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Military Munitions Working GroupFinal Report |
I. Introduction
The public is presently exposed to military munitions, unexploded ordnance (UXO), and constituents from munitions on millions of acres of uncontrolled or marginally protected sites, formerly used by the military for defense purposes. The Department of the Interior (DOI) estimates that some eight million acres of formerly used defense sites now under its management are contaminated with UXO. These lands are managed by an array of Interior Agencies including the Bureau of Land Management, the National Park Service, and the Fish and Wildlife Service. The Department of Defense (DoD) estimates there are some nine million acres of active and inactive ranges, as well as 1,200-1,700 Formerly Used Defense Sites (FUDS), which are thought to contain ordnance and require a cleanup response. Some of these installations or sites, such as Fort Ord in California, are in the process of being released from DoD use and converted to other uses under the Base Realignment and Closure (BRAC) Program. Many have already been returned to private ownership or are currently under control of tribal, state, and local governments. Presently, subdivisions, schools, highways, pipelines and other construction on these still contaminated and dangerous lands are underway to the peril of workers and the public. The cleanup of these lands to protect public safety and health and the environment is an area of increasing public concern.
In addressing these issues the Military Munitions Working Group (MMWG) of the Federal Advisory Committee to Develop On-Site Innovative Technologies (the DOIT Committee) initially set seven priority areas of concern associated with the environmental impact of the manufacture and use of munitions. They were: 1) detection and cleanup of UXO; 2) explosives and residue contaminated media (soil and water); 3) chemical agent cleanup; 4) biological agent cleanup; 5) munitions production; 6) remediation of depleted uranium; and 7) the prevention of contamination from rocket motor and fuel disposal.
The DOIT Committee was created to foster collaboration by a broad array of stakeholders to develop and test cooperative models to speed and improve the cleanup of federal facilities in the West. To accomplish this, the MMWG conducted fact finding meetings, participated in DOIT Workshops, and used the resources and expertise of the members to identify barriers to more effective remediation. Two key barriers to UXO and munitions hazardous and toxic waste (HTW) cleanup emerged; they were, inadequate technologies and an unclear regulatory framework. The MMWG sought to address these barriers by conducting demonstrations of collaborative approaches. It was recognized that process changes were often more important than new technologies to speed cleanups. The group envisioned testing both new technologies and new approaches to doing business at DOIT demonstrations. The purpose of the DOIT demonstrations was to evaluate ways to speed the use of innovative technologies and to accomplish federal cleanups faster, safer, cheaper, and better. Initial demonstration candidates were nominated because of their ability to focus on five key process changes or enhancements. These changes/enhancements included: 1) improved community stakeholder participation in technology selection and cleanup decisions; 2) clarification and development of a regulatory framework to guide munitions cleanup; 3) improvement of incentives for development and use of innovative technologies in detection and cleanup of UXO; 4) improved information sharing or technology transfer; and 5) the need to develop uniform risk evaluation methodology. Additional enhancements were identified for future testing. They included:
--The use of public /private partnerships for the advancement of technology
--New ways to bring innovative technologies to the marketplace
--Improved federal interagency and interstate cooperation in technology validation
--New ways to standardize cost and performance descriptions of technologies
--New approaches to procurement
Based on the findings of technical subgroups, the MMWG focused on three primary areas in need of technology improvements: 1) the detection, identification and remediation of buried UXO; 2) cleanup of explosives contaminated soil and water; and 3) alternatives to open burn/open detonation (OB/OD). In addition, the group found that in order to help the cleanup decision process, new approaches to risk assessment, risk communication, and risk management were needed. This included improved measures to provide long term protection to complement the deed restrictions currently relied upon for this purpose. After receiving briefings at the last two meetings in 1995 on the DoD plans and issues related to the destruction and demilitarization of stockpiled and non stockpile ordnance containing chemical agent, the Working Group concluded that this matter would need to receive priority attention in 1996 should the Working Group activities continue.
Activities
The MMWG issued its first report on November 3, 1993. The report was published in conjunction with the three other Working Groups formed under the DOIT Committee. A second report from the Working Groups was published in December 1994. All Working Group reports are considered public information and have been distributed to the participating agencies of the DOIT Committee, working group members, and interested parties.
Since its first meeting in May 1993, the MMWG has focused primarily on an assessment of technology needs, regulatory issues, stakeholder participation, the need to develop uniform risk evaluation methodology, and improved risk management tools. In early 1995 funding limitations impacted the MMWG resulting in several months of delay. With key support from the Department of Defense Explosive Safety Board (DDESB), partial funding was restored in late 1995. The MMWG convened in Herndon, Virginia on October 17, 1995 to continue its efforts to find better, faster, cheaper, and safer methods to address munitions issues.
The MMWG has held two full Working Group meetings since its last report and participated in this year's annual UXO Forum in March 1996. During these meetings, the MMWG also identified the need to address the technology and policy issues associated with the planned demilitarization and destruction of chemical weapons. At the October 17, 1995 meeting, members of the Non-Stockpile Chemical Material Program presented a thorough review of the chemical demilitarization program. While the MMWG identified chemical weapons as a priority topic, budget shortfalls and the scheduled expiration of the DOIT Memorandum of Understanding (MOU) in June 1996 prevented the Working Group from taking action on this issue. Should the MMWG be funded to continue its work it is likely the membership would pursue a collaborative process with DoD to address chemical materials and the demilitarization of stockpile and non stockpiled chemical agent.
II. Technology
The MMWG reviewed the status of technologies related to UXO detection, characterization (location and identification), mapping, destruction, and restoration and found that there is some mix of existing, new and emerging capability and gaps in each technology area. A benefit of the DOIT process was the creation of a forum that provided an opportunity to exchange information by various private companies, universities and government agencies involved in technology development.
It can be said that most technologies available work reasonably well under ideal conditions and with priori knowledge. For example: if it is known that in 1945 a single 1000 lb bomb was dropped into a specific 10 acres and there is a single magnetometer contact, there would be high confidence that the contact was the bomb. If, however, the 10 acres had at one time been a steel mill and 1,200 contacts were detected, the answer would not be as clear. It is the reality of existing test ranges, bombing ranges, and battlefields that causes the problem for today's technologies. The problem is vast; there are hundreds, maybe thousands, of contacts in densely wooded, wet terrain, or rough broken desert landscapes where one has to climb 200 to 300 feet up and down with rocks that look like ordnance and ground laced with shrapnel. The progress on the UXO problem is slow because it is a very difficult issue that has only recently been well understood and widely accepted as a major problem.
The press for speedy UXO cleanup compels seeking quick fixes to the problems associated with the technology. Unfortunately, there are no quick fixes. While work is being done on to correct the situation, the problem gets worse at an accelerating rate as newer munitions are developed. The following is a brief discussion of the status of five elements of the UXO remediation problem:
UXO Detection: Detection of UXO that have a low false alarm rate is a major problem. Shrapnel, naturally occurring magnetic materials, and other metallic objects complicate and interfere with the detection of UXO. Current sensor technologies and techniques provide high false alarm rates. Much of this problem is scientific which requires basic research. Technologies associated with surface and subsurface detection of UXO are divided into four areas; 1) Sensors, 2) Platforms, 3) Signal conditioning and analysis, and 4) Data management. Each of the four areas are continuously being improved by combinations of government and industry efforts. Increased funding for research, more centralized management of the technology development effort and clearer demand for new technologies would spur more rapid improvements to this technology.
Characterization (Identify and Locate): Better technologies and methods are needed to make UXO cleanup more efficient. While many advances in UXO detection technology have occurred and application of these advanced systems can likely aid in reducing UXO cleanup costs, sensors today are still not capable of identifying or distinguishing a UXO item from an inert or non-explosive material. Because of this limitation each contact signal located by the explosive ordnance disposal technician must be dug up and investigated. Until we are able to discriminate whether the contact signal is caused by buried UXO or and inert item and precisely locate the object, characterization efforts will be both time consuming and costly.
Mapping: The state-of-the-art of Global Positioning System (GPS) and Geographical Information System (GIS) has moved along to a point that implementation of quality mapping is not a technical issue today.
Destruction: Although destruction by open detonation or burning is the most used method of UXO destruction, it may not be the method of choice in many areas due to cultural and environmental impacts or impacts on unique habitats. Alternative methods of destruction or "render-safe" procedures require further development. Treaty and other commitments to demilitarize portions of the munitions stockpile compound this need for improved technologies. Regulatory changes may be required to support the development, demonstration, and operation of the new technologies needed.
Restoration: A number of promising approaches to remediate and restore contaminated soil and water were reviewed. While several technologies seem to be available, further evaluation is needed to define appropriate criteria for remediation and to validate the most promising approaches.
Currently, hand-held metal detectors are the most often used tools to detect UXO. These methods are slow, dangerous, costly, and labor intensive. For example, the Navy estimated that it would take $2 billion and 20 years to clear the 28,800 acre Hawaiian Island of Kaho'olawe to achieve the 4 foot depth needed to allow unrestricted access. Similarly, a study of the Jefferson Proving Ground reported in the September 1995 GAO Report to Congress found that current cleanup technologies were not practical for removing the UXO from the installation's 51,000 heavily forested acres.
GAO identified over 20 U.S. organizations that conduct or fund research and development on systems to detect and clear UXO. In the conference report accompanying the National Defense Authorization Act for Fiscal Year 1994, congress directed DoD to undertake a large scale detection and clearance technology demonstration. The Advanced Technology Demonstration conducted by Army Environmental Center (AEC) and the Navy Explosive Ordnance Disposal Technology Division (NEODTECHDIV) was mandated by congress and funded for fiscal years 1993, 1994 and 1995. Congress directed the Army to evaluate technologies for detection, neutralization and removal of mines for operations other than war in the FY 1995 National Defense Authorization Act conference report. The House Committee on National Security cited the need for a central authority to plan, oversee, and coordinate the research and development, and acquisition of the technology applicable to ordnance clearance. The Secretary of Defense was directed to prepare a plan to define research and development priorities, program management, and cooperative activities with international programs. The September 1995 GAO report UNEXPLODED ORDNANCE: A Coordinated Approach to Detection and Clearance Is Needed, recommended that the Secretary of Defense consult with other agencies involved and then develop a plan on how such a multi-agency clearing house would work. Additionally, the report urged that an executive agent be designated to serve this clearinghouse function. Even with this intensive interest in technology, implementation has been slow and actual clean-up programs are not fully utilizing available technologies.
There are several reasons for the slow development of technologies in the UXO area. The result is significant in terms of costs and in industry's motivation to continue its involvement in developing technology. Following is a summary of the salient points that relate to technology innovation in this area:
Military Explosive Ordnance Disposal (EOD) Technology versus Environmental (EOD): The design and implementation of military detection equipment has been driven primarily by the finite military EOD objectives of: 1) clearing passage through enemy minefields, and 2) the need for surface-only clearance of unexploded ordnance from the immediate vicinity of military operating areas. The subsurface clearance of unexploded ordnance (exclusive of land mines) is generally not required or performed. Armored vehicles with special scooping attachments, flailing, and similar methods are acceptable in a minefield environment, but are not applicable on the typical environmental UXO project. Cleanup criteria for UXO on FUDS or BRAC sites requires a significantly different methodology from the usual military ordnance clearance operations in order to provide for adequate risk reduction and environmental protection. It also may require subsurface clearance over large areas.
"The Technology Does Not Work": This is a generic statement which is often heard but which is not completely true when the whole array of technologies needed for UXO cleanup in order to protect human health and the environment are examined . While all technology works under certain conditions, the technologies for the detection, identification and location of UXO in difficult environments, are the least advanced.
Sensors - Metal detectors and magnetometer-based devices have been the primary sensor of choice since the 40's. Demand from the petro-chem and construction industries created practical applications for other sensors such as infrared, laser, thermal, seismic, radar and advanced magnetics. For surface surveying purposes, technologies such as radar and infrared imaging may be acceptable. For subsurface investigations, magnetometers are the most widely used tool even with the inability of this technology to identify a detected object.
Platforms - Vehicle, robotic, airborne, and remote controlled air vehicle are developed platforms which can accommodate a variety of sensors; however, because of the need to traverse difficult terrain, man-portable systems are still the most practical.
Signal Conditioning and Analysis - This technology area has experienced considerable advances in the past two to three years. Software is being developed by a number of entities, government and private, which enables analyzing raw sensor data to discriminate UXO from non-UXO and to derive size and depth of the UXO. A measured degree of success has been achieved. Sensor data can now be combined with spatial data, e.g., Global Positioning System (GPS) data, to provide detailed project documentation information in a single GIS medium.
Data Management - In addition to documenting the location and types of UXO located and recovered, information about endangered species, native plant and animal habitats, and local cultural and religious sites must also be collected and documented. An effective data management system which integrates and manages all the required project information is available today using commercial off-the-shelf software applications.
Traditional Approach vs. Newer Technology: The traditional approach to UXO detection/cleanup relies solely on the operator to detect the presence of an anomaly based on an audio tone from the detector. Very subtle changes in tone may not be evident to all operators. Operator fatigue, instrument sensitivity and poor sweep technique are all factors which can contribute to overall sweep inefficiencies. Utilization of instruments which automatically log data for post-processing and analysis alleviates much, if not all of the potential for operator and sweep technique error. Raw data can be independently analyzed for quality of findings, and it provides positive documentation of the number and location of anomalies located.
A quantum step in technology implementation is the integration of a computer into the magnetometer to provide for the electronic recording and management of anomaly signatures. This eliminates the subjectivity inherent in conventional aural-response systems. This technology has been demonstrated in the Jefferson Proving Grounds (JPG) evaluations as a method of detection. Reportedly, the most successful was the technology used by Geo-Metrics, Inc. with their Model G858G Cesium Magnetometer, and by Parsons/U.S. Army Corps of Engineers (USACE) using the Geonics EM-61 and the USACE-developed UXO Knowledgebase (KB).
Integration of multiple sensors on a single platform is within the current state of the art for geophysical subsurface detection. Geo-Centers, Inc. successfully demonstrated this also at the JPG program.
Traditional methodology utilizes the USACE QA criteria (no live ordnance located in a 10% grid swept using a Mark 26 Forester FEREX 4.021 magnetometer) to verify the standard of performance. This also is the standard for contracts issued by USACE for UXO cleanup. As a result, contractors tend to use the Mark 26 for the actual cleanup as this device is the benchmark their work will be compared to. Consequently there is little incentive for new technologies for use at actual cleanup.
No search effectiveness probability (SEP) standard has been established for the currently-utilized equipment. A result of the JPG demonstrations has been to document the SEP for the technologies demonstrated. There is no standard of performance for existing or traditional technology systems, consequently there are no criteria against which to measure performance on new systems.
There are no established specifications for UXO detection equipment insofar as depth, size of object, characterization, etc., are concerned. The standardization of requirements would provide a solid target for technology developers to meet. The implementation of a national range cleanup and munitions rule which are being developed will assist in this area.
Implementation of New Technology: Even though technology has advanced in all areas of detection (sensors, platforms, signal analysis, data management), current programs being conducted by the Corps of Engineers (COE) and other agencies of the DoD continue to utilize traditional methods.
Projects have been scoped, budgeted, and planned based on using the traditional approach. There are conflicting opinions within all of the responsible agencies regarding why this is the case. One suggestion is that new technology is rejected because of the anticipated additional cost of excavating additional items which will not be located using current less sensitive detection systems and methods. Another school of thought considers the new technology devices as unsafe to operate in a UXO environment. While safety is of critical concern, UXO personnel have reported good reviews of the new technology at live applications such as the Model Pilot Project on Kaho'olawe Island. UXO personnel are highly trained as former EOD military personnel. A necessary element of this training is adherence to the rule that one must work within accepted, proven standards and methods. Because of the hazardous nature of the UXO cleanup process, the use of methods and procedures which have not been absolutely proven and confirmed is unacceptable by the EOD/UXO culture.
The consequence of not implementing technology is significant: Many firms domestically and internationally have invested considerable time and money to develop, adapt or simply further detection technology only to find a lack of acceptance in the marketplace. Unless there are incentives to implement new methods, commercial firms will become discouraged and will eventually leave the marketplace. This will put the burden for development of needed new UXO technology on government agencies and, therefore, the commercial sector resources will not be utilized.
The development of new technologies along with the implementation of current methods must be continued, encouraged, and funded. Specific recommendations the subgroup concurs with are:
1. Develop a base line standard of performance, cost and quality applicable to all instruments and processes . This would become the unit of measure to judge the acceptability of new technologies and improvements to existing methods.
2. Evaluate procurement and contract policies and remove real or perceived restrictions on implementing innovative application of technology on current UXO programs.
3. Develop an incentive program to encourage the implementation of demonstrated new technologies that are safer, faster, better and cheaper.
4. Discontinue the practice of government furnishing only the standard detection, GIS and Information Management equipment. Instead, encourage the use and make available some of the new equipment and methods.
5. Implement a training program for the commercial UXO community on new methods and technologies. Many firms are small and cannot keep up with new methods.
6. Work toward a national standard for UXO cleanup so that technology developers have one set of rules with which to work.
Policy Options:
* DoD to implement the findings of the September 1995 GAO report which states that technology development would be enhanced by establishing a multi-agency clearinghouse to foster interagency collaboration. This clearinghouse should focus on developing requirements and criteria, and expediting the development, testing and utilization of advanced technologies for the detection, location and remediation of unexploded ordnance. This executive agent function is to be supported by a technical advisory body, such as the DoD Defense Science Board, and a policy advisory council comprised of a broad array of state, tribal, and other key stakeholders in the area of UXO cleanup. The MMWG fully supports the GAO report's findings.
* DoD establish an independent "third-party" or interagency technology evaluation program and test site(s) for the purpose of standardizing and validating cost and performance of the most promising advanced technologies for the detection, location and remediation of munitions. In the absence of a national standard for UXO cleanup, states, tribal governments, other regulators and key community stakeholders should be directly involved in the design and review of the validation testing. The Defense Science Board, Strategic Environmental Research and Development Program's (SERDP) test beds, and the Environmental Security Technology Certification Program (ESTCP) could serve as elements of a model framework for these advanced technology evaluations.
* DoD should seek ways to expand communications between sites that have similar UXO remediation projects. DoD Regional Environmental Offices can help manage this effort. This should include:
--working toward standardizing protocols and conducting cooperative assessments of applicable technology for site characterization and remediation.
--expanded communications between Restoration Advisory Boards which are addressing similar cleanup issues to collaborate on remedy selection.
III. Regulatory Subgroup
Introduction
The Regulatory Subgroup included federal agencies, state regulators, environmental group, public and industry representatives of the MMWG. Observers and others attending MMWG meetings often participated in Subgroup and MMWG discussions and deliberations on the regulatory aspects of munitions handling and cleanup. After examining the situation of existing regulation of munitions, it was clear that major national, tribal and state policy and rulemaking was needed to guide the massive UXO and munitions cleanup underway.
The Subgroup urged broad and open collaboration between responsible federal agencies, states, tribal government and the affected public to develop appropriate and acceptable public policies and regulations in this important area.
Findings
In the November 1993 report of the MMWG, the Regulatory Subgroup identified the lack of clear and consistent regulatory requirements for munitions cleanup as a barrier to technology development and environmental restoration of the millions of acres of federal and formerly federal lands in the United States. This gap in the regulatory and policy framework for munitions continued despite the congressional directive in the 1986 Superfund Amendments and Reauthorization Act (SARA) that the Secretary of Defense address detection and disposal of unexploded ordnance in establishing the Defense Environmental Restoration Program (DERP). On October 6, 1992 President Bush signed the Federal Facility Compliance Act which modified Section 3004 of the Resource Conservation and Recovery Act (RCRA) by adding a new subsection on munitions which required EPA to promulgate munitions regulations by October 6, 1994. The regulations were to identify when military munitions become hazardous waste and provide for safe transportation and storage of such waste.
In November 1994 the Inspector General of the DoD issued a report titled, Review of the Policies and Procedures Guiding the Cleanup of Ordnance on Department of Defense Lands. This review found vast differences in interpretation as to which environmental laws applied to ordnance and explosives (OE). Of the 38 installations and offices interviewed, 13 regarded Superfund as the principal guidance, six considered RCRA as prevailing, three followed the DoD Safety Standard as primary, and 16 did not know. This review paralleled the Subgroup findings that the DoD and military services guidances are incomplete and lack consistency. The Subgroup's findings indicate that lack of consistent guidance results in the lack of consist OE cleanup methods. In addition, the Subgroup found that environmental groups, DoD, EPA regional offices, and state agencies had significantly different interpretations of key aspects of regulation. For example, the moment when munitions are considered hazardous waste is interpreted differently by many state regulators. Some states have indicated they consider UXO a hazardous waste at the point DoD intends to abandon the property, other states identify UXO as a hazardous waste at the point of treatment, e.g. at a disposal facility. Some state regulators advocate UXO as a hazardous waste when it cannot be used for its intended purpose any longer; other states advocate that it becomes a waste when it hits the ground.
The Military Toxics Project (MTP), a coalition of over 30 citizen group involved with various military bases throughout the United States, filed suit when EPA did not proceed with the required rulemaking. EPA entered into a court refereed settlement with MTP to promulgate the required regulations by October 31, 1996. This was later extended to Dec. 2, 1996 to provide for the delays caused by federal furloughs and lack of an EPA budget for periods of time early in the 1996 fiscal year.
On November 8, 1995, after two years of consultation with DoD, interested state agencies, and some national community and environmental groups, EPA published a proposal for regulating munitions as hazardous waste. Public comments were accepted for the record until February 2, 1996. Final EPA promulgation of these requirements is to be completed by December 2, 1996.
The November proposal differed from earlier drafts circulated by EPA in one significant aspect: The EPA proposal asked for comments on an approach wherein DoD would be authorized to develop national requirements for regulating munitions at which time EPA and tribal, state or local authority to regulate and enforce any existing regulations would be sunset or preempted. State agencies objected to this sunset and questioned the legality and appropriateness of such self regulation without oversight by environmental agencies.
In response to the EPA sunset proposal, the DoD moved quickly to develop the DoD regulations so as to complete them by the December 2, 1996 date which would allow for a seamless transition to the DoD rules without the confusion of temporary EPA rules. By early March 1996 a Deliberative Draft of Military Range Rule was widely circulated for comment. The draft rules addressed military munitions wastes at closed, transferred and transferring ranges. DoD reported plans for policies and additional rules for active ranges in the near future.
The MMWG and the Regulatory Subgroup offered to be of assistance in the development, discussion and circulation of the draft rules so as to involve a broad array of interested stakeholders. This assistance was accepted by Ray Fatz, Acting Deputy Assistant Secretary of the Army. During March and April 1996 several national conference calls were arranged by the Working Group to facilitate open and full discussion of the proposal. State agencies, tribal governments, community groups and environmental organizations were provided copies of the draft rule, briefed and given the opportunity to comment on the proposal. Members of the Working Group presented a panel discussion on the draft regulations on April 2, 1996 at the annual meeting of the Association of State and Territorial Solid Waste Management Officials (ASTSWMO).
Stakeholder conference calls were also sponsored by the Working Group on the proposed EPA rules. The WGA and MMWG also compiled the comments from states, industry public groups, including the MTP, which were sent to EPA and provided copies to state, federal, tribal, industry and public participants nationwide. This broad based discussion of the regulatory issues assisted greatly in clarifying and understanding different regulatory needs and approaches.
The DoD plans to address stakeholder comments and redraft the strawman range rule. A redrafted rule will be officially published as a proposal in the Federal Register in May or June 1996. During the 60 day comment period, the DoD plans to hold four national public information forums to help ensure full public understanding and to provide an opportunity for stakeholders to review and comment on the proposal.
While major steps have been taken to establish the missing regulatory framework for munitions, the present EPA and DoD proposals still contain many inconsistencies and leave unclear many jurisdictional and implementation issues. Also, some argue that a fully comprehensive regulatory framework must extend beyond closed, transferred, and transferring military ranges to active ranges, all formerly used defense sites and other facilities that store, transfer, manufacture, dispose or otherwise handle or contain military munitions. Much work remains to achieve a fully protective regulatory framework which integrates the authorities and regulations of state, tribal and federal jurisdictions to establish a coordinated safety net of regulation for munitions.
Policy Options
* DoD and EPAcontinue to conduct full stakeholder collaboration to establish an effective and acceptable munitions regulatory framework . Institutionalize this collaborative approach to federal agency policy development. Conduct coordinated and integrated broad based training of personnel to ensure consistent interpretations and implementation of final regulations.
* Expand the stakeholder dialogue to achieve agreement on fundamental standards or criteria for UXO cleanup that will provide for safe and environmentally protective remediations.
IV. Stakeholder Subgroup
Introduction
The MMWG is comprised of members representing federal and state agencies, commercial and industrial interests, citizen environmental groups, academia and tribal governments. Because ineffective stakeholder involvement was identified as a barrier to the development and use of innovative technologies, a Stakeholder Subgroup was a necessary adjunct to the MMWG. The mission of this Subgroup was to guide and oversee stakeholder participation aspects of the Working Group and any stakeholder studies conducted as DOIT demonstrations.
The goals of the Stakeholder Subgroup were:
1. To identify and test mechanisms by which stakeholders can be involved early in the decision making processes for the development and demonstration of innovative technologies and munitions waste issues.
2. To help the MMWG act as a stakeholder mechanism in itself by establishing and implementing a collaborative dialogue on UXO, munitions, and technology issues.
3. To promote and illustrate the importance of stakeholder activity at the local and regional level where the impacts of decisions can be critical.
Subgroup Activities
The Subgroup has encouraged and advised on the development of stakeholder plans and activities at the various candidate DOIT demonstrations. Additionally, the MMWG has participated in the establishment of two Restoration Advisory Boards (RABs) at munitions cleanup sites. Members also assisted in the creation of a questionnaire and a list of questions for personal interviews as a means to measure effectiveness of RABs. Subgroup members were participants at the Tribal and Public Forum on Technology Assessment and the DOIT Stakeholder Forum conducted in the fall of 1995. The Subgroup also advised on stakeholder participation aspects of EPA's draft Munitions Rule and the DoD Rule for Closed, Transferred and Transferring Military Ranges.
The Military Munitions Working Group as a Stakeholder Involvement Mechanism
The MMWG is comprised of diverse stakeholder interests including five industry representatives; six state, eight federal and two tribal government representatives; three academia representatives; four citizen/ environmental group representative; one representative from the National Laboratories; and one local government representative. The membership roster was revised twice to replace members that could not continue as well as to ensure balanced viewpoints. Specifically, business, tribal and local government representation was increased. Additionally, some 30-60 observers, mostly from the UXO industry, attended the Working Group meetings and freely entered the discussions. The MMWG was able to maintain a balanced and diverse group because of the ability to provide travel money to local, state, tribal, public and academic participants.
In the early days of the Working Group, distrust and lack of common language and understanding made doing business and agreeing on even basic issues very difficult. After working through consensus decisions on key areas, the Working Group got better and better at achieving agreement. In time, the Working Group found they could do work through conference calls and a steering committee. However, face-to-face meetings remained the most effective means of communications. Through such meetings and discussions of key issues, the members were able to talk about the most controversial issues in a diplomatic and reasonable fashion as their distrust of each other gradually diminished.
A survey was distributed to the MMWG members to ascertain the usefulness of meeting as a working group as well as to garner lessons learned. Results from the survey indicated the majority of Working Group members felt their involvement with the group helped them to better understand the views of other stakeholder groups. Additional survey results indicated the majority of working group participants felt the working group was a useful forum to help policy makers explore new ideas and disseminate information. Comments from the survey include:
"Gained an understanding of public concerns"
"Helped break down the us vs. them attitude"
"The ripple effect of DOIT has been tremendous!"
"DOIT has been very helpful to states by providing excellent contacts and help to each other on munitions issues"
Similarly, participants agreed or strongly agreed with the following statements:
1. The type of multi-stakeholder involvement in technology policy discussion on regional basis like that of the working group can be a useful forum to help policy makers explore new ideas and disseminate information.
2. Participation in the working group was particularly helpful in understanding the private and federal remediation technology development, testing, and evaluation process and to better judge the merits of a technology.
3. Stakeholder involvement should be viewed as a means of efficiently determining and achieving acceptable cleanup goals.
DoD and EPA draft Rulemaking as a Stakeholder Involvement Processes
The EPA involved key stakeholders, including the Regulatory Subgroup, in the development of draft regulations for munitions as a hazardous waste by holding separate discussions with state, public interest groups and other federal stakeholder agencies. Participants were pleased to be involved but reported that not hearing the concerns and suggestions of other groups limited a broad based understanding of the issues and resulted in some polarization of the groups. Several expressed concern over deals they believed were being struck in these separate meetings. Additionally, the final proposal published in the Federal Register was strikingly different from the drafts that had been previously reviewed by the stakeholders. This lead to further distrust, frustration over time spent on the draft rule, and very little stakeholder acceptance of the proposed regulation.
Shortly after the EPA draft rule was published, the DoD drafted rules for the regulation of munitions on closed, transferring and transferred ranges. The DoD involved stakeholders by distributing an early draft rule to interested parties, conducting numerous briefings, and posting this draft on the Internet. This was done several weeks before the proposal would be published in the Federal Register for official comment. The draft rule was also discussed by numerous public and government stakeholders during three toll free conference calls which were open to the public. While many felt that the DoD's early public involvement efforts were an improvement over the EPA's efforts, others felt that DoD's efforts were still not early enough.
MMWG as a Stakeholder Mechanism - Policy Options
* Continue functioning of the MMWG to oversee the implementation of policy options and to report progress to the annual meeting of Western Governors Association (WGA).
* Continually seek out new interested stakeholders and groups to contribute and participate in discussions of munitions and technology issues at the local and national level. Once that dialogue is initiated, it must be continued. Also allow time and provide materials to bring the new members up to speed, as well as to educate them about the working group ground rules and procedures. Orientation meetings and the appointment of mentors are examples of effective ways to educate new members.
* Recommendations and advice that come out of advisory boards or working groups must be addressed by the agencies to which the advice or recommendations are directed. These agencies must either institutionalize these recommendations or provide a detailed explanation to the groups as to why their advice can not be acted on or institutionalized
* When setting up an advisory group, proactively seek interested parties and provide them with the means to adequately participate in meetings and dialogues.
* For future rulemaking efforts, include stakeholders and other interested parties in early conceptual discussions. Some suggest that interested stakeholders should be included on the team drafting the rule.
* Early stakeholder meetings and discussions on rulemaking should be held jointly so that each party can learn of the others issues and comments. Furthermore, the final proposal should reflect early stakeholder comments. If drastic changes are made, the stakeholders should be consulted. Strive to ensure openness and collaboration.
DOIT Demonstration - Stakeholder Studies
Black Hills, SD
The purpose of the Black Hills Army Depot (BHAD) DOIT demonstration project was to test and evaluate a stakeholder involvement process at FUDS contaminated with UXO and constituent or residue chemicals. The DOIT demonstration sought to determine whether the early involvement of a broad array of stakeholders lead to greater community, regulatory, and landowner understanding and acceptance of the cleanup, and the methods and technologies used. The mechanism for stakeholder involvement studied at this site was the formation and operations of a Restoration Advisory Board (RAB).
To provide an objective assessment of the RAB s effectiveness as a stakeholder involvement vehicle and to gauge perception changes attributable to the RAB process, the University of Denver was contracted to perform a study. This study consisted of developing, administering and evaluating responses to a questionnaire and personal interviews of RAB members and local citizens.
The assessment work performed to date indicates the RAB process, as implemented at the BHAD, has enhanced community understanding of the cleanup process and issues. The survey found that over 70% of the respondents agreed that those in power and authority heard and acted on the concerns of the group. Eighty-five percent said that while the decision process took longer by involving the community, they agreed that better decisions resulted. Also, a majority reported that the RAB process could become a model for decision making in their community. While satisfaction with the level of participation varies within the RAB membership and the public, participants felt that the increased access to the USACE, contractors, regulatory bodies, and the resulting first-hand information available to the public was a major improvement over past information dissemination to the community.
Nearly all respondents felt the most striking success of the BHAD RAB was the open, inclusive and collaborative way the RAB was established by involving community leaders in identifying and obtaining the participation of key organizations and the public. This process is a good model to follow in forming similar community advisory groups.
Impact of the RAB's input can be seen in the modifications made to USACE's original assessment/remediation strategies. These include:
Archives Searching - additional archives searches were performed; advertisements and 800 telephone number were established to solicit individuals with knowledge of operational history of site; and additional interviews were conducted.
Sample Timing and Analysis - based on RAB concerns, USACE modified contract to include a sampling in the spring of the year (wet season); also included sampling for contaminants not originally scoped by USACE.
Assessment Focus - RAB members suggested that the project was moving too slowly and suggested the USACE focus on areas of minimal contamination. USACE responded by changing original strategy and locations of investigation.
The DoD has established hundreds of RABs to serve as much needed stakeholder mechanisms at Military Installations and closing base cleanups. The formation of these RABs were the result of recommendations made by the Federal Facility Environmental Restoration Dialogue (a.k.a. the Keystone Report), an EPA Federal Advisory Committee. The DOIT study at the BHAD was the first one ever conducted to ascertain the effectiveness of RABs. It is also the first study to determine what aspects of the RAB formation and implementation processes are working and which are not. The appended April 15, 1996 report, Assessment of Local Stakeholder Involvement, which includes the analysis of the BHAD responses, yielded several findings and recommendations based on the one year study. Additional data should be collected from the ongoing operations of the group to provide lessons learned to new RABs and community groups.
BHAD Stakeholder Study - Policy Options
* Fund the second year of studies of RAB effectiveness at the BHAD RAB and add information and analysis of survey information from comparable community groups at the Oglala Sioux Badlands Bombing RAB and the BRAC facility at Fort Ord. Forward suggestions, based on DOIT studies, for revisions to the DoD/EPA guidance for the establishment of Restoration Advisory Boards. Furthermore other RABs should be studied, like the BHAD, in order to develop a more comprehensive report on creating and implementing a RAB.
* Based on the DOIT studies which revealed the beneficial value of RABs to community decisions and information regarding UXO cleanups, MMWG recommends continuing the DoD commitment to establishing RABs at defense installations. Broaden the use of these community stakeholder advisory groups to FUDS and other munitions remediation facilities.
Fort Ord, CA
The focus of the Fort Ord candidate DOIT demonstration, originally, was to test and document the usefulness of the Fort Ord Restoration Advisory Board and the Fort Ord Reuse Authority (FORA) as a stakeholder mechanism at a closing base or BRAC site. Since the RAB was fully underway before DOIT studies were funded, the MMWG concluded the data gathered would be inconclusive and focused the evaluation resources on the Black Hills RAB which was just getting organized. Transcripts of the first eight meetings have been obtained, however, and can be used to provide information to compare with the Black Hills RAB.
Kaho'olawe Island, HI
The Kaho'olawe project is an ongoing collaborative process to test the workability of a intergovernmental partnership to fashion a better regulatory framework in order to provide a faster, cheaper, safer and better cleanup. Representatives from the Kaho'olawe Island Reserve Commission attended the MMWG regularly and received and exchanged information regarding cleanup, stakeholder, and regulatory processes and issues. The Kaho'olawe Island Reserve Commission, a statutory authority, is dedicated to restoring the natural and cultural aspects of their island. An ongoing process is in place between the Kaho'olawe Island Reserve Commission and the US Navy. No DOIT resources were allocated to study and document the effectiveness of this unique approach to cleanup decisions at a munitions site.
Military Munitions Working Group Legacy Options
Department of Defense guidance required that a more aggressive role be taken to include citizens in decision making processes. A goal of the MMWG has been to establish a dialogue with the DoD regarding military munitions waste issues. It is thought that continuation of this dialogue would benefit the Department and stakeholders. The following are a few of the benefits of continuing the MMWG, or a similar stakeholder group, which have been identified by the Stakeholder Subgroup and approved by the MMWG:
1. In cooperation with the DoD, the MMWG, or a similar stakeholder group, could review current practices of public information dissemination regarding environmental issues performed by the military and make recommendations for process enhancement.
2. The Working Group could assist the DoD in the actual dissemination of information from military sources to the constituencies of the individual members.
3. The MMWG legacy could be a forum where the DoD could discuss its concerns, frustrations, and desires regarding the environmental impacts of munitions use and receive counsel from a knowledgeable, diverse, and interactive collage of stakeholders.
4. A panel could be formed to respond to invitations from communities, citizens groups, political or other entities who have a desire for information regarding the manufacture, testing, storage, transfer, use, demilitarization, environmental impacts or safety of munitions. The MMWG could serve as a resource for staffing this panel or providing information to panel members. The panel would be one vehicle for making cognizant DoD authorities directly available for discussions with interested parties.
The continuation of the MMWG concept offers the DoD a unique opportunity to benefit from the collective expertise of an existing group of individuals who have focused their attention on the complexities of dealing with the safety and environmental aspects of munitions. This valuable resource, originally conceived, established, and supported by the WGA, should not be wasted.
V. Technology Transfer Subgroup
Introduction
The Technology Transfer, Database and Education/Training Groups; Contaminated Media; OB/OD and alternatives; Commercialization; Jefferson Proving Ground; and Yuma Proving Ground Subgroups were combined to form an overarching Technology Transfer Subgroup to address technology transfer approaches to speed the communication and use of new technologies in the ordnance and explosive waste and hazardous toxic residues cleanup areas.
The former Contaminated Media Subgroup was formed to address the special problems associated with ordnance and explosive waste contaminated media (soil and water). The Subgroup conducted a preliminary evaluation of sites and available technologies that might be tested for detection and/or remediation of contaminated media. Candidate sites were identified, but declined to participate in the DOIT process because of their concerns over potential liability if something should cause increased contamination during the demonstration. This Subgroup also coordinated a workshop on the topic of remediation technologies for explosive waste on May 22, 1995. A videotape of this workshop discussion was made available to WGA states and other stakeholder groups. A similar workshop is scheduled for May 23, 1996 in Albuquerque, New Mexico. The findings from this Subgroup were conveyed to the Hazardous Waste Generic Technology Working Group (HWGTWG), which committed to pursue an interagency demonstration of such biological treatment technologies.
The former OB/OD and Alternatives Subgroup found that open burning and open detonation of munitions and munitions components, such as rocket fuel, while attractive in terms of personnel safety and cost, may not be an optimal disposal solution due to the noise and air pollution and potential soil and water contamination associated with this treatment. Also, the OD process is often incomplete and results in UXO, due to "kick outs." In 1994, Working Group representatives visited with technology developers and examined the Base Hydrolysis technique developed by Los Alamos National Laboratory. The Group concluded this method and possible others may provide promise for broad application at sites where waste munitions or rocket fuels are to be treated. No funding was provided for the Subgroup to continue to screen additional technologies for application in this area. Since many states are moving to limit OB/OD, additional work is needed in the area of technologies which could serve as an acceptable alternative.
The former Commercialization Subgroup found that demonstrated technologies may find willing buyers in private-sector markets; however, not all technologies demonstrated will prove suitable for commercialization. The key to this assessment is the technology owner's interest in commercialization combined with documented market demand for a given technology. If commercialization is pursued, the Subgroup found that a thorough market assessment must be made prior to demonstrating a technology to determine if there is sufficient demand for the technology to justify the expenditures.
Advanced Technology Demonstrations - Jefferson Proving Ground and Live Sites
The objective of the Advanced Technology Demonstration (ATD) program was to identify and evaluate innovative, cost-effective, commercially available systems for the detection, identification, and remediation of sites which contain UXO.
To date, JPG Phase I, JPG Phase II, and Live Site demonstrations have been conducted to establish a baseline for achievable UXO detection and remediation system performance. JPG Phase I and II demonstrations were conducted at a controlled test site, which contained inert ordnance at JPG, while the Live Site demonstrations were conducted at five geologically differing sites across the U.S that contained live ordnance. The demonstrators represented airborne, ground vehicle, and man-portable platforms; magnetometer, ground penetrating radar, electromagnetic induction, and infrared sensors; target processing software; and remediation technologies.
Several reports have been published which summarized the JPG Phase I technology performance and results. The data allows for a broad comparison of sensors, platforms, and data analysis capabilities of systems that performed in a know and controlled environment. JPG Phase II and Live Site Reports will be completed and available for distribution in May 1996.
Results from the demonstrations have shown systems exhibiting detection capabilities which range from 0-80%. High false alarm rates were exhibited during all demonstrations. Robotic remediation of targets was shown to be a very time consuming process.
Yuma Proving Ground
The Yuma Proving Ground demonstration of surface UXO detection technology and alternative ways to communicate findings of these tests, originally scheduled for May 1996, has been postponed due to unforeseen illness of key personnel. Should the work of the MMWG continue, it is expected that this demonstration will be rescheduled.
Subgroup Activities
A survey was distributed to an assortment of federal and state employees, stakeholders, and academia at the 1996 UXO Conference in Williamsburg, VA, March 26-28. The purpose of this survey was to ascertain the importance of conferences and other communication and networking mechanisms in terms of sharing useful information for technology permitting, barriers, and other cleanup issues. Results from the survey indicated that the majority of those surveyed attend these conferences specifically to network with others involved in the field. In addition to such conferences, maintaining contact with others in their field and using the Internet were found to be the most trusted and useful mechanisms for receiving and transferring relevant technology information.
Survey results of MMWG members were used to identify findings and policy options in the area of technology transfer. Results from this survey indicated that most MMWG members feel that a national program to independently verify technology costs and performance has clear value. Working group members also agree that sites should be set aside to field demonstrate innovative technologies with a risk sharing agreement with stakeholders. Members strongly agreed that the federal government should invest in applied research and development on demonstration testing of innovative technology.
The Association of State and Territorial Solid Waste Management Officers (ASTSWMO) conducted a nation-wide survey of state regulators and found that when reviewing treatment technologies, state regulators value most pilot bench scale test information specific to their site. Secondly, they favor test data from site specific demos. Survey results indicated that research papers on technology were found to be least useful regarding permitting decisions.
MMWG members participated in the DOIT Regulatory Barriers and Commercialization Workshops, which examined various barriers to innovative technology development and use. Reports of these workshops were reviewed for technology transfer findings and recommendations.
Findings
The Technology Transfer Subgroup found, through interviews, surveys and discussions, that community groups, state regulators and industry would value up to date information on the most promising technologies and permitting information as well as contact names. Therefore, the UXO Sourcebook was developed as a source of information on ordinance detection cleanup technology for a variety of users including technology permit writers, community groups, etc. This Sourcebook is a resource on where to obtain more information about UXO issues, including government documents, computer data bases, and points of contact in the military, regulatory, private and academic sectors.
The Subgroup also found that technology transfer opportunities are more dependent upon an end-user's interests and prior habits than the inherent qualities of a new technology. The most fundamental enhancement which implementation teams can provide to expedite technology transfer is efficient, simple and inexpensive access to product-related information by potential private-sector users.
The Subgroup found that participants in the Regulatory and Commercialization Barriers Workshops ranked the following as key barriers to technology transfer:
-- lack of standardized and validated cost and performance data on UXO detection and remediation technologies.
-- lack of regulatory predictability and means to coordinate interagency acceptance and interstate permitting of technologies.
-- lack of incentives for regulatory agencies and remediation officials to encourage the use of more flexible approaches and innovative technologies in cleanup.
-- unclear and uncertain market for remediation technologies.
-- lack of information by the public, the technology user community, and the regulators on the best available technologies. This lack of information leads to traditional technology selection and contributes to distrust of new approaches to cleanup.
Policy Options
* WGA and member states assist to provide widespread distribution of the Military Munitions and UXO Source Book of key information and names of contacts on dominant technologies in the areas of 1) UXO detection and remediation; 2) treatment of soils and water contaminated with explosives; and 3) alternatives to OB/OD of munitions components (e.g. rocket fuels). In order to provide users with the most up to date and useful information, the UXO Sourcebook should be updated by DoD on an annual basis.
* Encourage archival documentation of demonstrations and resulting data for future analysis and to assist in creating educational and training materials.
* Efforts should be made to develop and test standardized descriptions of the cost and performance of validated technologies.
* Establish an annual DOIT Innovative Technology Application award for remediation Project Managers or restoration teams at federal facilities in the west that have advanced the use of new technologies, new applications of detection and remediation technology or new approaches to accomplish better, faster, safer and cheaper cleanup. A substantial annual cash award will provide incentive and competition to use innovative applications of technology on federal cleanups. The award might be named after deceased Governor George Mickelson in honor of his role in forming the state/federal partnership that led to the DOIT Committee.
* Demonstrate not just technology performance, but also the development of markets for those technologies, especially new approaches to procurement and clear procurement paths for successfully demonstrated technologies. Marketing plan to accompany any technologies demonstrated at test sites.
* Explore mechanisms for integrated interstate and interagency permitting reciprocity of technologies. Increase the level of regulatory predictability in the technology demonstration and approval process. Reduce or offset the costs and time incurred by technology developers in the regulatory process by seeking ways to streamline through increased collaboration between states.
* Implement a training program for the commercial UXO community on new methods and technologies. Many UXO firms are small and cannot keep up with new methods.
VI. Risk Subgroup
Introduction
Military munitions have an inherent risk; they are designed to kill and injure people. Millions of acres of UXO and other contaminants of range activities are found on military run active, inactive, and closed ranges as well as transferring and transferred ranges now managed by nonmilitary federal agencies, tribes, state and local governments, and private landowners. Generally, the ranges that are not under military control are open to public access.
Understanding the inherent risks associated with military ranges and being able to assess these risks provides a knowledge base from which to manage the risk while making appropriate reuse of the former ranges.
There were three action items described in the MMWG Annual Report 1995:
1. Develop risk communication tools for stakeholders at transferred or transferring military ranges.
2. Look at alternatives for long term protection and risk warning to supplement deed restrictions on contaminated transferred or transferring federal properties.
3. Encourage and assist the development of an improved risk assessment process or model that integrates explosive risk with chemical risk at a cleanup site.
The Risk Subgroup focused its efforts this year on risk at transferring and transferred ranges, as these pose the greatest risk to the general public. By definition provided in the DoD's Deliberative Draft Range Rule, dated February 20, 1996, transferring ranges include those ranges associated with BRAC activities, and other property transfers to nonmilitary entities and transferred ranges include those identified in the FUDS program.
The Subgroup has worked with the U.S. Army Corps of Engineers, Huntsville District (QuantiTech model) and the Navy Explosives Ordnance Disposal Technology Center (PRCmodel) during risk assessment model development and provided input at appropriate times. The QuantiTech and PRC models are nearing field testing. The Subgroup has supported the development of the integrated risk assessment models and members plan to participate in the field testing.
Due to time constraints and funding limitations, the Risk Subgroup limited itself to safety risks associated with UXO. Risk associated with constituents from exploded ordnance and from other wastes associated with range activities which may have been released into the environment, were not fully addressed.
Findings
The transfer of military ranges out of military control, as well as the establishment of RABS for active military installations, has created the need for improved communications with new landowners and other stakeholders associated with transferred land contaminated with UXO.
Prior to the DOIT effort, there was little non-technical informational material available to assist these stakeholders with understanding the risks associated with UXO and the management of that risk.
The objective of the risk communications effort has been to provide basic information to reduce exposure to the risk from unexploded ordnance on transferred and transferring military ranges. Two products for two distinct audiences with different needs were identified. These products and audiences are described below.
1. A Risk Primer for policy stakeholders and managers, which include Restoration Advisory Boards, members of a Local Redevelopment Authority at a closing installation, and the manager and staff who are or will be responsible for the day-to-day activities occurring on the lands containing UXO (Federal, Tribal, state and local government agencies and private landowners)
2. A Safety Fact Sheet for persons using the land and resources within the range, which include persons engaged in sports and recreation activities, e.g., hunters, off-road vehicles operators, mountain bikers, hikers, campers, and commercial activities, such as wrangler/cowhand/shepherd, forester.
There remains a need for an information booklet to provide stakeholders with a basic understanding of issues related to other residues from range activities, including constituents of exploded ordnance and other potentially hazardous wastes.
Policy Options
* WGA to help distribute the Risk Booklet and Safety Fact Sheet to the stakeholders in and users of transferred and transferring military ranges.
* An evaluation as to the effectiveness of these documents should be undertaken one year after distribution. If appropriate, these documents should be updated and republished.
* DoD should take the lead in interagency collaboration to develop a detailed quantitative risk assessment model to use in cleanup decisions. This risk assessment model will integrate assessment of risks posed by military munitions and UXO at ranges, and the human health and environmental risks posed by other contaminants, to provide an overall risk estimate. This model is to serve as a tool to assess effectiveness of possible response action.
VII. Military Munitions Working Group Key Policy Options
* DoD should establish a multi-agency clearinghouse or executive agent to foster interservice and interagency collaboration and focus in developing requirements, criteria and expediting the development, testing and utilization of advanced technologies for the detection, location and remediation of unexploded ordnance. The clearinghouse should:
--include a technical advisory body, such as the Department of Defense Science Board, which includes representatives of agencies with technology approval responsibilities.
--include a policy advisory council comprised of a broad array of state, tribal, and other key stakeholders in the area of UXO cleanup.
--in cooperation with other responsible agencies, rapidly complete the national inventory of formerly used defense sites and other inactive, closed, transferred, or transferring sites which contain buried munitions and UXO.
--establish an annual DOIT Innovative Technology Application award for remediation Project Managers or restoration teams at federal facilities in the west that have advanced the use of new technologies, new applications of detection and remediation technology or new approaches to accomplish better, safer, faster and cheaper cleanup.
--annually update the DOIT Source Book of information and contacts for munitions detection and remediation technology for use by state, tribal, federal agencies and community Restoration Advisory Boards at munitions cleanups.
* DoD and EPA should collaborate with states and tribes to develop a detailed quantitative risk assessment model to use in cleanup decisions. This risk assessment model will integrate assessment of risks posed by military munitions and UXO and the human health and environmental risks posed by other contaminants to provide an overall risk estimate. The integrated risk assessment will serve as a tool to assess effectiveness of possible response action.
* DoD should establish an independent "third party" or multi-agency technology evaluation program for the purpose of validating cost and performance of the most promising advanced technologies for the: 1) detection, location and remediation of UXO; 2) remediation of soils and water contaminated with explosives; 3) Open Burning/Open Detonation technologies and alternatives; and 4) chemical munitions destruction technologies. This program should include:
--states, tribal governments, other regulators and key community stakeholders that have technology acceptance responsibilities should be directly involved in the protocol development, design, oversight of the validation testing and communication of findings.
--the Defense Science Board, Strategic Environmental Restoration Development Program test beds, and the Environmental Security Testing and Certification Program should serve as elements of a model framework for these advanced technology evaluations.
* DoD should continue its commitment to establishing Restoration Advisory Boards or other community-based advisory bodies at defense installations including formerly used defense sites. Finalize DoD programs to provide Independent Technical Assistance programs to the Advisory Boards that need this support.
* Continue the Black Hills Army Depot Restoration Advisory Board study to obtain second year of data on the effectiveness of this approach to stakeholder participation. Also, broaden the study to include at least one additional Restoration Advisory Board to compare data.
* Governors should adopt a resolution to support continued broad based interagency and other stakeholder collaboration on establishing a munitions regulatory framework. This framework should strive to avoid duplication, integrate appropriate existing regulations, and recognize and preserve DoD responsibilities and expertise in explosive safety and state, tribal and EPA responsibilities for environmental protection.
* DoD should seek ways to expand communications between sites that have similar UXO remediation projects. DoD Regional Environmental Offices can help manage this effort. This should include:
--working toward standardizing protocols and conducting cooperative assessments of applicable technology for site characterization and remediation.
--expanded communications between Restoration Advisory Boards which are addressing similar cleanup issues to collaborate on remedy selection.
* DoD should develop a Memorandum of Understanding with WGA or some other means to reconstitute and fund continuation of the Military Munitions Working Group for the purpose of continuing the dialogue on munitions issues by a broad-based group of stakeholders.
WORKING GROUP MEMBERS
Jim Austreng (Co-Chair)
Dept. Of Toxic Substances Control
10151 Croydon Way, #3
Sacramento, CA 95827-2106
P 916-255-3702
F 916-255-3697
John Beckum, PE
Envir. Management Compliance
126 Porter Street
Easton, PA 18042
P 215-252-6523
F same as phone
Ann Blakely
Earth Resources Corp.
1227 Marshal Farms Road
Ocoee, FL 34761
P 407-877-0877
F 407-877-3622
Kevin Brackney
Center for Hazardous Waste
Remediation Research
University of Idaho
Food Research 103
Moscow, ID 83843-1052
P 208-885-5979
F 208-885-5741
Grace Bukowski
The Rural Alliance for Military Accountability
3605 Gul Street
Reno, NV 89506
P 702-677-7001
F same as phone
Kendall Casey
Ballena Systems Corporation
5820 Stoneridge Mall Rd., Suite 205
Pleasanton, CA 94588
P 510-460-3740
F 510-460-3751
John Chestnut
US EPA Region IX
75 Hawthorn Street
San Francisco, CA 94105
P 415-744-2387
F 415-744-1917
Kim Clausen
Oglala Sioux Tribe
Natural Resouce Regulatory Agency
P.O. Box 320
Pine Ridge, SD 57770
P 605-867-5624
F 605-867-5659
William H. Dana, Project Manager
Dept. Of Environmental Quality
811 SW Sixth Avenue, 10th Floor
Portland, OR 97204
P 503-229-6530
F 503-229-5830
Jim Drake
DOD Explosive Safety Board
Hoffman Building 1, Suite 586 2461
Eisenhower Avenue
Alexandria, VA 22331-0600
P 703-325-0891
F 703-325-6227
Ray Duda
State of Utah
Department of Environmental Quality
Division of Solid & Hazardous Waste
288 North 1460 West Street
Salt Lake City, UT 84116
P 801-538-6170
F 801-538-6715
Larry E. Erickson, Director
Great Plains-Rock Mountain
Hazardous Substance Research Center
Dept. of Chemical Engineering
Kansas State University
105 Durland Hall
Manhattan, KS 66506-5102
P 913-532-4313
F 913-532-7372
Grant Ferrier
Editor Env. Business Publishing Inc.
4454 Park Blvd., Suite 306
San Diego, CA 92116
P 619-295-7685
F 619-295-5743
Dick C. Green
EG&G Idaho
P.O. Box 1624
Mail Stop 4129
Idaho Falls, ID 83415
P 208-526-2702
F 208-526-5474
Dwight Hempel
Bureau of Land Management - DOI
1849 C Street NW (1000 LS)
Washington, D.C. 20240
P 202-452-7778
F 202-452-7708
Barbara Hoditschek
Program Manager
Haz. Radioactive Materials Bureau
2044 Galisteo Street
Santa Fe, NM 87502
P 505-827-1557
F 505-827-1544
Raymond Hofferer
Walker River Paiute Tribe
Hospital Road
Reno Tahoe International
Schurz, NV 89427
P 702-773-2306
F 702-773-2585
Andrew E. Hooper, Chief (Co-Chair)
Advanced Technology Office
STEYP-TD-ATO
U.S. Army Yuma Proving Ground
Yuma, AZ 85365
P 602-328-6111
F 602-328-6283
Martin M. Edelson
Ames Labortory
Ames, Iowa 50011
P 515-294-4987
F 515-294-1230
Jerold L. Johnson
(MS 6260)
U.S. Bureau of Mines - DOI
Salt Lake City Research Center
729 Arapeen Drive
Salt Lake City, UT 84108-1283
P 801-584-4157
F 801-584-4134
Les Keffer
HQ USAF/CEW
Building 516
Bolling AFB
Washington, D.C. 20332-5000
P 703-697-3341
F 703-695-8943
Roger Kennett
Arizona DEQ
3033 North Central
Phoenix, AZ 80512
P 602-207-4179
F 602-207-4326
Dr. Teri Knight
The Nature Conservancy
1771 East Flamingo Rd., Suite 111B
Las Vegas, NV 89119
P 702-737-8744
F 702 737-5787
Eric Koglin
USEPA
National Exposure Research Laboratory
Characterization Research Division
P.O. Box 93478
Las Vegas, NV 89193-3478
P 702-798-2432
F 702-798-2261
Kevin Lombardo
Vice President
UXB International, Inc.
4800 Conference Center Dr., Suite 100
Chantilly, VA 22021
P 703-803-8904
F 703-803-9355
Sherry McCahill
Indian Head Division
Navy Ordnance Environmental
Support Office
Code OE
Indian Head, MD 20640-5035
P 301-743-6752
F 301-743-6749
Matt McDermott
South Dakota DENR
Joe Foss Building
523 East Capitol
Pierre, SD 57501-3181
P 605-773-3151
F 605-773-6035
Dave Minedew
Bureau of Fed Facilities
NV Div. of Environmental Protection
4250 Roff Drive
Reno, NV 89509
P 702-687-5872 ext. 3027
F 702-885-0868
Franklin Manke
Box 599
Edgemont, SD 57735
P 605-662-7912
F 605-662-7932
Barbara Nabors
Hazardous Mat. & Waste Mgt. Div.
CDPHE
Cherry Creek Drive South
Denver, CO 80222-1530
P 303-692-3393
F 303-759-5355
Gary Olhoeft
Dept. of Geophysics
Colorado School of Mines
1500 Illinois Street
Golden, CO 80401-1887
P 303-273-3458/3450
F 303-273-3478
Kelly Rigano
Program Manager for UXO
Detection & Remediation Program
U.S. Army Environmental Center
ATTN: SFIM-AEC-TSS (Rigano)
Aberdeen Proving Ground, MD
21010-5401
P 410-612-6868
F 410-612-6836
Drexel Smith
Wyle Laboratories
1841 Hillside Avenue
P.O. Box 160
Norco, CA 91760-0160
P 909-737-0871
F 909-735-4030/0278
Marianne Thaeler
New Mexico Sierra Club
2015 Huntington Drive
Las Cruces, NM 88011
P 505-522-3421
e-mail: FNCH43A@prodigy.com
Ross Vincent
Military Toxics Project
504 Starlite Drive
Pueblo, CO 81005
P 719-561-3117
F 719-561-1149
Rob Wilcox
U.S. Army Corps of Engineers
Huntsville Division
Mandatory Center of Expertise
Explosive Ordnance Engineering
106 Wynn Drive
Huntsville, AL 35807
P 205-895-1508
F 205-895-1178
Alternates
Jim Coppola (alt. to R. Wilcox)
Program Manager for Ordinance
& Explosives Wastes on Formerly Used Defense Sites
HQ, USACE
20 Massachusetts Ave., N.W.
Washington, DC 20314-1000
P 202-504-4992
F 202-504-5011
Richmond H. Dugger, III, Ph.D.
(alt. to K. Lombardo)
UXB International, Inc.
14800 Conference Center Dr.
Suite 100
Chantilly, VA 22021
P 703-803-8904
F 703-803-9355
Dennis Hjeresen (alt. To M. Edelson)
Los Alamos National Laboratory
Mail Stop J 3578
P.O. Box 1663
Los Alamos, NM 87545
P 505-665-7251
F 505-665-7238
Dave Larsen (alt. to R. Duda)
State of Utah
Dept. of Environmental Quality
Division of Solid/Hazardous Waste
288 N. 1460 W.
P.O. Box 144880
Salt Lake City, UT 84114-4880
P 801-538-6170
F 801-538-6715
Elveda Martinez (alt. to R. Hofferer)
Walker River Paiute Tribe
P.O. Box 220
Schurz, NV 89427
P 702-773-2306
F 702-773-2585
Lynn Olson (alt. to B. Nabors)
Hazardous Mat & Wst Mgt Division
CDPHI
4300 Cherry Creek Drive South
Denver, CO 80222-1530
P 303-692-3391
F 303-759-5355
Emma Featherman-Sam (alt to Clausen)
Director, Badlands Bombing Range Project
Oglala Sioux Tribe
P.O. Box 3010
Pine Ridge, SD 57770
P 605-867-1271
F 605-867-5044
Dennis Samuelson (alt. to D. Hempel)
NV State Office (NV-940)
Bureau of Land Management
P.O. Box 12000
Reno, NV 89520-0006
P 702-785-6619
F 702-785-6411
Lydia Sanchez (alt. to J. Drake)
DOD Explosive Safety Board
Hoffman Building 1, Suite 586
2461 Eisenhower Avenue
Alexandria, VA 22331-0600
P 703-325-0891
F 703-325-6227
Bob Dworkin(Alt to Manke)
Project director
U. S. Army Corps of Engineers
Omaha District
215 North 17th Street
Omaha, Nebraska 68102-4978
P 402-221-7716
F 402-221-783
Jay Sorensen (alt. to R. Vincent)
Sierra Club Alburquerque Group
207 San Pedro Dr., NE
Alburquerque, NM 87110
P 505-265-5506
F 505-256-0373
Lance VanderZyle (alt. to A. Hooper)
Environment and Safety Office
U.S. Army Yuma Proving Ground
Yuma, AZ 85365
P 602-328-2124
F 602-328-2652
Staff
Jim Lehr
Western Governors' Association
600 17th St., Suite 1705 South
Denver, CO 80202
P 303-623-9378
F 303-534-730
Joelle Klein
Coleman Research Corporation
301 Commercial Road
Suite B
Golden, CO 80401
P 303-278-8700
F 303-278-0789
Ginger Swartz
DOIT Project Administrator
600 17th St. Suite 1705 South
Denver, CO 80202
P 303-623-9378 or P 303-440-3527
F 303-440-3527