Information flies around the internet at the speed of light. This is a presentation on the Open Burning Ground which I first gave at the Blacksburg Friends Meeting House and later to the Executive Committee of the Virginia Sierra Club in May of 2012, lays out the basics. Although I've learned a lot and added to this in just the last year, putting it up here where I can be sure to get credit for my own work seemed like a good idea.
FYI, my research into RAAP began when I took a class at Virginia Tech called "Global Environmental Issues," in 2006 and learned what a toxic mess we have in our own backyard.
Wednesday, September 11, 2013
To Protect and Defend is Their Mission
As American citizens, it seems that we ought unabashedly expect clear, complete, accurate information from the U.S. Army when they are hosting a community meeting to engage stakeholders. We have a Right to Know what is in the toxic waste being burned at our expense at Radford Army Ammunition Plant's (RAAP) Open Burning Ground (OBG). What is burned - much of it after being soaked in diesel fuel includes heavy metals like the cancer-causing CHROMIUM , and even construction debris. You might think that the U.S. Army would volunteer this information at one of two community meetings they have held this year. in the interest of trust and transparency. Sadly, they chose not to tell the people who came to learn the truth and may be under the impression that what we are forced to breathe is in support of our soldiers.
Now, it would be understandable if BAE Systems, the corporate entity operating this GOCO facility, didn't high-light this fact in their presentations on the Open Burning Ground. But the U.S. Army has a mission to protect and defend against all enemies foreign and domestic, which someone might want to tell BAE's Michael Chertoff includes all of the people living here in the New River Valley.
It is with heavy heart that I report this information about whose toxic waste is being burned at the OBG and put in the Hazardous Waste Incinerators (HWI) was only revealed in response to a direct question. Even then, BAE's spokesperson shamelessly reported that yes, the tenants do pay BAE Systems for this waste disposal, but it is done "at cost." Apparently, the cost to the human beings and other living things here is not part of BAE's calculation.
Why should we be breathing the emissions from the OBG and the two Hazardous Waste Incinerators at RAAP that are being used for the benefit of private companies and BAE corporate profits?
What's more, why can't citizen stakeholders get straight answers to direct questions from officials of our military? Please note the different lists of tenants at RAAP according to the Army's Joint Munitions Command and as reported by them here, behind door number two. Which tenants of BAE Systems are being allowed to dispose of their toxic waste to the air we breathe? What types of hazardous, toxic, energetic - basically DEADLY waste are they "treating" over there at our expense, as faithfully reported by the Right to Know Network? We have a legal right to know, how often do they burn construction debris from building demolition at the OBG? Does BAE or the U.S. Army anticipate open burning construction debris ever again?
These are not unreasonable questions and would have been submitted in writing if an agenda for the September 5th meeting had been provided. Instead, the optics of the meeting provided a setting for surprise, obfuscation, misleading visual aids and the theatrics of audience participation by microphone.
Now, it would be understandable if BAE Systems, the corporate entity operating this GOCO facility, didn't high-light this fact in their presentations on the Open Burning Ground. But the U.S. Army has a mission to protect and defend against all enemies foreign and domestic, which someone might want to tell BAE's Michael Chertoff includes all of the people living here in the New River Valley.
It is with heavy heart that I report this information about whose toxic waste is being burned at the OBG and put in the Hazardous Waste Incinerators (HWI) was only revealed in response to a direct question. Even then, BAE's spokesperson shamelessly reported that yes, the tenants do pay BAE Systems for this waste disposal, but it is done "at cost." Apparently, the cost to the human beings and other living things here is not part of BAE's calculation.
Why should we be breathing the emissions from the OBG and the two Hazardous Waste Incinerators at RAAP that are being used for the benefit of private companies and BAE corporate profits?
What's more, why can't citizen stakeholders get straight answers to direct questions from officials of our military? Please note the different lists of tenants at RAAP according to the Army's Joint Munitions Command and as reported by them here, behind door number two. Which tenants of BAE Systems are being allowed to dispose of their toxic waste to the air we breathe? What types of hazardous, toxic, energetic - basically DEADLY waste are they "treating" over there at our expense, as faithfully reported by the Right to Know Network? We have a legal right to know, how often do they burn construction debris from building demolition at the OBG? Does BAE or the U.S. Army anticipate open burning construction debris ever again?
These are not unreasonable questions and would have been submitted in writing if an agenda for the September 5th meeting had been provided. Instead, the optics of the meeting provided a setting for surprise, obfuscation, misleading visual aids and the theatrics of audience participation by microphone.
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....
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....
Sunday, September 8, 2013
"Skid Burns" Dirty Business for the Army & BAE Systems
I am not a scientist of any kind. I'm actually a Social Studies teacher who hasn't done much classroom teaching at all. I do hold a BA in History from ASU, where I learned a few things about Peace Education. I also managed 50 credit hours towards a masters degree at Purdue, which honed my critical thinking skills from a citizen-education perspective.
Still and all, you don't have to be a rocket scientist to realize there is something fundamentally wrong when recommendations from a major consulting firm (CH2MHill,) to the U.S. Army's contractor in the Human Health Risk Assessment (HHRA) of 2005 are ignored by regulators. The report states in no uncertain terms that the current practice of "skid burns" at the Open Burning Ground (OBG) ought to change because it is exceedingly toxic. CH2MHill makes a gentle reference to what amounts to a toxic assault from RAAP on the air of every single baby, child and adult breathing here in the New River Valley. They inform the company operating the Arsenal from 1995 through June of 2012, Alliant Techsystems (ATK) that
"The low temperature combustion following the consumption of the diesel fuel provides conditions conducive to the formation of dioxins and furans as products of incomplete combustion." page 43.
This reference to what is known as a "skid burn" comes under the section heading 7.2 Proposed Mitigated Skid Burn Pan. Granted, the contractor is looking to make a profit here by installing natural gas lines to replace the diesel fuel as a source of combustion. Never mind that this whole toxic mess sits squarely in the 100 year flood plain, less than a mile from the Pulaski Thrust Fault and atop Karst topography. The report does seem to be saying that this method of soaking each clay lined pan loaded with "munitions constituents" in 12.5 gallons of diesel fuel to facilitate combustion creates more cancer causing particulate matter (PM) than is necessary. The U.S. Army who is on site helping to operate this base has taken an oath to protect and defend the people living here, so why would the U.S. Army Environmental Command allow this to continue? Shoot, why would Senator Mark Warner turn a blind eye to the pictures in the EPA inspection report which was brought to his office for a personal meeting with his staff on April 29th, 2013?
A "skid burn" is quite a site to behold, which is one reason the OBG permit issued by the Virginia DEQ for this special disposal method dating back seventy years, notes the following security procedure:
“Warning. The burning ground of the Radford Army Ammunition Plant is about to begin burning operations. Evacuate the river area immediately.”
As officials explained on September 5th, they make sure all the college students and others who like to float down the New River, smack dab through the Main Manufacturing Area (MMA) which includes the permitted pollution outfalls in addition to the OBG, are not in danger from the - well, they don't call it an explosion, exactly. You know what they say, "who are you going to believe, me or your lying eyes? This handy Map of Peppers Ferry to Whitethorne float from the Virginia Department of Game and Inland Fisheries (DGIF), does not make mention that your float may be interrupted by the military open burning along the way. Nor or there any signs where people of all ages "put into the water" to float down an otherwise stunningly beautiful New River.
Neither the U.S. Army nor BAE Systems elaborated on how long they patrol the river after a burn, but the EPA reports skid burns have been known to smolder for four hours or more. Paddle faster.
Still and all, you don't have to be a rocket scientist to realize there is something fundamentally wrong when recommendations from a major consulting firm (CH2MHill,) to the U.S. Army's contractor in the Human Health Risk Assessment (HHRA) of 2005 are ignored by regulators. The report states in no uncertain terms that the current practice of "skid burns" at the Open Burning Ground (OBG) ought to change because it is exceedingly toxic. CH2MHill makes a gentle reference to what amounts to a toxic assault from RAAP on the air of every single baby, child and adult breathing here in the New River Valley. They inform the company operating the Arsenal from 1995 through June of 2012, Alliant Techsystems (ATK) that
"The low temperature combustion following the consumption of the diesel fuel provides conditions conducive to the formation of dioxins and furans as products of incomplete combustion." page 43.
This reference to what is known as a "skid burn" comes under the section heading 7.2 Proposed Mitigated Skid Burn Pan. Granted, the contractor is looking to make a profit here by installing natural gas lines to replace the diesel fuel as a source of combustion. Never mind that this whole toxic mess sits squarely in the 100 year flood plain, less than a mile from the Pulaski Thrust Fault and atop Karst topography. The report does seem to be saying that this method of soaking each clay lined pan loaded with "munitions constituents" in 12.5 gallons of diesel fuel to facilitate combustion creates more cancer causing particulate matter (PM) than is necessary. The U.S. Army who is on site helping to operate this base has taken an oath to protect and defend the people living here, so why would the U.S. Army Environmental Command allow this to continue? Shoot, why would Senator Mark Warner turn a blind eye to the pictures in the EPA inspection report which was brought to his office for a personal meeting with his staff on April 29th, 2013?
A "skid burn" is quite a site to behold, which is one reason the OBG permit issued by the Virginia DEQ for this special disposal method dating back seventy years, notes the following security procedure:
“Warning. The burning ground of the Radford Army Ammunition Plant is about to begin burning operations. Evacuate the river area immediately.”
As officials explained on September 5th, they make sure all the college students and others who like to float down the New River, smack dab through the Main Manufacturing Area (MMA) which includes the permitted pollution outfalls in addition to the OBG, are not in danger from the - well, they don't call it an explosion, exactly. You know what they say, "who are you going to believe, me or your lying eyes? This handy Map of Peppers Ferry to Whitethorne float from the Virginia Department of Game and Inland Fisheries (DGIF), does not make mention that your float may be interrupted by the military open burning along the way. Nor or there any signs where people of all ages "put into the water" to float down an otherwise stunningly beautiful New River.
Neither the U.S. Army nor BAE Systems elaborated on how long they patrol the river after a burn, but the EPA reports skid burns have been known to smolder for four hours or more. Paddle faster.
Saturday, September 7, 2013
Geographic Co-Location (updated TRI link)
From the department of Idiocracy, this information about the shell game being played with the hazardous, toxic, not at all good for living things WASTE being "handled" at the Radford Army Ammunition Plant (RAAP). We learned at the BAE/U.S. Army community meeting on September 5th that the tenants at RAAP enjoy complimentary toxic waste disposal. As part of their "deal," (presumably negotiated under the unique RCRA permit), BAE accepts waste from their tenants for incineration in one of two Hazardous Waste Incinerators (HWI's) or firing up at the good 'ole Open Burning Ground (OBG). As the coveted corporate operator of this GOCO (Government Owned/Corporate Operated) facility, BAE Systems gets paid for this waste disposal service. According to representatives at the meeting last Thursday, the disposal is performed "at cost." (There was disagreement from the Army's man Charlie Sacks, who contended that what we're dealing with here is not actually hazardous waste, but the semantics of describing the poisons in what they burn and/or incinerate is arbitrary. What really matters are the long lasting effects it has on all things living here.)
"Now, here is where it gets tricky,"sometime in the last few months Alliant Techsystems (ATK), doing business as New River Energetics (NRE), got a new zip code of 24143. This is odd because the geographic coordinates listed on the Toxic Release Inventory (TRI) for each reporter indicate that they are actually co-located. That's right, the longitude (-80.540242) and latitude (37.182565) listed for the U.S. Army RAAP and New River Energetics TRI report are identical. But NRE reports sending their waste "off site" for disposal as if it was going somewhere. Instead, it gets "released" into the air we breathe and the New River at the same discharge points as the toxins from the rest of the Radford Arsenal operation - and the U.S. Army knows this truth! I'm not a geographer, but it seems a bit unorthodox to make a claim of moving something to "off site" when it's going nowhere. What gives?
The only advantage I can see to assigning this new 24143 zip code to NRE is to bolster the illusion that it's not sitting right there at RAAP - supposedly occupying the very same space. As an added bonus, the split of TRI reporting into 3 separate entities "dilutes" the source of toxins being released, thereby undoing RAAP's dubious distinction of "first place" on the TRI in Virginia every year since 2007. Alas, the old axiom that "dilution is the solution to the pollution" is not true. Oh, when we will ever learn?
"Now, here is where it gets tricky,"sometime in the last few months Alliant Techsystems (ATK), doing business as New River Energetics (NRE), got a new zip code of 24143. This is odd because the geographic coordinates listed on the Toxic Release Inventory (TRI) for each reporter indicate that they are actually co-located. That's right, the longitude (-80.540242) and latitude (37.182565) listed for the U.S. Army RAAP and New River Energetics TRI report are identical. But NRE reports sending their waste "off site" for disposal as if it was going somewhere. Instead, it gets "released" into the air we breathe and the New River at the same discharge points as the toxins from the rest of the Radford Arsenal operation - and the U.S. Army knows this truth! I'm not a geographer, but it seems a bit unorthodox to make a claim of moving something to "off site" when it's going nowhere. What gives?
The only advantage I can see to assigning this new 24143 zip code to NRE is to bolster the illusion that it's not sitting right there at RAAP - supposedly occupying the very same space. As an added bonus, the split of TRI reporting into 3 separate entities "dilutes" the source of toxins being released, thereby undoing RAAP's dubious distinction of "first place" on the TRI in Virginia every year since 2007. Alas, the old axiom that "dilution is the solution to the pollution" is not true. Oh, when we will ever learn?
Where Others Fear to Tread
This very insightful report about the leak in the Oleum line at the Radford Army Ammunition Plant on July 1, 2012 needs to be seen and saved somewhere. The TV station where it was originally broadcast WDBJ7, is a CBS affiliate owned by Schurz Communications. The station manager there has reportedly gotten "push back" in phone calls from the Pentagon. It seems this particular reporter's "tough questioning," of the U.S. Army is not to their liking, so they called this news station to advise them on how to choose reporters to cover news about their dirty deeds. WDBJ7 has since deleted this and other videos showing RAAP in their true colors from their public access. The reporter (Orlando Salinas) who had the cajones to ask the U.S. Army Joint Munitions Command the obvious, pointed questions about how much danger our community was in the night of July 1st deserves to have his REAL JOURNALISM seen far and wide. At the very least, you would think CBS News would be interested in the story about the story...Please share this video link because someone needs to answer for what happened at the Arsenal that night and why no one bothered to warn or protect our community. No one alerted the people living all around the plant that night of an emergency in their midst nor the next day or into the holiday when the ~8,000 gallons or so of acid washed into the New River. Nor did the Virginia DEQ or the EPA issue any violation. It's almost as if the whole incident never really happened, but it surely did happen and people in power know the truth.
The shocking record of how the U.S. Army responded to this reporter might be lost to obscurity, except for the Sun Sentinel link and the intrepid data accumulators at the Right-to-Know Network. This stellar run non-profit (formerly known as the Office of Management and Budget Watch,) puts environmental facts at your fingertips truly enabling citizen participation. The report of the major chemical leak at the Radford Arsenal is a bit of a bug-a-boo to find, though. It does appear under the list of accidents at all BAE facilities in 2012, but for some reason the location given was the Bradford Army Ammunition Plant. Go figure.
Someone - perhaps the former head at Homeland Security who now serves as Chairman of the Board of BAE Systems, should step up and take responsibility for assuring our community this will never happen again. You might think his focus would spur him to want to reassure our community that all safety precautions are indeed being followed at his ammunition plant down the road. Perhaps not. He has not taken the initiative to address the press, including the PBS Newshour. It may be that neither he, nor BAE, nor EPA, DEQ, Senator Mark Warner - non of the people in power seem to have any concern that this could become a public relations issue. I wonder why they're so self-assured?
Could it be that BAE Systems, who became a major corporate underwriter of the PBS Newshour earlier this year, fears no press? He does not seem to be compelled by anyone to be any more accountable for his corporate activities than say, Tony Hayward of British Petroleum. Mr.Chertoff has not been asked by any journalist about how he intends to keep BAE Systems following the law - corporate and environmental - at this plant in Appalachia. No, even Judy Woodruff failed to note his association with their new corporate underwriter when she interviewed Mr. Chertoff on August 1 of this year. An email response from the senior producer of the Newshour informed me that this oversight was being addressed by new policy which would have producers "cross check biographical information..." Really, when was that essential integrity check taken out of the job description for producers?
Seriously, folks this is one dirty, down low operation we're dealing with here!
The shocking record of how the U.S. Army responded to this reporter might be lost to obscurity, except for the Sun Sentinel link and the intrepid data accumulators at the Right-to-Know Network. This stellar run non-profit (formerly known as the Office of Management and Budget Watch,) puts environmental facts at your fingertips truly enabling citizen participation. The report of the major chemical leak at the Radford Arsenal is a bit of a bug-a-boo to find, though. It does appear under the list of accidents at all BAE facilities in 2012, but for some reason the location given was the Bradford Army Ammunition Plant. Go figure.
Someone - perhaps the former head at Homeland Security who now serves as Chairman of the Board of BAE Systems, should step up and take responsibility for assuring our community this will never happen again. You might think his focus would spur him to want to reassure our community that all safety precautions are indeed being followed at his ammunition plant down the road. Perhaps not. He has not taken the initiative to address the press, including the PBS Newshour. It may be that neither he, nor BAE, nor EPA, DEQ, Senator Mark Warner - non of the people in power seem to have any concern that this could become a public relations issue. I wonder why they're so self-assured?
Could it be that BAE Systems, who became a major corporate underwriter of the PBS Newshour earlier this year, fears no press? He does not seem to be compelled by anyone to be any more accountable for his corporate activities than say, Tony Hayward of British Petroleum. Mr.Chertoff has not been asked by any journalist about how he intends to keep BAE Systems following the law - corporate and environmental - at this plant in Appalachia. No, even Judy Woodruff failed to note his association with their new corporate underwriter when she interviewed Mr. Chertoff on August 1 of this year. An email response from the senior producer of the Newshour informed me that this oversight was being addressed by new policy which would have producers "cross check biographical information..." Really, when was that essential integrity check taken out of the job description for producers?
Seriously, folks this is one dirty, down low operation we're dealing with here!
Friday, September 6, 2013
Perchlorate Contamination of Drinking Water Wells Confirmed *Corrected*
In other news, three of five private wells in the vicinity of the Radford Arsenal tested positive for perchlorate. Two of the five wells were in Pulaski and three on the far side of the New River in Montgomery County. Testing was paid for by the Virginia Sierra Club, although results have not been made publicly available nor sent to members.
The question now is, how far does the perchlorate plume spread? What agency is responsible for testing all drinking water wells - private and municipal - for perchlorate contamination? Who is financially liable for this testing to determine whether perchlorate contamination, originating at the Radford Army Ammunition Plant, has contaminated groundwater off site? The EPA directed RAAP to test all drinking water wells within a five mile radius of each contaminated site when the facility was being assessed a Hazard Rating Score (HRS) during the process of determining listing on the National Priorities List (NPL) in the early 1990's. The testing that EPA directed the Arsenal to perform never happened. Senator Warner's office was made aware of this seemingly egregious failure to accurately assess risk when his staff member was presented with petition signatures from over 340 residents calling for well testing. These petitions were presented to his office last April, along with a review of the EPA Site Inspection results from 2011. Both issues seem to warrant follow up from Senator Warner. Unfortunately, the Senator has not responded to either issue yet.
NOTE CORRECTION AS OF 9-6-13 ~ FRIDAY AFTERNOON!!! That was 3 of 5 wells tested positive...my sincere apology for the shoddy proofreading!
The question now is, how far does the perchlorate plume spread? What agency is responsible for testing all drinking water wells - private and municipal - for perchlorate contamination? Who is financially liable for this testing to determine whether perchlorate contamination, originating at the Radford Army Ammunition Plant, has contaminated groundwater off site? The EPA directed RAAP to test all drinking water wells within a five mile radius of each contaminated site when the facility was being assessed a Hazard Rating Score (HRS) during the process of determining listing on the National Priorities List (NPL) in the early 1990's. The testing that EPA directed the Arsenal to perform never happened. Senator Warner's office was made aware of this seemingly egregious failure to accurately assess risk when his staff member was presented with petition signatures from over 340 residents calling for well testing. These petitions were presented to his office last April, along with a review of the EPA Site Inspection results from 2011. Both issues seem to warrant follow up from Senator Warner. Unfortunately, the Senator has not responded to either issue yet.
NOTE CORRECTION AS OF 9-6-13 ~ FRIDAY AFTERNOON!!! That was 3 of 5 wells tested positive...my sincere apology for the shoddy proofreading!
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