The public hearing being held June 4th is a perfect example. The Virginia DEQ's notification of this hearing reaches a new low in their dirty work, which is truly saying something. There are laws dictating how the public is to be informed about and included in public hearings on permit actions that effect their community. These are laws that public employees are breaking at their own peril in addition to implicating the private contractors employed at RAAP. The people who are supposed to be notified about PUBLIC HEARINGS are called STAKEHOLDERS because they hold the stake that the Virginia DEQ is about to drive into the bodies of every child, person and animal living here around the plant. Stakeholders are US -WE THE PEOPLE who will have to live with the decisions being made about about the hazardous (as in toxic, poisonous, disease causing deadly excrement) waste created at the Radford Army Ammunition Plant (RAAP).
Recall that RAAP was constructed with considerable haste atop Karst, which provides a sort of stealth septic system for contaminants to disappear into drinking water wells near and far, as well as into the New River. The EPA has long advised pubic and private entities against locating hazardous waste production or disposal atop Karst, but one might imagine the implications of this practice were not entirely clear in 1940, when the private lands straddling the New River as it divides Pulaski from Montgomery Counties in southwestern Virginia, were bought up by the Federal government. The implications of contaminating a precious Karst aquifer are certainly documented now and have been for a long time, as noted in this scientifically rigorous article on reliable contaminant monitoring in Karst that was published in 1986. One can hope that the caves and sinkholes known to exist on this land were not a factor that either resulted in a lower buying price for farmers to sell their land to the Feds, nor a "bonus" for the private company, Hercules Chemical who hired the contractor to construct the plant with an eye towards future profits. This government-private contractor relationship, originally forged to construct and operate ammunition plants in a hurry to "ramp up"production for WWII, is known as as GO/CO or government owned/corporately operated Federal Facility. (see previous posts)
Back to the injustice at hand….Why is there a public hearing set for June 4th, 2014, at the ever-so-odd starting time of 7:45 pm, which will follow the informational part of the hearing from 7 - 7:30? This is supposedly an action relevant and important to those people in the Central Office Region as the second link shows, rather than the Blue Ridge Region where the polluter is located and actually doing the polluting. Why is information about this meeting so invisible and unreported by any media outlet here? If you know you are in VADEQ's Blue Ridge Region or use their "region filters" as suggested, you will not find out that there is an important upcoming public hearing to discuss the Virginia DEQ's plan to allow RAAP to "close out" two sites where toxic waste has stewed underground for decades. Now, why would the website where VADEQ Public hearings by are announced to the public categorize this meeting taking place under the wrong region and fail to even mention that people can come learn about the permit action from 7 - 7:30, as is duly noted on a separate web site for public meetings in Virignia? (the first link) Just another one of those peas under a shell that keeps STAKEHOLDERS from having the facts they need in order to discover the ugly, toxic truth. Well, we're onto you, VADEQ!
PLEASE COME TO THE MEETING TO LEARN ABOUT WHAT'S IN THE GROUNDWATER (GW) that MAY BE MIGRATING into a water source supplying YOUR HOME! Many of the toxins in the GW at RAAP are not tested for under the
Safe Drinking Water Act (SDWA)
including perchlorate (rocket fuel)
EQUALLY, if not more IMPORTANT,
if you have a well or drink water that may just be contaminated by the toxic wastes at RAAP, SUBMITTING WRITTEN COMMENTS to the VADEQ on this permit action GIVES YOU LEGAL STANDING IN ANY POTENTIAL LAW SUIT for damages resulting from these permits which allow for
"imminent and substantial endangerment to
human health and the environment."
RCRA statues 7002 & 7003
The poisons are not gone from the groundwater at these sites they are proposing to "close," no, far from it actually, but that's one of the "bugaboos" of EPA Region 3 having handed off some of the most contaminated sites for remediation under RAAP's Unique RCRA permit to the Commonwealth of Virginia, who has demonstrated what some would call a criminal lack of due diligence in permit writing and enforcement since the VADEQ took over.
This opinion is born out in the VADEG permit written by employee Russell McAvoy for the
Open Burning Ground on the banks of the New River which violates the Clean Air Act, Clean Water Act and the conditions of their RCRA permit (as is clear from the four-day-long Multi-Media Inspection that EPA conducted at the facility from May 16 - 20, 2011.
{{{Thanks to the work of conscientious citizens, this inspection report and all the photos therein will be available for us to easily share per the FOIA fee waiver extended to our group very soon!}}} Yes, even the open burning of "too much" chromium to our air on two separate occasions at the OBG in the last couple of years has not phased the VADEQ employees with power over our air quality. The letter of April 25, 2012 [reference RFAAP letter # 11-815-115 dated August 22, 2011 and # 12-815-27 February 17, 2012] sent to Elizabeth A. Lohman of the Virginia DEQ from Paige Holt, PhD, Environmental Manager of Alliant Techsystems (ATK), Inc. (ATK is the corporation profiting from running RAAP from 1995 until July 1st of 2012) states that "Both exceedances were caused by human error." Is that justification for their decision that there would be no public notification of this toxic assault and it never became an actual violation with associated fines or required notification to the EPA, but instead resulted in a mere warning letter from VADEQ. More background on the FUBAR situation at the OBG is in my blog post of September 9, 2013 "Little Things Mean A Lot."
So, word to the wise, watch that hand behind their backs because it ain't flowers they're bringing to your door!
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