Friday, September 13, 2013

Why NOT Burn It Down?

At the meeting hosted by the U.S. Army ~ BAE Systems on September 5th, 2013, stakeholders (the people who live with the decisions they make) learned that tons of hazardous building debris and even contaminated filter drums were given the "go ahead" for treatment at the Open Burning Ground (OBG) by the Virginia Department of Environmental Quality (VADEQ). The Radford Arsenal's rudimentary waste disposal site is a mere 150 feet from the New River, a source of drinking water and recreation. The source of these facts about the serious violations documented,  is a copy of the inspection report obtained by FOIA from EPA's Region 3 in March of 2013.  

The report was provided in a bound paper format, with select names and photos depicting violations blacked out by the DoD, which was explained in the cover letter as a security measure. The voluminous record of violations is titled:
Multi-Media Inspection Report U.S. Army Radford Army Ammunition Plant (RFAAP) of May 16th to 20th, 2011. The following direct quotes from that report appear in Attachment RCRA-C-1: Virginia Department of Environmental Quality Approval for Open Burning at Contaminated Scrap Burn Area, [pages noted]

 "There is an estimated 200 tons of wood from the building walls that will need to be burned. This wood has been exposed to many years of building nitrocellulose/nitrocotton (NC) purification...An estimated 100 tons of scrap metal required burning to decontaminate prior to recycling off-plant as scrap metal. (pg 3)

"...two pieces of equipment coming from the B-Line Project that we propose to open burn rather than run through the oven. In the poacher blender building (BLDG 2024) the rotary vacuum filter drums are too heavy to get in the oven. They were removed by a track hoe from the upper floor and will require a crane to put it on flat bed truck (sic). The oven is accessed with a fork truck horizontally through the doors. These pieces of equipment are too heavy for the fork trucks to move into and out of the oven.

RFAAP requests that the rotary vacuum filter drums be added to the list of equipment to be open burned." (pgs.1-2)

When the Army, BAE and VADEQ have been asked about how open burning hazardous waste in this manner complies with the Clean Air Act, Clean Water Act, or their RCRA permit, they assure our community that it's all safe and being done according to the law. Now, I'm not a rocket scientist but how can anyone believe that the hazardous waste disposal conducted at the OBG does not present a risk of imminent and substantial endangerment to human health and the environment? Hello, is there anybody at home in Congress to exercise some oversight here? Does the DoD dictate policy to EPA that subverts measures to protect the people living and breathing here with complete inpugnity? Does Michael Chertoff care about security for this part of the homeland?

Despite having been informed by EPA that the U.S. Army has a copy of this inspection, their spokesperson publicly accused a very patriotic citizen (me) of "mis-characterizing the report." Someone is lying here and it ain't me, folks - the report is public information. So, it would be nice, when the EPA hands down an enforcement action on this inspection ~ as the law requires ~ for the U.S. Army to issue a formal apology for the character assassination in statements made by Rob Davie, Chief of Operations for the Joint Munitions Command at RAAP.

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