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Title:
Introduction
Text: The Department of the Navy (DON) has developed mandatory explosives safety policies and criteria to protect both essential and non-essential personnel, as well as real property, from hazards associated with munitions or explosives of concern (MEC) and material potentially presenting an explosive hazard (MPPEH).
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.
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Visual Description: A satellite image of a munitions response site (the red line outlines the munitions response area).
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Title:
MPPEH
Text: MPPEH is material that, prior to determination of its explosives safety status, potentially contains explosives or munitions (e.g., munitions containers and packaging material; munitions debris remaining after munitions use, demilitarization, or disposal; and range-related debris), or potentially contains high enough concentration of explosives such that the material presents an explosive hazard (e.g., equipment, drainage systems, holding tanks, piping, or ventilation ducts that were associated with munitions production, demilitarization or disposal operations.) Excluded from MPPEH are munitions within the Department of Defense's (DoD's) established munitions management system and other hazardous items that present explosion hazards (e.g., gasoline cans) that are not munitions or intended for use as munitions.
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Title:
Background - Explosives Safety
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 non-explosive 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 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.
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Visual Description: A graphic “wheel” depicts the three safety rules for explosives: 1, recognize. 2, retreat. 3, report.
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Title:
MC
Text: MCs in high enough concentrations (defined as primary explosives greater than 2% by weight and secondary explosives greater than 10% by weight) are considered MEC and present an explosives hazard. Thus, MCs in explosive concentrations must be treated as reactive.
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Title:
MEC Hazard Assessment (1 of 2)
Text: MCs that are below an explosive hazard 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), the Department of Defense (DoD), and the Department of Interior (DOI) worked jointly to develop the Interim Munitions and Explosives of Concern Hazard Assessment (MEC HA) Methodology (October 2008). 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.
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Visual Description: A screen shot of the DON policy on use of the Interim MEC HA Methodology issued April 6, 2009. Click on the screen to view the policy.
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Title:
MEC Hazard Assessment (2 of 2)
Text: In January 2009, the Office of the Deputy Undersecretary of Defense (Installations and Environment) (DUSD [I&E]) issued a memorandum encouraging DoD Components to use the Interim MEC HA Methodology over the next two years as a means to evaluate the relative reductions in explosives hazards when comparing response alternatives.
On April 6, 2009, the DON issued a policy on the Trial Use of the Interim MEC HA Methodology. The policy directs the Navy and Marine Corps to evaluate the MEC HA methodology over the next two years for Remedial Investigations/Feasibility Studies (RI/FS) at munitions response sites and decide, along with their regulatory and stakeholder partners, whether the methodology is appropriate for the specific site.
If it is decided that the tool will be implemented, further evaluation is required regarding the outcome and effectiveness of the tool. These decisions are to be documented and submitted to the Chief of Naval Operations annually over the two-year period. Following the two-year trial period requested by DUSD(I&E), DON will determine whether to continue further evaluation of the MEC HA Methodology.
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Visual Description:
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Title:
Roles of Organizations in the MRP
Text: The Naval Ordnance Safety and Security Activity (NOSSA) serves as DON's explosives safety technical 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 8020.15B 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/assurance (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.
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Visual Description: A graphical flow chart of who the Naval Ordnance Safety and Security Activity (NOSSA) reports to and their role.
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Title:
Guidance and Policy
Text: Key references related to explosives safety for munitions responses are listed below:
NOSSAINST 8020.15B, Explosives Safety Review, Oversight, and Verification of Munitions Responses. Click on the image to the left to open this document.
NAVSEA OP5, Ammunition and Explosives Ashore Safety Requirements for Handling, Storage, Production, Renovation, and Shipping.
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Visual Description: A screen-shot of the NOSSA Instruction 8020.15B document. Click on the image to open a PDF of the document.
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Title:
NOSSAINST 8020.15B
Text: The purpose of this instruction is to assign responsibility and establish procedures and reporting requirements to enable NOSSA to provide effective review, oversight, and verification of the explosives safety aspects of Navy munitions responses.
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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.
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Title:
Site Identification and Notification
Text: MEC or MPPEH 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 8020.15B contains information on how to contact the cognizant unit.
For previously unidentified sites, the RPM must submit the MRS Identification and Notification Report, Enclosure (1) of NOSSAINST 8020.15B within one week of the encounter. This report provides NOSSA with information about the site history, work task or project being performed, type and quantity of MEC or MPPEH found, actions taken to date and actions planned. NOSSA will keep a record of this form. Click on the adjacent graphic to view Enclosure (1).
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.
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Visual Description: A screen-shot of the MUNITIONS RESPONSE SITE (MRS) IDENTIFICATION AND NOTIFICATION REPORT document. Click on the image to open a Word version of the document.
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Title:
Explosives Safety Submission (1 of 6)
Text: An Explosives Safety Submission (ESS) must be reviewed and endorsed by NOSSA, then reviewed and 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 or MPPEH. NOSSA 8020.15B 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 NOSSA concurrence has been received. 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.
It is necessary to obtain final DDESB approval of an ESS, which could take several months, so RPMs must plan accordingly. RPMs should work with NOSSA (or MARCORSYSCOM at a Marine Corps site) to establish a reasonable schedule.
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Visual Description: Two images of technicians at a munitions response site documenting and submitting information on UXOs.
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Title:
ESS Required
Text: An ESS is required for response actions involving:
Placement of explosives on a site
Intentional physical contact with MEC or MPPEH, including the decontamination and demolition of buildings and installed equipment potentially contaminated with residual MEC, or
Conduct of ground-disturbing or other intrusive activities, including dredging, in areas known or suspected to contain MEC or MPPEH.
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Title:
ESS Not Required
Text: An ESS is not required for:
Explosives or munitions emergency responses*,
Maintenance and clearance activities on operational ranges,
Construction or non-munitions response activities, including dredging, in an area not known or suspected to contain MEC or MPPEH,
Demolition of magazines where there is no evidence of residual MEC contamination or historical record of explosives spills, or
Operation, maintenance, or cleanup of ammunition and explosives operating buildings in an active, standby, or layaway status.
*Emergency responses include 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.
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Title:
ESS May Not Be Required
Text: With concurrence of NOSSA, an ESS may not be required for operations taking place in areas known or suspected to contain MEC or MPPEH when the preponderance of evidence indicates that the likelihood of encountering MEC or MPPEH is low. These operations include:
On-call construction support and, when included in a conservative measure, on-site construction support
Ground-disturbing activities on former ranges used exclusively for testing or training with small arms ammunition
Anomaly avoidance employed during, for example, vegetation removal, cultural/natural resources survey, preliminary assessment (PA) site reconnaissance or site inspection (SI), and sign or fence installation
Demolition of magazines where there is evidence or a historical record of a spill or other residual MEC, 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.
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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 to NOSSA. This form is provided in NOSSAINST 8020.15B - Enclosure (2) and can be viewed here by clicking on the image to the left.
The RPM must provide information on site history, MEC or MPPEH known or suspected to be present, work task/project being proposed, and likelihood of encountering MEC or MPPEH. The form shown here allows NOSSA to evaluate the site-specific conditions and the associated hazards. NOSSA will provide a written response within two weeks of receiving the request.
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Visual Description: A screen-shot of the NOSSA REQUEST FOR A NOSSA EXPLOSIVES SAFETY SUBMISSION DETERMINATION document. Click on the image to open a Word version of the document.
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Title:
Explosives Safety Submission (3 of 6)
Text: NOSSAINST 8020.15B includes as Enclosure (3) 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 or characterization;
(2) a determination of No DoD Activity Indicated (NDAI)/No Further Action (NFA);
(3) time critical removal action (TCRA) involving MEC or MPPEH;
(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 (3) of NOSSAINST 8020.15B includes a matrix of the required ESS contents as shown to the left.
An example of an ESS prepared under NOSSAINST 8020.15B is the ESS for Installation Restoration Site 05 and Dredge Pond 7S Munitions Response Action at Former Mare Island Naval Shipyard. This ESS describes the response actions for the site including excavation and removal of chemically contaminated soil and the resolution of data gaps in wetland habitats. The ESS describes the types and quantities of MEC and MPPEH known or anticipated at the site and as well as explosion safety requirements for this project.
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Visual Description: A table that shows the detailed guidelines on how to prepare an ESS including who should submit the report, the execution of selected response, on-site construction support, time-critical removal action, NDAI/NFA and MRS investigation or characterization.
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Title:
Explosives Safety Submission (4 of 6)
Text: NOSSA 8020.15B Enclosure (3) provides detailed instructions on the required contents of the ESS. Information required in an ESS includes background information; project dates; types of MEC or MPPEH; detection techniques; extensive information on response actions; quality control and quality assessment/assurance (QC/QA); technical support (including required training for contractors); environmental, ecological, cultural, or other considerations; residual risk management; safety education program; and stakeholder involvement.
An ESS that is compliant with NOSSA 8020.15B Enclosure (3) meets the requirements of an explosives safety site approval request; therefore, NAVFAC Forms 1110.45 Part I and Part II Division A are not required. Signatures of the cognizant explosives safety officer (ESO) and public works department (PWD) planning office that would have been included on the NAVFAC forms will be required on the signature page found in Enclosure (3), Appendix A. The ESO and PWD signatures affirm that the ESS meets all applicable explosives safety and planning criteria, respectively.
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Visual Description: Screen shot of the ESS signature page from NOSSA 8020.15B Enclosure (3), Appendix A
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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. The ESS guidance indicates that, if there is anecdotal evidence suggesting that an MEC item with a larger MFD may be present, the item(s) should be included as contingency MGFDs. The tables to the left show examples of including 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 successfully employed (see Slide 7 of the case study).
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Visual Description: This table shows multiple contingency MGFDs and EZs based on potential MECs that may be encountered in the field and includes excavated soil screening as well as MEC treatments.
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Title:
Explosives Safety Submission (6 of 6)
Text: The ESS is then submitted to NOSSA for their review and endorsement to the DDESB for final approval. Since this process can take several months, RPMs must ensure that their project schedules include adequate time for preparation, review, and approval. Note that until the final ESS is approved by DDESB, an ESS is considered a working document and should not be released outside 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 approximately a month 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.
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 must be consistent with the final approved ESS.
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Visual Description: A picture of a NAVFAC Explosive Safety Submission document.
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Title:
ESS Amendments and Corrections
Text: Once an ESS is approved, no changes can be made to the munitions response process unless the ESS is amended or corrected. Amendments are required when a proposed change to an approved ESS increases explosives safety hazards/risks, identifies requirements for additional or increased explosive safety controls, or enlarges an ESQD arc. ESS amendments follow the same review and endorsement process as an ESS; however, in extenuating circumstances, project managers may request that NOSSA provide provisional approval when there is a demonstrated need in order to increase an approved ESQD arc.
Corrections address changes to an approved ESS that do not increase explosives safety hazards/risks, identify requirements for additional or increased explosives safety controls, or enlarge an ESQD arc. Corrections are primarily administrative in nature and are provided for informational purposes. Corrections must be submitted to and reviewed by NOSSA, but do not need to be endorsed to the DDESB for their review and approval.
An amendment or correction to an approved ESS does not require the resubmission of the complete ESS package if the number of amended or corrected pages is 10 or less and if the submittal meets the specifications in Enclosure (3), such as identifying the amendment/correction number and date on the title page and each corrected page. Coordinate with NOSSA to determine the appropriate change for your project.
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Title:
NOSSA Oversight
Text: NOSSA provides oversight of activities at MRSs as follows:
Reviews MRS Identification and Notification Reports
Reviews and endorses ESSs
Audits munitions response projects for compliance with explosives safety, environmental, and other requirements related to management of MEC and MPPEH
Provides Technical Assistance Visits (TAVs)
Reviews mishap reports
Reviews and endorses After Action Reports (AARs)
Verifies RC for safety aspects of a project.
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Visual Description: Screen-shot of the NOSSA website homepage.
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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 QC/QA processes.
Auditable documents include ESSs, work plans and standard operating procedures (SOPs), QC plans or QA project plans; site-specific health and safety plans; environmental protection plans, and UXO worker qualification and certification documents. Auditable field operations and procedures include: general explosives safety practices, explosives storage and transportation, occupational safety and health practices, environmental compliance, geophysical instrument checkout and use, anomaly detection and identification, manual/mechanized MEC/MPPEH removal, MEC treatment/disposal, MPPEH management and data management.
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Title:
Technical Assistance Visits
Text: The RPM may request that NOSSA provide a technical assistance visit (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.
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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.
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Visual Description: This satellite-based image shows a munitions response area that has areas shaded in different colors to represent the proposed work area, the construction boundary, and the standoff distance.
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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.
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Visual Description: A picture of several UXOs that are in a trench and connected to a detonator cord to be destroyed on site.
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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.
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Visual Description: A collage of pictures showing large amounts of UXOs that have been collected and are in piles.
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Title:
After Action Report
Text: The purpose of an After Action Report (AAR) is to document that the munitions response is complete in accordance with an approved ESS. An AAR is required for all responses completed in accordance with an approved ESS except NDAI/NFA or TCRA ESSs. AARs must be submitted within six months of completion of the specific munitions response authorized by the ESS. The six-month time period begins after all field work and data processing are complete. NOSSAINST 8020.15B Enclosure (4) 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.
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Visual Description: Before and after photographs of a munitions response site. The before shot shows scrap littered throughout the site. The after shot, shows how it has all been cleaned up as well as the installation of eco blocks for safety, an EOD tech viewing area, and soil screening equipment.
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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 of the munitions response is based upon, but not limited to, a review of the approved ESS and AAR, QC and QA reports, audit reports (including responses to findings), Record of Decision or similar decision document, Remedial Action Completion Report, Finding of Suitability to Lease or Finding of Suitability of Transfer, and proposed deed language addressing any remaining MEC or MPPEH contamination.
In the AAR, RPMs will either request that NOSSA provide project verification or state that verification is not required. Verification generally is not necessary for property that remains under DON control.
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Visual Description: A close up image of a sign that says: “Area closed. No earthmoving or dumping. Restricted access. Authorized personnel only.
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Title:
Contacts
Text: For MRP technical support, please contact:
NOSSA (N53): (301) 744-4450 or
NOSSA (N54): (301) 744-6044 (DSN 354)
NAVFAC Engineering Service Center (ESC): (805) 982-1795
For more information about the T2 Program, please contact:
PRTH_NFESCT2@navy.mil
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