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....