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Friday, November 1, 2013
Friday, September 20, 2013
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.
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.
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.
Sunday, September 15, 2013
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,
"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.Saturday, September 14, 2013
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.
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.
Friday, September 13, 2013
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.
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.
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