Assistant Secretary of the Army (Installations and Environment)
Army Munitions Response Topics
Environmental Affairs Committee
Society of Military Engineers
J. C. King
ODASA(ESOH)
January 2009
1
Assistant Secretary of the Army (Installations and Environment)
What is the Issue?
2
Assistant Secretary of the Army (Installations and Environment)
Agenda
•
•
•
•
General Principles
Current Topics
Collaboration
Lessons Learned
3
Assistant Secretary of the Army (Installations and Environment)
General Principles
4
Assistant Secretary of the Army (Installations and Environment)
Army Obligations
• Moral obligation to protect human health and
the environment from DoD-related activities
• Legal obligation for responding to hazardous
military munitions including unexploded
ordnance (UXO), regardless of location
• Inherent obligation to sustain its mission by
protection of the environment
5
Assistant Secretary of the Army (Installations and Environment)
Philosophy
• Risk reduction drives the program
– Worst first
– Education considered quickest method of reducing risk
– Management of residual risks
• Response actions based on current, determined or reasonably
anticipated end use
• One face to the regulators and stakeholders
– Early and continuous communication with regulators and stakeholders
– Transparency of decision making process
• Munitions response activities must be integrated and designed
to minimize impact on environment, while protecting people
6
Assistant Secretary of the Army (Installations and Environment)
Current Topics
7
Assistant Secretary of the Army (Installations and Environment)
3Rs Explosives Safety Program
GOAL:
• Consistent nation-wide message
• Eliminate duplication of effort
• Rapidly respond, when information is needed
STATUS:
• Revising website to make more user friendly
• New materials developed, as necessary
8
Assistant Secretary of the Army (Installations and Environment)
3Rs Explosives Safety Program
WHAT YOU SHOULD KNOW:
• If you have a specific requirement:
– Check website
– Ask for assistance
• Current material allow adding local contact
information and inserting relevant photos
• Local development of material discouraged,
duplicates efforts and wastes resources
• DASA(ESOH) is working on ANSI compliant
9
signage for sites
Assistant Secretary of the Army (Installations and Environment)
10
Assistant Secretary of the Army (Installations and Environment)
RCWM Program
GOAL:
• Formalize lines of authority and processes for
efficiently and consistency
• Establish funding to avoid cannibalization of
other programs
STATUS:
• SA signed implementation plan 20 Sep 07
• DASA(ESOH) revising Executive Agent
(EA) responsibilities for SA approval
11
Assistant Secretary of the Army (Installations and Environment)
RCWM Program
WHAT YOU SHOULD KNOW:
• Goal: realign current EA CWM responsibilities.
– ASA(ALT):
Demilitarization of CWM stockpile
Support ASA(I&E) RCWM Program requirements for
assessment and destruction
– ASA(I&E) for RCWM program
• Policy for CWM response under development
• Roles and responsibilities to be resolved
12
Assistant Secretary of the Army (Installations and Environment)
RCWM Program
• ASA(I&E) to be EA for RWCM Program
• Direction for CWM-related responses
(e.g., explosives and munitions emergencies,
CWM, other) to be centralized to ensure
consistency and attain efficiencies
• USACE to be single executor of CWM-related
responses, exception explosives or munitions
emergencies
• CMA to support USACE and explosive and
13
munitions emergencies
Assistant Secretary of the Army (Installations and Environment)
Explosives or Munitions Emergencies
• Military Explosive Ordnance Disposal (EOD) units
respond to emergencies involving military munitions in
the public domain
• Responses limited to addressing immediate threat
• Required follow on is done as a remedial response
• EOD reports are reviewed to identify:
– Patterns
– Additional MRS
– Effectiveness of education efforts
14
Assistant Secretary of the Army (Installations and Environment)
Technology Transfer
GOAL: Break the “Catch-22” of not fielding
until technology is “proven”
STATUS: Still experiencing resistance from
managers and regulatory community
WHAT YOU SHOULD KNOW:
• Army wants to use “new” technology
• Looking for ways to “prove” technology or
reduce contractor’s risk of attempting to use
new technology
15
Assistant Secretary of the Army (Installations and Environment)
Underwater Munitions
GOAL:
• Protect the public from imminent threats
• Comply with PL 109-364, Section 314 (Sec 314)
STATUS: Sec 314’s only deadline is reporting
findings of archival research in DoD’s FY09
Environmental Programs Annual Report to
Congress
16
Assistant Secretary of the Army (Installations and Environment)
Underwater Munitions
• Removal actions only required when imminent
and substantial threat
• Sec 314’s only deadline is for report on locations
of sea disposal operations
• Sec 314’s other requirements will be addressed as
Congressional funding allow
• Industry should not view recovery of underwater
military munitions as a requirement
17
Assistant Secretary of the Army (Installations and Environment)
MRSPP QA Review
GOAL: Ensure consistency in MRSPP scoring
nation-wide
STATUS: QA Panel met four times in FY08 and
reviewed over 1,050 applications of MRSPP
• Disapproved 108 scores
• Administrative corrections to over 200 scores
– Most fixed EHE or CHE to “no known or suspected
hazard” when Tables 1 or 11 scored zero
– About 20 corrections did not change the MRS
Priority
18
Assistant Secretary of the Army (Installations and Environment)
MRSPP QA
WHAT YOU SHOULD KNOW:
• MRSPP scoring improved significantly over time
• QA Panel:
–
–
Approval is primarily based on documentation provided
Agreement is more likely when all remarks in the modules
are populated
• Common issues:
– Rationale and site inspection (SI) references not
identified in each remarks section
– Remarks and SI do not support selections made
19
Assistant Secretary of the Army (Installations and Environment)
MPPEH Policy
GOAL:
• Safely manage MPPEH in
compliance with applicable
policy and laws
• Minimize potential for future
responses to such material
STATUS:
• Reconciled with other policy and guidance
• MPPEH implementing guidance and Technical
Manual are being developed
Material Potentially
Presenting an Explosive
Hazard
Material Regulated
Material Requiring
under Environmental
Demilitarization for
Requirements
Trade Security
(e.g., Haz Waste)
Assistant Secretary of the Army (Installations and Environment)
MEC Hazard Assessment
GOAL: Provide direction to the field on use of
MEC HA
STATUS: Voluntary use of MEC HA as a tool
for comparison of response alternatives
during two year trial period is approved
WHAT YOU SHOULD KNOW:
• OGC has concerns
• DoD will resolve concerns during trial period
21
Assistant Secretary of the Army (Installations and Environment)
Collaboration
22
Assistant Secretary of the Army (Installations and Environment)
Collaboration
GOAL:
• Maximize efficiency
• Ensure compliance
• Improve protection of human health and the
environment
23
Assistant Secretary of the Army (Installations and Environment)
Collaboration
STATUS: Working with a variety of groups and
in various venues
•
•
•
•
Canadian National Defence
National Association of Ordnance Contractors
Interstate Technology & Regulatory Council
International UW Munitions Dialogue
24
Assistant Secretary of the Army (Installations and Environment)
Collaboration
WHAT YOU SHOULD KNOW:
• Adversarial efforts are counter production
• Collaboration provides for continuous
improvement and reduced uncertainty
• Need to collaborate early and often – especially
at project level
• Regulations and policy are changeable
25
Assistant Secretary of the Army (Installations and Environment)
Lessons Learned
26
Assistant Secretary of the Army (Installations and Environment)
Lessons Learned
• Need to:
–
–
–
–
–
Work collaboratively with regulatory community –
regulatory uncertainty can have significant cost and
schedule impacts
Implement, as early as possible, an aggressive,
effective explosives Safety Education Program
Determine land’s end use as early in the process as
possible – use restrictions may be necessary
Involve the local community early and continuously
Reduce the “footprint” as quickly as possible
27
Assistant Secretary of the Army (Installations and Environment)
Lessons Learned
• Must acknowledge:
– Collaboration is better approach, than an
adversarial one
– Current technology has limitations
– Funding constraints
– Need for consistent, transparent process
28
Assistant Secretary of the Army (Installations and Environment)
Contact
J. C. King, COL (Ret)
Assistant for Munitions and Chemical Matters
Office of the Deputy Assistant Secretary of the Army for
Environment, Safety and Occupational Health
jc.king@us.army.mil
29