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Ordnance Holdings, Inc. (OHI) Managing UXO/MEC During Dredging Projects Presentation: Western Dredging Association Conference October 2016 Jonathan Sperka Technical Director, OHI Ordnance Holdings, Inc. (OHI) http://www.ordnanceholdings.com (443) 522-2933

Agenda Sources of UXO / MEC History Snap Shot Surf City, NJ UXO Inventory Issues / Concerns DoD s UXO Programs Policy / Guidance Overview Terminology Overview Planning Phase Staffing (UXO Positions) Field Work / Operations Munitions Management (cradle-to-grave) Other Potential Hazards

Sea Disposal Operations (early military procedures) Training Ranges / Bomb Target Areas* Ammunition loading areas / ports / harbors* Coastal Defense Batteries Wars / Conflicts Sources of UXO

Sources of UXO Historic Policy Bureau of Ordnance Publication, Ammunition Ashore (OP5) Volume 1 June 1944 Ammunition and explosives that are dangerously deteriorated or damaged, obsolete or otherwise unserviceable..are destroyed. The preferred method of disposal is by dumping at sea.

Sources of UXO Historic Policy Msg. 0400Z5Oct 1945 All toxic munitions on hand Middle Pacific are declared excess. Take immediate action to dispose of all ordnance and CWS ground and air toxics.. Dumping at sea will be coordinated with Navy. CNO Letter dated 24 April 1945 The area selected should be about 10 miles square and located outside regular steamer lanes.the dumping area must be in water over 150 fathoms deep and least 10 miles off shore. CWM Filled Munitions Being Disposed of through Deep Sea Dumping (1946)

History Snapshot Surf City, NJ 2006/7 (time frame) Long Beach Island, NJ Over 3,000 munition items brought ashore during dredging (WWII era sea disposal site) Result - extensive UXO cleanup effort (1.5 miles of beach impacted) Numerous beach closures and restrictions Expensive UXO cleanup which was preventable

UXO Inventory Issues (Example) Mullet Key WWII Era Bombing & Gunnery Range Tamp Bay, FL Graphic of Historic Range Fans Mullet Key Bombing & Gunnery Range (FUDS)

UXO Inventory Issues (Example) Tampa Bay, FL Historic Range Fans (Combined) Mullet Key Bombing & Gunnery Range (FUDS) And Fort Dade (Edgemont Key) FUDS

UXO Inventory Issues (Example) NOAA Chart 11412 Current NOAA Website No UXO hazards areas noted

Early FUDS Eligibility Old FUDS Eligibility Requirements* limited investigations to only the area within 100 yards of the shoreline also limited areas that were acts of war *ER 200-3-1 Formerly Used Defense Sites Program Policy dated 10 May 2004, Chapter 3 (3-1.5.3.8)

UXO Inventory Issues (Example) Mosquito Lagoon Target area Volusia County, FL 121 acre area (mostly water) Naval Air Training Area 1945 1946 Current part of a National Park area open for recreation In FUDS program - 2010 Site Inspection found evidence of munitions Former range areas not on NOAA charts

DOD s UXO Programs Military Munitions Response Program (MMRP) Army Air Force (USACE) FUDS (USACE) Army National Guard Navy (NAVFAC) Marines (NAVFAC) BRAC (all services) Air National Guard Operational Ranges Army Air Force Air National Guard Navy Marines Army National Guard Sea Disposal Sites Army (unofficial lead) Other Historical battle field (including Civil War sites) Former Non-Government / DoD Facilities (Private companies / States)

Terminology Overview Military Munitions Unexploded Ordnance (UXO) Discarded Military Munitions Munitions and Explosives of Concern (MEC) Contaminated Facilities Explosive Soil

Terminology Overview DMM Military munitions that have been abandoned without proper disposal or removed from storage in a military magazine or other storage area for the purpose of disposal. The term does not include unexploded ordnance, military munitions that are being held for future use or planned disposal, or military munitions that have been properly disposed of consistent with applicable environmental laws and regulations. Signs of DMM: Unfuzed munitions Un-scared rotating band Intact safeties (e.g., arming wires, pins)

Munitions Related Items (MPPEH)

Policy and Guidance Overview NAVSEA Ordnance Pamphlet (OP) 5 Volume 1, Ammunitions and Explosives Safety Ashore; (NAVSEA), July 2011 (Navy only) DoD Manual 6055.9-M, DoD Ammunition and Explosives Safety Standards; (DDESB), March 2012 EP 385-1-95a, Basic Safety Concepts and Considerations for Ordnance and Explosives Operations; (USACE), March 2007 EM 385-1-1, Safety and Health Requirements Manual, (USACE) EM 385-1-97, Explosives Safety and Health Requirements Manual Other USACE Guidance (various) Explosives Safety Submission (ESS)* (not required at all sites) * ESS contains site specific guidelines that MUST BE FOLLOWED

Explosive Safety Submission Not Required at all dredging sites Navy dredging sites - most likely required USACE - use of probability model low probability sites ESS not required Lengthy approval process (60-90 days) USACE District MMCX USATCES DDESB NAVFAC NOSSA DDESB ESS MUST BE FOLLOWED (non-negotiable) Amendments require written approval (process varies by Service)

EZ Table (From ESS) MGFD Munition Item HFD (Ft) MGFD (Ft) K24 (Ft) K18 (Ft) Primary 20 mm HEI M97 66 651 6 5 Cont No 1 37mm HE M63 1,044 144 11 8 Cont No 2 3-inch Stokes 1,379 423 31 23 Hazard Fragmentation Distance (HFD) establishes working exclusion zone (EZ) MGFD Munition with the greatest fragmentation distance ESS may require armoring of equipment (plexiglass) per DDESB TP -16 requirements Finding an item larger than your contingencies requires work shutdown and ESS amendment

EZ Image Multiple

Pending UXO/MEC Dredging Policy MEC Construction Support (USACE) Draft language issued in many contracts now (primarily East Coast) MEC Work Plan Worker Training Screening devices (on dredge intake and MEC basket) Official promulgation pending (likely integrated with EM 385-1-1 or EM 385-1-97) USACE Engineer Construction Bulletin Recommending UXO contractor support for all dredging contracts USACE / OESS shifting over to a QA role

Staffing (UXO Positions) DDESB Technical Paper 18 (Personnel Qualifications) Position Description Minimum Years Experience Necessary Special Requirements UXO Technician I 0 Successful completion of an approved course UXO Technician II N/A 3 years Prior military EOD Experience in UXO UXO Technician III 6 years 8 years remediation/range clearance Prior military EOD Plus documented supervisory experience/training Senior UXO Supervisor 10 years Experienced in all aspects of UXO operations. Five years experience in supervisory positions UXO QC Specialist 8 years Experienced in all aspects of UXO operations. Documented QC training/experience UXO Safety Officer 8 years Experienced in all aspects of UXO operations. Documented Safety Training/experience

Support Staff Can dredge personnel (i.e., non-uxo qualified) support UXO operations? Yes with restrictions and limitations DDESB TP -18 allows for UXO Sweep Personnel (basically laborers): must be given site-specific safety and explosives recognition training not allowed physical contact with munitions and/or explosive materials escorted by a UXO Technician when in EZ must be supervised by a UXO Technician III (or above) at all times

Standard Operating Procedures Maintaining EZs MEC Screen and Screening Basket Clearing Field Operations (what to plan for) MEC Reponses (Emergency and Non- Emergency) MPPEH Processing Other Hazards

SOP Exclusion Zone (EZ) Established by the ESS Access to EZ needs to be monitored Only essential personnel and authorized visitors allowed in EZ Visitors are escorted by UXO technician while in EZ and intrusive operations cease K18 distance usually requires double hearing protection K24 distance shielding requirements (if needed by ESS)* * Navy sites likely required, USACE probability driven

Field Operations What to Plan For UXO Team (quals, positions, responsibilities) UXO Responses Routine finds vs. Emergency response (what defines an emergency, who responds, how) Plan for the What-If s UXO found on dredge (at sea, at off-load area) UXO that is determined un-safe to move Can we store MEC / UXO (refer to ESS)? How much MPPEH can we store on-site (refer to ESS)? CWM Emergency response (EOD)

MEC Responses Emergency responses usually conducted by active duty Explosive Ordnance Disposal (EOD) personnel follow established protocol in contacting EOD EOD typically handles any underwater explosives issues UXO Contractor can handle non-emergency responses UXO contractors are limited in authority to: Transport UXO (only on short distances on-site) Controlled detonation (not allowed to render safe UXO) Constrained by the ESS / ATF / DOT / DOD policy 24-hour guard required on all MEC item(s) found until disposal is carried out (magazine exemption if allowed)

MPPEH / MD Processing Requires 100% inspection by two authorized individuals Explosive condition must be documented (MDEH / MDAS) 100% chain of custody Material stored in locked containers (to prevent comingling) Properly dispose of MDAS through qualified recycler (get destruction paperwork) Properly dispose (detonate) MDEH

Takeaways NOAA charts not accurate (from a UXO perspective) Develop detailed plans Work and safety plan addendums for UXO Develop contingencies (plan for the what if s ) Define response protocols (emergency vs. routine) Line up shielding (plexiglass supplier) If you find one UXO chances are good there are more Never mix munitions debris with cultural debris even inert munitions scrap needs to be processed DO NOT deviate from the ESS Prepare for the worst, hope for the best

OHI Contacts Jonathan Sperka Technical Director 443-522-2933 (O) 410-961-0364 (C) jsperka@ordnanceholdings.com Jenna Coven Perman Client Relations Manager 443-857-7474 (C) jenna@ordnanceholdings.com Ordnance Holdings, Inc. (OHI) http://www.ordnanceholdings.com (443) 522-2933