Munitions Response Site Prioritization Protocol Development, Content, and Training
Joint Services Environmental Management Conference & Exhibition
March 2006
Mr. Victor WieszekOffice of the Deputy Under Secretary of Defense
(Installations & Environment)/Environmental Management
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Overview
• Background
• MMRP Site Inventory
• Why the MRSP Protocol was Needed
• Overview of the Protocol
• Protocol Development
• Locations Subject to Protocol
• Locations Not Subject to Protocol
• Munitions Response Site
• Hypothetical Defense Site
• Protocol Structure
• Applying the Protocol
• Determining the MRS Priority
• Additional Requirements
• Reapplying the Protocol
• Sequencing the MRS
• Protocol Training
• Performance Goals
Ordnance specialist examines munitions
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Background
• For decades the Department of Defense (DoD) has used military munitions in training, testing, and weapons research
• There are potential environmental, health and explosive hazards that must be addressed whenever a former range, munitions treatment, or disposal site is put to another use
• In Fiscal Year (FY) 2001 DoD established the Military Munitions Response Program (MMRP) under the Defense Environmental Restoration Program (DERP)
• The MMRP addresses the potential risks associated with past use of military munitions at non-operational ranges
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Background (cont)
• Congress addressed munitions responses in the National Defense Authorization Act for FY2002, requiring DoD to –– Create an inventory of “defense sites” known or suspected of
containing unexploded ordnance (UXO), discarded military munitions (DMM), or munitions constituents (MC)
– Assign a priority for response activities to each site – Establish a program category to track munitions response costs– Prepare a detailed report to Congress on DoD’s plan to address
munitions
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MMRP Site Inventory
• DoD identified 3,309 MMRP sites as of the end of FY2005– 1,333 on active installations– 318 on installations affected by Base Realignment and Closure
(BRAC)– 1,658 on formerly used defense sites (FUDS) properties
• The MMRP inventory is updated annually and published in the Defense Environmental Program Annual Report to Congress
• It is also publicly available at http://derparc.egovservices.net/Derparc_FY04/do/mmrp
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Why the MRSP Protocol Was Needed
• With over 3,300 defense sites in the inventory, DoD could not address all munitions sites at once
• DoD needed a framework for prioritizing these sites
• Congress required DoD to establish a method for assigning priority to munitions responses
• DoD developed the Munitions Response Site Prioritization Protocol (The Protocol)
• The Protocol was published in the Federal RegisterOctober 5, 2005 and implemented as a codified regulation (32 CFR Part 179)
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Overview of the Protocol
• The Protocol : – Assigns a relative priority to each location in DoD’s
inventory of defense sites known or suspected of containing unexploded ordnance (UXO), discarded military munitions (DMM), and munitions constituents (MC)
– Prescribes procedures for prioritizing the defense sites and general Component responsibilities
– Is a prioritization tool
• The Protocol is not: – A risk assessment tool– Used for determining cleanup
levels or future land useExamples of Military Munitions
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• Convened a workgroup knowledgeable on explosive safety and the environment, which led the effort to develop the Protocol– Gathered data, reviewed existing prioritization models– Reviewed publications, methods, guidance documents, risk
assessment tools– Developed an outline – Identified specific characteristics that the Protocol should satisfy– Reviewed other priority setting models in use by federal agencies
• Ultimately determined that a new tool was needed to prioritize defense sites
Protocol Development
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Work group conducts extensive testing on the Protocol
Work group develops Protocol to evaluate potential explosive, chemical, and environmental hazards using a three-axis framework
Work group reviews characteristics of six existing prioritization models. Work group concludes that none of the existing models provide all the necessary requirements
Work group conducts interviews with experienced munitions and environmental response experts to gather information and establish a baseline for the Protocol
DoD convenes work group to develop the Protocol
Draft of Protocol published in the Federal Register (August 2003)
Public comments accepted on the draft Protocol (August -November 2003)
Work group revises the Health Hazard Evaluation Module, terminology, property owners’ role, and munitions types based on public comment
Work group consults with affected stakeholders in the Protocol's development
Advance notice of proposed rulemaking published in Federal Register (March 2002)
The Final Rule is published
October 2005
In 2001 DoD updated its DERP Management Guidance
for the MMRP
NDAA creates new requirements related to UXO,
DMM, and MC (FY2002)
Protocol Development (cont)
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Protocol Development (cont)
- Meetings held with state governments (Nov 2002, Feb 2003)- State feedback sought through Munitions Response Committee meetings (FY 2002)- Participated in Association of State Territorial Solid Waste Management Officials annual
meetings (Oct 2002, Apr 2003)- Participated in National Association of Attorneys General meetings
- Notified and invited all the Federally-recognized tribes to participate in the Protocol’s development- Meetings held with tribal governments (Sept 2002, Feb 2003)- Participated in National Conference of American Indians, Native American Land Environmental
Mitigation Program, and National Conference on Environmental Management meetings (Jun 2002, Nov 2002)
- Meetings held with United States Department of Agriculture, Environmental Protection Agency, and Department of the Interior (Dec 2002, Feb 2003)
Tribes
States
FederalAgencies
Advanced Notice of Proposed Rulemaking Published in FR (Mar 2002) and distributed to stakeholders
Proposed Rulemaking Published in FR (Aug 2003) and distributed to stakeholders
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Locations Subject to the Protocol
• The Protocol is applied to DoD’s inventory of defense sites
• Defense site –– Is a location that is or was owned by, leased to, or otherwise possessed or
used by the DoD– Does not include any operational range, operating storage or manufacturing
facility, or facility that is used for or was permitted for the treatment or disposal of military munitions
– [10 USC § 2710(e)(1)]
Defense sites
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Locations Not Subject to the Protocol
• Locations that are not, or were not, owned by, leased to, or otherwise possessed or used by DoD
• Locations neither known to contain, or suspected of containing UXO, DMM, or MC
• Locations outside the United States
• Locations where the presence of military munitions results from combat operations
• Operational ranges
• Currently operating military munitions storage and manufacturingfacilities
• Locations that are used for, or were permitted for, the treatment or disposal of military munitions – [32 CFR Part 179]
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Munitions Response Site (MRS)
• DoD developed two new terms to describe defense sites subject to the Protocol –– Munitions Response Area (MRA)
o Any area on a defense site that is known or suspected to contain UXO, DMM, or MC (e.g., former ranges or munitions burial areas)
o Must be comprised of at least one munitions response site (MRS) but may contain multiple munitions response sites
– Munitions Response Site (MRS)o Discrete locations within an MRA that, based on investigation or
historical records, is known or suspected to contain UXO, DMM, or MC and require a munitions response
o Subdividing an MRA into multiple MRS allows for more efficient characterization so that munitions responses specific to local conditions can be conducted
• The Protocol is applied at the MRS level
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Hypothetical Defense Site
Munitions Response Area 1
MRA 1 is made up of MRS 1.A and MRS 1.B Each MRA will be divided into one or more MRSs for assessing UXO, DMM, and MC
Sample Installation
Munitions Response Site 1.A
Operational Range(acreage excluded from definition of Defense Site)
Munitions Response Site 1.B
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Protocol Structure
• The Protocol is comprised of three separate modules
• Each module evaluates a different type of potential hazard posed by UXO, DMM, or MC that may be present at an MRS– The Explosive Hazard Evaluation (EHE) Module addresses explosive
hazards posed by UXO, DMM, and MC in high enough concentrations to pose an explosive hazard
– The Chemical Warfare Materiel (CWM) Hazard Evaluation (CHE) Module addresses hazards associated with the effects of CWM
– The Health Hazard Evaluation (HHE) Module addresses chronic health and environmental hazards posed by MC and other related chemicalconstituents
• Each module will receive a score, based on site-specific data, that will be used to determine the site’s priority
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Protocol Structure (cont)
• Each hazard evaluation module (EHE, CHE, HHE) is further divided into three factors that drive the module’s outcome– Hazard or Contaminant – What are the potential hazards?– Accessibility or Migration Pathway – How might the hazard be
encountered?– Receptor – Who may be affected by the hazard?
• Each factor is comprised of multiple data elements that use MRS-specific information to evaluate potential hazards
• Data elements are scored using available site-specific data
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Protocol Structure (cont)
ModulesFactorsData Elements
MRSPriorityMRS
Priority
CWM ConfigurationSources of CWMLocation of CWMEase of AccessStatus of Property
Types of Activities/StructuresEcological and/or Cultural Resources
Population DensityPopulation Near Hazard
Explosive HazardSource of Hazard
Location of MunitionsEase of AccessStatus of Property
Types of Activities/StructuresEcological and/or Cultural Resources
Population DensityPopulation Near Hazard
Contaminant Hazard
Receptor
HHE Module
CWM Hazard
CHE ModuleAccessibility
Receptor
EHE ModuleAccessibility
Receptor
Explosive Hazard
Migration Pathway
Significant (H)Moderate (M)Minimal (L)Evident (H)Potential (M)Confined (L)Identified (H)Potential (M)Limited (L)
MRSPriorityMRS
Priority
CWM ConfigurationSources of CWMCWM ConfigurationSources of CWMLocation of CWMEase of AccessStatus of Property
Location of CWMEase of AccessStatus of Property
Types of Activities/StructuresEcological and/or Cultural Resources
Population DensityPopulation Near HazardTypes of Activities/StructuresEcological and/or Cultural Resources
Population DensityPopulation Near Hazard
Explosive HazardSource of HazardExplosive HazardSource of Hazard
Location of MunitionsEase of AccessStatus of Property
Location of MunitionsEase of AccessStatus of Property
Types of Activities/StructuresEcological and/or Cultural Resources
Population DensityPopulation Near HazardTypes of Activities/StructuresEcological and/or Cultural Resources
Population DensityPopulation Near Hazard
Contaminant Hazard
Receptor
HHE Module
CWM Hazard
CHE ModuleAccessibility
Receptor
EHE ModuleAccessibility
Receptor
Explosive Hazard
Accessibility
Receptor
Explosive Hazard
Migration Pathway
Significant (H)Moderate (M)Minimal (L)Evident (H)Potential (M)Confined (L)Identified (H)Potential (M)Limited (L)
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Applying the Protocol
• Components complete tables to record MRS-specific information applicable to the data elements, factors, and modules– Tables are provided in the Protocol Primer and training materials
• Tables are completed using MRS-specific data available early in the munitions response process
• Data sources may include –– Preliminary Assessments– Site Inspections– Archive Search Reports (ASRs)– Conceptual Site Modes (CSMs)
• Additional data gathering activities may be required
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Applying the Protocol (cont)
• The tables allow the Components to develop –– A score for each data element– A value for each factor– A rating for each module– Completion of the tables leads to a “priority” for the MRS under
evaluation
Identifying MRS Information Table AMRSPP Tables
Module
EHE
CHE
HHE
Data Collection Module Rating Determining MRS Priority
Tables1 - 9
Tables11 - 19
Tables21 - 27
Table10
Table20
Table28
Table29
Identifying MRS Information Table AMRSPP Tables
Module
EHE
CHE
HHE
Data Collection Module Rating Determining MRS Priority
Tables1 - 9
Tables11 - 19
Tables21 - 27
Table10
Table20
Table28
Table29
Circle all data element classifications present at the MRS
Document any specificdata used in selecting the classification
Record only the largest classification score within each table in its corresponding box
Table 11CHE Module: CWM Configuration Data Element Table
DIRECTIONS: Below are seven classifications of CWM configuration and their descriptions. Circle the score(s) thatcorrespond to all CWM configurations present at the MRS.
Note: The terms CWM/UXO, CWM/DMM, physical evidence, and historical evidence are defined in Appendix C of thePrimer.
Classification Description Score
CWM, explosiveconfiguration either UXOor damaged DMM
The CWM known or suspected of being present at the MRS is:Explosively configured CWM that are UXO (i.e., CWM/UXO).Explosively configured CWM that are DMM (i.e., CWM/DMM) thathave been damaged.
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CWM mixed with UXO
The CWM known or suspected of being present at the MRS areexplosively configured CWM/DMM that have not been damaged, ornonexplosively configured CWM/DMM, or CWM not configured as amunition, that are commingled with conventional munitions that areUXO.
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CWM, explosiveconfiguration that areundamaged DMM
The CWM known or suspected of being present at the MRS areexplosively configured CWM/DMM that have not been damaged. 20
CWM, not explosivelyconfigured or CWM, bulkcontainer
The CWM known or suspected of being present at the MRS is:Nonexplosively configured CWM/DMM.Bulk CWM/DMM (e.g., ton container). 15
CAIS K941 and CAIS K942The CWM/DMM known or suspected of being present at the MRS isCAIS K941-toxic gas set M-1 or CAIS K942-toxic gas set M-2/E11. 12
CAIS (chemical agentidentification sets)
Only CAIS, other than CAIS K941 and K942, are known orsuspected of being present at the MRS. 10
Evidence of no CWMFollowing investigation, the physical evidence indicates that CWMare not present at the MRS, or the historical evidence indicates thatCWM are not present at the MRS. 0
CWM CONFIGURATION DIRECTIONS: Record the single highest score from above in thebox to the right (maximum score = 30).
DIRECTIONS: Document any MRS-specific data used in selecting the CWM Configuration classifications in the spaceprovided.
____________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________
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CWM, explosively configured
Damaged CWM/DMM surface or subsurface
Select the Module Rating that corresponds with the module valuecalculated above
Population Density= 100-500 p/sq mNearby suburbs >26 inhabited strucResidential area <2 miles awayEcological Resources - EndangeredspeciesAdd the three factor values recordeabove
Table 20Determining the CHE Module Rating
Source Score Value
CWM Hazard Factor Data Elements
CWM Confi guration Table 11
Sources of CWM Table 12
Accessibili ty Factor Data Elements
Location of CWM Table 13
Ease of Access Table 14
Status of Property Table 15
Receptors Factor Data Elements
Population Density Table 16
Population Near Hazard Table 17
Types of Activities/ Struct ures Table 18
Ecolog ical and /or CulturalResources Table 19
CHE MODULE TOTAL
CHE Module Total CHE Module Rating
92 to 100 A
82 to 91 B
71 to 81 C
60 to 70 D
48 to 59 E
38 to 47 F
less than 38 G
Evaluation Pendi ng
No Longer RequiredAlternative Module Ratings
No Known or Suspected CWMHazard
DIRECTI ONS:
1. From Tables 11-19, record thedata element scores in theScore boxes to the right.
2. Add the Score boxes for eachof the three factors and recordthis number in the Value boxesto the right.
3. Add the three Value boxes andrecord this number in the CHEModule Total box below.
4. Circle the appropriate range forthe CHE Module Total below.
5. Circle the CHE Module Ratingthat corresponds to the rangeselected and record this value inthe CHE Module Rating boxfound at the bottom of the table.
Note:An alternative module rating may beassigned when a module letter rating isinappropriate. An alternative modulerating is used when more information isneeded to score one or more dataelements, contaminat ion at an MRS waspreviously addressed, or there is noreason to suspect contamination wasever present at an MRS.
CHE MODULE RATING
3010
050805
03050503
74
Historical evidenceFence is incompleteNon-DoD Controlled
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18
16
C Record the Module Rating in the
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Determining MRS Priority
• The MRS priority is determined by evaluating the three module ratings and selecting the module that has the highest hazard rating
Hazard Evaluation A 2
Hazard Evaluation A (Highest) 1
Hazard Evaluation A 2
Hazard Evaluation B 3
Hazard Evaluation B 2
Hazard Evaluation B 3
Hazard Evaluation C 4
Hazard Evaluation C3
Hazard Evaluation C4
Hazard Evaluation D5
Hazard Evaluation D 4
Hazard Evaluation D5
Hazard Evaluation E6
Hazard Evaluation E5
Hazard Evaluation E6
Hazard Evaluation F 7
Hazard Evaluation F 6
Hazard Evaluation F7
Hazard Evaluation G (Lowest) 8
Hazard Evaluation G 7
Hazard Evaluation G(Lowest) 8
HHE Module RatingEHE Module Rating
CHE Module Rating
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Sequencing an MRS
• After the MRS priority is determined, the Components will sequence the MRS for response action
• The sequencing of an MRS is based primarily on the MRS’s relative priority. As a matter of DoD policy, an MRS with higher relative risks will be addressed before an MRS with lower relative risks
• DoD does recognize that other factors (e.g., environmental justice, economic development, programmatic) could influence sequencing decisions
Protocol Structure
CHE ModuleCHE Module
HHE ModuleHHE Module
MRS SequencingMRS SequencingMRS PriorityMRS Priority
EHE ModuleEHE Module
Relative Risk Programmatic
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Reapplying the Protocol
• Component personnel will reapply the Protocol when –– New information is available to update or validate an MRS– An “Evaluation Pending” rating can be more completely categorized– An MRA is broken out into more than a single MRS – A response action is completed that could change the potential hazard
rating of an MRS
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Additional Requirements
• Following application of the Protocol and determination of a priority for an MRS, Components will –– Document the prioritization
process– Review and report the priority to
ODUSD(I&E)– Consider other factors in
determining MRS sequencing – Perform quality assurance review – Reapply the Protocol at least
annually or as required
• These requirements are mandatory, established as part of the Protocol (codified at 32 CFR Part 179)
Documentation locations of protocol results
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Protocol Training
Training Workshops
January 2006Washington, DC
June 2006Savannah, GA
April 2006Chicago, IL
March 2006Denver, CO
February 2006Seattle, WA
December 2005Washington, DC
• Trains personnel to apply the Protocol consistently
• Explains Protocol Requirements
• Uses a Train-the Trainer Approach
• Participants include –DoD Components; States; EPA;Federal land managers;Tribal members
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Protocol Training (cont)
• DoD developed a technical Primer designed for munitions response project managers and other environmental personnel
• The Primer contains information about DoD's development of the Protocol and provides a step-by-step guide for applying the Protocol
• Once the training workshops are complete, the Primer and training presentations will be posted online and available to the general public
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Performance Goals
• DoD has developed several near-term performance goals for the MMRP –– Complete preliminary assessments for all MRSs at active installations
and FUDS properties by the end of FY2007– Finalize site inspections for all MRSs at active installations and FUDS
properties by the end of FY2010– Achieve Remedy In Place/Response Complete at all MRSs identified
in the first four rounds of BRAC program by the end of FY2009
• DoD will continue to develop program goals and performance metrics as MRSs are prioritized and munitions response actions are sequenced
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Feedback
• Do you have any comments, questions or concerns?
• Additional information is available at –http://www.denix.osd.mil/mmrp
For additional information, please contact:
703-571-9061
