ITRC Implementation Workshop Quality Considerations for Munitions Response Projects Bill Harmon, Michigan DEQ Guy Warren, Alaska DEC October 22, 2008 Phoenix, AZ
Overview • Estimates indicate that over 10 million acres in the United States may contain unexploded ordnance (UXO), at about 3,500 different sites (ARC 2007). • State regulators nationwide are increasingly providing oversight at munitions response (MR) projects. • Proper application of a process approach to MR should produce results of verifiable quality for defensible decision making. • Although most regulators are familiar with quality management practices for environmental cleanups, few have experience or knowledge of how these practices are applied to MR projects.
Tech-Reg Content • UXO-5 provides guidance to environmental regulators on how to systematically plan for and achieve quality results, and how to apply these concepts to processes common to an MR project. – UXO-5 emphasizes taking a whole-system approach to managing an MR to optimize quality. – Whole-system design means optimizing not just the parts, but the entire system. – Through the proper application of a process approach to plan and manage an MR project, the MR project should produce results of verifiable quality with sufficient QA and QC documentation for defensible decision making.
Tech-Reg Content (continued) • Provides a description of the individual process, the tasks that are typically performed, key factors to consider when planning each MR process, and QA/QC checks to monitor MR processes. The MR processes covered in the document are: – vegetation clearance – surface removal – geophysical prove-out – geophysical investigation • digital geophysical mapping • analog or “mag and dig” investigation – anomaly resolution – verification sampling
Steps to Achieve Impact • The quality concepts presented in this document are applicable to all U.S. DoD component programs (U.S. Army, Navy, etc.) and federal and state regulatory agencies. • Regulators are encouraged to use UXO-5 to ensure quality in MR projects. • Proper application of UXO-5 can lead to: – Cost savings – High confidence in project results – Defensible decision making
Where Tech-Reg Will Provide Impact BENEFIT TO BE RECEIVED EXPECTED USER GROUP INTENDED USE BY USERS Expedited regulatory review Tool to help evaluate MR and greater confidence in State and Federal Regulators work plans and final project finished product. Approach is documentation consistent with UFP-QAPP Cost savings, regulatory Consistent approach to approval, and greater DoD Component Services quality across projects confidence in finished product Build confidence that Inform them of quality Stakeholders consistent QA/QC procedures procedures are applied Consistent approach for Expedited regulatory review Contractors developing planning and approval document
Case Study of Tech-Reg Use Before… …After Inconsistent/varied Inconsistent/varied Project Team Project Team approach to project approach to project consults UXO-5 for consults UXO-5 for planning planning guidance guidance Regulator not Regulator not Regulator involved Regulator involved involved until late in involved until late in early in the planning early in the planning the process the process process process MR processes and MR processes and Regulator provided Regulator provided quality requirements quality requirements tools to assist in tools to assist in are not clearly stated are not clearly stated evaluating the quality evaluating the quality and understood by and understood by of the project of the project everyone involved everyone involved MR processes and MR processes and Project quality not Project quality not quality requirements quality requirements adequate to achieve adequate to achieve are clearly stated and are clearly stated and regulatory regulatory understood by understood by concurrence concurrence everyone involved everyone involved Potential re-work of Potential re-work of MR project results in MR project results in project site or lack of project site or lack of verifiable quality for verifiable quality for confidence that confidence that defensible decision defensible decision response action was response action was making making adequate to meet adequate to meet future land use future land use
Specific Implementation Target Ideas • Generally speaking, the process approach can be used on any project – UXO-5 can be used at any MR site • Relevant Conferences and Organizations: – EPA Quality Conference, October 2008 – NAOC, October 2008 – U.S. ACE Stand-down, December 17-18, 2008 (IBT) – Army Cleanup Workshop, March 2009 – UXO Forum, August 2009 – Navy Clean-up Conference – American Society for Quality (ASQ) – USAEC Tech Visits
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