ACTION ALERT: Open Air Burning of Munitions is Obsolete and Dangerous
February 2, 2016 Citizens for Safe Water Around Badger
The US Army reports that its retired stockpile of conventional (non-nuclear/non-biological/non-chemical) ammunition -- and more than 300,000 missiles and components -- grew from 557,000 tons in 2009 and could exceed 1.1 million tons by FY 2025 representing a $2.8 million clean-up liability. A national coalition of 29 organizations is supporting Louisiana residents in their fight to end open-air burning of a stockpile of hazardous explosive waste in the town of Colfax.
MERRIMAC, WI (February 1, 2016) -- A national coalition of 29 organizations is supporting Louisiana residents in their fight to end open air burning of hazardous explosive waste in the town of Colfax. In formal comments submitted to the Louisiana Department of Environmental Quality today, the coalition is calling for the immediate implementation of safer alternatives that will protect human health and the environment.
"Open burning and detonation of energetics and explosives-contaminated wastes results in the uncontrolled dispersion of toxic and carcinogenic emissions including heavy metals, energetic compounds, perchlorate, nitrogen oxides and other munitions-related contaminants to the environment," the coalition wrote.
The groups are objecting to current operations and a pending permit modification for the Clean Harbors facility in central Louisiana. If approved, the threshold for open air burning of reactive and explosives-contaminated wastes would increase from 480,000 pounds to over 2 million pounds per year.
The permit is currently issued pursuant to the Resource Conservation and Recovery Act (RCRA), a federal law that ironically prohibits all open burning of hazardous waste.
"The current and expanded RCRA permit for Clean Harbors Colfax does not comply with federal laws and regulations which ONLY allow for open burning and detonation of hazardous waste which cannot safely be disposed of through other modes of treatment," the letter to the Louisiana Department of Environmental Quality said.
"As the Department is well aware, safer technologies have been implemented and permitted elsewhere including Super Critical Water Oxidation, Static Detonation Chambers, Detonation of Ammunition in a Vacuum-Integrated Chamber (DAVINCH), Controlled Detonation Chambers, and Hydrolysis," the coalition emphasized.
The 700-acre Clean Harbors commercial facility currently receives, stores, and treats over 300 energetic/reactive waste streams in solid, sludge, and liquid forms. These hazardous wastes include fireworks, detonators, propellants, power charges, shaped charges, igniters, fuses, bulk high explosives, rocket motors, detonating cord, air bag inflators, and explosives-contaminated debris.
The joint letter was organized by Citizens for Safe Water Around Badger (CSWAB), a Wisconsin-based environmental justice organization that has worked on military cleanup issues for more than 25 years. CSWAB is a co-founder of the Cease Fire Campaign, a national grassroots initiative to end open air burning, detonation and incineration of toxic military wastes.
The Colfax, Louisiana facility is just one of approximately 100 communities where open air burning of hazardous wastes is still occurring.
EPA: End Open Air Burning of Waste Munitions
In communities across America, open burning and detonation of hazardous waste explosives results in the uncontrolled release of toxic heavy metals, energetic compounds, perchlorate, nitrogen oxides, dioxins and other carcinogens to the environment, placing the health of our soldiers, workers and neighbors at risk.
It is time to recognize that the exclusion adopted by the EPA in 1980 for the open burning and detonation of waste explosives is no longer relevant.
Over the past 15 years, the Department of Defense Explosives Safety Board has certified a number of technologies as safe for the destruction of hazardous wastes, which are explosive. These technologies are now in use by the Department of Defense and the private sector for the treatment of explosive hazardous waste.
HOW YOU CAN HELP:
Below is a petition to EPA Administrator Gina McCarthy
Dear EPA Administrator McCarthy:
I am writing to urge you to protect human health and the environment by calling for the immediate implementation of safer alternatives to open air burning, open detonation and non-closed loop incineration/combustion of military munitions.
I urge you to require safer alternatives that encourage waste prevention and recycling, prevent the release of toxic emissions and pollutants, and advance the principles of environmental justice by assuring that all people enjoy the same degree of protection and access to the decision-making process.
NOTE: It's very important that you add a brief personal comment at the end of the petition! The EPA typically gives much greater weight to a petition with a personal note. Then complete the form to the right and click 'Submit.'
Prescribed munitions range fire at Fort Ord, California 2013. (Photo by Mike Morales)
THANK YOU to the following organizations that co-signed formal comments to the Louisiana Department of Environmental Quality:
California Safe Schools, Los Angeles, CA
Crawford Stewardship Project, Rolling Ground, WI
Midwest Environmental Justice Organization, Madison, WI
Center for Public Environmental Oversight, Mountain View, CA
Peaceful Skies Coalition, Arroyo Hondo, NM
Kentucky Environmental Foundation, Berea, KY
Barron Park Association Foundation, Palo Alto, CA
Camp Minden Citizens Advisory Group (CMCAG), Minden, LA
Citizen Action New Mexico, Albuquerque, NM
Louisiana Progress Action, Baton Rouge, LA
Volunteers for Environmental Health and Justice, Kingsport, TN
Green Cross International, Washington, DC
Frederick Citizens for Bio-lab Safety, MD
Institute for Science and International Security, Washington, DC
Alaska Community Action on Toxics, AK
Texas Campaign for the Environment, TX
Military Toxics Project, TN
Physicians for Social Responsibility Wisconsin, WI
Wisconsin Environmental Health Network, Madison, WI
California Communities Against Toxics, Rosamond, CA
Protect All Children's Environment, Marion, NC
Voluntary Cleanup Advisory Board, Denver, CO
Wisconsin Resources Protection Council, WI
Louisiana Bucket Brigade, LA
Center for Health, Environment & Justice, VA
Defense Depot Memphis Tennessee Concerned Citizens Committee, TN
WI Coalition to Ground the Drones, Madison, WI
Louisiana Bucket Brigade, LA
Citizens for Safe Water Around Badger, Merrimac, WI
Environmentalists Against War, Berkeley, CA
Laura Olah is Executive Director of Citizens for Safe Water Around Badger (CSWAB)
E12629 Weigand's Bay South
Merrimac, WI 53561
The Secretary of the Army serves as the single manager for conventional ammunition and is responsible for demilitarizing the US Department of Defense’s conventional (non-nuclear/non-biological/non-chemical) ammunition stockpile and more than 300,000 missiles and missile components.
The US Army Audit Agency has reported that this stockpile grew from 557,000 tons as of March 2009 and could exceed 1.1 million tons by FY 2025 representing a $2.8 million demilitarization liability.
The US government is considering two treaties that, if ratified, would significantly impact US demilitarization operations. One treaty is the Convention on Cluster Munitions and the other is the Convention on the Prohibition of the Use, Stockpiling, Production and Transfer of Anti-Personnel Mines and on Their Destruction.
DOD has an inventory of 471,726 tons of cluster munitions and 23,436 tons of anti-personnel landmines that will have to be disposed of if the United States ratifies the two treaties.
All munitions have a finite service life and will at some state need to be either expended or disposed of. Disposal can involve dumping, resale and demilitarization. The three major types of demilitarization are uncontained thermal treatment such as Open Burning and Open Detonation (OB/OD), contained industrial thermal treatments such as incineration, and other industrial treatments such as oxidation and biodegradation.
OB/OD and INCINERATION
Detonation of ammunition may lead to the dispersion of heavy metals (cadmium, chromium, lead, etc.), energetic compounds, perchlorate, nitrogen oxides and other munitions-related contaminants to the environment.
Dioxins/furans should be considered as a potential contaminant of concern unless there is comprehensive data which explicitly demonstrates that chlorinated wastes are not being treated by OB/OD.
When carried out on a large scale over an extended period in one location, significant quantities of hazardous materials may accumulate on or near the site. The literature also emphasizes surface and subsurface contamination with heavy metals and unexploded explosives, which results from incomplete consumption of energetics, even during high-order detonation.
Open burning is still routinely used for disposal of propellants and some pyrotechnics. Even when done properly, the deflagration (combustion) is incomplete. If done incorrectly, raw propellant tends to scatter from the burn point, often leaching into the surrounding soil.
Beginning in 2000, some countries progressively moved away from OB/OD. That year, the Canadian Department of National Defence instituted severe restrictions on OB/OD operations as a result of reports of environmental contamination at several Canadian Forces bases and ammunition depots. A number of countries, notably Germany, the Netherlands, and Sweden, have banned OB/OD if alternative processes are available.
An incinerator (combustor) is a facility for the controlled burning of waste. Incinerators with names like gasification, pyrolysis, plasma arc, and waste-to-energy all emit dioxins and other harmful pollutants.
While mass-burn incinerators combust the waste in a single chamber, these incinerators typically heat the waste materials at high temperatures in one chamber with less oxygen present, and then burn the waste gases in a separate chamber connected to a smoke stack. However, the core environmental impacts of all types of incinerators are the same.
In 2002, three-quarter-mile-long Load Line 1 was set ablaze at Cornhusker Army Ammunition Plant in Nebraska, filling the prairie sky with thick black smoke. Click on the image to view the video.
Prescribed range fires, decontamination ovens, and open burning of explosives-contaminated buildings and other infrastructure are other sources of uncontrolled toxic releases to the environment. The prescribed range fires at Fort Ord, California, for example, are intended to clear vegetation in order to facilitate the recovery and removal of unexploded ordinance and munitions.
However, high levels of smoke lead to poor air quality due to an increase in fine particulate matter (PM). Inhalation of PM has been linked to increased risks of heart attacks, strokes and respiratory ailments.
In the past 25 years, alternatives to the incineration of hazardous waste have emerged due to the work of communities, EPA, and the Department of Defense (DOD). These technologies are being used by the DOD to destroy energetics and chemical warfare agents. These technologies could be readily applied to conventional munitions and other types of hazardous waste.
Under the Assembled Chemical Weapons Assessment program, the military established a process for identifying and demonstrating alternatives to incineration for the demilitarization of chemical weapons.
Seven of these technologies were evaluated for applicability to RCRA hazardous waste: chemical oxidation, chemical reduction (2), biological degradation, supercritical water oxidation (2), and thermal plasma.
Based on information provided by technology providers, an EPA report published in 2000 found that all seven of these technologies have the potential to treat a wide range of RCRA waste streams including energetics. Unlike incinerators, these alternatives are designed and operated so that they will not produce dioxin or dibenzofurans, technology providers said.
In 2001, a report by the National Research Council (NRC) committee identified technologies for disposal of "non-stockpile" chemical weapons wastes that pose low risk to workers and communities, compared to incineration. Non-stockpile chemical weapons are a category of warfare materials leftover from chemical weapons production, testing and training.
The NRC committee’s report, "Disposal of Neutralent Wastes," examined eight non-incineration disposal processes and ranked them by criteria such as safety, technical effectiveness and pollution prevention. The committee found that "the benefits of [some non-incineration] technologies over incineration include low worker risk, public acceptance, low risk to the surrounding community, and simplicity of operation."
Although focused on chemical weapons destruction, many of the techniques reviewed have application to conventional weapons as well. These technologies include Supercritical Water Oxidation (SCWO), DAVINCH (Detonation of Ammunition in a Vacuum-Integrated Chamber), Hot Detonation Chambers, and Detonation Chambers.
In many cases, resource recovery can be more cost effective than incineration. In 2001, the Department of Defense reported that small arms ammunition was demilitarized by a private contractor through a resource recovery methodology at a cost of $1 a ton versus $1,200 to $1,500 per ton for incineration at a government facility.
With the passage of the National Defense Authorization Act in 2007 passage, the Army gained the legal authority to sell recyclable munitions materials resulting from demilitarization and reinvest the proceeds into R3 operations. Proceeds from the reinvestment are estimated at $2-3 million annually.
The new law complimented other existing demilitarization initiatives -- the Demil Research and Development Program which focuses on disassembly and reusing existing munitions and Design for Demil which seeks to influence future munitions design for easier disassembly.
While capabilities exist to deal with most surplus munitions, new energetic materials and new munitions are becoming more and more complex. Before 1990 almost all new munitions had energetics that were TNT based -- today this is rarely so. The increasing variety of energetics will increase both the difficulty and cost of disposal.
Anniston Army Depot final HWP 2007 updated 2011 (AL)
Bluegrass Army Depot RCRA Permit Mod Request 2014 (KY)
Bluegrass Army Depot Title V Permit Renewal Application 2010 (KY)
China Lake Naval Air Weapons Station Permit_11-16-2010 (CA)
Colfax Clean Harbors 2007 permit from EPA website (LA)
Colfax Clean Harbors Draft Modified Haz Waste Permit 2015 (LA)
Colfax Clean Harbors Class 3 Permit Mod Request NOD #2 2015 (LA)
Colfax Clean Harbors RCRA Subtitle C Site ID Form 2014 (LA)
Crane Naval Surface Warfare Center Title V Permit (IN)
Edwards Air Force Base APPLICATION Part B EOD Range (CA)
Hawthorne Army Depot RCRA Permit 2013 (NV)
Hawthorne RCRA Permit Renewal Fact Sheet (NV)
Holston Army Ammunition Plant Mod 1 (A-1009) 12072015-1 (TN)
Holston Army Ammunition Plant Title 5 Operating Permit 558406 (TN)
Holston OBOD Permit TNHW-148 w response to comments (TN)
Iowa Army Ammunition Plant Title V Permit 2012 (IA)
Letterkenny Army Depot NPDES permit OB OD grounds (PA)
McAlester Army OB OD Deactivation Oven Permit 2013 (OK)
Radford AAP Corrective Action Permit Application 2015 (VA)
Radford AAP Open Burning 2013 Permit (VA)
Red River Army Depot Hazardous Waste Permit 2012 (TX)
Redstone US Army Garrison 2016 Emergency Permit OB OD (AL)
Redstone US Army Garrison OB OD 2010-20 final permit (AL)
Tooele Army Depot Permit Attachment 6 OB OD Static Fire (UT)
… still posting
40 CFR 265.382 -- Open burning; waste explosives
CEASE FIRE References for webpage 2015
Conventional Munitions Legacy Packet