Hazwaste Permit Application for Routine UXO Disposal Sought

Commonwealth of the Northern Mariana Islands (CNMI) millions of UXO are scattered throughout the Marianas from the heavy bombing and fighting that occurred throughout the area during WWII. Over the past 6 decades, thousands of UXO like the ones shown below have been recovered and destroyed with the assistance of Navy military EOD assets. When the Munitions Rule was implemented several years ago, it required an emergency disposal permit be issued each time a UXO item was reported and subsequently disposed of. This resulted in hundreds of emergency permits being issued over the years which was time consuming and cumbersome to manage.

Over the past couple of years, the CNMI Department of Public Safety (DPS) has been working to streamline (i.e. remediate) the process associated with the collection, handling, storage, transportation and subsequent treatment (i.e. disposal) of WWII era UXO found throughout the Marianas. For starters, an organic Explosive Response Team (XRT) was formed in 2004 under the DPS to serve as lead responders in addressing WWII era UXO finds. An OB/OD site was setup at the Marpi landfill site located in Saipan to dispose of the WWII UXO that was safe to transport by the XRT.

With the response team and OB/OD site in place, the next step was to revamp the emergency permitting process. The CNMI DPS working closely with the EPA have successfully negotiated a draft Administrative Order of Consent (AOC) to cover the routine storage, treatment and disposal of UXO at the Marpi OB/OD site. As part of the AOC, DPS drafted a Remedial Action Plan (RAP) which included basic policy and guidelines for the setup, design, operation, closure and post closure activities for the Marpi OB/OD site.

The draft RAP is currently out for public comment (see download button below to view) through 24 January 2008. When the RAP is finalized, the Marpi OB/OD site will be an official RCRA permitted storage, treatment and disposal facility.