Friday, September 20, 2013

Cloaked In Immense Power

According to the Multi-Media Inspection that EPA Region 3 performed at RAAP from May 16 -20th, 2011, the Open Burning Ground (OBG) at the Radford Army Ammunition Plant (RAAP) is violating the Clean Air Act. It appears that they are being allowed to continue to endanger the health of our community because they operate under the auspices of the U.S. Army. The EPA inspection report includes documentation of how RAAP was given permission by VADEQ to burn tons of wood contaminated with nitrocellulose to the open air without any protection or warning being provided to the children breathing downwind at Belview Elementary School, or residents living in the adjacent communities. The Army's Rob Davie  claimed that the violations found in this inspection were not serious, or they would have already prompted action by EPA. Please act on his assertion! Take a minute to contact Senators Warner & Kaine as well as Congressman Griffith to ask why there has not been an enforcement action following this 2011 inspection. 

Senator Mark Warner 202-224-2023 

Senator Tim Kaine 202-224-4024  

Congressman Morgan Griffith 202-225-3861

Despite the fact that toxins from corporate tenants of BAE are being disposed of in the two hazardous waste incinerators and the Open Burning Ground at RAAP, no one from the Army or BAE volunteered this information to those of us breathing it. Instead, BAE Systems confirmed the fact that they perform the toxic waste disposal at this Federally owned facility on September 5th, but only when asked directly. Why should we be made to pay with our health to increase the profit margins of BAE and their tenants - i.e. private corporations? How much of the average 37,000 pounds (18.5 tons) of waste BAE burns at the OBG every month, according to this document they provided, is generated by BAE's tenants?  Whose waste accounts for the source of the Chromium they have proposed to increase in the “small,” 500 pound "skid burns?" Are we breathing chromium to pad ATK's profit margins?

RAAP is a Government Owned-Corporate Operated (GOCO) Federal Facility, currently operated by BAE Systems. The Army holds the RCRA Subpart X permit detailing the open burning of 8,000 pounds of "munitions constituents" every day that the weather conditions allow. The sixteen clay-lined burning pans are 150 feet from the New River, a source of drinking water, recreation and an American Heritage River. This report from the U.S. Army Corp of Engineers in 1995  makes clear that this proximity violates the Clean Water Act (CWA) and  ought to be moved. (page 19) The Corp of Engineers note in this report that the State of Virginia fined RAAP for this violation, but VADEQ has claimed that no record of this violation exists. Worse yet, the  report could not predict that RAAP would start selling drinking water drawn from the New River to the good people living in Prices Fork/Merrimac as ATK proudly announced in this newsletter of 2003.

The special method of ignition for a significant percentage of the open burns conducted at RAAP are referred to as "skid burns."  Although no other U.S. Army facility uses diesel fuel in Open Burning, at our "for profit" Arsenal it gets the "go ahead" from VADEQ. This unique "skid burn," process involves soaking the wooden pallet and then dousing the material on top of the clay lined pan with 12.5 gallons of diesel fuel to facilitate ignition. As near as I can figure out,  “skid burns” do not provide complete combustion, which results in a slow smolder lasting four (4) hours or more. My understanding of this report, the Human Health Risk Assessment performed by CH2MHill for ATK in 2005, is that the "skid burn" method is excessively toxic and results in more dioxin and furans being released to the air we breathe than is necessary. The 2005 report proposes a "mitigation plan" to reduce the level of cancer causing emissions, but no action has been taken on this recommendation. (page 43)

The chronic inhalation, dermal and ingestion exposure from RAAP is most troubling for the children just 1.5 miles downwind of the OBG at Belview Elementary School. The permit written by Virginia DEQ and overseen by EPA Region 3, does not require any pollution control devices at the OBG nor ambient air quality monitoring. How does this failure to control or even monitor emissions comply with standards set for all Federal Facilities by the EPA? How does this  RCRA permit, as written by VADEQ, prevent a risk of imminent and substantial endangerment for the people living here? How does Michael Chertoff, Chairman of the Board for BAE Systems, justify BAE's decision to ignore the health assessment report finding that "skid burns" are more deadly for the children living here?

Unfortunately, the toxic particulate matter that goes up into the air during ignition  from these "skid burns" comes back down at receptor points on the NewRiver identified in 2005 on this map. The Safe Drinking Water Act does not require testing for many of the poisons coming out of those burns, including perchlorate, dinitrotoluene or hexavalent chromium - no one is testing anyone's drinking water for these toxins, even though we know they are being "released" into our air and water under the current permits and saturate the soil around the OBG. No one is testing despite a 2013 finding perchlorate in 100% of the 3 private drinking water wells tested in Montgomery County, which proves cross-contamination of groundwater from the Arsenal. 

Why are our elected representatives allowing the OBG's toxic assault on the people living here to continue unabated? What more do we need to know to demand NO MORE OPEN BURNING? Please send an email to ALL of our representatives in Congress today - ask WHY the OBG is being permitted to poison us for the sake of corporate profits.

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