Emplacement of a Corrective Action Management Unit, a Temporary Unit, or an Area of Contamination
A CAMU can also be considered for management of remediation waste. Using a CAMU for disposal of remediation waste can be considered a type of leave-in-place remedy, but it does not necessarily need to be in or even near an existing SWMU or disposal site. It would be established at a location where remediation waste could be consolidated and managed; this is similar to use of a landfill. However, in contrast with leave-in-place, remediation waste would be moved from the disposal units onsite to the CAMU. In addition, although the CAMU could receive munition bodies and scrap metal from the site and from the EDS or the EDTs, it would not necessarily need to include these metals. It could be used merely to manage contaminated media such as soil). In addition, in combination with designated areas of contamination, CAMUs used for storage and treatment, and possibly TUs, a cost-effective and efficient means of dealing with remediation waste that is protective of human health and the environment and that is tailored to the site in question could be developed.
On-site Treatment vs Off-site Transportation for Treatment
The DOD interim guidance (U.S. Army, 2009) clearly favors on-site treatment, but it leaves the door open for off-site transportation for treatment:
Under certain circumstances and after coordination with appropriate state, federal and DOD agencies and, when appropriate, with concurrence by Center for Disease Control’s U.S. Department of Health and Human Services (USDHHS), the DASA (ESOH) may authorize other dispositions (e.g., transport and treatment off-site, open detonation).
Off-site transportation would presumably be considered when space or other limitations prevent an onsite approach or when a military installation with EOD capabilities is a reasonable distance from the burial site. There may be circumstances in which off-site transportation for later destruction will be a good option.
In the quotation above, DOD leaves open the option of open detonation for RCWM. The DOD interim guidance goes on to say, “When open detonation is authorized, 50 USC, Section 1518 requires Congressional notification.” Clearly, open detonation would be used only in highly unusual circumstances when there is no safer way to deal with the RCWM.
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