Open Burning and Thermal Treatment of Munitions-Contaminated Wastes
Campaign Status Report
Beginning in 2000, the Army began pressing for approval to burnundreds of old buildings at Wisconsin’s Badger Army Ammunition Plant – a proposal hat even the military admitted was not “environmentally friendly”. The Army reported that open burning of explosive-contaminated structures produces toxic emissions including “nitrous oxide, carbon monoxide, asbestos, lead vapors, lead particulates, zinc, polyaromatic hydrocarbons, and dioxins”.
During an open burn, the Army said that “materials are changed from a solid form and are released to the atmosphere where they will certainly be deposited over a large area resulting in contamination of soil and surface water. This method poses several potential risks including:
- Potential risks to workers posed by the inhalation of vapors and fugitive particulates during the burning of the building
- Potential risks to personnel and others who may be exposed to air borne vapors and dust generated during burning
- Potential risks to both human receptors and environmental receptors from the deposition of air borne particulates; these deposited materials could affect both soil and surface water bodies in the area surrounding the burn site.”
Moreover, the proposed open burning directly contradicted the goals established for environmental cleanup by the Badger Reuse Committee, an independent advisory group representing community and government. Committee members unanimously agreed that cleanup and future use should “not contaminate nor pose the threat of additional contamination of the Badger property”.
Despite all these considerations, the Army said that open burning was the only viable solution. The potential explosive hazards, it said, were too great to even consider alternatives. Despite a prolonged and tireless campaign by CSWAB, the Wisconsin Department of Natural Resources (WDNR) agreed with the Army and approved open burning at Badger.
At the same time, CSWAB appealed to the U.S. Environmental Protection Agency (EPA) to intervene. We believed that the state’s risk assessment seriously underestimated risks to human health and the environment particularly because it only evaluated cancer risks to adults through inhalation. We maintained that assessment of risks to children and risks associated with other routes of exposure were required by federal law.
PCBs in Paint
In 2002, the Army first reported that high levels of PCBs (poly-chlorinated biphenols) had been detected in paint in buildings at concentrations of more than 400 times the federal threshold. As the agency responsible for regulating this highly toxic substance, EPA’s involvement escalated. Open burning would not only cause the uncontrolled release of PCBs, it would disperse dangerous levels of dioxins and furans to the environment – toxins that are known to accumulate in the food chain and cause birth defects in humans and animals.
CSWAB maintained that if the EPA approved open burning of regulated levels of PCBs that it would set a dangerous national precedent. The agency agreed and the decision was referred to EPA headquarters in Washington, DC.
During the 3 years that EPA considered the Army’s proposed open burning of PCB-contaminated buildings, CSWAB organized a strong national campaign opposing open burning that garnered support from more than 160 organizations. We traveled to Washington to meet with federal
legislators and EPA headquarters, to Chicago to meet EPA officials there, and submitted dozens of Freedom of Information requests.
Our members sent in more than 1,400 postcards to the EPA, thousands of emails were sent to legislators, EPA officials, and the WDNR. National and local media attention – radio, television, and print – raised the visibility of the issue and our campaign.
With support from community members and private foundations, we hired an internationally-known expert on dioxins. We built and strengthened alliances with communities near other bases including the Ravenna Arsenal in Ohio, Indiana Army Ammunition Plant, Sunflower Army
Ammunition Plant in Kansas, and others. Community members there helped to organize grassroots support for our shared campaign to protect human health and the environment.
Burning Stops Everywhere
During these same 3 years, burning of buildings at Army facilities everywhere stopped while the EPA considered its decision. Army officials at Badger were among the first to explore non-thermal
solutions and sought approvals for “wet demolition” of explosives-contaminated buildings. Already 92 buildings that were originally slated for burning have been successfully decontaminated and demolished using non-thermal solutions.
The Army at Ravenna abandoned plans to burn more than 100 buildings. At Iowa Army Ammunition Plant, the Army used chemical neutralization instead of burning to desensitize contaminated buildings. The Army utilized indirect heat to treat explosives-contaminated buildings
(without PCBs) at Twin Cities Army Ammunition Plant.
Clearly, open burning was no longer the only viable solution.
EPA Makes a Decision
On August 22, 2006, more than 5 years after CSWAB first started its campaign, EPA Headquarters announced its decision to prohibit the military from open burning regulated levels (above 50 parts per million) of PCBs. Army officials were notified of the determination by telephone
and a formal decision document is currently being prepared. While this is an incredibly important decision in terms of the health of workers, community members, and our environment, there are still a number of issues that remain unresolved.
Burning and Thermal Treatment Still Planned
While EPA has determined that “open burning” (direct contact with flames) of regulated levels of PCBs is not allowable under current law, this decision does not prohibit “thermal treatment” (indirect
heat/incineration) of PCB-contaminated military wastes and buildings. Temperatures as low as 80° F can liberate PCBs to the air. Dioxins and furans – which are highly toxic to the developing fetus, infants and children – are readily formed at temperatures as low as 200°F. The Army is considering “thermal treatment” of PCB wastes at temperatures ranging from 400° to 1,200°F.
The U.S. Army Construction Engineering Research Lab (CERL) in Champaign, IL is currently conducting a laboratory study of potential emissions from PCB painted items that would be placed in the decontamination oven at Badger Army Ammunition Plant. “We are using actual paint samples from Badger, at the temperatures used in the oven. We don’t know what the final answers will be as we believe this is new scientific ground,” CERL officials told CSWAB. The final report should be finished before the end of the year.
Moreover, the military can and has successfully challenged decisions by both state and federal environmental regulators to restrict thermal treatment of military toxins. Officials at Badger confirmed that the Army may appeal the EPA’s decision restricting open burning of
Changing National Policy
Open burning of hundreds of buildings is still proposed for Sunflower Army Ammunition Plant (Kansas), Indiana Army Ammunition Plant, the Savanna Army Depot in Illinois, and other bases. Because PCB concentrations at these other sites are below federal thresholds, the
recent EPA decision does not protect these communities.
CSWAB is joining local community and tribal members in calling on the Army to formally withdraw open burning and thermal treatment plans in favor of safe non-thermal alternatives. If we are successful, we will set a national precedent which will provide the momentum for national policy change and help protect communities everywhere.