On November 16, the Army made a presentation to officials with the U.S. Environmental Protection Agency (USEPA) and Illinois EPA outlining a proposal for thermal treatment of 10 buildings at the Savanna Army Depot in Illinois – an alternative to the Army’s long-standing practice of torching old buildings.
The draft proposal is to use hot air to desensitize potential explosive residues found in old buildings constructed of steel, wood, and tile block. Temperatures ranging from 200 to 600 degrees Fahrenheit are required to eliminate potential explosive risks or a 5X designation by the military. The treatment is to assure that buildings are safe for reuse or transfer to new owners. According to Army officials, indirect heat will be provided by propane heaters or other similar source.
While activities inside buildings are not regulated by the USEPA, activities that could cause a release to the environment are regulated under CERCLA (Superfund) and other federal environmental law. Heating of buildings and roofing materials, for example, could result in the release of volatiles to the air and would then be subject to state and federal regulation.
A similar method was used to desensitize several buildings at the Twin Cities Army Ammunition Plant in Minnesota. According to Army officials there, final approvals by the military’s Explosives Safety Board are still pending.
Regulated levels of PCBs are not believed to be present in paints in the buildings at the Savanna facility, USEPA officials said. High levels of PCBs have been found in paints on pipes, equipment, and buildings at other military installations including the Badger Army Ammunition Plant in Wisconsin and the Ravenna Arsenal in Ohio.
Open burning results in the uncontrolled release of dioxins, lead, and other toxins to the surrounding environment, prompting the military to explore alternative solutions. At the Badger plant, hundreds of buildings that were previously slated for open burning have been safely taken down using conventional demolition methods. At the Ravenna site, chemical neutralization and demolition will be used in lieu of burning.
Only one Army base – the former Sunflower Army Ammunition Plant – is actively using open burning to desensitize old buildings and infrastructure. Recently transferred to new owners, Sunflower Redevelopment LLC is currently seeking exemptions to Kansas environmental law to burn many as 110 buildings. From 1995 to 2005, the Army burned approximately 1,490 explosives-contaminated buildings and structures during 142 events. Debris, including asbestos from shingles, was carried up to three miles off-site and affected nearby residential areas.
A draft work plan for hot air treatment of buildings at Savanna is expected within the coming months and will be reviewed by both the USEPA and the Illinois EPA. CSWAB is currently pressing regulators for opportunities for public comment and independent technical review of the proposal.