Monday, September 9, 2013

Little Things Mean A Lot

How much waste are we talking about actually being burned at the Open Burning Ground there next to the New River? According to BAE, they treat approximately 37,000lbs of energetic material per month in this primitive method. The Army was quick to point out at the September 5th meeting that the amount of waste sent to the OBG has dramatically decreased this year. Although Col.Ortiz was proud to point out the drop off, he was ill-served by his minders who evidently did not give him the whole picture. The Colonel did not say that anyone has made a decision to permanently curtail the use of the OBG, Instead, he was merely charting the inordinately low quantities burned at the OBG over the last few very rainy months (pun intended). The rainfall here since January and flooding of the OBG at least once since BAE took over has served to "naturally attenuate" RAAP's hazardous waste disposal by open burning without any pollution controls.

The description of the toxic waste as "energetic" might be confusing, especially if you're trying to figure out if this practice presents a threat to your health or the environment. One way to evaluate what is burned above is to look at the soil around and groundwater below the burning area. A review of the list of  permitted contaminants  in that groundwater is telling because many of the chemicals cause cancer and all are toxic,
if not hazardous. This attachment to the Class III Major Permit revision for the OBG issued by the VADEQ in September 2011, lists what is allowed. The Army assured our community on the 5th that the results of required testing for contaminant levels in the groundwater will be made available on their website soon!

One thing is for sure, the U.S. Army has long known that perchlorate is a problem in the groundwater at our Arsenal, as cited in their 2010 report on perchlorate at RAAP. In fact, it was the discovery of carbon tetrachloride and perchlorate in the GW at the OBG in 2005 that prompted more regular screenings for these particular contaminants.  From the VA DEQ permit,   " Exceedances (sic) of established background values for carbon tetrachloride and perchlorate during the Fourth Quarter 2005 monitoring event prompted the need to develop a Compliance Monitoring program for the OBG in accordance with the requirements of the Permit."  
-->Don't even get me started on what they consider "background" under this permit. OK, perchlorate was not in the soil or water before the Arsenal started dumping it there and therefore DOES NOT meet the definition to even set a "background level." They go on with this charade by assigning a background level for chromium of 110 ppb, which then gave VADEQ the latitude to set an allowable level of 112 ppb for chromium which EXCEEDS THE EPA's Maximum Contaminant Level (MCL). This is a violation of RCRA statute if anyone in Congress could be bothered to make sure that EPA is enforcing  laws they wrote on our behalf, the violations are clear and numerous.
So, why is all this blatantly immoral,unethical and likely illegal action being allowed to go on in silence except for a couple of very energetic reporters? Why indeed....

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