A DBA
Request for Public Comment	ppgjftn j
Pools Prairie Superfund Site
Neosho, Missouri	July 2002
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Proposed Corrective Action Management Unit Designation for the
Components Test Area at the Site
In April 2001, you were asked to comment on the proposed cleanup plan for the Pools Prairie
Superfund Site when a Corrective Action Management Unit (CAMU) was suggested. Some
regulations have been revised since then and we are again asking for your comments.
The new regulations call for:
1)	defining the types of wastes that can go into a CAMU (called CAMU-eligible)
2)	increased levels of design and operating standards for CAMUs
3)	establishing treatment standards for the wastes to remain in a CAMU
4)	a public review and comment period
EPA believes the requirements of the regulation are met because:
-the wastes will be confined to those existing on the Test Site
-the wastes are CAMU-eligible
-the contaminated soils are CAMU-eligible without the area having to be lined or capped
-more than one CAMU is permitted on a site and as many as two are being proposed
As part of the ongoing cleanup activities at the
Components Test Area (CTA) of the Pools
Prairie Superfund Site, the United States
Environmental Protection Agency (EPA) is
proposing to designate a portion of the CTA as
a Corrective Action Management Unit
(CAMU). A CAMU is a special unit created
under the Resource Conservation and Recovery
Act (RCRA) to facilitate the treatment, storage,
and disposal of hazardous wastes managed
while implementing a cleanup action.
In April 2001 EPA requested comments on a
proposed cleanup plan for the CTA as
described in the document entitled "Final
Engineering
Evaluation/Cost Analysis, Components Test
Area, Pools Prairie Site, Newton County,
Missouri" dated March 2001 (CTA EE/CA).
This plan called for excavation and on-site
treatment of contaminated soils in the Former
Primary Lagoon Area. After treatment, some or
all of the soils would be re-deposited in the
Former Primary Lagoon Area excavation. The
CTA EE/CA suggested the possibility of
designating a CAMU in conjunction with
implementation of the proposed action.
On January 22,2002, EPA promulgated revised
CAMU regulations which changed the
requirements for CAMUs from those in effect
when EPA requested comment on the CTA
EE/CA. The revised CAMU regulations can be
found at 67 Fed. Reg. 2962. Changes made in
the revised CAMU regulations include (1)
defining the types of waste which can be placed
in a CAMU, i.e., so called "CAMU-eligible
wastes;" (2) establishing more detailed
minimum design and operating standards for

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CAMUs in which waste will remain after
closure; (3) establishing treatment standards for
wastes placed in CAMUs; (4) requiring that the
public be given notice and a reasonable
opportunity for public comment before final
CAMU determinations are made; and (5)
establishing new requirements for CAMUs that
will only be used for storage and treatment.
In light of the revised regulations EPA is
requesting your comments specifically on the
proposed CAMU designation. Key factors in
making this proposal are as follows:
1.	The area EPA proposes to designate
meets the definition of a CAMU. Under the
new regulations, a Corrective Action
Management Unit means an area within a
facility that is used only for managing CAMU-
eligible wastes for implementing corrective
action or cleanup at the facility. The area EPA
is proposing to designate as a CAMU is shown
on the attached map, which is based on Figure
8-1 from the CTA EE/CA. This area is located
entirely on the Test Site and will only be used
for managing waste as part of cleanup activities
at the Test Site. As discussed below, EPA
believes these wastes are CAMU-eligible
wastes.
2.	The contaminated soils are CAMU-
eligible wastes. As defined in the revised
CAMU regulations, CAMU-eligible waste
means "all solid and hazardous wastes, and all
media (including ground water, surface water,
soils and sediments) and debris, that are
managed for implementing cleanup." The
wastes to be stored, treated and disposed of in
the CAMU are soils contaminated with various
volatile organic chemicals (VOCs), primarily
trichloroethylene, to be excavated from the
Former Primary Lagoon Area at the CTA. EPA
believes these contaminated soils fall within this
definition of CAMU-eligible wastes.
3. Planned waste storage, treatment and
disposal activities meet the requirements of the
new CAMU regulations. The revised
regulations establish more specific design
standards for CAMUs in which waste will
remain after closure. However, the regulations
provide that CAMUs with wastes which have
been treated so that constituent levels are at or
below remedial levels or goals are not required
to install either a liner or a cap. Such CAMUs
are required to meet minimum treatment
standards, as specified in the revised CAMU
regulations. The target treatment standard
specified in the CTA EE/CA is 1 mg/kg of total
volatile organic chemicals (VOCs), which is the
remedial goal for CTA soils. The 1 mg/kg total
VOCs is a substantially more stringent level
than the minimum treatment standards for
wastes to be placed in a CAMU, as described in
the revised CAMU regulations. Thus, EPA
believes that the contaminated soils will meet
the CAMU regulation's requirement to be re-
deposited on site without the disposal area
having to be lined or capped.
The Former Primary Lagoon Excavation Area,
which is also the area in which treated soils
would be re-deposited, and the area proposed to
be used for storage and treatment of the
excavated soils, are depicted on the attached
map. The area actually used for storage and
treatment may vary slightly from the area shown
in this figure. The revised regulations provide
for designating one or more CAMUs at a
facility. EPA is considering either designating
one CAMU, encompassing both the Former
Primary Lagoon Excavation Area and the
storage/treatment area as shown on the map, or
designating two CAMUs, one for the Former
Primary Lagoon Excavation Area and a second
CAMU for the storage/treatment area. EPA
welcomes your comments on the relative merits
of designating one CAMU or two.

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The CTA EE/CA and a copy of the new CAMU
regulations referenced above, along with other
information about the Pools Prairie Site, is a
part of the Pools Prairie Administrative Record
File. The Pools Prairie Administrative Record
File and the CTA EE/CA are available for
public review at the following locations:
Neosho Public Library
201 W. Spring
Neosho, Missouri
EPA Region 7, Docket Room
901 N. 5th Street
Kansas City, Kansas
EPA is currently asking for comments on the
proposed designation of portions of the CTA as
a CAMU. The 30-day comment period opens
July 25, 2002 and closes August 23, 2002.
Comments can be submitted in writing (post-
marked no later than August 23, 2002), to:
David Williams
EPA Region 7
Superfund Division
901 N. 5th Street
Kansas City, Kansas 66101
Comments can also be e-mailed to
williams.dave@epa.gov

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