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
|
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
|
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