EP 75-1-3 

30 November 2004 

RECOVERED CHEMICAL WARFARE 

MATERIEL (RCWM) RESPONSE PROCESS 

ENGINEER PAMPHLET 

“Approved for public release; distribution is unlimited.” 
EP 75-1-3 

30 Nov 04 

 

AVAILABILITY 

Electronic copies of this and other U.S. Army Corps of Engineers publications are available 

on the Internet at http://www.hnd.usace.army.mil/techinfo/engpubs.htm. This site is the only 

repository for all official USACE engineer regulations, circulars, manuals, and other 

documents originating from HQUSACE. Publications are provided in portable document 

format (PDF). 

 i 

 DEPARTMENT OF THE ARMY EP 75-1-3 

 U.S. Army Corps of Engineers 

CECW-ET Washington, DC 20314-1000 

Pamphlet 30 November 2004 

No. 75-1-3 

Explosives 

RECOVERED CHEMICAL WARFARE MATERIEL RESPONSE PROCESS 

TABLE OF CONTENTS 

 Paragraph Page

Chapter 1. Introduction 

Policy ........................................................................ 1-1 1-1 

RCWM Response Action Overview......................... 1-2 1-1 

RCWM Response Regulatory Authorities................ 1-3 1-2 

Technical Project Planning (TPP)............................. 1-4 1-2 

Chapter 2. Responsibilities 

Introduction............................................................... 2-1 2-1 

General Responsibilities ........................................... 2-2 2-1 

Functional Roles ....................................................... 2-3 2-2 

Other Stakeholders’ Roles ........................................ 2-4 2-13 

Chapter 3. Response Action Execution 

Introduction............................................................... 3-1 3-1 

Property Management............................................... 3-2 3-1 

Quality Management................................................. 3-3 3-2 

Public Participation................................................... 3-4 3-2 

Coordination with Regulators................................... 3-5 3-2 

Environmental Considerations.................................. 3-6 3-2 

Geophysical Considerations...................................... 3-7 3-13 

Location Surveying and Mapping............................. 3-8 3-13 

GIS ............................................................................ 3-9 3-13 

Sampling and Analysis Considerations ................... 3-10 3-13 

Innovative Technologies in RCWM Response 

Actions.................................................................... 3-11 3-13 
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TABLE OF CONTENTS (Continued) 

 Paragraph Page

Chapter 4. RCWM Response Action Overview 

Introduction............................................................... 4-1 4-1 

Documents and Procedures Required on Suspect 

RCWM Sites............................................................ 4-2 4-1 

Types of Response Actions....................................... 4-3 4-9 

Chapter 5. Site Characterization Activities 

Introduction............................................................... 5-1 5-1 

Site Characterization Planning and Coordination..... 5-2 5-1 

Site Characterization for RCWM Projects................ 5-3 5-4 

Engineering and Operational Controls...................... 5-4 5-8 

Environmental Sampling and Analysis..................... 5-5 5-9 

Institutional Analysis ................................................ 5-6 5-9 

Risk Characterization................................................ 5-7 5-10 

Development and Evaluation of Response Action 

Alternatives.............................................................. 5-8 5-10 

RI Report or EE/CA Report...................................... 5-9 5-11 

RI or EE/CA Public Participation and Approval 

Process.................................................................... 5-10 5-12 

Action Memorandum/DD/ROD............................... 5-11 5-12 

Chapter 6. RCWM Detection, Response, and Completion 

Introduction............................................................... 6-1 6-1 

Response Design....................................................... 6-2 6-1 

RCWM Detection and Removal ............................... 6-3 6-3 

Project Completion ................................................... 6-4 6-8 

Operations and Maintenance (O&M) ....................... 6-5 6-9 
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TABLE OF CONTENTS (Continued) 

 Paragraph Page

Chapter 7. RCWM Response Action Plans 

Introduction............................................................... 7-1 7-1 

Contents .................................................................... 7-2 7-1 

Review and Approval ............................................... 7-3 7-9 

Amendments ............................................................. 7-4 7-9 

Corrections................................................................ 7-5 7-9 

Chapter 8. Safety and Health Considerations 

Introduction............................................................... 8-1 8-1 

Policy ........................................................................ 8-2 8-1 

Staff Organization, Qualifications, and 

Responsibilities........................................................ 8-3 8-2 

Site Description and Contamination 

Characterization....................................................... 8-4 8-3 

Hazard Analyses and Risk Assessment .................... 8-5 8-3 

Training..................................................................... 8-6 8-4 

Team Training and Pre-Start Exercises ................... 8-7 8-6 

Personal Protective Equipment................................. 8-8 8-7 

Medical Support........................................................ 8-9 8-9 

UXO Safety.............................................................. 8-10 8-10 

Radiation Dosimetry ................................................ 8-11 8-10 

Environmental and Personal Monitoring................. 8-12 8-11 

Site Control .............................................................. 8-13 8-12 

Personnel and Equipment Decontamination............ 8-14 8-12 

Emergency Response and Contingency 

Procedures (On-site and Off-site)........................... 8-15 8-14 

Confined Space Entry .............................................. 8-16 8-15 

Spill Containment .................................................... 8-17 8-15 

Heat/Cold Stress Monitoring .................................. 8-18 8-15 
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TABLE OF CONTENTS (Continued) 

 Paragraph Page

Chapter 8. Safety and Health Considerations (continued) 

Standard Operating Procedures, Engineering 

Controls and Work Practices.................................. 8-19 8-15 

Accident Prevention................................................. 8-20 8-16 

Emergency Equipment and First Aid 

Requirements.......................................................... 8-21 8-16 

Logs, Reports, and Record Keeping ........................ 8-22 8-16 

Chapter 9. Environmental Sampling and Analysis 

Introduction............................................................... 9-1 9-1 

Contaminants of Potential Concern (COPCs)........... 9-2 9-1 

Agent/ABP Sampling and Analysis Support ............ 9-3 9-1 

Air Monitoring ......................................................... 9-4 9-3 

Environmental Sampling .......................................... 9-5 9-8 

Chapter 10. Investigation Derived Waste 

Introduction.............................................................. 10-1 10-1 

Soil ........................................................................... 10-2 10-1 

Liquid Waste............................................................ 10-3 10-4 

Solid Waste .............................................................. 10-4 10-5 

Personnel Protective Equipment.............................. 10-5 10-6 

Equipment Disposition............................................. 10-6 10-6 

IDW Plan ................................................................. 10-7 10-6 

Manifesting Requirements....................................... 10-8 10-9 

Government Responsibilities................................... 10-9 10-9 

Chapter 11. Interim Holding Facility 

Introduction.............................................................. 11-1 11-1 

IHF Regulatory Requirements ................................. 11-2 11-1 

Organizational Responsibilities ............................... 11-3 11-2 
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TABLE OF CONTENTS (Continued) 

 Paragraph Page

Chapter 11. Interim Holding Facility (continued) 

Design Requirements............................................... 11-4 11-4 

IHF Siting Plan ........................................................ 11-5 11-4 

Physical Security Plan.............................................. 11-6 11-6 

Industrial Chemicals ................................................ 11-7 11-11 

Chapter 12. Transportation of Recovered Chemical Warfare 

Material 

Introduction.............................................................. 12-1 12-1 

Transportation Regulatory Requirements................ 12-2 12-1 

Organizational Responsibilities ............................... 12-3 12-1 

IHF Plan................................................................... 12-4 12-4 

Transportation Plan.................................................. 12-5 12-4 

Destruction Plan....................................................... 12-6 12-4 

Appendix A – References A-1 

Appendix B – Chemical Event Reporting B-1 

Appendix C – Chemical Safety Submission Outline C-1 

Appendix D – Pre-Operational Surveys D-1 

Appendix E – Generic Approval Letter E-1 

Appendix F – Soil And Bulk Item Headspace Analysis Procedures F-1 

Appendix G – Physical Security Plan Outline G-1 

Appendix H – Delegation of Authority for the Conduct of Pre-Operational Surveys H-1 

Glossary Glossary-1 
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CHAPTER 1 

Introduction 

1-1. Policy. The policy of the United States Army Corps of Engineers (USACE) is to plan 

and execute Recovered Chemical Warfare Materiel (RCWM) response actions in compliance 

with the Comprehensive Environmental Response, Compensation, and Liability Act 

(CERCLA), the National Oil and Hazardous Substance Pollution Contingency Plan (NCP), 

and all other applicable laws and regulations, and to fully meet expectations for quality, 

timeliness, and cost effectiveness. An acceptable level of quality does not imply perfection; 

however, there will be no compromise of functional, health, or safety requirements. 

Adherence to the Quality Management principles outlined in ER 5-1-11 and ER 1110-1-12 

will contribute to achieving this goal. RCWM response procedures must be formulated to 

ensure harmony with the USACE Strategic Vision and will be executed in concert with 

activities presented in other USACE guidance. 

1-2. RCWM Response Action Overview. 

a. Description of the RCWM Response Process. 

(1) RCWM response activities include actions taken to reduce the risk to human health 

and the environment from exposure to RCWM resulting from past Department of Defense 

(DOD) operations at a site. The discussions in this pamphlet apply to all activities at RCWM 

sites. 

(2) A large part of the RCWM response process uses the same procedures required for 

munitions response to Munitions and Explosives of Concern (MEC). Therefore, RCWM 

response actions are conducted in accordance with (IAW) the same procedures used for 

munitions response actions to MEC. This Engineer Pamphlet (EP) discusses the procedures 

and requirements that are unique to RCWM actions. A reference will be provided to 

EP 1110-1-18 for procedures and requirements that are applicable to RCWM but are identical 

to the requirements for MEC. 

b. RCWM Response Actions at Formerly Used Defense Sites (FUDS) and Active and 

Transferring Installations. A discussion of the requirements for conducting RCWM response 

actions at FUDS and Active and Transferring Installations is provided in ER 200-3-1. 
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c. Execution of RCWM Response Actions. IAW ER 1110-1-8153, the U.S. Army 

Engineering and Support Center, Huntsville (USAESCH) is the only USACE command 

authorized to execute RCWM response actions. If the presence of RCWM is suspected at a 

site, the Project Manager (PM) must coordinate with the USAESCH prior to beginning any 

on-site activities. 

1-3. RCWM Response Regulatory Authorities. 

a. A discussion of the governing laws and regulations for any specific RCWM 

response project is provided in ER 200-3-1 and EP 1110-1-18. The discussion in these 

documents provides an overview of the legal authorities for conducting a RCWM response 

action, including CERCLA, NCP, the Defense Environmental Restoration Program (DERP), 

which includes the FUDS program and the Installation Restoration Program (IRP). The 

discussion in these documents also addresses the Base Realignment and Closure (BRAC) 

program, Resource Conservation and Recovery Act (RCRA), Environmental Protection 

Agency (EPA) Military Munitions Rule, and Applicable or Relevant and Appropriate 

Requirements (ARARs). The Office of Counsel will be consulted to determine the 

appropriate legal requirements for the site being addressed. 

b. The responsibilities detailed herein are FUDS-specific. Environmental restoration 

actions necessary at FUDS that are adjacent to and independent from an active DOD 

installation will be the responsibility of the USACE. Before the USACE begins those 

environmental restoration activities, the DOD component controlling the active installation 

retains the “right of first refusal” to accept the restoration responsibility. Once accepted, the 

DOD component will execute all appropriate actions, as required. If the DOD component 

does not exercise its right of first refusal, the USACE will proceed to execute FUDS 

responsibilities at the property. Only the USAESCH Chemical Weapons Design Center (CWDC) is authorized to execute any phase of a RCWM response action. 

1-4. Technical Project Planning (TPP). During RCWM response actions, members of the 

Project Delivery Team (PDT) implement the TPP process. In summary, the TPP process is a 

four phased approach involving a series of meetings during which the project goals and 

objectives, project data needs and data collection methods, and data quality objectives 

(DQOs) are discussed and agreed upon. The results of these meetings are recorded in a living 

document that is constantly updated based on the investigation’s findings. Appropriate 
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implementation of the TPP process ensures that all PDT members, including stakeholders, 

understand and agree upon the project’s objectives, and that they also all concur with what is 

required to achieve project completion. The TPP process is performed IAW EM 200-1-2, 

which describes the TPP process in detail and provides related documentation tools. 
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CHAPTER 2 

Responsibilities 

2-1. Introduction. 

a. This chapter describes the responsibilities and functional roles of the USACE 

organizations and potential stakeholders in the RCWM response process. 

b. Munitions response actions at RCWM sites will be performed IAW ER 1110-1-

8153. The USACE is responsible for the overall project management and on-site supervision 

for RCWM response actions. Execution of all phases of a RCWM response action within the 

USACE is the responsibility of the CW-DC. ER 200-3-1 and ER 1110-1-8153 provides 

responsibility matrices delineating organizational responsibilities throughout the process. 

c. Throughout this document, District review and approval responsibilities for project 

activities are discussed. These responsibilities have been delegated by the Major Subordinate 

Command (MSC) to the assigned District within their geographic area. 

d. Districts requiring additional information beyond that discussed in this document 

should contact the USAESCH Military Munitions Mandatory Center of Expertise (MM CX), 

2-2. General Responsibilities. 

a. The Headquarters, United States Army Corps of Engineers (HQUSACE), MSCs, the 

District, and the MM CX all have the responsibility for quality and process improvement as 

described in ER 5-1-11. MSC Commanders are assigned overall responsibility for the overall 

project management of all RCWM response actions for all projects at which they are the PM, 

IAW ER 5-1-11. 

b. The responsibilities of HQUSACE for planning and executing a RCWM response 

action are discussed in ER 1110-1-8153, ER-200-3-1, and EP 1110-1-18. 

c. It is the responsibility of all USACE personnel involved with RCWM response 

actions to execute safely those actions IAW applicable laws, regulations, and policies. All 

USACE organizations will ensure that all personnel involved with on-site activities are 

familiar with and have access to copies of the approved Chemical Safety Submission (CSS) 

and Work Plan prepared for the site-specific activities to be conducted. In addition, each 
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organization will ensure that such personnel have received appropriate training, medical 

surveillance, and personal protective equipment (PPE) required by the safety plan, contract 

specifications, Occupational Safety and Health Administration (OSHA) Standards, USACE 

regulations, and applicable DOD and Department of the Army (DA) regulations. 

d. All USACE elements will ensure that RCWM response actions include provisions 

for meaningful stakeholder involvement pursuant to all applicable laws, regulations, and 

policies. 

2-3. Functional Roles. The following section provides a general description of key 

functional roles in the RCWM response process. The functional roles for non-USACE 

agencies have been extracted from their respective guidance documents. 

a. USACE. The following paragraphs describe the functional roles of USACE with 

respect to the HQ, Safety and Occupational Health Office, the USACE District, the 

USAESCH CW-DC, USAESCH MM CX, the Ordnance and Explosives (OE) Safety 

Specialist, the Construction Division, the Office of Counsel (OC), the Directorate of Real 

Estate, the Public Affairs Office (PAO), and the Hazardous, Toxic, and Radioactive Waste 

(HTRW) CX. Other functional areas for USACE are identified in ER 200-3-1. 

(1) HQ, Safety and Occupational Health Office. The Corps of Engineers Safety Office 

(CESO) has responsibilities that include safety and occupational health and other supporting 

issues related to the proper implementation and execution of the MEC program activities 

under USACE management (such as DERP, BRAC, range clearance, etc.). CESO is the 

HQUSACE Point of Contact (POC) for the MEC safety and occupational health program and 

will: 

(a) Oversee the safety and occupational health program and policy issues within the 

USACE MEC Program. 

(b) Coordinate the MEC safety and occupational health program and health policy 

issues with higher headquarters and DOD elements. 

(c) CESO has delegated the authority to USAESCH for the Major Command 

(MACOM) approval for Explosives Safety Submissions (ESSs) and CSSs. 

(d) Review, approve, and disseminate safety and occupational health technical guidance 

developed by the MM CX or others. 
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(e) CESO has delegated the authority to USAESCH to conduct the MACOM preoperational survey required by DA Pam 385-61 as a precursor to the start-up of chemical 

operations at any USACE RCWM response action (see Appendix H). 

(2) USACE District. 

(a) As delegated by the MSC, the USACE District will assign a PM to lead the RCWM 

PDT, coordinate all project activities, serve as a liaison with other stakeholders, and 

review/approve documents as required. This PM will manage RCWM response actions IAW 

ER 5-1-11. 

(b) The MSC may assign support functions to the USACE District during a RCWM 

response action. The District may perform these functions or further delegate them to 

USAESCH. Examples of these responsibilities include: 

• Prepare the Probability Assessment for the determination of applicability of the 

Interim Guidance for CWM/Biological Warfare Material (BWM) (as necessary). 

• Prepare Work Plans. 

• Provide site construction support. 

• Provide site security. 

• Provide cultural resources support. 

• Acquire rights-of-entry (ROEs). 

• Provide medical support and training. 

• Establish and maintain the Administrative Record. 

• Prepare the Public Evacuation or Shelter-in-Place Plan, as necessary. 

• Provide on-site support for coordination with local stakeholders. 

• Prepare the Memorandum of Agreement with local support agencies, as necessary. 
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• Prepare Remedial Investigation/Feasibility Study (RI/FS) reports or Engineering 

Evaluation/Cost Analysis (EE/CA) reports, as required. 

• Coordinate the Action Memorandum/Decision Document (DD)/Record of Decision 

(ROD), as necessary. 

(3) USAESCH CW-DC. 

(a) CW-DC POC. The CW-DC POC is the central figure responsible for coordination 

of the CW-DC functions for the RCWM response action, and acts as the liaison between the 

CW-DC and the PM. The CW-DC POC will ensure continuing and timely coordination with 

the PM regarding progression of activities at a project, as well as providing all necessary 

documents and information to the PM to maintain the administrative record. Further 

information on the responsibilities of the CW-DC POC is presented in ER 1110-1-8153. 

(b) Engineering Support. The USAESCH CW-DC provides multi-discipline 

engineering support to the RCWM PDT. Engineering support during RCWM response 

actions may include, but is not limited to, the following: 

• Engineering design of structures, facilities, and excavations. 

• Blast effects analysis. 

• Surveying. 

• Geographic information systems. 

• Geophysical investigations. 

• Soil sampling and analysis. 

• Systems safety. 

• Development of Maximum Credible Event (MCE) and calculation of exclusion 

zones (EZs). 

• Planning. 

• Preparation of technical Statements of Work (SOWs). 
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• Cost estimating and contract negotiation support. 

• Review of Work Plans and CSSs. 

• Coordination of technical issues. 

• Other efforts requiring engineering and technical expertise contained within the 

USAESCH CW-DC. 

(c) Contracting. The USAESCH CW-DC will perform all contracting actions for 

RCWM sites. Responsibilities include: 

• Assure all RCWM-related Requests for Proposal (RFPs), Commerce Business Daily 

(CBD) announcements, new contracts, SOWs, and delivery orders have been 

reviewed by the appropriate PDT members prior to issuing/awarding. 

• Assure an interdisciplinary, structured proposal evaluation team, including an OE 

Safety Specialist for all RCWM-related contracts. 

• Assure current Data Item Descriptions (DIDs) are used in all RCWM-related 

contracts. Current DIDs are available on the MM CX website at 

http://www.hnd.usace.army.mil/oew/didsindex.asp. 

• Plan, direct, coordinate, and accomplish actions required to select, negotiate, award, 

administer, modify, and terminate contracts for RCWM projects. 

• Appoint a Contracting Officer’s Representative (COR) when applicable. The 

Contracting Officer (CO) is the only person with the authority to enter into, 

administer, or terminate contracts. The CO and the officially designated COR may 

bind the government only to the extent of the authority delegated to them. 

Regardless of the exigencies of the site, the CO/COR are the only individuals who 

can “direct” a contractor to perform work, and then only within the limits of 

delegated authority. 

(d) Chemical Event Reporting. The CW-DC will prepare and submit Chemical Event 

Reports (CERs) IAW Army Regulation (AR) 50-6 and USACE Interim Guidance – 

Notification Procedures for Discovery of Recovered Chemical Warfare Materiel (RCWM) 

During USACE Projects, 23 Apr 04 (see Appendix B). 
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(e) Manifesting. The CW-DC will ensure that manifest documents (when required) are 

properly prepared and signed by the appropriate personnel IAW ER 200-3-1. 

(4) USAESCH MM CX. The USAESCH MM CX is located within the USAESCH 

Ordnance and Explosives Directorate. In addition to the responsibilities presented in 

ER 1110-1-8153, responsibilities of the MM CX include: 

(a) Review Work Plans and Site Safety and Health Plans (SSHPs). 

(b) Ensure that RCWM response actions are conducted IAW OSHA guidance; EM 385-

1-1 and ER 385-1-95, and the approved CSS and approved Work Plans. 

(c) Provide MACOM approval for CSSs per the delegation of authority from HQ, 

USACE – CESO (see Appendix H). 

(d) Execute the MACOM Pre-operation Survey for the Commander, USAESCH, as 

delegated by HQUSACE (see Appendix H). 

(e) Act as the MACOM representative at DA, DOD, and other agency working groups 

for RCWM issues and policies. 

(f) Develops policies and procedures for USACE relative to RCWM. 

(g) Review Federal, DOD, and DA regulations related to MEC and RCWM and propose 

implementation guidance to HQUSACE to ensure USACE compliance. 

(h) Review and approve RCWM and RCWM-related products IAW ER 1110-1-8153. 

(i) Provide technical support throughout USACE. 

(j) Review and evaluate RCWM detection and removal technology. 

(k) Develop RCWM-specific contract requirements and maintain current contract DIDs. 

(l) Assist HQUSACE in identifying RCWM program training requirements. 

(m) Evaluate security concerns at RCWM projects and assist in the preparation of 

physical security plans and focused vulnerability assessments. 
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(5) OE Safety Specialist. The OE Safety Specialist for RCWM response actions is 

located within the USAESCH Ordnance and Explosives Directorate. Responsibilities of the 

OE Safety Specialist include: 

(a) Provide on-site safety and health support for RCWM activities. 

(b) Review the Archives Search Report (ASR), delivery orders, SOW, Work Plan, and 

CSS. 

(c) Verify unexploded ordnance (UXO) qualifications of contractor employees. 

(d) Verify training and physical examination records. 

(e) Advise the contractor on RCWM procedures. 

(f) Coordinate EZ activities with on-site agencies. 

(g) Facilitate military Explosive Ordnance Disposal (EOD) response, when needed. 

(h) Provide technical safety support to USACE districts and contractors. 

(i) Conduct government quality assurance (QA) inspections of completed work. 

(j) Assist in preparation of CERs on-site, when necessary. 

(6) Construction Division. The District Construction Division may oversee field 

activities outside of the EZ; administers construction contracts; provides administration 

support; and may be assigned as the COR on a case-by-case basis. 

(7) OC. The District OC renders legal assistance to the RCWM PDT. The OC provides 

legal interpretation and advice on applicability of environmental statutes and regulatory 

requirements, contract acquisition and claim issues, including review for legal sufficiency of 

all associated settlement agreements and environmental restoration decision documents. Due 

to the nature of RCWM response actions, the OC will be consulted on all matters involving 

questions of regulatory or statutory authority or requirements. The OC supporting the MM 

CX is available to the RCWM PDT for consultation. 
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(8) Directorate of Real Estate. The District Directorate of Real Estate performs real 

estate functions to support a RCWM response action, such as obtaining ROEs, reviewing 

deed restrictions, and preparing real property transfer documents. 

(9) PAO. The District PAO provides for planning, developing, and managing public 

involvement and media relations for RCWM response projects. PAO personnel will 

coordinate with the CW-DC personnel prior to discussing any specific RCWM-related matters 

and the District PAO shall contact the CW-DC and PAO to coordinate the RCWM technical 

content prior to release. 

(10) HTRW CX. The HTRW CX provides safety and occupational health technical 

expertise for chemical contaminants that are not chemical agent, and provides environmental 

science and engineering technical expertise concerning the HTRW aspects of RCWM 

response actions. Safety and occupational health roles and responsibilities of the HTRW-CX 

are described in more detail in ER 385-1-92. 

b. Assistant Secretary of the Army (Installation and Environment) [ASA (I&E)]. The 

ASA (I&E) is responsible for establishing overall Army environmental, safety, and 

occupational health statutory compliance. These responsibilities are carried out through the 

Deputy Assistant Secretary of the Army (Environment, Safety, and Occupational Health). 

c. Director of Army Safety, Office of the Chief of Staff, U.S. Army. The Director of 

Army Safety, Office of the Chief of Staff administers and directs the Army Safety program as 

specified in AR 385-10. Responsibilities include: 

(1) Establish safety policy and standards for the Army chemical safety program for 

investigation of chemical defense research, development, testing, and evaluation events. 

(2) Coordinate and approve safety waivers and exemptions to personnel safety policies. 

(3) Approve CSSs for RCWM activities. 

d. U.S. Army Technical Center for Explosives Safety (USATCES). USATCES is 

responsible for reviewing CSSs for DA Safety and forwarding to Department of Defense 

Explosives Safety Board (DDESB) for approval or concurrence as appropriate. USATCES 

will be invited to participate as a survey team member on all USACE Pre-Operational 

Surveys as an agent for DA Safety. 
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e. DDESB. Responsible for approving or concurring with CSSs, as appropriate. For 

FUDS projects, DDESB concurrence is necessary for the CSS; for all other projects, DDESB 

approval of the CSS is necessary. 

f. Army Operations Center (AOC). Responsibilities of the AOC include: 

(1) Receive notification of RCWM discoveries and events. 

(2) Notify Army staff elements of RCWM discoveries and events. 

(3) Coordinate emergency response to RCWM discoveries and events. 

g. Program Manager for the Elimination of Chemical Weapons (PMECW). The U.S. 

Army PMECW—instituted as DOD’s executive agent for demilitarization of U.S. chemical 

warfare-related materiel—subsequently created the Office of the Product Manager for NonStockpile Chemical Materiel (PMNSCM) to carry out this effort. The Non-Stockpile 

Chemical Materiel Project (NSCMP) is the DOD umbrella organization that is responsible for 

the destruction of RCWM on military installations and FUDS. 

h. PMNSCM. Within the PMECW, the PMNSCM has the following responsibilities: 

(1) Provide centralized management and direction to the DOD for treatment and 

disposal of non-stockpile chemical materiel in a safe, environmentally sound, and costeffective manner. 

(2) Prepare for shipment, certify, transport, treat, and dispose of RCWM (including 

preparation of necessary documentation). 

(3) In coordination with USAESCH, prepare transportation, Interim Holding Facility 

(IHF), and disposal plans for the RCWM project and provide coordination of all 

transportation plans with the U.S. Department of Health and Human Services (DHHS). 

PMNSCM will usually contract with Technical Escort Unit (TEU) to perform the majority of 

the activities required by these plans. USAESCH will be responsible for some of the 

requirements of these plans such as site security and site preparation for the IHF. 

i. U.S. Army Research, Development, and Engineering Command (RDECOM). 

(1) Surgeon. The RDECOM Surgeon acts as a consultant to the USAESCH for RCWM 

projects. Regulations require medical support requirements be reviewed by the MACOM 
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surgeon and because USACE has no medical assets, the RDECOM Surgeon is consulted. 

Liaison with the surgeon is through the USAESCH Safety Office. 

(2) Edgewood Chemical and Biological Center (ECBC). Responsibilities of ECBC on a 

RCWM site may include but are not limited to: 

(a) Conduct air monitoring for chemical agent as tasked by USAESCH. 

(b) Conduct agent and agent degradation product analyses as tasked by USAESCH. 

(c) Sample unknowns that are munitions with unknown fillers, as necessary. 

(d) May support USACE to maintain any filter units for vapor containment as tasked by 

USAESCH. 

(e) Prepare the monitoring and analysis plans to be included in the Work Plan. The 

USAESCH contractor is required to summarize these monitoring and analysis plans in the 

CSS and/or SSHP. 

j. Technical Escort Unit (TEU). The TEU is a part of the U.S. Army Guardian 

Brigade. Responsibilities of the TEU on a RCWM site include: 

(1) Conduct on-site assessment of RCWM recovered during the RCWM response action 

IAW AR 50-6. 

(2) Perform on-site air monitoring utilizing the Miniature Chemical Agent Monitoring 

System (MINICAMS), if required during an emergency response or requested by the 

customer during response actions. 

(3) Conduct other on-site activities as tasked by USAESCH (e.g., D2PC [Downwind 

Hazard Prediction Model] modeling, emergency response, anomaly excavation). 

(4) Package and transport recovered RCWM as tasked by PMNSCM. 

(5) Conduct emergency destruction of RCWM munitions on-site as necessary. 

(6) Additional information is provided in 1 April 1997 Memorandum of Agreement 

between the 52nd Ordnance Group (EOD) and USAESCH. 
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k. Department of the Army Chemical Agent Safety Council (DACASC). 

Responsibilities include: 

(1) Serve as an open forum to evaluate, discuss, and coordinate chemical agent safety 

and health issues at the Headquarters Department of the Army (HQDA) level. 

(2) Research and develop chemical agent safety policy recommendations for the 

Director of Army Safety (DASAF) and chemical agent safety issues as requested by Army 

leadership. 

(3) Assess the safety and health of the chemical agent stockpile and disposal (stockpile 

and non-stockpile) programs. 

(4) Evaluate and recommend Army approval of alternate chemical protective equipment 

and clothing, chemical agent monitoring equipment, and requirements and procedures for 

chemical agent decontamination and disposal. 

l. Materiel Assessment Review Board (MARB). The MARB was established under 

the authority and direction of the Deputy Chief of Staff for Chemical and Biological Matters, 

AMC. The board is chaired by the Commander, TEU with membership selected from the 

explosives ordnance community, the chemical weapons research and development 

community, PMNSCM, and a historian from RDECOM. USAESCH has two non-voting 

members on the MARB. Responsibilities of the MARB on a RCWM site include: 

(1) Evaluate recovered munitions suspected of containing lethal chemical agent using 

all available documentation, pictures, x-rays, drawings, physical data, Portable Isotopic 

Neutron Spectroscopy (PINS) data and expertise of each member of the MARB. 

(2) Provide recommendations on the disposition of such materiel/munitions through a 

record of determination and decision for each materiel/munition. This record of 

determination and decision is forwarded to the Commander of the concerned installation or 

USACE District from the RDECOM Commander. If a consensus regarding disposition of a 

materiel/munition is not achievable, the MARB will determine the need for further 

information and delay action until such information is available. 

m. Office of the Surgeon General (OSG). The OSG, through the U.S. Army Center for 

Health Promotion and Preventive Medicine (USACHPPM), has the following responsibilities: 
EP 75-1-3 

30 Nov 04 

 2-12 

(1) Provide policy on the health aspects of pollution resulting from Army activities and 

operations. 

(2) Provide guidance, including educational materials on environmental health aspects, 

recommendations to mitigate or control adverse impacts and to protect individuals from 

hazardous exposure, and health risk assessments for environmental restoration. 

(3) Develop toxicological profiles concerning military-unique chemicals and 

unregulated hazardous substances (i.e., those not specified in 10 USC 2704a). 

(4) Establish environmental standards for chemical agents and weapons 

demilitarization. 

(5) Develop and prepare chemical exposure and drinking water criteria for 

environmental contaminants (in particular, military-unique compounds) for ASA(I&E) 

promulgation. 

(6) Conduct toxicity studies and develop health advisories and standards, criteria, and 

protocols for chemical exposure and drinking water. 

(7) Approve health risk assessments. 

(8) Establish public health criteria and standards for Army use. 

(9) Recommend standards for the safe storage, use, discharge, and ultimate disposal of 

hazardous materials and, in the absence of environmental and public health effects criteria, 

develop, compile, and evaluate environmental toxicology data. 

(10) Monitor the public health and environmental aspects of the Army’s waste 

management programs. 

(11) Advise USACE on the health aspects of managing hazardous and solid waste. 

n. U.S. Department of Health and Human Services (DHHS). The DHHS is required by 

Public Law 91-441 to provide concurrence for plans related to the transport or disposal of 

lethal chemical warfare agent(s). Therefore, once the CSS is approved by Department of the 

Army, Office of the Chief of Staff (DACS-SF) it will be forwarded to DHHS by PMNSCM. 
EP 75-1-3 

30 Nov 04 

 2-13 

2-4. Other Stakeholders’ Roles. Stakeholders will stakeholders will be given opportunity to 

participate actively in the RCWM response process, as required by CERCLA and the NCP. 

Stakeholders typically include: private landowners; Federal land managers; Indian Tribal 

Governments; Restoration Advisory Boards; and Federal, state, and local regulators. A 

description of the roles of these stakeholders is presented in EP 1110-1-18. The requirements 

concerning stakeholder involvement are provided in ER 200-3-1 and additional information is 

in EP 1110-3-8. 
EP 75-1-3 

30 Nov 04 

 3-1 

CHAPTER 3 

Response Action Execution 

3-1. Introduction. 

a. This chapter discusses the requirements for USACE elements involved at RCWM 

response projects. Several requirements for RCWM response actions are identical to those for 

munitions response to MEC. These requirements include: business management practices; 

project prioritization; the PDT approach; project management plans; scheduling; project 

funding; reporting requirements; contracting; estimating; and real estate activities. 

b. Project Management for RCWM projects will be implemented IAW ER 5-1-11. 

3-2. Property Management. As a general policy, contractors are normally required to furnish 

all equipment and materials necessary to perform their contract tasks. However, when 

deemed to be in the best interest of the government, equipment/materials (e.g., vehicles, 

engineering controls, explosives, magnetometers, etc.) may be provided to the contractor by 

the government. 

a. There is some Government Furnished Property (GFP) available for use at RCWM 

projects. This equipment has been used at past RCWM projects and has been contaminated 

with chemical agents. It has been properly decontaminated and the agent is no longer 

detectable at the action levels and is categorized as 3X. This category of equipment must 

remain under government control. This equipment can be used at future RCWM projects by 

government contractors with the proper procedures in place. The intent of using these pieces 

of equipment in lieu of buying or leasing new equipment is financial efficiency. If any of this 

category of GFP is necessary at the RCWM project, coordination will be accomplished 

between USAESCH, the contractor, and the supporting agency. 

b. If GFP is not provided but the contract requires specialized equipment or materials 

that are not included in the contractor’s overhead rate, procurement or lease may be 

authorized. In all cases, property management will comply with the Federal Acquisition 

Regulation (FAR), other applicable DOD and DA policies, and with the internal policies of 

the USACE District or USAESCH CW-DC, as appropriate. 
EP 75-1-3 

30 Nov 04 

 3-2 

c. Additional information on property management is provided in EP 1110-1-18. 

Topics discussed include: GFP provided to the contractor, acquisition planning, acquisitions, 

property management plan, and contract surveillance. 

3-3. Quality Management. Quality assurance (QA) and quality control (QC) requirements 

are discussed in EP 1110-1-18, EM 200-1-6, and EM 1110-1-4009. 

3-4. Public Participation. Public participation is an integral component of the RCWM 

response process. The USACE is committed to providing public participation activities 

during RCWM response actions. The requirements for public participation during a RCWM 

response action are presented in ER 200-3-1 and additional information is in EP 1110-3-8. 

3-5. Coordination with Regulators. USACE is required to coordinate with the appropriate 

regulatory agencies throughout the RCWM response process. The requirements for 

regulatory coordination during a RCWM response action, including identification of the lead 

regulator, are presented in ER 200-3-1. 

3-6. Environmental Considerations. 

a. The District, in consultation with their Office of Counsel (OC) and the OC 

supporting the MM CX, as required, is the lead USACE agency on environmental issues 

related to RCWM response actions and is responsible for coordinating with regulators on 

these issues. Environmental issues will be addressed in project work plans prior to the 

commencement of fieldwork. 

b. RCWM response actions must be conducted consistent with CERCLA and the NCP. 

There are some unique Federal requirements that may apply to RCWM actions, as well as 

some state considerations. The District must ensure that it has evaluated the applicable 

requirements and addressed those that are specific to that particular site. The impact of these 

regulations will not be the same at each site due to differences in site geography and 

differences among state/local regulations, for example. Vigilance must be constantly 

exercised to ensure that applicable changes in Federal, state, or local regulations are 

addressed. Additional information on Federal statutes and regulations, state laws and 

regulations, and local regulations is presented in ER 200-3-1. 

c. Table 3.1 presents a selection of DOD directives, instructions, and regulations 

relevant to the environmental aspects of RCWM response actions. This table is not allinclusive but may be used, in consultation with the OC, to assist with the determination of 

applicable environmental requirements for a specific project. 
EP 75-1-3 

30 Nov 04 

 3-3 

Table 3.1 

Directives, Instructions and Regulations for RCWM Response Actions 

Directive/Regulation Title Contents/Regulations Applicable

(Y/N) 

29 CFR 1910 Labor Describes labor specific requirements 

for working on potentially 

contaminated sites that may involve 

employee exposure or the reasonable 

possibility for employee exposure to 

safety or health hazards. 

29 CFR 1926 Construction Describes Safety and Health 

regulations for Construction activities 

DOD 6055.9-STD Ammunition and 

Explosives Safety 

Standards 

Primary DOD regulation that requires 

unexploded ordnance cleanup of 

DOD lands prior to transfer. 

DOD Directive 1000.3 Safety and 

Occupational 

Health Policy for 

the Department of 

Defense 

Establishes the basis for all DOD 

safety, fire protection, and 

occupational health programs 

DOD Directive 

4165.60 

Solid Waste 

ManagementCollection, 

Disposal, 

Resource 

Recovery and 

Recycling 

Program 

Sets DOD policy and procedures for 

the DOD comprehensive program of 

solid waste collection, disposal, 

material recovery, and recycling IAW 

USEPA guidelines, NEPA, and 

RCRA. 

DOD Directive 4500.9 Transportation and 

Traffic 

Management 

Describes general DOD transportation 

and traffic management policies. 

DOD Directive 4700.4 Natural Resource 

Management 

Program 

Sets DOD policy for management and 

protection of natural resources. 
EP 75-1-3 

30 Nov 04 

 3-4 

Table 3.1 (continued) 

Directives, Instructions and Regulations for RCWM Response Actions 

Directive/Regulation Title Contents/Regulations Applicable

(Y/N) 

DOD Directive 4710.1 Archeological and 

Historical 

Resources 

Management 

Program 

Establishes DOD policies and 

procedures for protection and 

management of archeological and 

historical resources. 

AR 50-6 Chemical Surety Prescribes policies, procedures and 

responsibilities for the Army 

Chemical Surety Program. Chapter 

10, Recovered Chemical Warfare 

Materiel and Chapter 4, Chemical 

Accident or Incident Response and 

Assistance/Event Reporting, apply to 

RCWM sites. The rest of the chapters 

discuss chemical surety requirements 

which do not apply to non-stockpile 

RCWM sites. 

AR 190-11 Physical Security 

of Arms, 

Ammunition, and 

Explosives 

Prescribes standards and criteria for 

the physical security of sensitive 

conventional arms, ammunition, and 

explosives. 

AR 190-59 Chemical Agent 

Security Program 

Specifies criteria and standards for the 

storage, handling, and movement of 

chemical surety materiel. 

AR 200-1 Environmental 

Protection and 

Enhancement 

Prescribes Army policies, 

responsibilities, and procedures to 

protect and preserve the quality of the 

environment. 

AR 200-2 Environmental 

Effects of Army 

Actions 

Contains Army procedures for 

implementing National 

Environmental Policy Act (NEPA). 
EP 75-1-3 

30 Nov 04 

 3-5 

Table 3.1 (continued) 

Directives, Instructions and Regulations for RCWM Response Actions 

Directive/Regulation Title Contents/Regulations Applicable

(Y/N) 

AR 200-3 National 

Resources – Land, 

Forest, and 

Wildlife 

Management 

This regulation sets forth policy, 

procedures, and responsibilities for 

the conservation, management, and 

restoration of land and the associated 

natural resources, consistent with the 

military mission and in consonance 

with national policies. 

AR 200-4 Cultural 

Resources 

Management 

This regulation prescribes Army 

policies, procedures, and 

responsibilities for meeting cultural 

resources compliance and 

management requirements. 

AR 385-10 Army Safety 

Program 

This regulation provides DA policy, 

responsibilities, and procedures to 

protect and preserve personnel and 

property against accidental loss. It 

provides for public safety incident to 

Army operations and activities. This 

regulation assures statutory and 

regulatory compliance. This 

regulation also provides the risk 

assessment model for use on MEC 

sites. 

AR 385-61 The Army 

Chemical Agent 

Safety Program 

Provides policy on the management 

of the chemical agent safety program. 

It provides procedures for requesting 

waivers and exemptions to these 

standards. 
EP 75-1-3 

30 Nov 04 

 3-6 

Table 3.1 (continued) 

Directives, Instructions and Regulations for RCWM Response Actions 

Directive/Regulation Title Contents/Regulations Applicable

(Y/N) 

AR 385-64 U.S. Army 

Explosives Safety 

Program 

Provides protection guidance for sites 

involving MEC. It sets explosives 

safety standards to protect the public, 

the workforce and the environment. 

It is to be used with DA Pam 385-64. 

DA Pam 40-173 Occupational 

Health Guidelines 

for the Evaluation 

and Control of 

Occupational 

Exposure to 

Mustard Agents 

H, HD, and HT 

Explains medical occupational 

policies and provides procedures 

pertinent to mustard agents H, HD, 

and HT. The medical policies and 

procedures are prescribed in AR 50-6. 

DA Pam 40-8 Occupational 

Health Guidelines 

for the Evaluation 

and Control of 

Occupational 

Exposure to Nerve 

Agents GA, GB, 

GD, and VX 

Explains medical occupational 

policies and procedures pertinent to 

nerve agents GA, GB, GD, and VX. 

The medical policies and procedures 

have been aligned with AR 50-6. 

DA Pam 50-6 Chemical 

Accident or 

Incident Response 

and Assistance 

Operations 

Explains the policies and procedures 

prescribed for Chemical Accident or 

Incident Response and Assistance 

(CAIRA) operations in AR 50-6. 

Chapter 6 discusses the medical 

support requirements on RCWM 

sites, Chapter 11 discusses 

environmental monitoring, and 

Chapter 17 discusses training 

requirements (e.g., table top exercises 

and pre-operational surveys). 
EP 75-1-3 

30 Nov 04 

 3-7 

Table 3.1 (continued) 

Directives, Instructions and Regulations for RCWM Response Actions 

Directive/Regulation Title Contents/Regulations Applicable

(Y/N) 

DA Pam 200-1 Environmental 

Protection and 

Enhancement 

This pamphlet describes, in detail, 

DA procedures and methodology to 

be followed in preserving, protecting, 

and restoring environmental quality 

IAW AR 200-1. 

DA Pam 200-4 Cultural 

Resources 

Management 

This pamphlet Provides guidance for 

implementation of the Army’s policy 

as prescribed in AR 200-4 Cultural 

Resources Management. 

DA Pam 385-61 Toxic Chemical 

Agent Safety 

Standards 

Establishes the Army safety program 

for all aspects of military toxic 

chemical agents. Provides guidance 

on management of the toxic chemical 

agent safety program, as well as 

specific toxic chemical agent safety 

technical requirements. 

DA Pam 385-64 Ammunition and 

Explosives Safety 

Standards 

The purpose of pamphlet explains the 

Army’s safety criteria and standards 

for operations involving ammunition 

and explosives prescribed by AR 385-

64. 

ER 1110-1-263 Chemical Data 

Quality 

Management for 

Hazardous, Toxic, 

Radioactive Waste 

Remedial 

Activities 

This regulation prescribes chemical 

data quality management 

responsibilities and procedures for 

HTRW remedial activities. 
EP 75-1-3 

30 Nov 04 

 3-8 

Table 3.1 (continued) 

Directives, Instructions and Regulations for RCWM Response Actions 

Directive/Regulation Title Contents/Regulations Applicable

(Y/N) 

ER 1110-1-8153 Ordnance and 

Explosives 

Response 

Establishes roles and responsibilities 

for USACE elements in managing 

and executing munitions responses 

and authorizes and provides for the 

delegation of such roles and 

responsibilities. 

ER 200-3-1 Formerly Used 

Defense Sites 

(FUDS) Program 

Policy 

Provides guidance on FUDS 

eligibility, restoration response, 

potentially responsible party, internal 

procedures, execution, public 

participation, coordination, and 

management. 

ER 385-1-92 Safety and Health 

Requirements for 

Hazardous, Toxic, 

and Radioactive 

Waste (HTRW) 

Activities 

Identifies the safety and occupational 

health documents and procedures 

required to be developed and 

implemented by USACE elements 

and their contractors responsible for 

executing HTRW activities. 

ER 385-1-95 Safety and Health 

Requirements for 

Ordnance and 

Explosive 

Operations 

Identifies safety and health 

requirements, responsibilities, and 

procedures for MEC operations. 

EP 200-1-2 Environmental 

Quality - Process 

and Procedures for 

RCRA 

Manifesting 

Provides a guide to the procedures 

and responsibilities associated with 

manifesting hazardous waste IAW 

RCRA and DOT regulations. 
EP 75-1-3 

30 Nov 04 

 3-9 

Table 3.1 (continued) 

Directives, Instructions and Regulations for RCWM Response Actions 

Directive/Regulation Title Contents/Regulations Applicable

(Y/N) 

EP 385-1-95a Basic Safety 

Concepts and 

Considerations for 

Munitions 

Response to 

Munitions And 

Explosives of 

Concern 

Operations 

Establishes operating procedures for 

dealing with MEC. 

EP 385-1-95b Explosives Safety 

Submission 

Provides procedural guidance for 

preparing ESSs for conventional 

munitions response actions. 

EP 415-1-266 Construction - 

Resident Engineer 

Management 

Guide (REMG) 

for Hazardous, 

Toxic, and 

Radioactive Waste 

(HTRW) Projects 

Provides information regarding 

remedial design activities, response 

actions involving HTRW, and 

response actions to MEC. It 

highlights the unique requirements of 

which resident engineers must be 

aware to complete environmental 

project successfully. 

EP 1110-1-18 Ordnance and 

Explosives 

Response 

Provides procedures for the 

management and execution of 

munitions responses to MEC. 

EP 1110-3-8 Public 

Participation in 

the Defense 

Environmental 

Restoration 

Program (DERP) 

for Formerly Used 

Defense Sites 

(FUDS) 

Provides information on public 

participation in the DERP for FUDS 

through discussion of procedures for 

establishing and maintaining 

community relations programs, 

Restoration Advisory Boards, and 

Administrative Records. 
EP 75-1-3 

30 Nov 04 

 3-10 

Table 3.1 (continued) 

Directives, Instructions and Regulations for RCWM Response Actions 

Directive/Regulation Title Contents/Regulations Applicable

(Y/N) 

EM 200-1-2 Technical Project 

Planning (TPP) 

Process 

Provides procedures for the TPP 

process. 

EM 200-1-3 Requirements for 

the Preparation of 

Sampling and 

Analysis Plans 

Provides guidance for the preparation 

of project-specific sampling and 

analysis plans for the collection of 

environmental data. 

EM 200-1-6 Chemical Quality 

Assurance for 

HTRW Projects 

Provides specific guidance, 

procedures, criteria, and tools for 

chemical implementation of the 

USACE HTRW QA Program. 

EM 385-1-1 Safety and Health 

Requirements 

Manual 

This manual prescribes the safety and 

health requirements for all Corps of 

Engineers activities and operations. 

EM 1110-1-1200 Conceptual Site 

Models for 

Ordnance and 

Explosives (OE) 

and Hazardous, 

Toxic, and 

Radioactive Waste 

(HTRW) Projects 

Provides procedural guidance to 

develop conceptual site models at 

sites that may contain MEC, HTRW, 

or both. 

EM 1110-1-4009 Munitions 

Response to 

Munitions and 

Explosives of 

Concern 

Provides procedures to be used to 

perform engineering and design 

activities for all phases of munitions 

response actions involving MEC. 
EP 75-1-3 

30 Nov 04 

 3-11 

Table 3.1 (continued) 

Directives, Instructions and Regulations for RCWM Response Actions 

Directive/Regulation Title Contents/Regulations Applicable

(Y/N) 

CESO-E 

Memorandum 

SUBJECT: 

Applicability of 

Biological 

Warfare Materiel 

and Non-Stockpile 

Chemical Warfare 

Materiel Response 

Activity Interim 

Guidance 

Directs the implementation of the 

DACS-SF Memorandum at all 

USACE activities. 

DA, Office of the 

Assistant Secretary 

Installations Logistics 

and Environment 

Memorandum * 

SUBJECT: 

Interim Guidance 

for Biological 

Warfare Materiel 

and Non-Stockpile 

Chemical Warfare 

Materiel Response 

Activities, 

5 Sep 97 

The purpose of this Interim Guidance 

is to ensure the protection of workers, 

the public, and the environment 

during RCWM response activities and 

ensure that these activities are 

conducted IAW safety and 

environmental laws and requirements. 

It defines RCWM, risk assessments, 

characterization, recovery, packaging, 

and CSSs. 

DASA-ESOH 

Memorandum 

Interim Guidance 

on Nerve and 

Mustard Agent 

Decontamination 

and Medical 

Services in 

Industrial 

Activities 

Provides requirement sand procedures 

for safer, more effective chemical 

agent decontamination and medical 

treatment. 
EP 75-1-3 

30 Nov 04 

 3-12 

Table 3.1 (continued) 

Directives, Instructions and Regulations for RCWM Response Actions 

Directive/Regulation Title Contents/Regulations Applicable

(Y/N) 

DACS-SF 

Memorandum* 

SUBJECT: Approval 

of Safety 

Submissions for NonStockpile Chemical 

Warfare Materiel 

Response Activities, 

29 Feb 00 

This document outlines procedures 

for the coordination, review and 

approval of CSSs and changes to 

CSSs. 

DACS-SF 

Memorandum 

SUBJECT: 

Applicability of 

Biological Warfare 

Materiel and NonStockpile Chemical 

Warfare Materiel 

Response Activity 

Interim Guidance, 19 

Mar 98 

Assists local commanders, 

installation commanders, and 

district commanders in determining 

if the Interim Guidance is to be 

followed at projects where 

construction, or environmental 

response actions other than a 

RCWM investigation or removal 

action is conducted at a site with a 

history of RCWM. 

DACS-SF 

Memorandum 

Notification of 

DDESB for 

Explosives and 

Chemical Agent 

Mishaps, 13 Jan 98 

Describes notification requirements 

in the event of an explosive and/or 

chemical agent mishap. 

DACS-SF 

Memorandum 

Amendments and 

Corrections to Safety 

Submissions for NonStockpile Chemical 

Warfare Materiel 

Response Activities, 

20 Sep 00 

Describes the procedures for issuing 

amendments and corrections to 

safety submissions for RCWM 

response actions. 
EP 75-1-3 

30 Nov 04 

 3-13 

EP 1110-1-18 presents additional tables of other environmental laws that may be applicable to 

RCWM response actions, and additional environmental laws and regulations that may be 

applicable at specific sites containing RCWM hazards. 

3-7. Geophysical Considerations. Detailed procedures for geophysical considerations for 

RCWM projects are provided in EM 1110-1-4009. 

3-8. Location Surveying and Mapping. An overview of location surveying and mapping 

considerations for munitions response actions involving MEC is provided in EM 1110-1-

4009. Detailed surveying, mapping, and Geographic Information System (GIS) requirements 

may be found on the MM CX website at http://www.hnd.usace.army.mil/oew. 

3-9. GIS. The GIS assembles all the data required to associate the non-intrusive subsurface 

geophysics investigative data to the correct geographical location, the relational database, 

mapping, and remote sensing data. It provides a standard methodology to assist in the 

assembly of all past, current, and proposed MEC project information into a common reference 

for analysis, management, and storage in a digital format for the response action’s 

administrative record. 

3-10. Sampling and Analysis Considerations. Requirements for sampling and analysis are 

provided in ER 1110-1-263 and EM 200-1-3. Agent and agent breakdown product (ABP) 

analyses must be performed IAW the U.S Army Chemical Agent Standard Reference Material 

(CASARM) QA Plan and the laboratory’s (ECBC’s or approved contractor facility’s) QA/QC 

plan. 

3-11. Innovative Technologies in RCWM Response Actions. 

 a. Innovative technologies, like any other engineering tool, must be applied 

appropriately to a RCWM response action. The best available technology for each RCWM 

response action may vary due to differing, as well as highly unpredictable, site conditions. 

 b. The MM CX has been charged with reviewing, evaluating, and approving the 

implementation of the best available RCWM detection and removal technologies for RCWM 

response actions. The MM CX ensures that the implementation of innovative technologies is 

efficient and effective. The MM CX defines current technology and functional requirements, 

provides consulting services for response actions, identifies technology gaps, provides seed 

money to field improved technologies, and supports other technology programs. To assist 

with these functions, the MM CX maintains a MEC Innovative Technology Program. 
EP 75-1-3 

30 Nov 04 

 3-14 

c. Additional information on the Innovative Technology Program and the Innovative 

Technology Advocate is provided in EP 1110-1-18. 
EP 75-1-3 

30 Nov 04 

 4-1 

CHAPTER 4 

RCWM Response Action Overview 

4-1. Introduction. This chapter discusses the types of activities and tasks, which may be 

implemented during a RCWM response action and the corresponding safety and health plans 

and procedures that are required. 

4-2. Documents and Procedures Required on Suspect RCWM Sites. 

a. Overview. 

(1) This section presents information on the documentation and procedures required on 

a suspect RCWM site. Information regarding when a district may perform work on a RCWM 

site is also provided. 

(2) All planned response activities in an area suspected of containing RCWM will be 

conducted in a manner protective of both public and worker health and safety, in a manner 

protective of the environment. Prior to conducting any activities on a suspect RCWM site, 

approved safety and health plans and procedures are required to be completed IAW the 29 

Feb 00 HQDA Memorandum “Approval of Safety Submissions for Non-Stockpile Chemical 

Warfare Materiel Response Activities.” The level of effort for these plans and procedures is 

dependent on site activities or tasks (i.e., the potential for encountering RCWM.) Figure 4-1 

details the process for determining which safety and health plans and RCWM requirements 

are applicable to activities on a RCWM site. 

(3) The process discussed below applies to all investigative, response, or construction 

activities performed at a RCWM site by a district or MSC. If the site is suspected to be 

impacted by RCWM, the plans and requirements discussed in sections 4-2b through 4-2f must 

be followed. Performing RCWM investigation and/or response at suspect RCWM projects, in 

support of a District’s RI/FS or EE/CA, is the responsibility of the USAESCH CW-DC. If the 

presence of RCWM is suspected at a project, the District must coordinate with USAESCH 

prior to beginning any on-site activities. IAW ER 1110-1-8153, USAESCH is the only 

USACE command authorized to execute RCWM response actions. 
EP 75-1-3 

30 Nov 04 

 4-2 

Figure 4-1. Process for Determining Which Safety and Health Plans and RCWM 

Requirements are Applicable to a RCWM Project. 

NO

YES

A

(See Figure 4.1a)

NO

YES

USACE conducting 

work on site?

Suspect 

RCWM Site?

Site Visit 

Only?

Are RCWM 

Locations Intent 

of Investigation?

USAESCH

Project

Chemical Safety 

Submission Required

DA Safety Approval

(See Paragraph 4.2f)

B

(See Figure 4.1b)

Prepare ASSHP

USAESCH Review

(See Paragraph 4.2b)

NO

YES

NO

YES

A

(See Figure 4.1a)

NO

YES

USACE conducting 

work on site?

Suspect 

RCWM Site?

Site Visit 

Only?

Are RCWM 

Locations Intent 

of Investigation?

USAESCH

Project

Chemical Safety 

Submission Required

DA Safety Approval

(See Paragraph 4.2f)

B

(See Figure 4.1b)

Prepare ASSHP

USAESCH Review

(See Paragraph 4.2b)

NO

YES

NO

YES

A

(See Figure 4.1a)

NO

YES

USACE conducting 

work on site?

Suspect 

RCWM Site?

Site Visit 

Only?

Are RCWM 

Locations Intent 

of Investigation?

USAESCH

Project

Chemical Safety 

Submission Required

DA Safety Approval

(See Paragraph 4.2f)

B

(See Figure 4.1b)

Prepare ASSHP

USAESCH Review

(See Paragraph 4.2b)

NO

YES
EP 75-1-3 

30 Nov 04 

 4-3 

Figure 4-1a. Process for Determining Which Safety and Health Plans and RCWM 

Requirements are Applicable to a RCWM Project. 

Conduct Work

IAW Applicable 

Regulations

A

NO

YES

USAESCH Review

(See paragraph 4.2.e)

Conventional

MEC Suspect?

SSHP with Agent

Precautions

Worker Safety

Public Safety

Medical Exercises

Conduct Project

IAW Conventional MEC

Requirements

NO

YES

Agent

contaminated

media suspect?

Conduct Work

IAW Applicable 

Regulations

A

NO

YES

USAESCH Review

(See paragraph 4.2.e)

Conventional

MEC Suspect?

SSHP with Agent

Precautions

Worker Safety

Public Safety

Medical Exercises

Conduct Project

IAW Conventional MEC

Requirements

NO

YES

Agent

contaminated

media suspect?
EP 75-1-3 

30 Nov 04 

 4-4 

Figure 4-1b. Process for Determining Which Safety and Health Plans and RCWM 

Requirements are Applicable to a RCWM Project. 

NO

YES

YES

NO NO

Seldom

Unlikely

YES

Frequent

Likely

Occasional

B

Intrusive

Investigation?

Surface

RCWM

Suspect?

SSHP Required

USAESCH Review

(See paragraph 4.2.d)

Prepare a Probability

Assessment (PA)

USAESCH

Reviews PA

SSHP with Agent

Precautions

Probability 

of Encountering 

CWM

Interim Guidance Applies

USAESCH Project

(See paragraph 4.2.c)

AgentContaminated Media

Suspect?

Installation, District Commander, or 

Designated Representative 

signs PA and assumes risk

• WP needs Contingency Plan

• Interim Guidance does NOT apply

(See paragraph 4.2.c)

NO

YES

YES

NO NO

Seldom

Unlikely

YES

Frequent

Likely

Occasional

B

Intrusive

Investigation?

Surface

RCWM

Suspect?

SSHP Required

USAESCH Review

(See paragraph 4.2.d)

Prepare a Probability

Assessment (PA)

USAESCH

Reviews PA

SSHP with Agent

Precautions

Probability 

of Encountering 

CWM

Interim Guidance Applies

USAESCH Project

(See paragraph 4.2.c)

AgentContaminated Media

Suspect?

Installation, District Commander, or 

Designated Representative 

signs PA and assumes risk

• WP needs Contingency Plan

• Interim Guidance does NOT apply

(See paragraph 4.2.c)
EP 75-1-3 

30 Nov 04 

 4-5 

b. Site Visits. If site activities include only a site visit (walk through of the site) and no 

intrusive activities are planned, the only safety and health plan required is the Abbreviated 

Site Safety and Health Plan (ASSHP). This ASSHP must contain RCWM-specific 

information (i.e., what to do if a munition with an unknown filler is found). The format of the 

ASSHP can be obtained from EP 1110-1-18 and on the MM CX website at 

http://www.hnd.usace.army.mil/oew/erepems.asp. Prior to the site visit, the ASSHP must be 

approved by the MM CX or designee, IAW EP 1110-1-18. 

c. HTRW, Conventional MEC, or Construction Support on a Suspect RCWM Site. 

(1) If the intent of the investigation on a RCWM site is not to remove the RCWM, but 

rather to mitigate either HTRW or conventional ordnance or to provide construction support, 

RCWM safety and health plans and requirements may not be required. The Interim Guidance 

for Biological Warfare Materiel and Non-Stockpile Chemical Warfare Materiel Response 

Activities discusses safety and health requirements on a RCWM site. However, it does not 

specifically address those situations when construction or an environmental response action 

other than a RCWM investigation or response action is conducted at a site that is suspect of 

containing RCWM. To determine whether the Interim Guidance applies to non-RCWM 

activities, a procedure called a probability assessment was developed and is contained in a 

HQDA Policy Memorandum, “Applicability of Biological Warfare Materiel and NonStockpile Chemical Warfare Materiel Response Activity Interim Guidance,” dated 19 Mar 98. 

Any district or installation planning to conduct an environmental response action (i.e., 

investigation, removal, or construction support) on a suspect RCWM site must complete a 

probability assessment. The following paragraphs provide a summary of the probability 

assessment procedure. 

(a) Determine the scope of the proposed site activities. 

(b) Conduct a historical study (e.g., installation records, the PMNSCM Survey and 

Analysis report), USACE Topographic Engineering Center Historical Photographic Analysis, 

and site investigation to determine previous site usage and the potential for encountering 

RCWM. 

(c) Determine the probability of encountering RCWM during proposed site activities 

based on the scope of proposed site activities, previous site usage, and the potential for 

encountering RCWM. The probability must be documented; documentation will include the 

information used to determine the probability. IAW AR 385-10, the probability of 

encountering RCWM will be ranked in one of five categories: 
EP 75-1-3 

30 Nov 04 

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• Frequent: Occurs very often, continuously experienced. 

• Likely: Occurs several times. 

• Occasional: Occurs sporadically. 

• Seldom: Remotely possible; could occur at some time. 

• Unlikely: Can assume will not occur, but not impossible. 

(d) The completed probability assessment will be provided to USAESCH for review and 

comment. If the probability of encountering RCWM is determined to be “seldom” or 

“unlikely,” either the installation, District Commander, or designated representative must sign 

the probability assessment and assume the risk of conducting site activities as a non-RCWM 

site (i.e., the Interim Guidance will not be implemented). This decision must be justified and 

documented in writing. 

(2) If the District’s signed probability assessment determines that the probability of 

encountering RCWM is “seldom” or “unlikely,” the following requirements apply. 

(a) The safety and health plan for the proposed site activities must include contingency 

plans providing for a safe and expeditious response in the event RCWM is encountered. 

RCWM contingency plans will have the concurrence of the MM CX and the installation 

and/or District safety and environmental offices, EOD and TEU, and from all Army agencies 

responsible for the work activities. 

(b) Any time munitions with unknown fillers are encountered, all work will 

immediately cease. Project personnel will withdraw along cleared paths upwind from the 

discovery. A team consisting of a minimum of two personnel will secure the area to prevent 

unauthorized access. Personnel will position themselves as far upwind as possible while still 

maintaining security of the area. 

− At FUDS projects, the UXO team will notify the local POC designated in the Work 

Plan. The local POC will facilitate EOD response and two personnel will secure the site until 

EOD’s arrival. If the local POC designated in the Work Plan is not the local law enforcement 

agency, the local POC will inform the local law enforcement agency of the discovery, if 

necessary. The EOD unit will notify the TEU and secure the area until TEU’s arrival. After 

notifying the local law enforcement agencies, the local POC will notify the USAESCH MM 

CX to inform them of the actions taken. 
EP 75-1-3 

30 Nov 04 

 4-7 

− On active installations, the UXO team will normally notify the Range Control 

Officer, Facility Engineer, Post Headquarters, or POC designated in the Work Plan. After 

notifying the Range Control Officer or POC, the local POC will notify the MM CX to inform 

them of the actions taken. 

(c) If the item is confirmed to be RCWM, all investigative and/or construction work 

will stop. All of the elements of the Interim Guidance and other relevant RCWM Army 

regulations will be implemented before work will commence. The PMNSCM, the TEU 

Commander, the installation (or District safety and environmental offices), and USACE will 

coordinate on implementing the Interim Guidance. 

(3) If the District’s signed probability assessment determines that the probability of 

encountering RCWM during project activities is “frequent,” “likely,” or “occasional,” all of 

the requirements in the Interim Guidance apply and USAESCH must be involved in the 

response action. The types of safety and health plans and procedures required are dependent 

on whether the site activities are classified as non-intrusive, anomaly avoidance, or intrusive, 

as discussed in the following sections. 

d. Non-Intrusive Activities. If there is a high potential of encountering RCWM items 

at the surface during non-intrusive activities (e.g., geophysical mapping), a CSS is required 

(see paragraph f.(1) below). Otherwise, a SSHP will be developed and approved by 

USAESCH. The SSHP will include all of the elements of an HTRW SSHP. The SSHP will 

address the requirements of 29 CFR 1910.120(b)(4), 29 CFR 1926.65(b)(4), ER 385-1-92, 

EM 385-1-1, and ER 385-1-95. The SSHP will include information on the agents that are 

suspected to be on-site and hazard communication information. 

e. Investigative and Assessment Activities Utilizing Anomaly Avoidance. When 

anomaly avoidance is used for site investigation and assessment (e.g., soil and water 

sampling, or the installation of monitoring wells) a SSHP, approved by the MM CX, is 

required. Additional precautions, as stated below, must also be met: 

(1) Public Safety. A MCE must be determined. The MCE is the maximum release of 

chemical agent from a munition, container, or process that might realistically result from an 

unintended, unplanned, or accidental occurrence. Army regulations require the CSS to use 

the 1 Percent Lethality Distance when computing Public Safety for siting purposes. USACE 

will also calculate the No Significant Effects (NOSE) distance to be used in the Work Plan for 

the project. Intrusive activities will not be conducted when unprotected or untrained 
EP 75-1-3 

30 Nov 04 

 4-8 

personnel are within the NOSE distance, which is the distance at which personnel should not 

experience any significant effects if the MCE occurs. 

(2) Additional information on anomaly avoidance activities is published in EP 75-1-2. 

f. Response Activities with the Intent to Uncover, Characterize, and/or Remove 

Geophysical Anomalies and RCWM Burial Locations. 

(1) Chemical Safety Submission. 

(a) When anomaly avoidance is not used for site investigation or response activities or 

the suspect item cannot be detected (e.g., surface removal of RCWM or excavation when the 

intent is to uncover, characterize and remove geophysical anomalies), a CSS is required. The 

CSS serves as the specifications for conducting RCWM work activities at the project. It 

details the scope of the response action, the planned RCWM work activities, the potential site 

hazards and the methods of controlling the hazards. 

(b) Risk Assessment. Activity at a RCWM project will require the determination of risk 

to the public and to site workers. Risks to human health and the environment resulting from 

RCWM can be divided into explosive safety risks and risks associated with the release of 

chemical agent. Both of these risks need to be evaluated in order to determine the 

effectiveness of risk management decisions concerning RCWM. A site-specific MCE shall be 

developed by USAESCH or the implementing agency to form a basis to generate hazard 

zones: hazard zones shall be computed using the MCE and Army-approved atmospheric 

dispersion modeling. Quantitative risk assessment codes shall be developed to assess 

response hazards (e.g., dispersion of agent-contaminated soil, explosive hazards). Public risk 

information and controls shall be addressed in safety planning documents. 

(c) The USAESCH CW-DC is the only USACE office that is authorized to perform this 

work. The CSS is normally prepared by USAESCH with input from other agencies and 

approved by the office of the Director of Army Safety. The CSS is built on the Work Plan 

and supplemental plans, so those plans must be complete before the CSS can be completed. 

The overall length of the plan shall not exceed 50 single-sided pages. 

(d) Chapter 7 presents a detailed discussion on the contents of the CSS and approval 

procedures for the document. 

(2) Additional precautions must also be met when performing intrusive activities on a 

RCWM site. IAW Army guidance, intrusive activities will not be conducted unless: 
EP 75-1-3 

30 Nov 04 

 4-9 

(a) Calculation of the munition with the greatest fragmentation distance (MGFD) and 

the requisite minimum separation distance (MSD) has been calculated for the project (as 

necessary). 

(b) A risk analysis shows that the benefits justify the costs. 

(c) The Army has the capability to handle the retrieved RCWM. 

(d) The NOSE distance has been calculated and the general public is protected. 

(e) A tabletop exercise and pre-operational survey have been successfully completed. 

(f) Medical support arrangements have been made. 

(g) The CSS has been approved. 

(h) The Public Access Exclusion Distance (PAED) has been calculated. 

4-3. Types of Response Actions. 

a. General 

(1) The purpose of a RCWM response action is to reduce, in a timely, cost-effective 

manner, the risk to human health, safety and the environment resulting from past DOD 

activities. The response action includes all activities involved in the remediation or removal 

of RCWM and chemical agent contaminated media from the environment to include 

preliminary work (e.g., the Remedial Preliminary Assessment and Remedial Site Inspection) 

and the disposal of removed materiel. Response actions also include, though are not limited 

to, the use of security fencing or other measures to prevent, minimize, or mitigate damage to 

the public health or welfare or to the environment. 

(2) The types of response actions available are: 

(a) Remedial action. 

(b) Time Critical Removal Action (TCRA). 

(c) Non-Time Critical Removal Action (NTCRA). 

(d) Emergency removal action. 
EP 75-1-3 

30 Nov 04 

 4-10 

b. Selection of Response Action Type. 

(1) The selection of the appropriate type of RCWM response action is based on an 

evaluation of the following site-specific features: 

(a) The nature of the RCWM hazard. 

(b) The urgency/threat of release or potential release of RCWM. 

(c) The timeframe required for initiating a response action. 

(2) Following the evaluation of the above features, the suitable type of response action 

is selected. The Army has given execution authority to USACE for remedial actions, TCRAs 

and NTCRAs at FUDS. ER 200-3-1 discusses the circumstances under which each type of 

response action is implemented. USACE does not execute emergency removal actions with 

regard to RCWM. Such actions are performed by authorized DA response agencies such as 

EOD or TEU personnel. 

(3) This EP discusses the requirements for conducting a RCWM response action IAW 

the CERCLA/NCP process. This EP will focus on the requirements for executing a response 

action that are unique to RCWM projects and that are not already addressed in ER 200-3-1 

and EP 1110-1-18. A reference to ER 200-3-1 is provided for those instances in which the 

requirements are generic to FUDS and a reference to EP 1110-1-18 is provided where the 

requirements for RCWM and MEC are identical. 
EP 75-1-3 

30 Nov 04 

 5-1 

CHAPTER 5 

Site Characterization Activities 

5-1. Introduction. 

a. This chapter presents an overview of the site characterization activities involved 

with a RCWM response action. A RI/FS must be completed for all remedial actions and an 

EE/CA must be completed for all NTCRAs, as required by the NCP. The CW-DC is 

responsible for executing the site characterization phase for RCWM projects IAW CERCLA 

and the NCP. 

b. The purpose of the site characterization is to identify the most appropriate response 

action to address RCWM risk at a project. The determination of the recommended response 

alternative occurs following the completion of a site characterization, risk assessment of 

RCWM hazards present at the site, and evaluation of potential response alternatives. The data 

generated to support the selection of a RCWM response alternative is presented in either a RI 

report for a remedial action or an EE/CA for a NTCRA. The components of the site 

characterization phase, as they relate to the RCWM response process, are explained in the 

following paragraphs. 

5-2. Site Characterization Planning and Coordination. The site characterization planning and 

coordination process includes the preparation of the Statement of Work (SOW), independent 

government estimate (IGE), and schedule; completion of a site visit; preparation and approval 

of all required planning documentation; and fulfillment of the project management, 

regulatory, real estate, and public participation requirements. 

a. Preparation of the SOW. The site-specific data gathered during the Preliminary 

Assessment (PA) and SI is used to prepare the SOW. The RCWM PDT will manage the 

preparation of the SOW and ensure that all applicable technical disciplines are appropriately 

involved. The PDT will include the customer(s), the PM, technical experts within or outside 

the local USACE activity, specialists, consultants/contractors, stakeholders, representatives 

from other Federal and state agencies, and vertical members from division and headquarters 

that are necessary to effectively develop and deliver the project. Additionally, the MM CX 

may be consulted to provide the appropriate statements concerning the background or 

authority for the task order’s award. 
EP 75-1-3 

30 Nov 04 

 5-2 

b. Preparation of the IGE. The IGE for a site characterization will be prepared IAW 

the guidance provided in EP 1110-1-18. 

c. Site Visit. 

(1) Site Visit SOW. The site visit may be authorized as either a purchase order or as the 

first task of an incrementally funded contract. 

(2) Purpose. The purpose of the site visit is to provide the contractor with the 

opportunity to gather pertinent information for use in preparing the Work Plan and other 

planning documents. The information collected from the site visit allows the contractor to 

gain a better understanding of the nature and extent of the RCWM hazard and verify the 

locations of the proposed areas of interest. This information, which is instrumental in 

planning the site characterization, includes: 

(a) Site features, such as terrain, soil type, access, and amount of brush clearance 

required. 

(b) Location of / coordination with nearest hospital. 

(c) Location of / coordination with nearest fire station 

(d) Coordination with local Emergency Management Agency. 

(e) Coordination with local airport/Federal Aviation Administration representatives. 

(f) Coordination with local police, sheriff, Federal Bureau of Investigation, and/or 

Military Intelligence Office to assess security. 

(g) Fencing requirements for explosives storage magazines. 

(h) Location for support zone, investigative-derived waste storage locations, and 

explosive storage magazines if applicable. 

(i) Location of the IHF, if applicable. 

(j) Logistical coordination for lodging, equipment and vehicle rental, office space, 

explosives dealers, etc. 
EP 75-1-3 

30 Nov 04 

 5-3 

(k) Coordination with Range Control, Defense Reutilization Management Office, 

Ammunition Supply Point, and Post Provost Marshal, if applicable. 

(l) Coordination with TEU, air monitoring personnel, PMNSCM, and the District for 

support activities during field investigations, as applicable. 

(m) Location of Geophysical Prove-Out (GPO). 

(3) Site Visit Requirements. The following paragraphs present requirements that apply 

to the site visit: 

(a) Prior to the site visit, the contractor will be provided with copies of the ASR and any 

other site-specific information for review. 

(b) An ASSHP will be prepared and submitted to the MM CX prior to visiting the site. 

The ASSHP will be prepared using the format provided in EP 1110-1-18. 

(c) Generally, no more than three contractor personnel are required to participate. One 

contractor participant must be the project manager. Other recommended contractor personnel 

include the project geophysicist or project engineer. If there is potential for MEC, a 

government or contractor UXO escort will also be required. 

(d) Since the site visit will be non-intrusive and anomaly avoidance techniques will be 

implemented, site visit participants are not required to have Hazardous Waste Operations 

(HAZWOPER) training or medical monitoring. 

(e) The District will coordinate with the property owner/operator prior to the site visit if 

a ROE is required. 

(f) A site visit for a typical project should take no longer than five days, including travel 

time. 

(g) United States Army Center for Explosives Safety (USATCES) personnel will 

normally be given the opportunity to attend a site visit early on during the response action to 

facilitate a better review of the CSS for DA Safety. 

d. Preparation of Planning Documents. To ensure all members of the PDT agree on 

the approach and procedures used to investigate the potential RCWM or CWM hazard 

locations, a RCWM Conceptual Site Plan (CSP) will be developed prior to initiating the CSS 
EP 75-1-3 

30 Nov 04 

 5-4 

and Work Plan. A detailed outline is provided in Chapter 7. A CSS may be required prior to 

beginning intrusive work at the RCWM site (see Chapter 4). If a CSS is not required, a Work 

Plan and supporting plans will still be required to conduct field activities. 

(1) Work Plan. A site-specific Work Plan is required for all site characterization 

activities. The Work Plan documents the methodology that will be used to complete the site 

characterization. Following the site visit, the Work Plan will be developed IAW the SOW. 

The contents of the Work Plan, including sub-plans, are discussed in Chapter 7. 

(2) SSHP. The contractor will also prepare a SSHP IAW the guidance provided in 

Chapter 7 of this document. The SSHP is included as a part of the Work Plan IAW ER 385-

1-95 and EM 385-1-1. 

(3) Supporting Plans. If a CSS is required, the following supporting plans will be 

prepared IAW Chapter 7 of this document: TEU Assessment Plan, Environmental Media 

Sampling and Analysis Plan, Public Evacuation or Shelter-in-Place Plan, and PMNSCM 

Plans. If only agent-contaminated media is suspected, TEU and PMNSCM plans may not be 

required. 

(4) Public Affairs, Real Estate and Regulatory Requirements. During the site 

characterization planning and coordination process, the District PM must ensure that all 

applicable public affairs, real estate, and regulatory requirements, as discussed in EP 1110-1-

18 and EP 1110-3-8, have been satisfied. Additionally, the applicable safety and training 

requirements, as specified in Chapter 8 of this document must be fulfilled. 

(5) Anomaly Review Board. The District PM may also consider the establishment of an 

Anomaly Review Board (ARB). An ARB is only used in exceptional circumstances. 

Information on ARB procedures is provided in EP 1110-1-18. 

5-3. Site Characterization for RCWM Projects. 

a. Overview. 

(1) In general, RCWM sites are comprised of disposal pits and test trenches, and to a 

lesser extent, impact ranges. The purpose of a RCWM site characterization is to obtain 

surface and subsurface RCWM data to characterize the site and to generate recommendations 

for the proposed RCWM response action. This characterization will include any data from 

any RCWM that has been located and/or disposed of by EOD or local law enforcement. 
EP 75-1-3 

30 Nov 04 

 5-5 

Potential sources for this data include the ASR, EOD records, or local law enforcement 

records. The following types of data will be collected for the site: 

(a) Type of CWM or CWM-related activities associated with the site. 

(b) Locations of CWM or CWM-related activities, including locations of pits or 

trenches. 

(c) Density of CWM munitions at impact areas. 

(d) Penetration depth of CWM munitions at impact areas. 

(2) The components of the site characterization phase include: 

(a) Implementation of the sampling methodology. 

(b) Geophysical Instrument Prove-Out. 

(c) Area preparation. 

(d) Field sampling. 

b. Statistical Tools. During a site characterization, statistical tools may be used to 

collect site-specific data for impact areas. In many cases, this is not required due to the fact 

that suspect areas have already been identified as disposal/burial areas and sampling is biased 

to these locations. Contact the MM CX for additional detail on the following: 

(1) UXO Calculator. The UXO Calculator is a statistical model for determining the 

potential amount of UXO in a sector. The UXO Calculator assumes homogeneous presence 

of MEC within an identified area. It is used to determine statistical confidence intervals for 

UXO density and to perform statistical tests concerning UXO densities. 

(2) Other. Other statistical methods that are agreed to by stakeholders, documented and 

approved. 

c. MEC Detection Instrument Testing. 

(1) Before geophysical surveys can begin on a site, the proposed geophysical survey 

methods and techniques must be tested and evaluated. The results of the GPO will identify 

realistic capabilities and limitations of applying geophysics at a particular site and aid in 
EP 75-1-3 

30 Nov 04 

 5-6 

determining proper post-processing procedures for the geophysical data. Additionally, a GPO 

demonstration offers the client an opportunity to observe the contractor’s methods and 

evaluate their ability to meet Data Quality Objectives and compliance with project 

requirements. A GPO must be constructed so that it is representative of the project and the 

specific buried munition items known or suspected to exist. 

(2) The objectives for the GPO are concerned mainly with establishing and maintaining 

high levels of quality control throughout this phase of the response action. EM-1110-1-4009 

provides a detailed list of general objectives for a GPO, including the GPO Plan and GPO 

Report. In addition, stakeholders and regulators for the project will be consulted before the 

objectives are finalized. 

(3) The GPO is performed prior to initiation of the field investigation. Prior to the 

GPO, a GPO Plan and appropriate SSHP must be developed. 

d. Area Preparation. Area preparation includes the identification and marking of 

geophysical sampling grids and the removal of sufficient vegetation and other obstacles that 

may restrict sampling efforts. 

(1) Location Surveying and Mapping. Location surveying and mapping will be 

performed by the contractor to establish the boundaries of the areas under investigation. The 

procedures to be used in the execution of location surveying and mapping are discussed in 

EM 1110-1-4009. 

(2) Brush Clearance. 

(a) Prior to conducting any field sampling, brush clearance may be required. The 

purpose of brush clearance is to remove sufficient vegetative growth from the areas to be 

investigated in order to effectively locate, investigate, and remove subsurface anomalies. 

(b) The vegetation removal techniques used must be coordinated with the District 

environmental staff and documented in the Work Plan. A UXO Technician II shall always 

escort the brush clearing crew in areas not previously cleared of MEC or munitions with 

unknown fillers. The safety requirements listed in EM 385-1-1 shall be followed. PPE will 

be provided to the brush clearance crew and used for protection as required. All brush 

clearance personnel must be trained in the safe operation of the necessary equipment and have 

obtained site-specific safety training IAW Chapter 8 of this document. 
EP 75-1-3 

30 Nov 04 

 5-7 

(3) Removal of Surface Debris. Surface debris removals are conducted to remove all 

MEC, RCWM, munitions debris, and other metallic debris from the surface of the area to be 

characterized that may interfere with the geophysical investigation. UXO-qualified personnel 

will flag, identify, and record the approximate location of all MEC, RCWM, or munitions 

with unknown fillers. TEU is responsible for assessing munitions with unknown fillers and 

then packaging and transporting those items to the IHF IAW the approved CSS. UXOqualified personnel may assess, handle, and dispose of MEC items IAW the approved CSS. 

The contractor may handle and dispose of other items of surface debris, and will also assist 

the TEU as needed. The contractor will remove all chemical agent contaminated scrap and 

non-RCWM related materials that may interfere with the geophysical investigation. These 

items will be headspaced and decontaminated as necessary before being stored for later 

disposition. 

e. Field Sampling. During the field sampling, surface and/or subsurface sampling is 

conducted to obtain the data necessary to conduct an accurate site characterization. 

(1) Surface Sampling. In the event that RCWM or munitions with unknown fillers were 

encountered during the removal of surface debris, the contractor will perform environmental 

sampling IAW Chapter 9 of this document to verify that no residual chemical agent remains at 

those locations. 

(2) Subsurface Sampling. 

(a) Prior to the subsurface sampling effort, the contractor will perform a geophysical 

survey to locate subsurface anomalies. The procedures for conducting geophysical surveys 

are discussed in Chapter 6 of this document. Anomalies identified by the geophysical survey 

team will be intrusively investigated. Only TEU or approved UXO-qualified personnel will 

perform intrusive operations. RCWM response actions will proceed IAW the approved CSS. 

(b) Once a munition with unknown filler has been exposed, TEU will assess, package, 

and transport the RCWM or munition with unknown filler to the IHF. The contractor will 

assist TEU as needed. 

(c) If a munition with unknown filler is removed, then the excavated location will be 

rechecked with a magnetometer or other geophysical equipment. Upon completion of the 

recheck, if the location does not produce another anomaly or signs of additional burial (e.g., 

fill materials are no longer encountered), the excavated area will be sampled IAW Chapter 9 

to determine if residual chemical agent is present. If the area is determined to be free of 
EP 75-1-3 

30 Nov 04 

 5-8 

agent, the area may be backfilled with clean soil. If chemical agent is present in the sample, 

then the on-site OE Safety Specialist will be notified. 

(d) Evacuations are sometimes necessary when conducting intrusive investigations to 

minimize the risk of the operation. An EZ distance is calculated to ensure that all nonessential personnel are outside of that distance during the conduct of the excavation. The EZ 

distance may be reduced by implementing approved engineering controls. 

(e) There are several other considerations, which must be accounted for during the 

intrusive investigation, including: engineering controls, EZ management, and quality 

assurance. These topics are discussed in detail in later chapters of this pamphlet. 

5-4. Engineering and Operational Controls. 

a. Engineering controls are used to improve personnel safety and/or to reduce the EZ 

during response operations. If an engineering control design is required to reduce an EZ due 

to fragmentation concerns, the Military Munitions Design Center (MM-DC) shall be 

contacted for design approval. Examples of engineering controls for vapor containment for 

RCWM activities include: 

(1) The use of environmental structures to reduce or contain the agent should a release 

occur (e.g., an engineering control structure capable of vapor containment and blast 

mitigation). This is usually accompanied by the use of an approved air filtration system to 

capture the agent vapors. 

(2) Filtered Shelter (other than the Vapor Containment Structure). 

b. Operational Controls. Examples of operational controls for RCWM are described 

below. 

(1) RCWM operations shall be performed during the hours of daylight. 

(2) Certain temperatures can reduce the rate of release of agents. For example, mustard 

agent, or H, becomes a solid at temperatures below 57 degrees Fahrenheit. If the chemical 

agent of concern at the project was mustard agent, operations could be restricted to periods 

when the temperature would be below that temperature, thereby reducing the NOSE distance. 

However, even at temperatures below 57 degrees Fahrenheit, if the MCE is an explosively 

configured munition, containing H agent and the round functioned as designed, there would 
EP 75-1-3 

30 Nov 04 

 5-9 

be a hazard resulting from the release of agent caused by the heat generated from the 

explosion. 

(3) Wind speed has a direct effect on downwind hazard distances. Normally the higher 

the wind speed, the more air turbulence exists, thereby reducing the downwind distance of the 

agent plume. Therefore, operations could be restricted unless the wind speed is at or above a 

certain level. 

(4) Atmospheric stability. The time of day, the strength of sunlight (if any) in the area, 

the extent of cloud cover, and the wind velocity all play major roles in determining the level 

of turbulence in the atmosphere. Turbulence is the extent of “mixing” in the atmosphere. 

These factors determine downwind distances over which airborne contaminants will remain 

hazardous. Meteorologists typically divide atmospheric conditions into six atmospheric 

stability classes that generally range from “A” to “F”. Class A represents unstable conditions 

under which there is strong sunlight, clear skies, and high turbulence in the atmosphere. 

These conditions promote rapid mixing and dispersal of airborne contaminants. At the other 

extreme, atmospheric stability Class F represents light steady winds, nighttime skies, and low 

level of turbulence in the atmosphere. Airborne contaminants mix and disperse much slower 

with air under these conditions. 

(5) D2PC shall be used to calculate how temperature, wind speed, and atmospheric 

stability will affect the MCE-based hazard distances, such as the 1 Percent Lethality and 

NOSE distances. These calculations are performed during planning for the project to 

delineate EZs for the project, as well as during intrusive operations, where they are calculated 

regularly for specific weather conditions so that project personnel are prepared for an 

emergency in the event of a release and to determine whether planned EZs are adequate or 

overly conservative. 

5-5. Environmental Sampling and Analysis. Soil samples will be obtained from locations, 

which could potentially have been contaminated with RCWM or decontamination products. 

Soil samples will be obtained at intervals justified in the approved Work Plan. Sampling and 

analysis may also be required for investigation-derived waste (IDW). Detailed information on 

environmental sampling and analysis is provided in Chapter 9 of this document. 

5-6. Institutional Analysis. 

a. Purpose. An institutional analysis is conducted to determine what opportunities 

exist to implement a land use control (LUC) program at a specific site. The institutional 
EP 75-1-3 

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analysis also identifies the existence of any local, state, Federal, or private agencies that may 

be available to assist in the implementation or maintenance of the LUC program. An 

institutional analysis is necessary in order to evaluate whether LUCs are viable at a particular 

site as a stand-alone response action or as a supplement to other response activities. LUCs are 

appropriate at virtually every site where RCWM is discovered. The institutional analysis will 

also aid in developing the most effective LUC program, if it is selected as the stand-alone 

response alternative, or as part of a more comprehensive remedial or removal alternative. 

b. Determination of Existing LUCs. The existence of any current deed restrictions or 

other type of legal or administrative LUC that may have been placed on the property in the 

past as a result of some other activity shall be determined. If such restrictions are found to 

already exist at a site, it may be easier to modify the existing restriction to address the risk 

posed by RCWM than to implement an entirely new LUC. 

c. For additional information on the application of LUCs for the munitions response 

process, refer to EP 1110-1-24. 

5-7. Risk Characterization. 

a. Purpose. A risk characterization is required as part of the response process. A risk 

characterization of a RCWM site is conducted to determine the level of safety risk that exists 

at a site as a result of the RCWM hazard. The risk characterization is a key component in 

determining the type of response necessary to address the safety risk and the basis on which 

subsequent cost-benefit analyses are conducted in the RI or EE/CA report. 

b. Types of Risk Characterization Tools. Typically, a qualitative risk characterization 

tool is used for RCWM projects. For additional information on the selection of risk 

characterization tools, contact the MM CX. 

5-8. Development and Evaluation of Response Action Alternatives. 

a. Development of Response Action Alternatives. Once site-specific data has been 

gathered and analyzed, potential site-specific response action alternatives will be developed. 

A response action alternative may include physical removals, as well as any other alternatives 

that reduce risk to the public. The alternatives will be developed based on existing site 

conditions, historic use of the site, the existing or proposed land use, and the extent and depth 

of RCWM. Site-specific alternatives must ensure the most effective use of resources, while 

providing maximum return to the public. 
EP 75-1-3 

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b. Response Action Alternatives. The development of response action alternatives is 

described in detail in ER 200-3-1. 

c. Evaluation of Response Action Alternatives. Once the cleanup objectives have been 

established for a site, the various response action alternatives developed in the RI or EE/CA 

report must be evaluated in terms of how well they will meet these objectives. Three general 

evaluation criteria are used to evaluate the proposed alternatives for both RI/FS and EE/CA. 

For RI/FS, the categories of evaluation criteria are threshold criteria, primary balancing 

criteria, and modifying criteria. For a NTCRA the categorie of evaluation criteria are 

effectiveness, implementability, and cost. The specific evaluation criteria and the evaluation 

process for both remedial and removal actions are described in detail in ER 200-3-1. 

d. Comparative Analysis of Response Action Alternatives. Those alternatives that still 

appear feasible after the above evaluation are then compared to each other using the same 

criteria described above. During this comparative analysis, the alternatives are ranked and the 

recommended response action alternative is selected. 

5-9. RI Report / EE/CA Report. The RI or EE/CA report documents the methodologies used 

during the site characterization and presents the findings of the alternatives evaluation. The 

RI or EE/CA report is a flexible document that is tailored to the scope, goals, and objectives 

of the response process. It should contain data to support the selection of a response 

alternative and future 5-year recurring reviews. Existing documentation should be relied on 

whenever possible. 

a. The RI or EE/CA report for an RCWM response action is executed and approved by 

the CW-DC. The RI or EE/CA report is reviewed by the District and the MM CX. 

b. ESS Requirement During the Site Characterization Process. 

(1) A CSS may need to be prepared as part of the response action planning process, as 

discussed in Chapter 4 of this document. However, an ESS is prepared if the draft RI or 

EE/CA report recommends the response action alternative of either No DOD Action Indicated 

(NDAI) or LUCs. Examples of the content and format of an NDAI ESS and LUCs ESS are 

available in EP 385-1-95b. 

(2) Both the NDAI ESS and LUCs ESS must receive concurrence from the USATCES 

and DDESB. Once the ESS has been approved, and all other comments on the draft RI or 

EE/CA report have been incorporated, the final RI or EE/CA report may be prepared. 
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5-10. RI or EE/CA Public Participation and Approval Process. 

 a. Once the RI or EE/CA report has been prepared and reviewed by the CW-DC, the 

MM CX, the District, and other stakeholders, the report becomes part of the Administrative 

Record for the site. The RI or EE/CA report is then made available for public review. The 

requirements for public participation are presented in ER 200-3-1 and additional information 

is in EP 1110-3-8. 

 b. If RCWM remains or is suspected to remain after completion of a response action, 

the property owner(s) will be apprised through the Administrative Record or other written 

agreements and all documentation will be annotated accordingly. 

5-11. Action Memorandum/DD/ROD. 

 a. The Action Memorandum/DD/ROD are concise documents that identify the 

response action chosen for implementation at a site. The Action Memorandum or DD/ROD 

may also reserve the appropriate funding needed for the proposed response action. An Action 

Memorandum is required prior to implementation of TCRAs and NTCRAs. Requirements 

concerning the applicability of the Action Memorandum/DD/ROD, their format, and their 

review and approval process are laid out in ER 200-3-1 and additional information can be 

found in EP 1110-1-18. 
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CHAPTER 6 

RCWM Detection, Remediation/Removal, and Completion 

6-1. Introduction. This chapter provides information on the RCWM response process and 

project completion procedures. 

6-2. Response Design. 

a. The CW-DC is responsible for the removal design in coordination with the PM. 

b. USACE performs necessary tasks associated with a response design process during 

the development of the site-specific SOW, Work Plans, and CSS for the response action. The 

level of detail for the response design phase is dependent on the complexity of the work to be 

performed and the type of contract to be utilized. 

c. The purpose of the response design process is to describe the technical details of 

how the removal action will be performed. The response design process includes the 

following components, which are illustrated in Figure 6-1 and discussed below: 

(1) Preparation of the removal action SOW and IGE. The USAESCH CW-DC is 

responsible for executing and approving the munitions response SOW and IGE. SOW and 

IGE quality excellence will be accomplished through the conscientious, cooperative efforts of 

each design team member. The District reviews the SOW and IGE and provides comments. 

Additional information on the SOW and IGE are provided in EP 1110-1-18. 

(2) A site visit may be required to gather additional information on the nature and extent 

of the hazard at the site. The site visit is conducted to provide the contractor with the 

opportunity to gather pertinent information for use in preparing the cost estimate and planning 

documents. Detailed information on the site visit is provided in EP 1110-1-18. 

(3) The preparation of planning documentation (e.g., CSS) and completion of all 

coordination tasks prior to the Notice-to-Proceed will be necessary for the response action. A 

CSS is required when anomaly avoidance is not used for response activities or the suspect 

item cannot be detected. The CSS will be prepared and approved IAW the requirements 

found in Chapter 7 of this pamphlet. 
EP 75-1-3 

30 Nov 04 

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Figure 6-1. Response Design Process 

PREPARATION OF

THE SOW/IGE

SITE VISIT

PREPARATION OF

PLANNING DOCUMENTS

REVIEW AND APPROVAL OF

PLANNING DOCUMENTS

APPROVAL OF

ACTION MEMORANDUM/DECISION DOCUMENT/ROD

NOTICE-TO-PROCEED

FOR REMEDIAL/REMOVAL ACTION

PREPARATION OF

THE SOW/IGE

SITE VISIT

PREPARATION OF

PLANNING DOCUMENTS

REVIEW AND APPROVAL OF

PLANNING DOCUMENTS

APPROVAL OF

ACTION MEMORANDUM/DECISION DOCUMENT/ROD

NOTICE-TO-PROCEED

FOR REMEDIAL/REMOVAL ACTION

PREPARATION OF

THE SOW/IGE

SITE VISIT

PREPARATION OF

PLANNING DOCUMENTS

REVIEW AND APPROVAL OF

PLANNING DOCUMENTS

APPROVAL OF

ACTION MEMORANDUM/DECISION DOCUMENT/ROD

NOTICE-TO-PROCEED

FOR REMEDIAL/REMOVAL ACTION
EP 75-1-3 

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6-3. RCWM Detection and Removal. 

a. Introduction. The RCWM response phase begins following the receipt of the 

Notice-to-Proceed. The response action is intended to permanently and comprehensively 

address both short- and long-term health and safety hazards at RCWM impacted sites. The 

response action may be implemented using active duty military personnel, DOD civilian 

personnel, private contractors, or a combination of the three. The implementing agency will 

be responsible for full coordination for all activities, including procurement, funding, 

scheduling, and authorizations. The response action phase is composed of the following 

tasks, which are illustrated in Figure 6-2 and discussed in paragraphs 6-3b through 6-3i. 

b. Location Surveying and Mapping. Location surveying and mapping will be 

performed by the contractor to establish boundaries of the areas under investigation. The 

procedures for the execution of location surveying and mapping are discussed in EM 1110-1-

4009. 

c. Area Preparation. 

(1) Prior to the initiation of a RCWM response action, brush clearance may be required. 

The purpose of brush clearance is to reduce or remove the vegetative growth from the work 

areas in order to effectively locate, investigate, and remove surface and subsurface RCWM. 

(2) The areas cleared and techniques used must be coordinated with the District 

environmental staff and documented in the Work Plan. A UXO Technician II must always 

escort the brush clearing crew in areas not previously cleared of MEC or RCWM. The safety 

requirements in EM 385-1-1 must be followed. PPE will be provided to the brush clearance 

crew and used as required for protection. All brush clearance personnel must be trained in the 

safe operation of the equipment and must have obtained site-specific safety training IAW 

Chapter 8 of this document. 

(3) The duration of the response action will determine if the establishment of a staging 

area is required prior to intrusive work. The staging area may be used to store IDW and house 

office facilities and mobile laboratories. The IHF will also be located in the staging area. 

Location considerations should include: 

(a) Electrical requirements. 

(b) Telephone requirements. 
EP 75-1-3 

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Figure 6-2. Removal Action Process. 

NOTICE-TO-PROCEED

LOCATION SURVEYING AND MAPPING

AREA PREPARATION

RCWM and CHEMICAL AGENT CONTAMINATED

MEDIA SURFACE REMOVAL

GEOPHYSICAL INVESTIGATION

RCWM and CHEMICAL AGENT

CONTAMINATED MEDIA SUBSURFACE REMOVAL

ENVIRONMENTAL SAMPLING

IDW DISPOSAL

DEMOBILIZATION

SITE-SPECIFIC FINAL REPORT
EP 75-1-3 

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(c) Water and sanitation support. 

d. Surface Debris Removal. Surface debris removals are conducted to remove all 

MEC, RCWM, munitions debris, and other metallic debris from the surface of the work area. 

UXO-qualified personnel will flag, identify, and record the approximate location of all MEC 

or munitions with unknown fillers. TEU is responsible for assessing munitions with unknown 

fillers and then packaging and transporting those items to the IHF IAW the approved CSS. 

UXO-qualified personnel may assess, handle, and dispose of MEC items IAW the approved 

CSS. The contractor may handle and dispose of other items of surface debris, and will also 

assist the TEU as needed. In addition, the contractor will perform environmental sampling 

IAW Chapter 9 of this document to verify that no residual chemical agent remains after the 

surface removal of munitions with unknown fillers. The contractor will remove all chemical 

agent contaminated scrap and non-RCWM related materials that may interfere with the 

geophysical investigation. These items will be headspaced and decontaminated as necessary 

before being stored for later disposition. 

e. Geophysical Investigation. The purpose of the geophysical investigation is to 

acquire geophysical data and identify all anomalies that resemble RCWM or locations where 

CWM was disposed. A GPO may be used by the PDT to select the most appropriate survey 

instrument and optimum navigational equipment. Geophysical investigations may be 

completed using detection equipment with real time or post-processing discrimination 

techniques. The latter requires the collection and recording of geophysical data that is 

subsequently processed by commercial software to identify electromagnetic signals 

representative of anomalies. All anomalies selected for excavation will be mapped, 

documented on dig-sheets, physically re-established by survey methods, geophysically 

reacquired, and marked for investigation. Information on the elements, which must be 

considered when planning and executing a geophysical investigation, is provided in EM 

1110-1-4009. 

f. RCWM and Chemical Agent Contaminated Media Subsurface Removal. 

(1) Intrusive activities are conducted to investigate and identify the source of each 

subsurface anomaly. Anomalies determined to be less than 12 inches below the surface will 

be dug by hand. Anomalies deeper than 12 inches may be excavated to within 12 inches 

using mechanical or manual methods. Only approved UXO personnel will perform 

excavations involving RCWM. All excavations will be performed IAW the provisions of 29 

CFR 1926, subpart P. 
EP 75-1-3 

30 Nov 04 

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(2) After the probable source of the subsurface anomaly is removed, the excavation will 

be rechecked with a magnetometer or other geophysical instrument prior to backfilling. If the 

location does not produce another anomaly upon the recheck, then the excavated area will be 

backfilled and restored IAW contract requirements. If a munition with unknown filler is 

uncovered, the TEU will assess the item, then package and transport the item IAW the 

approved CSS. The contractor will assist the TEU as needed. In addition, after a munition 

with unknown filler has been removed from a location, the contractor will perform 

environmental sampling IAW Chapter 9 of this document to verify that no residual chemical 

agent remains at that location. Also, when possible, the contractor will remove all chemical 

agent-contaminated media from that location, then headspace and decontaminate as necessary 

before storing those media for later disposition. 

(3) EZ. 

(a) The EZ distance is the greater of the NOSE distance or the conventional 

fragmentation distance, taking into consideration reduction of either of these distances due to 

the use of engineering controls. Evacuations are sometimes necessary when conducting 

intrusive investigations in order to minimize the risk of the operation. The NOSE distance is 

based on the MCE and is calculated to ensure that the public and workers without adequate 

PPE are protected during the conduct of the excavation. Implementing engineering or 

operational controls can reduce the NOSE distance. The use of engineering controls is 

discussed in Chapter 5 of this document. 

(b) Conventional fragmentation distance. The PDT shall use the following guidelines 

when determining which fragment range to use. If the identification of the MEC expected at 

the site is unknown, the default distances listed in DOD 6055.9-STD will be used. If it is not 

practical to use these default distances and the identification of the MEC expected at the site 

is known, then the maximum fragment throw range will be calculated IAW DDESB 

Technical Paper 16, Methodologies for Calculating Primary Fragment Characteristics (1 Dec 

02). The item with the maximum fragment distance will become the MGFD for the site. For 

unintentional detonations, the PDT may request approval from the MM CX to use the range to 

no more than one hazardous fragment per 600 square feet (1/600 distance). The maximum 

fragment distances and the 1/600 distance will be calculated by the MM CX and provided to 

the PM. 

(4) Other considerations. There are several other considerations, which must be 

accounted for during the intrusive investigation, including: air monitoring, personnel 
EP 75-1-3 

30 Nov 04 

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decontamination station site, EZ management, and quality assurance. These topics are 

discussed in detail in later chapters of this document. 

g. Unknown Fillers. Complete identification of recovered munitions is required before 

destruction or disposal. If positive identification of the filler cannot be determined, the 

following procedures will be followed on RCWM sites: 

(1) TEU will normally be present at RCWM projects and will perform the assessment of 

the filler as part of their normal procedures. 

(a) If the assessment has ruled out RCWM as the filler, the item will be disposed as 

specified in the approved Work Plan. 

(b) If the assessment indicates RCWM as the filler, the item will be packaged and 

secured per the approved CSS. 

h. IDW Disposal. IDW will be characterized and disposed of IAW the procedures 

described in Chapter 10. 

i. Demobilization. 

(1) Demobilization may occur for a variety of reasons, including: 

(a) The response action may be completed with all work accomplished. 

(b) The response action may be incomplete, but the contractor has expended most of the 

contract funds. 

(c) Adverse weather conditions. 

(d) Determination that continuing in the present course of action is not in the best 

interest of the government. 

(2) The demobilization plan will be documented in the Mobilization/Demobilization 

Plan as part of the supporting plans included in the approved Work Plan. The demobilization 

plan will be developed by the contractor in close coordination with the PMNSCM, TEU, PM, 

CW-DC, OE Safety Specialists, and the customer. Authorization to demobilize from a site 

must be issued in writing to the contractor from the CO. The following areas will be 

addressed in the demobilization plan: 
EP 75-1-3 

30 Nov 04 

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(a) Arrangements for periodic maintenance and monitoring for the IHF. 

(b) Arrangements for closing out the IHF and shipping back to PMNSCM, if not in use 

at the end of the response action. 

(c) Disposal of RCWM scrap (if necessary). 

(d) Disposal of conventional scrap (if necessary). 

(e) Storage and transport of 3X contaminated equipment (if necessary). 

(f) Disposal or transfer of remaining explosives (if necessary). 

(g) Disposal of media (e.g., soil, water, etc.). 

(h) Disposition of commercial explosive storage containers (if necessary). 

(i) Close down of Command Post facilities. 

(j) Disposition of GFP (if necessary). 

(k) Disposition of portable sanitary facilities (if necessary). 

(l) Shutting down of public utilities at the project (i.e., water, electrical). 

(m) Restoration of site to previous condition. 

j. Site Specific Final Report. At the completion or termination of a RCWM response 

action, the contractor will prepare and submit a Site Specific Final Report. The Site Specific 

Final Report documents all activities and operations that occurred and lists the RCWM found 

during the response action. This report is used as the basis for USACE’s recommendations 

for future land use and for any proposed restrictions on the cleared area. EP 1110-1-18 

discusses the required content and submittal procedures for the Site Specific Final Report. 

6-4. Project Completion. The project completion requirements for a RCWM response action 

are discussed in ER 200-3-1 and additional information is found in EP 1110-1-18. Since the 

CW-DC executes the RCWM response action, the requirements for completion of a munitions 

response executed at a FUDS by the CW-DC, as described in ER 200-3-1 and EP 1110-1-18, 

are applicable to RCWM projects. 
EP 75-1-3 

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6-5. Operations and Maintenance (O&M). The purpose of O&M activities is to ensure that 

appropriate site safety and security measures remain in place and to maintain the integrity of 

any site controls, such as fences and signs. The determination of appropriate safety and 

security measures site controls must be made on a case-by-case basis. The District is 

responsible for ensuring that appropriate O&M activities are in place. Additional information 

on O&M related issues, such as recurring reviews, recordkeeping and access restrictions are 

discussed in EP 1110-1-18 and EP 1110-1-24. 
EP 75-1-3 

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CHAPTER 7 

RCWM Response Action Plans 

7-1. Introduction. 

a. The project plans (CSP, CSS, Work Plan, and supporting plans) are the basis for the 

RCWM response action. If a determination of applicability of the Interim Guidance indicates 

that the probability of encountering RCWM is seldom or unlikely and the District is willing to 

assume the risk, then a CSS is not necessary. 

b. The RCWM CSP will be used to describe the project’s background and proposed 

general approach and procedures to address the scope of the RCWM project. This plan will 

be developed and approved before the remaining project plans are initiated if the PDT 

determines the CSP is required for the project. 

c. The RCWM CSS will be used to provide RCWM response action safety criteria for 

approval by Army Safety and DDESB. 

d. The Work Plan (including the SSHP and supporting plans) provides the 

specifications for conducting work activities at a RCWM project. It details the scope of the 

project, the planned work activities, the potential site hazards, and the methods of controlling 

the hazards. A CSS is required when response activities will be performed (e.g., surface 

removal of RCWM, excavations when the intent is to uncover, characterize, and remove 

geophysical anomalies and burial locations that have the potential to be RCWM items). 

e. The CW-DC is the only USACE office authorized to prepare these plans. The CSS 

is normally prepared by the CW-DC with input from other agencies. 

7-2. Contents. 

a. CSP. 

(1) The PDT will determine whether a RCWM CSP is required for the initiation of a 

new RCWM response action. If required, the CSP will be prepared following the site visit. 

The following information will be included: 

(a) Project Authorization. 
EP 75-1-3 

30 Nov 04 

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(b) Purpose and Scope. 

(c) Work Plan Organization. 

(d) Project Location. 

(e) Site Description to include site location, topography, climate, vegetation, and site 

geology. 

(f) Site History. 

(g) Current and Projected Land Use. 

(h) Previous Investigations. 

(i) Initial Summary of RCWM Risk (summarize RCWM potentially on-site, and 

characteristic hazard presented by those items). 

(j) Project Objectives. 

(k) Organizational Roles. 

(l) Site Characterization Goals. 

(m) Site Characterization Procedural Overview. 

(n) RCWM Sampling Locations. 

(o) RCWM Sampling Procedures. 

(p) Surveying, Non-intrusive Investigations and Site Control. 

(q) Intrusive Investigation Operations. The Contractor shall describe proposed 

operations necessary for completion of this response action. 

(2) The CSP will be prepared IAW contract requirements. Generally, the CSP will 

discuss the topic areas provided above. If the topic area is not required for a particular 

project, the chapter will be included in the CSP with a declaration that the information is not 

required for the project. 
EP 75-1-3 

30 Nov 04 

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b. Work Plan. Additional information regarding Work Plans may be found on the 

MM CX website at http://www.hnd.usace.army.mil/oew. 

(1) A Work Plan is required for all RCWM projects. Following the approval of the 

CSP, if one is required by the PDT, the Work Plan will be prepared to describe the 

methodology for accomplishing the RCWM response action. 

(2) The Work Plan will be prepared IAW contract requirements. These work plans are 

prepared in the same manner as conventional MEC plans as described in EM 1110-1-4009. 

However, they will include the additional chapters listed below. If a topic area is not required 

for a particular project, the chapter will be included in the Work Plan with a declaration that 

the information was not required for the project. 

(a) MCE. 

(b) EZ. 

(c) Contingency Plan. 

(d) Intact Containers Monitoring and Disposal. 

(e) IHF Siting Plan. 

(f) Physical Security Plan. 

c. SSHP. 

(1) Prior to performing on-site work, a SSHP will be prepared IAW the requirements of 

29 CFR 1910.120(b)(4), 29 CFR 1926.65(b)(4), ER 385-1-92, and ER 385-1-95. 

(2) The SSHP will be prepared IAW contract requirements. The SSHP will discuss the 

topic areas provided below. 

(a) Introduction. A reference to the Work Plan is sufficient to direct readers to detailed 

information on the site description; project scope and objectives; and staff organization, 

qualifications and responsibilities. 

(b) Staff Organization, Qualifications, and Responsibilities. 

(c) Activity Hazard Analysis and Risk Assessment per task. 
EP 75-1-3 

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(d) Training. 

(e) Personal Protective Equipment. 

(f) Medical Support. 

(g) UXO Safety. 

(h) Radiation Dosimetry. 

(i) Environmental and Personnel Monitoring. 

(j) Site Control. 

(k) Personnel and Equipment Decontamination. 

(l) Emergency Response and Contingency Procedures (on-site and off-site). 

(m) Confined Space Entry. 

(n) Spill Containment. 

(o) Site Description and Contamination Characteristics. 

(p) Heat/Cold Stress Monitoring. 

(q) Standard Operating Procedures (include as a separate document). 

(r) Accident Prevention. 

(s) Logs, Reports, and Record Keeping. 

(3) This outline presents the subcomponents required for each of the topic areas listed 

above. Chapter 8 of this pamphlet provides more detailed information on the safety 

considerations for RCWM response actions. 

d. Supporting Plans. This section discusses the supporting plans required in the Work 

Plan. These plans, which are prepared by government agencies, include: TEU Assessment 

Plan; Air Monitoring and Analysis Plan; Environmental Media Sampling and Analysis Plan; 

Public Evacuation or Shelter-in-Place Plan; and PMNSCM Plans. At the time a SOW is 
EP 75-1-3 

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 7-5 

provided to the contractors, a SOW is issued to TEU, ECBC (or equivalent support 

organization), and PMNSCM to initiate the preparation of the supporting plans. Supporting 

plans can be provided in a separate volume from the Work Plan. 

(1) TEU Operations. 

(a) This plan is prepared by the TEU and includes their standard operating procedures 

(SOPs), Operational Orders, and specific equipment operations manuals that will be used to 

support the cleanup efforts. 

(b) TEU’s responsibilities generally include the following tasks: 

• Coordinate and provide input to the Work Plan. 

• Calculate the downwind hazard areas using D2PC. 

• Aid contractor in the excavation activities within the EZ when non-MEC items are 

being excavated. 

• Assess munitions with unknown fillers. 

• Package munitions with unknown fillers. 

• Transport munitions with unknown fillers. 

(c) SOPs for Specific Items. The following SOPS, as applicable, must be located onsite: 

• EOD Response to Ordnance Items. 

• Use of the Portable Isotopic Neutron Spectroscopy (PINS). 

• Use of the Raman spectrometer. 

• Packaging. 

• X-Ray Procedures. 

• Assessment/reassessment. 
EP 75-1-3 

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(2) Air Monitoring and Analysis Plan. The Air Monitoring and Analysis Plan will 

describe air monitoring and analysis methodologies for chemical agent and, if required, 

industrial chemicals, and will discuss the following topics: 

(a) Purpose, scope, and objectives of sampling and analysis. 

(b) Responsibilities of the air monitoring and analysis personnel. 

(c) Monitoring and analysis terms. 

(d) Terms. 

(e) Types of monitoring to be used. 

(f) Monitoring/analysis procedures, including: 

• Process controls. 

• Near real time monitoring. 

• Confirmation/historical monitoring. 

• Soil headspace analysis procedure. 

• Headspace analysis procedures for scrap, PPE, and bulk items 

• Background (general area) monitoring. 

(g) Monitoring record maintenance. 

(h) Quality control. 

(3) Environmental Media Sampling and Analysis Plan. The Environmental Media 

Sampling and Analysis Plan will describe sampling methodologies for sampling and analysis 

of environmental media for chemical agents and degradation products, and will discuss the 

following topics: 

(a) Purpose, scope, and objectives of environmental media sampling and analysis. 

(b) Responsibilities of the air monitoring and analysis personnel. 
EP 75-1-3 

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(c) Sampling/analysis procedures, including: 

• Analytes of concern. 

• Analytical methods and procedures. 

• Quality control. 

• Data reporting. 

• Sampling/analysis record maintenance. 

(4) Public Evacuation or Shelter-in-Place Plan. The USACE District, in close 

coordination with the CW-DC, will be responsible for these plans, as necessary. These plans 

will discuss the logistics of evacuation and alarm procedures, as required. 

(5) PMNSCM Plans. The PMNSCM Plans are composed of the following sub-plans: 

(a) IHF Plan. The IHF Plan will address all matters concerning the temporary storage 

of recovered RCWM. This includes the physical location, design, physical security, 

equipment requirements, personnel training requirements, monitoring requirements, 

descriptions of all necessary activities required during operation, and surveillance 

requirements. 

(b) Transportation Plan. The Transportation Plan will address all transportation matters 

concerning the movement of the RCWM item(s) from the EZ to the IHF and from the IHF to 

the final destination point. 

(c) Disposal Plan. The Disposal Plan will be provided by PMNSCM for the CSS. 

e. Chemical Safety Submission. A detailed outline for the CSS is provided in 

Appendix C. 

(1) The CSS is intended for this document to be a “stand-alone” document from the 

Work Plan and other supplemental plans for the project. 

(2) This plan is based on the Work Plan and supplemental plans, so those plans must be 

complete before the CSS can be completed. The overall length of the plan shall not exceed 50 

single-sided pages. 
EP 75-1-3 

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 7-8 

(3) The CSS is intended to provide those reviewing and approving agencies the 

necessary technical information, as required in the DA Interim Guidance of 1997. This 

outline has been agreed to by USAESCH and USATCES. No substantive changes will be 

made without the approval of the MM CX. 

(4) Document control is positively essential during the drafting, editing, and publishing 

of this CSS. Each page must have a footer that identifies the document, either original date or 

date of the latest change. Additionally, a sheet shall be inserted into the front of the document 

that specifies the latest dates and changes. All changes to the original document will leave the 

bars in the outside margins to identify change locations throughout the document. 

(5) It is intended for this document to include the necessary information required for an 

ESS as well, should it be necessary for the conduct of site operations for the RCWM 

activities. 

(6) The CSS will contain an Executive Summary and the following chapters: 

(a) Introduction. 

(b) Sampling Plan Summary. 

(c) Air Monitoring Plan Summary. 

(d) PPE and Decontamination Summary. 

(e) Medical Support Summary 

(f) Public Protection Plan Summary. 

(g) IHF Siting Plan Summary. 

(h) MEC Transportation Plan Summary. 

(i) RCWM Transportation Plan Summary. 

(j) Engineering Controls Summary. 

(k) Post-Recovery Assessment Activities Summary. 
EP 75-1-3 

30 Nov 04 

 7-9 

7-3. Review and Approval. Coordination, review and approval of CSSs and corrections or 

amendments to CSSs will be submitted IAW DACS-SF Memorandum, Approval of Safety 

Submissions for Non-Stockpile Chemical Warfare Materiel (RCWM) Response Activities, 29 

Feb 00. A flow chart summarizing the review/approval process and timeline for CSSs is 

shown in Figure 7-1. 

7-4. Amendments. Amendments to CSSs shall be signed by the same signatories (offices or 

agencies) as the original CSS. 

7-5. Corrections. Corrections to CSSs are those changes that do not adversely affect worker 

or public safety. Corrections are typically administrative changes and will be initiated by the 

MACOM with overall responsibility for the CWM activity. Corrections require coordination 

with all support agencies and are approved by the MACOM with overall responsibility for the 

CWM activity. Copies of the corrections will be provided for information to all support 

agencies, USATCES, DA Safety, and DDESB. 
EP 75-1-3 

30 Nov 04 

 7-10 

Figure 7-1. Flow Chart and Timeline for Chemical Safety Submissions for RCWM Projects 

Corps 

District

PMNS

MACOM

ECBC/TEU

USATCES

RDECOM 

(ECBC)

TEU

CESO-E

Regulators

PMNS

District PM

USAESCH

Customer6

Notes:1. Review and comment.2. DDESB Reviews and approves on Active Installations, and provides concurrence on FUDS.3. Final Document to USATCES (4 copies) 60 days prior to start of work (include written concurrences from TEU, ECBC, PMNS, and District)4. USATCES will send copies to DDESB and DA Safety for final review and approval5. Once final approval has been granted, PMNS may take the CSS to DHHS for concurrence.6. Work for BRAC, IR, and Others will have the Installation, MACOM Safety Office, and appropriate service Staff involved in the process as well.7. The USAESCH Table Top and Huntsville Pre-Op may be conducted during the last two weeks the CSS is at DDESB awaiting approval, MACOM Pre-Op will be conducted the week following DA 

approval.

8. Ensure USATCES involvement in the project at the Conceptual Site Plan Phase I.9. USAESCH will host an On Board Review (OBR), this review will replace the Draft Final stage of the CSS. Attendees at the OBR need to be individuals that can make decisions for the agency 

involved. The intent is to come out of the OBR with a Final Document and signed copies of the concurrence memos and to send the CSS directly to USATCES/DA.

USATCES4 HQDA, Army Safety Office

Army

Approval5

USAESCH USAESCH

PMNS

USATCES

Regulators

TEU

MACOM

District PM

Customer

RDECOM (ECBC)

Begin Site

Operations

Project

Recognized

Defining Goals

For Project Develop SOW Award Contract Begin Project Conceptual Plan8

(Approximately 10 weeks)

2 weeks 2 weeks 4 weeks 2 weeks

Phase 2 (Approximately 18 weeks)

Design CSS

Preparation Draft

4 weeks6

Review and

Comment 

Period1

6 weeks

On Board Review9

Final Document upon

Completion w/

Concurrence Memos

1 week

Table-Top

Huntsville Pre-Op

MACOM Pre-op7

3 weeks

Phase 1

Draft Final

HQDA, DA Level 

Review 2 weeks, then

DDESB – 4 weeks

MM-CX

sends 4 copies

of Final to

USATCES

DDESB2

USAESCH

Corps 

District

PMNS

MACOM

ECBC/TEU

USATCES

RDECOM 

(ECBC)

TEU

CESO-E

Regulators

PMNS

District PM

USAESCH

Customer6

Notes:1. Review and comment.2. DDESB Reviews and approves on Active Installations, and provides concurrence on FUDS.3. Final Document to USATCES (4 copies) 60 days prior to start of work (include written concurrences from TEU, ECBC, PMNS, and District)4. USATCES will send copies to DDESB and DA Safety for final review and approval5. Once final approval has been granted, PMNS may take the CSS to DHHS for concurrence.6. Work for BRAC, IR, and Others will have the Installation, MACOM Safety Office, and appropriate service Staff involved in the process as well.7. The USAESCH Table Top and Huntsville Pre-Op may be conducted during the last two weeks the CSS is at DDESB awaiting approval, MACOM Pre-Op will be conducted the week following DA 

approval.

8. Ensure USATCES involvement in the project at the Conceptual Site Plan Phase I.9. USAESCH will host an On Board Review (OBR), this review will replace the Draft Final stage of the CSS. Attendees at the OBR need to be individuals that can make decisions for the agency 

involved. The intent is to come out of the OBR with a Final Document and signed copies of the concurrence memos and to send the CSS directly to USATCES/DA.

USATCES4 HQDA, Army Safety Office

Army

Approval5

USAESCH USAESCH

PMNS

USATCES

Regulators

TEU

MACOM

District PM

Customer

RDECOM (ECBC)

Begin Site

Operations

Project

Recognized

Defining Goals

For Project Develop SOW Award Contract Begin Project Conceptual Plan8

(Approximately 10 weeks)

2 weeks 2 weeks 4 weeks 2 weeks

Phase 2 (Approximately 18 weeks)

Design CSS

Preparation Draft

4 weeks6

Review and

Comment 

Period1

6 weeks

On Board Review9

Final Document upon

Completion w/

Concurrence Memos

1 week

Table-Top

Huntsville Pre-Op

MACOM Pre-op7

3 weeks

Phase 1

Draft Final

HQDA, DA Level 

Review 2 weeks, then

DDESB – 4 weeks

MM-CX

sends 4 copies

of Final to

USATCES

DDESB2

USAESCH
EP 75-1-3 

30 Nov 04 

 8-1 

CHAPTER 8 

Safety and Health Considerations 

8-1. Introduction. 

a. This chapter discusses the safety and health considerations for planning and 

executing a RCWM response action. 

b. Safety is the primary consideration in all RCWM response actions. Detailed safety 

and health practices and procedures must be developed and implemented at each site to 

provide proper control of and protection against the unique safety hazards associated with 

specific on-site activities. All RCWM response activities will be planned and conducted IAW 

the requirements of this section, will be thoroughly coordinated with the MM CX, and will 

include participation of explosives safety technical personnel. 

8-2. Policy. 

a. All USACE and contractor elements will conduct RCWM response actions in 

compliance with regulations and guidance publications referenced below. Additionally, 

safety and occupational health documentation will comply with other applicable Federal, 

state, and local safety and occupational health requirements. 

b. The contractor shall develop a SSHP IAW the requirements of EM 385-1-1, 

AR 385-61, and other applicable Federal, state, and local safety and health requirements. The 

SSHP will be included in the Work Plan IAW ER 385-1-95. The level of detail provided 

shall be tailored to the type of work, complexity of operations to be accomplished, and the 

hazards anticipated. The SSHP shall address those elements, which are specific to the site, 

and have the potential for negative effects on the safety and health of workers according to the 

requirements detailed in Section 28.A.02 of EM 385-1-1. Where a specific element is not 

applicable, list the element in the plan and state that the element is not applicable with a brief 

justification for its omission. The SSHP shall be an implementing document with emphasis 

on “who” will have each of the specific responsibilities and “how” and “when” each of the 

applicable requirements will be performed. The prime contractor shall integrate all 

subcontractor work activities into the SSHP, make the SSHP available to all contractor and 

subcontractor employees, and ensure that all subcontractors integrate provisions of the SSHP 

in their work activities. Daily safety and health inspections shall be conducted to determine if 

site operations are conducted IAW the accepted plans and contract requirements. The SSHP 
EP 75-1-3 

30 Nov 04 

 8-2 

may serve as the Accident Prevention Plan provided it addresses all content requirements of 

EM 385-1-1. 

8-3. Staff Organization, Qualifications, and Responsibilities. 

a. The contractor shall summarize the operational and health and safety responsibilities 

and the qualifications for each key person identified in the SSHP. The organizational 

structure, with lines of authority and overall responsibilities for the safety and health of the 

contractor employees and all subcontractors, shall also be discussed and an organizational 

chart showing the lines of authority for safety shall be provided. Each person assigned 

specific safety and health responsibilities shall be identified and his/her qualifications and 

experience documented using a résumé in the SSHP. 

b. The contractor is responsible for having as many of the professionals – Certified 

Industrial Hygienist (CIH), Certified Safety Professional (CSP), or Certified Health Physicist 

(CHP), involved in the design, review and approval (in their respective fields of expertise) of 

the SSHP. The approving individual(s) will sign and date the SSHP attesting to their 

approvals. Not all of these professionals may be required to review and approve the SSHP. It 

is a corporate responsibility and liability to ensure the appropriate review is done and 

signatures obtained. 

c. A UXO individual, meeting the personnel requirements of EP 1110-1-18 for a UXO 

Safety Officer (UXOSO) or Senior UXO Supervisor (SUXOS), shall also sign the SSHP. The 

SUXOS shall have experience with RCWM-related activities commensurate with the specific 

project. 

d. A UXOSO, meeting the personnel requirements set forth in EP 1110-1-18, shall be 

used at all RCWM projects. In addition, the UXOSO shall have experience with RCWMrelated activities commensurate with the specific project. The contractor shall provide the 

UXOSO’s résumé as requested by the CO. 

e. At least two persons currently certified in First Aid and Cardiopulmonary 

Resuscitation (CPR) by the American Red Cross or equivalent agency, IAW EM 385-1-1, 

shall be present on-site at all times during site operations. During operations when two 

medical support personnel such as paramedics or emergency medical technicians and an 

ambulance are dedicated to the project and are on-site, the contractor does not have to have 

the two first aid attendants/CPR qualified persons on-site. During the operations when the 
EP 75-1-3 

30 Nov 04 

 8-3 

medical support is not required to be on-site, the contractor must have two first aid/CPR 

trained persons on-site. 

8-4. Site Description and Contamination Characterization. Provide a description of the site 

based on results of previous studies, site history, and prior uses and activities. Compile a 

summary of hazardous substances and safety and health hazards likely to be encountered onsite. Include ordnance and chemical/biological, concentration ranges, media in which found, 

locations on-site, and estimated quantities/volumes to be impacted by this work. The site 

descriptions shall be based on results of previous studies and the history of prior uses and 

activities conducted under the Site Visit task of the SOW. 

8-5. Hazard Analyses and Risk Assessment. 

a. Identify each task and/or operation to be performed. Identify the ordnance, safety, 

chemical, physical, radiological and/or biological hazards of concern presented by each task 

and/or operation as indicated below. EM 385-1-1 provides details concerning activity hazard 

analysis preparation. The tasks and hazard/risk analyses shall be modified as needed to 

address changing work conditions. 

(1) Ordnance. Identify potential ordnance/UXO items that may be encountered and 

necessary steps to mitigate the hazards. If there is the potential for UXO and UXO disposal is 

part of the assigned tasks, identify the hazards associated with the explosive disposal of the 

UXO. 

(2) Safety. Evaluate the potential for injury from all site conditions and activities (e.g., 

excavations, slips, trips and falls, electricity, equipment and machinery, etc.). Reference 

EM 385-1-1. 

(3) Chemical. List the chemical hazards that may be encountered during site activities 

and evaluate the chemical, physical, and toxicological properties of the chemicals. Describe 

the sources and pathways of employee exposure and anticipated on-site and off-site exposure 

levels. Address Federal, state, and local regulations or recommended exposure standards. 

Address employee exposure to hazardous substances bought on-site for the execution of site 

activities. 

(4) Physical. Evaluate the potential for injury from physical hazards such as noise, heat 

and cold stress, vibration, etc., that may be present. 
EP 75-1-3 

30 Nov 04 

 8-4 

(5) Radiological. Evaluate the risk to human health caused by radioactive materials or 

ionizing radiation fields in the area where work is to be performed. Consider the presence of 

radioactive isotopes and the type of ionizing radiation they emit. Describe the sources and 

pathways of employee internal exposure and anticipated on-site and off-site internal and 

external levels. Address Federal, state, and local regulations or recommended exposure 

standards. 

(6) Biological. Evaluate the potential for illness or injury due to biological hazards 

(e.g., poisonous plants, animals, insects, microorganisms). 

b. Establish action levels and methods to mitigate the hazards noted above for the 

situations listed below. Action levels and required actions shall be presented in text and 

tabular forms. 

(1) Implementation of engineering controls and work practices. 

(2) Upgrades/downgrades in levels of PPE. 

(3) Work stoppage and/or emergency evacuation of on-site personnel. 

(4) Prevention and/or minimization of public exposures to hazards created by site 

activities. 

c. At some projects, a site may be determined to be “non-RCWM” by a risk 

assessment IAW the applicability Memorandum of the Interim Guidance for Biological 

Warfare Material (BWM) and Non-Stockpile RCWM Response Activities. Sites that are 

determined not to be suspect RCWM sites by the applicability memorandum may still have 

chemical agent hazard present. On these sites, the contractor must determine the probability 

of worker exposure to chemical agent and make a recommendation as to whether agent 

monitoring and on-site medical support is necessary. If the contractor is tasked to perform the 

chemical agent monitoring, they must recommend the type of monitoring to be performed, the 

instrument(s) to be used, the frequency of monitoring, the action levels, actions to be taken, 

and other requirements described in Section 8-12 of this chapter. 

8-6. Training. All personnel performing on-site work activities, wherein they may be 

exposed to hazards resulting from hazardous waste site operations, shall have completed 

applicable training in compliance with 29 CFR 1926, 29 CFR 1910.1200, AR Pam 385-61, 

DA Pam 385-61, DA Pam 40-8, DA Pam173, and EM 385-1-1. Prior to performing on-site 
EP 75-1-3 

30 Nov 04 

 8-5 

activities in contaminated areas (Contamination Reduction Zone and EZ), personnel shall 

successfully complete the following: 

a. A minimum of 40 hours of HTRW health and safety instruction of the site. 

b. Three days of actual field experience under the direct supervision of a trained, 

experienced supervisor, and eight hours of refresher training annually. 

c. All on-site supervisors shall complete the above requirements and an additional 

eight-hour supervisor’s course. 

d. Site-Specific Training. 

(1) Generally, on non-stockpile sites, the following information is covered during the 

site-specific training prior to the start of work on-site. A qualified instructor (qualified IAW 

29 CFR 1910-120(e)(5)) from either the contractor or RDECOM will provide the training. 

This training is conducted annually for long-term activities. Employees will be trained in the 

following items at the beginning of each response action: 

(a) Names of persons and alternates responsible for site safety. 

(b) Safety, health, and other hazards known to be on the site. 

(c) Use of PPE. 

(d) Work practices to minimize hazards. 

(e) Safe use of equipment and other controls on-site. 

(f) Medical surveillance requirement. 

(g) Decontamination procedures (if necessary). 

(h) An emergency response plan. 

(i) Confined space entry procedures (if applicable). 

(j) A spill containment program (if applicable). 
EP 75-1-3 

30 Nov 04 

 8-6 

(2) Additional site-specific training covering site hazards, procedures, and all contents 

of the approved SSHP will be conducted by the UXOSO. This training will be provided for 

all on-site employees, including those assigned only to the Support Zone, prior to the 

commencement of work; for visitors prior to entering the site; and on a continual basis. 

e. The UXOSO shall be responsible for maintaining a list of training records and 

expiration dates of applicable training for all on-site personnel (including government 

workers). 

f. The UXOSO shall notify each organization’s on-site supervisor if a site worker’s 

training has expired. 

g. Each agency shall be responsible for maintaining a copy of the training 

certification(s) on-site. The CO or a representative of the CO may request to review the 

training certification at any time. 

8-7. Team Training and Pre-Start Exercises. 

a. It is critical that each organization and member of the PDT understand their roles 

and responsibilities within the project framework. The proper chain of command and lines of 

communication must be followed to ensure safe and successful project execution. PDT 

knowledge and procedure will be tested during a tabletop exercise and pre-operational survey 

(pre-op) preceded by a USAESCH-conducted training exercise. USAESCH personnel will 

conduct training one week prior to the scheduled start date of the tabletop and pre-op. The 

USAESCH training is typically five days in duration. All equipment must be on-site, and all 

other site-specific training must be completed prior to initiation of the USAESCH training. It 

is the responsibility of each organization to ensure that when their workers are rotated out 

during a project that the information gained during the exercises is communicated to new site 

personnel. 

b. Table Top Exercise. 

(1) A table top exercise is required by Army regulation to be completed prior to the start 

of a chemical agent project. According to the Interim Guidance for BWM and Non-Stockpile 

RCWM Response Activities, the table top exercise will be conducted by the Major Command 

(MACOM) with overall responsibility for the activity. USAESCH will conduct the table top 

exercise as requested by the USACE District. Participants will include all on-site support 

agencies and any local responders that are supporting the project. 
EP 75-1-3 

30 Nov 04 

 8-7 

(2) The table top exercise is generally conducted in a “conference room” and usually 

lasts between two and six hours, depending on the project size and interest. This open 

discussion will take place in a non-threatening environment. It is an exercise utilizing 

simulations to conduct drills of emergency response to different CWM accident and incident 

scenarios. The purpose of the table top exercise is to ensure the effectiveness of the responses 

and to identify deficiencies or omissions in the emergency response process. It is also used to 

establish continuity and coordination among response agencies. 

c. Pre-Operational Survey (Pre-Op). 

(1) A Pre-Op is required by DA Pam 385-61 prior to the startup of any chemical 

operation. The Pre-Op will be conducted IAW the plan included in Appendix D. 

(2) The Pre-Op is conducted on-site and usually lasts between three and four days. 

Close coordination between the MM CX and the CW-DC is essential in successfully 

executing the Pre-Op. The purpose of the Pre-Op is to evaluate the PDT’s readiness to 

perform the chemical/explosives operations associated with the RCWM project. This is 

achieved by having a Pre-Op survey team comprised of subject matter experts from groups 

such as USACHPPM and from each agency responsible for executing on-site RCWM 

activities (e.g., TEU, ECBC, PMECW, PMNSCM, CESO, USATCES, and the USAESCH 

MM CX). The MM CX subject matter expert will act as the Survey Team Leader for the PreOp). Not all disciplines may be able to participate but a minimum of three persons will 

comprise the Survey Team: one from the USAESCH MM CX (the Survey Team Leader), one 

from USATCES, and at least one other member from the agencies involved in the chemical 

operation. 

(3) It is critical to note the Pre-Op is not a training exercise for the PDT. All required 

training must be accomplished prior to the Pre-Op. The Pre-Op is an evaluation and, as such, 

is subject to failure. If the PDT fails the Pre-Op, they will not be permitted to begin chemical 

operations until they are able to satisfactorily complete another Pre-Op survey. 

8-8. Personal Protective Equipment. 

a. The PPE program shall be included in the SSHP. The contractor shall describe in 

detail and provide appropriate PPE to ensure workers, official visitors, and government 

employees are not exposed to levels greater than the action level for identified hazards for 

each operation and work zone. The program shall address: 
EP 75-1-3 

30 Nov 04 

 8-8 

(1) All the elements of 29 CFR 1910.120(g)(5), 29 CFR 1910.134, and 29 CFR 

1910.132. 

(2) Minimum levels of protection necessary for each task/operation to be performed at 

each site based on probable site conditions, potential occupational exposure, and the hazard 

analysis/risk assessment required above. Levels of protection must be relevant to site-specific 

conditions including heat stress and associated PPE safety hazards. Include specific types and 

materials for protective clothing and respiratory protection. 

(3) Establish and justify upgrade/downgrade criteria based upon the action levels 

established as required by Section 8-5 of this chapter (as a minimum) and as appropriate. 

(4) Provide site-specific procedures to determine PPE program effectiveness and for onsite fit-testing of respirators, proper cleaning, maintenance, inspection, and storage of all PPE. 

b. DA Safety has issued a blanket approval that has several types of respirators and 

protective suits that are approved for use against agent under certain conditions. A copy of 

this blanket approval is found in Appendix E. If the contractor’s PPE or task is not listed in 

this blanket approval, the contractor shall prepare and submit for approval a PPE matrix. In 

this matrix, the contractor shall discuss Level A & B suits and respirators to use on-site and 

the scenarios. The format for this matrix can be obtained from the CEHNC Safety Office. 

The PPE matrix will be a separate submittal and is not part of the CSS. Several level A & B 

suits, and respirators, have already been approved by the Army for use at RCWM projects. 

c. Chemical Protective Undergarments (CPUs) are charcoal impregnated garments 

worn under an outer chemical resistant suit. DA Memorandum, Chemical Protective 

Undergarment (CPU) Service-Live, (17 Sep 02) states that all CPUs used by RDECOM 

chemical workers have a 15-day service life. CPUs must be disposed 15 days after they have 

been removed from the original package, regardless of the number of time they have been 

worn, remaining shelf life on them, or if they have been laundered less than six times. CPUs 

may still be laundered up to six times during the 15-day service life period. CPU shelf live is 

12 years for garments in unopened, original packages. 

(1) CPU managers shall mark each CPU label with the day, month, and year that the 

original package was opened. The garment must be disposed no later than 15 days after the 

marked date. CPU garments removed from their original package but not marked with the 

package removal date will be disposed immediately. 
EP 75-1-3 

30 Nov 04 

 8-9 

(2) CPUs must be stored in sealable plastic bags when not in use during the 15-day 

service life. This will reduce exposure of the garments to airborne contaminants that could 

degrade the chemical protective properties of the CPU fabric. 

8-9. Medical Support. 

a. This section discusses medical support arrangements made for the treatment of 

chemical casualties. The signed Memorandum of Agreement (MOA)/Contract for hospital 

and on-site medical support shall be maintained on-site by the UXOSO. The UXOSO shall 

also maintain a roster of the medical support personnel who have been trained in chemical 

agent casualty care. 

b. All personnel performing on-site activities shall participate in an ongoing medical 

surveillance program meeting with the requirements of 29 CFR 1910.120. If chemical agent 

is a suspect site contaminant, the requirements in DA PAM 40-8 and/or 40-173 shall apply. 

The medical examination protocols and results shall be overseen by a licensed physician who 

is certified in Occupational Medicine by the American Board of Preventive Medicine or who 

by necessary training and experience is board eligible. Minimum specific examination 

content and frequency, based on probable site conditions, potential occupational exposures, 

and required protective equipment shall be specified. 

c. Each agency shall be responsible for maintaining a copy of the physician’s medical 

opinion assessing the fitness to perform work on-site. The written medical opinion from the 

examining physician as to fitness to perform the required work shall be made available to the 

CO upon request for any site employee. 

d. The UXOSO shall be responsible for maintaining a list of medically qualified 

personnel and the examination dates for all on-site personnel. 

e. On-Site Support. In general, as a minimum, a State or National Registry of 

Emergency Medical Technician-certified paramedic, with special training in chemical warfare 

agent casualty care, will be available at each site during site characterization, excavation, 

transportation and/or disposal operations, along with a vehicle designated for use in patient 

transport. A MOA or a contract which contains all of the wording contained in the MOA will 

be developed and signed by both the medical provider and the contractor prior to the state of 

intrusive work on site. 

f. Medical Treatment Facility. A MOA will be developed with a medical treatment 

facility that is capable of handling site injuries. 
EP 75-1-3 

30 Nov 04 

 8-10 

8-10. UXO Safety. If explosively configured RCWM or conventional MEC is expected, the 

provisions of EP 385-1-95a, EP 1110-1-18, and EM 1110-1-4009 will be adhered to 

concerning personnel qualifications, demolition activities, safety, use, and storage of 

explosives, and disposal of same (if tasked in the SOW). 

8-11. Radiation Dosimetry. 

 a. All employees working within a radiological restricted area shall receive appropriate 

dosimetry monitoring for radiation exposure. 

b. Radiation dosimetry shall be evaluated by an individual holding current personnel 

dosimetry accreditation from the National Voluntary Laboratory Accreditation Program 

(NVLAP). Electronic dosimetry may be used to assign external dose if approved by the 

Qualified Health Physics personnel. 

c. All employers shall document employee exposure to external radiation. In order to 

do this, employers shall review each employee’s radiation exposure history per 10 CFR 

20.2104 for compliance with exposure standards prior to allowing the employee access to a 

restricted area. If the employee has no exposure history, the employee shall provide a signed 

written statement to that effect. 

d. When possibility of internal radioactive contamination exists, employers shall 

estimate exposure with a bioassay program. The bioassay program will provide sampling of 

employees’ nasal passages, urine and/or feces, or whole body counting, as appropriate to 

evaluate the suspected radionuclides. Air monitoring will be used to estimate inhalation 

exposure to suspected radionuclides. 

e. Reports of Exposure to Ionizing Radiation will be furnished: 

(1) To each employee: 

(a) At least annually; 

(b) Upon termination, and; 

(c) Within 30 days of any personal request. 

(d) Whenever an unusual event occurs or a significant dose is received by either an 

extremity or the whole body. 
EP 75-1-3 

30 Nov 04 

 8-11 

(2) To the Radiation Safety Officer (RSO) as soon as available. 

8-12. Environmental and Personal Monitoring. 

 a. This section in the SSHP will include all information on air monitoring (agent and 

industrial) to be conducted on-site. Chemical agent monitoring shall use protocols approved 

in the Work Plan and the action levels will be IAW AR 385-61 and DA Pam 385-61. If 

ECBC is responsible for conducting the agent monitoring, the contractor shall coordinate with 

them. 

 b. An air monitoring summary shall be included in this section. This table shall 

include, but is not limited to, the following: contaminant of concern (agent and industrial), 

instrument to monitor, location of instrument, frequency, agency conducting monitoring, 

action level, and actions to be taken. 

c. Where it has been determined that there may be employee exposures to on and/or off 

site migration potentials of hazardous airborne concentrations of hazardous substances, 

appropriate direct reading (real-time) air monitoring and integrated (time weighted average) 

air sampling shall be conducted IAW applicable Federal, state, and local requirements. Both 

air monitoring and air sampling must accurately represent concentration of air contaminants 

encountered on and leaving the site. The types and frequency of monitoring/sampling to be 

performed shall be specified for on-site and perimeter, where applicable. Where perimeter 

monitoring is not deemed necessary, provide suitable justification for its exclusion. When 

applicable, National Institute for Occupational Safety and Health (NIOSH) and/or EPA 

sampling and analytical methods shall be used. Laboratories successfully participating in and 

meeting the requirements of the American Industrial Hygiene Association’s (AIHA) 

Proficiency Analytical Test (PAT) or laboratory Accreditation Program, where necessary, 

shall analyze personal samples. Include, as appropriate, real-time (direct-read) monitoring 

and integrated Time Weighted Average (TWA) sampling for specific contaminants of 

concern, meteorological, noise, and radiation monitoring shall be conducted, as needed 

depending upon the site hazard assessment. All monitoring and sampling protocol shall be 

specified to include instrumentation to be used and calibration of instruments. All monitoring 

and sampling protocol shall be specified to include instrumentation to be used and calibration 

of instruments. All monitoring results shall be compared to action levels to determine the 

need for corrective actions. 
EP 75-1-3 

30 Nov 04 

 8-12 

8-13. Site Control. The contractor shall describe site control measures, which include site 

maps, the work zone delineation and access points, the on and off site communication system, 

general site access controls, and physical security procedures. 

 a. The EZ at RCWM projects is the area within the boundaries of the NOSE and/or the 

fragmentation distances for the MGFD, whichever is greater. 

 b. Personnel Within The 1 Percent Lethality Zone. 

(1) Only personnel who are essential to accomplish the work are allowed to work inside 

the 1% lethality zone. 

(2) Only UXO-qualified personnel will be used to perform procedures related to MEC 

that include, but are not limited to, gaining access to (manual excavation) and identifying 

subsurface anomalies, assessing surface MEC, and recovering MEC. UXO-qualified 

technicians will make final disposition of all MEC items IAW applicable guidance. 

c. The OE Safety Specialist is responsible for ensuring safety and for reviewing 

changes or adjustments to any of the EZs established for a site. The OE Safety Specialist may 

adjust operational procedures that do not constitute a change to the CSS. Under emergency 

conditions, the OE Safety Specialist may invoke changes to ensure increased worker safety 

and public protection. The OE Safety Specialist will document and notify the PM, the CWDC, and the RCWM PDT of changes or adjustments as soon as possible. 

8-14. Personnel and Equipment Decontamination. 

a. The contractor shall develop and specify decontamination procedures with 29 CFR 

1910.120 for personnel, PPE, monitoring instruments, sampling equipment, and other 

equipment used on-site. Decontamination procedures shall address specific measures to 

ensure that contamination is confined to the work site. Necessary facilities and their 

locations, detailed SOPs, frequencies, supplies, and materials to accomplish decontamination 

of site personnel and to determine adequacy of equipment decontamination shall be discussed. 

b. Location of the Personnel Decontamination Station (PDS). 

(1) The PDS will be located outside the NOSE distance. Exceptions to this rule might 

be required and should be reviewed on a case-by-case basis. 
EP 75-1-3 

30 Nov 04 

 8-13 

(2) An Emergency PDS will be established as close to the work site as possible so that 

any gross contamination can be removed. 

(3) The location of the PDS will be based on the more restrictive of: 

(a) The MCE of the site based on the worst possible weather conditions; or 

(b) Actual meteorological conditions. 

(4) If actual meteorological conditions are used, they must be monitored hourly, and the 

NOSE distance must be calculated hourly using D2PC. If actual conditions cause the PDS to 

be within the NOSE distance, work must stop until the conditions improve or the PDS must 

be moved outside the NOSE distance. 

(5) The PDS will never be established within the fragmentation zone as described in AR 

385-64, unless approved engineering controls are used. 

c. Chemical Casualty Personnel Decontamination Monitoring. Provisions will be 

made for air monitoring at the PDS. In the event that a chemical casualty is suspected, the 

casualty will be monitored before crossing the hotline. The monitoring will be performed 

after the casualty has been processed through the PDS and is performed after three washes to 

verify adequate decontamination (i.e., less than 1 TWA – the workplace airborne exposure 

limit). Monitoring will be performed using a low-level air monitoring device, such as a 

MINICAMS, to detect any evidence of agent vapor off-gassing. Once monitoring has 

confirmed adequate decontamination, transfer of the suspected casualty to the support zone is 

permitted in order that they can be treated by medical personnel. 

d. PPE Within The 1 Percent Lethality Zone. 

(1) All personnel working within the 1 Percent Lethality Zone must wear the same level 

of PPE. Personnel outside of the 1 Percent Lethality Zone, but within the NOSE distance, 

may be in modified Level D PPE with slung masks. All personnel working in the 1 Percent 

Lethality Zone must also be protected from fragmentation, if at all possible. 

(2) Support personnel, such as the cascade operator, may be in collective protection 

(such as a tent). PPE and collective protection will be furnished by the supporting 

organization; e.g., TEU or ECBC. 
EP 75-1-3 

30 Nov 04 

 8-14 

8-15. Emergency Response and Contingency Procedures (On-site and Off-site). An 

Emergency Response Plan, as required by 29 CFR 1910.120 shall be developed and 

implemented. At a minimum, it shall address the following elements: 

a. Pre-emergency planning and procedures for reporting incidents to appropriate 

government agencies for potential chemical exposure, personal injuries, fire/explosions, 

environmental spills and releases, and discovery of radioactive materials. 

b. Personnel roles, lines of authority, and communications. 

c. Posted instructions and list of emergency contacts: physician, notified nearby 

medical facility, fire and police departments, ambulance service, state/local/Federal agencies, 

CIH, CSP, CHP, and CO. 

d. Emergency recognition and prevention. 

e. Site topography, layout, and prevailing weather conditions. 

f. Criteria and procedures for site evacuation, emergency alerting procedures/employee 

alarm system, emergency PPE and equipment, safe distance, place of refuge, evacuation 

routes, and site security and control. 

g. Specific procedures for decontamination and medical treatment of injured personnel. 

h. Route maps to nearest pre-notified medical facility. 

i. Public Safety. This section shall include a discussion on the MCE, NOSE distance 

(also known as the Public Withdrawal Distance), and the procedures to be used to keep the 

public outside the NOSE distance. The contractor, based on historical records, shall 

recommend an MCE to USAESCH. If a site has several operable units, an MCE shall be 

determined for each site. Documentation (downwind hazard calculations) from the D2PC 

modeling program shall be provided by USAESCH for inclusion into the plan. Criteria for 

initiating a community alert program, contacts, and follow-up shall also be discussed. The 

contractor shall discuss site methodology used to protect the public against site contaminants. 

This shall include, but is not limited to, air monitoring and evacuation procedures. 

Information regarding meteorological monitoring and daily D2PC calculations shall also be 

included in this section. 
EP 75-1-3 

30 Nov 04 

 8-15 

j. Material Safety Data Sheets (MSDS) for each hazardous substance anticipated to be 

encountered on-site shall be made accessible to site personnel at all times and shall be 

maintained on-site. Each agency shall be responsible for having and maintaining the required 

MSDS for the hazardous substances they bring on-site. The UXOSO shall ensure that all 

required MSDS are on-site and available to all on-site workers. 

8-16. Confined Space Entry. The contractor shall develop procedures for confined space 

entry IAW 29 CFR 1910.146. If no confined spaces exist on-site and there are no planned 

excavations that could result in a confined space, this section may be omitted. 

8-17. Spill Containment. Where major spills may occur, a spill containment program shall be 

implemented to contain and isolate the entire volume of the hazardous substance being 

transferred or stored. The program will be designed IAW 29 CFR 1910.120(j) and will be 

required for hazardous substances on the site as well as hazardous materials brought on to the 

site for use during the work process. 

8-18. Heat/Cold Stress Monitoring. Heat and cold stress monitoring protocols, as 

appropriate, shall be described in detail. Work/rest schedules shall be determined based upon 

ambient temperature, humidity, wind speed (wind chill), solar radiation intensity, duration and 

intensity of work, and protective equipment ensembles. Minimum required physiological 

monitoring protocols, which will affect work schedules, shall be developed. In cases where 

impervious clothing is worn, the NIOSH/OSHA/USCG/EPA, Occupational Safety and Health 

Guidance Manual for Hazardous Waste Site Activities, protocol for prevention of heat stress 

shall be followed and heat stress monitoring shall commence at temperatures of 70°F and 

above. Where impervious clothing is not worn, the American Conference of Governmental 

Industrial Hygienists (ACGIH) heat stress standard (TLV) shall be used. For cold stress 

monitoring to help prevent frostbite and hypothermia, the ACGIH cold stress standard shall 

be referenced and followed, as a minimum. 

8-19. Standard Operating Procedures, Engineering Controls and Work Practices. The 

contractor shall develop SOPs to protect field personnel, prevent accidents, minimize hazards, 

and to take action to correct hazards where necessary. Site rules and prohibitions for safe 

work practices shall be discussed and shall include such topics as use of the buddy system, 

smoking restrictions, material handling procedures, confined space entry, excavation safety, 

physiological and meteorological monitoring for heat/cold stress, illumination, sanitation, 

daily safety inspections, etc. This list of topics is not intended to be all-inclusive. 
EP 75-1-3 

30 Nov 04 

 8-16 

8-20. Accident Prevention. 

 a. The minimum basic outline for an Accident Prevention Plan is identified in 

EM 385-1-1. The plan shall be site specific and address any unusual or unique aspects of the 

project. 

 b. Daily safety and health inspections shall be conducted to ensure the effectiveness of 

the SSHP and determine if operations are being performed IAW the SSHP, USACE, and 

OSHA regulations, and contract requirements. 

 c. In the event of an accident/incident, the CO shall be notified IAW EM 385-1-1. 

d. The contractor shall complete and submit required accident reports within 2 working 

days of any reportable accident. 

e. If there is an accident involving radiation, the Radiation Protection Officer (RPO) 

for the USACE District or the Radiation Protection Staff Officer shall be notified. 

8-21. Emergency Equipment and First Aid Requirements. The following items, as 

appropriate, shall be immediately available for on-site use: 

a. First aid equipment and supplies IAW the recommendation of a licensed physician. 

b. Emergency eyewashes/shower (per ANSI Z – 358.1). 

c. Emergency-use respirators (escape and rescue). 

d. Spill control materials and equipment (see Section 8-17 of this chapter). 

e. Fire extinguishers (specify type, size, and locations). 

8-22. Logs, Reports, and Record Keeping. 

a. Record keeping procedures for training logs, daily safety inspection logs, 

employee/visitor registers, medical surveillance records and certifications, air monitoring 

results, and personal exposure records shall be specified. 

b. All personal exposure and medical monitoring records shall be maintained IAW 

applicable OSHA standards and CFRs 1904, 1910, and 1926. 
EP 75-1-3 

30 Nov 04 

 8-17 

c. The contractor shall develop, retain, and submit, as part of the final report, all visitor 

registration logs, training logs, and daily safety inspection logs (as part of the daily Quality 

Control (QC) Reports). 

d. The contractor shall maintain copies of the required training and medical certificates 

on-site and shall make them available for government inspection upon request. 

e. Accidents/incidents will be reported IAW EM 385-1-1. The following categories of 

accidents/incidents shall be reported to the CO by telephone or written report. 

(1) Accidents/Incidents which result in a fatality, injury of employees, lost workdays, 

and/or property damage assessed at a cost of $2,000 or more shall be reported by telephone to 

the CO as soon as possible after learning of the incident. The report shall contain as much 

information as is known concerning the incident. An ENG Form 3394 shall be completed 

IAW the instructions attached to the form and forwarded to the CO within 5 working days 

after the incident. The ENG Form 3394 shall be legible and signed by the supervisor of the 

person injured (or supervisor of the activity where property damage occurred) and by the next 

level of management. 

(2) The contractor shall immediately report to the CO any incident that could bring 

adverse attention or publicity to the USACE. 

(3) The contractor shall maintain a list of alternate POCs in the event the CO is not 

available. USAESCH will provide the alternate POCs. 

f. The Safety Exposure Report, a tabulation of field labor hours, lost workday accidents, 

and number of lost workdays shall be submitted monthly. (Note: This report does not negate 

the requirement to submit an ENG FORM 3394 to report an accident). The report shall 

include the following information: 

(1) Title of Report. 

(2) Month and year for which the report is made. 

(3) Contract Number/Task Order/Delivery Order/Project Name/Site Name and 

Location. Report each Task Order/Delivery Order on a separate line on the form. 
EP 75-1-3 

30 Nov 04 

 8-18 

(4) Hours worked in direct support of the contract (by all personnel) during the reported 

month, and cumulative. (Do not report hours expended on corporate personnel issues, 

payroll, etc. or hours expended by subcontract personnel in direct support of the contract.) 

(5) Total number of lost workday accidents during the reported month and cumulatively 

since task initiation. 

(6) Total number of lost workdays due to on-the-job accidents during the reported 

month and cumulatively since task initiation. 

(7) Number of property damage accidents (includes vehicles) with property loss value 

of $2,000 or more, during the reported month and cumulative since task initiation. 

(8) Signature, Title, and Date: A corporate manager shall sign and date the exposure 

data report along with the progress report. Both reports shall be submitted under a single 

letter of transmittal to the CO, with two copies furnished to USAESCH, ATTN: CEHNC-OES. 
EP 75-1-3 

30 Nov 04 

 9-1 

CHAPTER 9 

Environmental Sampling and Analysis 

9-1. Introduction. 

a. This chapter discusses the purpose, applicability, and procedures for environmental 

sampling and analysis. 

b. Purpose. When a CWM release occurs, whether by detonation, spillage, leakage, or 

disposal, any media (e.g., air, soil, water), which has potentially been contaminated with 

chemical agent, may pose a threat to human health or the environment. The purpose of 

analyzing and/or monitoring representative samples of this media is to discern the 

presence/absence of chemical agent. These data are used to evaluate whether pre- or post-site 

actions are protective of human health and the environment. 

c. Applicability. Environmental sampling and analysis should be performed as part of 

the site characterization. Environmental sampling and analysis must be performed during 

removal actions to confirm that chemical agent contaminated media has been removed. 

9-2. Contaminants of Potential Concern (COPCs). 

a. During the initial phases of site characterization, COPCs are determined from 

historical information and are documented in the CSP. If a CSP is not required by the PDT, 

COPCs will be identified in the CSS and/or Work Plan. The actual COPCs may change 

during the site characterization process based on additional findings. Changes in the sitespecific COPCs as identified in the CSS and/or Work Plan may require modifications to these 

documents if changes to the site operation procedures are required. Table 9.1 lists the COPCs 

associated with CWM that are most commonly found at FUDS. 

9-3. Agent/ABP Sampling and Analysis Support. 

a. ECBC is the government agency responsible for the development of analytical 

procedures and SOPs pertaining to chemical operations. At USAESCH RCWM projects, 

ECBC or an equivalent organization with current Bailment agreement to handle surety 

materiel is responsible for: 
EP 75-1-3 

30 Nov 04 

 9-2 

Table 9.1 

Contaminants of Potential Concern Found at FUDS Associated With CWM. 

Common 

Contaminants of 

Potential Concern

Air 

Monitoring 

Soil/ 

Aqueous

Samples Source 

Description/Physical Properties 

(at room temperature) 

Cyanogen Chloride 

(CK) 

Yes N/A2 Production, 

munitions 

Blood agent. Industrial chemical. Colorless gas with a 

pungent, biting odor. 

Phosgene (CG) Yes N/A2 CAIS, munitions Choking agent. Industrial chemical. Colorless, 

nonflammable gas that smells like new mown hay, grass, or 

green corn. Condenses to a colorless liquid below 46°F. 

Levenstein Mustard 

(H, HS); Distilled 

Mustard (HD) 

Yes Yes CAIS, munitions Blister agent. Colorless when pure, but usually yellow to 

brown oily liquid with a slight garlic or mustard odor. 

Nitrogen Mustard 

(HN-1, HN-3) 

Yes Yes Drums, containers Blister agent. Colorless to pale yellow, oily liquid with a 

faint fishy or musty odor. 

Lewisite (L) Yes Yes CAIS, production Blister agent. Colorless, oily liquid with a geranium odor. 

Very little odor when pure. 

Chloroform Yes N/A2 CAIS Industrial chemical. Clear colorless liquid with a pleasant, 

sweet odor 

Chloropicrin (PS) Yes N/A2 CAIS Industrial chemical. Colorless to faint yellow liquid with a 

stinging, pungent odor. 

Tri-Phosgene N/A1 N/A2 CAIS White to off-white crystals, may react to form phosgene 

gas. 

1,4-dithiane N/A1 Yes Mustard breakdown 

product 

Agent breakdown product. Odor similar to mustard. 

1,4-thioxane N/A1 Yes Mustard breakdown 

product 

Agent breakdown product. Colorless liquid. Odor similar 

to mustard. 

Thiodiglycol (TDG) N/A1 Yes Mustard breakdown 

product 

Agent breakdown product. Colorless to pale yellow liquid. 

Odor similar to mustard. 

Triethanolamine 

(TEA) 

N/A1 Yes HN-1 breakdown 

product 

Agent breakdown product. Colorless to light yellow, 

viscous liquid with a slight ammonia odor. 

Diethanolamine 

(DEA) 

N/A1 Yes HN-1 breakdown 

product 

Agent breakdown product. Colorless crystals or a syrupy, 

white liquid with a mild, ammonia-like odor. 

2-chlorovinyl 

arsenous acid 

(CVAA) 

N/A1 Yes Lewisite 

breakdown product 

Agent breakdown product. Dilute acid. 

2-chlorovinyl 

arsenous oxide 

(CVAO) 

N/A1

 Yes Lewisite 

breakdown product 

Agent breakdown product. White powder, no discernable 

odor. 

N/A1 – Constituents are not monitored for in air due to physical properties or because they are breakdown products. 

N/A2

 – Constituents are not subject to laboratory analysis due to fate and transport properties. 
EP 75-1-3 

30 Nov 04 

 9-3 

(1) Development of the Air Monitoring and Analysis Plan IAW the CASARM QA Plan 

and DA Pam 385-61. 

(2) Conducting all monitoring for chemical agent. 

(3) Maintaining control over all CWM monitoring data generated during the response 

action. 

(4) Training and certifying personnel on the operation of the MINICAMS, Depot Area 

Air Monitoring System (DAAMS), and Open-path Fourier Transform Infrared Spectrometer 

(OP-FTIR). 

(5) Providing and calibrating equipment for personnel monitoring. 

(6) Calibrating, challenging, and operating MINICAMS for real time analysis support. 

(7) Setting up monitoring stations and collecting historical monitoring samples in 

support of real time monitoring. 

(8) Conducting onsite analysis for headspace samples collected from media suspected of 

being contaminated with chemical agent. 

(9) Maintaining all sampling records IAW AR 40-5 and 29 CFR 1910.120. 

b. Other responsibilities that ECBC or an equivalent organization may be required to 

perform during site operations are on-site analysis of environmental samples using a field 

laboratory or headspace monitoring of environmental samples before they are shipped off-site 

by a commercial carrier for analysis at the ECBC offsite laboratory or a contractor facility 

with current Bailment agreement to handle surety materiel. 

9-4. Air Monitoring. 

a. General. Air monitoring for chemical agent is required whenever there is a risk for 

worker or public exposure to chemical agent during or due to site operations. An air 

monitoring plan must be developed and included as a supporting plan to establish the policies, 

objectives, procedures, and responsibilities for the execution of a site-specific monitoring 

program. 
EP 75-1-3 

30 Nov 04 

 9-4 

b. Purpose of Air Monitoring. The intent of air monitoring is to indicate to workers 

when a hazardous atmosphere is present and to maintain a record of employee exposure to 

airborne chemical agent, thus ensuring the safety of the operators, the environment, and the 

public. The choice of monitoring equipment is based on the type of monitoring to be 

performed and the types of agent involved. The location of monitors or sample ports is based 

on the operation, the airflow in the area, and the location of the source of agents. 

c. Air Monitoring Plan. DA Pam 385-61 requires that a monitoring plan be developed 

in writing and implemented. Generally, the air monitoring section within the SSHP and the 

Air Monitoring and Analysis Plan satisfy this requirement. The policy requires that the plan 

contain the following information: 

(1) A diagram of the operation. 

(2) Agent(s) involved. 

(3) Monitors to be used. 

(4) Placement of sampling points based on characteristics of agent, airflow, and 

monitoring equipment being used. 

(5) The kind of sampling lines used, to include the length, material made from and if the 

sampling lines are heat traced. 

(6) Provisions for low-level personnel monitoring during operations. 

(7) Identification of workstations where agent leakage is considered possible. 

d. Monitoring Equipment. The following low level, near real time monitoring 

equipment is used on an agent-contaminated media site for air monitoring for agent. 

(1) Miniature Chemical Agent Monitoring System. MINICAMS is an automatic air 

monitoring system that collects compounds on a solid sorbent trap, thermally desorbs them 

into a capillary gas-chromatography column for separation, and detects the compounds with 

either a halogen specific detector (XSD) or a flame photometric detector (FPD). It is a 

lightweight, portable, near real time, low-level monitor with alarm capability, designed to 

respond to Sarin (Isopropyl methylphosphonofluoridate), also known as GB; O-ethyl ester, 

also known as VX; mustard; nitrogen mustard; and Lewisite. The MINICAMS can also be 

used to detect certain industrial compounds, such as phosgene, chloropicrin, and chloroform. 
EP 75-1-3 

30 Nov 04 

 9-5 

(2) Fenceline Open-path Fourier Transform Infrared Spectrometry Air Monitoring. 

Open-path air monitoring of gaseous compounds is a direct extension of laboratory 

spectroscopy systems that identify and quantify gases based on their spectral absorption 

characteristics. Typically, open-path systems send a beam of light through the open air, to a 

reflector and then back to a receiver. If gases that absorb light are present in the beam, they 

can be identified and quantified. This technology will not sample down to the airborne 

exposure limit (AEL) for most CWM agents. 

(3) Depot Area Air Monitoring System. 

(a) DAAMS is a portable air sampling unit that is used for agent confirmation sampling. 

It is designed to draw a controlled volume of air through a glass tube filled with a collection 

material (Tenax GC). As the air is passed though the solid sorbent tube, agent is collected on 

a sorbent bed. After sampling for the predetermined period of time and flow rate, the tube is 

removed from the vacuum line. The tube is transferred to the field laboratory, or to the ECBC 

offsite laboratory or contractor facility with current Bailment agreement to handle surety 

materiel, for gas chromatography (GC) analysis. 

(b) GC analysis is first performed by desorbing the tube on to the instrument transfer 

tube. Chemical agents are then desorbed from the transfer tube into the GC where they are 

separated from each other in the GC column. The chemical agents are then detected as they 

elute from the GC column. The GC is configured to detect each chemical agent. The purpose 

of the GC analysis is to determine the presence, type, and quantity of agent collected in the 

sampling tubes. This technique will sample down to the AEL for agent. 

(4) Field Laboratory. A field laboratory is a self-contained unit that can be moved to a 

project and that contains all of the equipment necessary to analyze and confirm samples taken 

with DAAMS tubes and extracts of soil and surface water samples. The field laboratory shall 

be a fully functional laboratory that can cover the critical on-site chemical analysis and 

monitoring needs. An example of a suitable field laboratory is the Mobile Analytical 

Platform (MAP) used by ECBC. 

(5) Chemical Agent Monitor (CAM). The CAM is a lightweight, hand-held gross level 

vapor detector designed to respond to nerve and mustard agent vapors. It detects vapors of 

chemical agents by sensing molecular ions of specific mobilities and uses timing and 

microprocessor techniques to reject interferences. When the CAM detects the presence of a 

chemical agent vapor, a visual display will indicate the class of agent and the relative 
EP 75-1-3 

30 Nov 04 

 9-6 

concentration of agent. The CAM does not have an audible alarm. It has a real-time response 

capability for the detection of GB, VX, and mustard. 

(6) Commercially Available Monitoring Equipment. For the industrial chemicals such 

as those found in CAIS (e.g., phosgene and chloropicrin) there are commercially available 

instruments that may also be used on-site for air monitoring, as required. However, 

depending on the level of detection required, MINICAMS can be used to determine the 

presence of certain industrial chemicals. In each case a method of confirmation must be 

employed, such as colorimetric tubes. 

e. Types of Monitoring. This section discusses the types of air monitoring. Table 9.2 

presents a summary of these types of air monitoring. 

(1) Background Monitoring. This monitoring shall be conducted prior to initiation of 

site operations in order to provide a baseline of reference for subsequent analyses and to 

determine any interference in the area. DAAMS tubes and/or MINICAMS are generally used 

for this monitoring of the chemical agents of concern. 

(2) Area Monitoring. General area monitoring provides an early warning to personnel 

that there is a problem and that action must be taken. The monitoring device or sampling port 

is placed in strategic locations in the work area where there is a potential for encountering 

agent vapors. The sample locations are determined based on such factors as the agent 

involved, the airflow patterns in the area, the operations(s) being performed, and the location 

of the source of the potential release. A MINICAMS and/or commercially available monitors 

are used for this type of monitoring. 

(3) Perimeter Monitoring. This monitoring will not be used to immediately warn of 

hazardous conditions, but will be used to document conditions over time and to confirm a 

hazardous condition that was indicated by the MINICAMS. DAAMS tube sampling stations 

and/or the OP-FTIR are located at the perimeter of the work area to record any chemical agent 

release beyond the EZ. 

(4) Mobile Area Monitoring. Mobile area monitoring is a method of sampling airborne 

levels of contaminants in the work place. It is taken over the entire workday. A sampling 

train is used consisting of DAAMS tubes that are connected to a dual-port sampler. The dual 

port sampler is attached by Tygon tubing to a personal air pump. The train is calibrated to a 

specified air flow rate (liters per minute [LPM]). 
EP 75-1-3 

30 Nov 04 

 9-7 

Table 9.2 

Types of Air Monitoring 

Air Monitoring Type Method Purpose 

Background 

Monitoring 

Baseline DAAMS Tubes 

MINICAM 

OP-FTIR 

To provide a baseline of reference for 

subsequent analyses 

Area Monitoring Near-Real Time MINICAM 

Commercially 

Available Monitor 

To provide early, rapid warning to 

personnel of airborne exposure 

Perimeter 

Monitoring 

Confirmation/ 

Historical 

DAAMS Tubes To confirm real time alarms and to 

provide a historical record of public 

exposure due to an airborne release 

Mobile Area 

Monitoring 

Confirmation/ 

Historical 

DAAMS Tubes To confirm the results of the real time 

monitors and to document conditions 

over time 

Decontamination 

Monitoring 

Near-Real Time 

Real time 

MINICAMS 

CAM 

To continuously monitor at the hot 

line to provide early, rapid warning of 

airborne exposure 

Surface 

Monitoring 

NA DAAMS Tubes To determine if surface 

decontamination is required for media 

such as scrap metal, glass, etc. that is 

or has a high potential to be 

contaminated with chemical agent 

Headspace 

Monitoring 

NA DAAMS Tubes 

MINICAMS 

To screen environmental samples, 

bulk items, PPE and scrap which may 

potentially be contaminated with 

chemical agent 
EP 75-1-3 

30 Nov 04 

 9-8 

(5) Decontamination Monitoring. Personal decontamination station monitoring is used 

to verify that complete decontamination of a worker or piece of equipment has been 

conducted. Decontamination monitoring will be conducted using a MINICAMS. 

(6) Surface Monitoring. Surface monitoring will be done on equipment and waste of 

any kind that is suspected to be contaminated with chemical agent IAW AR and 

DA Pam 385-61. 

(7) Headspace Monitoring. Headspace monitoring will be conducted on environmental 

samples suspected of being contaminated with chemical agent prior to off-site shipment for 

analysis. This is to prevent samples contaminated above the AEL from being shipped by 

commercial carrier. Procedures for headspace monitoring of environmental samples is 

provided in Appendix F. 

9-5. Environmental Sampling. 

a. Environmental sampling will be used to determine if residual chemical agent 

contamination from a release, spill or disposal operation is present in the surrounding 

environment. Environmental sampling will also be undertaken to determine if other 

hazardous chemicals are mixed with the chemical agent(s) of concern. The sampling of other 

COPCs is necessary for the determination of the appropriateness of worker protection and to 

determine if residual concentrations of non-agent COPCs are present. 

b. Some types of chemical agents are not persistent in certain types of environments or 

after certain periods of time. The persistence of a chemical agent and its environment should 

be taken into consideration when determining COPCs for a specific site. For example, 

industrial chemicals such as phosgene, tri-phosgene, chloropicrin, chloroform, and cyanogen 

chloride are typically non-persistent in the environment and would be unsuitable selections as 

COPCs. Available references on fate and transport of chemical agents include 

“Environmental Chemistry and Fate of Chemical Warfare Agents” (Southwest Research 

Institute, 1994) and “The Sources, Fate, and Toxicity of Chemical Warfare Agent 

Degradation Products” (Munro, et al., 1999). 

c. Environmental samples may consist of soils and other solids, water, sludge, and 

vegetation. Each environmental sample collected will be homogenized and then divided into 

a minimum of three split samples prior to monitoring or analysis. Homogenization of the 

sample is required to ensure that each split sample is adequately representative. Prior to offsite shipment, unless the sampled media is aqueous, one of the split samples will be screened 
EP 75-1-3 

30 Nov 04 

 9-9 

for agent using airborne methods to ensure that concentrations are below the AEL. Once 

agent concentrations are determined to be below the AEL, the sample will be analyzed using 

soil and water extraction methods to ensure concentrations are below detectable levels IAW 

DA Pam 385-61. Extraction analysis may be performed at the site, or the sample may be 

shipped to an appropriate off site facility. This screening process is illustrated in Figure 9-1. 

d. Sampling Locations. Environmental samples will be collected immediately beneath 

and/or adjacent to any RCWM. Samples of surrounding media should also be collected 

whenever there are visual or airborne indicators of potential chemical agent contamination. 

Historical information may also be used to determine sampling locations. 

e. HTRW or Other Analyses. If split samples of environmental samples are to be 

analyzed for HTRW or other contaminants, the following procedures will be followed: 

(1) Split samples will be created and screened/analyzed for agent as described in 

Paragraph 9-5c. and Figure 9-1. 

(2) Split samples created for HTRW analyses will be retained on-site until they have 

been analyzed by extraction and determined to have no detectable concentrations of chemical 

agent. 

(3) The receiving laboratory to conduct the analyses is notified in writing prior to 

beginning work at the project that samples could possibly contain chemical agent 

contamination. Any non-surety laboratory to which samples are sent must be notified in 

writing that samples may contain chemical agent hazards. This notification shall explain the 

measures taken to ensure, to the extent possible, that the non-surety laboratory will not 

receive samples that are contaminated by chemical agent. Example text for this letter follows: 

“This letter is to inform you of the nature of the operations that will be taking 

place at the above project. The objective for sampling at this site includes an 

assessment for chemical warfare agent and agent breakdown products, as well 

as the hazardous and toxic wastes (HTW) for which your laboratory will be 

performing analyses. 

Prior being sent to your laboratory, the disposal characterization samples will 

be cleared for agent by [state name of ECBC laboratory or contractor facility 

with current Bailment agreement to handle surety materiel for analysis]. A 

copy of the clearance report for these samples will be sent to your laboratory 

along with the HTW samples.” 
EP 75-1-3 

30 Nov 04 

 9-10 

Figure 9-1. Environmental Sample Characterization. 

Collect Environmental

Sample

Create 3 Split Samples

(minimum)

1 Split Sample for HTW Characterization 

Held on Ice under Chain-of-Custody

until Agent Analysis complete

2 Split Samples for

Agent Sample Analysis

(1 Headspace and 1 Extraction)

Above 

AEL?

Decontaminate 

Drummed Soil

Submit Extraction Sample

for Agent Clearance to

ECBC or Equivalent

Agent Extraction 

Analysis

Agent 

present?

Headspace

Analysis

Aqueous?

NO

NO

NO

YES

YES

YES

Samples May be Sent to HTW 

Lab for Further Analysis

Sampled Material Handled as Agent 

Contaminated Material IAW Federal, 

State, & Local Regulations

Collect Environmental

Sample

Create 3 Split Samples

(minimum)

1 Split Sample for HTW Characterization 

Held on Ice under Chain-of-Custody

until Agent Analysis complete

2 Split Samples for

Agent Sample Analysis

(1 Headspace and 1 Extraction)

Above 

AEL?

Decontaminate 

Drummed Soil

Submit Extraction Sample

for Agent Clearance to

ECBC or Equivalent

Agent Extraction 

Analysis

Agent 

present?

Headspace

Analysis

Aqueous?

NO

NO

NO

YES

YES

YES

Samples May be Sent to HTW 

Lab for Further Analysis

Sampled Material Handled as Agent 

Contaminated Material IAW Federal, 

State, & Local Regulations
EP 75-1-3 

30 Nov 04 

 9-11 

f. Shipment of Environmental Samples. 

(1) Environmental samples shall not be shipped off-site to commercial or QA 

laboratories until those samples have been confirmed as non-detect for chemical agent by 

ECBC or equivalent. 

(2) Prior to shipping samples by commercial carrier to ECBC or a contractor facility 

with current Bailment agreement to handle surety materiel, all samples shall have a split 

sample headspace monitored to ensure chemical agent concentrations are below the AEL, or 

the samples will be analyzed on-site by extraction to ensure agent concentrations are below 

detectable levels. 

(3) Equipment blanks do not require headspace analysis prior to sample shipment. 

(4) Shipping will be IAW DA Pam 385-61 and EM 200-1-3, Appendix F. Applicable 

Department of Transportation requirements will be followed for all shipped samples. In 

addition, for samples transported by air, the International Air Transport Association 

requirements for the carrier must be followed. All samples suspected of containing agent 

should be sent as Class 6 or Class 9 DOT regulated materials. Packaging must be consistent 

with the DOT and IATA regulations.” 
EP 75-1-3 

30 Nov 04 

 10-1 

CHAPTER 10 

Investigation Derived Waste 

10-1. Introduction. 

a. This chapter discusses the types of IDW encountered at RCWM projects, 

characterization procedures, and management procedures. Figures 10-1a and 10-1b illustrate 

the IDW management process. 

b. IDW may consist of anything generated during a site investigation or removal action 

that cannot be reused or recycled. Some media must be managed as IDW until it has been 

fully characterized. The characterization may determine that the media is suitable for reuse. 

10-2. Soil. 

a. Soil. Soil may be generated during a response action in the form of environmental 

samples, drill cuttings, or excavated soil. Characterization of soil generated during a response 

action is required whenever there is historical, visual, or other detectable evidence that 

contamination may be present. If monitoring indicates an airborne hazard, soil will be 

containerized to prevent exposure to the contamination. If monitoring does not indicate an 

airborne hazard, soil may be stockpiled in a way to minimize spread of contamination until 

characterization has been completed. 

b. Characterization. 

(1) Large volumes of soil are generally characterized by analyzing composite samples. 

The number of composite samples required to characterize a given volume of soil is generally 

site-specific due to local laws and regulations. When multiple types of contamination are 

suspected, characterization will be prioritized based on hazard level, beginning with the 

greatest hazard level. 

(2) Disposal decisions shall be based on agent/ABP and HTRW disposal 

characterization sampling results. If HTRW characterization is performed, it shall be IAW 

EM 200-1-3 requirements for chemical analysis. Use of disposal facilities or onsite disposal 

is contingent upon compliance with the facility-specific requirements for waste acceptance, 

and state and local regulations. These requirements include, at minimum, complete analytical 

characterization data and disposal documentation paperwork. 
EP 75-1-3 

30 Nov 04 

 10-2 

Figure 10-1a. IDW Management Process: Solid Waste, Equipment, and PPE. 

IDW is generated

Segregate, containerize, or 

stockpile, as appropriate

Above 

AEL?

Decontaminate

Monitor for agent

Suspect agent 

contaminated?

NO

YES

YES

Solid Waste Equipment PPE Soil Liquid Waste

Reference 

Figure 10-1b

CWM 

related 

scrap?

Handle as

3X scrap

Suspect HTRW 

contaminated?

Handle as

X

Dispose as 3X scrap

as specified in

DA Pam 385-61

Handle as

3X

YES

YES

YES

NO

NO

NO Above 

AEL?

Decontaminate

Monitor for agent

YES Cost-effective 

for Government 

to retain control?

Government

control as 3X NO

NO

Manage as Non-Hazardous 

Waste IAW Federal, State, 

& Local Regulations

Manage as Hazardous 

Waste IAW Federal, State, 

& Local Regulations

Reference 

Figure 10-1b

IDW is generated

Segregate, containerize, or 

stockpile, as appropriate

Above 

AEL?

Decontaminate

Monitor for agent

Suspect agent 

contaminated?

NO

YES

YES

Solid Waste Equipment PPE Soil Liquid Waste

Reference 

Figure 10-1b

CWM 

related 

scrap?

Handle as

3X scrap

Suspect HTRW 

contaminated?

Handle as

X

Dispose as 3X scrap

as specified in

DA Pam 385-61

Handle as

3X

YES

YES

YES

NO

NO

NO Above 

AEL?

Decontaminate

Monitor for agent

YES Cost-effective 

for Government 

to retain control?

Government

control as 3X NO

NO

Manage as Non-Hazardous 

Waste IAW Federal, State, 

& Local Regulations

Manage as Hazardous 

Waste IAW Federal, State, 

& Local Regulations

Reference 

Figure 10-1b
EP 75-1-3 

30 Nov 04 

 10-3 

Figure 10-1b. IDW Management Process: Soil and Liquid Waste. 

Above 

AEL?

Monitor for agent

YES NO

Manage as Agent Contaminated 

Material IAW Federal, State, & 

Local Regulations

Agent

Extraction

Analysis

Agent 

present?

Decontaminate

Analyze for 

HTW Disposal 

Parameters

Hazardous 

Constituents

present?

YES

Manage as Non-Hazardous NO

Waste IAW Federal, State, & 

Local Regulations

Manage as Hazardous 

Waste IAW Federal, State, & 

Local Regulations

IDW is generated

Segregate, containerize, or 

stockpile, as appropriate

Solid Waste Equipment PPE Soil Liquid Waste

Reference 

Figure 10-1a

Reference 

Figure 10-1a

Create Split Samples

(see Chapter 9)

Create Split Samples

(see Chapter 9)

YES

NO

Above 

AEL?

Monitor for agent

YES NO

Manage as Agent Contaminated 

Material IAW Federal, State, & 

Local Regulations

Agent

Extraction

Analysis

Agent 

present?

Decontaminate

Analyze for 

HTW Disposal 

Parameters

Hazardous 

Constituents

present?

YES

Manage as Non-Hazardous NO

Waste IAW Federal, State, & 

Local Regulations

Manage as Hazardous 

Waste IAW Federal, State, & 

Local Regulations

IDW is generated

Segregate, containerize, or 

stockpile, as appropriate

Solid Waste Equipment PPE Soil Liquid Waste

Reference 

Figure 10-1a

Reference 

Figure 10-1a

Create Split Samples

(see Chapter 9)

Create Split Samples

(see Chapter 9)

YES

NO
EP 75-1-3 

30 Nov 04 

 10-4 

(3) The presence of contamination in soil is based on positive detections of agent/ABP as 

determined by ECBC or equivalent, and characterized for disposal by an HTW laboratory. 

Typical HTW disposal analyses for soils include: Toxicity Characteristic Leaching Procedure 

(TCLP) metals, TCLP Volatile Organic Compounds (VOCs), TCLP Semi-volatile Organic 

Compounds (SVOCs), ignitability, corrosivity, and reactivity. Depending upon the site 

history and disposal facility requirements, TCLP pesticides, TCLP herbicides, and polychlorinated biphenyls (PCBs) may also be analyzed. 

c. Decontamination and Disposal. Soil contaminated with chemical agent will be 

decontaminated and disposed of IAW DA Pam 385-61. When soil is contaminated with 

chemical agent and the AEL is exceeded, it will be decontaminated prior to off-site shipment 

for incineration at an approved facility. Soil characterized as hazardous will be incinerated or 

otherwise disposed of appropriately at a RCRA-permitted facility. 

10-3. Liquid Waste. 

a. Liquid waste may be generated during a RCWM response action in the form of 

environmental samples, drilling fluids, and/or decontamination water. Liquid waste that is 

suspected to be contaminated will be containerized and managed as IDW until 

characterization is complete. 

b. Characterization. 

(1) Liquid waste will be characterized by analyzing representative samples of the 

generated waste for any suspected contamination. Chemical agents generally break down in 

water to form less hazardous byproducts. However, if chemical agent is suspected, the 

environmental sampling procedures described in Chapter 9 of this document will apply. 

(2) Disposal decisions shall be based on agent/ABP and HTRW disposal 

characterization sampling results. If HTRW characterization is performed, it shall be IAW 

EM 200-1-3 requirements for chemical analysis. Use of disposal facilities or onsite disposal 

is contingent upon compliance with the facility-specific requirements for waste acceptance, 

and state and local regulations. These requirements include, at minimum, complete analytical 

characterization data and disposal documentation paperwork. 

(3) The presence of contamination in liquid wastes is based on positive detections of 

agent/ABP as determined by ECBC or equivalent, and characterized for disposal by an HTW 

laboratory. Typical HTW disposal analyses for liquid wastes include: TCLP list compounds, 
EP 75-1-3 

30 Nov 04 

 10-5 

corrosivity, and reactivity. Depending upon the site history and disposal facility 

requirements, TCLP pesticides, TCLP herbicides, and PCBs may also be analyzed. 

c. Disposal. Liquid wastes that are determined to have contamination levels above the 

site-specific action levels will be classified as hazardous waste and managed IAW Federal, 

state, and local laws and regulations as appropriate. 

10-4. Solid Waste. 

a. Solid waste or scrap may be generated during a response action in the form of 

recovered debris (e.g., metal, glass, wood) resulting from former site activities. All recovered 

scrap will be managed as IDW; however, until it has been characterized, scrap will be 

segregated and managed based on possible contamination. 

b. Characterization. 

(1) Scrap. Scrap will be visually inspected to determine if an explosive hazard is 

present. If present, the explosive hazard must be mitigated prior to disposal. All scrap must 

be certified to be free of an explosive hazard prior to disposal. 

(2) Scrap suspected to be contaminated with chemical agent must be monitored to 

determine if contamination is above the AEL. Scrap that will be considered suspect includes 

materials known to have been used for CWM operations, materials known to have been 

exposed to chemical agent, and materials that have been in direct contact with other media 

determined to be contaminated with chemical agent. If agent contamination is above the 

AEL, surface decontamination IAW DA Pam 385-61 is required. If agent contamination is 

below the AEL or when an item has been decontaminated to below the AEL, the scrap will be 

classified as 3X material. 

(3) Scrap that has other indications that it may be contaminated with HTRW (e.g., 

biological waste, visual contamination, air monitoring indicators) will be managed as a 

hazardous waste. 

c. Disposal. Scrap contaminated or suspected to be contaminated with chemical agent 

or HTRW will be classified as hazardous waste and managed IAW Federal, state, and local 

laws and regulations as appropriate. All 3X material will be disposed of IAW DA Pam 385-

61. Scrap that is determined to be free of contamination may be disposed of in a sanitary or 

industrial landfill. Whenever possible, scrap that is uncontaminated will be recycled. 
EP 75-1-3 

30 Nov 04 

 10-6 

10-5. Personal Protective Equipment. 

a. PPE is a generated waste when it is consumable, requiring disposal after its use is 

finished or when it becomes contaminated with chemical agent or HTRW and 

decontamination of the PPE is not possible or cost effective. When it is cost effective to do 

so, chemical agent contaminated PPE can be decontaminated to 3X levels and reused. There 

are exceptions to this reuse; however, property that is determined to be 3X must remain under 

the control of the Federal Government IAW DA Pam 385-61. 

b. Decontamination and Disposal. PPE that is contaminated with chemical agent must 

be monitored to determine if contamination is above the AEL. If agent contamination is 

above the AEL, surface decontamination IAW DA Pam 385-61 is required. PPE 

contaminated or suspected to be contaminated with chemical agent or HTRW will be 

classified as hazardous waste and managed IAW Federal, state, and local laws and regulations 

as appropriate. All 3X material will be disposed of or managed IAW DA Pam 385-61. PPE 

that has not been in contact with agent liquid or vapor may be disposed of in a sanitary or 

industrial landfill. 

10-6. Equipment Disposition. 

a. Equipment is classified as either consumable or durable goods. Some examples of 

consumable goods are PPE and sampling equipment. Heavy equipment is an example of 

durable goods that is utilized at RCWM projects. 

b. Equipment contaminated with agent requires disposition after its intended use is 

completed either through disposal or reuse. When cost effective to do so, chemical agentcontaminated equipment can be decontaminated to the 3X levels and reused. However, 

equipment classified as 3X must remain under the control of the Federal Government IAW 

DA Pam 385-61. 

10-7. IDW Plan. The IDW Plan will be included in the Work Plan and will contain the 

following information: 

a. Handling. Describe how IDW (RCWM-contaminated media, hazardous waste, and 

decontamination wastes) will be handled at this site. 

(1) Identify methods to be used to containerize, store, test, transport and handle IDW. 

(2) Identify methods used to minimizing the quantity of IDW. 
EP 75-1-3 

30 Nov 04 

 10-7 

(3) Identify the methods used to manage IDW consistent with the final remedy. 

(4) Address how pre-transportation storage, transportation, treatment, and ultimate 

disposal of the various waste streams will be accomplished. 

b. Contracting Office Recommendation. Include a letter report for the CO 

recommending appropriate disposal actions and treatment. 

c. Timely Disposal. Identify how the IDW disposal will be accomplished in a timely 

manner. To be agreed upon prior to the SOW. 

d. Regulated Facility. Document how the disposal of the IDW is conducted by a 

facility that operates as a Treatment, Storage, and Disposal Facility (TSDF) under RCRA 

regulations. USAESCH will identify a POC for signature of the hazardous waste manifest. 

e. Packaging. Describe the packaging of the materiel IAW state and Federal laws and 

regulations. Packaging will be addressed in the Work Plan for the purpose of segregation of 

materiel (if necessary) for transportation and ultimate disposal of the IDW. 

f. Personnel. 

(1) Identify all personnel and equipment necessary to package, label, manifest, 

transport, and dispose of the IDW IAW the approved Work Plan. 

(2) Provide copies of training certificates with respect to RCRA, HW, and DOT 

hazardous material regulations. 

(3) Provide emergency response contacts. 

g. Licenses and Permits. Describe the necessary licenses and permits, and will comply 

with applicable Federal, state, and local laws, codes, and regulations when executing this 

work. 

h. Transportation. Identify the methods used to ensure the shipment or transportation 

of IDW is IAW DOT Hazardous Material Regulation 49 CFR 100-199. 

i. Manifesting. Describe the preparation of all required hazardous waste manifests, 

which will include a correct description of all wastes to be shipped in a complete and legible 

manner and the appropriate details from Paragraph 10-8. 
EP 75-1-3 

30 Nov 04 

 10-8 

j. Waste Characterization. 

(1) Prepare and provide a copy of the Waste Profile Sheet(s), along with a copy of the 

analytical results used to prepare the profile, to USAESCH and the District or installation. 

(2) Include identification of the waste codes and underlying hazardous constituents. 

(3) Demonstrate site-specific knowledge of COPCs. 

(4) Estimate the type and quantity of IDW to be generated. 

k. Weight Slip. Provide a signed weight slip to USAESCH and the District or 

installation that indicates the actual weight of the IDW that has been shipped to the TSDF. 

l. Land Disposal Restriction (LDR) Notification Forms. A copy of the LDR 

Notification Form and the manifest will go to USAESCH for review prior to USAESCH 

signing the manifest. This form will identify associated treatment standards required in 40 

CFR 268. The contractor will make any revisions to this form. USAESCH will provide a 

copy of the approved form to the District or installation. 

m. Certificate of Disposal. TSDFs must be required under the contract to provide a 

Certification of Disposal indicating final disposition of all items, signed by the authorized 

agent of the TSDF, within 10 working days of final disposition. Final payment will not be 

made until ultimate disposal has been made. This certification will indicate: 

(1) The materiel (by item and quantity) that was disposed. 

(2) The specific method of treatment. 

(3) The date of treatment. 

(4) Manifest number of waste. 

n. Applicable, Relevant, and Appropriate Requirements. Identify potential ARARs 

and any exemptions to ARARs. In some jurisdictions, chemical agent and chemical agent 

contaminated media are considered hazardous waste by regulation. Therefore, local and state 

hazardous waste regulations will be reviewed to determine which regulations apply. 
EP 75-1-3 

30 Nov 04 

 10-9 

10-8. Manifesting Requirements. 

a. Manifests will be prepared IAW 40 CFR 260-268, applicable state regulations, and 

49 CFR 171-178. 

b. Completed copies of all manifests, land disposal restriction notification forms, and 

waste profiles will be forwarded to USAESCH (or the installation) for review at least 

10 working days prior to shipment of the IDW. 

c. The contractor will make revisions to the manifest as requested. 

d. No shipment of the IDW will occur until the Government is satisfied that all entries 

are correct and the authorized representative of USAESCH has signed the manifest. 

10-9. Government Responsibilities. Government responsibilities will include the following: 

a. Inspection. Inspect the materiel in the IDW container to be transported for disposal 

prior to loading, to ensure that only authorized wastes are being offered for 

treatment/disposal. Upon completion of inspection, notify the contractor of any unauthorized 

wastes discovered. 

b. Designated Generator. Be designated as the Generator at RCWM projects for the 

purpose of manifesting. For sites adjacent to active installations, where the active installation 

has assumed responsibility, the installation will make the necessary manifest certifications. 

For FUDS, the manifest signatory will be an authorized representative of USAESCH. The 

District’s generator number will be used for manifests. A copy of all paperwork will be 

provided to the PM for information. 

c. Manifest Retention. Maintain manifests at the project office for a minimum of three 

years as required by 40 CFR 262.40. Under Multiple Award Remediation Contracts, maintain 

records for extended lengths of time as required. 
EP 75-1-3 

30 Nov 04 

 11-1 

CHAPTER 11 

Interim Holding Facility 

11-1. Introduction. This chapter presents an overview of the regulatory requirements, 

organizational responsibilities, and general requirements for the IHF. The IHF is constructed 

onsite for the receipt and temporary storage of RCWM, pending onsite disposal or removal 

from the site. The PMNSCM is responsible for preparing an IHF Plan to provide information 

about the temporary storage of RCWM in a safe, secure, and environmentally sound manner. 

11-2. IHF Regulatory Requirements. IHF operations will be in compliance with DA and 

other regulatory guidelines. Some of the major regulatory requirements for IHF operations 

include: 

a. An EPA identification number will be obtained by the USACE District as the 

generator of RCWM per 40 CFR 264.11. 

b. RCWM hazardous waste must be characterized according to 40 CFR 264.12, then 

labeled IAW 40 CFR 262.34. An operating record must be maintained IAW 40 CFR 264.73-

264.76 and applicable local regulatory requirements. 

c. Appropriate signs must be posted restricting access to the facility per 40 CFR 

264.14. Agent and supplemental signs will be posted IAW DA Pam 385-61. 

d. IHF inspection procedures must be IAW 40 CFR 254.15 and available on-site for 

inspection per 40 CFR 264.74. 

e. All personnel involved in hazardous waste management must be 40-Hour Hazardous 

Waste Operations and Emergency Response (HAZWOPER) trained IAW 29 CFR 1910 to 

ensure they can implement emergency procedures and activate the facility contingency plan 

as required by 40 CFR 264.50-264.56. 

f. The IHF must be equipped with a secondary containment system per 40 CFR 

264.75, and all wastes must be stored separately in containers that are compatible with the 

waste they contain per 40 CFR 264.172. 

g. Storage of RCWM will be IAW AR 385-61, DA Pam 385-61, AR 385-64, 

DA Pam 385-64, AR 50-6, and AR 190-11. 
EP 75-1-3 

30 Nov 04 

 11-2 

11-3. Organizational Responsibilities. The primary organizations participating in IHF 

activities on FUDS include the PM District, the CW-DC, PMECW/PMNSCM, the Guardian 

Brigade, and USAESCH. 

a. The District. The District, in close coordination with the CW-DC and PMECW, has 

the following responsibilities for IHF operations: 

(1) Exercise site control per the IHF Plan and Work Plan during all phases of RCWM 

recovery operations. 

(2) Select the IHF location and exercise control of RCWM after receipt from the 

recovery site until the RCWM is removed from the IHF and destroyed onsite or shipped 

offsite for treatment. 

(3) Be responsible for the RCWM until it is transported offsite. The physical custody of 

the RCWM will be immediately transferred to the TEU. 

(4) Coordinate standby decontamination, medical support, and emergency response 

during all phases of recovery, on-site transport, and storage. 

(5) Oversee site operations conducted by TEU to manage RCWM safely. 

(6) Support routine maintenance of the IHF. 

(7) Inspect IHF operations to ensure compliance with directives. 

(8) Provide physical security support for site operations. 

(9) Conduct public involvement in coordination with PMECW. 

(10) Coordinate with PMNSCM if failure of the IHF structure or major components 

occurs. Should repair be impractical, coordinate with PMNSCM to replace the IHF and 

ensure that RCWM is transferred following procedures developed for receipt and storage of 

RCWM. 

(11) Provide communications equipment to key organizations and emergency services. 

b. PMECW/PMNSCM. The responsibilities of the PMECW/PMNSCM for IHF 

operation include: 
EP 75-1-3 

30 Nov 04 

 11-3 

(1) Provide safe and environmentally acceptable transportation and disposal of RCWM. 

(2) Perform a Hazard Analysis that addresses the relative risk associated with the IHF 

Plan. 

(3) Provide a portable IHF for use at the site, if required. 

c. Guardian Brigade. The TEU is a specialized unit of the Guardian Brigade that may 

be tasked with the following IHF responsibilities: 

(1) Support the District, PMECW, and USAESCH. 

(2) Recover munitions with unknown fillers at the site. 

(3) When directed by USAESCH, represent the Guardian Brigade, assume physical 

custody of RCWM when recovered, perform assessment to determine fill contents, and 

package the RCWM in overpack containers. 

(4) Escort RCWM during on-site transportation and operation of the IHF. 

(5) Provide direct support to USAESCH/PMECW to perform monitoring. The TEU, in 

the absence of ECBC or equivalent organization, will monitor the IHF for chemical agents 

stored in the IHF prior to opening. The TEU may be tasked to train District or Districtdesignated personnel to perform surveillance monitoring. The TEU may also be tasked to 

perform periodic IHF monitoring during long-term storage. 

(6) Inspect the IHF periodically for signs of deterioration or other damage that could 

lead to release of chemical agent. 

(7) Provide first response during any emergency situations that occur during recovery, 

overpacking, transportation, and storage operations. 

(8) Train personnel in IHF operations, including proper lifting techniques and hazard 

communication training for all chemicals used at the site. 

d. Air Monitoring Personnel. The responsibilities of the air monitoring personnel 

(ECBC or equivalent organization) for IHF operations include: 

(1) Provide direct support to the TEU. 
EP 75-1-3 

30 Nov 04 

 11-4 

(2) Perform laboratory analyses of samples to determine if chemical agent is present. 

(3) Provide the TEU with material handling equipment, monitoring devices, and 

calibration solutions, as requested. 

(4) Provide sampling capability (monitoring equipment and personnel) at the IHF for 

first entry monitoring. 

e. USAESCH. The responsibilities of USAESCH during IHF operations include: 

(1) Provide direct support to the District in preparation of the site work plan and Safety 

Submission. 

(2) Provide on-site expertise during site investigation. 

(3) Conduct the IHF vulnerability assessment. 

(4) Review and certify all hazmat shipments. Sign all hazardous waste manifests and 

associated paperwork. 

11-4. Design Requirements. The IHF is a storage building provided by PMNSCM and 

designed to hold RCWM. The IHF design is the product of PMNSCM and meets all storage 

parameters necessary for the temporary storage of RCWM. The specifications for the IHF are 

identified within the IHF Plan, one of PMNSCM’s submittals for the CSS. 

11-5. IHF Siting Plan. This section contains instructions for preparing a Work Plan chapter 

or Appendix to address the layout, explosive safety requirements, and security measures for 

the IHF at RCWM projects and incorporates guidance from AR 385-61, DA Pam 385-61, AR 

and DA Pam 385-64, EP 75-1-3, and DOD 6055.9. 

a. The Contractor shall submit an IHF Siting Plan that describes the safety and security 

criteria to be employed during RCWM operations. 

b. The following chemical operations shall be described in the plan and sited on the 

Quantity-Distance (Q-D) map: 

(1) Static storage of RCWM in the IHF. 

(2) Assessment of RCWM. 
EP 75-1-3 

30 Nov 04 

 11-5 

c. MCE for the operations at the IHF. 

(1) The Government will provide the D2PC calculations for the MCE. For siting 

purposes, always use the following parameters: 

(a) Wind speed of one meter per second. 

(b) Stability factor of “D.” 

(2) Details for explosively-configured RCWM. 

(3) Details for non-explosively-configured RCWM. 

(4) The Government will provide the primary fragmentation characteristics for the 

explosively configured RCWM. 

(5) The Government will provide the calculations for engineering controls necessary to 

prevent primary fragments from propagating the explosives wave between Multiple Round 

Containers (MRC), limiting the MCE to no more than one explosively configured RCWM 

item in the IHF (see Table 1 below). 

(6) For explosively configured RCWM, an instantaneous release of all agent within the 

item will be assumed if the MCE occurs. 

(7) For non-explosively-configured RCWM, the release of a percentage of the agent 

will be assumed and will be determined dependent upon specific item being identified and 

will be provided to the contractor by the Government. 

d. Site Map. The recommended scale for the site map is one-inch equals 400 feet. 

However, a larger scale may be used if available and if the map can be logistically included in 

the Work Plan. A smaller scale is acceptable if distances can be accurately shown. If an 

unscaled map is used, the map must have all pertinent distances labeled. Ensure the following 

items are identified on the map: 

(1) Q-D arc for the 1 Percent Lethality Distance, as calculated by D2PC. 

(2) Q-D arc for the Net Explosive Weight (NEW) for the IHF (usually will be the NEW 

of the MCE, if explosively configured). 
EP 75-1-3 

30 Nov 04 

 11-6 

(3) Public Withdrawal Distance. This distance is usually the NOSE Distance calculated 

by the D2PC. 

(4) Secondary fragment distance from DOD 6055.9-STD, usually the distance specified 

for less than 31 pounds NEW. 

e. Describe any additional engineering controls that may be necessary to ensure the 

public is protected in the event the necessary Q-D cannot be achieved. 

(1) Use of a primary fragmentation capturing device to eliminate primary fragments 

from penetrating another MRC should an MCE occur within the IHF (see the Table 11.1 

below). The Government will provide this design, should it be required. 

(2) Use of a Vapor Containment Structure (VCS) designed to mitigate the blast 

overpressure should the explosively configured MCE occur within the IHF. The VCS used 

by the USACE has been approved for use for explosive bursters up to 0.25 pounds without 

modification. 

(3) Use of an Engineering Control Structure (ECS) for a non-explosively-configured 

MCE will be required during assessment activities outside of the IHF if the Q-D for the PWD 

cannot be achieved or absolute exclusion cannot be maintained. 

(4) Use of a chemical agent filtering system, in conjunction with the VCS, to capture the 

agent release should the MCE occur within the IHF. 

11-6. Physical Security Plan. 

a. The contractor will submit a Physical Security Plan. The Physical Security Plan will 

describe the security criteria to be employed during RCWM operations, to include the storage 

of RCWM within the IHF. The general content of the Physical Security Plan is as described 

below: 
EP 75-1-3 

30 Nov 04 

 11-7 

Table 11.1 

Penetration of Fragments from Explosively Configured Agent-Filled Munitions 

Chemical Round 

Thickness of Mild Steel 

Required to Prevent 

Perforation (inch) 

Thickness of Mild Steel 

Required to Prevent 

Perforation After 

Perforation of MRC (inch) 

4 lb Incendiary AN-M50X-A1 0.10 0.00 

VB Rifle Grenade Mark I 0.21 0.08 

M15 WP Grenade 0.09 0.00 

115 mm M55 Rocket (Chemical) 0.22 0.09 

6 lb Incendiary Bomb 0.35 0.22 

75 mm MkII 0.31 0.18 

75 mm M1/M8 (Chemical) 0.11 0.00 

4 in Stokes (Chemical) 0.11 0.00 

105 mm M60 0.25 0.12 

105 mm M360 0.46 0.33 

4.2 in M2/M2A1 (Chemical) 0.10 0.00 

4.7 in (Chemical) 0.21 0.08 

155 mm Mk 2 0.59 0.46 

155 mm M122 (Chemical) 0.66 0.53 

8 in M426 (Chemical) 0.85 0.72 

8 in Livens (Chemical) 0.11 0.00 

NOTE: Penetration is based upon design fragment weight and velocity calculated IAW 

HNC-ED-CS-S-98-1 and penetration of mild steel using the THOR equations. 
EP 75-1-3 

30 Nov 04 

 11-8 

(1) Project mission. 

(2) Purpose of the Physical Security Plan. 

(3) Objective of the security. 

(4) Threat analysis. 

(5) Vulnerabilities. 

(6) Priorities. 

(7) Limited and exclusion areas. 

(8) Equipment and devices to detect or delay intrusion. 

(9) Security lighting. 

(10) Communication systems. 

(11) Locks and keys. 

(12) Measures to control personnel, vehicles, and material. 

(13) Personnel identification system. 

(14) Vehicle control. 

b. A detailed outline for the Physical Security Plan is included in Appendix G 

including an example of instructions for the security force. 

c. Before the Physical Security Plan can be developed a Vulnerability Assessment 

(VA) must be conducted. The assessment will determine the vulnerability to sabotage, theft, 

loss, seizure, unauthorized access, and use or diversion of chemical agents from both external 

and internal threats. The assessment will ensure that the security measures documented in the 

Physical Security Plan are adequate for the identified vulnerabilities. The key elements, 

annotated outline, and description of the phases are provided below. 

(1) VA Key Elements. 
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(a) The VA will be accomplished by a team to include the following personnel: 

• PM or his designated representative for FUDS projects. 

• FBI or Military Intelligence office for specific project region. 

• Members of site security forces. 

• Local law enforcement personnel. 

• Safety and Health representatives. 

• Other personnel as designated by the PM. 

(b) The VA team will be briefed on the purpose and scope of the VA. 

(c) Briefings will be provided on the storage facility being assessed. 

(d) Physical Security Plan and SOPS will be reviewed. 

(e) The VA team will identify and target specific areas/items of security interest within 

the IHF, and will identify potential adversary acts for each target. 

(f) The VA team will tour the IHF site to become familiar with site configuration, 

terrain, storage structures, security systems and forces, and technical operations. During the 

tour, the team will identify specific vulnerabilities from internal and external threats to 

include: 

• Observing day and night operations. 

• Interview of personnel as appropriate. 

• Demonstration of equipment and procedures. 

• Note how security systems are utilized, to include forces and backup forces. 

• Table-top one or more scenarios to evaluate responses. 

• Based on results of scenarios, the team will identify the necessary corrective actions. 
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• Conclusions and recommendations will be developed and documented by the team. 

Established vulnerabilities will have specific recommendations for actions to 

eliminate or reduce the vulnerabilities. 

o Conclusions will express results that logically flow from the team. 

o Recommendations will support conclusions. 

(2) Vulnerability Assessment Outline. 

(a) Introduction 

• Purpose. 

• Scope. 

• Site Description. 

• Site Mission. 

• Security Interests. 

(b) Identification and Description of Potential Threats. 

• Target Identification. 

• Identified Vulnerabilities. 

• Scenarios Developed. 

• Conclusions and Recommendations. 

• Team Leader Signature. 

• MACOM Decisions on Conclusions and Recommendations. 

(3) Vulnerability Assessment Phases. 

(a) In Phase I, the VA Team will: 
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 11-11 

• Assess the IHF Siting Plan. 

• Converse with local law enforcement to discuss the Physical Security Plan (PSP) for 

the site. 

• Converse with regional FBI or Military Intelligence personnel to discuss the threat 

situation for the site. 

• Review the PSP and other SOPs applicable to physical security for the site. 

• Review the IHF Plan. 

(2) In Phase II, the VA team will perform a site visit to the IHF. If the location for the 

IHF is questionable, this phase may be performed first. 

(3) In Phase III, a tabletop exercise will be conducted independently or in conjunction 

with the site operations tabletop exercise. Scenarios that incorporate physical security into the 

total picture will be executed during the tabletop exercise. 

11-7. Industrial Chemicals. Safety and storage considerations concerning intact containers, 

other than ordnance configurations, which contain commercial chemicals such as chlorine, 

hydrogen cyanide, potassium cyanide, carbonyl chloride, cyanogen chloride, chloropicrin, etc. 

will conform to the requirements and guidance in AR 385-10 and practices which are 

generally acceptable for industrial operations. 
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CHAPTER 12 

Transportation of Recovered Chemical Warfare Material 

12-1. Introduction. This chapter documents the transportation and disposal procedures for 

RCWM. 

12-2. Transportation Regulatory Requirements. Transportation operations of RCWM will 

follow DA and other regulatory guidelines. Some of the major requirements include: 

a. Manifesting and preparing shipments in according to 40 CFR 260-268 and 49 CFR 

171-179 as necessary. 

b. Following applicable state, EPA, DOT, OSHA, and Army requirements for worker 

training and certifications for the transportation of hazmat including hazardous waste. 

c. Following security guidelines provided in AR 190-11, AR 50-6, 49 CFR 172 

Subpart I, DOD 4500.9-R Chapter 205 paragraph X, and ETL 1110-1-502, Security Planning 

and Training Requirements for Hazardous Materials Shipments. 

d. Following 50 USC 1512-1517. 

12-3. Organizational Responsibilities. 

a. PMECW. The PMECW has command responsibility to ensure that the RCWM is 

handled in a safe and environmentally acceptable manner. The PMECW has responsibility 

for overseeing RCWM handling activities such as monitoring, inspecting, labeling, 

documenting, loading, trans-loading, unloading, and transporting. A PMECW coordinator 

will be identified for this transportation effort to ensure all required coordination is conducted 

and responsibilities are fulfilled. Other PMECW responsibilities include: 

(1) Developing a hazard analysis that addresses the relative risk associated with the 

planned transportation of RCWM. This analysis will identify variables that impact selection 

of landing areas and air corridors. In addition, the hazard analysis will assess transportation 

activities along the selected truck and air routes and risks associated with the vehicles or 

aircraft selected for this mission. 
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(2) Coordinating to ensure that all transportation operations are conducted in a safe and 

environmentally acceptable manner. 

(3) Coordinating to ensure that the RCWM is properly packaged and repackaged, if 

required. 

(4) Coordinating to ensure that standby decontamination and medical support is 

available during all phases of the transport operation. 

(5) Coordinating RCWM movement with the TEU. 

(6) Monitoring the status of the movement in coordination with RDECOM. 

(7) Coordinating the Transportation Plan with the DHHS. 

(8) Coordinating RCWM movement with the state emergency management agencies for 

all states along the transportation route. 

b. District. The responsibilities of the PM with regard to RCWM transportation 

include: 

(1) Providing proper notification to the USEPA and state regarding the transportation 

operation. 

(2) Providing physical security and emergency response capabilities in direct support of 

TEU transportation activities. 

(4) Notifying the National Response Center and the state officials of RCWM spills 

within the state, if releases exceed the reportable quantity. 

(5) Providing communications equipment to be used by the TEU supervisor, site safety 

officer, and the PM while transferring the RCWM from the IHF to helicopter for off-site 

transport. The radios and telephones permit communications among key organizations and 

with emergency services organizations. 

c. USAESCH. USAESCH is responsible for signing the hazardous waste manifest(s) 

for the RCWM (RCRA hazardous waste). 

d. RDECOM. The responsibilities for RDECOM include the following: 
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(1) Arranging for all aircraft and providing trained crews required to support the 

Transportation Plan. 

(2) Coordinating air transportation with the appropriate agencies. 

(3) Transporting RCWM from the site to the final disposition-site via helicopter and 

airplane. 

(4) Operating an operations center to monitor the complete movement of RCWM to the 

arsenal for disposal. 

(5) Implementing loading, trans-loading, and unloading plans for all operational 

activities. 

e. TEU. The TEU is a specialized unit of the Guardian Brigade that has historically 

been the sole escort of RCWM as required by AR 50-6. TEU has the following 

responsibilities for transporting RCWM: 

(1) Ensuring that all required permits are obtained to transport hazardous 

materials/waste through each jurisdiction, as required. 

(2) Providing qualified escort personnel and trained emergency response teams to travel 

with the RCWM from the IHF until it reaches its final destination. The TEU will perform 

emergency response duties as required en route. 

(3) Providing and operating chemical agent monitoring equipment for first entry, transloading, contingency, and confirmation monitoring. 

(4) Ensuring that all personnel have completed required certification training prior to 

commencing the mission. 

(5) Providing transport vehicle(s) to move RCWM from the IHF to the embarkation 

point. 

(6) Selecting specific equipment to load, trans-load, and unload cargo and prepare a 

SOP for its use. The TEU will be required to develop inspection criteria to ensure equipment 

is operable. 
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12-4. IHF Plan. PMNSCM will provide an IHF plan for the project. The IHF plan will 

address transportation of the RCWM from the “work site” to the IHF, before, during and after 

actions of receiving RCWM into the IHF, and storage and monitoring procedures. This plan 

will be included in the Work Plan. 

12-5. Transportation Plan. PMNSCM will provide a placeholder for the Transportation Plan 

for inclusion in the CSS. Once the response action is underway and RCWM has been 

encountered, packaged, and placed in the IHF, a site-specific Transportation Plan will be 

produced. This plan will address all transportation matters concerning the movement of the 

RCWM item from the IHF to its final offsite disposal location. A Transportation Plan will 

not be required if an onsite destruction option is used. 

12-6. Destruction Plan. If determined to be feasible and more cost effective than offsite 

transportation, PMNSCM may develop an onsite destruction plan. This plan would detail the 

methods and procedures for the safe destruction of RCWM onsite. The onsite destruction 

would involve equipment such as the Explosives Destruction System to safely neutralize the 

RCWM. Unless incorporated as part the CSS, the destruction plan will require the same 

approval process as the CSS. 
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APPENDIX A 

References 

A-1. Section I 

Required Publications 

Base Realignment and Closure Act of 1988, Public Law (PL) 100-526, 102 Stat. 2632. 

Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) of 

1980, PL 96-510, 94 Stat 2767, 42 USC 9601 

Defense Base Realignment and Closure Act of 1990, PL 101-510, 104 Stat. 1808. 

Defense Environmental Restoration Program, PL 99-499, Section 211, 100 Stat 1719, 10 USC 

2701 et seq. 

Resource Conservation and Recovery Act (RCRA) of 1976, PL 94-580, 90 Stat 2796, 42 USC 

6901, et seq., as amended 

Superfund Amendment and Reauthorization Act (SARA) of 1986, PL 99-499, 100 Stat 1613, 

amending CERCLA, 42 USC 9601 et seq., and miscellaneous other sections 

29 CFR 1910.120 

OSHA Hazardous Waste Operations and Emergency Response 

29 CFR 1926 

OSHA Safety and Health Regulations for Construction 

40 CFR Part 260-280 

EPA Resource Conservation and Recovery Act, as amended 

40 CFR Part 300 

EPA National Oil and Hazardous Substance Pollution Contingency Plan 

49 CFR Part 171-178 

Hazardous Materials Table, Special Provisions, Hazardous Materials Communications, 

Emergency Response Information and Training Requirements 
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DOD 4500.9-R 

Defense Traffic Regulation 

DOD 6055.9-STD 

Ammunition and Explosives Safety Standards 

AR 40-5 

Preventive Medicine 

AR 50-6 

Chemical Surety 

AR 190-11 

Physical Security for Arms, Ammunition, and Explosives 

AR 190-59 

Chemical Agent Security Program 

AR 200-1 

Environmental Protection and Enhancement 

AR 200-3 

National Resources – Land, Forest, and Wildlife Management 

AR 200-4 

Cultural Resources Management 

AR 385-10 

The Army Safety Program 

AR 385-61 

Army Toxic Chemical Agent Safety Program 

AR 385-64 

Ammunition and Explosives Safety Program 

AR 405-90 

Disposal of Real Estate 
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DA Pam 40-8 

Occupational Health Guidelines for the Evaluation and Control of Occupational Exposure to 

Nerve Agents GA, GB, GD, and VX 

DA Pam 40-173 

Occupational Health Guidelines for the Evaluation and Control of Occupational Exposure to 

Mustard Agents H, HD, and HT 

DA Pam 50-6 

Chemical Accident or Incident Response and Assistance (CAIRA) Operations 

DA Pam 200-1 

Environmental Protection and Enhancement 

DA Pam 200-4 

Cultural Resources Management 

DA Pam 385-61 

Toxic Chemical Agent Safety Program 

DA Memorandum 

Interim Guidance for Biological Warfare Materiel and Non-Stockpile Chemical Warfare 

Materiel, 5 Sept 1997 

DA Memorandum 

Applicability of Biological Warfare Materiel and Non-Stockpile Chemical Warfare Materiel 

Response Activity Interim Guidance, 19 March 1998 

DA Memorandum 

Approval of Safety Submissions for Non-Stockpile Chemical Warfare Materiel Response 

Activities, 29 February 2000 

DA Memorandum 

Assignment of Responsibility for Conduct of Pre-Operational Surveys for USACE-led 

Response Actions Involving Chemical Warfare Materiel, 29 Mar 2004 

DA Memorandum 

Chemical Protective Undergarment (CPU) Service-Live, 17 September 2002 
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DA Memorandum 

Generic Approval of Commercial Chemical Protective Equipment, 28 February 2002 

DASA-ESOH Memorandum 

Interim Guidance on Nerve and Mustard Agent Decontamination and Medical Services in 

Industrial Activities, 10 June 2003 

ER 5-1-11 

U.S. Army Corps of Engineers Business Process 

ER 200-3-1 

Formerly Used Defense Sites Program Guidance 

ER 385-1-92 

Safety and Occupational Health Document Requirements for Hazardous, Toxic, and 

Radioactive Waste (HTRW) Activities 

ER 385-1-95 

Safety and Health Requirements for OE Operations 

EP 385-1-95a 

Basic Safety Concepts and Considerations for Munitions Response to Munitions and 

Explosives of Concern Operations 

EP 385-1-95b 

Explosives Safety Submissions 

EP 1110-3-8 

Public Participation in the Defense Environmental Restoration Program (DERP) for Formerly 

Used Defense Sites (FUDS) 

ER 1110-1-12 

Quality Management 

ER 1110-1-263 

Chemical Data Quality Management for Hazardous, Toxic, Radioactive Waste Remedial 

Activities 
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 A-5 

ER 1110-1-8153 

OE Response 

ER 1110-1-8158 

Corps-Wide Centers of Expertise Program 

EP 75-1-2 

Unexploded Ordnance (UXO) Support During Hazardous, Toxic, and Radioactive Waste 

(HTRW) and Construction Activities 

EP 200-1-2 

Process and Procedures for RCRA Manifesting 

EP 415-1-266 

Resident Engineer Management Guide (REMG) for Hazardous, Toxic, and Radioactive 

Waste (HTRW) Projects 

EP 1110-1-18 

Ordnance and Explosives Response 

EP 1110-1-24 

Establishing and Maintaining Land Use Controls for Munitions Response to Munitions and 

Explosives of Concern Projects 

EP 1110-3-8 

Public Participation in the Defense Environmental Restoration Program for Formerly Used 

Defense Sites 

EM 1110-1-4009 

Munitions Response to Munitions and Explosives of Concern 

EM 200-1-2 

Technical Project Planning (TPP) Process 

EM 200-1-3 

Requirements for the Preparation of Sampling and Analysis Plans 

EM 200-1-6 

Chemical Quality Assurance for Hazardous, Toxic and Radioactive Waste (HTRW) Projects 
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EM 385-1-1 

Safety and Health Requirements Manual 

EM 1110-1-1200 

Conceptual Site Models for Ordnance and Explosives (OE) and Hazardous, Toxic, and 

Radioactive Waste (HTRW) Projects 

ETL 1110-1-502 

Security Planning and Training Requirements for Hazardous Materials Shipments 

CESO-E Memorandum 

Applicability of Biological Warfare Materiel and Non-Stockpile Chemical Warfare Materiel, 

13 April 1998 

CEHNC-OE-MCX Memorandum 

Exclusion Zone Requirements and Requirements for the Location of Personnel 

Decontamination Stations at Recovered Chemical Warfare Materiel (RCWM) Projects, OEMCX Interim Guidance Document Number 02-02, 13 March 2002. 

CEHNC-OE-MCX Memorandum 

Procedures for Assessing Munitions with Unknown Fillers, Ordnance, and Explosives Center 

of Expertise (OE-CX) Interim Guidance Document 02-03, 8 January 2003. 

USACE Memorandum 

Applicability of Biological Warfare Materiel and Non-Stockpile Chemical Warfare Materiel 

Response Activity Interim Guidance, 13 April 1998. 

USAESCH “Geophysical Investigations For Buried Munitions, Operational Procedures And 

Quality Control Manual” Draft Final, 11 June 2002. 

NIOSH/OSHA/USCG/EPA “Occupational Safety and Health Guidance Manual for 

Hazardous Waste Activities.” 
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A-2. Section II 

Related Publications 

A related publication is merely a source of additional information. The user does not have to 

read it to understand this pamphlet. 

AR 200-2 

Environmental Effects of Army Actions 

AR 385-40 

Accident Reporting and Records 

DA Pam 385-64 

Ammunition and Explosives Safety Standards 

TM 5-855-1 

Fundamentals of Design for Conventional Weapons 

EP 385-1-95a 

U.S. Army Engineering and Support Center, Huntsville Safety Concepts and Basic 

Considerations for Unexploded Ordnance (UXO) Operations 

Department of Defense Explosives Safety Board Technical Paper No.16 

Methodologies for Calculating Primary Fragment Characteristics, 1 December 2002. 

Southwest Research Institute, Final Report 

Environmental Chemistry and Fate of Chemical Warfare Agents, SwRI Project 01-5864 

March 3, 1994. 

The Sources, Fate, and Toxicity of Chemical Warfare Agent Degradation Products Nancy B. 

Munro, Sylvia S. Talmage, Guy D. Griffin, Larry C. Waters, Annetta P. Watson, Joseph F. 

King, and Veronique Hauschild. Environmental Health Perspectives Volume 107, 

Number 12, December 1999. 
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APPENDIX B 

Chemical Event Reporting 

B-1 
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B-2
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B-3 
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B-4 
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B-5 
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B-6 
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B-7
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B-8 
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 C-1 

APPENDIX C 

Chemical Safety Submission Outline 

C-1. General Guidelines. 

a. It is intended for this document to be a “stand-alone” document from the Work Plan 

and other supplemental plans for the project. 

b. This plan is built on the Work Plan and supplemental plans, so those plans must be 

complete before the CSS can be completed. 

c. The overall length of the plan should not exceed 50 single-sided pages. 

d. It is intended to provide those reviewing and approving agencies the necessary 

technical information, as required in the DA Interim Guidance of 1997. This outline has been 

agreed to by USAESCH and USATCES. No substantive changes will be made without the 

approval of the MM CX. 

e. Document control is positively essential during the drafting, editing, and publishing 

of this CSS. Each page must have a footer that identifies the document, either original date or 

date of the latest change. Additionally, a sheet shall be inserted into the front of the document 

that specifies the latest dates and changes. All changes to the original document will leave the 

bars in the outside margins to identify change locations throughout the document. 

f. It is intended for this document to include the necessary information required for an 

ESS as well, should it be necessary for the conduct of site operations for the RCWM 

activities. 
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 C-2 

C-2. Outline. 

EXECUTIVE SUMMARY 

ES1.0 Project Overview. Brief overview of the project, project objective, site history 

and background, expected RCWM/OE. (1 to 2 paragraphs maximum) 

ES2.0 Synopsis of Site Operations. 

ES2.1 Intrusive operations (brief paragraph on the activity covering; reacquisition of 

anomalies, use of UXO personnel, use of engineering controls or evacuation, use of 

fragmentation distances, use of 1 Percent Lethality distances, and anticipated date of startup 

of operations, include projected date of Pre-Operational Survey). 

ES2.2 Brief description of the MGFD - list the MGFD and reference the appropriate 

section of the body of the CSS. 

ES2.3 Brief description of the MCE - list the MCE and reference the appropriate 

section of the body of the CSS. 

ES2.4 Brief description of discovery actions for: conventional ordnance items, 

suspect ordnance items, is EOD required, if suspect RCWM TEU does assessment, if 

preliminary assessment is RCWM then packaging by TEU, transportation to IHF by TEU, 

subsequent assessment by TEU. 

ES3.0 Brief description of air monitoring for RCWM agents; using MINICAMS, for 

agents (name them), DAAMS, OP-FTIR, sentence on appropriate personal protective 

equipment dependent upon air monitoring results. 

ES3.1 Brief description of actions to be taken in the event of a MINICAMS ring-off 

or discovery of RCWM. 

ES4.0 Environmental Sampling. 

ES4.1 Brief paragraph on the types of samples that will be taken on site; surficial 

sampling, subsurface soil, pit characterization, soil disposal, aqueous investigative waste, 

decontamination water, Investigation Derived Waste (IDW). 
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ES4.2 Brief paragraph on what CWA is expected and the applicable ABPs, and how 

and who will be doing the analysis. 

ES5.0 Monitoring and Disposal. Briefly describe who will monitor for what and with 

what equipment.

ES6.0 Site Usage after cleanup, brief statement as to projected site usage after 

cleanup. 

TABLE OF CONTENTS. 

1.0 Introduction. 

 1.0.1 Project Authorization. 

 1.0.2 Objective. 

 1.0.3 Site History and Background. 

 1.0.4 Suspected CWM/MEC. 

1.1 Conventional Ordnance Handling Plan. 

 1.1.1 Conventional UXO Types. 

 1.1.2 On-Site Disposal Operations. 

 1.1.3 Explosives Siting Plan Requirements. 

 1.1.4 Explosives Management Plan Requirements. 

1.2 Summary of Actions (brief paragraph describing the below, list personnel limits for 

each activity). 

 1.2.1 CWM. 

 1.2.2 Conventional UXO. 

 1.2.3 HTW (only for ABPs and agent-contaminated media). 
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 1.2.4 Activity Hazard Analysis for RCWM and Explosives-related tasks (all others 

will be located within the SSHP). 

1.3 Organizational Responsibilities. 

 1.3.1 UXO Contractor. 

 1.3.2 HTW Contractor. 

 1.3.3 ECBC (or equivalent organization). 

 1.3.4 TEU. 

 1.3.5 Industrial Air monitoring (for the chemicals CG, AC, CK, PS, etc.) 

 1.3.6 USAESCH (include Chemical Event Reporting and Safety Oversight of Site 

Operations). 

 1.3.7 Corps District. 

1.4 Exclusion Zones (MGFD and MCE). 

 1.4.1 Fragmentation Distance of MGFD. 

 1.4.2 Public Access Exclusion Distance (PAED) 

 1.4.3 1 Percent Lethality Distance for MCE. 

 1.4.4 Interim Holding Facility. 

1.5 Maps and Drawings (use 1 inch = 400 feet, or when smaller scales are used, ensure 

all distances to objects within the map are clearly marked as to what the items are and the 

distances to those items (DOD 6055.9). 

 1.5.1 Fragmentation Zones (QD Arcs) (if applicable). 

 1.5.2 1 Percent Lethality Distance. 

 1.5.3 Public Access Exclusion Distance (PAED). 
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 1.5.4 Installation Boundaries. 

 1.5.5 Explosive Storage Locations. 

 1.5.6 IHF Location. 

 1.5.7 Overall Site Map. 

 1.5.8 Predetermined UXO Disposal Locations for Safe-To-Move UXO. 

2.0 Sampling Plan Summary. 

2.1 Introduction. 

2.2 Soil Sampling. 

 2.2.1 Pit Characterization Sampling. 

 2.2.2 Soil Disposal Sampling. 

2.3 Aqueous Sampling. 

2.4 Scrap and Non-RCWM Intact Container Sampling. 

3.0 Air Monitoring Plan Summary. 

3.1 Introduction. 

3.2 HTW (for those chemicals that are agent-related only). 

3.3 Chemical Warfare Agents. 

3.4 Environmental/Industrial (for the chemicals CG, AC, CK, PS, etc.) 

4.0 PPE and Decontamination Summary. 

4.1 PPE Summary. 

 4.1.1 General Requirements. 
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 4.1.2 Task-specific Levels of PPE. 

4.2 Personal Decontamination Procedures. 

 4.2.1 General Decontamination Procedures. 

 4.2.2 Specific Decontamination Procedures. 

4.3 Equipment Decontamination Procedures. 

 4.3.1 General Decontamination Procedures. 

 4.3.2 Specific Decontamination Procedures. 

5.0 Medical Support Summary. 

5.1 Project Resources. 

5.2 Health Care Facilities - where to take casualties (chemical and non-chemical). 

5.3 MedEvac Procedures. 

5.4 Emergency Contact Information (for health care facilities). 

5.5 Directions to health care facilities. 

6.0 Public Protection Plan Summary. 

6.1 Introduction. 

6.2 Public Notifications. 

6.3 Emergency Operations. 

6.4 Downwind Hazard Modeling (D2PC) Calculations. 

7.0 Interim Holding Facility Siting Plan Summary. 

7.1 Introduction. 
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7.2 IHF Container Description. 

 7.2.1 Location and Layout (Include a map, or refer to existing maps that clearly 

show the layout and distances identified in 7.3). 

7.3 IHF Siting Requirements. 

 7.3.1 Public Access Exclusion Distance and 1 Percent Lethality Distance. 

 7.3.2 Inhabited Building Distance (IBD). 

 7.3.3 Net Explosive Weight (NEW). 

 7.3.4 Evacuation/Protective Distance. 

 7.3.5 Intra-line Distance. 

 7.3.6 Public Traffic Route (PTR) Distance. 

 7.3.7 Public Notification. 

 7.3.8 IHF Access Controls. 

 7.3.9 Multiple IHF Siting. 

7.4 IHF Use and Occupancy. 

7.5 Security. 

7.6 Evacuation. 

 7.6.1 Notification for IHF Entry. 

 7.6.2 Notification Procedures. 

8.0 MEC Transportation Plan Summary. 

8.1 Procedures. 

 8.1.1 Discovery and Transport to Storage Area. 
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 8.1.2 Packaging. 

 8.1.3 Manifesting/Placards. 

 8.1.4 Off-site Selection. 

 8.1.5 On-site Disposal Facility. 

8.2 Emergency Response. 

 8.2.1 Incident Containment and Controlling of Hazardous Waste. 

 8.2.2 Military EOD Participation. 

9.0 RCWM Transportation Plan Summary 

9.1 Discovery and Transport to IHF. 

9.2 Off-site Transport (This is a placeholder for PMNS in the event that RCWM is 

discovered). 

9.3 On-site Destruction 

10.0 Engineering Controls Summary. 

10.1 Introduction. 

10.2 Brief description of what types will be used at the project: VCS, ECS, Filters, 

Blast mitigating devices and their effects on the safety distances for the MGFD and the NOSE 

distance. Full technical details will be available on-site, or upon request, or included for 

“first-used” technology. 

10.3 Evacuation/Shelter-in-Place. 

11.0 Post-Recovery Assessment Activities Summary. 

11.1 Brief description of what assessment activities will be used at the project, what 

types of engineering controls will be used to mitigate release of RCWM vapors into the 

atmosphere during post-recovery assessment activities, brief discussion on what technologies 
EP 75-1-3 

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 C-9 

will be used during the assessment process. Identify 1 Percent Lethality Distance and NOSE 

distance for this operation and any necessary Q-D Arcs for explosively configured items. 

LIST OF FIGURES. 

a. In Section 1: 

(1) Explosives Siting Distances, Storage Site (Q-D Arcs)(if applicable). 

(2) Fragmentation Zones (Q-D Arcs)(if applicable). 

(3) Installation/Site Boundaries. 

(4) 1 Percent Lethality Distance/IBD/PAED. 

(5) Areas Designated for Disposal of “safe-to-move” conventional UXO. 

b. In Section 6: Wind Rose Data for Site. 

c. In Section 7: IHF Layout with all applicable distances and Q-D arcs identified. 

d. In Section 11: Layout of area where Assessment activities takes place. 

LIST OF TABLES. 

a. In Section 1: 

(a) 1 Percent Lethality Distances for MCE(s). 

(b) Activity Hazard Analysis Tables for all RCWM and Explosives-related tasks. 

b. In Section 2: Analytical Methods for RCWM 

c. In Section 3: Air Monitoring Matrix 

d. In Section 4: 

(1) PPE Requirements by Task. 

(2) PPE Upgrade Criteria. 
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(3) Decontamination Applications. 

(4) Personnel Decontamination Procedures. 
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C-3. Chemical Safety Submission Information Sheet (CSSIS). 

The following items are keyed to the subparagraphs of DOD 6055.9-STD, Revision 3, 

Chapter 5, Paragraph 5.4.4. This sheet shall be used to identify where the following areas of 

interest may be found within the CSS. This CSSIS will be the first page in the CSS. 

DOD 6055.9 

Paragraph Topic Location found in the CSS 

5.4.4.3.2 Drawings of Site Maps (typically 1 in equals not more 

than 400 feet) 

5.4.4.3.2 Fragmentation range (MSDs and Overpressure) 

5.4.4.3.2 Downwind Hazard distances (1 Percent Lethality, 

PAED) 

5.4.4.3.3 Distances to installation/site boundaries 

5.4.4.3.3 Public Railways/Highways 

5.4.4.3.3 Power Transmission and utility lines 

5.4.4.3.4 Other inhabited facilities within the IBD 

5.4.4.3.5 Description of Hazardous materials or items 

5.4.4.3.5 Quantities, hazard class and division of material/items 

(IHF only) 

5.4.4.3.6 Personnel limits for each operation (IHF) 

5.4.4.3.1 General details (Project Background) 

5.4.4.3.8 Brief summary of design considerations to reduce Q-D 

(Engineering Controls) 

5.4.4.3.9 Type and arrangement of Operations 

5.4.4.3.10 Topographic map (usually not needed unless using 

topography to reduce or mitigate blast, downwind 

hazard areas) 

5.4.4.3.11.1 Personal protective clothing and equipment 

5.4.4.3.11.2 Treatment of effluent and waste 

5.4.4.3.11.3 Adequacy of medical support 
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 C-12 

DOD 6055.9 

Paragraph Topic Location found in the CSS 

5.4.4.3.11.4 Average Wind Speed and Direction (Wind Rose data) 

5.4.4.3.11.5 Other support facilities pertinent to chemical safety 

5.4.4.3.11.6 Shelter-in-place 

5.4.4.3.11.5 Available resources (Project structure – organizations) 

5.4.4.3.11.6 Evacuation 

5.4.4.3.11.6 Disaster control plan (Public Protection Plan/PAP) 

5.4.4.3.8 Emergency destruction of (specify item) (only if EDS 

is programmed) 

5.4.4.3.9 Intentional detonation of munitions 

5.4.4.3.11.6 Warning and detection systems 

5.4.4.3.11.7 Hazard Analysis (Risk Assessment) 

5.4.4.3.12 Deviations from Safety Standards 
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APPENDIX D 

Pre-Operational Surveys 

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USACE Pre-Operational Survey Requirements and Procedures for MM CX 

Recovered Chemical Warfare Materiel (RCWM) Response Actions 

1. General. 

 a. All USACE Recovered Chemical Warfare Materiel (RCWM) projects will have a 

Pre-Operational Survey, here after called “Survey” conducted and successfully 

completed on the site prior to any intrusive activities. Headquarters, United States Army 

Corps of Engineers (HQUSACE) is responsible for the execution of the Survey, as the 

MACOM. HQUSACE has delegated the responsibility for the conduct of the Survey to 

the Commander, U.S. Army Corps of Engineers, U.S. Army Engineering and Support 

Center, Huntsville (USAESCH), Huntsville, Alabama. The Military Munitions Center of 

Expertise (MM CX) within USAESCH will lead the Survey. 

 b. All planned RCWM response actions must undergo a Survey prior to the start of 

operations. This includes sampling efforts, if the intent is to dig to an anomaly and there 

is a potential to encounter RCWM, or if provisions are made to store RCWM. Surveys 

are valuable and necessary tools in the preparation of chemical agent operations at 

response action projects. Surveys are intended to judge the readiness of those 

organizations performing response actions activities to operate in a safe and healthful 

manner and are the final step in gaining approval to conduct operations. Surveys are 

not training events, nor are they the time to draft safe work procedures. It is the 

responsibility of the Project Manager (PM) to have response personnel fully trained, 

practiced, and prepared for the Survey prior to arrival of the Survey team. 

 c. The Survey evaluates planned activities relative to safety, health, environment, 

and operational readiness and recommends whether the planned activities should be 

allowed to transition to chemical agent operations. Survey teams will consist of subject 

matter experts from the organizations listed below, as available. The Survey will be 

conducted under the direction and control of the U.S. Army Corps of Engineers. Survey 

team members will be selected based on technical background and areas of expertise. 

The Project Delivery Team (PDT) consists of any personnel responsible for the 

execution of the project on the ground. Under no circumstances will members of 

the PDT serve as evaluators on the Survey Team. This is necessary to preclude 

any possibility of biased participation. The MM CX will select the team members 

and serve as the Survey Team Leader. The organizations below will be invited to 

participate in the Survey. However, based on availability, the minimum acceptable 

number of personnel required to participate on the Survey team, as evaluators, will be 

three; the MM CX (lead), United States Army Technical Center for Explosives Safety 

(USATCES), and one from any of the other organizations identified as evaluators listed 

below. 

 (1) The PM for the site (both District and USAESCH) or Installation Commander 

(non- evaluator). 

 (2) U.S. Army Center for Health Promotion and Preventive Medicine (USACHPPM) 

(evaluator). 

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 (3) Each agency responsible for executing on-site RCWM activities (e.g., The 

Guardian Brigade (Technical Escort Unit), U.S. Army Research Development and 

Engineering Command (ECBC) (evaluator). 

 (4) Program Manager for the Elimination of Chemical Weapons (PMECW) 

(evaluator). 

 (5) HQ USACE Safety and Occupational Health Office (CESO) (evaluator). 

 (6) For active installations and BRAC project sites, or Work for Others, the 

corresponding Safety offices will be invited to attend (non-evaluator). 

 

 d. Surveys will examine all aspects of chemical agent operations and emergency 

response activities. The Survey team will review pertinent documentation, inspect 

selected processes, support equipment and facilities, as appropriate, and witness 

selected activities and operations. Operations during Surveys will be conducted as 

though chemical agent and/or explosives were present. If specific simulations or 

deviations from this concept are required, they must be approved by the Survey team 

leader before the start of the Survey and explained in the Survey report. The need for 

significant simulations or deviations may indicate that the system is not ready to operate, 

precluding successful completion of the Survey (e.g., having to simulate that the 

chemical agent filtration system (CAFS) (if used) is fully operational due to mechanical 

difficulties, or other similar instances). All approved Standing Operating Procedures 

(SOPs), work plans, checklists, maps of the project site, a copy of the Chemical Safety 

Submission (CSS) and approval documents, environmental requirements, security plan, 

and other documentation will be provided to team members prior to the Survey. Any 

documentation needed by or requested by Survey team members will be made available 

on site or, if requested, prior to the Survey. Fourteen days prior to the projected date of 

the Survey, the PM will provide 5 CDs with copies of all site documents discussed above 

to the MM CX for distribution to the Survey Team Members. 

 e. Deliberate unearthing, exposing, accessing, or contacting RCWM is not permitted 

until all required CSS approvals are obtained and a Survey has been successfully 

completed. 

 f. Operational personnel will perform a dry run in the presence of MM CX and Site 

Safety personnel prior to the restart of any RCWM operation that has not been 

conducted in the last 90 days. The MM CX, in coordination with project safety personnel, 

will determine the actions required to verify readiness. These actions will be based on 

the scope of operations and length of delay between the initial Survey and the re-start of 

operations and may result in conducting another Survey. 

 g. See Glossary for definitions and Attachment A for references and sources of 

information. 

2. Applicability.

 a. These requirements and procedures are applicable to all RCWM response 

activities. These requirements and procedures do not apply to RCWM emergency 

response actions, nor do they apply to stockpile activities, which are covered under AR 

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385-61. In addition, while requirements for Surveys of systems used for the disposal of 

RCWM are covered under AR 385-61, the interrelation between the disposal system and 

RCWM removal actions is subject to these requirements and procedures. 

 b. Changes in plans or operations that result in a greater hazard may require a 

follow-on Survey to assess safety, health, and readiness. In such situations, the MM 

CX, in coordination with project safety personnel, and others, as necessary, will 

determine the requirement for subsequent Surveys. 

3. Survey Preparation. Key considerations in preparing for a Survey are coordinating, 

planning, defining the scope of the Survey, selecting a qualified Survey team, and 

developing a Survey plan. Planning timetables are provided at Appendix B for a Survey. 

A typical sequence of events associated with preparation for the Survey is as follows: 

 a. The PM, considering the progress toward operational readiness, initially 

coordinates the Survey date. This information will be provided to the MM CX to facilitate 

early planning for the Survey. Early coordination with the MM CX, even though the 

actual date may not be available, is important to facilitate planning and for coordination 

with external agencies which will be asked to participate. The PM will provide funding to 

MM CX and/or team members necessary for Survey activities. 

 b. Two weeks prior to the start of the Survey: 

 (1) MM CX will prepare a Survey plan. The plan will be written to reflect the scope 

of work and site-specific objectives, identify the personnel who will be members of the 

Survey team, and provide a general schedule for Survey team activities. Survey plans 

will include a comprehensive list of areas specific to the operation to be surveyed. The 

plan will be used to assure completeness of the Survey. A guide for selecting functional 

areas for inclusion in the Survey plan is at Appendix C. Survey plans establish 

personnel requirements and requirements for the use of technical specialists to 

accomplish the Survey. Personnel will be selected for specific assignments based on 

experience and training which are commensurate with the complexity and special nature 

of the activities being surveyed. The plan will be provided to the PM, and others as 

appropriate, for review and comment. 

 (2) The Survey team leader will certify to the site PM that all Survey team members 

have completed 40 hours of Hazardous Waste Operations and Emergency Response 

(HAZWOPER) training, and required refresher training, and have respirator/medical 

clearance. Survey team members must provide documentation to the Survey team 

leader so he or she can certify to the PM that team members are trained and cleared.) 

Exceptions to this requirement (e.g., subject matter experts brought on-site for limited 

duration to investigate a particular aspect of the Survey) require approval of the 

executing USACE District Safety and Occupational Health Office. Each team member is 

required to wear the appropriate personal protective equipment required by the site 

safety and health plan to include OSHA approved safety footwear while conducting the 

Survey. 

 c. One week prior to the start of the Survey: 

 (1) The PM will submit a memorandum to MM CX detailing the status of 

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preparation of the project site for the Survey and the status of the required 

documentation (CSS, Work Plan, etc.), in accordance with Attachment B of this 

guidance. Milestones will be provided for all required items not completed. At this time, 

the MM CX, in coordination with the PM, will determine if the Survey can be conducted 

on the date scheduled or must be re-scheduled. 

 (2) The Survey team leader will verify that all Survey team members have copies 

of the final approved version of the CSS (usually digital) via e-mail or telephone. The 

copies will be federal express shipped to the team members IAW Attachment B. 

 

 

d. The PM will certify telephonically to the MM CX that the project is ready for 

the Survey. The Survey will not begin until the PM has made this verification. 

4. On-Site Activities.

 a. The first day of the Survey, the Survey team leader will meet with the Survey team 

members to designate roles, areas of responsibility, and to ensure all Survey team 

members understand how the category of Non-conformances/Observations will be 

determined. 

 b. An entrance interview will be held with the PM (and others as mutually agreed to 

by the PM and the Survey team leader). The purpose, scope, schedule, and 

requirements of the Survey will be discussed and administrative support requirements 

associated with the Survey will be agreed upon. The types of simulations permitted and 

the ground rules for conducting the Survey will be provided, in writing, by the Survey 

team leader to the PM. If previously agreed to by the PM and the Survey team leader, 

participation in the Survey may be opened to other interested parties (however, the PM 

is responsible for ensuring visitor compliance with safety and work plan requirements). 

 c. Daily out-briefs will be conducted so that the Survey team leader can discuss the 

Non-conformances/Observations related to that day’s activities with the PM (and others 

as determined by the PM and the Survey team leader); all supervisors of the 

organizations who are responsible for correcting Non-conformances/Observations 

should be represented. Attendance at, and duration of, this meeting will be held to the 

minimum necessary. 

 d. The Survey team members will review the following activities/documents during 

the Survey: 

 (1) Plans, procedures, and other relevant documentation (including Material Safety 

Data Sheets (MSDSs), SOPs, laboratory procedures, and contingency plans) will be 

reviewed for availability, consistency with the CSS, and compliance with applicable 

regulations. 

 (2) Memorandums of Agreement (MOAs) or Memorandums of Understanding 

(MOUs), explosives storage licenses, pending and existing contracts (as applicable), 

and other permits, as applicable, will be reviewed for completeness and accuracy. 

 (3) System test reports and approvals, as necessary and as cited in the pre-op 

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Survey plan, will be reviewed for completeness and accuracy. 

 (4) Training records will be reviewed to verify the appropriateness of training 

subjects. 

 (5) Respirator issue documentation will be reviewed to verify completion of medical 

screening and respirator approval. 

 (6) All pertinent facilities and equipment (e.g., support facilities, interim holding 

facility, 

laboratory, fire support, medical support, utilities, warehouses, offices, etc.) will be 

inspected to verify consistency and compliance with the CSS and supporting 

documentation. 

 (7) All portions of the operations are subject to being witnessed by the Survey 

team. The 

contractor and support personnel must be prepared to conduct operations with the 

minimum number of simulations, but live chemical agents or explosives will not be 

processed during the Survey. All simulations must be approved by the Survey team 

leader prior to beginning the Survey. 

 (8) Emergency response plans will be exercised and evaluated for effectiveness, 

consistency and compliance with the CSS and supporting documentation, and 

availability of, and employee familiarization with, required emergency equipment. 

Emergency response exercises may include any of the following, individually, or in 

combination: 

 (a) Agent detected in selected areas of the site. 

 (b) Agent exposure to one or more workers. 

 

 (c) Explosion with or without agent release/contamination. 

 (d) Industrial accident requiring a response from the medical support. 

 (e) Accident requiring extraction of a worker. 

 (f) Loss of utilities. 

 (g) Fire. 

(9) The wearing of Personal Protective Equipment (PPE). 

 (10) The use of monitoring equipment during the Survey. 

 e. At the conclusion of the Survey, the Survey team will prepare a draft report. (See 

Appendix D for report format.) The report will contain narrative related to the Survey 

conduct, Non-conformances/Observations, recommendations, and conclusions. Nonconformances/-Observations will be presented on Survey Worksheets (Appendix E) and 

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will be designated as follows: 

 (1) Category 1 - Items which are considered essential to the safety of personnel or 

the environment or the operational readiness of the system. These items must be 

resolved before the start of operations. Approval can be delegated to an appropriate 

person as determined by the Survey team leader, however it is anticipated the Survey 

team leader will remain on-site until all Category 1 findings have been resolved. 

 (2) Category 2 - Items which are not considered immediately essential to the safety 

of personnel or the environment or the operational readiness of the system, but which 

must be corrected. Category 2 Non-conformances/Observations must be resolved as 

soon as practical. A suspense date for correction of these items will be established 

before project site operation activities begin. A point of contact for reporting correction of 

category 2 Non-conformances/Observations will be specified in the Survey report. 

 (3) Category 3 - Items which were noted by the Survey team, but which were 

corrected 

while the Survey was being conducted. No additional response is required. 

 (4) Category 4 - Items that were noted by the Survey team, but which are not 

categorized as 1, 2, or 3. No response is required. 

 f. An exit briefing will be conducted for the PM on the last day of the Survey. 

Attendance at the briefing may be opened to others, if previously agreed to by the 

Survey team leader and the PM. 

 g. Actions Following a Survey. 

 (1) The Survey team leader may remain on site at the conclusion of the Survey to 

verify resolution of Non-conformances/Observations. 

 (2) The final Survey report will be prepared by the Survey team leader within one 

week of Survey completion. Information copies will be provided to the site PM, CESO, 

and each Survey team member. In some cases, on-site validation may be necessary 

and may require repeating some or all phases of the original Survey. The determination 

will be reflected in the final Survey reports. On-site validation may delay the final Survey 

report until Non-conformances/Observations are satisfied. 

 (3) After the PM provides the MM CX written evidence of resolution of all category 1 

recommendations and plans have been established for resolution of all category 2 

recommendations, the MM CX will notify CESO the Survey has been successfully 

completed. Commander, USAESCH, upon satisfaction that the CSS has all required 

approvals and that category 1 and category 2 findings are properly resolved, will give 

approval to begin site operations. 

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Glossary 

Chemical Safety Submission (CSS): The document that serves as the specifications for 

conducting work activities at the project. The CSS details the scope of the project, the 

planned work activities, and potential hazards (including the MCE) and the methods for 

their control. 

Chemical Warfare Materiel (CWM): An item configured as a munition containing a 

chemical substance that is intended to kill, seriously injure, or incapacitate a person 

through its physiological effects. Also includes V- and G-series nerve agent, H-series 

blister agent, and lewisite in other-than-munition configurations; and certain industrial 

chemicals (e.g. hydrogen cyanide (AC), cyanogens chloride (CK), or carbonyl chloride 

(called phosgene or CG) configured as military munitions. Chemical agent identification 

sets are considered CWM. 

Deliberate unearthing/exposing: Intentionally exposing an item. 

Non-conformance: Deviation from a written requirement. 

Observation: Deviation from expected performance or a noted opportunity for 

improvement. 

PM: The USACE individual with responsibility for managing a RCWM project. 

Readiness review: A local activity, which includes process demonstrations, to assure 

that a system is ready to successfully undergo a Survey. 

Recommendation: A method the Survey team believes will satisfy the intent of the 

associated non-conformance or observation. Unless otherwise noted, recommendations 

are not mandatory in detail. 

Recovered chemical warfare materiel (RCWM): Non-stockpile CWM that was previously 

discarded, buried, or fired and discovered either unexpectedly or during planned 

environmental restoration projects. RCWM does not fall within the scope of the Army 

Chemical Surety Program. 

RCWM response action: The planned, longer-term remediation of an area known or 

suspected to contain RCWM, in accordance with DERP procedures; may be preceded 

by time-critical or non-time critical removal activities. Incorporates the planned 

progression through the four phases of hazard identification, site investigation, response, 

design and cleanup, and site closeout. 

Survey: A formal review/assessment of a response action project immediately prior to 

beginning RCWM and/or explosives operation activities. Surveys may also be applied to 

activities involving other hazardous materials when appropriate. In this guidance 

document, this term encompasses RCWM Surveys and readiness reviews. 

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Attachment A 

References 

1. AR 385-61, The Army Chemical Agent Safety Program 

2. DA Pam 385-61, Toxic Chemical Agent Safety Standards 

3. DASA(ESOH) memorandum dated 5 Sep 1997, SUBJECT: Biological Warfare 

Materiel and Non-Stockpile Chemical Warfare Materiel Response Activities 

4. 29 CFR 1910, Occupational Safety and Health Standards 

5. DOD 6055.9-STD, DOD Ammunition and Explosives Safety Standards 

6. AR 50-6, Chemical Surety 

7. AR 385-64, U.S. Army Explosives Safety Program 

8. DA Pam 385-64, Ammunition and Explosives Safety Standards 

9. AR 200-1, Environmental Protection and Enhancement 

10. 40 CFR Part 260, et al. Military Munitions Rule: Hazardous Waste Identification and 

Management; Explosives Emergencies; Manifest Exemption for Transportation of 

Hazardous Waste on Right-of-Ways on contiguous properties; Final Rule 

11. EP 75-1-3, RCWM Remedial/Response Actions. 

12. Memorandum, DASA-ESOH, dated 29 Mar 2004, SUBJECT: Assignment of 

Responsibility for Conduct of Surveys for USACE-led Response Actions involving 

Chemical Warfare Materiel. 

13. Memorandum, HQ, USACE-CESO-E, 25 Mar 2003, SUBJECT: HQs, COE 

Delegation of Authority. 

14. Memorandum, HQ, USACE-CESO-E, 5 Apr 2004, SUBJECT: Assignment of 

Responsibilities for Conduct of Surveys for USACE-Led Response Actions involving 

Chemical Warfare Materiel. 

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Attachment B 

Planning Timetable for Pre-Operational Surveys 

Action Time Responsible 

Office/Individual 

Pre-coordination ASAP PM 

Preliminary request for Survey to 

MM CX 

Determine if Survey can be 

conducted as scheduled 

5 weeks before Survey PM 

MM CX, CESO 

Prepare Survey plan (using CSS, 

WP/SSHP, and SOPs) 

Memo to MM CX detailing status 

of preparation for Survey and 

status of required documentation. 

Provide copies of final approved 

CSS, Work Plan, and Site SOPs 

to Survey team leader as required 

(normally 5 copies on CD) 

Survey plan to Survey team 

members 

2 weeks before Survey MM CX 

PM 

PM 

MM CX 

Certify site readiness to MM CX 

telephonically 

1 week before Survey Site PM 

Review final documentation 1 week before Survey Survey team 

members 

Initial team meeting First day of scheduled Survey Survey team leader 

Entrance interview with site PM First day of scheduled Survey Survey team leader 

Daily outbriefs The last part of each Survey 

day 

Survey team 

Conduct the Survey (usually 1 week in duration) Survey team 

Draft Survey report Before exit briefing Survey team 

Exit briefing Final day of scheduled 

Survey 

Survey team leader 

Final report 

Notification of successful 

completion to CESO 

1 week after Survey MM CX 

MM CX 

Authorization to operate After category 1 

recommendations are 

resolved and MM CX 

recommendation obtained 

Commander, 

USAESCH 

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Attachment C 

Sample Pre-Operational Survey Guide 

Operation-specific Survey plans will be developed for each Survey. Examples of items 

that might be included in a plan are provided below. This list should not be considered 

all-inclusive, nor should any item be included in an operation-specific Survey plan solely 

because it appears here. 

Documentation 

SOPs correct, approved, signed, and appropriately available at the work site 

Chemical Safety Submission (CSS) current and approved 

Contingency procedures approved 

Site monitoring plan approved 

Hazards analysis completed and all identified hazards managed appropriately 

Hazard tracking log maintained 

Training records complete and personnel appropriately certified 

Operational test records for monitoring systems 

Preventive maintenance plan complete and adequate 

Preventive maintenance records available and accurate 

Environmental compliance documentation complete 

Policies in place for deviations from approved procedures 

Data collection system adequate; all significant items recorded 

Calibration and test records adequate 

Identification of decontaminated items 

Agent/munition accountability procedures/records 

Waste Management Plan 

Chemical Hygiene Plan 

Test reports of engineering controls 

Facilities and Equipment 

System/process equipment properly operational 

Monitoring and detection equipment in place and functioning properly 

Equipment properly calibrated and marked 

Decontamination systems adequate 

Material handling equipment properly maintained and operated 

Porous material in potentially contaminated areas minimized 

Tools used in potentially contaminated areas segregated and marked 

Operations/Maintenance 

Emergency notification procedures demonstrated and adequate 

Operator proficiency demonstrated 

Maintenance proficiency demonstrated 

Laboratory and monitoring procedures demonstrated 

Adequacy of communications demonstrated 

Protective clothing selection, inspection, and use demonstrated 

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Contingency 

Emergency Operations Center 

Communications 

Handling of agent contaminated casualties 

Loss of utilities 

Industrial accident 

Agent alarm 

Non-agent alarm 

Leaker detected 

Hot line equipment and procedures 

HAZMAT response 

Knowledge/communication of muster points 

Personnel accounting 

Safety 

Compliance with Occupational Safety and Health Administration standards 

Electrical equipment properly rated and installed 

Emergency showers and eyewashes properly located, marked/identified, and function 

tested 

Lifting devices load/function tested, marked, and records maintained 

Noise hazard areas marked and hearing protection available 

Eye hazard areas marked and eye protection available 

Proper labeling of chemicals 

Current MSDSs are available 

Respirators (to include SCBA) properly fit tested 

Documentation of breathing air (Grade D or better) 

Proper storage for flammable materials 

Hand held fire extinguishers available 

Personnel and explosives limits posted and observed 

Explosives and chemical agent placarding 

LPS (down conductors, air terminals, etc.) 

Safety responsibilities properly located in the management structure 

Eating, drinking, and smoking areas identified and approved 

Mask fitting procedures 

Criteria for change-out of mask canisters 

First aid kits available where necessary 

Environmental 

Hazardous material and waste properly stored and labeled 

90-day accumulation sites properly identified 

Compliance with all RCRA, CAA, CWA, TSCA requirements and Permit Conditions 

Spill cleanup kits properly constituted and located 

Record keeping 

Environmental inspections accomplished 

Medical Support Operations 

Training/certification of medical personnel 

Manning levels adequate 

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Facilities and equipment adequate 

Necessary support in place 

Record keeping 

Pre-employment physicals 

Medical evaluations of potentially exposed individuals, as a result of the Survey 

simulated exposure 

Security Support Operations 

Access control/Entry Control Rosters 

Key control 

Security lighting 

Guard orders 

Fire Support Operations

Equipment 

Personnel manning level 

Response time 

Fire inspections 

Storage Facility (Interim Holding Facility Area)

Assessment Holding Facility 

 Glovebox 

 Engineering Controls 

 Inventory Records 

 Standing Operating Procedures 

Munitions Assessment Review Board Holding Facility 

Interim Holding Facility 

 Inventory records 

 Operations 

 Standing Operating Procedures 

Magazines 

 Licensed 

 Site approval 

 Inventory Records 

 Hazard symbols 

 Access control 

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Attachment D 

Format for a Survey Recommendation to Approving Authority 

1. Prepare in a memorandum format: 

a. Title Page: Include project title, site location and organization, as appropriate, 

and signatures indicating submittal and approval of the report. 

b. Introduction: Statement of purpose of the Survey 

c. Background: Dates and facts pertinent to the Survey (briefings, meetings, 

notifications, etc.) 

d. Team members 

e. Scope: A statement of what was included and what was excluded from the 

Survey 

f. General: When appropriate, any other comments bearing on the Survey or its 

result 

g. Non-conformances/Observations: Each Non-conformance or Observation 

must be supported by a recommendation for improvement. A worksheet and 

instructions are at Attachment E. 

h. Conclusions. The assessment of the Survey team leader regarding the ability 

of the operation to proceed in a safe and efficient manner. 

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ATTACHMENT E 

Pre-Operational Survey Worksheet Item No: 

1. Location: 2. Name of Survey Team Member: 

3. Description of Observation or Action: 

4. Reference/Recommendation: 

(For non-conformances, reference specific requirement in this block)

5. Survey Report Category: (mark appropriate category) 

 1 Must be closed prior to recommendation to start operations 

 2 Corrective Action/improvement plan must be accepted prior to recommendation to start operations 

 3 Corrected and closed during the Survey; no additional response required 

 4 No Response required

6. Response: 

7. Response provided by: 

____________________________ _________________________ _____________ 

 (Name and Org) (Signature) (Date) 

8. Evaluation of corrective action/improvement: 

(Check one) 

Satisfactory _______________________________________ _______________ 

Unsatisfactory (Signature) (Date)

9. Closed: 

Survey Team Leader: ________________________________ ____________________ 

 ( Signature) ( Date) 

Starting category: ______ Final category: _________ 

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Instructions 

Block Instructions 

Item No. Assigned by survey team chairman. Identifying numbers will have the form yyyy-xxx#-zzzz, where: 

 yyyy = calendar year survey was conducted, 

 xxx# = a three-letter code to identify the location with a single number to uniquely identify this survey, 

 usually assigned sequentially, as scheduled. For surveys that are conducted in phases, a letter 

 corresponding to the phase will be included 

 zzzz = a sequential number assigned to worksheet 

Example: 2004-SIB-01 (First Worksheet for the Camp Sibert Pre-Op conducted in 2004) 

Note: Worksheets for a survey report will be numbered sequentially, without gaps. If a number in the sequence is not 

used for some reason, a placeholder worksheet will be included with that number and descriptive verbiage to identify 

that fact. 

1 Location of Project Site 

2 Name of team member who noted the condition. 

3 Note the observation or action. 

4 If the observation is a non-conformance action, a reference is required. The reference may include a brief 

restatement of the requirement. Include a recommended corrective action. A non-conformance finding is one that the 

action is required by a project document and not being accomplished. 

5 Marked by the Survey Team Leader after consultation with team members. 

6 The response from the project team to the observation and corrective action done to resolve the finding. 

7 Which Project Team Member provided the response/corrective action.. 

8 The Survey Team Member who made the observation, or the Survey Team Leader will observe/review the corrective 

action and check the appropriate section (Satisfactory or Unsatisfactory) 

9 The Survey Team Leader will close out the finding/observation in this block. Both the starting category of the 

finding/observation and final category will be annotated. 

Note: It is intended this form be filled out in longhand, not to be typed in, and 

signatures of appropriate personnel on the form.

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 E-1 

APPENDIX E 

Generic Approval Letter 
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E-2
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E-3
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30 Nov 04

E-4
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30 Nov 04 

E-5
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30 Nov 04

E-6
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30 Nov 04 

E-7
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30 Nov 04

E-8
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30 Nov 04 

E-9
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30 Nov 04

E-10
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30 Nov 04 

E-11
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30 Nov 04

E-12
EP 75-1-3 

30 Nov 04 

E-13
EP 75-1-3 

30 Nov 04

E-14
EP 75-1-3 

30 Nov 04 

E-15
EP 75-1-3 

30 Nov 04

E-16 
EP 75-1-3 

30 Nov 04 

 F-1 

APPENDIX F 

Soil and Bulk Item Headspace Analysis Procedures 

SOIL: Under normal conditions soil sample headspace analysis will be conducted using the 

Miniature Chemical Agent Monitoring System (MINICAMS). If Depot Area Air Monitoring 

System (DAAMS) tubes are used in place of MINICAMS, start the following sequence at 

step 12. DAAMS tubes must be used to confirm all positive MINICAMS results above 0.2 

Airborne Exposure Limit (AEL). This monitoring shall be used to screen soil samples for H, 

HN1, HN3, and L contamination. Headspace monitoring for Phosgene (CG), Chloropicrin 

(PS), Cyanogen Chloride (CK), or chloroform is not necessary due to the extreme volatility of 

these compounds. Headspace Monitoring Procedures of soil samples using the MINICAMS 

and DAAMS are as follows:

1. Contractor delivers soil sample to monitoring personnel with proper CoC documentation. 

2. Don protective gloves. Don protective mask when soil sample is collected by personnel 

wearing Environmental Protection Agency (EPA)/ Occupational Safety and Health 

Administration (OSHA) Level C Personal Protective Equipment (PPE) or above. 

3. Place up to six samples in a heated sample box. Open bags and remove sample jar lids. 

Insert temperature probe into a selected soil sample. Close sample box lid and allow 

samples to equilibrate at 90°F (plus or minus 10°F) for 15 minutes. 

4. Insert MINICAMS probe into the heated sample box. Monitor headspace for two 

complete cycles on the MINICAMS. 

 a. If MINICAMS result is below a 0.2 AEL reading, go to step 13. 

 b. If MINICAMS result is above the alarm set point or the result is above 0.2 AEL 

reading, go to step 5. 

5. Don Mask and Gloves. 

6. Open sample box and replace lids on sample containers and close bags. 

7. Allow sample box to re-equilibrate for 15 minutes. 
EP 75-1-3 

30 Nov 04 

 F-2 

8. Insert MINICAMS into heated sample box and monitor headspace. Once the MINICAMS 

result is below the alarm set point go to step 9. 

9. Don mask and gloves, open lid of sample box. Samples will be monitored one at a time. 

10. Open bag and remove lid from a single sample container. Insert temperature probe into 

soil sample. Close sample box lid and allow sample to equilibrate at 90 degrees (plus or 

minus 10 degrees) Fahrenheit for 15 minutes. 

11. Insert MINICAMS probe into the heated sample box. Monitor the headspace for two 

complete cycles on the MINICAMS. 

 a. If MINICAMS result is below the alarm set point, replace lid and close bag, go to step 

9 for next sample container. 

 b. If MINICAMS result is above the alarm set point for agent or the result is above 0.2 

AEL, sample must be confirmed with DAAMS tubes. Go to step 12. 

12. Allow samples to re-equilibrate at 90 degrees (plus or minus 10 degrees) Fahrenheit for 15 

minutes. Collect DAAMS tubes at 400 milliliters per minute for 60 minutes. Transport 

DAAMS tubes to the MAP for analysis by Dynatherm/GC/MS. 

 a. If agent is detected from the DAAMS tubes analysis, the U.S. Army Engineering and 

Support Center, Huntsville (USAESCH) On-Site Safety Specialist must be 

immediately notified. 

 b. If DAAMS analysis results in a non-detect for agent the go to step 13. 

13. Give clear samples to the contractor for proper disposition. 

Soil Headspace Data Notification. The USAESCH On-Site Safety Specialist will be notified 

of all confirmed detection’s. This includes concentration levels below the AEL value. 

Soil Resample Procedure: In the event that soil has been decontaminated, the soil can not be 

re-sampled using the headspace analysis procedure. Therefore, the ECBC shall request a 

sample of the decontaminated soil for extraction and subsequent analysis for H, HN1, HN3 

and L by GC/MS to confirm complete decontamination. 

Soil Headspace Sampling Records. Copies of all soil headspace air sampling results will be 

maintained. 
EP 75-1-3 

30 Nov 04 

 F-3 

SCRAP/PPE/BULK ITEM: A sample of scrap, PPE, or a bulk item must be contained in an 

environment heated to a minimum of 70 degrees (plus or minus 10 degrees) Fahrenheit for 

four hours prior to monitoring with the MINICAMS/DAAMS. The item may be monitored at 

temperatures of at least 50 degrees Fahrenheit if the item is under full sunlight for four hours. 

However, the use of a heated box may be used to raise the temperature of the items in the case 

of inclement weather. Once the item has been contained for four hours and meets the 

referenced temperatures, monitoring may. Any items suspected of CWM contamination must 

follow the procedures using the DAAMS tubes rather than screening with MINICAMS. 

1. Contractor delivers scrap/PPE/bulk sample to monitoring personnel with proper CoC 

documentation. 

2. Utilize heated sample box, if necessary, to achieve temperature requirements stated above. 

3. Don protective gloves and safety glasses. Don protective mask when sample is collected 

by personnel wearing EPA/OSHA Level C PPE or above. 

4. Insert MINICAMS probe directly into single sample bag or container. Monitor headspace 

for two complete cycles on the MINICAMS. 

 a. If MINICAMS result is below a 0.2 AEL reading, go to step 6. 

 b. If MINICAMS result is above the alarm set point or the result is above 0.2 AEL 

reading, go to step 5. 

5. Allow samples to re-equilibrate at 70 degrees (plus or minus10) degrees Fahrenheit for 

four hours. Collect DAAMS tubes at 400 milliliters per minute for 60 minutes. Transport 

DAAMS tubes to for analysis by Dynatherm/GC/MS. 

 a. If agent is detected from the DAAMS tubes analysis, the USAESCH On-Site Safety 

Specialist must be immediately notified. 

 b. If DAAMS analysis results in a non-detect for agent the go to step 6. 

6. Give clear samples to the contractor for proper disposition. 

Headspace Data Notification: The USAESCH On-Site Safety Specialist will be notified of all 

confirmed detection’s. This includes concentration levels below the AEL value. 

Headspace Sampling Records: Copies of all headspace air sampling results will be 

maintained. 
EP 75-1-3 

30 Nov 04 

 G-1 

APPENDIX G 

Physical Security Plan Outline 

Physical Security Plan 

DEPARTMENT OF THE ARMY 

U.S. ARMY CORPS OF ENGINEERS, (District) 

(District Address) 

PHYSICAL SECURITY PLAN (U) 

(Project) 

(Date) 

1. Mission. The mission of the (project name) is to investigate (what are we doing at the 

project) and remove any recovered chemical warfare material (RCWM) and contaminated 

media. 

2. Purpose. This plan defines the areas of security interest related to (project location) and 

specifies the equipment, forces, and devices utilized to protect RCWM and provide an 

effective security posture. 

3. Objective. 

a. Prevent unauthorized access to RCWM. 

b. Prevent damage from sabotage, espionage, or unauthorized use of RCWM. 

c. Prevent theft or diversion of RCWM or government equipment and supplies. 

4. Threat Analysis. Contact with the (insert local/regional physical security office) 

indicates (no terrorist threat, extreme terrorist threat, whatever the situation is) at this time. 

The most likely threat comes from (trespassers and other unauthorized attempts or other 

appropriate terminology) to access the property. 
EP 75-1-3 

30 Nov 04 

 G-2 

5. Vulnerabilities. The following security areas are considered the most vulnerable 

because of their locations and uses: (Use EP 75-1-3, Chapter 11 for Vulnerability Assessment 

guidance.) 

a. The site (project name) consists of (enter size) and is (fenced or not fenced). This 

site is where the intrusive investigation will take place. (Depending upon the location of the 

site, fencing of the entire project may not be possible.) 

b. The location at (enter name) is the Interim Holding Facility (IHF) where all RCWM 

will be stored. (The entire area will be surrounded with a fence meeting the minimum 

requirements) 

c. (FE-5) as specified in Chapter 5, AR 190-11.) (Possible statements for this section.) 

6. Priorities. The priority of physical security is: 

a. First to RCWM at the site, then during transportation to the IHF. 

b. Second to the security of equipment and supplies at the (project location) site due to 

the sensitive nature of the work and the property. 

c. Third to the security of the equipment and supplies at the (administrative) location. 

7. Limited and Exclusion Areas. Access to the (project location) will be controlled by 

(name of security force) security force. Only those personnel on approved access rosters will 

be allowed on the site without an escort. The IHF will also be a limited access area. Only 

personnel from CEHNC, Technical Escort Unit (TEU), and the Edgewood Chemical and 

Biological Center (ECBC) will be allowed access to the inside of the IHF area once RCWM 

has been placed in the facility. 

8. Equipment and Devices to Detect or Delay Intrusion. 

a. (Project name) 

(1) Perimeter boundary: List what, if any equipment or devices are located at the 

project, for example: “An FE-5 type fence surrounds the entire site with privacy fencing on 3 

of the sides. A video camera is focused on the personnel gate facing the home at the site. This 

camera is monitored during daylight hours.” 
EP 75-1-3 

30 Nov 04 

 G-3 

(2) Clear zones: (Does one exist for the project? May not be necessary for the entire 

project.) 

(3) Gates: All gates will be locked during the non-operational hours and monitored 

during operational periods when it is unlocked. The (Security Force) will monitor the vehicle 

and personnel gate during all hours. 

(4) Signs: Metallic Restricted Area signs are used on the fence, one per side (if the 

project is fenced). 

(5) Inspections and maintenance: The security force checks the fences at the site every 

(two hours during both operational and non-operational hours—this cyclic rate will be 

determined based on the threat analysis and if there is RCWM within the IHF). Maintenance 

of the site is provided by (contractor’s name) through contract with the Huntsville 

Engineering and Support Center. 

(6) When RCWM is secured within the IHF, a 24-hour security guard will be positioned 

at the IHF. 

b. (Secondary location within the project, if applicable.) 

(1) Perimeter boundary: An FE-5 type fence surrounds the IHF. 

(2) Clear zones: A 12-foot clear zone exists around the IHF (if practicable). 

(3) Gates: The gate to the IHF is locked at all times except during transportation of 

RCWM and when authorized operations are ongoing. 

(4) Signs: Metallic Restricted Area signs are used on all four sides of the IHF fence. 

(5) Inspections and maintenance: The security force checks the fences at the site every 

two hours during both operational and non-operational hours. 

9. Security Lighting. 

a. (IHF Location). 

(1) Types – Lighting is provided around the IHF. 
EP 75-1-3 

30 Nov 04 

 G-4 

(2) Types of light source – Per FM 3-19.30, Chapter 5. 

(3) Use control and standards: Lighting will remain on at all times when RCWM is 

placed in the IHF. The control switch for the lighting will be locked to prevent unauthorized 

access. 

(4) Inspections and maintenance: The security force checks the security lighting at the 

site every two hours during non-operational hours. Maintenance of the site is provided by 

(USACE District or specified agency). 

(5) Emergency actions for power failure: If power failure occurs, Security Forces may 

be enlarged until the situation is corrected. Generator power will be coordinated by (USACE 

District or specified agency) in the event the power failure is prolonged. 

10. Communication Systems. The security force is equipped with both cellular telephones 

and radios. This provides immediate access to on-call project personnel and to emergency 

response forces from the (Security Force). 

11. Locks and Keys. Locks and keys for the IHF gate are controlled by the USACE, and the 

IHF doors are controlled by TEU, once RCWM is stored within the IHF. Locks and Keys for 

collateral areas and equipment will be maintained by (specify who). (Use Appendix A of the 

Physical Security Plan for Key and Lock Control Log.) 

12. Measures to Control Personnel, Vehicles, and Material. 

a. Personnel Access Controls: Only authorized personnel will be permitted entry into 

the site or the IHF. Control procedures will assure positive identification of all personnel 

prior to entry. Visitors and maintenance personnel will be escorted at all times. 

b. Escort Requirements: Escorts will keep the visitor under constant observation at all 

times. 

c. Non-operational hours access procedures: The On-site Operations Officer or his 

designated representative must approve non-duty hour access. All pertinent facts concerning 

the access will be recorded and reviewed the by the operations officer. 

13. Personnel Identification System. Security personnel will check photo identification 

against the Access Roster prior to admittance to both the site and to the IHF. 
EP 75-1-3 

30 Nov 04 

 G-5 

14. Vehicle Control. Only authorized vehicles are allowed at the site. Only authorized 

transportation vehicles are allowed in the IHF. 

15. Material Control. The TEU will manifest all material being transported from the site to 

the IHF. RCWM will be transported by TEU with an escort. 

16. Security Forces. 

a. Type and composition: (Security Force) provides (one or however many is 

determined to be necessary) security person(s) at the (Project) and then an additional security 

person(s) when RCWM is placed in the IHF. 

b. Authority and Jurisdiction: (Name of) District has contracted with the local 

authorities to provide security at both the project and the IHF. 

c. Weapons, Ammunition, and Equipment: Security personnel are armed and equipped 

IAW standard local procedures. 

d. Rules of engagement and use of deadly force: These are commensurate with the 

rules employed by the local security forces. 

e. Training: This is the responsibility of the (Security Force). Site specific instructions 

have been provided by the on-site Operations Officer and are included in Appendix B. (Use 

Appendix B of the Physical Security Plan to provide Security Force Instructions.) 

f. Actions to be taken under adverse weather and limited visibility conditions: Patrols 

will be maintained during these conditions to ensure security integrity. 

g. Posts: (Explain post locations.) 

h. Working dogs: (May or may not be applicable.) 

i. Response force: The (Security Officer) on duty will call for the appropriate response 

force from the (depends on his assessment of the situation). Response times will be (identify 

the requirements). 

17. Emergency Actions of General Nature. Actions pertaining to emergency situations will 

be IAW the (Project) Chemical Safety Submission (CSS). 
EP 75-1-3 

30 Nov 04 

 G-6 

18. Recovered Chemical Warfare Material Movement. Procedures for movement of 

recovered chemical warfare material are as outlined in the CSS. 

19. Coordination. This plan has been coordinated with all members of the (Project) team to 

include local security, TEU, ECBC, PM Non-stockpile, U.S. Army Engineering and Support 

Center, Huntsville, and (name of Contractor(s) on-site). 

20. Appendices. 

A. Key and Lock Control Log 

B. Instructions for the Security Force 

 (Contractor Project Manager's Signature Block) 

DISTRIBUTION: 

Name of Security Force 

(Applicable) District, Corps of Engineers, Attention: Project Manager and Security Office 

U.S. Army Engineering & Support Center, Huntsville (OE Design Center Point of Contact) 

Contractor(s) working the site 

Customer's designated representative 

CDR, TEU, Attention: (Name) 

CDR, ECBC, Attention: (Name) 

PM Non-stockpile, Attention: (Name) 
EP 75-1-3 

30 Nov 04 

 G-7 

ATTACHMENT 1 

Key and Lock Control Log 

Project Name: Location: 

Lock Number Where Located Number of Keys Key Numbers 

 

Date Key Number Time Out Time In Print Name and Signature 

 

Example (Variations may be used.) 
EP 75-1-3 

30 Nov 04 

 G-8 

ATTACHMENT 2 

Instructions for the Security Force 

(Name of Site) 

a. Security officers at the excavation-site will visually check the site at least once every 

two hours. 

b. Officers will make radio communication on a periodic basis between posts. 

c. When items are stored at the IHF, officers at the (IHF Location) will station 

themselves in the vicinity of the IHF to allow maximum observation of the area. Officers will 

walk around the IHF area at least once every two hours. 

d. In the event an intruder is detected at either site, the officers will take appropriate 

action to stop the intruder and maintain the security of the site. If necessary, the officer will 

call for appropriate additional support from the (backup security force name). Response times 

would be IAW standard police protocols. 

e. If anything unusual is detected, the officer should contact (name of person the 

security force should contact) during daytime operations at (phone number). After hours the 

officer should contact (who) at pager number ( ) or cell phone number ( ). 

f. Questions concerning these instructions should be directed to (name of designated 

individual). 

g. Enter any additional instructions to the security force. 
EP 75-1-3 

30 Nov 04 

Appendix H 

Delegation of Authority 

H-1 
EP 75-1-3 

30 Nov 04 

H-2 
EP 75-1-3 

30 Nov 04 

 Glossary-1 

GLOSSARY 

Section I 

Acronyms 

ACGIH ......................American Conference of Governmental Industrial Hygienists 

AEL ...........................Airborne Exposure Limit 

AIHA .........................American Industrial Hygiene Association 

AMC..........................Army Materiel Command 

AOC...........................Army Operations Center 

ABP ...........................Agent Breakdown Products 

AR..............................Army Regulation 

ARAR........................Applicable, Relevant and Appropriate Requirement 

ARB...........................Anomaly Review Board 

ASA (I&E).................Assistant Secretary of the Army (Installation and Environment) 

ASR ...........................Archives Search Report 

ASSHP.......................Abbreviated Site Safety and Health Plan 

BRAC ........................Base Realignment and Closure 

BWM .........................Biological Warfare Material 

CACM .......................Chemical Agent Contaminated Media 

CAIRA.......................Chemical Accident or Incident Response or Assistance 

CAIS..........................Chemical Agent Identification Sets 

CBD...........................Commerce Business Daily 

CERCLA Comprehensive Environmental Response, Compensation, and Liability 

 Act 

CFR............................Code of Federal Regulations 

CG..............................Phosgene 

CHP ...........................Certified Health Physicist 

CIH ............................Certified Industrial Hygienist 

CK..............................Cyanogen Chloride 

CO..............................Contracting Officer 

CoC............................Chain-of-Custody 

COPC.........................Contaminants of Potential Concern 

COR...........................Contracting Officer’s Representative 

CPR............................Cardiopulmonary Resuscitation 

CPU ...........................Chemical Protective Undergarment 

CRP............................Community Relations Plan 
EP 75-1-3 

30 Nov 04 

 Glossary-2 

CSP............................Certified Safety Professional or Conceptual Site Plan 

CSS............................Chemical Safety Submission 

CSSIS ........................Chemical Safety Submission Information Sheet 

CWA..........................Chemical Warfare Agent 

CWM .........................Chemical Warfare Materiel 

CX..............................Mandatory Center of Expertise 

D2PC .........................Downwind Hazard Prediction Model 

DA .............................Department of the Army 

DA Pam .....................Department of the Army Pamphlet 

DAAMS.....................Depot Area Air Monitoring System 

DACASC...................Department of Army Chemical Agent Safety Council 

DACS-SF...................Department of the Army, Office of the Chief of Staff 

DASAF......................Director of Army Safety 

DDESB......................Department of Defense Explosives Safety Board 

DERP.........................Defense Environmental Restoration Program 

DHHS ........................Department of Health and Human Services 

DID............................Data Item Description 

DOD ..........................Department of Defense 

DOT...........................Department of Transportation 

ECBC.........................Edgewood Chemical and Biological Center 

ECS............................Engineering Control Structure 

EE/CA........................Engineering Evaluation/Cost Analysis 

EM .............................Engineer Manual 

EOD...........................Explosive Ordnance Disposal 

EP ..............................Engineer Pamphlet 

EPA............................Environmental Protection Agency 

ER..............................Engineer Regulation 

ESS ............................Explosives Safety Submission 

EZ ..............................Exclusion Zone 

FAR ...........................Federal Acquisition Regulation 

FBI.............................Federal Bureau of Investigation 

FPD............................Flame Photometric Detector 

FUDS.........................Formerly Used Defense Site 

GB..............................Sarin (Isopropyl methylphosphonofluoridate) 

GC..............................Gas Chromatography 

GFP............................Government Furnished Property 

GIS.............................Geographic Information System 

GPL............................General Population Limit 
EP 75-1-3 

30 Nov 04 

 Glossary-3 

H ................................Levinstein Mustard (bis[2-chloroethyl] sulfide) 

HN-1..........................Nitrogen Mustard (2.2' dichloro-triethylamine) 

HN-3..........................Nitrogen Mustard (2.2'.2-trichloro-triethylamine) 

HAZWOPER.............Hazardous Waste Operations and Emergency Response 

HQDA........................Headquarters, Department of the Army 

HQUSACE ................Headquarters, United States Army Corps of Engineers 

HTRW .......................Hazardous, Toxic, and Radioactive Waste 

HTW..........................Hazardous and Toxic Waste 

IAW ...........................IAW 

IDLH..........................Immediately Dangerous to Life or Health 

IDW ...........................Investigation Derived Waste 

IGE ............................Independent Government Estimate 

IHF.............................Interim Holding Facility 

INPR..........................Inventory Project Report 

IRP.............................Installation Restoration Program 

L.................................Lewisite 

LDR ...........................Land Disposal Restriction 

LPM...........................Liters Per Minute 

LUC ...........................Land Use Control 

MACOM....................Major Command 

MAP ..........................Mobile Analytical Platform 

MARB .......................Materiel Assessment Review Board 

MCE ..........................Maximum Credible Event 

MCX..........................Mandatory Center of Expertise 

MEC ..........................Munitions and Explosives of Concern 

MINICAMS...............Miniature Chemical Agent Monitoring System 

MM CX .....................Military Munitions Response Mandatory Center of Expertise 

MMR MCX ...............Military Munitions Response Mandatory Center of Expertise 

MOA..........................Memorandum of Agreement 

MRC ..........................Multiple Round Container 

MSC...........................Major Subordinate Command 

MSD ..........................Minimal Separation Distance 

MSDS ........................Material Safety Data Sheet 

NCP ...........................National Oil and Hazardous Substance Pollution Contingency Plan 

NDAI .........................No DOD Action Indicated 

NEPA.........................National Environmental Policy Act 

NEW..........................Net Explosive Weight 

NIOSH.......................National Institute for Occupational Safety and Health 
EP 75-1-3 

30 Nov 04 

 Glossary-4 

NOSE.........................No Significant Effects 

NTCRA......................Non-Time Critical Removal Action 

NVLAP......................National Voluntary Laboratory Accreditation Program 

OC..............................Office of Counsel 

OSG ...........................Office of the Surgeon General 

OSHA ........................Occupational Safety and Health Administration 

PA..............................Preliminary Assessment 

PAED.........................Public Access Exclusion Distance 

PAO ...........................Public Affairs Office (or Officer) 

PAT............................Proficiency Analytical Test 

PCB............................Poly-Chlorinated Biphenyl 

PDS............................Personnel Decontamination Station 

PDT............................Project Delivery Team 

PINS ..........................Portable Isotopic Neutron Spectroscopy 

PL ..............................Public Law 

PM .............................Project Manager 

PMNSCM ..................Product Manager for Non-Stockpile Chemical Materiel 

PMECW ....................Program Manager for the Elimination of Chemical Weapons 

POC ...........................Point of Contact 

PPE ............................Personal Protective Equipment 

Pre-Op........................Pre-Operational Survey 

PS...............................Chloropicrin 

PSP ............................Physical Security Plan 

Q-D............................Quantity Distance 

QA .............................Quality Assurance 

QC..............................Quality Control 

OP-FTIR ...................Open-Path Fourier Transform Infrared Spectrometry Air Monitoring 

RAB...........................Restoration Advisory Board 

RCRA ........................Resource Conservation and Recovery Act 

RCWM ......................Recovered Chemical Warfare Materiel 

RDECOM ..................Research, Development, and Engineering Command 

RFP............................Request for Proposal 

RI/FS..........................Remedial Investigation/Feasibility Study 

ROE ...........................Right-of-Entry 

RSO ...........................Radiation Safety Officer 

SARA ........................Superfund Amendments and Reauthorization Act of 1986 

SI................................Site Inspection 

SOP............................Standard Operating Procedure 
EP 75-1-3 

30 Nov 04 

 Glossary-5 

SOW ..........................Statement of Work 

SSHP..........................Site Safety and Health Plan 

STEL..........................Short-term Exposure Limit 

SUXOS......................Senior UXO Supervisor 

SVOC ........................Semi-Volatile Organic Compound 

TCL............................Target Compound List 

TCLP .........................Toxicity Characteristic Leaching Procedure 

TCRA ........................Time-Critical Removal Action 

TEU ...........................Technical Escort Unit 

TM .............................Technical Manual 

TSDF .........................Treatment, Storage, and Disposal Facility 

TWA ..........................Time Weighted Average 

U.S. ............................United States 

USACE......................United States Army Corps of Engineers 

USACHPPM..............U.S. Army Center for Health Promotion and Preventive Medicine 

USAESCH.................U.S. Army Engineering and Support Center, Huntsville 

USATCES .................U.S. Army Technical Center for Explosives Safety 

USC ...........................United States Code 

UXO ..........................Unexploded Ordnance 

UXOSO .....................UXO Safety Officer 

VCS ...........................Vapor Containment Structure 

VOC...........................Volatile Organic Compounds 

VX .............................V Agent (O-ethyl ester) 

WPL...........................Worker Population Limit 

XSD ...........................Halogen Specific Detector 
EP 75-1-3 

30 Nov 04 

 Glossary-6 

Section II 

Terms 

1 Percent Lethality Distance 

Distance that is calculated from a given MCE and meteorological conditions (temperature, 

wind speed, and so forth) and is established as the distance at which dosage from an MCE or 

actual agent release would be 150 mg-min/m3

 for H and HD agents, 75 mg-min/m3 for HT 

agent, 150 mg-min/m3

 Lewisite, 10 mg-min/m3 for GB agent, 4.3 mg-min/m3 for VX vapor, 

and 0.1 mg for inhalation/deposition of liquid VX. The meteorological conditions used will 

be the existing conditions in the event of an actual release or the realistic, worst-case 

conditions used will be the existing conditions for siting purposes. 

3X 

This is an indication of the level of decontamination to which an item has been subjected. 

XXX indicates the item has been surface decontaminated by locally approved procedures, has 

been bagged or contained in an agent-tight barrier (plastic bags may be used if they have been 

tested and found to be effective for the purpose) of sufficient volume to permit sample air to 

be withdrawn while minimizing dilution with incoming air, and/or appropriate 

tests/monitoring have verified that concentrations above 0.0001 mg/m3

 for agents GA/GB, 

0.00001 mg/m3

 for agent VX, 0.003 mg/m3 for H or L, or 0.00003 mg/m3 for agent GD 

(unmasked worker AEL values for other covered chemicals do not exist. 

Action Memorandum 

Approves time-critical removal action and also concludes the engineering evaluation/cost 

analysis. Provides a concise, written record of the decision to select an appropriate removal 

action. As the primary decision document, it substantiates the need for a removal action, 

identifies the proposed action, and explains the rationale for the removal action selected. 

Active Installations 

Installations under the custody and control of DOD. Includes operating installations, 

installations in a standby or layaway status, and installations awaiting closure under the Base 

Realignment and Closure (BRAC) legislation. Examples include but are not limited to posts, 

camps (including National Guard camps), forts, depots, activities, ports, ammunition supply 

points, basic load ammunition storage areas, and ammunition plants. 

Active Range 

A military range that is currently in service and is being regularly used for range activities. 

(40 CFR 266.201) 
EP 75-1-3 

30 Nov 04 

 Glossary-7 

Administrative Record 

The body of documents that “forms the basis” for the selection of a particular response at a 

site. Documents that are included are relevant documents that were relied upon in selecting 

the response action as well as relevant documents that were considered but were ultimately 

rejected. (ER 1110-1-8153) 

Anomaly 

Any item that is seen as a subsurface irregularity after geophysical investigation. This 

irregularity should deviate from the expected subsurface ferrous and non-ferrous material at a 

site (i.e., pipes, power lines, etc.). (EP 1110-1-18) 

Anomaly Avoidance 

Techniques employed by EOD or UXO personnel at sites with known or suspected MEC to 

avoid any potential surface MEC and any subsurface anomalies. This usually occurs at mixed 

hazard sites when HTRW investigations must occur prior to execution of munitions response. 

Intrusive anomaly investigation is not authorized during ordnance avoidance operations. 

(EP 75-1-2) 

Anomaly Review Board (ARB) 

A technical group established to provide technical guidance and quality assurance oversight 

of the review and resolution of geophysical information related to unresolved anomalies at a 

site. (EP 1110-1-18) 

Applicable or Relevant, and Appropriate Requirements (ARARs) 

Applicable requirements are cleanup standards, standards of control, and other substantive 

environmental protection requirements promulgated under federal or state environmental law 

that specifically address a hazardous substance, pollutant, contaminant, remedial action, 

location or other circumstance found at a CERCLA site. Relevant and appropriate 

requirements are cleanup standards that while not “applicable”, address situations sufficiently 

similar to those encountered at a CERCLA site that their use is well suited to the particular 

site. 

Approval Memorandum 

Secures management approval and funding to conduct the engineering evaluation/cost 

analysis. 
EP 75-1-3 

30 Nov 04 

 Glossary-8 

Archives Search Report (ASR) 

A detailed investigation to report on past munitions-related activities conducted at an 

installation. The principal purpose of the Archives Search is to assemble historical records 

and available field data, assess potential ordnance presence, and recommend follow-up 

actions at a DERP-FUDS. There are four general steps in an Archives Search: records search 

phase, site safety and health plan, site survey, archives search report including risk 

assessment. 

Base Realignment and Closure (BRAC) 

Program governing the scheduled closing of Department of Defense sites. (Base Closure and 

Realignment Act of 1988, Public Law 100-526, 102 Stat. 2623, and the Defense Base Closure 

and Realignment Act of 1990, Public Law 101-510, 104 Stat. 1808) 

Chemical Agent 

A chemical substance that is intended for use in military operations to kill, seriously injure, or 

incapacitate a person through its physiological effects. Excluded are research, development, 

test, and evaluation (RDTE) solutions, industrial chemicals, riot control agents, chemical 

defoliants and herbicides, smoke flame, and incendiaries. (ER 385-1-95) 

Chemical Agent Contaminated Media (CACM) 

Any mixture of detectable concentrations of chemical agent(s) with soil, water, debris, or 

other solid or liquid media. 

Chemical Warfare Materiel (CWM) 

An item configured as a munition containing a chemical substance that is intended to kill, 

seriously injure, or incapacitate a person through its physiological effects. Also includes Vand G- series nerve agent, H- series blister agent, and lewisite in other- than-munition 

configurations. Due to their hazards, prevalence, and military-unique application, chemical 

agent identification sets (CAIS) are also considered CWM. CWM does not include: riot 

control agents, chemical herbicides; smoke and flame producing items; or soil, water, debris, 

or other media contaminated with chemical agent. (HQDA Interim Guidance for Biological 

Warfare Materiel and Non-Stockpile Chemical Warfare Materiel Response Activities) 

Chemical Weapons Design Center (CW-DC) 

A design center is the specified USACE field office assigned a singular technical mission that 

is permanent and USACE-wide in scope. This designated office is to be considered the “lead 

activity” in a specialized area where capability needs to be concentrated for maximum 

effectiveness, economy, and efficiency. The CW-DC is the USACE Design Center 
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authorized to execute RCWM response actions. The CW-DC is located within USAESCH. 

(ER 1110-1-8153) 

Collective Protection 

Protective equipment or methods used to insulate a group of people from the chemical, 

thermal, explosive or other hazards presented by the environment in which they are working. 

For example, such items as tents and engineering control structures. 

Community Relations Plan (CRP) 

The Community Relations Plan (CRP) or Public Involvement Plan for FUDS projects serves 

as the framework to establish a successful information exchange with the public for munitions 

response actions. The CRP follows guidelines set forth under CERCLA and the SARA. Each 

CRP must be tailored to fit the individual site and situation and should also accommodate any 

site-specific agreements between the U.S. Army and the EPA or state environmental agencies. 

The CRP is not a static document and should be revised to reflect the project’s 

development/progress. 

Comprehensive Environmental Response, Compensation, and Liability Act of 1980 

(CERCLA) 

Also known as “Superfund”, this congressionally enacted legislation provides the 

methodology for the removal of former operations. Response actions must be performed 

IAW the National Oil and Hazardous Substances Pollution Contingency Plan. 

Construction Support 

Support provided by qualified UXO personnel during construction activities at potential MEC 

sites to ensure the safety of construction personnel from the harmful effects of UXO. When a 

determination is made that the probability of encountering UXO is low, a two-person UXO 

team stands by in case the construction contractor encounters a suspected UXO. When a 

determination is made that the probability of encountering a UXO is moderate to high, UXO 

teams are required to conduct subsurface UXO clearance for the known construction footprint 

in conjunction with the construction contractor during intrusive activities. The level of effort 

for construction support will be determined on a case-by-case basis in coordination with MM 

CX. (ER 1110-1-8153) 

Conventional Munitions and Explosives of Concern (MEC) 

The term “conventional MEC” refers to munitions and explosives of concern (see definition) 

other than CWM, BWM and nuclear ordnance. (EP 75-1-2) 
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Defense Environmental Restoration Program (DERP) 

Established in 1984, DERP promotes and coordinates efforts for the evaluation and cleanup of 

contamination at Department of Defense installations. (10 U.S.C. 2701) 

Discarded Military Munitions (DMM) 

Military munitions that have been abandoned without proper disposal or removed from 

storage in a military magazine or other storage area for the purpose of disposal. The term 

does not include unexploded ordnance, military munitions that are being held for future use or 

planned disposal, or military munitions that have been properly disposed of consistent with 

applicable environmental laws and regulations. (10 U.S.C. 2710(e)(2)) 

Districts Approved to Execute Munitions Response Actions 

These districts are selected and approved by the MSC Commander with concurrence from the 

MM CX, trained, and assigned the mission of conducting munitions response actions. The 

districts are responsible for final response action execution. Only USAESCH is authorized to 

execute any phase of a RCWM response action. (ER 1110-1-8153) 

Easement 

An easement allows the holder to use the land of another or to restrict the uses of the land. An 

easement “appurtenant” provides a specific benefit to a particular piece of land. For example, 

allowing a neighbor to walk across your land to get to the beach. The neighbor’s land, the 

holder of the easement, benefits by having beach access through your land. An easement “in 

gross” benefits an individual or company. For example, allowing the utility company to come 

on your land to lay a gas line. The utility company, the holder of the easement, benefits by 

having use of the land to lay the gas line. An affirmative easement allows the holder to use 

another person’s land in a way that, without the easement, would be unlawful - for example, 

allowing a use that would otherwise be a trespass. A negative easement prohibits a lawful use 

of land - for example, creating a restriction on the type and amount of development of land. 

Engineering Evaluation/Cost Analysis (EE/CA) 

An EE/CA is prepared for all non-time-critical removal actions as required by Section 

300.415(b)(4)(i) of the NCP. The goals of the EE/CA are to identify the extent of a hazard, to 

identify the objectives of the removal action, and to analyze the various alternatives that may 

be used to satisfy these objectives for cost, effectiveness, and implementability. 

Exclusion Zone (EZ) 

A safety zone established around a MEC work area. Only project personnel and authorized, 

escorted visitors are allowed within the EZ. Examples of EZs are safety zones around MEC 
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intrusive activities and safety zones where MEC is intentionally detonated. The EZ is the area 

where potential contamination may exist. (DDESB-KO, 27 January 1990) 

Explosive Ordnance Disposal (EOD) 

The detection, identification, field evaluation, rendering safe, recovery, and final disposal of 

unexploded ordnance or munitions. 

Explosives or Munitions Emergency Response 

An immediate response by explosives and munitions emergency response personnel to 

control, mitigate, or eliminate the actual or potential threat encountered during an explosives 

or munitions emergency. An explosives or munitions emergency response may include inplace render-safe procedures, treatment or destruction of the explosives or munitions or their 

transport to another location to be rendered safe, treated, or destroyed. Reasonable delay in 

the completion of an explosives or munitions emergency response caused by a necessary, 

unforeseen or uncontrollable circumstance does not terminate the explosives or munitions 

emergency. Explosives and munitions emergency responses can occur on either public or 

private lands and are not limited to responses at RCRA facilities. (40 CFR §260.10) 

Explosives Safety Submission (ESS) 

The document that serves as the specifications for conducting work activities at the project. 

The ESS details the scope of the project, the planned work activities, and potential hazards 

(including the maximum credible event) and the methods for their control. (EP 1110-1-18) 

Explosive Soil 

Explosive soil refers to mixtures of explosives in soil, sand, clay, or other solid media at 

concentrations such that the mixture itself is explosive. 

(a) The concentration of a particular explosive in soil necessary to present an explosion 

hazard depends on whether the particular explosive is classified as “primary” or “secondary.” 

Guidance on whether an explosive is classified as “primary” or “secondary” can be obtained 

from the MM CX or Chapters 7 and 8 of TM 9-1300-214, Military Explosives. 

(b) Primary explosives are those extremely sensitive explosives (or mixtures thereof) that are 

used in primers, detonators, and blasting caps. They are easily detonated by heat, sparks, 

impact, or friction. Examples of primary explosives include Lead Azide, Lead Styphnate, and 

Mercury Fulminate. 

(c) Secondary explosives are bursting and booster explosives (i.e., they are used as the main 

bursting charge or as the booster that sets off the main bursting charge). Secondary 
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explosives are much less sensitive than primary explosives. They are less likely to detonate if 

struck or when exposed to friction or to electrical sparks. Examples of secondary explosives 

include Trinitrotoluene (TNT), Composition B, and Ammonium Picrate (Explosive D). 

(d) Soil containing 10 percent or more by weight of any secondary explosive or mixture of 

secondary explosives is considered “explosive soil.” This determination was based on 

information provided by the USAEC as a result of studies conducted and reported in USAEC 

Report AMXTH-TE-CR 86096. 

(e) Soil containing propellants (as opposed to primary or secondary high explosives) may also 

present explosion hazards. 

Formerly Used Defense Sites (FUDS) 

FUDS includes those properties previously owned, leased, or otherwise possessed by the U.S. 

and under the jurisdiction of the Secretary of Defense; or manufacturing facilities for which 

real property accountability rested with DOD but were operated by contractors (Government 

owned - contractor operated) and which were later legally disposed of. FUDS is a subprogram 

of the DERP. Restoration of military land was extended to formerly used sites in 1983 under 

Public Law 98-212 (DOD Appropriations Act of FY84). 

General Population Limit (GPL) 

The GPL is an occupational chemical exposure limit for the general population. It is 

expressed as a time-weighted average that should not be exceeded during any twenty-four 

hour period. 

Geophysical Techniques 

Techniques utilized for the detection and measurement of buried anomalies (e.g., 

ferromagnetic indicators and ground penetrating radar) to investigate the presence of 

munitions. (ER 385-1-95) 

Hazardous, Toxic, and Radioactive Waste (HTRW) Activities 

HTRW activities include those activities undertaken for the Environmental Protection 

Agency’s Superfund program, the Defense Environmental Restoration Program (DERP), 

including Formerly Used Defense Sites (FUDS), and Installation Restoration Program (IRP) 

sites at active DOD facilities, HTRW actions associated with Civil Works activities, and any 

other mission or non-mission work performed for others at HTRW sites. (ER 385-1-92) 
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Immediately Dangerous to Life and Health (IDLH) 

The IDLH concentration is a limit for personal exposure to a substance defined by the 

National Institute of Occupational Safety and Health (NIOSH) that is normally expressed in 

parts per million (ppm). Th IDLH concentration is considered to be the limit beyond which 

an individual will not be capable of escaping death or permanent injury without help in less 

than thirty minutes. 

Information Repository 

A repository, generally located at libraries or other publicly accessible locations, which 

contains documents reflecting the on-going environmental restoration activities. This may 

include the EE/CA, CRP, RAB meeting minutes, public notices, public comments and 

responses to those comments, etc. 

Intrusive activity 

An activity that involves or results in the penetration of the ground surface at an area known 

or suspected to contain MEC. Intrusive activities can be of an investigative or removal action 

nature. (ER 385-1-95) 

Inventory Project Report (INPR) 

The report resulting from the preliminary assessment. The INPR includes data as well as a 

recommendation for further action and guides investigators through further site studies. 

Documents whether DOD is responsible for contamination at a FUDS. 

Mandatory Center of Expertise (CX) 

A CX is a USACE organization that has been approved by HQUSACE as having a unique or 

exceptional technical capability in a specialized subject area that is critical to other USACE 

commands. Specific mandatory services to be rendered by a CX are identified on the CX’s 

homepage. These services may be reimbursable or centrally funded. The USAESCH is the 

MM CX for the USACE. (ER 1110-1-8153) 

Material Potentially Presenting an Explosive Hazard (MPPEH) 

Material potentially containing explosives or munitions (e.g., munitions containers and 

packaging material; munitions debris remaining after munitions use, demilitarization, or 

disposal; and range-related debris); or material potentially contaminated with a high enough 

concentration of explosives such that the material presents an explosive hazard (e.g., 

equipment, drainage systems, holding tanks, piping, ventilation ducts) associated with 

munitions production, demilitarization or disposal operations. Excluded from MPPEH are 

munitions within DOD’s established munitions management system and other hazardous 
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items that may present explosion hazards (e.g., gasoline cans, compressed gas cylinders) that 

are not munitions and are not intended for use as munitions. 

Maximum Credible Event (MCE) 

The worst single event that could occur at any time, with maximum release of a chemical 

agent from a munition, container, or process as a result of unintended, unplanned, or 

accidental occurrence. (HQDA Interim Guidance for Biological Warfare Materiel (BWM) 

and Non-Stockpile Chemical Warfare Materiel (CWM) Response Activities) 

Military Munitions 

All ammunition products and components produced for or used by the armed forces for 

national defense and security, including ammunition products or components under the 

control of the Department of Defense, the Coast Guard, the Department of Energy, and the 

National Guard. The term includes confined gaseous, liquid, and solid propellants, 

explosives, pyrotechnics, chemical and riot control agents, smokes, and incendiaries, 

including bulk explosives and chemical warfare agents, chemical munitions, rockets, guided 

and ballistic missiles, bombs, warheads, mortar rounds, artillery ammunition, small arms 

ammunition, grenades, mines, torpedoes, depth charges, cluster munitions and dispensers, 

demolition charges, and devices and components thereof. The term does not include wholly 

inert items, improvised explosive devices, and nuclear weapons, nuclear devices, and nuclear 

components, except that the term does include non-nuclear components of nuclear devices 

that are managed under the nuclear weapons program of the Department of Energy after all 

required sanitization operations under the Atomic Energy Act of 1954, (42 U.S.C. 2011 et 

seq.) have been completed. (10 U.S.C. 2710(e)(3)(A)) 

Minimum Separation Distance (MSD) 

The minimum separation distance required for personnel (public and UXO Qualified), as a 

result of an intentional and unintentional detonation of an item of ordnance, that could occur 

during activities involving MEC. The event must be realistic with reasonable probability of 

occurrence. (ER 385-1-95) 

Most Probable Event (MPE) 

The MPE is the most likely event that could occur during munitions response activities as a 

result of an accidental, unplanned, or unintended detonation of an ordnance item. The event 

must be realistic with reasonable probability of occurrence. (ER 385-1-95) 
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Munition with the Greatest Fragmentation Distance (MGFD) 

The munition with the greatest fragmentation distance that might be recovered as a result of 

previous training during actions based on historical information. The selected MGFD must be 

realistic with reasonable probability of occurrence. (DOD 6055.9-STD) 

Munitions and Explosives of Concern (MEC) 

This term, which distinguishes specific categories of military munitions that may pose unique 

explosives safety risks, means: 

(a) Unexploded Ordnance (UXO), as defined in 10 U.S.C. 2710 (e) (9); 

(b) Discarded Military Munitions (DMM), as defined in 10 U.S.C. 2710 (e) (2), or 

(c) Munitions constituents (e.g., TNT, RDX) present in high enough concentrations to pose 

an explosive hazard. 

Munitions Constituents (MC) 

Any materials originating from unexploded ordnance, discarded military munitions, or other 

military munitions, including explosive and non-explosive materials, and emission, 

degradation, or breakdown elements of such ordnance and munitions. (10 U.S.C. 2710(e)(4)) 

Munitions Debris 

Remnants of munitions (e.g., penetrators, projectiles, shell casings, links, fins) remaining after 

munitions use, demilitarization, or disposal. 

Munitions Response 

Response actions, including investigation, removal and remedial actions to address the 

explosives safety, human health, or environmental risks presented by unexploded ordnance 

(UXO), discarded military munitions (DMM), or munitions constituents (MC). 

Munitions Response Area (MRA) 

Any area on a defense site that is known or suspected to contain UXO, DMM, or MC. 

Examples include former ranges and munitions burial areas. A MRA is comprised of one or 

more MRSs. 

Munitions Response Site (MRS) 

A discrete location within a MRA that is known to require a munitions response. 
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National Oil and Hazardous Substance Pollution Contingency Plan (NCP) 

Revised in 1990, the NCP provides the regulatory framework for responses under CERCLA. 

The NCP designates the Department of Defense as the removal response authority for 

ordnance and explosives hazards. 

Non-Stockpile Chemical Warfare Materiel 

CWM (see definition) that is not included in the chemical stockpile. Non-stockpile CWM is 

divided into five categories: buried CWM, recovered CWM (items recovered during range 

clearing operations, from chemical burial sites, and from research and development testing), 

former chemical weapon production facilities, binary chemical weapons, and miscellaneous 

CWM (unfilled munitions and devices and equipment specially designed for use directly in 

connection with employment of chemical weapons). (HQDA Interim Guidance for Biological 

Warfare Materiel [BWM] and Non-stockpile Chemical Warfare Materiel [CWM] Response 

Activities) 

Non-Time-Critical Removal Action (NTCRA) 

NTCRAs are actions initiated in response to a release or threat of a release that poses a risk to 

human health, its welfare, or the environment. Initiation of removal cleanup actions may be 

delayed for six months or more. 

Ordnance and Explosive Safety Specialist 

USACE Personnel, classified as a GS-018 Safety Specialist, and who is UXO-qualified. 

Ordnance and Explosive Safety Specialists perform safety, quality assurance and UXO 

subject matter expert functions for the Government. The Ordnance and Explosive Safety 

Specialist for RCWM response actions is located within the USAESCH Ordnance and 

Explosives Directorate.. (ER 1110-1-8153) 

Personal Protective Equipment (PPE) 

Whatever protective equipment may be used to insulate an individual from the chemical, 

thermal, explosive or other hazards presented by the environment in which he or she is 

working. For example, such items as safety glasses, hard hats, protective shoes, chemicalresistant clothing, and breathing apparatus. 

Preliminary Assessment of Eligibility (PA) 

The PA is the initial phase of the non-time-critical response action process. A PA includes a 

review of existing information and an off-site reconnaissance, if appropriate, to determine if a 

release may require additional investigation or action. A PA may include an on-site 

reconnaissance, if appropriate. The findings of the PA are reported in the INPR, along with 
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 Glossary-17 

recommendations for further action, if appropriate. This document is used to determine 

property and project eligibility under DERP-FUDS. 

Project Delivery Team (PDT) 

The PDT is a multi-disciplined team, led by the Project Manager, with responsibility for 

assuring that project activities stay focused, first and foremost on the public interest, and on 

the customer’s needs and expectations and that all work is integrated and done IAW a PMP 

and approved business and quality management processes. The PDT focuses on the quality of 

project delivery, with heavy reliance on partnering and relationship development to achieve 

better performance. (ER 5-1-11) 

Project Manager (PM) 

Within the TPP process, the PM is the decision maker responsible for leading the team’s TPP 

efforts, progressing towards site closeout, and meeting the customer’s expectations. 

(EM 200-1-2). 

Public Access Exclusion Distance (PAED) 

The greater of the inhabited building distance (IBD) (based on the fragment hazard distance 

or the net explosive weight (NEW) of the munitions) or the one percent lethality distance of 

the MCE. 

Quality Assurance (QA) 

A process that provides oversight to quality control and involves an audit/review of the 

quality control process. (ER 1110-1-12) 

Quality Control (QC) 

A process that monitors and checks the design process to insure that the product will meet 

agreed-upon requirements of the customer, is on schedule and within budget. (ER 1110-1-12) 

Quantity Distance (Q-D) 

The quantity of explosives material and distance separation relationships that provide defined 

types of protection. These relationships are based on levels of risk considered acceptable for 

the stipulated exposures and are tabulated in the appropriate Q-D tables provided in DOD 

6055.9-STD. Separation distances are not absolute safe distances but are relative protective 

safe distances. Greater distances than those shown in the Q-D tables will be used whenever 

possible. (DOD 6055.9-STD) 
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 Glossary-18 

Recovered Chemical Warfare Materiel (RCWM) 

Non-stockpile CWM that was previously discarded, buried, or fired and discovered either 

unexpectedly or during planned environmental restoration operations. (ER 385-1-95) 

Remedial or Remedial Action 

Those actions consistent with permanent remedy taken instead of or in addition to removal 

actions in the event of a release or threatened release of a hazardous substance into the 

environment, to prevent or minimize the release of hazardous substances so that they do not 

migrate to cause substantial danger to present or future public health, welfare or the 

environment. The term includes, but is not limited to, such actions at the location of the 

release as storage; confinement; perimeter protection using dikes, trenches, or ditches; clay 

cover; neutralization; cleanup of released hazardous substances and associated contaminated 

materials; recycling or reuse; diversion; destruction; segregation of reactive wastes; dredging 

or excavations; repair or replacement of leaking containers; collection of leachate and runoff; 

onsite treatment or incineration; provision of alternative water supplies; and any monitoring 

reasonably required to assure that such actions protect the public health, welfare and the 

environment. The term includes the costs of permanent relocation of residents and businesses 

and community facilities where the President determines that, alone or in combination with 

other measures, such relocation is more cost-effective and environmentally preferable to the 

transportation, storage, treatment, destruction, or secure disposition offsite of hazardous 

substances, or may otherwise be necessary to protect the public health or welfare. The term 

includes offsite transport and offsite storage, treatment, destruction, or secure disposition of 

hazardous substances and associated contaminated materials. (DERP Management Guidance) 

Remedial Investigation/Feasibility Study (RI/FS) 

An in depth study designed to gather the data necessary to determine the nature and extent of 

known contamination at a site, assess risk to human health and the environment, and establish 

criteria for cleaning up the site. During the FS, the RI data is analyzed and remedial 

alternatives are identified. The FS serves as the mechanism for the development, screening, 

and detailed evaluation of alternative remedial actions. 

Removal or Removal Action 

The cleanup or removal of released hazardous substances from the environment. Such actions 

may be taken in the event of the threat of release of hazardous substances into the 

environment, such actions as may be necessary to monitor, assess, and evaluate the release or 

threat of release of hazardous substances, the disposal of removed material, or the taking of 

such other actions as may be necessary to prevent, minimize, or mitigate damage to the public 

health or welfare or to the environment, which may otherwise result from a release or threat of 
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release. The term includes, in addition, without being limited to, security fencing or other 

measures to limit access, provision of alternative water supplies, temporary evacuation and 

housing of threatened individuals not otherwise provided for, action taken under section 

9604(b) of this title, and any emergency assistance which may be provided under the Disaster 

Relief and Emergency Assistance Act [42 U.S.C. 5121 et seq.] The requirements for removal 

actions are addressed in 40 CFR §§300.410 and 330.415. The three types of removals are 

emergency, time-critical, and non time-critical removals. (DERP Management Guidance) 

Resource Conservation and Recovery Act (RCRA) 

Enacted in 1976, RCRA promotes the protection of health and the environment. It regulates 

waste generation, treatment, storage, transportation, and disposal for facilities currently in 

operation. The munitions response process is affected by RCRA if MEC must be disposed 

off-site. 

Restoration Advisory Board (RAB) 

A forum for discussion and exchange of information between agencies and the affected 

communities. RABs provide an opportunity for stakeholders to have a voice and actively 

participate in the review of technical documents, to review restoration progress, and to 

provide individual advice to decision makers regarding restoration activities. (ER 1110-1-

8153) 

Risk Assessment Code (RAC) 

An expression of the risk associated with a hazard. The RAC combines the hazard severity 

and accident probability into a single arabic number on a scale from 1 to 5, with 1 being the 

greatest risk and 5 the lowest. The RAC is used to prioritize response actions. 

Short-term Exposure Limit (STEL) 

The STEL is defined by the American Conference of Governmental Industrial Hygienists 

(ACGIH) as the concentration to which workers can be exposed continuously for a short 

period of time without suffering from irritation, chronic or irreversible tissue damage, or 

narcosis of sufficient degree to increase the likelihood of accidental injury, impair self-rescue 

or materially reduce work efficiency. Workers can be exposed to a maximum of four STEL 

periods per eight-hour shift, with at least 60 minutes between exposure periods. 

Site Inspection (SI) 

Activities undertaken to determine whether there is a release or potential release and the 

nature associated threats. The purpose is to augment the data collected in the PA and to 

generate, if necessary, sampling and other field data to determine the presence, type, 
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distribution, density and location of MEC. The results of the SI are reported in an Archives 

Search Report (ASR). 

Stakeholder 

Stakeholders include federal, state, and local officials, community organizations, property 

owners, and others having a personal interest or involvement, or having a monetary or 

commercial involvement in the real property that is to undergo a munitions response. 

(ER 385-1-95) 

Superfund Amendments and Reauthorization (SARA) 

Enacted in 1986, this legislation establishes standards for cleanup activities, requires federal 

facility compliance with CERCLA, and clarifies public involvement requirements. 

Time-Critical Removal Action (TCRA) 

TCRAs respond to a release or threat of release that poses such a risk to public health (serious 

injury or death), or the environment, that clean up or stabilization actions must be initiated 

within six months. 

Technical Assistance for Public Participation (TAPP) 

Program that can provide independent assistance to Restoration Advisory Boards in 

interpreting scientific and engineering issues with regard to the nature of MEC hazards and 

response activities at a MEC project. (ER 1110-1-8153) 

Technical Escort Unit (TEU) 

Military chemical agent response unit. (EP 1110-1-18) 

Unexploded Ordnance (UXO) 

Military munitions that: (a) Have been primed, fuzed, armed, or otherwise prepared for 

action; (b) Have been fired, dropped, launched, projected or placed in such a manner as to 

constitute a hazard to operations, installations, personnel, or material; and (c) Remain 

unexploded either by malfunction, design, or any other cause. (U.S.C. 2710 (e) (9)) 

UXO Personnel 

Contractor personnel who have completed specialized military training in EOD methods and 

have satisfactorily performed the EOD function while serving in the military. Various grades 

and contract positions are established based on skills and experience. Check with the MM 

CX for current ratings. (ER 1110-1-8153) 
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 Glossary-21 

Worker Population Limit (WPL) 

The WPL is an occupational chemical exposure limit for workers. It is expressed as a timeweighted average that should not be exceeded during an eight hour working day.