Title: Introduction Text: The Department of the Navy (DON) has developed mandatory explosives safety policies and criteria to protect people and real property from hazards associated with munitions or explosives of concern (MEC). To ensure that explosives safety is properly addressed, NAVFAC Remedial Project Managers (RPMs) must integrate these requirements into their Munitions Response Program (MRP) projects, as well as any other projects that deal with munitions. This Web tool outlines the key steps for ensuring that munitions response actions are conducted safely.

Title: Background - Explosives Safety (1 of 3) Text: The MRP addresses response actions at munitions response sites (MRSs) where MEC and munitions constituents (MCs) are present in the environment. MEC is defined as unexploded ordnance (UXO), discarded military munitions (DMM), and MC present in high enough concentrations to pose an explosive hazard. MCs are any materials originating from UXO, DMM, or other military munitions, including explosive and nonexplosive materials, and emission, degradation, or breakdown elements (e.g., lead, barium, chromium, RDX, TNT, HMX). RPMs should be aware of these general safety rules for explosives: Assume all munitions to contain a live charge until it can be determined otherwise; Consider any MEC that has been exposed to fire or detonation to be extremely hazardous; Do not touch or move suspected MEC items; and Do not allow unauthorized or unnecessary personnel to be exposed to MEC.

Title: MC Text: MCs in high enough concentrations (typically > 10% by volume) are considered MEC and present an explosives hazard and must be treated as reactive. Lower concentrations are treated as a toxic, not a reactive. Some MCs (primary explosives for example) can be reactive at <5% by volume.

Title: Background (2 of 3) Text: MCs in lower concentrations are not considered MEC. The chronic risks associated with MCs can be assessed using traditional chemical risk assessment tools that are commonly available in the Installation Restoration Program (IRP). However, these same tools are not suited for MEC because the explosive effects for MEC are immediate. To meet the need for assessing acute hazards associated with MEC, the Environmental Protection Agency (EPA) and the Department of Defense (DoD) are working jointly to develop a MEC Hazard Assessment (MEC HA). A MEC HA evaluates: Severity: the potential severity of the result should a MEC item function. Accessibility: the likelihood that a receptor will be able to interact with a MEC item. Sensitivity: the likelihood that a MEC item will function should a receptor interact with it.

Title: Background - Explosives Safety (3 of 3) Text: The Naval Ordnance Safety and Security Activity (NOSSA) serves as the Navy's explosives safety authority. NOSSA provides general oversight of explosives safety, with specific responsibility for technical oversight, review, and verification of munitions response actions. This includes preparing policies, design criteria, and procedures associated with explosives safety such as NOSSAINST 8020.15A and NAVSEA OP5 as outlined in this Web Tool. More specific details on the activities conducted by NOSSA are provided later in the tool. Click here to view their Web site. The Marine Corps Systems Command (MARCORSYSCOM) has similar responsibilities for the Marine Corps' MRP program. Click here to view their Web site. The Naval Explosive Ordnance Disposal Technology Division (NAVEODTECHDIV) plays a support role in the MRP. NAVEODTECHDIV developed the Automated Quality Assessment Program System (AQAPS), which can be used on MRP sites to conduct quality assessment (QA) tasks and to assist in the development of data quality objectives. Click here to view the NAVEODTECHDIV Web site. NOSSA and MARCORSYSCOM are mission-funded. However, RPMs should plan on funding for NAVEODTECHDIV to support their site.

Title: Guidance and Policy Text: Key references related to explosives safety for munitions responses are listed below: NOSSAINST 8020.15A, Explosives Safety Review, Oversight, and Verification of Munitions Responses. Click on image to the left to open this document. NAVSEA OP5, Ammunition and Explosives Ashore Safety Requirements for Handling, Storage, Production, Renovation, and Shipping.

Title: NOSSAINST 8020.15A Text: The purpose of this instruction is to assign responsibility and establish procedures and reporting requirements for the oversight, review, and verification of the explosives safety aspects of Navy response actions involving MEC.

Title: NAVSEA OP5 Text: Chapter 14 of this document is titled "Response Actions Involving Munitions and Explosives of Concern." This chapter establishes criteria to protect people and real property from explosive hazards associated with real property known or suspected to contain MEC and munitions responses to MEC.

Title: Site Identification and Notification Text: MEC items may be encountered unexpectedly during construction and dredging operations, underground utility maintenance, or environmental response actions. When this occurs, the RPM must stop all operations that present an explosives hazard to personnel, equipment, or property and then notify the responsible Explosive Ordnance Disposal (EOD) unit. NOSSAINST 8020.15A contains information on how to contact the cognizant unit. For previously unidentified sites, the RPM must submit within one week of the encounter the MRS Identification and Notification Report, Enclosure (2) of NOSSAINST 8020.15A. This report provides NOSSA with information about the site history, type and quantity of MEC found, and actions taken. NOSSA will keep a record of this form. For IRP sites where only small quantities of munitions are encountered, the munitions response will likely be incorporated into the overall IRP process. An unexpected encounter with MEC is considered incidental and does not need to be separately identified under the MRP. RPMs will need to evaluate if an IRP site will remain in the IRP program or become part of the new MRP site. For IRP sites with a sizeable munitions component discovered as part of the IRP response, it is necessary to differentiate between the two response actions. The munitions response that addresses MEC and MC will then be captured as a new MRS and will be funded under the MRP. The remaining environmental work will continue to be captured under the original site as part of the IRP. If the work remaining is the MRP component, the IRP site should be closed and identified as Response Complete (RC) with land use controls. Please note that each of these scenarios must be evaluated for explosives safety requirements.

Title: Explosives Safety Submission (1 of 6) Text: An Explosives Safety Submission (ESS) must be approved and endorsed by NOSSA, as well as approved by the Department of Defense Explosives Safety Board (DDESB), prior to the initiation of any munitions response activities that involve explosives, intentional physical contact with MEC, or ground-disturbing or other intrusive activities in areas known or suspected to contain MEC. NOSSA 8020.15 outlines when an RPM must submit an ESS as follows: Click here to view a list of activities for which an ESS is required; Click here to view a list of activities for which an ESS is not required; Click here to view a list of activities for which an ESS may not be required provided you have NOSSA concurrence. The ESS addresses the explosives safety aspects of a munitions response including, but not limited to, site location, response techniques, identification of the munition with the greatest fragmentation distance (MGFD), required explosives safety arcs and exclusion zones (EZs), site conditions, and other pertinent information that impacts explosives safety on the site. A Site Approval Request (SAR) must be included with the ESS submission to conduct operations involving the handling, processing, storing, or treating of munitions and explosives at any facility. It can take up to a year to obtain final DDESB approval of an ESS and RPMs must plan accordingly. RPMs should work with NOSSA (or MARCORSYSCOM at a Marine Corps site) to establish a reasonable schedule.

Title: ESS Required Text: An ESS is required for response actions involving: Placement of explosives on a site Intentional physical contact with MEC, including the decontamination and demolition of buildings and installed equipment known or suspected to contain residual explosives, or Conduct of ground-disturbing or other intrusive activities in areas known or suspected to contain MEC, including non-routine dredging operations or dredging operations occurring in an area where MEC has been historically encountered such as around ammunition handling piers.

Title: ESS Not Required Text: An ESS is not required for: Munitions or explosives emergency responses* Preliminary assessment or site inspection (PA/SI) activities when intentional physical contact with MEC or ground-disturbing activity is not intended Maintenance and clearance activities on operational ranges Demolition of magazines where there is no evidence or historical record of spills or other MC contamination Operation, maintenance, or cleanup of ammunition and explosives operating buildings in an active, standby, or layaway status, or Routine dredging operations or dredging operations occurring in an area where MEC is not expected to be encountered. *all immediate response activities by an explosives and munitions emergency response specialist to control, mitigate, or eliminate the actual or potential threat encountered during an explosives or munitions emergency. An emergency response may include in-place render safe procedures, treatment or destruction of the explosives or munitions, and/or transporting those items to another location to be rendered safe, treated, or destroyed.

Title: ESS May Not Be Required Text: With concurrence of NOSSA, an ESS may not be required for: Munitions responses on former ranges used exclusively for testing or training with small arms ammunition On-call construction support Anomaly avoidance activities Construction or non-munitions response activities after having a single explosives or munitions emergency response in an area not otherwise known or suspected of having MEC Demolition of magazines where there is evidence or a historical record of a spill or other MC contamination, but where the spill or contamination was removed, or Demolition of operating buildings where operations exclusively involved all-up rounds (no exposed explosives) and did not generate explosive residues.

Title: Explosives Safety Submission (2 of 6) Text: If the RPM is unsure as to whether or not an ESS is required, the first step is to submit an ESS Determination form at Enclosure (3) of NOSSAINST 8020.15A to NOSSA. The RPM must provide information on site history, proposed operations and how MEC will be avoided, and an operational risk management assessment. The form shown here allows NOSSA to evaluate the site-specific conditions and the associated risk/hazard assessment. NOSSA will concur or non-concur in writing to the ESS determination.

Title: Explosives Safety Submission (3 of 6) Text: NOSSAINST 8020.15A includes as Enclosure (4) detailed guidelines on how to prepare an ESS, including the required format and contents. There are five categories of ESS as follows: (1) MRS investigation/characterization; (2) A determination of No DoD Activity Indicated (NDAI)/No Further Action (NFA); (3) Time Critical Removal Action (TCRA) involving MEC; (4) On-site construction support where the probability of encountering MEC is determined to be moderate or high; and (5) Execution of the selected munitions response. More than one of the above categories may apply to an MRS. Because each category requires a unique set of information, Enclosure (4) of NOSSAINST 8020.15A includes a matrix of the required ESS contents as shown to the left.

Title: Explosives Safety Submission (4 of 6) Text: An ESS also includes the Explosives Safety Site Approval Request (SAR) (see Section 2 in matrix). The purpose of the SAR is to obtain explosives safety site approval from NOSSA and DDESB to conduct operations involving the handling, processing, storing, or treating of materials potentially presenting an explosive hazard (MPPEH) at any facility, including those operations taking place at an MRS. The SAR consists of NAVFAC form 11010/31 and plans and maps that show the proposed project location, land use plans, existing facilities, and other siting constraints.

Title: Explosives Safety Submission (5 of 6) Text: The ESS identifies the Munition with the Greatest Fragmentation Distance (MGFD). The MGFD serves as the basis for establishing Explosives Safety Quantity-Distance (ESQD) arcs, Exclusion Zones (EZs), and setting up other safety related operational parameters. It is possible to identify a single MGFD when there is a high probability that the selected MEC has the greatest fragmentation distance of all MEC to be encountered. However, a good strategy is to build flexibility into the ESS to account for uncertainty in the types of MEC encountered. This example shows a table with multiple contingency MGFDs and EZs based on potential MECs that may be encountered in the field. The use of contingency EZs will prevent the need for an ESS amendment whenever a larger than anticipated MEC item is encountered. This will minimize potentially long and costly work stoppages as long as the MEC item has been considered in the ESS. Click here to view a case study at Mare Island Naval Shipyard where adjustable ESQD arcs and EZs were employed successfully (see Slide 7).

Title: Explosives Safety Submission (6 of 6) Text: The ESS, including the SAR, is then submitted as one package to NOSSA for their review and endorsement to the DDESB for final approval. Since this process can take up to a year, RPMs must ensure that their project schedules include adequate time for preparation, review, and approval. Note that the distribution of the draft ESS is limited to the DON. RPMs are encouraged to include NOSSA early in the project planning stages so that they can ensure that all aspects of explosive safety are considered prior to submission of the final ESS. RPMs should anticipate NOSSA taking up to a month to review and comment on each draft and to endorse the final version. RPMs should expect DDESB to take up to six months to review, comment, and approve the final version. The project schedule needs to include these times and be clearly articulated to the entire project team, including regulatory agencies and stakeholders. To the extent possible, RPMs should allow the contractor direct access to NOSSA to resolve comments and issues on the ESS/SAR. When circumstances dictate, NOSSA can authorize a munitions response to proceed while awaiting approval by the DDESB provided that NOSSA has endorsed the submission, it is at the DDESB for approval, and the Navy accepts that the DDESB approval process may impose different or additional requirements. NOSSA will provide this interim approval to the responsible project manager in writing. The Work Plan developed for the site should be consistent with the final approved ESS.

Title: ESS Amendments and Corrections Text: An amendment or correction to an approved ESS does not require the resubmission of the complete ESS package. However, the information submitted must be in sufficient detail to identify the specific ESS being amended or corrected, the affected portions, and the precise amendment or corrections. Coordinate with NOSSA to determine the appropriate change for your project. Amendments are only required when a change to an approved ESS increases explosives safety risks, identifies requirements for additional or increased explosive hazard controls, or increases or decreases an ESQD arc or EZ. Corrections address changes to an approved ESS that do not increase explosives safety risks or exposures. Corrections are primarily administrative in nature and are provided for informational purposes. Corrections do not require approval.

Title: NOSSA Oversight Text: NOSSA provides oversight of activities at MRSs as follows: Reviews MRS Identification and Notification Reports Reviews and endorses ESSs and SARs Reviews Explosives Ordnance Disposal incident reports Provides Technical Assistance Visits (TAVs) Audits munitions response projects for compliance with explosives safety requirements Reviews and endorses After Action Reports (AARs) Verifies RC for safety aspects of a project.

Title: Audits Text: An audit will be conducted at the direction of NOSSA or when requested by the RPM in order to satisfy a specific project goal such as a formal NOSSA verification that the MRS has achieved RC with respect to explosives safety. As part of the audit, NOSSA assesses the extent to which a project complies with applicable explosives safety and environmental requirements related to the management of MEC in accordance with the approved ESS, OP5, and other safety publications. Audits include a review of the munitions response project documents and field activities, including the quality control (QC) and QA processes. NOSSAINST 8020.15A, Enclosure (6) includes a guide for conducting an MRS audit. Auditable documents include ESS plans, SOPs, and documents addressing explosives safety and environmental requirements. Auditable field operations include: explosives safety practices; site health and safety practices; worker qualifications; environmental protection; QC/QA program; geophysical investigation; data management; intrusive operations; soil sampling; munitions treatment operations; munitions scrap management; and land use controls.

Title: Technical Assistance Visits Text: The RPM may request that NOSSA provide a TAV to assess the level of project compliance, much as they would during an audit. The main difference is that the RPM need not respond to TAV findings. TAVs can be tailored to a specific need or area, or can be broad in scope (like an audit). TAVs are most beneficial when conducted early in the life of the project.

Title: Safety Plan Text: The contractor is responsible for preparing and then following an approved Site Safety and Health Plan (SSHP). The SSHP must reflect the explosives and operational safety requirements identified in the ESS. The contractor UXO Safety Officer (UXOSO) has specific job requirements identified in OP 5, Vol. 1, Chapter 14 which must be spelled out in the SSHP. The UXOSO is responsible for all site safety and health requirements including establishing and maintaining all project EZs, determining whether non-UXO MEC items are safe to transport, overseeing the proper storage of MEC, overseeing the proper packaging of MEC for transport and compliance with all applicable OSHA safety precautions and ESS and Site Approval requirements.

Title: MEC Treatment Text: Destruction-in-place is considered to be the safest approach to address MEC that is encountered in the field. Recovered MEC may also be treated within a common area such as an Open Burn/Open Detonation (OB/OD) range. When recovered MEC cannot be destroyed on-site, the ESS will address how explosives safety requirements will be met during on-site movement and storage, or off-site shipment, storage, and/or treatment. Either the responding EOD team leader or contractor Senior UXO Supervisor (SUXOS) for the project may evaluate the MEC items to determine whether or not they are safe to move on site. A SUXOS is required any time there are intrusive activities or removal/disposal actions are to be taken. Only EOD personnel can certify UXO as safe-to-ship off site.

Title: MPPEH Management Text: Munitions and range-related debris are classified as MPPEH. These materials are considered to be unsafe because of the possibility that unexploded components or explosives residues may be present. These materials must be inspected, certified, and verified prior to further demilitarization and release from DoD control. The ESS will outline all required steps.

Title: Quality Control/Quality Assessment Text: The contractor is responsible for executing the project QC in accordance with an approved QC Plan. The QC Plan must incorporate three-phases of control (e.g. preparatory, initial, and follow-on phases) for each definable feature of work to ensure it is in compliance with the ESS. QA is a government responsibility. The munitions response QA Program consists of the following activities: Evaluating completed munitions response actions to verify/validate that these actions meet contractual requirements as stated in the work plan or other defining documents; Compiling a QA assessment documenting that the completion of response actions is collected, documented, and maintained; Ensuring the integrity of the QA data gathered during the process; and Supporting the verification required by NOSSA for RC with respect to MEC explosives safety. Regardless of whether NAVEODTECHDIV or an independent contractor conducts the QA efforts, they must develop the Quality Assurance Project Plan (QAPP) for the MEC. NAVEODTECHDIV uses the AQAPS to conduct QA activities at MRSs. AQAPS consists of the following: Data Quality Objectives Data Quality Elements Question Sets Work Instructions Quality Assessment Record Corrective Action Record Also embedded in the AQAPS software is the Quality Assessment Manual (QAM). The QAM provides step-by-step detailed instructions on conducting a successful QA operation.

Title: After Action Report Text: The purpose of an After Action Report (AAR) is to document that the explosives safety aspects of a response have been completed in accordance with an approved ESS. An AAR is required for all responses completed in accordance with an approved ESS. AARs are submitted within six months of completion of the munitions response. NOSSAINST 8020.15A Enclosure (5) contains a detailed list of the required AAR contents. AARs are submitted through the same channels as the ESS. However, the DDESB will acknowledge the receipt of an AAR and may raise concerns that require resolution before land transfer or an alternate use can safely proceed.

Title: Verification and Final Response Action Text: Verification is the formal process by which NOSSA finds that (1) the munitions response actions were completed per the approved ESS and (2) the final remedy, including required LUCs, is protective of human health and the environment with respect to explosives safety, consistent with the current, determined, or reasonably anticipated future land use of the MRS. Verification is based on a review of the following project documents, as applicable: ESS AAR Audit Report Record of Decision Findings of suitability to lease or finding of suitability of transfer Proposed deed, with language addressing the MEC contamination Land Use Control Plan, including a description of explosives safety-related institutional and engineering controls Long-Term Management Plan

Title: Contacts Text: For more information, please contact: NFESC T2 POC (805) 982-1656 PRTH_NFESCT2@navy.mil NFESC MRP POC (805) 982-1795 NOSSA POC (301) 744-4534 NAVEODTECHDIV (301) 744-6850 MARCORSYSCOM (703) 432-1803