Remedial Action Plan (RAP) to Manage and Treat Unexploded Ordnance in the Commonwealth of the Northern Mariana Islands (CNMI)

World War II military occupation and warfare resulted in millions of pounds of unexploded munitions and explosives left on CNMI. Some of these munitions were fired but failed to detonate, while other ordnance was abandoned after the war ended. Unexploded bombs, artillery shells, grenades and bullets are still found routinely. These munitions slowly degrade into the environment and can detonate if disturbed. Explosions also disperse chemicals to air, soil, surface water, sediment, and groundwater. Although the CNMI government did not create these hazards, local agencies are remediating them to make the island safe for the residents and for future development.

The RCRA Permit/Remedial Action Plan provides a framework to address the threat of unexploded ordnance. Treatment of the waste munitions takes place at a permitted hazardous waste treatment unit, a detonation unit. CNMI has established a secure storage cave within the fenced facility area.

CNMI’s Department of Fire and Emergency Management Services operates the storage cave and detonation unit under a permit issued in 2008. A proposed permit was available for public comment from April 17, 2018, to June 4, 2018. EPA received three comment letters, discussed below. All comments supported approval of the RAP.

• Final Remedial Action Plan Permit: CNMI DFEMS Marpi Point Explosives Detonation Site (pdf) (244.65 KB, 7/13/2018)
  FINAL Commonwealth of the Northern Mariana Islands (CNMI) Department of Fire and Emergency Medical Services (DFEMS) Marpi Point Explosives Detonation Site Remedial Action Plan.
• Notice of Approval of a RCRA Remedial Action Plan Application (pdf) (65.78 KB, 7/13/2018)
  The Statement of Basis on the Final Permit Decision and Response to Comments for the Commonwealth of the Northern Mariana Islands (CNMI) RCRA Remedial Action Plan application.
• Correspondence With Permittee: USFWS Requests (pdf) (184.69 KB, 6/15/2018)
  Email correspondence with the permittee concerning ability to implement U.S. Fish and Wildlife recommendations from informal consultation.
• Comment Letter: CNMI Department of Fire and Emergency Medical Services Commissioner of Fire and EMS (pdf) (87.2 KB, 6/4/2018)
  Comment received during the public comment period from the CNMI Department of Fire and Emergency Medical Services (the permittee) Commissioner of Fire and EMS. The comment requested reduction in groundwater monitoring to once in 10 years. The commenter was in support of issuance of the permit.
• Comment Letter: CNMI Department of Fire and Emergency Medical Services Fire Captain (pdf) (87.73 KB, 5/31/2018)
  Comment received during the public comment period from the Fire Captain with the CNMI Department of Fire and Emergency Medical Services (the permittee). Comment requests reduction in groundwater monitoring to once in 10 years. The commenter was in support of issuance of the permit.
• Comment Letter: CNMI BECQ Comments on the Draft CNMI RAP (pdf) (324.16 KB, 5/30/2018)
  Comments received during the public comment period from the Northern Mariana Islands Bureau of Environmental and Coastal Quality Commissioner including: grammatical corrections, suggestions on improving coordination prior to detonation events on the island, and a request to reduce groundwater monitoring to once in 10 years. The commenter was in support of issuance of the permit.
• U.S. Fish and Wildlife Letter to U.S. EPA (pdf) (1.19 MB, 5/24/2018)
  U.S. Fish and Wildlife Service Informal Consultation on the Remedial Action Plan, Marpi Point Explosives Detonation Site, Saipan, CNMI.
• 2018 Groundwater Monitoring Data: OB/OD Facility at Marpi Point, Saipan (pdf) (3.27 MB, 5/1/2018)
  Groundwater Monitoring Report for the Unexploded Ordnance Open Burn / Open Detonate Facility, Marpi, Saipan, CNMI.
• CNMI Application (pdf) (2.51 MB, January 2018)
  Department of Fire and Emergency Management Services submitted an application for the Remedial Action Plan renewal on January 24, 2018. The application included the details on how the unit met Environmental Protection Standards.
• EPA letter to USFWS on RAP (pdf) (77.67 KB, March 2018)
  Informal consultation between USEPA and USFWS on threatened and endangered species on activities permitted in the RAP. Lists permit conditions set by USFWS to be protective of threatened and endangered species. USEPA has determined that the Federal action of a proposed permit, including the proposed permit conditions, may affect but is not likely to adversely affect threatened or endangered species or designated critical habitat.
• Saipan UXO Groundwater Sampling 2007 (pdf) (9.09 MB, November 2007)
  Groundwater monitoring wells were installed and groundwater sampling was performed in 2007. The four wells produced data to determine the conditions of the groundwater in 2007.