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.

Other Approaches

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.

REFERENCES

DOD (U.S. Department of Defense). 1998. Policy to Implement the EPA’s Military Munitions Rule. July 1. http://uxoinfo.com/blogcfc/client/enclosures/1July98mrip.pdf. Accessed February 17, 2012.

EPA (Environmental Protection Agency). 1976. Resource Conservation and Recovery Act (RCRA). 42 U.S.C. § 6901 et seq., as amended through P.L. 107–377, December 31, 2002. Available at http://epw.senate.gov/rcra.pdf. Accessed June 14, 2012.

EPA. 1984. Hazardous and Solid Waste Amendments of 1984. H.R. 2867 (98th). November 8. Available at http://www.govtrack.us/congress/bills/98/hr2867. Accessed May 31, 2012.

EPA. 1990. National Oil and Hazardous Substances Pollution Contingency Plan (“National Contingency Plan”). 40 CFR Part 300; Preamble at 55 FR 8713. March 8. Available at http://www.epa.gov/superfund/policy/remedy/sfremedy/pdfs/ncppreamble61.pdf. Accessed March 29, 2012.

EPA. 1998. Management of Remediation Waste Under RCRA. EPA 530F-98-026. October 14. Available at http://www.epa.gov/superfund/policy/remedy/pdfs/530f-98026-s.pdf. Accessed March 21, 2012.

EPA. 2002. Amendments to the Corrective Action Management Unit Rule; Final Rule. 40 CFR Parts 260, 264, and 27. January 22. Available at http://www.gpo.gov/fdsys/pkg/FR-2002-01-22/html/02-4.htm. Accessed April 11, 2012.

EPA. 2005. Handbook on the Management of Munitions Response Actions. May. Office of Solid Waste and Emergency Response. Available at http://nepis.epa.gov/Exe/ZyPURL.cgi?Dockey=P100304J.txt. Accessed March 20, 2012.

EPA. 2010. Munitions Response Guidelines. July. Office of Solid Waste and Emergency Response Available at http://www.epa.gov/fedfac/documents/docs/munitions_response_guidelines.pdf.

NRC. 2006. Review of International Technologies for Destruction of Recovered Chemical Warfare Materiel. Washington, D.C.: The National Academies Press.

U.S. Army. 2004. Recovered Chemical Warfare Materiel (RCWM) Response Process. EP 75-1-3. U.S. Army Corps of Engineers. November 30. Washington, D.C.: Headquarters, Department of the Army. Available at http://publications.usace.army.mil/publications/eng-pamphlets/EP_75-1-3/toc.htm. Accessed April 11, 2012.

U.S. Army. 2006. Military Munitions Response Process. EP 1110-1-18. U.S. Army Corp of Engineers, Engineer Pamphlet. April 3. Washington, D.C.: Headquarters, Department of the Army. Available at http://ww.hnd.usace.army.mil/oew/policy/IntGuidRegs/EP1110-1-18.pdf. Accessed March 29, 2012.

U.S. Army. 2009. Interim Guidance for Chemical Warfare Material (CWM) Responses. Memorandum from Office of the Assistant Secretary, Installations and Environment. April 1.



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