FACT SHEET: Open Burning at Ravenna Arsenal

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Additional Information and Discussion Concerning the Ravenna Arsenal Burn

Introduction and Purpose of this Paper

As you can imagine there is much apprehension and fear in our communities about the Arsenal proposal. To this point inadequate information and misdirection haven’t helped. We hope that this additional information will be considered by the regulatory agencies concerned, the local, state and national leaders as well as give the community a clearer picture of events.

The Site

The Ravenna Army Ammunition Plant is a 21,4l9 acre compound 3.5 miles wide and 11 miles long located in N.E. Ohio. Several townships, Charleston, Freedom, Paris, Windom, Braceville and Newton surround the arsenal. Incorporated communities are also in close proximity. These include Ravenna, Windom, Newton Falls and Warren, Ohio. If all factors are included, over 30,000 people could be put in harms way by events at the Arsenal.

The Problem

There are many areas of concern at this facility. This discussion is concerned only with the 8 load lines used during WW II, Korea and Vietnam to produce munitions All of the load lines are thought to contain unexploded ordinance (UXO) and other contaminants including:

Lead Azide- Pb(N3)2 -Primer material
Lead Styphnate- 2,4,6-dinitrobenzene- 1,3-diol-lead salt -primer material
Black Powder-75%Potassium Nitrate, 15% Charcoal, 10% Sulfur. Primer material and explosive
Tetryl-2,4,6-trinitrofenil-nmetilnitramina
PETN-Pentaerythritoltetra nitrate
Nitroguanidine- l-rnethyl-l-nitroso-3-nitro guanidine. Explosive
Nitro Cellulose-Nitric acid ester of cellulose. Gun Cotton. Explosive
Nitroglycerine-Glycerol Trinitrate. Explosive
TNT-2,4,6 trinitrotoluene. Explosive
RDX-Hexahydro-1,3,5-trinitro-1,3,5-triazine. (Cyclonite)
HMX-Octahydro-l,3,5,7-tetra nitro-l ,3,S,7-tetrazocine.(High melting explosive)
Ammonium Nitrate-NH4N03
Aluminum Chloride-A1Cl3
Compound B

Prior to turning over control of these areas to the National Guard, the Army Corps of Engineers is responsible for eliminating all UXO and tearing down the structures. After these structures are removed any ground contaminants must be addressed. During this process the safety of the workers must be protected.

In addition, paint that covers about 60% of these buildings surface contain PCBs. The amount ranges from 37 parts per million (ppm) to over 14,000 ppm. The EPA limit for open burning is 50 ppm. This is the exemption being applied for.

MKM’s Solution

MKM Engineering has been employed by the Army Corps of Engineers as a performance based contractor to solve the problem. Their purpose is twofold.

1. To protect workers from explosive detonation.

2. To test air quality to legitimize this technology for future operations.

Their solution is to fill the buildings concerned with wood dunnage, soak that dunnage with diesel fuel, and ignite it. This would be done electronically from a safe distance. Several heat sensors would be placed throughout the structures ensuring that temperature and duration would be sufficient to neutralize all UXO. MKM would also place several particle-catching instruments to measure air quality during the burn. Also a fire brake line and local fire departments would be present to ensure that the compound does not catch fire.

The Problem with the Solution

Load line 11 has been selected for the test burn. The 10 buildings to be ‘thermally treated’ have been filled with up to 9,000 pallets. MKM has assured the EPA that only new kiln dried pallets are to be used. An investigation of the local companies that sold pallets to the arsenal revealed that used and scrap pallets were bought. Further, these pallets were not kiln dried. One company that declined to sell to the arsenal expressed concern that Chinese and German pallets might have been included in scrap piles The owner related that these pallets are chemically treated before being shipped overseas Regardless of the wood involved there is a substantial risk from wood burning.

The tables included in this paper were taken from a 1993 EPA report, A Summary of the Emissions Characterizations and Noncancer Respiratory Effects of Wood Smoke. This document EPA-453/R-93-036 can be ordered from the EPA at 919-541-5344. The tables break down the chemical composition of wood smoke in grams per kilogram of fuel burned, g/kg. There are two values expressed, a high and a low, that cover a wide range of woods tested in this study. To make these tables relevant to the test burn, three additional values were added, total grams, ounces and pounds. Taking 9,000 pallets at a weight of 15kg each (a light weight by industry standards) gives a total dunnage weight of 135,000 kg. Taking this figure 135,000 and multiplying g/kg gives the total weight of each chemical produced in grams. Dividing this figure by 28 gives the total weight in ounces. Dividing the total ounces by 16 yields tie total pounds. For example, Carbon Monoxide g/kg 80 X 135,000=10,800,000 grams divided by 28=385,000 ounces divided by 16 = 24,107 pounds. Scientific notation used in the study was expressed as a decimal.

Chemical Composition of Wood Smoke

Species/Chemical g/kg Total grams Total oz. Total pounds
Lupe none .002

.008

270

1,080

9.6

38.6

2.4
Friedelin
.000004

.00002

0.5

2.7

Chlorinated Dioxins .00001

.00004

1.4

5.4

Particulate Acidity .007

.07

945

9,450

33.8

338

2.1

21

Carbon Monoxide 80

370

10,800,000

49,950,000

385,714

1,783,928

24,107

111,495

Methan 14

25

1,890,000

3,375,000

67,500

120,536

4,219

7,534

VOC’s 7

27

945,000

3,645,000

33,750

130,179

2,109

8,136

Aldehydes 0.6

5.4

81,000

729,000

2,893

26,036

181

1,627

Formaldehyde 0.1

0.7

13,500

94,500

482

3,375

30

211

Acrolein 0.02

0.1

2,700

13,500

96

482

6

30

Propionaldehyde 0.1

0.3

13,500

40,500

482

1,446

30

90

Butryaldehyde 0.01

1.7

1,350

229,000

48

8,196

3

512

Acetaldehyde 0.03

0.6

4,050

81,000

145

2,893

9

181

Furfural 0.2

1.6

27,000

216,000

964

7,714

60

482

Substituted furans 0.15

1.7

20,250

229,500

723

8,196

45

512

Benzene 0.6

4.0

81,000

540,000

2,893

19,286

181

1,205

Alkyl Benzenes 1.0

6.0

135,000

810,000

4,821

28,929

301

1,808

Toluene 0.15

1.0

20,250

135,000

723

4,821

45

301

Acetic acid 1.8

2.4

243,000

324,000

8,679

11,571

542

723

Formic acid 0.06

0.08

8,100

10,800

289

386

18

24

Nitrogen oxides

(NO)(NO2)

0.2

0.9

27,000

121,500

964

4,339

60

271

Sulfur Dioxide 0.16

0.24

21,600

32,400

771

1,157

48

72

Methyl Chloride 0.01

0.04

1,350

5,400

48

193

3

12

Napthalene 0.24

1.6

32,400

216,000

1,157

7,714

72

482

Substituted Napthalenes 0.3

2.1

40,500

283,500

1,446

10,125

90

633

Oxygenated Monoaromatics 1.0

7.0

135,000

945,000

4,821

33,750

301

2,109

Guaiacol 0.4

1.6

54,000

216,000

1,929

7,714

121

482

Phenol 0.2

0.8

27,000

108,000

964

3,857

60

241

Syringol 0.7 94,500 3,375 211
Catechol 0.2 27,000 964 60
Total particle mass 7.0

30.0

945,000

4,050,000

33,750

144,643

2,109

9,040

Particulate Organic Carbon 2.0

20.0

270,000


2,700,000

9,643

96,429

603

6,027

Oxygenated PAHS 0.15

1.0


20,250

135,000

723

4,821

45

301

Polycyclic Aromatic Hydrocarbons PAH
Fluorine .00004

0.17

5.4

2,295

82 5
Phenanthrene .00002

.034

2.7

4,590

164 10
Anthracene .00005

.000021

6.8

2.8

Methylanthracenes .00007

.00008

9.5

10.8

Floranthene .0007

.042

94.5

5,670

3.4

203

12.7
Pyrene .0008

0.31


108

4,185

3.9

149.5

9.3
Benzo(a) anthracene .0004

.002

54

270

1.9

9.6

Chrysene .0004

.01

5.4

1,350

48 3
Benzofluoranthenes .0006

.005

81

675

2.9

24

1.5
Benzo(e)pyrene .0002

.004

27

540

.9

19

1.2
Benzo(a)pyrene .0003

.005

40.5

675

1.4

24

1.5
Perylene .00005

.003

6.8

405

14.5
Ideno(1,2,3-cd)pyrene .0002

.013

27

1,755

.9

63

4
Benz(ghi)perylene .00003

.011

4

1,485

53 3.3
Coronene .0008

.003

108

405

3.9

14.5

Dibenzo(ah)pyrene .0003

.001

40.5

135

1.4

4.8

Retene .007

.03

945

4,050

33.8

145

2.1

9

Dibenz(ah)anthracene .00002

.002

2.7

270

9.6
Trace Elements
Na .003

.018

405

2,430

14.5

86.8

5.4
Mg .0002

.003

27

405

9

14.5

Al .0001

.024

13.5

3,240

116 7.2
Si .0003

.031

40.5

4,185

1.4

149

9.3
S .001

.029

135

3,915

4.8

140

8.7
Cl .0007

.021

94.5

2835

3.4

101

6.3
K .003

.086

405

11,610

14.5

415

26
Ca .0009

.018

121.5

2,430

4.3

87

5.4
Ti .00004

.003

5.4

405

14.5
V .00002

.004

2.7

540

19 1.2
Cr .00002

.003

2.7

405

14.5
Mn .00007

.004

9.5

540

19 1.2
Fe .0003

.005

40.5

675

1.4

24

1.5
Ni .000001

.001

0.1

135

4.8
Cu .0002

.0009

27

121.5

9

4.3

Zn .0007

.008

94.5

1,080

3.4

38.6

2.4
Br .00007

.0009

9.5

121.5

5.3
Pb .0001

.003

13.5

405

14.5
Particulate Elemental Carbon 0.3

5.0

40,500

675,000

1,446


24,107

90

1507

Normal Alkalines (C24-C30) .001

.006

135

810


4.8

29

1.8
Cyclic di and triterpenoids
Dehydroabietic acid
0.01

0.05


1350

6750

48

241

3

15

Isopimaric acid
0.02

0.10


2700

13,500

96

482

6

30

Ohio’s Open Burning Regulations

Before You Light It…
Know Ohio’s Open Burning Regulations

Ohio EPA
Lazarus Government Center
122 S. Front St.
Columbus, Ohio 43215

When you burn trash outdoors, the potential cost to your health, your home, your neighbors, and your environment far exceeds the price of adequate collection services. Protect yourself, your neighbors, and your wallet by knowing the rules–what you can burn and where. And remember, there are alternatives to open burning.

What does Ohio EPA consider “open burning”?

You are open burning any time you light an outdoor fire. In the past, many materials–including leaves, tree trimmings, tires, and construction debris–were routinely burned outdoors.
Why do Ohio’s laws prohibit so many kinds of open burning?

Depending upon the material being burned, open fires can release many kinds of toxic fumes. Leaves and plant materials send aloft millions of spores when they catch fire, causing many people with allergies to have difficulty breathing. The pollutants released by open burning also make it more difficult to attain, or maintain, health-based air quality standards, especially in or near the major metropolitan centers. The gases released by open burning can also harm neighboring buildings by corroding metal siding and damaging paint. Besides, open burning is not a very efficient way to get rid of wastes since open fires do not get hot enough to burn the materials completely.

What materials can never be burned?

Some materials may not be burned anywhere in the state at any time. These are:

•  materials containing rubber, grease, and asphalt or made from petroleum, such as tires, cars and auto parts, plastics, or plastic-coated wire;
•  garbage–any wastes created in the process of handling, preparing, cooking, or consumption of food; and
•  dead animals.

Additional problems with the Solution

There are 121 buildings at RVAAP that are believed to contain UXO. Only 10 of these are to be thermally treated at the test burn. With at east 111 more buildings to be burned at future times (presumably with more wood dunnage) one begins to get some idea of the incredible amount of pollutants this area would be subjected to. Several of these materials would, most likely, violate EPA standards for air quality. There is another problem with some of these buildings.

Some of the fuse load lines contain anti-static flooring. This material was necessary during production because of the danger of static electricity detonating fuse explosives. The material used back in the 40s was rubber or a synthetic rubber based material. It was not uncommon to include asbestos as a fire retardant. Some of these buildings are rather large and the flooring one half inch thick or better. This could add several tons of material to the already intimidating list of pollutants As far as the Ohio EPA is concerned this material can never be open burned. See attached paper.

Air Testing

MKM is to test air quality during the burn. To do this, particle-catching instruments will be placed inside the compound. There are, as I understand it, no plans to place them anywhere else. The considerable updraft created by burning nearly 150 tons of wood should place the bulk of the materials several hundred feet in the air, into the prevailing winds, and beyond the Arsenal’s boundaries. What little is learned by this approach, most likely, will be further handicapped by the limited amount of pollutants being tested for.

Air Dispersion Modeling

During the first two test burns (Lls 6 and 9) no air dispersion modeling was done. A perfect opportunity to study this “technology” was missed. If air dispersion modeling is used this time it would most likely be a single source Gaussian dispersion model. This computer model must have reliable data to accurately predict a level of concern of a threshold concentration of an airborne pollutant. There are many other models as well but all depend on good input data. What little input data there is would be handicapped by a number of variables.

1. MKM’s prior lack of testing.

2. The unknown quantities of explosives and other contaminants.

3. Explosions. This would make plume shape and area dispersal difficult or impossible to predict.

4. Weather variables of N.E. Ohio.

5. The variation of specific gravity, polar attraction, and particle size of the large number of constituents.

6. Buildings, trees, topography, highways, and bodies of water that would affect dispersion.

7. The oversimplification in risk assessment and testing to this point would indicate a similar approach to air dispersal modelin

8. We won’t know what the internal structure of this fire is until it happens, if then.

Alternative Technologies

Water Demolition

This technology has been approved for the Badger AAP. Doug Rubingh of Shaw Environ­mental and Infrastructure has stated that there is no risk of explosion and conventional equipment can be used. Two Army explosive experts have also endorsed the methodology.

Robotics

MKM has said this is not an option. However, in concert with other technologies it could have a place at Ravenna.

Other Technologies

In a country that leads the world in technological development and application it is hard to believe that thermal decomposition is the only method that would work at RVAAP. We would encourage MKM to be in communication with Shaw Environmental and other contractors to develop appropriate technologies. Clearly, although safe for workers, thermal decomposition is a very bad choice for the Arsenal’s neighbors. A very good choice would protect both workers and community.

Conclusions

Thermal decomposition would throw literally thousands of pounds of pollutants into the air. The PCBs (51 pounds) in the buildings would undergo chemical reaction and turn some of this material into Dioxins and Furans. These chemicals are a hundred times more toxic than PCBs — a bad trade for us. Since these compounds attack at the cellular level people with high body loads and children, whose biological systems are still developing, are at great risk. No risk assessment can be valid without considering existing levels of chemicals in the population being evaluated. MKM’s risk assessment assumes no other dioxins would be formed other than from the PCBs. They also do not consider existing body loads.

We know that aluminum chloride and sodium chloride would be present. The additional chlorine atoms would be available for dioxin formation in the burn. The burning wood itself would form some dioxin. The EPA report puts dioxin production in the burn at 1.4g to 5.4g. A study by Nestrick and Lamparski, Anal. Chem. 54,2292 1982, found much higher dioxin formation. TCDDs ranged from 0.1 to 7.8mg/kg of wood burned. Considering that human risk factors for dioxin are measured in parts per trillion, the total dioxin from the test burn could be very dangerous for our communities.

In Summary

We ask the EPA not to grant an exception to the 50ppm for the open burning of PCBs.
We ask the EPA to evaluate and enforce any violations created by the dunnage.
We ask the EPA to not allow the burning of any anti-static flooring.
We ask the EPA to not grant any open burning permit to the RVAAP.
We ask that existing body loads be included in risk assessment.
We ask that consideration of property values and environmental risk be a part of all actions.
We ask nothing more than the protection of our rights granted by the constitution.
We ask that all Government agencies, political leaders, and citizens not violate this trust.

W.R. Krimmer on behalf of The Citizens Opposed to the Open Burning at the Ravenna Arsenal

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