A lot of stuff in here. This year, I've invited Elliot, who's an RPM out of Region 4 I've been working with a lot lately to break me up from talking. You don't have to listen to me the whole time and give a kind of a relevant case study for some other water.

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work in the middle. And let's just kind of jump in. So I like this slide. Sadly.

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You know, this is art imitating life. This is a site a little south of DC, Marine Corps Base.

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See all those white flags on the playgrounds? Some of those were high explosive mortars. They mistakenly built on top of a range area. We use this site. I was actually there, we were testing out some advanced classification sensors and all, but we can find munitions anywhere.

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DoD most we have a handle on the inventory sites still pop up every now and again, or something went off site. But you know, there are things that are out in the public domain formerly used defense sites and and others that we don't have controls on yet. So, um, just.

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Be careful. So let's talk a little bit of the boring part here of kind of the the program, the regulations we operate under and kind of get a common understanding with that.

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If you take anything away from this training, um, the last point we normally do CERCLA for these cleanups. And you know we do removal actions, remedial actions. There's some special considerations under Circle 120 for transferring property and doing other things. You know, when we're doing CERCLA.

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you know, we're exempt from administrative and permitting requirements. We'd need to meet the substantive requirements. However, the key point is here. If you're coming into the doing munitions cleanup. It's not a different regulatory process. You're you're in the same thing. You're going to be seeing an Rifs. You're going to be seeing rods. You're going to be doing stepping out, doing removal actions and action memos.

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Um, and ECOS. That's the same process. We've got different technology, got different… a lot of different QAQC, which I'll talk about some as we go through. But really, if you've been working on cleanups before, it's the same process.

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So when I started doing MMRP stuff in the 90s with DOD, everything was done as a removal action. We just did removals for munitions. That's it.

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that sort of wasn't the way CERCLA was designed.

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But doing removals, you get to implement things quickly. You can do emergency time critical or non-time critical. We still use these. I, you know, just looking at, I've been looking at some documents lately where we're bringing in, you know, the removal work into back into the remedial process and going back through.

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This is where we normally live with remedial response to get our permanent remedies. And we're looking at, you know, long-term land use remedies, institutional controls, soil and groundwater remediation.

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You know, and we still have… we meet… need to meet Circle and NCP criteria and Ncp expectations.

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There's no special… stuff for munitions response, where you're in under the circle of program here.

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Executive order 5 12 5 80. This delegates the circle of authority to Federal land holding agencies, you know, to the EPA administrator, the lead agency. In this case, normally do. There I go again, is responsible for the site cleanup.

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Um, we have… we don't transfer as much property now as we used to in the BRAC days and all, but there's a lot of responsibility and issues that can come up when transferring property.

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So the Federal agency is going to conduct the circle action. So we are. This is how in in my agency, its headquarters, where things are different. Federal facilities program versus the I'm going to say private site remedial program. We're overseeing DOD, another Federal agency.

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We're concurring at NPL sites, we're required to concur. Approval of the remedy at the site per that federal facility agreement that we have in place with them. And we EPA has the authority to select the remedies if the parties don't agree. And we've had some remedies that have been disputed, and they've gone all the way up to the EPA administrator.

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Um, haven't had any in a while, and we tend to really… my office is focused on partnering with DOD, even as issues arise, we try to handle them at the lowest level we can and resolve those, and work with our folks, um.

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And DOD to get everybody on the same page. Sometimes it just takes some different folks getting involved and looking at the issues and talking through it to be able to resolve those issues. State and tribal governments, you know, are consulted. There are independent authorities, especially with tribal governments and state laws.

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that factor into this as well. Ncp expectations. You need to treat principal threats. Yes, munitions can be a principal threat waste. We've had this… issue go through. We've actually had a dispute that went all the way up and had to get resolved about that. There's some language we put into documents about it. So they can be. Um…

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you know, some of the expectations, you want to use a combination of treatment, land use controls.

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Treatment is preferred. We'll leave it at that. You may the way we used to do munitions investigations, and I'm going to talk a bit about the technology in a bit.

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We would kind of clean up as we went along. And, um, by the time we get to the record of decision, we're doing a land use control only rod. And that's got some implications with it, but that's kind of like you did source removal, and then you write a rot. You know, think of it that way. So, that's okay with newer technology now, with advanced classification.

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We can do enough sampling to know what we have and then kind of move forward and write a forward looking rod. So maybe things will change here a little bit. Innovative technologies are encouraged. We do use some of those with MMRP. We'll talk about that as we go as well.

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So DoD has two programs, the Military Munitions Response Program.

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And the installation restoration program. Irp is the typical, if you were a Corps of Engineers before HTRW has this tox of radioactive waste. Um, MMRP is Military Munitions response. So, um… I'm gonna talk through some definitions in a bit. I think definitions and acronyms, especially some of them are very specific and are important. But what are the drivers? I've talked through CERCLA. We can be a resource conservation recovery app. You could be working under, there is an NPL site where there's a record order, and that's what they're operating under instead of a federal facility agreements, and that's fine.

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You should be getting to the same endpoint in those. You know, and working through the rest, there's a lot of EPA policy and guidance out. I'm going to talk through some of that specifically as well as some of the DOW policy and guidance and state laws and requirements also key in as well.

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So what is the MMRP? Back in the day. So the Defense Environmental Restoration program dirt, like I said, has 2 components to it. It's all funded the same, and they just kind of split out the sites.

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Um, this was back in 2,001. DOD established the MMRP. I'll talk about these acronyms, UXO, DMM, and MC and stuff in a little bit, but that's all military munitions. So what does it address? Um… Areas and sites on active installations, formally used defense site FUDS properties, and then we still have BRAC sites, base realignment and closure sites still going and and trying to finish up the cleanups there. So it's kind of the…

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Active sites, and then it's the, really, the closed-down sites, FUDs, and sometimes even BRAC for those. And depending on who's doing the work, you may have some implications for how to implement land use controls and what you can actually do.

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at the site, and how well you can access the site there.

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Um, who's gonna be involved? Yeah, everybody. A lot of stakeholders. Npl sites. We're going to have EPA, you know, the federal agency responsible States, tribes, federal land managers. They may own land that you're on, and may have a vested interest in it. They may have been.

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told they were taking the land and not had any choice in it, and need to deal with making sure that cleanup is safe for their folks to do what they need to do with the land. There are other stakeholders involved as well with the public and others that that can be involved, and they can be very vocal and.

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opinionated of their situation and all as well. This is where EPA is. Things have changed a little bit. I had to update this slide. So basically, we have headquarters, and then we have regions. I'm in the first here, Office of Land Emergency Management is the bigger office. Under that we have now this new office of Superfund and Emergency Management OSIM.

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And I have to tell you, we're still figuring things out. I'm in a technical support area. We're all the agency kind of technical experts were led, and PFAS and and everything are all kind of located there. I also, we have a deputy director who's in charge of federal facilities. So I'm also reporting her.

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Couple bosses, um, and they're still trying to figure out how all these things go together. The Office of Resource Conservation Recovery, the RCRA office, Solid Waste Management and Hazardous Waste Management, um, has actually stayed the same, personnel shift and all, but they're still there. Um, we still have our enforcement office, federal facilities, our sister office there.

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And like I said, regional offices are set up similarly. They did a reorg a couple years ago, so you're usually dealing with a Superfund emergency Management Division, SEMD, in those areas, and that's where Elliott is located in EPA Region 4.

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So, uh, you know, this is probably a little dated, but it'll give you the idea.

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You have headquarters with UW, you still call them OSD Office of Secretary of Defense, but now it's Osw. The Department of Defense Exposed Safety Board is still is still, I think, located under there. But then you have. So you have their headquarters, and then you have their component staff. And within the component there's a secretarian staff, field operating agencies, and and they're also the component explosive safety.

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offices underneath that. The point of this slide is DOD, DOW has a lot of different, a lot of layers between where the field work is being done and what their headquarters people are doing.

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Very often, um, yeah, well, for EPA, we're much flatter than that. I have a lot of direct involvement with the EPA regional staff and issues are brought up very quickly. I'll go talk to my counterpart in one of the services, and they have absolutely no idea.

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Because there's so many layers in between. However, they are very good at getting the information, trying to find out, and working through it. But, you know, sometimes we have a lot more success with me elevating up the issue and talking to my counterparts at DOD headquarters and working through it.

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than trying to elevate it through the department that way.

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So, now we're gonna talk about definitions, which are important here. So we have military munitions. Seems pretty straightforward. It's defined in 10 usc, you know.

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conventional chemical ammunition products and their components. These can include things that are a little weird, like, you know, jet-assisted take-up coffee units, ejection cartridges from fighter jet seats and other things like that. So there are some weird things in there, but mostly what you would think are military munitions are munitions.

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Munitions constituent. This is kind of an overarching term we use. It's anything originating from these munitions, unexploded orange DMM or munitions. So Rdx, TNT, the metals, anything else that that may come out that at that site. So, at a munition site, we're going to be.

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looking for the munitions that hose that explosive hazard. And we're also going to be looking for the byproducts, you know, the residues there that came from that possibly came from that.

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Um, this is a term a former colleague of mine, JC, decided to change things up and make this munitions and explosives of concern MEC. And then there's reasons for trying to do this. But this is an all-encompassing term. It includes unexploded ordnance. We'll define the minute discarded military munitions.

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And the last thing, this MC, this is really a term for explosive hazard. So for this MC, we're not looking at just a couple of molecules of it. This is something, you know, these MC present in high enough concentration to pose an explosive hazard. This is like greater than 10% explosives in soil.

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or big pieces of bulk explosive. We don't find that a lot. It has to be at a heavily used OBOD site, a manufacturing area, something like that, where you'd have something like this. It's not super common to find at a regular kind of a fudge training range that we used for two years.

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So here are the important terms. So unexploited ordnance or UXO. These are military munitions that have been prime, fused, armed, or otherwise prepared for action. They tried to shoot it. They dropped it, fired it, launched it, placed it.

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And it didn't go off, and we don't know why.

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You could touch it, it could go off. You could possibly pick it up, kick it, drop it, do whatever, and it would never go off. We don't know.

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what it is. These are very dangerous. Um, this is probably the higher level of danger with the exception of a few special categories. And so we tend to, if we don't know what something is at a site, we're going to treat it like UXO, which is that higher level of, okay, we're not going to handle this unless we absolutely have to. We're probably going to have to blow it up where it does.

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Discarded military munitions are kind of what you would expect. This is DMM is munitions that have been abandoned, dumped, disposed of, buried. They could be fused.

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They are not fired. They're not placed into operation.

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Somewhere you would think these are on the lesser end of the, um… explosive safety iron. There are some special case DMM that are very dangerous, and we don't, you know, that kind of ratchet that up there. But for the most part, that's a little bit on the less hazard thing. Still have high explosives in it, so you don't want to be playing around with these, messing with them, or…

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or doing anything with them. Alright, so this came about this MMRP site inventory. Dod has this up on the website. I know a lot of things have changed. I will double check this and we'll correct it if it's wrong. I think I went through all of them.

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Um, part of the Defense Annual… environmental programs annual report to Congress, they identify the number of munitions response sites and the funding obligated to do this. It's very interesting. The last I looked, I think the 2024 fiscal year was the last that was up at the park site.

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There is… you can search by state, by DOD component here, what will be here. They're required to do this by Congress, and they keep it up. It's pretty basic information, but it's very good to know, hey, somebody found something here. Is there actually a DoD munitions response site in this area? I've actually used it for that in the past and found out, yeah, there was a flood site about.

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a quarter mile away from where someone reported finding munition and calling me.

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Um, munitions response site prioritization protocol. This was established. You know, DOD was ordered in the mid 2 thousands to.

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Um, inventory of their sites and prioritize their sites. This is their national ranking tool for prioritizing their sites. Um, this was coming out right when I started this job in 2002, and we got to comment on it. So there's 3 modules in it. The Explosive Hazard Evaluation Module, the chemical warfare.

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And then the Health Hazard Hhe module, which is kind of more the chemical risk type tool. Supposed to be reviewed and updated annually. I know as budgets are going down, these are used for some funding prioritization decisions across, uh, across the agencies.

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The scoring goes from 1 to 8, 1 being the worst, 1 is chemical weapons on the surface with full public access. I don't think we have any of those sites anymore. Two is high explosives in that same category. I don't think we have any more of those that haven't been addressed. We're kind of down in the four fives and sixes dealing with sites now.

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Um, but you would expect to see this as part of the documentation at the site, you know, in the RI or PASI.

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So what are the unique challenges for munitions sites? We don't have any regulatory standards. We don't have any safe levels. We're looking at an acute hazard. It might be a kind of a low likelihood, high consequence type event is how it's.

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really put forth. Like I said, acute hazard, direct interaction, it can cause serious injury or death. You can blow a hand off, you can take out several people dependent on the size of it. We're looking at discrete items. We're not looking for plumes. It's kind of a.

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Mindset shift when you're looking at how do we investigate the site. The attractive nuisance.

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This, yeah, especially teenage boys. And if you have a sign that says caution munitions, you know, danger, they're going to jump the fence. They're going to go to try and find things. It tends to bring things in. And your conceptual site model too is.

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People coming to the munitions, interacting with them, not, like, in a normal chemical site, the chemicals going out, and we can model that, how that's… and they're getting into people's drinking water, or, you know, air risk, or whatever it may be.

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So that nuisance part is part of the problem of people coming to it and wanting to do things with it. I've seen hunters trying to shoot munitions that they find at sites.

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Um, which is not a great idea either. Um, a picture of some… munitions types, many different types of munitions. This is the smaller end of things, which can even be more dangerous. People can pick them up, take them, do things with larger bombs. People usually don't do that. We have so many different site conditions, pretty much anything you can think of or into underwater now.

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I've cleaned up things on the sides of hillsides where they shot into the hillsides, and they were falling down and rolling down the hillside. It can be quite complicated.

00:27:28.000 --> 00:27:45.000
Technology limitations have… we are where we are with physics. I will talk through some of the technology and how we find things. It's somewhat limited by physics and depth, what we can find, and if smaller things go deeper than we can find them, we can't find them.

00:27:45.000 --> 00:28:00.000
Um, and we may not know we're there. Costs can be a lot… Um, more expensive, especially when you get into the underwater environment. Things get even more expensive in the underwater environment, having to investigate and to clean up.

00:28:00.000 --> 00:28:07.000
So where are we with, um… RACRA.

00:28:07.000 --> 00:28:16.000
The military munitions rule, you've probably heard about this, it's been around since the late 90s. Some of the things that come in.

00:28:16.000 --> 00:28:28.000
Um, with this, you know, under record authority, sorry, we have characteristic tests and management standards and the important one, the standards for open burning, Open Detonation, which I'll talk about in a little more detail in a minute.

00:28:28.000 --> 00:28:51.000
What is this… what did this rule do? It avoid… Avoided record subtitle C on operational military ranges. There's a conditional exemption. So if munitions are used for their intended purpose, remain on operational range, they are not regulatory solid waste under RCRA. There's some other definitions in there about munitions becoming a waste and how relationships are gone.

00:28:51.000 --> 00:29:09.000
Um, some things. You know… exempted under that, a lot of training, R&D, other things. When you see the term active, inactive, that's the same as operational now. This is kind of older language that DOD has gone beyond. Um…

00:29:09.000 --> 00:29:23.000
Subject to RCRA, though, are some things. Leaking munitions, abandoned munitions, and then if things were disposed of, if you look at disposal, even if it's on an operational area, could be subject to it.

00:29:23.000 --> 00:29:37.000
Sorry, I think I hit twice. Nope, there we go. Also, under the munitions rule, there's a lot of talk with emergency response and the explosives or munitions specialist and calls that they can make on it.

00:29:37.000 --> 00:29:54.000
This is one I want to get to. So we're in the process. Epa is. This is our rocker office updating these OBOD open burn, open detonation and waste explosives. There's some factors in here about the munitions rule and emergency response provisions.

00:29:54.000 --> 00:30:09.000
That are being updated. They have a whole work group they've been working through DOD and going through the proposal was put out. We got a lot of comments back. They're still working through it. I know they're still working with DOD. We're ancillarily involved in any of those that might affect, kind of, the cleanup.

00:30:09.000 --> 00:30:37.000
They also issued a memo in August 22 and trying to clarify, you know, their their thoughts on alternative technologies and where that goes, which is really what this gets into. So how does this impact circle cleanups? It's really… you know, this OBOD standard. The law is is an error, and we have to consider that when we're going. So what… what should we do? As we're looking at for the treatment of how we're going to clean up these munitions? Are we going to blow them up? Can we use a detonation chamber? Can we use other things?

00:30:37.000 --> 00:30:46.000
Those… that's really where this pulls into that CERCLA framework there.

00:30:46.000 --> 00:31:01.000
Um, this is a bit oldest guidance, about 16 years old. Now I wrote this. It took us 10 years to get it through an OB interagency review with things, which is probably why we haven't updated. It's still still applicable. So this is kind of the framework for our folks overseeing.

00:31:01.000 --> 00:31:17.000
Mac and the cleanup there, where DoD is doing the work. This is kind of everything that's included in there. We're looking at possibly in the future updating this. We've had a lot of different technologies developed with geophysical detection that that can kind of.

00:31:17.000 --> 00:31:31.000
help us understand this. So that's what I wanted to get into now, with a little bit about detecting technology. I know this is more of a policy webinar, but there's some implications on what technology we're using and what we can do with the site, and the level of data we have.

00:31:31.000 --> 00:31:49.000
So how do we find it? We're not. We don't have an explosion. We don't use explosives detectors, usually. Yeah, I've worked with some dogs in the past and other things, and that's very cool, and it does work somewhat. But as far as large scale, we're looking for detecting the metal case casing as a surrogate for it, you know, on the surface buried.

00:31:49.000 --> 00:31:56.000
Um, there's a lot of mortars, bombs, or steel, some things are aluminum, some things are brass.

00:31:56.000 --> 00:32:06.000
So 2 methods. Magnetic methods, which is a passive. You're you're measuring naturally occurring and man-made magnetic fields.

00:32:06.000 --> 00:32:14.000
Electromagnetic induction. This is an active method where we're actually inducing a signal, which in turn.

00:32:14.000 --> 00:32:29.000
induces the buried metal to generate a magnetic field which we can make. So you're looking at the, you know, inducing that and looking at the response and the decay based on that. And we can do some very interesting things with that, with that EMI method. So I'll mention next.

00:32:29.000 --> 00:32:44.000
So, the systems, what can we do with it? You know, this is kind of the how we do it. Okay, so we have that underlying technology. So digital systems, obviously, this is where we want to be. We want to record all the data, we want to be able to analyze.

00:32:44.000 --> 00:33:00.000
Um, that data, and have a record of that. And that's usually this digital geophysical mapping, DGM. Analog systems, eh, well, that's… if you've seen the guy walking along with a detector, and he's listening for the… the beep.

00:33:00.000 --> 00:33:28.000
And he puts a flag in the ground. This is where we were when I started doing this in the mid-90s, and we would have a sea of flags, and we'd have to go out and dig each one of them. There's no record or data of that interpretation. There's no… it's kind of a real-time analysis, and if the guy went to a concert the night before, and his hearing's a little off, there's some ways to try to catch that with QAQC, but it's… Really, you're in this 40 to 70% detection range, which is not great for doing a cleanup.

00:33:28.000 --> 00:33:41.000
So, we knew that back in 2001, and this was a… You'll tell management principles document that DOD and EPA kind of wrote and and and agreed upon where.

00:33:41.000 --> 00:33:59.000
We want a permanent record of the data, including a clear audit trail of the data and analysis and resulting decisions and actions. That doesn't sound like analog. That sounds like digital to me. So we want to pick the best and most appropriate and effective detection. And then at that time we were having, I think, some concerns with how much.

00:33:59.000 --> 00:34:08.000
regulatory involvement was, and even public involvement for doing that. I don't see that as much anymore. I think we've come a long way. We've come a long way since then.

00:34:08.000 --> 00:34:21.000
Um, but this… this is kind of a summary of a paper that's included in the Munitions response clap volume one toolkit one and two, where we.

00:34:21.000 --> 00:34:36.000
I actually didn't write this. Dod wrote this. They have concerns about the usability of the data anyway, and this is this quantification of analog technology. When we teach an in-person course, we do analog as one of the options, but we want to show you.

00:34:36.000 --> 00:34:57.000
In one of our breakout groups, you want to show you the limitations of it. It's kind of a last-ditch. It's also useful for doing some source reduction. And then, if you're going to go back and resurvey the site. But again, these are all the problems you're seeing. I think we listed 50 to 72% there based on that document for the probability of detection. It's just not a great.

00:34:57.000 --> 00:35:12.000
Way to go. And we've really moved away from this. So I think if you're a regulator or stakeholder here, if you see analog being presented to you, ask why. What else could you have done? We have. There are some handheld better instruments you could use.

00:35:12.000 --> 00:35:23.000
Also, DoD is requiring an SCS or a flag level officer approval to use this if it's being done in a decision.

00:35:23.000 --> 00:35:32.000
We spent a lot of time working with DOD using that electromagnetic induction system and developing this advanced geophysical classification.

00:35:32.000 --> 00:35:47.000
What this does, we take a, for lack of a better way to describe it, a three-day look at the target, and we're looking at the decay of these signals based on all these little transmit cubes that are on that platform there. And you can.

00:35:47.000 --> 00:36:14.000
get a lot of… analyze that data and come up with the size and the shape of the object, what it is, the depth it's at, the orientation it may be at, whether it's upright, partially, and then you can… do a lot more accurate digging, target selection, and less digging with a high degree of confidence. We actually participated in a multi-year advisory group, EPA and states, with all the DOD services working through this, so this wouldn't be such a black box.

00:36:14.000 --> 00:36:25.000
For this. And out of that advisory group came this DAGCAP, they love acronyms. It's the DoD Advanced Geophysical Classification Accreditation Program. When we ask these questions in this advisory group.

00:36:25.000 --> 00:36:33.000
He said, hey, we have a lab accreditation program, and we're gonna be… you're going to be trusting your geophysicists to make a call based on data they see.

00:36:33.000 --> 00:36:52.000
So can we do something to make this standardized and make sure there's a system supporting them? So part of that DADCAP accreditation is two parts. One, it's the company QAQC program that is supporting the analyst, okay? And that's analyzed and looked at by an outside accrediting board.

00:36:52.000 --> 00:37:11.000
Um, and then there's field… type of demonstration that they can actually do with that. They need to be recited. I think it's every two years now. There's a list of them online. Originally, we thought we'd get 4 or 5 companies. I think there's 15 or so that are up there now. So if you're doing any contractor doing.

00:37:11.000 --> 00:37:19.000
Advanced geophysical classification has to be accredited for DoD, period. That's why you'll see some combinations of contractors of the site because they need that.

00:37:19.000 --> 00:37:29.000
There's two different types of systems. One's queued. That's where you survey the site, identifies potential areas, you go back and sit over top, grab the data and go.

00:37:29.000 --> 00:37:43.000
We've moved somewhat past that now to be a little more efficient and we can get the data as we go, as we're doing the initial survey and getting enough data to do that analysis. And that's one pass or dynamic system.

00:37:43.000 --> 00:38:09.000
Um, underwater technology I mentioned it's in… Complex, difficult. We've focused a lot on, um… terrestrial-based development of systems, and now we're applying all of that to the underwater. It's a lot of policy issues coming out. We've got some groups that we're talking through them. Got a bunch of meetings next week with with the UD and others to talk through that mainly.

00:38:09.000 --> 00:38:20.000
How good is good enough? What can we get to? You know, there's new, different technologies, acoustic technologies that you know how well do we do QEQC on those?

00:38:20.000 --> 00:38:40.000
So this is a term we use in our class, weight of evidence for decision making. We don't have a clearly defined endpoint based on acceptable risk. So this weight of evidence approach is is really better way of getting to our endpoint. We look at all the lines of evidence incorporated into that conceptual site model.

00:38:40.000 --> 00:38:54.000
We're not solely relying on one piece of information, although one piece of information, like, hey, we found one munition here, may be driving a lot of things there, but this will allow kind of an informed, defensible decision, you know, on your munition site.

00:38:54.000 --> 00:39:01.000
So how do we sample? Um, and how do you do? We need to find these geophysical.

00:39:01.000 --> 00:39:21.000
Do these geophysical investigations. So there is a tool visual sampling plan. It's meant to. It was designed to find like targets and things like that. So these statistical tools are great. But if you don't know what you're putting into them, and you're using them in the wrong place, kind of like the garbage in, garbage out.

00:39:21.000 --> 00:39:38.000
theory where you're not going to get anything useful. So, if you're looking, say, for… that looks kind of like a target area to me there, we're trying to find, say, a mortar target, and you know what type of mortar and all you can find… design a… this transect coverage, these spaced transect coverage to find.

00:39:38.000 --> 00:39:46.000
that target, if it's there with a high degree of reliability. However, trying to find, say, if you had random disposal.

00:39:46.000 --> 00:40:00.000
They're at a firing point or at a disposal area. There's no statistical way of doing that. So trying to use VSP and do transects. I had this come to me before where there was a whole plan set up to do this statistical sampling.

00:40:00.000 --> 00:40:11.000
Transect sampling to find disposal. And we don't know the size of the disposal areas or anything, so we can't really set it up, it just doesn't work that way. So keep that in mind, and that's the point I wanted to make here. There are classes on.

00:40:11.000 --> 00:40:20.000
you know, VSP and sampling design and the munitions, and we teach that in our class some of what you need to pay attention to, and the inputs to it as well.

00:40:20.000 --> 00:40:28.000
So data quality. I'm a regulator. So I'm going to harp on this. This is almost the end of my talk part, and you get to listen to Elliot for a little while.

00:40:28.000 --> 00:40:40.000
We need good QAQC, we need clear data to make these decisions. And the regulators need to be informed of problems there. So how do we do that?

00:40:40.000 --> 00:40:57.000
Um, back in the day, we used to do these things called geophysical prove-outs. At every site, we would build this elaborate testing area, and the contractors would come out with their A team, and they'd say, hey, we can do this. And we do it really well. Problem is, that's not the team that's going to show up on week 3.

00:40:57.000 --> 00:41:12.000
necessarily. And and there's no ongoing kind of measure of the quality and making sure that they're doing good things that day, making good decisions, and the equipment's working right. So we worked with DOD's R&D folks, and all the components.

00:41:12.000 --> 00:41:29.000
Came up with this geophysical systems verification process, which is still being used today, even though that document was from 2009. In that there's this instrument verification strip, Ibs, and then we rely on on seeding. This is not. This is actually planting.

00:41:29.000 --> 00:41:43.000
Munitions, objects, or, um, similar… similar… these industry standard objects that simulate munitions at the site. I encourage you to look at this ITRC training that came out. It goes through that somewhat.

00:41:43.000 --> 00:41:59.000
Um, this is the IVS. You're gonna see this, you know, put into your things. If you see the term ISO, it's industry standard object. These are, like, heavy walled pipes, because that's a lot of what munitions are. We have known measurements of these. So they're going to run this at the beginning.

00:41:59.000 --> 00:42:04.000
an end of every day. We're gonna know the instrument's working.

00:42:04.000 --> 00:42:16.000
Seeding is really critically important, and these are blind seats, because the people doing the investigation do not know where they are. So we're going to bury these items. We want them to encounter one per day per team minimum.

00:42:16.000 --> 00:42:21.000
Um, and there's two types. There's QC seeds, quality control, and these are buried by the contractor.

00:42:21.000 --> 00:42:36.000
The data collector and analyst don't know where they are. The contractor does, and they span the range of detectability, because they want to test it, they want to know, yeah, we… So, they may miss some of these, and they may have to do a root cause analysis and come back and fix things and all. That's okay, because they're testing.

00:42:36.000 --> 00:42:43.000
The validation or these QA seeds buried by the government, some cases, um, their designee, they use another contractor.

00:42:43.000 --> 00:42:59.000
And we put these at depths where 100% detection is expected. We're not putting them all the way down at the depth of detection or anything like that. If they miss these, it's a very big deal. It could affect their accreditation and they could stop work and they're going to have to figure it out and see what goes on. Maybe in some cases, this has happened.

00:42:59.000 --> 00:43:13.000
The government put them in and… put the location, you know, mark the location incorrectly. And then you go back, and the contractor actually identified that as an item and found it, and then everything was okay. So…

00:43:13.000 --> 00:43:26.000
you will see those terms. Lastly, here. We developed this Ufb quap. It's a tool to guide project teams through the systematic planning process. This was developed for first for chemical investigations.

00:43:26.000 --> 00:43:42.000
Boy, this was difficult to apply to a munition site, because when you're doing QAQC for chemicals versus QAQC for munitions, finding the objects and doing geophysics, they don't really match up super easily. So we developed a work group.

00:43:42.000 --> 00:43:47.000
and developed two of these modules, one Rfs, the others, remedial action.

00:43:47.000 --> 00:44:08.000
Again, the QAP is this following the scientific method, working through the process, and ensuring the data collected will support the intended use. You really do get used to it. This is a consensus standard. The up QAP is across board. Dod has chosen to implement it fully. Epa is now implementing it fully at all our fun lead sites.

00:44:08.000 --> 00:44:26.000
And contracting. I've highlighted some key MRQAP worksheets. I we have whole training we could do on MR quap and how to do it and all that. These are the ones I really pay attention to with communication pathways and procedures, and when regulators are going to get notified of things, you know, the project planning sessions.

00:44:26.000 --> 00:44:41.000
Conceptual site model, big one. You know, data quality objectives, MPCs, if you don't know what that is, we're going to do more training for you. Worksheet 17 is kind of how we're doing the sampling and going in and doing it. And then 22, how we're going to measure that our data is good enough.

00:44:41.000 --> 00:44:47.000
And at the end, we're going to do a data usability assessment. Did we get the data that we need? Is it of the quality that we needed?

00:44:47.000 --> 00:44:51.000
So I think… We're at a Q&A.

00:44:51.000 --> 00:45:15.000
We are at a Q&A. So, Doug, we had a number of questions that came in while you were presenting, and the first area that I'm going to point out is a lot of people are asking about OBOD, open burn, open detonation. First, they want to know if you're going to talk about this at some point, and then the second part of it is, are there points of contact or experts that they can connect with? Because this has been a point of issue at some of their sites.

00:45:15.000 --> 00:45:33.000
So… Yes, so, and it depends. Um, so yeah, I'm not going to go into… I'll talk a little bit about treatment technologies right after Elliott's talk. We have a few videos of size of things and all. It is currently an issue as well as alternative technology and selection. And when you do that.

00:45:33.000 --> 00:45:48.000
It is much more so kind of on the RECRA and the permitting end of things. We have a team in our rocker office. I can put them any folks in contact with Sasha Gerhard is the lead for that and has been working on this rulemaking and things. So if you're talking about.

00:45:48.000 --> 00:45:56.000
Doing open detonations on a cleanup site, that would be me, that we could talk to about that and talk about, you know.

00:45:56.000 --> 00:46:08.000
What implications there are with that. If it's more of the, we're working on a permit at this Arsenal or something, and this is a problem, we want to talk to the record people. That would be that that other group. So I do have all those contacts.

00:46:08.000 --> 00:46:17.000
Okay. All right, we do have a question or two regarding or comments about statutory.

00:46:17.000 --> 00:46:33.000
Coverage of what's covered under what part of what statute now, so I just wanted to make a note that some individuals have commented that military munitions are now part of 10 USC 101F4, and I'll note that as some of these comments are coming in, I'll be sharing these comments with presenters so that revisions can be made.

00:46:33.000 --> 00:46:36.000
Okay.

00:46:36.000 --> 00:46:50.000
But one of the questions came in from a participant who notes that while munitions remediation is covered under CERCLA, munitions as closed ranges are considered hazardous waste and can be managed under RCRA.

00:46:50.000 --> 00:46:57.000
Except. And I think this is where their question is coming from. Dod is requesting that we use CERCLA.

00:46:57.000 --> 00:46:58.000
I don't know if you can reflect on that.

00:46:58.000 --> 00:47:09.000
Yeah, and that's okay. Yeah, that's a… can be a touchy subject, but… Where we are with… so, if munitions, when they're fired and land on their operational range, okay?

00:47:09.000 --> 00:47:24.000
Conditionally exempt under RECRA. When that range closes, you know, at some point in time they become a waste and they're considered discarded. So you know, if the range is put to an incompatible use, or if it's closed, there's some discrepancies on when that actually happens. But.

00:47:24.000 --> 00:47:40.000
At that point, when you're cleaning it up, yeah, certainly munitions can be a hazardous waste. The reactive. They've got explosives in them. They're also a hazardous substance. So you could proceed down either path.

00:47:40.000 --> 00:47:58.000
It depends on the. authorities at that time. I mean, DOD's preferences to do CERCLA. Um, personally, CERCLA is a cleanup statute. It's a little more straightforward to work through, but RCRA should get you the equivalent outcome at the end. There are some sites that… big NPL site down south.

00:47:58.000 --> 00:48:15.000
They've got a record permit, things are going forward. That's fine. As long as everything gets done correctly, maybe, you know, in some cases, there may be a little more regulatory control and input in one statute versus another. So I can't really comment on that. States have their own authorities. I know DoD's preferences to do CERCLA.

00:48:15.000 --> 00:48:29.000
Personally, it is, for me as well. However, there may be some ties into RECRA. Maybe they had a permit, maybe they're doing a clean closure that would require you to go down that path, and that's fine. The technology and all is still the same.

00:48:29.000 --> 00:48:36.000
Most of the policy is still the same. Your documents are going to say have different titles and all, but you can still get there in the end. I have seen both. Far more under CERCLA than under Wrecker or something else.

00:48:36.000 --> 00:48:46.000
Okay. Okay. What about munitions that go off range when you have an active site? Do they qualify as waste and hazardous waste?

00:48:46.000 --> 00:48:56.000
Right? Yeah. So under the if you look, military munitions rule munitions that land off range are are required to be promptly recovered.

00:48:56.000 --> 00:49:00.000
If they are not covered, then they could be considered discarded.

00:49:00.000 --> 00:49:01.000
Okay.

00:49:01.000 --> 00:49:18.000
So those are not part of the operational range. There's no exemption from them. Usually, DoD should have taken care of that. My involvement in that more is we find them later on when the range is closed, and we realize, wow, these keep going out past the border. But CERCLA is.

00:49:18.000 --> 00:49:20.000
Mm-hmm.

00:49:20.000 --> 00:49:29.000
You follow the contamination, so we keep drawing our boundary further out, and then maybe it's in the public domain, and there's some issues with working with that as well. But yeah.

00:49:29.000 --> 00:49:44.000
Okay, I'm going to take just a handful of more questions and then remind the audience that we will pause again later on. We're going to try to get through as many questions as we can in the time that we have allotted today. Uh, real quickly, what type of detection was listed after magnetic?

00:49:44.000 --> 00:49:45.000
when you were going through… Thank you. And then go ahead.

00:49:45.000 --> 00:50:04.000
electromagnetic induction. Emi. which I have to say, is where we… we do use mag some, but the EMI and the advanced geophysical classification kind of go hand in hand, and that's really where we are for a lot of our… working with a lot of our sites in the better tech.

00:50:04.000 --> 00:50:12.000
Okay, we also had an observation that a lot of the systems you were talking about have operators walking over some of these potential munitions areas.

00:50:12.000 --> 00:50:18.000
And they were wondering what degree or to what degree does this pressure sensitivity influence one of the geophysical methods that are being used?

00:50:18.000 --> 00:50:30.000
So there should be a surface. And again, this is a really short webinar versus a very big class. So when we talk through this, there will be.

00:50:30.000 --> 00:50:31.000
Mm-hmm.

00:50:31.000 --> 00:50:44.000
a lot of surface work done prior to geophysical folks coming in. We don't want to blow up our geophysicists. We like them. We want to keep them safe. There will always usually be a UXO technician walking in front of them, making sure there's nothing there.

00:50:44.000 --> 00:51:00.000
Um, as far as sensitivity, couple inches below, couple feet below. I've driven… we've driven over 2,000 palm pound palm on a site, hundreds and thousands of times before we realized it, that that was the bump in the road.

00:51:00.000 --> 00:51:01.000
Mm-hmm.

00:51:01.000 --> 00:51:10.000
Um, and everything was okay for that. However, with UXO, you don't know what can trigger it to go off. I do know that the.

00:51:10.000 --> 00:51:26.000
force dampens quickly going into the soil. It depends on your soil type and all as well. So we've not had any issues to my knowledge, with that being a problem. Now, if we had a an area with super sensitive munitions.

00:51:26.000 --> 00:51:38.000
Precautions need to be taken, and DoD should be able to handle those.

00:51:38.000 --> 00:51:39.000
Hi, James.

00:51:39.000 --> 00:51:52.000
All right. I'm going to share one comment from a future Clue in webinar presenter, James Salisbury from the Army Corps is on. And James just wanted to share an observation about VSP, and noting that you had mentioned it might not be useful for finding those disposal areas. He just clarified BSP will help you find areas of elevated anomaly density.

00:51:52.000 --> 00:52:06.000
So he would say that you can use it to find disposal areas, such as pits or trenches, assuming that you have an estimate of how large those features actually are.

00:52:06.000 --> 00:52:12.000
Mm-hmm.

00:52:12.000 --> 00:52:19.000
Yeah.

00:52:19.000 --> 00:52:20.000
Yeah.

00:52:20.000 --> 00:52:29.000
And that's what I was… I think I usually say, unless we have… because usually we don't have an idea of how big these disposal areas are. Now, if you knew I'm looking for a 15… foot by 50 foot trench, and it's aligned a certain way. You could technically do that, so you could do that. So, um, I agree with that. The things I've seen, um, come across my desk before were, yeah, we think there was some random disposal done in this area, we don't know really how big it is, and they have a 100-foot space transects.

00:52:29.000 --> 00:52:30.000
Yeah.

00:52:30.000 --> 00:52:38.000
I don't know what you can reliably say from that, but you can't say we found it, or not found it. So that's kind of the point I was taking to make. So, good point taken, James. Thank you.

00:52:38.000 --> 00:52:59.000
Alright, excellent. With that, I think we're going to carry on with the presentation in the interest of times, uh, time. So I'm going to call up our second presenter and bring him up to the stage, if you will. So, Elliot, I can see that you're on camera. Let me put you up. You're unmuted, and hopefully you have control, and I'll turn the floor over to you to carry on with today's presentation.

00:52:59.000 --> 00:53:20.000
Great. Let's see. All right. Hi, guys. My name is Elliott Harrington. I'm a Region 4 EPA RPM. I work on federal facility sites. I want to give a shout out real quick to my Paris Island tier one team. If anybody is on a great team to work with.

00:53:20.000 --> 00:53:32.000
And today I'm going to define what acceptable uncertainty is for underwater munitions and explosives of concern.

00:53:32.000 --> 00:53:51.000
So I got this video actually from the Navy. Shout out to the Navy and their advanced munitions course. It's a great course. I highly recommend any Rpm to take it. Just I just love this video, and hopefully it'll wake you up.

00:53:51.000 --> 00:53:55.000
Uragh.

00:53:55.000 --> 00:53:56.000
So I believe that was a detonation of a sea mine in Hawaii.

00:53:56.000 --> 00:54:03.000
How many times.

00:54:03.000 --> 00:54:19.000
Okay, so context for today's discussion. So roughly 75% of Federal facilities have a munition site which would include small arms regions for region 4. A lot of cleanup takes place in these coastal and tidal environments across the southeast.

00:54:19.000 --> 00:54:33.000
So my presentation really focuses on the remedial investigation to feasibility transitioning point and the potential consequences that are attached to uncertainty at the end of an Ri.

00:54:33.000 --> 00:54:51.000
So Doug walked through most of this. However, I did leave this in here to briefly connect how terrestrial investigations differ to underwater. So on land, even though we rely heavily on geophysics, we typically have more opportunities for intrusive conformation. So our assumptions can often be validated more directly.

00:54:51.000 --> 00:55:00.000
Underwater, we're even more dependent on geophysical data and indirect evidence. So confirmation is often limited, and sometimes it's infeasible.

00:55:00.000 --> 00:55:17.000
Um… So in terrestrial environments, we often excavate and visually confirm anomalies underwater intrusive confirmation is significantly more complex. It could be costly and safety sensitive. So at my site, the site I work on Paris Island.

00:55:17.000 --> 00:55:34.000
And accessibility is driven by these extensive title marshes, a term in the South we call pluff mud, which is a marsh-based mud that often can feel similar to quicksand and murky water, which, you know, can significantly limit intrusive investigation.

00:55:34.000 --> 00:55:51.000
We also have sensor resolution that can be limited by your water clarity, depth, platform stability, you know, coverage gaps can occur due to navigation drift or your terrain. Your positioning accuracy in underwater is inherently more difficult than on land.

00:55:51.000 --> 00:55:59.000
You know, also underwater environments are very dynamic. Sediment transport can either bury or unbury objects over time.

00:55:59.000 --> 00:56:09.000
And lastly, we do not have an established quantitative risk methodology for underwater munitions. So this can really make end-state decisions more complex.

00:56:09.000 --> 00:56:17.000
And I also took that image from the Navy Advanced Munition course. I think it's a great image that represents some of these challenges.

00:56:17.000 --> 00:56:40.000
Oh. So now I want to orient everyone to my case study site. So Paris Island is an active Marine Corps recruit depot in Port Royal, South Carolina. It sits in Beaufort County between Charleston, South Carolina, and Savannah, Georgia. You know, since it's an active installation, response actions must be coordinated with ongoing training activities.

00:56:40.000 --> 00:56:56.000
and mission requirements. We have 7 UXO unexploded ordnance sites that have progressed at the end of the remedial investigation, and we have confirmed MEG presence at multiple UXO boundaries. And I think that photo is of the phase one Ri.

00:56:56.000 --> 00:57:19.000
And UXO4, them uncovering some munitions. So I created this slide to show the mapped UXO side boundaries across Paris Island. So a few months ago I visited the facility with the lead environmental manager from the Marines to look at these open water access points along specific UXO boundaries, mainly UXO4, 5, and 6.

00:57:19.000 --> 00:57:38.000
And I wanted to include the perspective here to give you, like, a boots on ground look to how these boundaries interface with the marsh and tidal environments that are potentially open to the general public. But today's discussion, I'm going to be focusing on UX05 and 6. That's that triangle located on the eastern side of the installation.

00:57:38.000 --> 00:57:54.000
And one important note here, I want to say is the shaded area between these two boundaries represents an active training area. And like Doug said, under CERCLA, we generally do not investigate active training areas. Those would become addressed once those training areas are closed.

00:57:54.000 --> 00:58:12.000
And also the firing a point associated with these boundaries is presumed and based on historical information. The exact location is unknown, but it was estimated to be near the top of that triangle area above UX05.

00:58:12.000 --> 00:58:31.000
So Ux05 and 6 are associated with former World War II artillery training areas. The adjacent marshes and waterways likely served as downrange impact areas. So the up range is Ux05, and the downrange is Ux06, but they're portions of the same historical field shrapnel range.

00:58:31.000 --> 00:58:53.000
Most munitions fired were 75 millimeter rounds. The boundaries were updated together because of these overlapping potential munitions impacts. Our aquatic anomalies extending across the marshes and waterways, and most importantly, the uncertainty and inaccessibility of these waterways.

00:58:53.000 --> 00:59:11.000
So this is just a brief investigation summary. I'm going to go into more detail in the next slide. So Ux05 and 6 were 1st investigated in 2010, the followed by the phase one Ri that was conducted in 2012 and 13, and it mostly focused on the accessible part of the terrestrial areas.

00:59:11.000 --> 00:59:27.000
Then we had a phase two that was conducted in 2022 to 2023, which expanded our DGM into the aquatic areas, and we had limited AGC again in the accessible terrestrial areas.

00:59:27.000 --> 00:59:43.000
So large portions of Ux05 and 6 were delineated. However, only a small portion of the operable unit could be intrusively investigated due to that environmental inaccessibility. So about 6% of the total boundary was mapped due to this environmental inaccessibility.

00:59:43.000 --> 01:00:00.000
So that's 30 out of 574 acres. So there were three items that were originally classified as MEC, but then they were confirmed to be material documented as safe. Then they were transferred actually to the Paris Island Museum. They had found some cannonballs from the Civil War.

01:00:00.000 --> 01:00:17.000
So recoveries were limited, and really what I want to point out here is that there are no underwater anomalies were intrusively investigated. So we had aquatic anomalies identified, but we cannot confirm.

01:00:17.000 --> 01:00:34.000
So the Ri identified limited munition recoveries relative to the overall boundary size. So at the time of the Ri, the lead agency elected to apply this conservative language in the conclusions, specifically treating uninvestigated aquatic DGM anomalies as potential MEC.

01:00:34.000 --> 01:00:44.000
And considering those inaccessible areas as potentially impacted. So this approach satisfied our expectation for uncertainty management at the time.

01:00:44.000 --> 01:01:05.000
However, as we're moving further into the FS, we're starting to see how this conservative framing can directly affect the development and evaluation of our remedial alternatives, particularly here, the entire OU footprint is being carried forward as potentially impacted.

01:01:05.000 --> 01:01:24.000
So now we've kind of arrived at this big picture discussion. So the Ri, we were not able to spatially bound mix. So therefore, our Fs must assume potential Meg presence across the entire operable unit. The absence of defined low and high density areas limits the ability to target remedial alternatives geographically.

01:01:24.000 --> 01:01:34.000
And now we have land use controls that must account for a site-wide uncertainty and hazard distribution.

01:01:34.000 --> 01:01:48.000
So to walk through this, I've kind of created this hypothetical example of the type of land use control alternative language you could encounter in an FS. So in this example, the alternative includes a statement as install signage in accessible areas.

01:01:48.000 --> 01:02:06.000
So at first glance, you know, that language seems pretty straightforward. However, there are important distinctions embedded in that phrase that warrant us a closer review. You know, what type of signage is being contemplated here? Is this warning signage intended to inform the public of potential munitions hazards?

01:02:06.000 --> 01:02:26.000
Or is this restrictive signage intended to legally limit access or prohibit certain activities? You know, second, that phrase, accessible areas. To me, that requires clarification. You know, if the signage is limited to accessible areas, how is risk managed in areas where physical signage may not be feasible?

01:02:26.000 --> 01:02:40.000
You know, so these are the types of questions that become important when evaluating these land use controls reliant remedies.

01:02:40.000 --> 01:02:59.000
So this slide, you know, helps highlight that core challenge of, you know, how do we justify the type and extent of land use controls when our hazards are not spatially bounded, you know, minimum controls may not be protective. Maximum controls may be hard to justify or implement.

01:02:59.000 --> 01:03:07.000
You know, I… I do appreciate maintaining flexibility in your Fs. So the remedy is not constrained during your remedial design.

01:03:07.000 --> 01:03:19.000
But land use control alternatives must still clearly define, you know, who's being protected from what activities and under what site conditions to ensure protect protectiveness.

01:03:19.000 --> 01:03:39.000
And I do want to highlight that the lead agency and my project team are actively working through these questions and concerns that are similar, and we're strategizing on the most appropriate path forward, given our site's accessibility constraints. And, you know, EPA is also considering reasonably anticipated.

01:03:39.000 --> 01:03:47.000
future land use in light of our accessibility constraints.

01:03:47.000 --> 01:04:03.000
So this slide, you know, I just wanted to show the difference between warning and restriction controls. So warning based controls. They're informational, you know, restriction based controls. They prohibit activities and are implemented through enforceable mechanisms, often under title 33 authorities.

01:04:03.000 --> 01:04:18.000
So really, restrictions are not just stronger warnings. They're significantly more complex. I mean, this now involves jurisdictional questions. Your water body ownership, DNR, interagency coordination, and.

01:04:18.000 --> 01:04:26.000
Long-term maintenance.

01:04:26.000 --> 01:04:40.000
So, you know, uncertainty is unavoidable at munition sites and is extremely unavoidable at underwater munition sites. I think here the key issue is alignment.

01:04:40.000 --> 01:04:46.000
So if uncertainty applies site-wide, remedies and controls must also apply sidewide.

01:04:46.000 --> 01:04:58.000
If controls are intended to be, you know, targeted or minimal, then your uncertainty must be reduced enough to justify that approach. So really, EPA's perspective here is acceptable uncertainty.

01:04:58.000 --> 01:05:07.000
is uncertainty that aligns with the scope and stringency of the selected remedy.

01:05:07.000 --> 01:05:22.000
Oh, and so I I just wanted to shout out DOW and Itrc. There's programs such as certcp, and itrc that are evaluating these advanced sensors, platforms, and drones.

01:05:22.000 --> 01:05:36.000
And, you know, that those technologies could reduce uncertainty over time. I do want to point out, you know, technology does not replace the need for defensible decisions under current site conditions. And, you know.

01:05:36.000 --> 01:05:54.000
I I've been at EPA for about 3 years. I was a contractor about 8 or 9 years, and I think one of the biggest, the best things I've done in my career, in my federal career, was join an itric team. And our underwater munitions team is awesome. There's so many smart people in that team, and I've learned.

01:05:54.000 --> 01:06:02.000
A lot in just a short amount of time. So if you're a newer Rpm, and you kind of like.

01:06:02.000 --> 01:06:07.000
this kind of stuff, I would highly suggest you to check out Itrc.

01:06:07.000 --> 01:06:14.000
And that sums up my. case study.

01:06:14.000 --> 01:06:27.000
All right, thank you so much, Elliot. I think just in the interest of time, we're going to progress back on with the presentation. Doug, I'm going to call you back up to the stage, if it's all right.

01:06:27.000 --> 01:06:28.000
Sure.

01:06:28.000 --> 01:06:41.000
And then we're gonna thank Elliot for his time. And Doug, let me transition the floor over to you, and we'll carry on. I'll just make a note to the audience. You can continue submitting questions in through the Q&A. We will have a second Q&A break later on today.

01:06:41.000 --> 01:07:02.000
If you have already sent a question in and we haven't brought it up, don't worry, we see them in the queue. We're just trying to get through the presentation content and then pause again later in our session for another Q&A break. So with that gentle reminder and a great big thank you for Elliot, who is going to stick with us because we recognize we might get some questions for you here at the end.

01:07:02.000 --> 01:07:11.000
Great. Thank you. So yeah, this this picture was not Paris Island. It was Camp Lejeune, but that was a great site visit. We were actually watching them use some.

01:07:11.000 --> 01:07:18.000
Um, airborne mag drones to look for munitions in the waterways. And it's very interesting.

01:07:18.000 --> 01:07:32.000
So, um, some people talked about OBOD. There were some questions on that, and I'm hopefully going to address some of it here. So… Comparing cleanup sites with a.

01:07:32.000 --> 01:07:42.000
kind of production facility building munitions, and then having to get rid of some, because they're either off spec, or they're just out of date.

01:07:42.000 --> 01:07:58.000
Those things are… it's different levels of risk. I wouldn't necessarily classify the reduction things as handling out a lot of UXO. It's munitions that they can handle, that they can move, that they can store for a period of time.

01:07:58.000 --> 01:08:09.000
and get into these alternative treatment technologies. So a lot of the work that's been done with OBOD and talking about alternative treatment technologies has really started out gearing towards that.

01:08:09.000 --> 01:08:24.000
Um, there's permitted facilities where they have this kind of a production mode of going and of, you know, they're producing things, and then they need to get rid of some things. So for… like I mentioned before about UXO, a lot of this munitions we find on our sites have been fired.

01:08:24.000 --> 01:08:38.000
used, put into production. We don't put into, you know, shot dropped, whatever, and are dangerous. Excessive handling, storing, and doing things with those can really ratchet up.

01:08:38.000 --> 01:08:53.000
the risk for the site workers as well. So a lot of times we're doing blow in place or what's called consolidated detonation at a site for cleanup site for these. We're not going to transport these things off site.

01:08:53.000 --> 01:09:00.000
There are some, you know, exceptions to this, where we've found large, um.

01:09:00.000 --> 01:09:18.000
you know, disposed of, buried, you know, mortars that were in good shape, and back in the 90s, we actually had some recra orders to use a detonation chamber for those and to minimize releases to the environment and all. But it's really a kind of an initial safety call for that. So at cleanup sites.

01:09:18.000 --> 01:09:37.000
more often than not, we're we're having to utilize this this opened OBOD more open detonation, although there are some unique alternatives to Opod, and they need to be evaluated in the circle process, and you need to provide the justification. And that's something we haven't done in this.

01:09:37.000 --> 01:09:52.000
program necessarily as well documented to it is to explain the rationale as we're looking through. Okay, we're going to go find these munitions, and then we need to do X, Y, or Z with them of why we're doing that. There may be some cases where it makes sense, you know.

01:09:52.000 --> 01:10:11.000
Massachusetts Military Reservation back in the day, we realized we had a lot of discarded military munitions, which were safe to move and store for periods of time, and we had to really… Push hard to get DOD to do that. Different detonation. Now, this chamber, I took this picture 2018.

01:10:11.000 --> 01:10:16.000
2020 on. 2022, I think it was in 22.

01:10:16.000 --> 01:10:33.000
Down on Vieques. This is one of the two chambers they had to use. They used it. It was actually congressionally funded and kind of pushed in there, but it was useful for some things. However, it's really difficult to use and to get to where it needed to be, even though it was somewhat mobile.

01:10:33.000 --> 01:10:50.000
exceptionally hard to move down the road. Things would rattle loose. You couldn't even get to the area. And the amount of handling that it required to wrap the munitions in donor explosives and get them inside the container and then get them into the thing could be very dangerous for.

01:10:50.000 --> 01:10:58.000
for a lot of the UxO that we have to deal with. So what my expectation is with alternative tech.

01:10:58.000 --> 01:11:03.000
Which is kind of the big thing in OBOD now is that it's looked at in the.

01:11:03.000 --> 01:11:18.000
alternatives process when we're looking about how we're dealing with munitions and all, and there really needs to be a good rationale to meet that ARR for that is why we've selected what we've selected. And I've talked to DOD about this over the last few years through some of my national groups.

01:11:18.000 --> 01:11:40.000
And they agree, there may be some situations where we really need to strongly consider looking at using, you know, some kind of alt tech, usually a detonation chamber similar to this, maybe a little bigger. Um… at a site where we may have that quantity of stuff that we can move, handle, store, get into these systems and do it. Do it safely for our folks.

01:11:40.000 --> 01:11:58.000
So next, talking about open detonations and vehicles. This first one, I just did a couple videos to wake you up a little bit of size of detonations. This is a little bit smaller one. This is we're about a mile out in an observation post, and I'll start it.

01:11:58.000 --> 01:12:03.000
Boom! Oh wow. point of view.

01:12:03.000 --> 01:12:21.000
And if you're an engineering geek like me, you notice, hey, that took 4 seconds to get there. It's probably about a mile. But that was 200 pounds, I think, or so detonation. This next one I was involved in Region 6 on an emergency response, and it turned into a long-term a little longer removal.

01:12:21.000 --> 01:12:36.000
Um, where we had 21 million pounds of unstable explosives and propellants. Part of this, um, two bunkers got really wet, and some of the material was deemed highly unstable to the point no one was going into bunkers.

01:12:36.000 --> 01:12:56.000
And we had to have military explosive awareness to total folks come out and detonate two bunkers in place. So where you saw 200 pounds or so before, now you're going to see about 200,000 pounds here. And this is really the last resort. There was nothing else we could do, and we were afraid these these bunkers were going to detonate themselves at some point with people in or nearby.

01:12:56.000 --> 01:13:00.000
If you look really close, you can see the debt cord on the on the ground go.

01:13:00.000 --> 01:13:08.000
Farno!

01:13:08.000 --> 01:13:17.000
If you'd like to see more videos of this, you can Google Campmen and CBI burn. There's lots of things. I grabbed the stuff used to YouTube.

01:13:17.000 --> 01:13:30.000
So that was a bit about technology. We are somewhat limited with what we can do with technology. And even if we really want to push hard. We have to do things in a safe manner.

01:13:30.000 --> 01:13:45.000
Now I'm going to talk through some kind of… policy issues and where we are with certain things, and what's taken up some of my time here. So, you know.

01:13:45.000 --> 01:14:01.000
Regulatory issues. So we we've sort of resolved this munitions as a hazardous waste, hazardous substance. This was a big deal when I started this in the early 2 thousands. We went to a 3-year long dispute at Fort Ord.

01:14:01.000 --> 01:14:09.000
With the army, and finally got them to acknowledge, yeah, okay, we understand that we kind of agree with that. So.

01:14:09.000 --> 01:14:25.000
Munitions are a hazardous substance, hazardous waste, and therefore hazardous substance when they're at a cleanup site. It's very pretty straightforward. Those authorities are there. Those are the… that's what the authorities DOD is acting under for Circle is cleaning up hazardous substance.

01:14:25.000 --> 01:14:46.000
Um, we've had some… disagreements in the past as well about principal threat waste determination. Epa believes that munitions can be a principal threat waste and need to be treated. We've worked on some language up just reviewing a proposed plan, had some language in there. It's pretty straightforward.

01:14:46.000 --> 01:15:06.000
Um, that just means if we know that there's… If we determine these munitions are that, that we're going to treat them, we're not going to leave them there. And that's kind of important for us for that determination to be made, so that that would be… those things would be removed and treated. Can't really do much about what we can't find, and that's the uncertainty of technology and the depth we can find things.

01:15:06.000 --> 01:15:22.000
ARA's, I did have a… used to have a quiz in here about what Arar stand for, and I know I'm going to get it wrong. So we're not going to go there. But we don't have a set standard of when you're going through the feasibility.

01:15:22.000 --> 01:15:39.000
study and develop identifying them in the Ri. We are working on it within the agency. It's something Elliott and I have brought up with our RPM group some, and we're trying to get some consistency as far as, you know, pushing back when errors are.

01:15:39.000 --> 01:15:55.000
kind of brought up by Dod. I've had some interesting involvements lately with DOD, where I had a site on the West Coast and the site on the East Coast, uniquely similar, because there was some big explosion there in the past, and and one site did a pretty decent job of, I thought, of identifying the ARCH.

01:15:55.000 --> 01:16:11.000
in the documents. And then the other site, they obviously weren't talking to each other. This is a year or so later, came back and pushed really hard of, there are no ARARs for munitions. So if you get that answer.

01:16:11.000 --> 01:16:20.000
Flag should go up. You need to have a bigger discussion, maybe talk to me about that. So when I pointed site 2.

01:16:20.000 --> 01:16:35.000
Back to site one and said, hey, you have a uniquely similar site to this, and this is the ARS they came up with. They went, oh, that's very interesting. And problem resolved and kind of went forward. So my point there, I don't think DOD, UOW has a very standardized set.

01:16:35.000 --> 01:16:50.000
Within there is… you know as well. So this is kind of an evolving thing as we get into further in the circle of process. Something I want to pay attention to, make sure we we have everything listed as well.

01:16:50.000 --> 01:16:57.000
So let me see. Sorry, there we go. I knew there was a different slide. So.

01:16:57.000 --> 01:17:17.000
Rod and decision document language. I know James is on, so he can smile now, because I'm only going to do one slide on this now, but I'm going to plug the training. So, DOD was supposed to have their expense of environmental restoration Program DERP Forum last year two years ago than last year got due to all the craziness with everything federal and.

01:17:17.000 --> 01:17:33.000
meetings and conferences and all getting canceled, so they decided to do a training kind of on the sessions, and I had agreed to be on a session where we're going to talk about feasibility, alternate feasibility studies, alternatives, analysis, and then rods.

01:17:33.000 --> 01:17:48.000
And I'm going to talk about the rod part. So this is a little preview, but going to go in a lot more detail, and I encourage you, I think the training will be later in June. We're still working on dates and stuff for that, but DOD is going to get that information out for it.

01:17:48.000 --> 01:18:00.000
Some of the things we need. You need to have a robust remedial alternatives range. This happens several times, where it seems a site was progressing through, and they really.

01:18:00.000 --> 01:18:16.000
Thought they had the remedy selected, whether it was kind of a no further action or just lux, and that's all they analyzed in the FS, and then it went to proposed plan, and Rod's at EPA for munitions are coming up to headquarters, kind of a voluntary, but.

01:18:16.000 --> 01:18:26.000
Highly recommended review. We haven't made it mandatory, but, um, so I'm looking at a lot of them, and I caught some inconsistencies, and I said, well, I don't think we can support that, no further action or something.

01:18:26.000 --> 01:18:37.000
Let's go… let's select maybe we want to do some LUX at that site, because the inherent uncertainty with with certain things, and how well the investigation was done, and what they could even accomplish.

01:18:37.000 --> 01:18:52.000
There were no other alternatives that were analyzed, so they had to go back to the feasibility study and do an addendum, and then come back through. So that's not really useful. And I think we need to look at analyze treatment alternatives as well as different land use.

01:18:52.000 --> 01:19:12.000
alternatives, and I mentioned before, if possibly there's some kind of alt tech for the treatment of admissions themselves that need to be analyzed in there. So we're not going to default to Lux only every time. That's, I think, the rods as we're moving forward, and when we're using advanced classification, we're going to be looking more for a forward-looking of, hey, we get enough data to move forward.

01:19:12.000 --> 01:19:22.000
Make the decision, and then we're gonna go actually clean the site up, versus… When I used to be doing all the field work, we would clean it up as we go. We couldn't tell with the early.

01:19:22.000 --> 01:19:32.000
DGM sensors. We would just do anomaly picks, and we would just say, oh, all these anomalies are above a certain threshold, let's go dig them and see what they are.

01:19:32.000 --> 01:19:40.000
We didn't have enough data to understand that was a munition, that was a horseshoe, that was a piece of metal. We can do that in a lot of cases now.

01:19:40.000 --> 01:20:06.000
So by the time we did all that analysis, we had dug most of the site. So that's why we have some luck-only rods that are coming through. Um… Rod and proposed language. Boy, keep in mind what your rod is for. It's your public description of your decision at the site. People need to understand it. If the headquarters EPA project manager has been working with you on the site for 20 years.

01:20:06.000 --> 01:20:17.000
Tries to read the rod and can't understand what you're trying to say and do, you've really missed the audience in a big way. To have that happen with some rods in the last year or two, we've had to go back with significant comments.

01:20:17.000 --> 01:20:27.000
Breakout boxes, tables, things, just think of… keep that in mind when you're doing it, as opposed to just jamming all the information in and having in there, but you need to… you really want to.

01:20:27.000 --> 01:20:44.000
Not paint the story. Yeah, paint the story of why you did what you did, and where we are with the decision, and why you're selecting that remedy. And it needs to be clearly supported, and talk about the risk inherent at the site, and what you… what you want to do, and why you selected this remedy. It really makes a difference.

01:20:44.000 --> 01:21:09.000
We have rods that, from when I was in college in 91 that turned into a nightmare because it was kind of a very vaguely written rod, and… People tried to unilaterally interpret it one way and we push back, and that duty component didn't want to go along with us. We went to dispute and we had to get the penalties, and it was just… it's a mess on both sides if you're not clear.

01:21:09.000 --> 01:21:28.000
and understandable for the decision. I'm not going to be around when a lot of these remedies are implemented, or when they're doing 5-year reviews later on. I want to make sure, and some of you may not either, some like Elliot, you're going to be here longer. But you may… they want to be clear, they need to stand the test of time, so people look back, they understand why you did things, and maybe, too, they realize, wow.

01:21:28.000 --> 01:21:35.000
No, we need to go back and change that, and that's okay. There's a process for doing that as well.

01:21:35.000 --> 01:21:44.000
So another fun topic, and I'll do people are probably cringing right about now. Munitions or hazard assessment, whatever you want to call it for munitions.

01:21:44.000 --> 01:22:00.000
So munitions risks are unique. You know, we're looking at individual discrete item. We're not looking at a plume. And again, I'm talking about the explosive hazard. I'm not talking about the munitions constituent, because that we're going to analyze just like other chemicals and we can do risk assessments. We can do that. That's not what I'm talking about now.

01:22:00.000 --> 01:22:09.000
Just talking about the explosive hazard. So when we're looking at this, every munition is a point source. There's a wide type of.

01:22:09.000 --> 01:22:30.000
These types of source, you know, types, components of munitions are at different depths. I mean, we can much easier to define these chemical chemicals that way, but trying to figure that out is is is very difficult. There's a direct correlation of the hazard to the exposure, you know, and it's it's in a.

01:22:30.000 --> 01:22:45.000
It's in a it's a chronically acute risk, you know. It's a low consequence, possibly at, say, a flood site. It's not a high likelihood you're going to have that interaction. You're going to do exactly what you need to do. But there's a high consequence to that event, should it happen.

01:22:45.000 --> 01:22:53.000
in the public. So, and that's a really difficult thing to quantify even at EPA, under our.

01:22:53.000 --> 01:23:16.000
you know, scoring for the NPO. We can't score explosive hazard for munitions. We have to score chemical release stuff to list them on… onto the NPL if we do. So, it's just… Because we did the chronic exposure and we've never gone back to change the acute exposure pathways. We don't really have an agreement on acceptable risk.

01:23:16.000 --> 01:23:33.000
you know, what is considered acceptable with munitions is kind of based on opinion, not really research or agreed upon things. We don't have an agreed upon methodology, necessarily. We have some tools we can use, and I think we can work through that, get the information we need.

01:23:33.000 --> 01:23:42.000
to fill back into the Circle process and come to a solution at a site. I think we can do that. But there's some pitfalls you have to do.

01:23:42.000 --> 01:23:53.000
So let's go back one thing. If you're saying, if you find your project team saying, or or the DoD folks, or the contractor, whatever saying to you as a regular.

01:23:53.000 --> 01:23:58.000
Well, we're doing this because the tool said we need to do that.

01:23:58.000 --> 01:24:14.000
You've completely missed the point of all the tools that are out there now. So those tools are there to inform the process, the decision process is going through the CERCLA process. Just because you get an output to the MEC hazard assessment or the RMM risk management methodology, which I'm going to talk in a minute, doesn't mean that's the answer.

01:24:14.000 --> 01:24:28.000
That's informing into your decision. And if that's another point you can take out of that is that keep that in mind with what that is. That's not the decision. Those tools are not designed to be that way. They are relative tools.

01:24:28.000 --> 01:24:38.000
So DOD's Rmm is out. They developed this in-house years ago.

01:24:38.000 --> 01:24:57.000
10 plus years ago, um… Yeah, because it was the 2017 when it first came out, we started hearing about it before that. There was no regulator involvement in the beginning at all. We pushed back pretty hard, us EPA and states wanted some to fill in. This is a.

01:24:57.000 --> 01:25:20.000
table-based type of, um, tool. There are some good parts to it. Um, now, you know, the way they set it up, the information they gather, and pulling it into exposure areas and all is very valuable, and I think you should be doing that anyway, and developing your conceptual site model. I have some concerns with how the.

01:25:20.000 --> 01:25:37.000
This tool has been used. It… It gives you an acceptable slash unacceptable output. But what do they mean? There's no definition with that. So you hear acceptable and cleanup.

01:25:37.000 --> 01:25:53.000
That kind of takes you one path, and that's not really, I think, where they really want to go for that. So right now, this tool's really supposed to only be used for baseline risk for DoD's guidance. But that's also got some inherent things because you could get acceptable for the baseline risk.

01:25:53.000 --> 01:26:08.000
but still need to continue through the circle process. It's not an exit. You can't use this tool to exit Circle. That actually happened at a site where I was given a feasibility study to look at by the region, and I and it was a site, and it had 2 areas, and.

01:26:08.000 --> 01:26:24.000
One of the areas… it was in some of the maps, but they weren't talking about it. And I said, what? What? I asked I asked… my RPM, why is that other site not in there? And she said, um, I don't know, let's go look. And she just picked the site up as well from another colleague who had left.

01:26:24.000 --> 01:26:41.000
They got an acceptable on RMM running at the baseline, so they cut the site out, even though there were still munitions there, and they thought they had exited Circlet, and that was a big misunderstanding, and we fixed it and come back in, and there's some training that needs to go through. That's not what that tool is used for. It's meant to facilitate discussions.

01:26:41.000 --> 01:26:54.000
Not determining the level of risk. You're not saying, oh, this is acceptable for UUE because to do a baseline risk for me is pretty simple. You either have or suspect you have munitions. Yes, move forward.

01:26:54.000 --> 01:27:00.000
It's a very high bar to say no there. So.

01:27:00.000 --> 01:27:05.000
Still some work to be done in earlier versions. They did use it in the feasibility study.

01:27:05.000 --> 01:27:16.000
I find it a little less helpful than, say, Mecca, which I'll talk about next and then that, because if you get acceptable for all the alternatives, there's no other information, really, to compare and contrast your alternatives.

01:27:16.000 --> 01:27:27.000
So one of the other tools that was developed earlier, say jointly developed by EPA states and DOD. Dod signed on kind of a trial period. All those folks are gone now.

01:27:27.000 --> 01:27:39.000
It's a good tool to use during the feasibility study. So if you have a list of alternatives, you can run Macoff for each alternative, and you get a you get a score. You get a relative risk reduction between the different.

01:27:39.000 --> 01:27:54.000
remedies. That's not the decision in itself. You're gonna pull it into the circle process, and you're going to look at cost and acceptance and other things. All the other 9 criteria to do that. But it's one piece to go in there. I did see this use.

01:27:54.000 --> 01:28:12.000
an incorrect way recently, where they kind of almost changed their sport categories. They changed the term of, yeah, we want to get to a 2, and then we'll be good to go, you know, and they changed how this from a relative tool where you compare things to a decision tool, and that's not how this was meant to be done.

01:28:12.000 --> 01:28:24.000
Um, it's still useful. It was designed in the mid 2 thousands. It's still up. I I think it adds value to the circle process when you're looking at your remedies. If you do it correctly.

01:28:24.000 --> 01:28:48.000
Okay. Um, the other one, the MHAT, the Air Force took and made some changes to it. Air Force has some bigger bases. There's some disagreement about Lux and… They wanted to give it more for Lux, a little bit less for treatment. We didn't agree with that because we're kind of going off the NCP of a preference for treatment and less lux for that.

01:28:48.000 --> 01:28:59.000
The thing I don't particularly like, um, munitions debris only as a category. So munitions debris is just, you know, pieces of munitions that you may find at a site.

01:28:59.000 --> 01:29:11.000
The thing I really don't like to hear is, oh, we only found. So if you say you do transects at the site, you investigate 10% of the site, and they come back, and they say, we only found munitions debris. What does that mean?

01:29:11.000 --> 01:29:17.000
Well, to me, you found evidence of use at the site.

01:29:17.000 --> 01:29:24.000
You didn't write yourself out of the site and having to do anything else. You found evidence of munitions use.

01:29:24.000 --> 01:29:34.000
Right? There may only be a couple actually live items there, and you just didn't get incredibly lucky. I've had this question asked to me when they did.

01:29:34.000 --> 01:29:40.000
transects that covered 2 or 3% of the site. And they said, well, we didn't find any UXO or MEC.

01:29:40.000 --> 01:29:55.000
Okay. So you found munitions, debris. You found evidence of use. It looks like you identified a high density area. Yeah, but we didn't find any mech. Well, to find, say, if there's 20 MEC items on a on a site of that size.

01:29:55.000 --> 01:30:06.000
When you're only sampling 2% is really hard to do. So keep in mind what you're… when you're investigating, what you're looking for, what the… what it means with that.

01:30:06.000 --> 01:30:13.000
So get asked this a lot. Unlimited use, unrestricted exposure.

01:30:13.000 --> 01:30:22.000
If you ask me this 24 years ago… God, it's been that long since I when I started with this position at EPA, I would have said no.

01:30:22.000 --> 01:30:36.000
Um, we were not there with understanding… and that's just with a look at a site, do some geophysics, and then say, do we get it or not? Um, is it possible? Eh, maybe. I mentioned the UFP QAP Module 2 before.

01:30:36.000 --> 01:30:42.000
Um, there is an example where we walk through getting to UUE at a site.

01:30:42.000 --> 01:30:59.000
I think it's… few sites that are going to get that path. I know DoD has to analyze this as one of their program requirements to analyze have UAE as an alternative. A lot of times it gets screened out because it's impractical, which makes sense.

01:30:59.000 --> 01:31:04.000
With UUE, we really want to… you want to start planning with the end in mind. You really should do that for all these sites.

01:31:04.000 --> 01:31:24.000
If you ask at the end of the process, what do we need to get to UUE? I've had that asked to me at several large, uh… NPL munitions cleanup sites that have gone on for 20 or so years. They started out with Mag and flag, moved on to some DGM, did some different areas. We've had some QC failures, QA failures along the way.

01:31:24.000 --> 01:31:36.000
There was no comprehensive plan to get to that endpoint, and my response to them at the time was, well, here's the good news. You removed a lot of stuff. You found a lot of stuff. If you want to go to try to get to UE.

01:31:36.000 --> 01:31:45.000
When you resurvey the site and set your quality levels to that high bar, maybe we can try to get there if everything's accessible.

01:31:45.000 --> 01:32:07.000
And I like to hear that. Um… Sight characteristics really throw this off. If you can't survey an area and look at an area. I've had areas of paved over tree growth. Did the trees grow in afterwards? The munitions were used there because they could be in the root ball in there. How good was your QAQC? How good was your data? You know, quality?

01:32:07.000 --> 01:32:16.000
How we're getting better. One of the improvements my colleagues from the core of engineers came up with was this.

01:32:16.000 --> 01:32:29.000
you know, a 3D CSM and a depth profile, and showing where things are in relation to, you know, reliable depth of detection and all. It really makes a big difference when you're looking to think kind of visually that way.

01:32:29.000 --> 01:32:37.000
you know, what about technology limitations? What did you use here? I can tell you without a doubt. If you used analog detection.

01:32:37.000 --> 01:32:49.000
The survey as I can clean it up, do not bother coming to tell me you reached UUE, unless you happen to be digging and sifting. Most of the… UE determinations.

01:32:49.000 --> 01:32:55.000
Getting there is more of a dig and sift type of operation, followed by geophysics to ensure we got everything.

01:32:55.000 --> 01:33:07.000
You know, but… Continue as you go through the process, build a very strong CSM, update it frequently, try to limit the uncertainty as you go. It's additive and you'll keep going.

01:33:07.000 --> 01:33:15.000
And also, this is one thing that I guess that other project team needed to learn acceptable risk does not always equal UE.

01:33:15.000 --> 01:33:30.000
You know, that's especially with the RMM acceptable risk kind of thing doesn't mean you can go do anything necessarily with that property.

01:33:30.000 --> 01:33:45.000
There's some other munition sites that can be problematic and have some interesting challenges. Obod, I noticed there were some questions on this as well. I don't do permitting that much. I've been involved in some.

01:33:45.000 --> 01:34:00.000
interactions with our record office and stuff. These, when I mentioned OBOD operating sites, this is the permitted sites that they're working through, and a lot of the states have… are authorized under RECRA and are the ones doing… issuing the permits. There's actually a Subpart XOBOD, um.

01:34:00.000 --> 01:34:29.000
There's a subpart X work group that they meet, and then they talk through these issues, and we do listen into that and some crossovers into the cleanup program as well. Operational ranges… are tricky. I mentioned the munitions rule and the conditional exemptions that go under those. Nothing gets the bosses called quicker to regular agencies when you start messing with operational rangers. Like I said, the munitions on operational ranges, they were used for their intended purpose or conditionally exempt.

01:34:29.000 --> 01:34:34.000
Um, there's a lot of different laws and regulations that may.

01:34:34.000 --> 01:34:44.000
go there. Disposal in your type of circle actions, like if munitions were disposed of, there could be a release, there could be a VOCs on the range stuff. I've dealt with that before.

01:34:44.000 --> 01:34:58.000
Circle still applies. Now, we give great weight and deference to DoD and their training mission in a lot of these cases, we are able to ascertain that the contamination was limited and.

01:34:58.000 --> 01:35:11.000
Kept the exposure was kept in check by the controls on the operational range, and we can defer doing cleanup on that and not interrupt with that, or maybe we can work with them on schedules and all that. So if some. The point here is.

01:35:11.000 --> 01:35:21.000
Um, they're also not eligible under DERP, so if there was something that was going to need to be done there, that would be a different funding source for them as well, which could be problematic as well.

01:35:21.000 --> 01:35:43.000
Keep in mind, operational ranges can be very tricky, very politically sensitive, not politically, but sensitive and management way within DOD. So you want to work with them. If you're EPA, if you're looking at something on operational range, I recommend you contact me and work with the headquarters office on it as well.

01:35:43.000 --> 01:35:59.000
We've got a lot of partnerships. I mentioned this before, this is my last slide or so, and we got some time to go through some, um… questions and answer. Do a lot of partnering over the years. I've spent a lot of my time doing that, and I… that really helps us to.

01:35:59.000 --> 01:36:11.000
keep problems from bubbling up and having having to slow the cleanup process down and go through disputes. There are times we need to go to dispute, and we need to work a few issues out, and we've had a few of those.

01:36:11.000 --> 01:36:24.000
Um, so one of the biggest groups for that policy kind of thing, it's now called the Munitions Response Dialogue. It used to be the Munitions Response Committee, then we had a state-led version in the middle due to some FACA concerns and all that, but it's still this national level dialogue group.

01:36:24.000 --> 01:36:29.000
Um, it's shared by DOD, EPA, and there's a state.

01:36:29.000 --> 01:36:34.000
co-chair as well. Um, we have a meeting in two weeks, I think.

01:36:34.000 --> 01:36:40.000
In DC, we're going to talk through some things. This is really a dialogue group. We're not doing.

01:36:40.000 --> 01:36:48.000
products, because then that triggers some FACA concerns and other things, but it's a really good way. It's all the DoD components, EPA, federal land managers.

01:36:48.000 --> 01:37:09.000
And a bunch of states, I think we're at 9, but don't quote me on that. If you're a state and you're interested in who those folks are, I can get you in contact. One of them was Jeff Swanson, who just retired from the state of Colorado, and I know he had been working and doing some all-state calls and trying to bring some… that bigger state perspective into this group as we kind of talk through issues. We've talked through.

01:37:09.000 --> 01:37:27.000
The risk management methodology and the implications and problems we have as regulators with it. We're looking at training, we're looking at underwater types of technology. This is the group that we'll talk about. We have problems with underwater technologies. We have problems with, you know, policy implications of how good is a QAQC and all that.

01:37:27.000 --> 01:37:30.000
coming out of it, this is the group that can talk about it.

01:37:30.000 --> 01:37:58.000
Um, the Intergovernmental Data Quality Task Force IDQTF. That's the group we worked on to develop the Mr. The 2, the Rfs and the Ra. We… are probably going to be doing some updates on these MR quaps as we work through them and use them. And that's something. So look for possibly some updates. Spend a lot of time working with cert at PSTCP. Cert up is the the basic research arm of DOD.

01:37:58.000 --> 01:38:18.000
ESTCP is the pilot testing program. I'm EPA's rep on their munitions response track that works on all these geophysics and all these treatment technologies and stuff. There used to be the former symposium. Now it's the DoD Applications Workshop is next week. I know I'm going to see some of you are there. I saw some of the names that were on online today, so I look forward to seeing you next week.

01:38:18.000 --> 01:38:36.000
Great partnership there. They've formed a lot of advisory groups as we're working through technologies on wide area assessment and advanced geophysical classification. We have a current advisory group on underwater munitions and that technology that's coming out and trying to keep the black box out and trying to get the.

01:38:36.000 --> 01:38:51.000
the whole of the projects looking at this technology as it's being fielded, and will this really work? Do we have quality concerns with the data coming out, and what can we do to fix that now before we start really deploying it heavily in the field? Lastly, but not least.

01:38:51.000 --> 01:39:07.000
Elliott mentioned this, the ITRC. I've been involved with the group for different teams for a long time. This latest is a great team. Like Elliott mentioned, if you're newer to this and want to join this team and just get involved, and it's a great way to learn by fire.

01:39:07.000 --> 01:39:22.000
There's a lot of us older folks that are on there that have done this a while, and there's a lot of new RPMs, a lot of new state RPMs, there's industry representatives who know this stuff and they do this stuff all the time. They're sure to be a TCP representatives from DOD on there, and we're trying to write this document.

01:39:22.000 --> 01:39:33.000
And do some training. We're gonna do some interim fact sheets, or whatever we're going to call them shorter white papers, um, to get out in the meantime. But it's great to see these folks.

01:39:33.000 --> 01:39:50.000
not even understand what underwater munitions were a year ago, to now having these great in-depth conversations about it as they've kind of worked through this and learned. So, and I think the documents coming out are going to be really high quality, and there's going to be some associated training with it as well. It'll be very useful.

01:39:50.000 --> 01:39:58.000
So here's the thing. You know, these are kind of the high points we hit.

01:39:58.000 --> 01:40:10.000
Same process we're in, different technology work with everybody. We have got a lot of partnerships and collaborations going on.

01:40:10.000 --> 01:40:28.000
Um, I know so many different people. We've had a lot of losses over the last year with folks leaving, retiring. We're trying to recoup from that and build out our capacity and technical capability at EPA. I want to have some consistent oversight. We're working on a lot of that internally.

01:40:28.000 --> 01:40:40.000
doing training for our folks. My DoD colleagues, I'm going to be reaching out to you to come and do some training for us internally as well to help us out. But we really want to, you know, kind of keep things moving and keep talking.

01:40:40.000 --> 01:40:48.000
This is my contact info, my phone and email did not change, my office and boss and all that did, but, you know, hey.

01:40:48.000 --> 01:40:50.000
I think we got some time for questions now.

01:40:50.000 --> 01:41:12.000
I… you… you are guessing correct, so I'm going to ask your co-presenter to go ahead and come on camera as well, and I'll spotlight the two of you here to our virtual stage, so we can jump into our second and final Q&A period. I do want to thank the audience who has been chiming in with questions, and we'll try to get through as many as we can in the time that we have left together.

01:41:12.000 --> 01:41:29.000
And with that, Elliot. There we go, Elliott. So I'm going to go ahead and bring you here, and let me jump right on in. Doug, we did get this question earlier, and this one hopefully is straightforward. How common are those non-ferrous, so aluminum or plastic items with MMRP?

01:41:29.000 --> 01:41:44.000
aluminum a lot more. So I didn't mention this before, and I probably should have missed one of my notes. If you're looking for ferrous items, magnetometer works great. If you're looking for non-ferrous items like aluminum or others, you need to use EM.

01:41:44.000 --> 01:41:59.000
technology to do that. Most common aluminum is probably a 40 millimeter grenade. Pretty common to find plastics, not as much. That's more in the scary landmine type, you know.

01:41:59.000 --> 01:42:14.000
type of munitions items where they're really trying to avoid detection afterwards. We do not. Luckily, we do not have many submunition landmine sites in the Us. Or cleanup sites. We've had a couple, and that's a whole new level of technical complexity. So.

01:42:14.000 --> 01:42:24.000
Okay, um, I have another question in here. Can a metal detector trigger munitions?

01:42:24.000 --> 01:42:32.000
So there will be an analysis at your site. Yeah, I mean… Technically, for EM, you're inducing.

01:42:32.000 --> 01:42:51.000
you know the current. There is that super low probability. However, your explosive safety experts from DOD are going to take a look at the munitions types that are at your site. This is rarely an issue for us that I've seen come up, but is something they're aware of, and we'll look at.

01:42:51.000 --> 01:43:12.000
This is more of an issue at more active sites in the more complex electronics and newer munitions than it is in the older. I mean, we're really looking at World War II, Vietnam-era type, or even, sorry, and Civil War and World War I, because I've done a lot of human cannonball cleanups.

01:43:12.000 --> 01:43:13.000
Okay.

01:43:13.000 --> 01:43:19.000
Those are not typically… you're not getting any energy level where it's going to impart a problem. But that's a great question to ask your project team if you're concerned about it when you're going, and what they've looked at and what their considerations they they thought up for.

01:43:19.000 --> 01:43:36.000
Okay, Elliot, I see a couple of case study questions. I'm going to turn to you in a minute. But before I do that, Doug, how about those sites where geology is very challenging for geophysics? Would you say that analog methods are appropriate in those sites?

01:43:36.000 --> 01:44:02.000
If you've got a lot of background. In that case, where it's throwing off… you've… I'm not a geophysicist, so I wish I could call on my friends from the Corps and others, because I routinely do to talk through. We do have some challenging sites. So geologic background is actually one of the issues we throw up in one of our training… in our training course that we teach jointly with DOD, which we're doing a version of next week.

01:44:02.000 --> 01:44:21.000
Um, where there's geologic… issue in an area, and and the question is, could that be masking? What could be there, or is there nothing there? So it's it's a real issue, and it's very site-specific, and it depends on what it is. So…

01:44:21.000 --> 01:44:22.000
Mm-hmm. Mm-hmm.

01:44:22.000 --> 01:44:32.000
Yes, it's more of a question between kind of analog and not an analog mag and EM, which maybe you can get a better, better look at it, but you could be severely hampered by what you can say and do at that time.

01:44:32.000 --> 01:44:33.000
Those types of sites. I know they have some issues in, like, volcanic rocks and other areas.

01:44:33.000 --> 01:44:38.000
Okay, he's talking about…

01:44:38.000 --> 01:44:40.000
right? He's got clays and Ferris rocks. That's what he's. Yeah. So okay.

01:44:40.000 --> 01:44:51.000
Yeah, yeah. So, it's certainly a consideration and something you're going to look at as you get into the site, and it can certainly make a difference, say, if you're trying for something optimistic like Uui.

01:44:51.000 --> 01:45:00.000
If you've got that kind of interference and background, wow, I don't know that you're even thinking you're getting to that endpoint. So it's definitely a consideration.

01:45:00.000 --> 01:45:18.000
Okay. All right, Doug, I'm gonna take you out of the hot seat here and take a few questions or comments for Elliot, but don't go away. We'll come back to you in just a moment, Doug. So, Elliot, if you want to unmute this first question is coming in where the participant noted that the operational ranges were left out of the Paris investigations.

01:45:18.000 --> 01:45:35.000
Because they were still training areas or op ranges. They wanted to know were the areas investigated at Paris Island prior operational ranges that were then declassified as operational ranges, so they then required cleanup.

01:45:35.000 --> 01:45:51.000
So the areas investigated under the OU were portions of the formal shrapnel range that are currently deconflicted from the active operational ranges and training areas. So the Ri did not include active ranges in their surface danger zone. Those areas remain.

01:45:51.000 --> 01:45:58.000
In the operational range program, and would only be addressed under the MRP. If they.

01:45:58.000 --> 01:46:09.000
when they're close. So the areas investigated were not declassified operational ranges. They were non-operational portions of the former range footprint.

01:46:09.000 --> 01:46:10.000
Okay. And…

01:46:10.000 --> 01:46:28.000
One thing I'd like to add. I mean, that that does happen at sites. I actually worked with Elliot's predecessor on this a little bit, and it gets a bit.

01:46:28.000 --> 01:46:29.000
Mm-hmm.

01:46:29.000 --> 01:46:35.000
difficult to investigate and make decisions, and it adds into that uncertainty if you're firing point or part of the range is not being investigated, but this part is. So that's DoD's call. It's it's their range. They know what they need to use it for and all we've we've had.

01:46:35.000 --> 01:46:51.000
I wouldn't say we would not challenge that in the past. We've had conversations about, does it really make sense if you cutting out the center of the donut, and you want to clean up that little area, but the rest of it, you're still operating on? Does that make sense? What specific purpose do you need that for? So yeah, again.

01:46:51.000 --> 01:46:56.000
It's it's it's a challenge, and I know it's been a challenge at Elliott site somewhat too.

01:46:56.000 --> 01:47:05.000
Okay, we have another question for you, Elliot. At that case study site, were any toys identified?

01:47:05.000 --> 01:47:11.000
Um, so the parade grounds is a different Uxo boundary. So.

01:47:11.000 --> 01:47:13.000
Okay.

01:47:13.000 --> 01:47:23.000
That is UX03, not UX05 and 6, and we're actually at the proposed plan stage right now. So that one is kind of the guinea pig on how.

01:47:23.000 --> 01:47:25.000
The others are gonna kinda unfold. So, um…

01:47:25.000 --> 01:47:36.000
Okay. Just out of curiosity, though, if you had a high use area, how would you consider your your looks?

01:47:36.000 --> 01:47:38.000
Uh, to be very stringent.

01:47:38.000 --> 01:47:56.000
Got it. All right, thank you. And then another participant mentioned or noted that you brought up the Seacoast Basic Advanced Munitions Response Site Management course, and so I just wanted to put it out there to the audience that, um, uh, an individual is on who can get.

01:47:56.000 --> 01:48:12.000
You directed and or in touch with course administrators, so if you are interested in that course, you can feel free to send a message to us in the Q&A, and then I can get your contact information over to our presenters so they can connect you to learn more from those course administrators.

01:48:12.000 --> 01:48:42.000
And one thing, Gene, I throw out there as well, especially if you're a newer regulator into this. If you want advice on what trainings out there, what you can get to get in contact with Elliot and I. We're putting together a lot of info for our folks. Um… To share, I'm happy to share that with whomever about this. It's a project we've worked on in the Munitions response dialogue, as well as trying to identify what training is out there, what's archived out there, what's ongoing. We do joint training classes with DOD as well. So.

01:48:43.000 --> 01:48:52.000
Don't be shy. Reach out. and and we can get you connected with with what's there, and what's coming up.

01:48:52.000 --> 01:48:53.000
Yeah, it's a great class. I learned. I learned a lot, and I'd highly recommend it if you have an underwater site.

01:48:53.000 --> 01:48:58.000
Sure. Um, I…

01:48:58.000 --> 01:49:01.000
And I think it's going to be in San Diego, but I'm not positive.

01:49:01.000 --> 01:49:21.000
Yeah, uh, actually, it's in… I think it's in, like, 2 weeks in San Diego. They're up on there, and DOD is, as the Navy folks have told me at their headquarters, they're like, if regulators want to participate in the class, absolutely, they're happy to have them there. That's why we.

01:49:21.000 --> 01:49:22.000
Mm-hmm.

01:49:22.000 --> 01:49:33.000
And honestly, the weight of evidence class we teach, we're doing next week and add some later in this year. We do them as joint courses, because we do, you know, we want the different inputs. We do breakout sessions like project teams, you know, where we… I just don't want all geophysicists in one group.

01:49:33.000 --> 01:49:42.000
Because that just would about kill me. But we'll have regulators, we'll have DOD, we'll have contractors, and we'll break them out and we'll make them walk through decisions and stuff.

01:49:42.000 --> 01:49:47.000
And I think that's really useful to do that joint training like that. So.

01:49:47.000 --> 01:50:13.000
Sure. I see a handful of questions that are, well, I should say there's a number of questions still in the queue, and I am being mindful of the clock. So we may not get through all of the questions that I have in there. I have time for a few more, but I wanted to make sure that I point out to the audience if there are questions that we have not addressed during today's session, or you have some site specific based questions, I see a number.

01:50:13.000 --> 01:50:27.000
of them where people are asking if this happens at this type of site, how would you? And I think those are great things to reach out to our presenters. Doug is kind enough to place his contact information up here, so again, if we don't get to your question or you have site-specific questions.

01:50:27.000 --> 01:50:44.000
I certainly encourage you to reach out to Doug, but there are a handful that I think we can take before we close out here. So a few people, Doug, have been asking about small arms ranges, specifically, and site closure, the UUUE.

01:50:44.000 --> 01:50:48.000
Would you consider them differently since the explosives and mechs not an issue?

01:50:48.000 --> 01:51:07.000
So, yeah, because you're… you're not looking for an explosive hazard, per se, you're looking, you know, small arms ranges. Now, um, at Elliott's site, one of the smaller inventions, we found a high explosive fuse, and that turns it into a different category. So, if you're doing small arms range, which is.

01:51:07.000 --> 01:51:26.000
you know, rifle or handgun type of range. You're really looking at a chemical release. You're looking at lead. Maybe some phas at the firing point or something like that. There are. There are some guidance as actually the Federal facilities forum paper, which I believe I'm pretty sure is one of the links. If not, we'll we'll add it up there.

01:51:26.000 --> 01:51:40.000
It was written a number of years ago, and there's a big section in there about investigating small arms firing ranges. And this is, again, not explosively configured rounds. This is your typical bullets that you're shooting into a backstop.

01:51:40.000 --> 01:52:00.000
Sure. And I will just also note that we have some participants again who are chiming in with more statutes and language from DODM 4715.2A. So just I'll point out that there's a lot of regulatory citation that's being shared in the.

01:52:00.000 --> 01:52:01.000
Sure.

01:52:01.000 --> 01:52:12.000
the responses, and Doug, maybe one of the things we'll do is we'll go through it with you, and then perhaps there'll be an addendum resource that we can share, because other people are asking, well, where is the citation for this? So perhaps we can call out a couple of important citations and share it as a resource later on. So I wanted to.

01:52:12.000 --> 01:52:17.000
Yep.

01:52:17.000 --> 01:52:18.000
Sure.

01:52:18.000 --> 01:52:34.000
Thank everyone who's chiming in and offering those those quotes. I want to go back one quickly here. Does that that buried explosion module, is that an alternate to OBOD for field disposition?

01:52:34.000 --> 01:52:37.000
I think this one's targeting you, Doug.

01:52:37.000 --> 01:52:40.000
here's a question. It's kind of a…

01:52:40.000 --> 01:52:51.000
So, does the buried explosion module, BEM, apply as an alternate to OBOD for field disposition?

01:52:51.000 --> 01:52:58.000
I'm gonna phone a friend on that one and get back to them, because that's… I'm not sure I get the whole question.

01:52:58.000 --> 01:52:59.000
Mm-hmm.

01:52:59.000 --> 01:53:03.000
So I'll reach back out, then we can have a bit of a discussion on that.

01:53:03.000 --> 01:53:04.000
Okay. All right.

01:53:04.000 --> 01:53:08.000
more complicated, and there might be some site… Involvement as well.

01:53:08.000 --> 01:53:33.000
Okay. All right. Well, I think looking at the clock, seeing as how it is 258 PM Eastern, and I still have a handful of reminders that I need to walk through before we officially close out today's session. What I'm going to do is thank both of our presenters for their time and expertise and sort of take the show back from them so I can walk through a few quick final reminders before we close things out today. So again, Doug and Elliot.

01:53:33.000 --> 01:53:51.000
Thank you so much for sharing your time and knowledge with us. I'm going to go ahead and carry on with just a few final reminders before we close things out today. I do want to thank everybody for joining us and I encourage you to visit us at the Cleanup Information Network or cluhen.org and make sure you sign up for our free monthly newsletter, Tech Direct.

01:53:51.000 --> 01:54:05.000
which I send out on the first of each month, and will highlight free online tech transfer sessions like today's webinar, along with a whole variety of other information repositories, websites, and events related to hazardous waste site characterization and cleanup.

01:54:05.000 --> 01:54:24.000
If you were not here at the beginning, just a gentle reminder that this is the first in an 11 part webinar series that we will be hosting one event per month on as part of the Federal Facilities Online Academy. Each session in that series will have a unique seminar homepage. We started with today's topic on military munitions policy overview.

01:54:24.000 --> 01:54:41.000
You can access information about today's session along with copies of the presentation material, links to the ITRC teams, to a number of the guidance and resources that were highlighted in today's session on the seminar homepage. That URL is shown in red, and it's also accessible in the QR code here.

01:54:41.000 --> 01:55:06.000
If you are watching the archived version, you can still access that website and scan the code to get to these materials. Now, one of the most common questions I get is if we offer CEUs or PDHs and while we don't offer those types of credit hours for cluing events, I can provide you with the participation certificate, which may be helpful for those of you that are working to achieve the Federal Facilities Academy certificate. Remember, to do so, you need to take all 11 webinars.

01:55:06.000 --> 01:55:15.000
live or replay the archived version and then qualify and complete the in-person three-day training opportunity if you are a regulator.

01:55:15.000 --> 01:55:40.000
We'll continue to share information about that in follow-on sessions. But for those of you looking for a certificate of participation for today's session, again, you can visit that seminar homepage, and if you fill out the feedback form, that form is linked at the bottom of that page, there's a box you can check to certify you are here for the entire session, and then as soon as you submit your form, you'll immediately have access to a certificate that you can download or print out. I will email a copy to you as well, but they'll sometimes get caught up in junk or spam filter.

01:55:40.000 --> 01:56:00.000
So I encourage you to download it or print it out from the confirmation screen as soon as you submit it. If you hosted a watch party at your location and had other colleagues join from a room with you, simply send your colleagues to this particular URL. Each person can share their feedback in their own submission and get their own certificate of participation, even though they didn't register independently.

01:56:00.000 --> 01:56:18.000
Today's session was recorded, as will all of the sessions in the series. In about 1 week or so, we'll post a copy of the recording on Cluwen's live archive page. And if you happen to be one of the lucky people who's watching the archived version right now, you can still share your feedback based on replaying the archive. You can check the box.

01:56:18.000 --> 01:56:38.000
Uh, in sending in your feedback for the online archive replay and get a certificate based on the replay of the session. So right about now in the archive, above my head, in the upper right, there will be links to that seminar homepage, as well as the feedback form, so you can submit your feedback to get your certificate. Again, look for a follow-up email with information on how to access this recording in about one week.

01:56:38.000 --> 01:57:08.000
And with that, I want to thank each and every one of you for participating, sharing your questions, your knowledge, your quotes, and I look forward to you joining us on a future Clue and Seminar. I hope that this has been a valuable expenditure of your time. With that, it's my pleasure to formally conclude today's live broadcast.