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investigated. Only approved UXO personnel will perform intrusive operations. OE removal
actions will proceed in accordance with 29 CFR 1926, Subpart P.
(b) Once an OE item has been exposed, it will be inspected, identified, and transported to a
designated area for cataloging and eventual disposal. If an OE item cannot be safely moved to an
alternate location for destruction, it will be blown-in-place.
(c) If a subsurface anomaly is removed, then the excavated location will be rechecked with
a magnetometer or other ordnance detector. Upon completion of the recheck, if the location does
not produce another anomaly, then the excavated area will be backfilled. If an OE item is
recovered from the area, the location will be marked and the item disposed of in accordance with
approved project procedures.
(d) Evacuations are sometimes necessary when conducting intrusive investigations to
minimize the risk of the operation. An exclusion zone distance is calculated to ensure that all
non-essential personnel are outside of that distance during the conduct of the excavation. The
exclusion zone distance may be reduced by implementing engineering controls. The use of
engineering controls is discussed in Chapter 21.
(e) There are several other considerations which must be accounted for during the intrusive
investigation, including: explosives storage, engineering controls, exclusion zone management,
disposal and transportation of OE, and quality assurance. These topics are discussed in detail in
later chapters of this pamphlet.
9-5. Institutional Analysis.
a. Purpose. An institutional analysis should be conducted to show what opportunities
exist to implement an institutional control program at a specific site. The institutional analysis
also identifies the existence of any local, state, federal, or private agencies that may be available
to assist in the implementation or maintenance of the institutional controls program. An
institutional analysis is necessary in order to evaluate whether institutional controls are viable at a
particular site as a stand-alone response action or as a supplement to other cleanup activities.
The institutional analysis will also aid in developing the most effective institutional control
program, if it is selected as the response alternative or as part of a response alternative.
b. Components.
(1) There are five elements of an institutional analysis which should be evaluated for each
local, state, federal or private agency that may be able to assist in the implementation or
monitoring of a proposed institutional controls program. These elements include:
(a) Jurisdiction of the agency.
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