Cloaked In Immense Power

According to the Multi-Media Inspection that EPA Region 3 performed at RAAP from May 16 -20th, 2011, the Open Burning Ground (OBG) at the Radford Army Ammunition Plant (RAAP) is violating the Clean Air Act. It appears that they are being allowed to continue to endanger the health of our community because they operate under the auspices of the U.S. Army. The EPA inspection report includes documentation of how RAAP was given permission by VADEQ to burn tons of wood contaminated with nitrocellulose to the open air without any protection or warning being provided to the children breathing downwind at Belview Elementary School, or residents living in the adjacent communities. The Army's Rob Davie  claimed that the violations found in this inspection were not serious, or they would have already prompted action by EPA. Please act on his assertion! Take a minute to contact Senators Warner & Kaine as well as Congressman Griffith to ask why there has not been an enforcement action following this 2011 inspection. 

Senator Mark Warner 202-224-2023 


Senator Tim Kaine 202-224-4024  


Congressman Morgan Griffith 202-225-3861


Despite the fact that toxins from corporate tenants of BAE are being disposed of in the two hazardous waste incinerators and the Open Burning Ground at RAAP, no one from the Army or BAE volunteered this information to those of us breathing it. Instead, BAE Systems confirmed the fact that they perform the toxic waste disposal at this Federally owned facility on September 5th, but only when asked directly. Why should we be made to pay with our health to increase the profit margins of BAE and their tenants - i.e. private corporations? How much of the average 37,000 pounds (18.5 tons) of waste BAE burns at the OBG every month, according to this document they provided, is generated by BAE's tenants?  Whose waste accounts for the source of the Chromium they have proposed to increase in the “small,” 500 pound "skid burns?" Are we breathing chromium to pad ATK's profit margins?

RAAP is a Government Owned-Corporate Operated (GOCO) Federal Facility, currently operated by BAE Systems. The Army holds the RCRA Subpart X permit detailing the open burning of 8,000 pounds of "munitions constituents" every day that the weather conditions allow. The sixteen clay-lined burning pans are 150 feet from the New River, a source of drinking water, recreation and an American Heritage River. This report from the U.S. Army Corp of Engineers in 1995  makes clear that this proximity violates the Clean Water Act (CWA) and  ought to be moved. (page 19) The Corp of Engineers note in this report that the State of Virginia fined RAAP for this violation, but VADEQ has claimed that no record of this violation exists. Worse yet, the  report could not predict that RAAP would start selling drinking water drawn from the New River to the good people living in Prices Fork/Merrimac as ATK proudly announced in this newsletter of 2003.

The special method of ignition for a significant percentage of the open burns conducted at RAAP are referred to as "skid burns."  Although no other U.S. Army facility uses diesel fuel in Open Burning, at our "for profit" Arsenal it gets the "go ahead" from VADEQ. This unique "skid burn," process involves soaking the wooden pallet and then dousing the material on top of the clay lined pan with 12.5 gallons of diesel fuel to facilitate ignition. As near as I can figure out,  “skid burns” do not provide complete combustion, which results in a slow smolder lasting four (4) hours or more. My understanding of this report, the Human Health Risk Assessment performed by CH2MHill for ATK in 2005, is that the "skid burn" method is excessively toxic and results in more dioxin and furans being released to the air we breathe than is necessary. The 2005 report proposes a "mitigation plan" to reduce the level of cancer causing emissions, but no action has been taken on this recommendation. (page 43)

The chronic inhalation, dermal and ingestion exposure from RAAP is most troubling for the children just 1.5 miles downwind of the OBG at Belview Elementary School. The permit written by Virginia DEQ and overseen by EPA Region 3, does not require any pollution control devices at the OBG nor ambient air quality monitoring. How does this failure to control or even monitor emissions comply with standards set for all Federal Facilities by the EPA? How does this  RCRA permit, as written by VADEQ, prevent a risk of imminent and substantial endangerment for the people living here? How does Michael Chertoff, Chairman of the Board for BAE Systems, justify BAE's decision to ignore the health assessment report finding that "skid burns" are more deadly for the children living here?


Unfortunately, the toxic particulate matter that goes up into the air during ignition  from these "skid burns" comes back down at receptor points on the NewRiver identified in 2005 on this map. The Safe Drinking Water Act does not require testing for many of the poisons coming out of those burns, including perchlorate, dinitrotoluene or hexavalent chromium - no one is testing anyone's drinking water for these toxins, even though we know they are being "released" into our air and water under the current permits and saturate the soil around the OBG. No one is testing despite a 2013 finding perchlorate in 100% of the 3 private drinking water wells tested in Montgomery County, which proves cross-contamination of groundwater from the Arsenal. 

Why are our elected representatives allowing the OBG's toxic assault on the people living here to continue unabated? What more do we need to know to demand NO MORE OPEN BURNING? Please send an email to ALL of our representatives in Congress today - ask WHY the OBG is being permitted to poison us for the sake of corporate profits.

Perchlorate - What Does the "Government Police Office" Say?

There are a lot of reasons that toxic chemicals do not get assigned a Maximum Contaminant Level (MCL) by the Environmental Protection Agency (EPA) in America. This  2011 Government Accountability Office (GAO) report goes into detail about the failure to regulate perchlorate under the Safe Drinking Water Act (SDWA). The GAO reports,

"Also, the credibility of EPA’s exposure estimate for perchlorate, which is based on a novel analysis, is reduced by the lack of a comprehensive explanation of the methodology’s limitations and uncertainties in the preliminary determination notice. Finally, according to key EPA scientists, the agency mischaracterized important scientific findings on the sensitivity of various age groups to perchlorate exposure." (pg. 2)


It is no coincidence that the DoD is the primary source of perchlorate contamination nationwide. The lack of action on perchlorate standards is similar to what happened with a commonly used solvent now found at most Superfund sites, trichloroethylene (TCE). When the EPA tried to lower the MCL for TCE in drinking water to better protect human health, lobbyists swarmed like buzzards to pick apart common sense regulation. The story of TCE, (which also forms a large contaminant plume at RAAP known as HWMU5), is chronicled in this 2006 article by Ralph Vartabedian, "How Environmentalists Lost the Battle Over TCE." It tells a story that rings true for the money and meddling that leaves us hanging on perchlorate, too.


The GAO explains why anyone with an ongoing source of perchlorate contamination in their midst should demand testing of their water for this hormone disrupting chemical. That goes double for any community relying on water that is not subject to the SDWA standards, such as that sold by any water supplier putting out a Consumer Confidence Report. No, according to the people who hold government's feet to the fire - the GAO, 

"Improvements in Implementation Are Needed to Better Assure the Public of Safe Drinking Water" (this link goes to a different report than the first GAO link)

the "government police" say that the danger of perchlorate -especially for children - is being mis-characterized.

Roll Over, Ike!

The practice of open burning Munitions Constituents (MC) at military bases  is not unique to the Radford Army Ammunition Plant (RAAP). What is different at other Army Open Burning Grounds (OBG) is that they operate at  bases not subject to providing economic gains for their corporate overseers. These Government Owned, Government Operated (GOGO) Army bases have no "mixed allegiance" to contend with - they carry out their mission according to military standards. That's one reason that the OBG permit for the Tooele Army Base in Utah is a total of ten pages, whereas the one issued to RAAP by the Virginia DEQ has 9 Modules and 21 attachments that make a mockery of transparency. In the words of one environmental professional  who reviewed the RAAP OBG permit proposed for modification in 2011, "this is a joke." These comments submitted for the official record in that process details what is so wrong about the permit that the VA DEQ ultimately approved.

The handy map of GOGO and GOCO facilities nationwide provided in this presentation by the Tooele Army base helps identify where corporate profits and the U. S. Army have a symbiotic relationship. Some of the ammunition plants built in preparation for WWII and established as Government Owned, Corporately Operated (GOCO) facilities, included the DuPont run Charlestown Indiana plant and that of the company that they gave spawn to under the Sherman Antitrust Act, Hercules Chemical.  

As this short history  provided by the Army's Joint Munitions Command outlines, RAAP was originally operated by Hercules Chemical, a company that developed strong ties with Virginia Tech (VT) and even came to share executive management. Many graduates of VT have gone on to work at the Arsenal, typically in management jobs where they are not exposed to the same level of toxins and dangers that those without college degrees endure at RAAP on a daily basis. Perhaps the key alum in weaving the interests of Hercules Chemical with those of the public University less than ten miles away was "maverick" businessman, Al Giacco. 

After immigrating to America from Italy as a young boy, Mr. Giacco graduated with a degree in Chemistry from Virginia Tech. His 1941 thesis on smokeless powder so impressed Hercules, Inc., that he was invited to their Wilmington headquarters later that year to discuss employment. According to page 45 of his autobiography, "Maverick Management," he reported to work  after Pearl Harbor at the end of March 1942. Mr. Giacco became a very valuable employee who worked his way up to the position of CEO in 1977. He also continued a close relationship with VT, being appointed to the Board of Visitors in 1979, although he was living in Delaware. Even more importantly, he became the University Rector from 1984 to 1987, (a position tantamount to University President in terms of practical power in Virginia), one of only two public Universities with a military Corp of Cadets. (Texas A & M is the other.) This dual management of the ammunition plant and Virginia Tech sealed the relationship between the two entities like a resin, in a way that redounds to the present day. After Giacco retired from Hercules, the company established the Alexander F. Giacco Presidential Chair at Virginia Tech with a $1 million endowment.

Alas, it is a wide and complex web of business interests interwoven into academia and the mission of our military. General Eisenhower must be rolling in his grave.

Now You See It...

The internet is pretty amazing for folks like me...and rather than look a gift horse in the mouth, I'll take this one as a blessing. Many thanks to the Orlando Sun Sentinel, a newspaper of integrity who has maintained a link to this story! I don't know how to save electronic files and stuff, though...

Last March, when the Restoration Advisory Board held one of their meetings to include the community in decisions about the hazardous waste clean up at RAAP, a real, live reporter was there! Orlando Salinas, reporting for  WDBJ7, provided a rare look into how the U.S. Army treats the community at their RAB.  The video of his report, which seemed to have vanished like the mist that so often hangs over our valley, is once again live and available. The title of this report was originally, "Radford Arsenal Public Meeting Turns Ugly," but through the  genius of NewSpeak, was changed to "Radford Arsenal Works to Clean Up Property." Go figure. 

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.

Where Do All the Toxins Go? (Long Time Passing) *updated links*

You might think all this toxic waste being treated by incineration and open burning at the U.S. Army owned and BAE Systems operated Radford Army Ammunition Plant would have an effect on the New River downstream. You would be correct! According to this EPA report of 2008,  toxic byproducts of 2,4 Dinitrotoluene were found in the New River (where people fish and frolic) 

"...intermediates formed during DNT's degradation include 1,3-dinitrobenzene, hydroxynitrobenzene derivatives, and carboxylic acids.

Microbial biodegradation of DNT in water has been observed in both aerobic and anaerobic conditions. Bioremediation occurs mainly through the reduction of the nitrogroup (Spanggord, et., al. 1981). ..2,4 DNT degradation occurred in waters taken downstream from the Radford Army Ammunition Plant..." [pg. 16 of EPA report linked above]

According to EPA mandated reporting on the Toxic Release Inventory (TRI) and complied by the non-profit  Right-to-Know Network, 103,043 pounds  of 2,4 DNT were released to the air and New River in 2009. Subsequent years do not show anywhere near this quantity, so there must have been a significant improvement made in the waste process. Certainly all of it became harmless years ago as who-knows-who went floating through it...Mercury releases, on the other hand have fluxuated from 
29 pounds in 2009, surging to 104 pounds in 2010 and precipitously back down to the same level of 29 pounds released in 2011.

The  CDC is currently updating the toxicological profile for DNT and would welcome YOUR input. There aren't a lot of recent studies of exposed populations (and the CDC's ATSDR will not be evaluating our exposure to DNT as part of the tax-payer funded) >>>link to study updated 9-16<<<  Health Assessment for our community,  so anecdotal reports about similar neurological symptoms is just what they need to hear. These symptoms, as ATSDR/CDC notes from a study of munitions workers in 1947 might sound familiar if you work at or live around RAAP:  (section 3.2.3.4 Neurological Effects)

Various neurological symptoms, including headache, vertigo, and pain or numbness in the extremities,

have been reported in surveys of munitions workers exposed to unspecified concentrations of 2,4-

DNT (McGee et al. 1947). 

  If you breathe at or around the Radford Arsenal and have experienced any of these symptoms, please take a minute to email the lead researcher for the study being done around RAAP. These symptoms are similiar to diabetes, but some people say they get headaches and dizziness here for no apparent reason at all. Dr. Neurath will be glad to hear from you at her offices of the  Agency for Toxic Substances & Disease Registry (ATSDR) at the Center for Disease Control (CDC) because she is our public servant in charge of the Health Assessment for our community: Dr. Sue Neurath sfn8@cdc.gov and you can help by providing comments using the link for "updating the profile" from above before September 30th.

"Historic" Contamination, Indeed

The community meetings that have been hosted this year by the U.S. Army and BAE Systems were announced after several concerned citizens came to a Restoration Advisory Board (RAB) meeting that the facility is required to hold in conjunction with their unique RCRA permit. The meeting in March caught Jim McKenna a bit "off guard," even though he has been running these meetings since they started at RAAP a decade ago.

It may have been the level of concern, or perhaps the impact of the WDBJ7 news report on how citizens were treated at that meeting (a report which has since disappeared),  that prompted the Army and BAE to decide to hold separate meetings for purposes of informing the community about ongoing hazardous waste disposal practices at RAAP. Whatever the motivation, Col.Ortiz made sure stakeholders at the meeting on the 5th knew that the 

                 RAB meeting at 7 pm 
       on Wednesday the 25th of this month 

is being convened to discuss "historic contamination" and not the Open Burning Ground (OBG). Funny thing is, the soil at the OBG is being "remediated" as part of that "historic" waste problem. The soil in the EPA's RCRA permit to address areas of contamination "discovered" in the 1980's is now known as Solid Waste Management Unit 13 (SWMU13) and regulated separate from the actual burning pans above and groundwater below the Open Burning Ground at what VA DEQ described in an email as the "co-located Hazardous Waste Management Unit 13 (HWMU13)" . So, if you're concerned about the lead, benzo(a)pyrene and nitroglycerin in the soil at the OBG, <<< link to MAP of levels in soil<<<
 the Arsenal's RAB Meeting at 7 pm on the 25th is FOR YOU! (same time, same place as last Thursday)

That's right, in another instance of "geo-graphic co-location," the soil that's been doused with metals, explosives like RDX, HMX, Dinitrotoluene (and who knows what)  since 1941 and continues to receive the "fall out" from ongoing operations at the OBG, is not covered under the Virginia DEQ permit for the OBG, it's an EPA RCRA site all by itself. So, if you think that some of the contaminants in that soil that are still being addressed:

      Solid Waste Mangement Unit 54 and the New River Unit, for two...
 
 might have some "long lasting" effects, despite being "historic," this meeting is a "must attend." Hope to see YOU there!

Other sites covered under the RAB include the New River Unit in Dublin, where asbestos continues to be a problem along with PCB's like Arachlor which were found saturating the soil in a building they demolished there a couple of years ago. This might have something to do with the PCB's found in fish tissues here in the New River....

Radford Army Ammunition Plant Open Burning Ground OBG

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.

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.

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....

"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.

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?

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!

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!

Congress Must Exercise Oversight of EPA & DoD

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.

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?

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.

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.