Attachment_Q14_AmendESS_FINAL-Clean_V6_05102023_Redacted.pdf
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- Solicitation number
- N4008024R2227
About this file
This document is an Explosives Safety Submission (ESS) related to a federal contract opportunity for renovations to Buildings 28, 154, and 164, as well as repairs to the water utility system, at the Naval Support Facility Indian Head in Maryland.
The key details are:
- The scope includes construction support for potentially contaminated drain lines and repair of the water utility system within the IR 24 site area. The types of munitions and explosives of concern (MEC) and material potentially presenting an explosive hazard (MPPEH) expected are primarily residual nitrocellulose contamination in abandoned drain lines.
- The primary munition with the greatest fragmentation distance (MGFD) is estimated to be 0.5 pounds of nitrocellulose in a 6-inch pipe, with a contingency MGFD of 2.0 pounds. Exclusion zones and safety protocols are detailed for the various response actions.
- The document outlines the quality control and quality assurance processes, technical support requirements, environmental and cultural considerations, and residual risk management for the munitions response activities during the construction projects.
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Explosives Safety Submission (ESS) Building 28, 154, ,164 Renovations, and
Water System Repair Naval Support Facility Indian Head
Prepared for:
Naval Ordnance Safety and Security Activity (NOSSA)
3817 Strauss Avenue, Suite 108 Indian Head, MD 20640-5151
Final Version 6
April 2023
TABLE OF CONTENTS
Page Table Of Contents ............................................................................................................... ii List Of Tables ..................................................................................................................... v List Of Figures .................................................................................................................... v List of Acronyms ............................................................................................................... vi
1. BACKGROUND
1.1 Navy Project Manager
1.2 Site Identifier and Description
1.3 Regional Map
1.4 Scope of Munitions Response
1.5 History of Munitions Use
1.6 Previous Studies of Extent of Munitions and Explosives of Concern
(MEC) and/or Material Potentially Presenting an Explosive Hazard (MPPEH) Contamination
1.7 Justification for No Further Action (NFA) Decision
2. PROJECT DATES
3. TYPES OF MEC AND/OR MPPEH
3.1 Types and Quantities of MEC and/or MPPEH
3.2 Munition with the Greatest Fragmentation Distance (MGFD)
3.2.1 Multiple Primary MGFD
3.2.2 Quantities of MEC/MPPEH
3.2.3 Contingency MGFD
3.2.4 Fragmentation Distance Sources
3.2.5 Primary and Contingency MGFDs
3.2.6 Additional MRSs
3.2.7 MEC/MPPEH Contingencies
3.2.8 Explosively Contaminated Piping
3.3 Maximum Credible Event (MCE)
3.4 Explosively-contaminated Buildings
4. MEC AND/OR MPPEH MIGRATION
5. DETECTION AND POSITIONING TECHNOLOGIES
5.1 Detection and Positioning Technologies
5.2 Detection Equipment, Method, and Standards
5.2.1 Performance Standards
5.2.2 Munitions Response Quality Assessment
5.2.3 Use of Analog Systems
5.2.4 Site-Specific Conditions
5.2.5 Use of Detection Technologies
5.2.6 Compliance with HERO Program
5.3 Positioning System, Method, and Standards
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5.4 Equipment Checkout
5.5 Data Collection and Storage
6. RESPONSE ACTIONS
6.1 Response Techniques
6.1.1 Vegetation Reduction
6.1.2 Mechanized Operations
6.1.3 Engineering Controls
6.1.4 Intrusive Investigation
6.1.5 MEC/MPPEH Hazard Classification and Disposition
6.1.6 Munitions Handling Equipment
6.1.7 Contingencies
6.2 Exclusion Zones
6.2.1 EZs
6.2.2 Underwater EZs
6.2.3 Operations to be Conducted
6.2.4 Hearing Protection
6.2.5 Encumbering PESs
6.2.6 Control of EZs
6.2.7 Waterway Controls
6.2.8 Access Protocol
6.2.9 Exclusion Zone Access Request Protocol
6.3 MEC and/or MPPEH Hazard Classification, Movement, Transportation, and Storage
6.3.1 Hazard Classification
6.3.2 Movement
6.3.3 Transportation
6.3.4 Storage Requirements
6.3.5 Storage Methods and Locations
6.3.6 Collection Points
6.4 MEC and/or MPPEH Disposition Processes
6.4.1 MEC/MDEH Disposition
6.4.2 MPPEH Disposition
6.5 Explosively-Contaminated Soil
6.6 Contaminated Buildings
6.6.1 Excavation Oversight
6.6.2 Buried Drain Lines
6.7 Operational Risk Management
7. QUALITY CONTROL (QC) AND QUALITY ASSURANCE (QA)
7.1 QC/QA Program
7.1.1 QC/QA Program Complexity
7.2 QC Implementation
TABLE OF CONTENTS- (Continued)
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7.2.1 Instrument Verification Strip (IVS)
7.2.2 Excavated Soil
7.3 QA Implementation
7.3.1 QA Inspections
7.3.2 Advanced Geophysical Classification
7.3.3 Excavated Soil
8. TECHNICAL SUPPORT
8.1 Explosive Safety Officer
8.2 Physical Security
8.3 UXO Contractor
8.3.1 Munitions Response Training
8.3.2 Geophysical Training
8.3.3 Diver Training
8.3.4 UXO Contractor Training
8.4 EOD
9. ENVIRONMENTAL, ECOLOGICAL, CULTURAL AND/OR OTHER CONSIDERATIONS
9.1 Regulatory Statute, Phase, and Oversight
9.2 Environmental, Ecological, Cultural, and/or other considerations
9.3 Non-Explosive Soil
10. RESIDUAL RISK MANAGEMENT
10.1 Land Use Controls
10.2 Long-Term Management
11. SAFETY EDUCATION PROGRAM
12. STAKEHOLDER INVOLVEMENT
13. REFERENCES
Appendix A: SUPPORTING EXPLOSIVES SAFETY DATA [NOT APPLICABLE]
Appendix B: ESQD MAPS
Appendix C: SIGNATURE PAGE (Completed Electronically in WebESS)
TABLE OF CONTENTS- (Continued)
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Page
Table 3-1. Primary and Contingency MGFDs
Table 6-1. Project Exclusion Zones
Table 6-2. Controlling Exclusion Zones
Table 6-3. Hazard Analysis Matrix
LIST OF FIGURES
Page
Figure 1-1. Regional Map Showing NSFIH
Figure 1-2. Munitions Response Site Boundary
Figure 1-3. Piping Layout in IR-24 Site Area
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LIST OF TABLES
Figure 1-4. Water Line Profile
LIST OF ACRONYMS
AAR After-Action Report AGM Above ground magazine BEM Buried Explosion Module CBR-D Chemical, Biological, and Radiological Defense Division C/D Class/Division CRTDA Caffee Road Thermal Decontamination Area DDESB Department of Defense Explosives Safety Board DFOW Definable Feature Of Work DLA Defense Logistics Agency DoD Department of Defense DR Determination Request DSN Defense Switched Network EA Environmental Assessment ECPs Entry control points EHW Explosive hazardous waste EOD Explosive Ordnance Disposal EOL Explosives operating location EPA Environmental Protection Agency ESQD Explosive safety quantity-distance ESS Explosives Safety Submission EZs Exclusion zones Ft Feet GPR Ground Penetrating Radar HAZWOPER Hazardous waste operations and emergency response HERO Hazards of Electromagnetic Radiation to Ordnance HFD Hazardous Fragmentation Distance IAW In accordance with IHD Indian Head Division IHIRT Indian Head Installation Restoration Team IR Installation Restoration IVS Instrument Verification Strip IWP Industrial Waste Processor Lb. Pound LOD Limit of disturbance MCE Maximum Credible Event MCO Major Combat Operations MDAS Material documented as safe MDE Maryland Department of the Environment MDEH Material documented as an explosive hazard MEC Munitions and Explosives of Concern MFD-H Maximum Fragmentation Distance MGFD Munition with the Greatest Fragmentation Distance MHE Munitions Handling Equipment MHT Maryland Historical Trust MOA Memorandum of Agreement
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MPPEH Material potentially presenting an explosive hazard MRS Munition Response Site MSD Minimum Separation Distance NAVFAC Naval Facilities Engineering Command NAVSEA Naval Sea Systems Command NC Nitrocellulose NDW Naval District of Washington NEW Net explosive weight NFA No Further Action NOSSA Naval Ordnance Safety and Security Activity NOSSAINST Naval Ordnance Safety and Security Activity Instruction NSASP Naval Support Activity South Potomac NSF Naval Support Facility NSFIH Naval Support Facility Indian Head NSWC Naval Surface Warfare Center OB Open Burn OP Ordnance Pamphlet OPNAVINST Office of the Chief of Naval Operations Instruction ORM Operational risk management OSHA Occupational Safety and Health Administration
POC
PDO
Point of Contact Property Disposal Office
PES Potential Explosion Site PPE Personal protective equipment PTR Public Transportation Route QA Quality Assurance QAPP Quality Assurance Project Plan QASP Quality Assurance Surveillance Plan QC Quality Control SATTP Strauss Avenue Thermal Treatment Point SDS Safety Data Sheets SOPs Standard Operating Procedures SQ Square SSP Site Screening Process SUXOS Senior Unexploded Ordnance Supervisor TNT Trinitrotoluene TP Technical Paper USAESCH US Army Engineering and Support Center, Huntsville UXO Unexploded Ordnance UXOQCS Unexploded Ordnance Quality Control Specialist UXOSO Unexploded Ordnance Safety Officer WRF Work Review Form
Version 6 April 2023vii
1.4 Scope of Munitions Response
This amendment is to expand the scope of munition response to include construction support for the repair of the water utility system component within the IR 24 site.
The previous scope of this munitions response has been to provide on-site construction support for potentially contaminated drain lines that may be encountered during earth-disturbing activities associated with renovations to Buildings 28, 154, and 164 and construction of parking lots for Buildings 154 and 164. These renovations will accommodate the relocation of the mission and operations of the Chemical, Biological, and Radiological Defense Division (CBR-D) from its current location in NSF Dahlgren in Dahlgren, Virginia to
NSFIH.
Renovations to Buildings 28, 154, and 164 and the construction of a nearby parking lots are all within the footprint of IR Site 24 and will involve excavation in areas where potentially contaminated drain lines may be encountered. The approximate limit of disturbances (LODs) are as follows:
• Building 28 renovations: 3,000 square-feet (sq-ft)
• Building 154 renovations: 100,000 sq-ft
• Building 164 renovations: 36,000 sq-ft
• Building 154/164 Parking Lot: 50,000 sq-ft
• Building 164 Parking Lot: 50,000 sq-ft
Building 28 is an 830-sq-ft single story building that is currently unoccupied. Building 154 is currently a 20,000-sq-ft warehouse used for inert storage. Building 164 is a 10,900-sq-ft high-bay, brick, gable-roof warehouse with a partial second deck. The sitework design for Building 164 will include the demolition and construction of a new retaining wall that surrounds multiple sides of the structure, the construction of an outdoor equipment pad for HVAC and electrical equipment, and the construction of stormwater management systems.
Other potential earth moving activities around Buildings 28, 154, and 164 include excavations for utility upgrades (e.g., water, sewer, fire protection, electrical), perimeter drainage improvements, and grinding existing pavement and site grading for parking improvements.
Excavation depths will not exceed 12 feet below the surface. Figure 1-2 provides an aerial view of the Munitions Response Site Boundary. All proposed earth-moving activities will occur within this boundary.
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Figure 1-2. Munitions Response Site Boundary
General munition response activities during on-site construction support include oversight during excavation and renovation, assessment of explosive hazards of any drain lines that are encountered, and manual/high input mechanized operations to separate, remove and decontaminate drain line sections, as necessary.
This amendment adds the repair of water utility system (piping and system support components) within IR site #24. See work area figure 1-3 below. Work will replace damaged piping, installing 6" PVC water mains. Piping depth is typically 4’ below grade except for locations where the new waterline passes under an existing sewer main. The depth at those locations will be appoximately 9-10 feet below grade. See Figures 1-4a through 1-4f for water piping profiles.
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Figure 1-3. Water System Repair Area in IR-24 Site
Figure 1-4a. Water Line Profile
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Figure 1-4b. Water Line Profile n Figure 1-4c. Water Line Profile
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Figure 1-4d. Water Line Profile
Figure 1-4e. Water Line Profile
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Figure 1-4f. Water Line Profile
1.5 History of Munitions Use
IR Site 24 (Abandoned Drain Lines) was established due to the presence of potentially contaminated drain lines believed to be abandoned in place. It encompasses former single-base propellant manufacturing facilities that either remain inactive or were previously demolished with potentially contaminated drain lines left in place. Single-base manufacturing facilities were built in the late 1800s and early to mid-1900s, and included operations such as picking, washing, boiling, poaching, pulping, dewatering, mixing, pressing, cutting, drying, solvent recovery and reworking as well as solvent and acid storage. These historical uses of buildings within IR Site 24 indicate the potential for NC contamination, including within terra cotta drain lines (Fred C.
Hart Associates, Inc., 1983).
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Building 28 was constructed in 1929 as the powder line office and is currently unoccupied. There are no other known historical uses (Final Environmental Assessment (EA), 2019).
Building 154 was constructed in 1923 as a NC boiling house, which was part of the single-base propellant production line. Safety Department records indicate the building never had explosives limits. As of 1957, Public Works facility records list the building as inactive, and by 1961, the building was being used for inert motor storage. Later on, Building 154 housed the central laundry and has been used most recently for inert material storage. The building has recently been emptied for repurposing. NC is the only explosives constituent that may have been processed at Building 154 (Jacobs, 2018).
Building 164 was constructed in 1893 as an ether vault storehouse with a maximum capacity of 150,000 gallons. The building has also been used for recovery and distillation of ether and alcohol from production as late as 1964, as well as carbon recovery. Most recently, this building has been used for inert storage (Jacobs, 2018).
1.6 Previous Studies of Extent of Munitions and Explosives of Concern (MEC) and/or Material Potentially Presenting an Explosive Hazard (MPPEH) Contamination
In September 2004, a Site Screening Process (SSP) investigation was initiated to evaluate environmental and safety related concerns for IR Site 24. By 2007, a decision was reached between the Navy, Environmental Protection Agency (EPA) Region III, Maryland Department of the Environment (MDE), and members of the Indian Head Installation Restoration Team (IHIRT) that IR Site 24 required no further action and the necessary safety controls were already in place (Decision Document, 2007). The SSP was never completed.
In 2013, over 300 linear feet of underground river water piping was installed within IR Site 24 under an ESS Determination Request (DR). In July 2013, while excavating at a location off the corner of Building 154 closest to Building 292 (within this ESS Munition Response Site (MRS) boundary), an existing pipe was encountered that indicated the presence of explosives, presumed to be residual NC (ESS DR, 09 April 2010; ESS DR Response, 26 Apr 2010).
1.7 Justification for No Further Action (NFA) Decision
Not applicable.
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2. PROJECT DATES
The Building 154 / 164 Parking lot construction project was awarded 30 September 2020 and has a current, estimated project completion date of 31 December 2022. Earthmoving efforts for this project will proceed upon acceptance of this ESS.
The remaining projects have not been programmed for construction execution; therefore, their construction start and completion dates are currently unknown. The anticipated order of construction execution priority is as follows:
1. Building 154 Renovation
2. Building 164 Renovation
3. Building 164 Parking Lot Construction
4. Building 28 Renovation
The water system repair project was awarded on July 29, 2022. Project completion date is planned for June 2, 2025
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3. TYPES OF MEC AND/OR MPPEH
3.1 Types and Quantities of MEC and/or MPPEH
Expected MPPEH is limited to the following:
• Buried terra cotta drain lines with trace amounts of explosives residue (primarily NC).
The type of MEC likely to be present is NC since that was the main explosive produced in that area. NC may be classified as Class/Division (C/D) 1.1 or 1.3 explosive material, depending on whether it is wet. As required by Naval Sea Systems Command (NAVSEA) OP-5 paragraph 14-11.11.3.d.1, any known or suspected NC identified during the munitions response will be classified as C/D 1.1 material.
3.2 Munition with the Greatest Fragmentation Distance (MGFD)
The primary MGFD for this project is estimated to be 0.5 pound net explosive weight (NEW) of C/D 1.1 NC in a 6-inch diameter cast iron pipe. Contaminated cast iron piping is not expected to be encountered in this munitions response, but is used as a conservative model for the piping hazard. This munition was chosen based on the expected dispersion of contaminated material within drain lines, previous experience decontaminating similar facilities (generator knowledge) and the results of site inspections and preliminary decontamination actions described in Section 1.6 above.
3.2.1 Multiple Primary MGFD
Not applicable.
3.2.2 Quantities of MEC/MPPEH
Not applicable.
3.2.3 Contingency MGFD
As a conservative measure, contingency maximum credible event (MCE) #1 of 2.0 pounds of C/D 1.1 material in a pipe is proposed. This munition was chosen based on the expected dispersion of contaminated material within drain lines, previous experience decontaminating similar facilities (generator knowledge) and the results of site inspections and preliminary decontamination actions described in Section 1.6 above.
3.2.4 Fragmentation Distance Sources
The Department of Defense Explosives Safety Board (DDESB) Memo “Interim Guidance for Modeling Fragment Hazards and Determining Minimum Separation Distances During Decontamination of Explosively-Contaminated Infrastructure” dated 22 Nov 2016 (henceforth referred to as “DDESB Interim Guidance”) was used to determine minimum separation distances (MSDs) for both MGFDs.
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Alternatively, in order to avoid the costs of demobilizing and remobilizing while the ESS is being amended, an email can be sent to the NOSSA N4 personnel who reviewed the original ESS requesting that work continue at the site while the ESS is being amended. The email must provide all pertinent information on the new MGFD (and contingency MGFD, if appropriate), including required separation distances for DDESB-approved operations, and a revised map(s) showing the relevant separation distances. Buried Explosion Module (BEM) printouts for the new MGFD(s) must also be included if the BEM will be used during detonation of MEC. The amended ESS must be submitted to NOSSA via WebESS within 2 weeks of NOSSA authorization to continue operations or the authorization will expire. The change in MGFD must be documented in the AAR.
3.2.8 Explosively Contaminated Piping
See Section 3.2.4 for use of DDESB Interim Guidance.
3.3 Maximum Credible Event (MCE)
One primary MCE is proposed for this munitions response:
• Primary MCE: 5 lbs. NEW of C/D 1.1 unconfined bulk material
Primary MCE will be applied to decontamination operations if unconfined bulk material is found. This MCE will be 5 pounds NEW of C/D 1.1 material. This MCE is the maximum quantity of contamination that may be present. It is a conservative estimate based on the quantity of explosives contamination (typically, bulk propellants are considered within current munitions response policy as bulk explosives) already discovered during other similar munition responses which have been decontaminated. This type of explosives contamination that has been discovered has been unconfined and open to the atmosphere and therefore unable to contain a detonation or generate hazardous fragments. If additional explosives contamination is discovered, it is expected to also be unconfined and open to the atmosphere.
Section 6 identifies the impacts on exclusion zones (EZs) if the contingency MCE is used. Refer to Section 6.2.1 to identify the modeling approach used for each specific operation and EZ determination during this munitions response.
If while executing the project, MEC is encountered that has a greater HFD, MFD, or K328 distance than the primary MCE, the SUXOS will halt all operations and notify the Navy Project Manager. The Navy Project Manager will submit to NOSSA (N4), via WebESS, an amended ESS which reflects the new MGFD. Operations will resume only after the amended ESS is NOSSA (N54) endorsed and DDESB approved and all safeguards associated with the newly selected MGFD are in place. The change in MGFD will be documented in the AAR.
Alternatively, if circumstances warrant, an email requesting that work continue at the site while the ESS is being amended will be sent to the NOSSA N4 personnel that reviewed the original ESS. The email will provide all pertinent information regarding the new MGFD/MCE, as appropriate (and contingency MGFD/MCE, if appropriate), including required separation distances for DDESB-approved operations, and a revised map(s) showing the relevant separation distances. Buried Explosion Module (BEM) print-outs for the new MGFD(s)/MCE(s) must also be included, if the BEM will be used during detonation of MEC. The amended ESS will be
Version 6 April 202312 submitted to NOSSA via WebESS within one week of NOSSA authorization to continue operations at the site with the revised MGFD(s)/MCE(s) and protections. The change in MGFD/MCE will be documented in the AAR.
3.4 Explosively-contaminated Buildings
The explosives contamination of concern within the scope of this project includes residual contamination within drain lines, most likely in the form of NC.
Explosives contamination is not expected in the soil being excavated as the project is not located in areas of known explosives soils contamination and residual explosives contamination would be contained within abandoned drain lines. Explosives contamination could still be present if broken drain lines are encountered. Contamination, if present, is not expected to be greater than 10% by weight in the surrounding soil; however, explosives contamination in the soil will be verified if suspect or known contamination is found. If contamination is equal to or greater than 10%, the ESS will be amended. Explosives present in quantities that do not pose an explosive hazard (less than 10% by weight) will be addressed as described in Section 9.
4. MEC AND/OR MPPEH MIGRATION
MEC is limited to residual contamination within and the vicinity of abandoned drain lines. The likelihood of migration during on-site construction support is very low. This is due to the use of engineering controls and operating procedures that are intended to minimize the potential for release. Refer to Section 6 for additional details on these procedures.
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5. DETECTION AND POSITIONING TECHNOLOGIES
5.1 Detection and Positioning Technologies
Buried piping will be located and avoided to the maximum extent possible during construction activities. Typical methods of anomaly detection (i.e., magnetometers or ground penetrating radar (GPR)) will be ineffective in identifying terra cotta piping. All communication devices shall comply with NSWC IHD’s Hazards of Electromagnetic Radiation to Ordnance (HERO) policy. Naval Facilities Engineering Command (NAVFAC) used historical drawings in the development of the construction project plans and alignment of project work with the intent of avoiding buried piping in the area, and also requires utility location to be performed by the excavation contractor before any work is performed. A thorough visual inspection of the ground surface will be conducted before any operations are begun in the area of work. When potentially contaminated drain lines are encountered in the area of work, the excavation approach in Section 6.6, Contaminated Buildings, will be followed.
5.2 Detection Equipment, Method, and Standards
Buried piping will be located and avoided to the maximum extent possible during construction activities. Typical methods of anomaly detection (i.e., magnetometers or ground penetrating radar (GPR)) will be ineffective in identifying terra cotta piping.
5.2.1 Performance Standards
Not applicable.
5.2.2 Munitions Response Quality Assessment
Not applicable.
5.2.3 Use of Analog Systems
Not applicable.
5.2.4 Site-Specific Conditions
Not applicable.
5.2.5 Use of Detection Technologies
Not applicable.
5.2.6 Compliance with HERO Program
All communication devices shall comply with NSWC IHD’s HERO policy.
5.3 Positioning System, Method, and Standards
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5.4 Equipment Checkout
5.5 Data Collection and Storage
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6. RESPONSE ACTIONS
6.1 Response Techniques
As this munitions response is related to decontamination and removal of terra cotta drain lines as necessary during on-site construction support, the response techniques are detailed in Section 6.6, Contaminated Buildings.
6.1.1 Vegetation Reduction
Vegetation removal within 50 feet of the project area is handled by on-station contractor personnel in accordance with NAVSEA OP 5 firebreak requirements. Vegetation clearance teams will be escorted by UXO technician(s) to observe operations, identify any potential MEC/MPPEH items that may be encountered, and ensure site clearing and brush removal operations are conducted in ways that avoid the potential for interaction with any MEC/MPPEH items. When feasible to conduct a surface sweep prior to vegetation clearance, the UXO-qualified escort will conduct a visual surface sweep for MEC/MPPEH using search lanes no wider than five feet.
Vegetation reduction/removal will be accomplished using a combination of manually operated gas-powered tools, such as weed-eaters and/or chainsaws, and mechanical equipment such as a skid steer-mounted brush cutter/mower. Vegetation to be removed will include only what is needed to perform construction activities and will be chipped and/or spread on site. UXO technicians shall ensure that all vegetation clearance equipment operate a minimum of six inches above the ground surface to avoid contact with MPPEH. Vegetation removal will be performed using anomaly avoidance techniques. UXO technicians will ensure that the tools will not intentionally contact the ground during the vegetation removal process.
6.1.2 Mechanized Operations
As shown in Table 6-2, this project may include high-input mechanized operations.
Removal of overburden soil will be performed utilizing anomaly avoidance techniques.
Mechanized operations will not be performed within 12 inches of an anomaly. Within 12 inches of an anomaly, the excavation team will use manual excavation with hand tools until the item is identified. If NC contamination is observed, manual excavation with hand tools will be performed by UXO technician(s) .
6.1.3 Engineering Controls
Engineering controls may be employed to reduce EZs for high-input mechanized operations by covering pipe sections during separation in order to defeat hazardous fragments.
NAVSEA OP-5, Paragraph 14-11.11.3.c indicates the requirements for essential personnel are K24 and shielding. If needed, essential personnel will be located outside of K24 distance from the site of the high-input processing operation with an intervening barricade. Otherwise, essential and non-essential personnel will not be allowed within the MFD EZ. MFD EZs are determined by DDESB criteria for building components contaminated with explosives (DDESB Interim Guidance dated 22 Nov 2016). Hazardous fragments are not expected from the primary MCE
Version 6 April 202316 because the type of explosive contamination is unconfined and open to the atmosphere and therefore unable to contain a detonation or generate hazardous fragments.
6.1.4 Intrusive Investigation
As described in Section 5, typical methods of anomaly detection will be ineffective in identifying terra cotta piping. If the contractor exposes unidentified piping while performing excavation work, work will stop and the UXO contractor will determine whether the unidentified piping is potentially contaminated. If potentially contaminated, the piping will be removed/decontaminated by the UXO contractor as discussed below. If the piping can be identified as non-hazardous, the contractor will be advised to proceed with removal via normal construction methods.
Excavation to expose potentially contaminated drain lines will be achieved using heavy equipment to remove concrete/asphalt/soil above and beside the drain lines, up to approximately 12 inches from the drain lines (anomaly avoidance). Hand tools will be used to remove the final soil immediately adjacent to drain lines (manual operation). If NC contamination is observed, manual excavation with hand tools will be performed by UXO technician(s)
. Drain lines will be removed as a manual operation or mechanized operation using the approach discussed below. Exclusion zones will be applied during drain line removal operations as specified in Table 6-2. Section 6.6 continues to describe the procedures that will be followed when potentially contaminated drain lines are encountered.
6.1.5 MEC/MPPEH Hazard Classification and Disposition
All recovered MEC and/or MPPEH will be managed in accordance with NAVSEA OP-5 requirements for C/D 1.1 material unless otherwise classified by NOSSA (N85). In the event that stable, bulk explosives material is discovered; the material will be identified, evaluated as safe to move by the SUXOS and the UXOSO
, documented in writing as safe to move, collected in a Velostat® conductive bag, properly labeled with the locally approved hazardous waste sticker and identification number for tracking purposes, and hand carried to a collection point near or within the munitions response site and separated from intentional detonations by a minimum of inter-magazine distance in order to prevent propagation prior to movement to Building 328 at the end of the workday. The collection point will not hold MEC/MPPEH longer than 24 hours, unless there is the presence of a guard on site at all times to protect personnel and ensure the security of the site. Section 6.3 further describes MEC/MPPEH hazard classification, movement, transportation, and storage.
6.1.6 Munitions Handling Equipment
Operators of fork trucks, rigging equipment (e.g., slings, hoists, and winches) or other munitions handling equipment (MHE) utilized to move or handle MEC or MPPEH (such as contaminated drain lines), will meet all applicable Navy and Occupational Safety and Health Administration (OSHA) licensing, certification and training requirements, including those required by NAVSEA SW023-AH-WHM-010, NAVSEA OP 5, and the DoD-STD 6055.09- Manual.
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6.2.4 Hearing Protection
K18 distances may be used only when essential personnel wear double hearing protection which provides >9 decibel attenuation.
6.2.5 Encumbering PESs
There are no potential explosion sites (PES) with K18 arcs that encumber any part of the project area.
6.2.6 Control of EZs
EZs, as described above in Section 6.2.3, will be in place during project activities. Roads leading to the EZs will be barricaded with appropriate signage to indicate that access is prohibited. Signage will include a warning that progress beyond this point must be coordinated with a defined point of contact (POC) (site supervisor) and phone information in the event that access is required. The entry control points (ECPs) are depicted in Appendix B, Site Maps.
6.2.7 Waterway Controls
In areas where the EZs encumber portions of the Mattawoman Creek, the area will be cleared of boaters using warning signals and megaphone(s) as necessary, and during operations that generate those EZs, spotters will be placed at designated locations along the creek to signal to supervisor to halt all operations if nonessential personnel enter EZs during operations.
6.2.8 Access Protocol
While these EZs are in effect, access to these areas will be limited to personnel essential to the operation being conducted. However, under specific conditions and on a case-by-case basis, authorized visitors may be granted access to the EZ when operations are being conducted.
The UXOSO, further discussed in Section 8.3 (UXO Contractor), will be responsible for conducting an operational risk management (ORM) assessment in accordance with Office of the Chief of Naval Operations Instruction (OPNAVINST) 3500.39C prior to initiating response actions involving MEC. In addition, the UXOSO will determine the maximum number of personnel (essential personnel and authorized visitors) that can be in the EZ at one time. The ratio of UXO-qualified escorts to visitors will be determined by the UXOSO based on this site-specific operational risk analysis.
Based on the risk posed by the munitions response operation underway, the UXOSO may determine that access to the EZ is unsafe for visitors. However, every effort will be made to accommodate the authorized visitor’s needs. With concurrence of the Navy Project Manager, the UXOSO will grant EZ access to authorized visitors. Access to the site will be based upon the operational risk analysis of the scheduled MEC operations and availability of escorts, as well as a demonstrated visitor need and subsequent completion of visitor safety briefings.
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6.2.9 Exclusion Zone Access Request Protocol
Personnel requiring access to the EZ must demonstrate a legitimate need for access and obtain authorization from the Navy Project Manager and UXOSO. At a minimum, the request for authorization will include names of the individual requesting access, the identification of emergency contacts for these individuals, purpose of visit, task(s) to be performed, and rationale to support EZ access. Personnel requesting access must submit their request to the Navy Project Manager and UXOSO prior to the proposed date of the site visit. This advance notice will allow time for the UXOSO to support the visit request by assigning a qualified escort, conducting an operational risk analysis on the operations planned for the date of the site visit, and preparing a visitor site-specific safety briefing for the planned operations.
Prior to entry, all authorized visitors will receive a site-specific safety briefing describing the specific hazards and safety procedures to be followed within the EZ for operations underway that work day. Each authorized visitor will acknowledge receipt of this briefing in writing.
Authorized visitors to the EZ will be escorted at all times by a UXO-qualified person assigned to the project. Any authorized visitor that violates the established safety procedures will be immediately escorted out of the EZ and/or site for their own protection and to protect essential personnel working at the site. Any other requirements that apply, such as OSHA, will be adhered to.
All buildings within the exclusion zones will be evacuated of non-essential personnel.
Work may be scheduled on weekends so as to preclude the need to evacuate certain facilities and reduce potential conflicts with building evacuations.
6.3 MEC and/or MPPEH Hazard Classification, Movement, Transportation, and Storage
6.3.1 Hazard Classification
All recovered MEC and/or MPPEH will be managed in accordance with NAVSEA OP-5 requirements for C/D 1.1 material unless otherwise classified by NOSSA (N85).
6.3.2 Movement
In the event that stable, bulk explosives material is discovered; the material will be identified, evaluated as safe to move by the SUXOS and UXOSO
, documented in writing as safe to move, collected in a Velostat® conductive bag, properly labeled with the locally approved hazardous waste sticker and identification number for tracking purposes, and hand carried to a collection point near or within the munitions response site prior to movement to Building 328 at the end of the workday. Storage and disposal of materials will be coordinated with NSWC IHD Code M34.
In the event that potentially unstable (i.e., large, unexpected quantities or questionable stability and/or age) bulk explosives material is discovered and determined not to be safe to move by the SUXOS in consultation with the Navy Project Manager
, or a potential UXO or explosives-filled item is discovered; the
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MPPEH will be evaluated as it is generated and held in the work area as in-process material until it has been determined to be material documented as an explosive hazard (MDEH), material documented as safe (MDAS), or safe to move to a staging area or processing location for further decontamination. In-process MPPEH will be segregated within the work area and certified as MDAS or MDEH in lots prior to disposition, unless it is moved to a staging area or processing location for further processing. Refer to Section 6.4.2, MPPEH Disposition, for more detail.
6.3.3 Transportation
Although bulk explosives that require treatment will be moved by vehicle to Building 328 at the end of each work shift, these vehicles will not be traveling over public transportation routes (PTRs). Similarly, MPPEH may be moved by vehicles on-station within the restricted area and not over any public traffic routes as necessary to staging areas for storage or processing locations for further decontamination. However, these vehicles will meet all NAVSEA OP 5 requirements for explosive vehicles. Building 328 is located less than one mile west of the project area and is shown in Appendix B, Site Maps.
6.3.4 Storage Requirements
All OP 5 requirements will be followed during handling and storage of MEC/MPPEH items.
6.3.5 Storage Methods and Locations
Building 328 will be used to store recovered bulk explosives material. Building 328 is a permitted less than 1-year explosive hazardous waste (EHW) storage site used to store material awaiting treatment at the Strauss Avenue Thermal Treatment Point (SATTP). Building 328 has explosives limits of 2,000 lbs C/D 1.1 and 20,000 lbs C/D 1.3. Building 135 may be used as a staging area for MPPEH prior to final disposition. It is a sited MPPEH storage location Above Ground Magazine (AGM) used to store MPPEH awaiting evaluation of its explosives safety status prior to disposition. Building 135 has explosives limits of 1 lb C/D 1.1 and 1.3. Building 1924 may be used as a processing location for MPPEH that requires further processing prior to final disposition. It is a sited explosives operating location (EOL) used as a pre-processing facility in support of the Industrial Waste Processor (IWP). Building 1924 has explosives limits of 2 lbs C/D 1.1 and 10 lbs C/D 1.3.
Any wash water generated during the drain line decontamination and demolition process will be collected and held in the work area as in-process material until completion of the drain line decontamination/removal effort. All collected wash water will be managed and dispositioned in accordance with Section 6.4.2. The concentration of explosives residue in the wash water is not anticipated to be high enough to be considered explosive.
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Road Thermal Decontamination Area (CRTDA) prior to being recycled. The IWP and CRTDA facilities are approved by NOSSA/DDESB as a technical method for documenting MPPEH as safe, MDAS. The requirements specified in the approval, including any post-processing sampling inspection, will be implemented to assess and document the MPPEH as MDAS. Prior to entering the IWP or CRTDA, MPPEH is inspected and certified as “Safe for IWP” via the IHD Form 2271. Safe for IWP represents a locally defined level of contamination, not a NAVSEA OP-5 defined explosives safety status, which ensures items are safe to be further processed at the IWP and CRTDA per the facility permits as well as the DDESB approval of the IWP and CRTDA as technical methods to certify MPPEH as MDAS. This material is still considered MPPEH until processed at the IWP or CRTDA and assessed following processing.
Drain line sections that will be processed at the IWP or CRTDA will be accumulated in wire baskets, roll-off dumpsters or similar containers (separate from MDAS material). Each container will be certified as “Safe for IWP” once full or at the end of each work shift and sent to the IWP or CRTDA for further processing. All material that is processed at the IWP or CRTDA is turned over to the local PDO for disposition following final certification as MDAS. All metal processed at the IWP or CRTDA will be turned over to DLA via the local PDO.
Wash water generated may be contaminated, but it is not anticipated to have a high enough concentration of explosives residue to be considered explosive. The combined mixture will be sampled for analysis at a Navy approved laboratory to determine final disposition. The analysis results will be reviewed to determine the appropriate method of disposition. The wash water will be managed and dispositioned in accordance with all state and federal regulations.
An AAR will be prepared as defined in NOSSA Instruction (NOSSAINST) 8020.15E and will include a summary of any bulk explosives found and MPPEH recovered, the disposition of those materials, MDAS certificates, and certificates of destruction and/or treatment.
6.5 Explosively-Contaminated Soil
As discussed in Section 3.4, explosively contaminated soil is not anticipated.
6.6 Contaminated Buildings
The steps in the subsections below are discussed in the intended sequence; however, the operations below may be iterative or occur non-sequentially.
The following personal protective equipment (PPE) will be worn while conducting munition response actions: safety glasses, protective coveralls, gloves, and standard (non-conductive) safety shoes.
6.6.1 Excavation Oversight
Excavation for building renovations will proceed with on-site support from UXO-qualified contractor personnel. If a potentially contaminated drain line is encountered, it will be assessed and removed in accordance with Section 6.6.2 below.
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6.6.2 Buried Drain Lines
Visual observation and review of historical drawings has been used to attempt to locate buried drain lines. However, if the contractor exposes unidentified piping while performing excavation work, work will stop and the UXO contractor will determine whether the unidentified piping is potentially contaminated. If potentially contaminated, the piping will be removed/decontaminated by the UXO contractor as discussed below. If the piping can be identified as non-hazardous, the contractor will be advised to proceed with removal via normal construction methods.
Excavation to expose potentially contaminated drain lines will be achieved using heavy equipment to remove concrete/asphalt/soil above and beside the drain lines, up to approximately 12 inches from the drain lines (anomaly avoidance). In the event a contaminated pipe is discovered, during excavation to expose potentially contaminated drain lines, the excavator will need the cab to be shielded by 1.2 inches of plexi-glass, 0.93 inches of bullet resistant glass or comparable, per the “Explosives Safety Submission River Water Extension within IR Site 24”, NSFIH, dated November 2018. Hand tools will be used to remove the final soil immediately adjacent to drain lines (manual operation).
Drain lines will be removed as a manual operation or mechanized operation using the approach discussed below. Exclusion zones will be applied during drain line removal operations as specified in Table 6-2.
Separation of the drain line segments may be accomplished by one of the following methods by UXO-contractor : 1) hand tools; 2) a sling connected to a wire rope dragged by a truck-mounted winch, and/or 3) a sling connected to a wire rope dragged by heavy equipment such as a hydraulically operated forklift or other like equipment. If the segments cannot be visually inspected (e.g., drain line with some sort of blockage or bend), they will be separated remotely as a remote high-input mechanized (K24) operation. The segments will be pulled apart at the joints. A nylon sling will be placed around the pipe segment and either pulled by a wire rope connected to a truck-mounted winch or heavy equipment such as a hydraulically operated forklift or other like equipment. This equipment will be operated remotely so as to provide essential personnel K24 separation with an intervening barricade wall or shield. If the segments can be visually inspected and verified to not present an explosive hazard, the same approach will be used but the operation will be considered a manual operation. If feasible, manual hand tools may be used to disassemble segments regardless of whether the segments have or have not been inspected. In that scenario, the operation would be considered a manual operation.
Once drain line segments have been separated, subsequent handling/movement of the segments will be considered a manual operation. If no pipes or contaminated soil are encountered during excavation, then the contractor can proceed with construction normally with continued oversight by the UXO contractor .
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6.7 Operational Risk Management
An assessment of the operational risk management for munitions response activities has been performed and is included as Table 6-3, below. Table 6-3 describes the major munitions response activities to be performed, associated risks, risk assessment, and controls to be implemented during operations.
Operational risk management guidance (OPNAVINST 3500.39C) was used to evaluate the inherent risk associated with the on-site construction support during earth-disturbing activities.
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7.3 QA Implementation
NSWC IHD will supply UXO Technician IIIs qualified IAW DDESB TP-18, or equivalent, and who have completed Navy construction quality management training to perform QA duties. The UXOQCS will perform with UXO QA Manager oversight, inspections, evaluations, and audits on processes performed during construction support. The UXO QA Manager has the authority to install blind seeds as a part of the QA program. The UXO QA Manager also has the authority to stop work if operations are found to be out of compliance with contract requirements and/or specifications.
7.3.1 QA Inspections
QA inspections are necessary to verify compliance with the Quality Assurance Project Plan (QAPP) or applicable work plan and Quality Assurance Surveillance Plan (QASP).
7.3.2 Advanced Geophysical Classification
Not applicable.
7.3.3 Excavated Soil
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9. ENVIRONMENTAL, ECOLOGICAL, CULTURAL AND/OR OTHER CONSIDERATIONS
9.1 Regulatory Statute, Phase, and Oversight
The explosives response actions discussed in this ESS are not being mandated by regulation or regulators.
Although the project is not mandated by any regulatory agencies or environmental laws, the wastes generated from these actions will be managed and disposed in accordance with applicable federal and state regulations. In particular, recovered explosives will be managed and treated in accordance with RCRA.
9.2 Environmental, Ecological, Cultural, and/or other considerations
The Navy consulted with the Maryland Historical Trust (MHT) under Section 106 of the National Historic Preservation Act (NHPA) because Buildings 28, 154, and 164 are contributing resources to the Naval Powder Factory (NPF) Historic District (CH-491). Required mitigation measures are outlined in a signed Memorandum of Agreement (MOA) between the Navy and
MHT.
Sediment and erosion control plans will be developed by the Government or the contractor.
9.3 Non-Explosive Soil
Non-explosive soil (i.e., soil with concentrations that do not present an explosive hazard) will be re-used onsite in the general location of its point of origin or left in place if undisturbed, and areas will be seeded and stabilized.
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10. RESIDUAL RISK MANAGEMENT
10.1 Land Use Controls
After completion of this project, the land will remain under control of DoD. No restrictions will be placed on the site due to explosives safety concerns.
10.2 Long-Term Management
The excavation, decontamination and recovery of possible drain lines will resolve all known explosives safety issues in the area of construction for Buildings 28, 154, and 164;
however, IR Site 24 will continue to exist and be managed by the IR program.
11. SAFETY EDUCATION PROGRAM
Personnel participating in decontamination activities will receive a hazard control briefing within 30 days prior to performing the work. The hazard control briefing addresses safety and environmental concerns, required safety equipment, and personal protective equipment (PPE). Additionally, the Safety Data Sheets (SDS) for hazardous materials required during the project will be made available to all personnel.
This area will be retained under operational control of NSWC IHD. There is no public involvement in regards to this site; therefore, no public safety education programs are planned.
12. STAKEHOLDER INVOLVEMENT
Stakeholders from other departments within NSWC IHD as well as other commands in the region (NSASP, NAVFAC, EODMU12DD) are being coordinated with for this project to ensure explosives safety and environmental concerns are addressed.
Community involvement/notification will be necessary for this project as some of the project activities will generate exclusion zones that extend over the Mattawoman Creek.
Community involvement/notification will occur prior to the start of operations and during operations via operations advisories coordinated through the NSWC IHD and NSASP Public Affairs offices. While EZs are in effect, spotters will be in place along the shoreline as discussed in Sections 6.2.6, Control of EZs, and Section 8.2, Physical Security.
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13. REFERENCES
1. Ammunition and Explosives Safety Ashore (OP-5), Volume 1, Revision 7, Change 15, NAVSEA, 25 March 2020.
2. Decision Document, Site 24 – Abandoned Drain Lines Naval Support Facility, Indian Head Indian Head, Maryland, 4 April 2007
3. Department of the Navy Physical Security Instruction for Conventional Arms, Ammunition, and Explosives. OPNAVINST 5530.13C, 26 September 2003
4. Defense Explosives Safety Regulation 6055.09, Edition 1, (DESR 6055.09, Edition 1), 13 January 2019
5. Explosives Safety Submission Determination Request to Replace River Water Lines Within UXO Site 9 and Site 24, Naval Support Facility Indian Head, Maryland, 26 April
6. Explosives Safety Submission River Water Extension within IR Site 24, Naval Support Facility Indian Head, Maryland, November 2018
7. Explosives Safety Review, Oversight, and Verification of Munition Responses, NOSSAINST 8020.15E, 11 September 2020
8. Final Environmental Assessment for Relocation of Chemical, Biological, and Radiological Defense Division from NSF Dahlgren to NSF Indian Head, May 2019
9. Initial Assessment Study of Naval Ordnance Station Indian Head, Maryland, Fred C. Hart Associates, Inc., May 1983
10. Interim Guidance for Modeling Fragment Hazards and Determining Minimum Separation Distances During…
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