# Presentation: 710680

## Munitions and Explosives of Concern Hazard Assessment (MEC HA)            Initiative 

- ASTSWMO August 4, 2005

**Notes:**

MRC HA is under development for use as site specific tool.

You will hear this theme a lot 

Much like the HRS & HHRA, the MRSPP and the MEC-HA can serve analogous purposes. The HRS and the MRSPP serve as national prioritization tools.  The human health risk assessment serves as a tool for making site-specific risk-based evaluations, including evaluation of response actions. The MEC HA development is being approach in a similar manner. That is to develop a tool to help with site-specific evaluations.

## Purpose of this Briefing

- Overview – Why a MEC HA?
- Discuss the participants, progress, and process
- Discuss what the MEC HA will provide
- Structure overview
- Scoring example “Camp Sample”
- Discuss next steps and outreach
- Emerging issues for Guidance document

**Notes:**

Talk to the slide – these are the main topics for this presentation

## Why a MEC HA ?

- CERCLA & NCP require “risk assessment”
- Traditional risk assessment methods not applicable to MEC hazards
- Need for consistent method under CERCLA for MEC response actions
*Emphasis* for EE/CA, RI/FS analysis to support remedy selection

**Notes:**

The MEC HA is being developed to “fill in the box” in the CERCLA process for “risk assessment” under the NCP for MEC sites response actions. 

MEC-HA – site specific evaluations of removal and response actions.
	- more sensitive to land use decisions
	- more sensitive to 9 criteria analysis
	- technical tool.

Analogies

## Relationship Between the MEC HA and the MRSPP

- MRSPP Supports Programmatic Goals
*Provides relative priority for each Munitions Response Site, based on overall risks *
*Allows sequencing decisions to consider Other Factors (e.g., programmatic, environmental justice, development) *
- MEC HA Supports Site Specific Decisions
*- **Removal & Remedial Actions*
*- Land Use Activities*

**Notes:**
MRSPP – national funding priorities

MEC-HA – site specific evaluations of removal and response actions.
	- more sensitive to land use decisions
	- more sensitive to 9 criteria analysis
	- technical tool.

Analogies

HRS = MRSPP

MRSPP does not substitute for HHRA

MEC-HA  analogous to HHRA

## CERCLA PROCESS

**PA/SI**

**ROD**

**RI/FS**

**RA**

- CERCLA PROCESS

**Notes:**

MRSPP and MEC HA serve two different functions

MRSPP applied primarily at PA/SI step for relative ranking for funding priorities.

MEC HA applied primarily at Feasibility Study step  to support 9 criteria analysis and remedy selection.  

MEC HA under development to be more sensitive to different land uses, comparative analysis of alternatives, relative risk reduction between response action alternatives.

## MEC HA Work Group Participants

- EPA
- DOD
- DOI
- ASTSWMO
- TASWER

**Notes:**

Exec committee sponsors from each organization

6 month outreach  program before work group kick off in Spring 2004

Small work = get things done

Participants – act as conduits to organizations

## Work Group Underlying Principles

- Support the management of uncertainty
- Connection to the Conceptual Site Model
- Utilize a relative hazard assessment approach

**Notes:**
Next three slides will cover these common themes and how the work group has looked at them.

Uncertainty will be explicitly addressed and managed throughout the MEC HA process. How much info is needed to make a decision and when?

The MEC HA process will be designed to support decision-making at the earliest time that sufficient information becomes available. This principle of acting when sufficient data are available, and of not collecting data just for the purpose of updating a hazard assessment, will carry forward through the guidance document. The guidance document will provide criteria to identify when reassessment is appropriate and when it may not be appropriate.

The CSM is directly linked to the MEC-HA and provides the key inputs to the assessment. 

Present these issues in transparent ways understandable to non-technical stakeholders

Rely on a combination of qualitative and quantitative input factors that will result in a qualitative output
Probabilistic methods not used

The MEC HA structure is being designed to be compatible with MRSPP. 

## Work Group Underlying Principles 

- Rely on input factors compatible with the MRSPP
- Support early decision making
- Support communication with stakeholders.

**Notes:**
Next three slides will cover these common themes and how the work group has looked at them.

Uncertainty will be explicitly addressed and managed throughout the MEC HA process. How much info is needed to make a decision and when?

The MEC HA process will be designed to support decision-making at the earliest time that sufficient information becomes available. This principle of acting when sufficient data are available, and of not collecting data just for the purpose of updating a hazard assessment, will carry forward through the guidance document. The guidance document will provide criteria to identify when reassessment is appropriate and when it may not be appropriate.

The CSM is directly linked to the MEC-HA and provides the key inputs to the assessment. 

Present these issues in transparent ways understandable to non-technical stakeholders

Rely on a combination of qualitative and quantitative input factors that will result in a qualitative output
Probabilistic methods not used

The MEC HA structure is being designed to be compatible with MRSPP. 

## Work Group Progress 

- Issue Papers
- Framework Papers
- Outreach Plan
- Pilot Tests

**Notes:**

Quick background info

Issue papers = Program level considerations [NCP risk assessments; 9 Criteria; etc]

Framework papers = Technical level considerations [ input & output factors; role in decision making; MEC-HA MRSPP comparisons]

Outreach plan – more on this at the end of the presentation.

4 inch binder of materials

FFRRO has a a website with all work group materials.  You will find a lot more info than I can hope to cover in an overview brief

## Issue Papers

- Review of Existing Methods
- Purpose of MEC HA
- Role of Uncertainty
- Probabilistic Risk
- Input Factors
- Analysis of Response Alternatives
- MEC HA as Communication Tool

**Notes:**

Quick background info

Issue papers = Program level considerations [NCP risk assessments; 9 Criteria; etc]

Framework papers = Technical level considerations [ input & output factors; role in decision making; MEC-HA MRSPP comparisons]

Outreach plan – more on this at the end of the presentation.

4 inch binder of materials

FFRRO will stand up a website in October with all work group materials.  You will find a lot more info than I can hope to cover in an overview brief

## Framework Papers 

- Performance Objectives
- Comparison of MRSPP to MEC HA
- Input Factors
- Structure and Output
- MEC HA in the CERCLA Process

**Notes:**
Quick background info

Issue papers = Program level considerations [NCP risk assessments; 9 Criteria; etc]

Framework papers = Technical level considerations [ input & output factors; role in decision making; MEC-HA MRSPP comparisons]

Outreach plan – more on this at the end of the presentation.

4 inch binder of materials

FFRRO will stand up a website in October with all work group materials.  You will find a lot more info than I can hope to cover in an overview brief

## What will the MEC HA Provide ?

- Consistent framework for developing a site-specific hazard assessment
- Assistance in managing uncertainty
- Facilitate site-specific land use activity decisions

**Notes:**

Provide a consistent framework. The development and application of a consistent framework for MEC HA will allow project teams to organize and communicate information systematically.  It ensures that project teams in different parts of the country have a similar understanding of hazards and should make similar hazard management decisions for similar site situations.
Assist project teams to manage uncertainty.  Site-specific hazard assessment guidance will provide a consistent framework for evaluating site explosive hazard, and can also be used to identify when sufficient quantity and quality of information is available to make management decisions supporting no action, removal, or remedial decisions.
Focus attention on hazard management choices. Project teams can use a site specific hazard assessment to evaluate approaches to cleanup to support future land uses and assess the impact of those approaches in the decision making process. 
Ensure continuity of hazard management evaluations and decisions.  When a consistent, accepted framework is in use, decisions for a munitions response site are more likely to continue to be supported when the project team changes, such as when new staff and contractors, and new stakeholders become involved.

Land use activities – the nature of the intrusive activities that take place at an MRS can be more important than the land use designation. For example, a residential land use may have less intrusive activities associated with it that could lead to a receptor interacting with a below surface MEC item than say a recreational land use designation that routinely has intrusive activities (e.g. driving tent stakes, digging fire pits, etc.)

## What will the MEC HA Provide ? 

- Evaluation of hazard management choices – response actions
- Support hazard communication
- Build confidence in decision making process

**Notes:**

Provide a consistent framework. The development and application of a consistent framework for MEC HA will allow project teams to organize and communicate information systematically.  It ensures that project teams in different parts of the country have a similar understanding of hazards and should make similar hazard management decisions for similar site situations.
Assist project teams to manage uncertainty.  Site-specific hazard assessment guidance will provide a consistent framework for evaluating site explosive hazard, and can also be used to identify when sufficient quantity and quality of information is available to make management decisions supporting no action, removal, or remedial decisions.
Focus attention on hazard management choices. Project teams can use a site specific hazard assessment to evaluate approaches to cleanup to support future land uses and assess the impact of those approaches in the decision making process. 
Ensure continuity of hazard management evaluations and decisions.  When a consistent, accepted framework is in use, decisions for a munitions response site are more likely to continue to be supported when the project team changes, such as when new staff and contractors, and new stakeholders become involved.

## Relationship to Conceptual Site Model (CSM)

- The CSM components (source, pathways, receptors) are addressed by the MEC HA
- MEC HA organization follows the Hazard Assessment functions
- Recognizes the fundamental differences from human health risk assessment
- Focus on the functions of the MEC HA

**Notes:**
The traditional Hazardous and Toxic Waste (HTW) organization does not reflect the understanding that a MEC HA is fundamentally different from traditional chemical risk assessment.  This is due to the fact that for MEC the effects are acute and immediate, whereas for traditional chemical risk assessment, chronic effects are evaluated.  Therefore, the description of the functional relationships between input factors will differ from the traditional “source, pathway, receptor” organization.  The functional relationships addressed in the MEC HA are:
Severity:  The potential severity of the result should an MEC item function.
Accessibility:  The likelihood that a receptor will be able to interact with an MEC item.
Sensitivity:  The likelihood that an MEC item will function should a receptor interact with it.

## MEC HA  Structure

- Includes scoring, weighting, and combining input factors
- Will use a relative numeric approach, similar to the approach used in the EHE module of the MRSPP
- The organization of the structure will follow the severity, accessibility and sensitivity components.

**Notes:**
In summary, we are looking at these principles, model, and linkages to develop and test a structure to see if it will provide a level of sensitivity, transparency, and reproducibility to help with site-specific evaluations and decision making.

The relative numeric approach provides greater flexibility in the identification and definition of these categories, assists in prioritizing sites, and supports reclassification of the hazard of a site based on new information or changes in conditions at the site. 

The hazard assessment structure encompasses the methods used to score, weight and combine the input factors.  The methods used to score, weight and combine input factors will use a relative numeric approach, similar to the approach used in the EHE module.  The organization of the structure will follow the severity, accessibility and sensitivity components describe in the previous chart. 

## MEC HA  Structure 

- The functional relationships addressed in the MEC HA are:
***Severity***:  The potential severity of the result should an MEC item function.
***Accessibility***:  The likelihood that a receptor will be able to interact with an MEC item.
***Sensitivity***:  The likelihood that an MEC item will function should a receptor interact with it.

**Notes:**
The next few minutes and slides I will talk about the framework we are developing and its relationship to CSM.

This is where we shift gears.  We are working with a framework to get more to cause and effect issues. As a result, the starting point for organizing the major elements of the framework look different, and are specifically designed to try to better capture the acute nature of interactions between people and MEC.

This structural organization is somewhat analogous to the RRSE module where the structure for it is cross-linked between the CHF, MPF, and RF to the CSM.

The framework of an MEC HA can be described by specifying its input factors, its structure (the way in which the input factors are weighted and combined), and the nature of its output.

## MEC HA  Structure 

***Severity***:  Input Factors
- Filler Type
- Distance to Additional Receptors
- Proximity of Critical Infrastructure
- Proximity of Cultural Resources
- Proximity of Ecological Resources

**Notes:**

Proximity items are addressed as a “ present or not” approach.  Will be addressed in the guidance document introduction, not in the guidance on how to score sites.

Next slides illustrates filler type & distance input factors and scores.

## MEC HA  Structure 

| Input Factor | Category or Value | Score |  |  |
| --- | --- | --- | --- | --- |
|  |  | Untreated | Surface MEC
Response | Subsurface
MEC Response |
| Filler Type | High Explosive | 100 | 100 | 100 |
|  | Incendiary | 80 | 80 | 80 |
|  | Spotting Charge | 80 | 80 | 80 |
|  | Propellant | 20 | 20 | 20 |
| Distance of Additional Potential Human Receptors to Explosive Hazard | Within MRS or hazardous distance of the MRS boundary | 30 | 30 | 30 |
|  | Outside of the hazardous distance | 0 | 0 | 0 |
|  | Non-HE filler type | 0 | 0 | 0 |

**Notes:**

Talk to the slide

## MEC HA  Structure 

***Accessibility***:  Input Factors
- Site Accessibility
- Potential Contact Hours
- Amount of MEC
- MEC Depth Relative to Intrusive Depth
- Migration Potential

**Notes:**

Talk to slide

Next three slides will illustrate the specific input factors and the scores associated with them.  

## MEC HA  Structure 

| Input Factor | Category or Value | Score |  |  |
| --- | --- | --- | --- | --- |
|  |  | Untreated | Surface MEC Response | Subsurface MEC Response |
| Site Accessibility | Full accessibility | 80 | 60 | 15 |
|  | Moderate Accessibility | 55 | 25 | 10 |
|  | Limited Accessibility | 15 | 10 | 5 |
|  | Very Limited Accessibility | 5 | 5 | 5 |
| Potential Contact Hours | Many Hours | 120 | 90 | 30 |
|  | Some Hours | 70 | 50 | 20 |
|  | Few Hours | 40 | 20 | 10 |
|  | Very Few Hours | 15 | 10 | 5 |

**Notes:**

Talk to slide

## MEC HA  Structure 

| Input Factor | Category or Value | Score |  |  |
| --- | --- | --- | --- | --- |
|  |  | Untreated | Surface MEC Response | Subsurface MEC Response |
| Amount of MEC | Target area | 180 | 120 | 30 |
|  | OB/OD area | 180 | 140 | 30 |
|  | QA function test range | 165 | 90 | 25 |
|  | Burial Pit | 30 | 30 | 10 |
|  | Maneuver areas | 115 | 15 | 5 |
|  | Storage | 25 | 10 | 5 |
|  | Explosive-related industrial facility | 20 | 10 | 5 |
|  | Firing points | 75 | 10 | 10 |
|  | Safety buffer areas (Range safety fans and OB/OD kick-out areas) | 30 | 5 | 5 |

**Notes:**

Talk to slide

## MEC HA  Structure 

| Input Factor | Category or Value | Score |  |  |
| --- | --- | --- | --- | --- |
|  |  | Untreated | Surface MEC Response | Subsurface MEC Response |
| Minimum MEC Depth Relative to the Maximum Intrusive Depth | MEC located on surface | 240 | Not Applicable | Not Applicable |
|  | MEC located subsurface, intrusive depth overlaps | 220 | 220 | 150 |
|  | MEC located subsurface, intrusive depth does not overlap | 25 | 25 | 25 |
| Migration Potential | Possible | 30 | 30 | 10 |
|  | Unlikely | 10 | 10 | 10 |

**Notes:**

Talk to slide

## MEC HA  Structure 

***Sensitivity***: Input Factors
- MEC Category
- MEC Size

**Notes:**
UXO Category = UXO, DMMM, Fuzes

Size = greater than or less than 107mm

Next slide shows specific input factors and scoring regime.

## MEC HA  Structure 

| Input Factor | Category or Value | Score |  |  |
| --- | --- | --- | --- | --- |
|  |  | Untreated | Surface MEC Response | Subsurface MEC Response |
| MEC Category | UXO special case | 180 | 180 | 180 |
|  | UXO | 110 | 110 | 110 |
|  | DMM with category 1 fuzes | 105 | 105 | 105 |
|  | DMM with category 2 fuzes | 55 | 55 | 55 |
|  | Unfuzed DMM | 45 | 45 | 45 |
| MEC Size | Small | 40 | 40 | 40 |
|  | Large | 0 | 0 | 0 |

**Notes:**

Talk to slide

## MEC HA  Outputs

- The Output Categories for the MEC HA are based on relative numeric scores
- Score Range is from 115 to 1000
- Score Range is broad enough to differentiate between hazard categories
- Uses a different range than the MRSPP

**Notes:**

Talk to the slide

## MEC HA  Outputs

- The Output Categories Scores for the     MEC HA are:
***Category 1:              860 - 1000***
***Category 2:              720 - 855***
***Category 3:              475 - 715***
***Category 4:              115 - 470***

**Notes:**

Talk to the slide

Ranges represent the relative scores for each hazard category

## MEC HA  Outputs

- The Output Categories for the MEC HA are:
***Category 1:*** Sites with the highest hazard potential under current use conditions.
***Category 2:*** Sites with a hazard potential under current use conditions.
***Category 3***:  Sites compatible with current uses,  not with more intrusive future uses.
***Category 4***:  Sites compatible with current or future uses.

**Notes:**

Qualitative description of categories

## MEC HA Scoring Example 

***       “******Camp Sample”***

**Notes:**

Transition slide

Hypothetical FUDS property

Will go through several slides on investigation,then HA and how it fits into the FS evaluations

## Historical Research at “Camp Sample” Practice Range Identified

**Installation boundary**
**Roads**
**Water body**
**Range**

**Notes:**

Talk to the slide

Ranges represent the relative scores for each hazard category

## Former “Camp Sample”         Site Features

- Undeveloped inside boundaries
- Nature trail through portion of the property
- Existing residential area nearby
- Elementary school planned nearby

**Notes:**

Talk to the slide

## “Camp Sample” Historical Information

- 2.36” rockets used for training
- Training in WWII through1950’s

**Notes:**

Talk to the slide

Ranges represent the relative scores for each hazard category

## Historical Information

**Suspected firing point area**

**Suspected target area**

**Site boundary**

**Hiking trail**

**Proposed school location**

**Hill**

**Notes:**
The historical records review for our hypothetical “Camp Sample” provides information about the firing point for the 2.36-inch rockets and the likely target area. This information provides a good preliminary CSM and indicates where the site investigation may be focused.

## Suspected locations of
Firing point
Range fan

**Target**

**Firing Point**

- Suspected locations of
- Firing point
- Range fan

- Preliminary Conceptual Site Model

**Notes:**
For our hypothetical “Camp Sample” we will assume that the firing point and the range fans for this site are known from the Archive Search Report (ASR) conducted previously by the Army Corps of Engineers as part of the historical records review process.

The tank is a stationary target, fired on from the firing point, as shown on the preliminary conceptual site model. The range fan includes the target area as well as buffer and safety zones.

We have a lot of knowledge about what the range fan looks like. A 2.36” rocket range fan has an expected effective range fan of approximately 600 yards. The distance to target is approximately 100 to 250 yards. While we do not know exactly where the target was located, the MEC contamination in the range fan is expected to be a relatively small area.

## Data Quality Objectives (DQOs)

- Specify the type and quality of data needed to support site investigation
- Statements that :
- Clarify objectives of data collection
- Specify how data will be used to support hazard assessment
- Define appropriate type, quantity, and quality of data to collect
- Specify acceptable levels of decision errors *** ***

**Notes:**

Talk to the slide

Same kind of DQO process for MEC HA as for HHRA

## Identify Data Needs for Investigation Design

- Data Need 1.
- Define boundaries
-   of the target area
- Define geophysical
-    transect spacing

**Notes:**

Talk to the slide

Ranges represent the relative scores for each hazard category

## Identify Data Needs for Investigation Design (Cont)

- Data Need 2: Where is the most likely boundary of the target area ?
- Increase transect density over suspected target
- Data Need 3: What are the UXO distributions in the target area ?
- Use of mini-grids to better define nature and extent within target area.

**Notes:**

Talk to the slide

Ranges represent the relative scores for each hazard category

## Detected Anomalies

- Site boundary

- Hiking trail

- Suspected firing point area

- Proposed school location

- Suspected target area

**= ****detected**
**	****anomaly**

**Notes:**
This is an example of what anomalies look like and what their interpreted locations are on the actual transect. 

## Anomalies Identified

- Site boundary

- Hiking trail

- Suspected firing point area

- Proposed school location

- Suspected target area

**= Non-MEC anomaly**

**= MEC Frag ****(2.36” rocket)**

**= UXO-2.36” rocket**

**Notes:**
This is an example of what anomalies look like and what their interpreted locations are on the actual transect. We found non-range related debris, some UXO frag, unexploded 2.36” rockets and an 81 mm mortar along the hiking trail. From the information collected, the project team has identified the suspected target area.

## Results of Increased Transects

**Increased transects in this area**

**Results of adding 25 foot transects added to investigation**

**Notes:**
Based upon decision rule we discussed earlier, which stated that anywhere we found unexploded ordnance, we would increase the number of transects to 25 foot spacing.

## Items detected: 2.36” rockets (HE) and 2.36” rocket frag
Depth ranges: Surface to one-foot
UXO density: estimated 4/acre
Scrap density:
	estimated 480 anomalies/acre

- Depth ranges: Surface to one-foot
- UXO density: estimated 4/acre
- Scrap density:
- 	estimated 480 anomalies/acre

- Detailed Sampling Results

**Notes:**
Closer to the suspected firing point, only frag was found. The information from these findings indicate that we have done a good job of bounding the target area. We did not find any indications of 81 mm mortars anywhere in the target area. This supports our assertion that the 81 mm mortar found on the hiking trail came from somewhere else off-range, probably carried by a hiker.

## Target Area Delineated – Extent of Contamination

- 17 acres

**Notes:**
Using the information presented in the previous slide, we can come up with rough estimates of cost. Based on the information found in the grid, we would expect to find frag kicked out from the target area (frag distance for 2.36” rockets could be 800 to 900 feet); therefore, we can expect to find frag outside of the target area boundary.

## Continuing the Investigation – Firing Point

**100% investigation of firing point to be conducted**

**Notes:**
Now we are going to talk about what was done and found in the firing point.

## Anomalies identified during mapping are cultural features (buried tin rations and metal fence)
No evidence of buried discarded military munitions found

- No evidence of buried discarded military munitions found

**Digital geophysical map of firing point**

- Results of the Investigation of the Firing Point

**Notes:**
The picture shown here shows the geophysical data from the geophysical sensor. There are a couple of data gaps where parts of transects were missing (probably obstructions in the way of the sensor). There are a couple of locations where there are anomalies (red and blue areas). The dig team went out to characterize what was found in these areas. These were found to be buried metal ration cans, metal fence posts, etc. No evidence of discarded military munitions were found. Therefore, we can predict that we will find a no further action finding for this area. 

## Additional site information needed for MEC HA
Ready to begin feasibility study and site remediation process
Camp Sample example is a simplified example of an investigation of a munitions response site

- Ready to begin feasibility study and site remediation process
- Camp Sample example is a simplified example of an investigation of a munitions response site

- Geophysical Investigation Complete

**Notes:**
Please remember, that “Camp Sample” is a simplified site; most ordnance sites will usually be much more complex. For example, more than one ordnance type, more than one target area, more varied terrain, etc. are typical of other sites.

## Additional Site Information for MEC HA

- Determine distance to additional receptors
- Accessibility determination
- Estimate potential contact hours
- Determine if there are intrusive site activities that could result in contact with MEC items
- Evaluate migration potential

**Notes:**

Talk to the slide

Ranges represent the relative scores for each hazard category

## Ready to Begin Feasibility Study

**Notes:**
No associated notes.

## Target area objective: remove detectable UXO
To maximum depth of penetration as determined in investigation 
Use best available technology 
To support future land use activities

- To maximum depth of penetration as determined in investigation
- Use best available technology
- To support future land use activities

- Remediation Objectives for Target Area

**Notes:**
May be known as Preliminary Remediation Goals. 
Used for planning purposes. 
Should identify the area that is the subject of the cleanup and the required depth of clearance.

## 
Technology options developed for target area remedial alternatives 

Alternatives are evaluated using CERCLA nine criteria

- Technology options developed for target area remedial alternatives
- Alternatives are evaluated using CERCLA nine criteria

- Developing Specific Remedial Alternatives

**Notes:**
CERCLA nine criteria are as follows:
1. Overall protection of human health and the environment
2. Compliance with applicable or relevant and appropriate substantive requirements (ARARs)
3. Long-term effectiveness and permanence
4. Reduction of toxicity, mobility, or volume through treatment
5. Short-term effectiveness
6. Implementability
7. Cost
8. State acceptance
9. Community acceptance

## Example Alternative: Clearance to Depth of Detection for Target Area

**1 foot**

**21⁄2 feet**

**Geophysical detection limit = 21⁄2 feet**

**Range Fan**

**Target Area**

**Buffer Zone**

**Buffer Zone**

**Bedrock**

**Notes:**
Geophysical sensor can detect 2 1⁄2 feet
Bedrock is at 3-3 1⁄2 feet
Munitions found in the top 1 foot

## Consider remediation objectives and land use
Consider site-specific conditions
Proximity to populations
Terrain, site geology, vegetation
Nature and extent of contamination
Cultural and ecological resources

- Consider site-specific conditions
- Proximity to populations
- Terrain, site geology, vegetation
- Nature and extent of contamination
- Cultural and ecological resources

- Other Information to Inform the Remedial Alternatives Evaluation

**Notes:**
Analyze the remediation objectives in light of the current and future land use and site specific conditions to determine the potential ways to meet all of those requirements.

Remediation alternatives are usually: No DoD Action Indicated (NDAI), surface clearance, clearance to a specified depth, Land Use Controls (LUCs).

## Scoring Example “Camp Sample” Target Area

- Filler Type - HE
- Distance to Additional Receptors – outside MRS
- Accessibility  - Fully
- Contact Hours  - Few
- Amount of MEC  -  Target Area
- MEC Depth vs Intrusive Depth – Overlaps
- Migration – Unlikely
- Category – UXO
- Size – Small

**Notes:**

Talk to the slide.

This information represents the known conditions of the MRSs that are the example for scoring outputs.

## Scoring Example “Camp Sample”

|   | Current Conditions |  |
| --- | --- | --- |
| Input Factor | Input Factor Category | Score |
| Type of Filler | High Explosive | 100 |
| Distance between additional receptors and explosive hazard | Outside of the hazardous distance | 0 |
| Site Accessibility | Full accessibility | 80 |
| Potential Contact Hours | Few Hours | 40 |
| Amount of MEC | Target area | 180 |
| Minimum MEC Depth/ Maximum Intrusive Depth | MEC located on surface | 240 |
| Migration Potential | Unlikely | 10 |
| MEC Category | UXO, Special Case | 180 |
| MEC Size | Small | 40 |
| Total Scores |   | 870 |
|  | Output Category | 1 |

**Notes:**

Talk to the slide.

This information represents the known conditions of the MRSs that are the example for scoring outputs.

## Remedial Alternatives for “Camp Sample” Target Area

***No Action***
***Land Use Activity Change***
***Surface Treatment***
***Surface Treatment and Land Use Activity Change***
***Subsurface Treatment***

**Notes:**

These are the remedial alternatives evaluated through the draft framework

## Slide 54

**Notes:**

For the target area MRS

Untreated = C1
Surface treatment = C2
Subsurface treatment = C4
Land Use Activity change = C2

## Output for Remedial Alternatives “Camp Sample” 

***No Action – Category 1***
***Land Use Activity Change – Category 2***
***Surface Treatment – Category 2 ***
***Surface Treatment and Land Use Activity Change – Category 3***
***Subsurface Treatment – Category 4***

**Notes:**

These are the remedial alternatives evaluated through the draft framework

## Evaluating the Remedial Alternatives

- Apply CERCLA nine criteria to remedial alternatives:
- Threshold criteria
- Protectiveness of human health and the environment.
- Compliance with applicable or relevant and appropriate  requirements (ARARs)
- Balancing criteria
- Long-term effectiveness and permanence
- Reduction of toxicity, mobility or volume through treatment
- Short-term effectiveness
- Implementability
- Cost
- Modifying criteria
- State acceptance
- Community acceptance

**Notes:**
This process should be open to observation and participation by the stakeholders. Select a remedy that can be performed and supports the end land use.

CERCLA nine criteria are as follows:
1. Overall protection of human health and the environment
2. Compliance with applicable or relevant and appropriate substantive requirements (ARARs)
3. Long-term effectiveness and permanence
4. Reduction of toxicity, mobility, or volume through treatment
5. Short-term effectiveness
6. Implementability
7. Cost
8. State acceptance
9. Community acceptance

ARARs – CERCLA cleanups must achieve applicable or relevant and appropriate substantive requirements (ARARs) when hazardous substances, or pollutants or contaminants are left on site.

## Outreach Plan

- The Outreach Plan includes:
- Munitions Response Committee involvement
- Opportunities for Stakeholder involvement.
- Schedule for informational briefings.
- Use of outlets such as websites, fact sheets, and mailing lists.
- www.epa.gov/fedfac/

**Notes:**
Outreach is a critical component to developing wider stakeholder involvement with and buy-in to the process.  The plan details activities and outreach opportunities over the course of the development and implementation of the MEC HA.  The outreach plan includes:
Involvement and buy-in by the Munitions Response Committee (MRC).
Identification of opportunities for stakeholder involvement. Lenny Seigel help
Establishment and tracking of a schedule for informational briefings.

Identification of outlets such as websites, fact sheets and mailing lists. 

## Next Steps

- Complete Pilot Test Framework
- Stakeholder Workshop
- Draft Guidance in Late 2005

**Notes:**

Pilot tests underway with Camp Beale and Camp Butner

Stakeholder workshop is being re-scheduled

Draft guidance on current timeline.  Results of pilot tests may influence development and publication

## Pilot Test Process

- Camp Beale complete, Camp Butner complete on August 9th
- Interaction between project teams and MEC HA TWG on framework details
- Evaluation of MEC HA, feedback to TWG
- Modifications to framework in response to pilot process with project teams
- Identification of guidance issues

**Notes:**

Talk to the slide.

## Pilot Test Objectives

- Evaluation & Feedback
- Usability
- Transparency
- Consistency
- Do the input factors make sense ?
- Does the weighting & scoring work well?
- Do the output factors make sense ?

**Notes:**

Talk to the slide

## Pilot Test Objectives

- Reality checks based on site-specific data & evaluations from project teams
- Modifications to framework
- Identification of issues for guidance development

**Notes:**

Talk to the slide

## Emerging Issues for Guidance Document

- Clear instructions on use of MEC HA needed
- Sufficiency & quality of data
- Emphasis on collaborative decision-making
- Use of MEC HA to support NOFA

**Notes:**

Talk to the slide

## Emerging Issues for Guidance Document

- Should Construction Support be included in MEC HA scoring?
- Activity (intrusiveness) has greater emphasis than land use category
- Scores are relative
- Output category descriptions qualitative
- Framework is biased to cleanup over changes in access, activities

**Notes:**

Talk to the slide

## Questions ?

- Kevin Oates
- 334-270-3427
- oates.kevin@epa.gov

**Notes:**

Has this presentation answered any questions you had before listening to this ?

Is the MEC HA TWG on the right track ?

Feedback on the presentation itself.