The U.S. Army made some surprising assertions at the meeting last night. One was that the waste being "treated" in the two hazardous waste incinerators is not "hazardous waste." The second was that if the EPA inspection of 2011 found serious violations, they would have done something about it by now. On the second score, Mr.Davie is correct - the EPA ought to have taken enforcement action by now.
When I met with Senator Warner's point person on water issues in April, she was keenly interested in the EPA inspection report brought to his office along with citizen petitions requesting well testing. She did plan to follow up on the impending legal action against RAAP, although she said the citizen petitions did not warrant a reply. Clean Water Action was there to witness the entire meeting and lend support. Her response and the record of Senator Warner's "Deputy State Director" Ann Rust, sending a letter by snail mail in 2011, instructing our group never to email anyone in his office about RAAP again, is why it's so important that Senator Mark Warner decide it's time to DO something about RAAP and the lack of EPA oversight. Senator Warner is our employee - despite the fact that so many of his aids seem to have their allegiance to DoD. Call Senator Warner to ask why he has refused to look into the EPA documented violations at the Radford Army Ammunition Plant. Who is he protecting here? Whose interests does Mark Brunner represent? Call Senator Warner's office to ask that he help his constituents get the truth about violations and health risks being posed by RAAP's Open Burning Ground and send emails about it to: luke_albee@warner.senate.gov 202-224-2023. Get your concerns on the record so that Senator Warner's decision to ignore his responsibilities of oversight will be publicly available knowledge.
Then call Congressman Morgan Griffith's office and ask him to do the same thing - open an investigation into why RAAP is in violation of federal environmental laws without any action being taken by EPA. Congressman Griffith wants to hear from you - 202-225-3861. Ask both lawmakers and Senator Tim Kaine - 202-224-4024, to meet with the Spokesperson for Environmental Patriots of the New River Valley to review the EPA inspection report and take action on it. It's their job.
Friday, September 6, 2013
Thursday, September 5, 2013
There's a Price
I understand the urge to believe what you want to believe - it's only human - but when do you draw the line? When is it time to say, "What else aren't you telling us?" It's high time to question authority at the Radford Army Ammo Plant because getting the whole truth out of them is like pulling teeth.
It was like navigating a corn maze to get officials, who ostensibly work for us, to acknowledge that the Corporate Operator of the Arsenal (the "CO" part of the GOCO in Government Owned, Corporately Operated ~ a cozy pre-WWII arrangement) i.e. BAE Systems is paid to dispose of tenants' hazardous waste. That would be our tax dollars there, folks -as in the Federal Government is paying for RAAP's numerous and expensive permits, upgrades, maintenance.....but BAE Systems gets to make money off of tenants by offering free waste disposal! Great deal if you can get it, huh?
Who really pays for the free hazardous waste disposal at the Radford Army Ammunition Plant? We do. We pay with the air the breathe, the water that gives life to this valley, the soil they befoul with lead and perchlorate and explosive wastes galore. We pay and BAE makes huge corporate profits. We pay and ATK gets to dispose of their waste as part of the deal. We pay for their waste disposal and nobody even bothers to tell us this is what we breathe here? Are you kidding me?
What is being done at the Radford Army Ammunition Plant's Open Burning Ground is truly obscene, folks and the whole story is going to get a lot uglier as the truth comes to light.
Who profits? BAE Systems, the British company that the Department of Justice found guilty in 2010 of defrauding the U.S. government under the Foreign Corrupt Policies Act by violating the Arms Export Control Act. The record-setting fine of $400 million was imposed just one year before BAE Systems was awarded the contract to operate the Radford Army Ammunition Plant.
Of course, it couldn't have hurt to have Michael Chertoff on BAE's Board of Directors when that guilty plea was made by BAE. His promotion to Chairman of the Board in 2012 put him in a position to "usher through" the corporate interests of one of Britain's largest defense contractors in DC.
Tonight, we were told the two hazardous waste incinerators HWI at RAAP aren't actually for hazardous waste. Are they seriously claiming what is put in the incinerators is not hazardous waste, really?
It was like navigating a corn maze to get officials, who ostensibly work for us, to acknowledge that the Corporate Operator of the Arsenal (the "CO" part of the GOCO in Government Owned, Corporately Operated ~ a cozy pre-WWII arrangement) i.e. BAE Systems is paid to dispose of tenants' hazardous waste. That would be our tax dollars there, folks -as in the Federal Government is paying for RAAP's numerous and expensive permits, upgrades, maintenance.....but BAE Systems gets to make money off of tenants by offering free waste disposal! Great deal if you can get it, huh?
Who really pays for the free hazardous waste disposal at the Radford Army Ammunition Plant? We do. We pay with the air the breathe, the water that gives life to this valley, the soil they befoul with lead and perchlorate and explosive wastes galore. We pay and BAE makes huge corporate profits. We pay and ATK gets to dispose of their waste as part of the deal. We pay for their waste disposal and nobody even bothers to tell us this is what we breathe here? Are you kidding me?
What is being done at the Radford Army Ammunition Plant's Open Burning Ground is truly obscene, folks and the whole story is going to get a lot uglier as the truth comes to light.
Who profits? BAE Systems, the British company that the Department of Justice found guilty in 2010 of defrauding the U.S. government under the Foreign Corrupt Policies Act by violating the Arms Export Control Act. The record-setting fine of $400 million was imposed just one year before BAE Systems was awarded the contract to operate the Radford Army Ammunition Plant.
Of course, it couldn't have hurt to have Michael Chertoff on BAE's Board of Directors when that guilty plea was made by BAE. His promotion to Chairman of the Board in 2012 put him in a position to "usher through" the corporate interests of one of Britain's largest defense contractors in DC.
Tonight, we were told the two hazardous waste incinerators HWI at RAAP aren't actually for hazardous waste. Are they seriously claiming what is put in the incinerators is not hazardous waste, really?
How Virginia DEQ violates the Clean Air Act & RCRA Subpart X
At the direction of Congress, the EPA established guidelines in RCRA Subpart X permits to protect human health and the environment. The ability of Virginia DEQ to write the provisions of the permit for the Open Burning Ground at the Radford Army Ammunition Plant does not allow them to violate federal law, but that's exactly what they have done without any enforcement action from EPA. The hazardous nature of the debris in question means it is NOT SAFE nor appropriate for disposal by Open Burning (OB). This is one reason that Hercules Chemical recognized that building material contaminated with nitrocellulose (NC) must be disposed of very carefully. In fact, this judicial record of hazardous waste clean up at the former NC plant in New Jersey (Picatinny Arsenal) notes:
Hercules is currently in the second phase of the shut down: demolishing the buildings and disposing of the debris. There is no projected completion date for this phase since disposal of the debris is a dangerous and tedious process. Because of its nature, nitrocellulose permeates the buildings and equipment. Each piece of material and equipment must be wiped clean of nitrocellulose particles and the nitrocellulose disposed of, per New Jersey regulations. SAR 34.
The Virginia DEQ, on the other hand, gave the U.S. Army (under the corporate management of Alliant Techsystems [ATK] in 2010) the okey dokey to burn this type of extremely hazardous material at the Open Burning Ground next to the New River without any pollution control devices, air quality monitoring or even informing the community living nearby. In an email exchange dated June 3, 2010 between Frank Adams of DEQ and ATK subject: Re: B-Line Demo Project, Mr. Adams writes:
"The DEQ Air and Waste staff has discussed your proposal for open burning materials from the demolition project. We agree with your proposal, provided that only those materials identified in section 5c are burned."
The description of the materials as defined in 5c to be burned includes:
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. The building has been in "stand-by" status for many years with operations continuing to wash the building down due to the risk of nitrocellulose in the building. An estimated 100 tons of scrap metal requires burning to decontaminate prior to recycling off-plant as scrap metal.
NOTE: Rob Davie of the U.S. Army stated at the meeting last night (9.5.13) that this material was sent off-site for disposal. He said it was first "decontaminated by thermal treatment," which he clarified to mean Open Burning at the OBG next to the New River. He did not elaborate on whether the 200 tons of wood were "consumed" in this unique decontamination process or sent offsite along with the 100 tons of scrap metal. He said there is documentation of his assertion that this waste was transferred off site, which the Army will provide.
ATK goes on to reply to a question from VA DEQ about prior permission granted by their agency for the open burning of such waste:
A review of our records indicate that about 140,000 pounds were accumulated on the scarp burning during the first calendar quarter 2001 (January - March) and 165,000 pounds were accumulated on the scrap burning ground during the second calendar quarter 2001 (April - June). Records indicate that the scrap burning ground was burned once in 2001 on June 8, 2001.
{What were YOU doing that fine Friday in 2001, or the following weekend ~ floating the river, kayaking or perhaps fishing downstream on the New River?}
Further explanation as to why this hazardous waste (B-Line debris) ought to be "treated" by open burning at the OBG, a mere ~ 1 1/2 miles upwind of Belview Elementary School:
This project will generate three kinds of materials that present a safety concern that requires open burning. First, there are carbon steel tanks and piping (mostly water piping) that have been in NC service that have a rust layer in contact with NC. Our experience indicates that NC is incorporated into this rust layer as it is formed and cannot be removed by washing. The joints of pipe that are less than 9' feet long will be sent to the decon oven. The tanks and longer piping sections will require open burning. Second there are stainless steel items that have been in NC service such as long joints of pipe that are too big to go in the decon oven and cannot be adequately cleaned and inspected to be sold as scrap metal without heat decontamination. Third there is wood that has been in NC service that has sufficient cracks and NC exposure that the Safety Department requires heat decontamination before removal from the facility. In general, this will be limited to the interior wood walls and structural support for the NC service buildings. The hollow wall construction and years of operation has allowed NC to build up in the space between the metal siding and the interior wooden walls. These buildings have been kept wet weekly wet downs during the standby period. The wood will be keep (sic) wet during demolition and removal...
Even though the Virginia DEQ seems to believe they had the right to allow this egregious violation of the Clean Air Act, they do not in fact have that right. The EPA MUST follow up to the inspection of May 2011 which includes the details of this violation.
Ask Senator Mark Warner why his office has not responded to requests for a review of EPA compliance at this Federal Facility. In fact, in 2011, Senator Warner's office instructed us NOT TO SEND any more emails about RAAP to ANYONE at his office...how's that for representation of constituent interests? Call Senator Warner today to ask about this failure 202-224-2023 - talk to Luke Albee, who has a copy of that letter from Ann Rust. Ask what his office is doing to ensure compliance with all Federal regulations at RAAP.
See you at the BAE/U.S. Army meeting TONIGHT ~ Sept. 5, 6 pm sharp! 6580 Valley Center Drive 24141! I'll be the one carrying the 2 inch thick EPA inspection report.
Hercules is currently in the second phase of the shut down: demolishing the buildings and disposing of the debris. There is no projected completion date for this phase since disposal of the debris is a dangerous and tedious process. Because of its nature, nitrocellulose permeates the buildings and equipment. Each piece of material and equipment must be wiped clean of nitrocellulose particles and the nitrocellulose disposed of, per New Jersey regulations. SAR 34.
The Virginia DEQ, on the other hand, gave the U.S. Army (under the corporate management of Alliant Techsystems [ATK] in 2010) the okey dokey to burn this type of extremely hazardous material at the Open Burning Ground next to the New River without any pollution control devices, air quality monitoring or even informing the community living nearby. In an email exchange dated June 3, 2010 between Frank Adams of DEQ and ATK subject: Re: B-Line Demo Project, Mr. Adams writes:
"The DEQ Air and Waste staff has discussed your proposal for open burning materials from the demolition project. We agree with your proposal, provided that only those materials identified in section 5c are burned."
The description of the materials as defined in 5c to be burned includes:
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. The building has been in "stand-by" status for many years with operations continuing to wash the building down due to the risk of nitrocellulose in the building. An estimated 100 tons of scrap metal requires burning to decontaminate prior to recycling off-plant as scrap metal.
NOTE: Rob Davie of the U.S. Army stated at the meeting last night (9.5.13) that this material was sent off-site for disposal. He said it was first "decontaminated by thermal treatment," which he clarified to mean Open Burning at the OBG next to the New River. He did not elaborate on whether the 200 tons of wood were "consumed" in this unique decontamination process or sent offsite along with the 100 tons of scrap metal. He said there is documentation of his assertion that this waste was transferred off site, which the Army will provide.
ATK goes on to reply to a question from VA DEQ about prior permission granted by their agency for the open burning of such waste:
A review of our records indicate that about 140,000 pounds were accumulated on the scarp burning during the first calendar quarter 2001 (January - March) and 165,000 pounds were accumulated on the scrap burning ground during the second calendar quarter 2001 (April - June). Records indicate that the scrap burning ground was burned once in 2001 on June 8, 2001.
{What were YOU doing that fine Friday in 2001, or the following weekend ~ floating the river, kayaking or perhaps fishing downstream on the New River?}
Further explanation as to why this hazardous waste (B-Line debris) ought to be "treated" by open burning at the OBG, a mere ~ 1 1/2 miles upwind of Belview Elementary School:
This project will generate three kinds of materials that present a safety concern that requires open burning. First, there are carbon steel tanks and piping (mostly water piping) that have been in NC service that have a rust layer in contact with NC. Our experience indicates that NC is incorporated into this rust layer as it is formed and cannot be removed by washing. The joints of pipe that are less than 9' feet long will be sent to the decon oven. The tanks and longer piping sections will require open burning. Second there are stainless steel items that have been in NC service such as long joints of pipe that are too big to go in the decon oven and cannot be adequately cleaned and inspected to be sold as scrap metal without heat decontamination. Third there is wood that has been in NC service that has sufficient cracks and NC exposure that the Safety Department requires heat decontamination before removal from the facility. In general, this will be limited to the interior wood walls and structural support for the NC service buildings. The hollow wall construction and years of operation has allowed NC to build up in the space between the metal siding and the interior wooden walls. These buildings have been kept wet weekly wet downs during the standby period. The wood will be keep (sic) wet during demolition and removal...
Even though the Virginia DEQ seems to believe they had the right to allow this egregious violation of the Clean Air Act, they do not in fact have that right. The EPA MUST follow up to the inspection of May 2011 which includes the details of this violation.
Ask Senator Mark Warner why his office has not responded to requests for a review of EPA compliance at this Federal Facility. In fact, in 2011, Senator Warner's office instructed us NOT TO SEND any more emails about RAAP to ANYONE at his office...how's that for representation of constituent interests? Call Senator Warner today to ask about this failure 202-224-2023 - talk to Luke Albee, who has a copy of that letter from Ann Rust. Ask what his office is doing to ensure compliance with all Federal regulations at RAAP.
See you at the BAE/U.S. Army meeting TONIGHT ~ Sept. 5, 6 pm sharp! 6580 Valley Center Drive 24141! I'll be the one carrying the 2 inch thick EPA inspection report.
Disinformation or Poor Recall?
The meeting being hosted tonight by BAE Systems and the U.S. Army is reported to be a follow up to concerns from the April 23rd. meeting. The following written responses written responses were provided already:
These answers raise more questions that ought to be answered tonight.
1. Is perchlorate currently being burned at the Open Burning Ground?
2. What were the results of the perchlorate testing performed in July?
3. U.S. Army MERIT documents have noted the following perchlorate levels at RAAP:
Media Sampled
*Drinking Water --*
Three samples taken from drinking water intake points showed no presence of perchlorate. The Army also tested drinking water from raw water intake points at two drinking water plants under
the Unregulated Contaminants Monitoring Rule (UCMR). Perchlorate was not detected in any of these samples.
*Groundwater --*
> In 2005, 113 groundwater samples were collected near a solid waste management unit. Perchlorate was detected in two of the 113 samples with a high detect of 140 ppb.
> In 2007, 88 samples out of 112 detected perchlorate. The sample results ranged from
0.1 to 101.0 ppb.
*Surface Water --*
> Twenty-eight surface water samples were collected and
analyzed for perchlorate. Of the 28 samples collected, perchlorate was
detected in one sample at a concentration of 1.71 ppb.
> In 2007, all nine samples taken detected perchlorate. The sample results ranged from 0.1
to 5.7 ppb.
Appropriate Action
The Army continues to monitor perchlorate levels in groundwater and
surface water as part of the Resource Conservation and Recovery Act
(RCRA) requirements. In August 2007, a permit modification was submitted
by RFAAP to add corrective action to address groundwater and source
areas. We are in the process of working with the Department of
Environmental Quality (DEQ) on this permit modification process.
POC Information
Malcolm Garg, Army Cleanup Programs, Emergent Contaminant Issues
malcolm.garg@us.army.mil
/Created: 01-MAR-08/
/Updated: (null)/
Then, in 2010 MERIT reports:
Media Sampled and Findings
Drinking Water — Prior to 2007, three samples from drinking water intake points reported no
detection. Drinking water from raw water intake points at two drinking water plants under the
Unregulated Contaminants Monitoring Rule also reported no detection.
Groundwater —
> In 2010, 16 of 16 samples detected perchlorate from 2.8 to 143 ppb.
> In 2009, 16 of 16 samples detected perchlorate from 1.3 to 127 ppb.
> In 2008, 33 of 35 samples detected perchlorate from 0.13 to 81.9 ppb.
> In 2007, 88 of 112 samples detected perchlorate from 0.07 to101 ppb.
> Prior to 2007, 2 of 113 samples detected perchlorate with a high of 140 ppb.
Surface Water — In 2007, nine of nine samples detected perchlorate from 0.14 to 5.66 ppb.
Prior to 2007, 1 of 28 samples detected perchlorate at 1.71 ppb.
Clearly, the levels of perchlorate in groundwater is going up. This groundwater is in Karst, meaning it travels unpredictably through fissures, sinkholes, caves and underground conduits. Prior dye tracer studies at RAAP demonstrated that groundwater flow could not be tracked.
3. Why did Rob Davie of the U.S. Army tell our community on April 23, 2013 that he didn't know if perchlorate was a part of the waste stream (being burned) at the Open Burning Ground when their own records show levels of perchlorate are indisputably increasing?
Why does the U.S. Army claim in the follow up answers (linked above) that they have not tested drinking water intakes since 2004? Is Mr. Davie, Chief of Operations for the Army at the Radford Arsenal, unaware of the record of perchlorate testing or intentionally misleading the public? Mike Gangloff of the Roanoke Times reported ten years ago in 2003: (emphasis added)
"Rob
Davie, the Army's operation's chief at the Radford arsenal, said Friday that
the arsenal
had not carried out comprehensive testing that would indicate whether the plant
has a perchlorate problem. 'We
haven't sampled enough to say there's none here,' Davie said. Davie said he wasn't sure if perchlorate is
still used at the arsenal. Perchlorate
turned up in a 1999 water sample taken at an area used in the 1970s as a
disposal site for ash from the burning of waste propellant, said Jim McKenna,
who heads the arsenal's cleanup of waste left from former operations."
4. Does the U.S. Army and BAE Systems condone the dissemination of disinformation?
Why is the EPA, Virginia DEQ and DHS not scheduled to participate in this important community engagement meeting? According to the unique RCRA permit issued to RAAP in 2000, a site manager from the Superfund Division has been assigned to assist our community. Who is that person and why has our community never had anyone from EPA's Superfund division at a RAAP meeting? The only EPA site managers that have attended important community meetings have NOT been from Superfund. The current site manager is Erich Weissbart, a Virginia Tech graduate and former VA DEQ employee where in 2006 he worked in the Central Office overseeing permits including those issued to the Radford Army Ammunition Plant. He was subsequently hired by EPA Region 3 and assigned to RAAP in 2011, when the RCRA permit was coming up for renewal. Mr. Weissbart stated at an EPA community meeting on May 2, 2011 that he had "just been assigned to RAAP," and didn't know much about the facility or permit yet. He is not part of the Superfund division. This hastily called (less than seven days notice) community meeting was recorded by Tim Thornton of WVTF, the Virginia Tech Foundation owned public radio station here. Tim's report the next morning was VERY short lived and disappeared from their archive later that same day.
Curiouser and curiouser.
Wednesday, September 4, 2013
Site/Area Maps
I've been asked in the past for a map of the Arsenal. Well, it seems Google makes available it's satellite images as long as it's a "fair use." Finally an aerial view of the Main Manufacturing Area of the Radford Army Ammunition Plant - RAAP
http://www.newrivertrail.com/node/27
From this link, pan out and go North...you'll see the Arsenal occupying the area known as the Horseshoe Bend.
And here's a nifty map of where the "receiving points" on the New River for the toxic particulate matter that falls from the Open Burning Ground:
https://files.acrobat.com/preview/e8c15de1-a666-4d34-92fd-df79b100a675
http://www.newrivertrail.com/node/27
From this link, pan out and go North...you'll see the Arsenal occupying the area known as the Horseshoe Bend.
And here's a nifty map of where the "receiving points" on the New River for the toxic particulate matter that falls from the Open Burning Ground:
https://files.acrobat.com/preview/e8c15de1-a666-4d34-92fd-df79b100a675
Check out the FACEBOOK Page, Please
Well now, this is somewhat embarrassing. Seems I've been tooling along writing and posting on the Facebook page for this effort without realizing I'd left the blog twisting in the wind. If you are comfortable having a Facebook account, please visit the page - Environmental Patriots of the New River Valley to peruse the documents and other musings about the work.
AND----- BAE Systems along with the U.S. Army is hosting a meeting tomorrow night at 6 pm to discuss the virtues of the Open Burning Ground. Please show up if you can! 6580 Valley Center Drive 24141
AND----- BAE Systems along with the U.S. Army is hosting a meeting tomorrow night at 6 pm to discuss the virtues of the Open Burning Ground. Please show up if you can! 6580 Valley Center Drive 24141
Tuesday, April 23, 2013
Tonight's meeting held by BAE was a testament to the democratic process. People who care showed up and asked quesitons. Morgan Griffith and Josepth Yost had representatives present, as was a former candidate himself, Don Langrehr. Questions were posed - answers were dodged and the whole thing was covered by actual news media. It's a new day, America...we are Volunteers of America here to say, no more open buring...no way, no how!
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