Please join California Communities Against Toxics and Citizens for Safe Water Around Badger (CSWAB) in calling for a national BAN on open burning PFAS and hazardous munitions wastes.

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President Joe Biden
The White House
1600 Pennsylvania Avenue
Washington DC 20460

Michael Regan, Administrator
United States Environmental Protection Agency
1200 Pennsylvania Ave
Washington DC 20460

June XX, 2024

RE: Banning the Open Air Burning of PFAS and Hazardous Munitions Wastes

Dear President Biden and Administrator Regan,

The open burning of hazardous waste must end.  Americans, especially our nation’s veterans, are keenly aware of the dangers of this practice, yet the Environmental Protection Agency (EPA) and the Department of Defense (DOD) are still allowing it to occur at over 60 sites across our nation. This Administration has the opportunity to end this terribly destructive and damaging practice, and we are urging you to act now.

When EPA adopted the regulations implementing the Resource Conservation and Recovery Act (RCRA), which was designed to protect public health and the environment from the nation’s waste, EPA recognized the obvious need to ban the open burning of hazardous wastes. However, at the request of the Department of Defense, EPA allowed a narrow exception for the open burning/open detonation of explosive hazardous wastes only until safe alternatives could be found…that was nearly a half century ago

Today, advanced treatment technologies to replace OB/OD are available and in use, and have been, for many years.  A coalition of communities living near these sites asked EPA to issue a new rule banning this archaic practice. Instead, EPA has now proposed a rule that, while including certain minimum necessary requirements, does not ban the open burning of hazardous waste or adequately protect human health and the environment.

Disappointingly, the agency’s proposal even envisions new loopholes that will only serve to perpetuate the serious pollution problems communities face. For example, EPA threatens to exempt certain types of hazardous waste incinerators­ from longstanding necessary pollution protections promised by RCRA and the Clean Air Act. It is crucial to transition from open burning to safe and controlled treatment technologies, but communities cannot be forced to accept deregulated and dangerous hazardous waste incinerators as the solution.

Insensitive munitions contain large amounts of PFAS chemicals.  Increasingly, the munitions manufactured by the U.S. are insensitive munitions.  These munitions should not be open burned or incinerated since these types of thermal treatments are not a proven method of destruction for these highly toxic compounds.  There are advanced treatment methods available to destroy these compounds and both EPA and the DOD should be looking to implement these for PFAS destruction.

Open burning of hazardous waste spews toxic fumes into the open air, putting workers, communities, and the environment at serious risk. The remediation costs from contaminated soils and groundwater at open burn sites now runs into the billions of dollars. Many sites have extensive contamination that is very costly to remediate and presents threats of serious public health and environmental harm.

We urge you to simply ban the open burning of hazardous waste and reject the creation of any new regulatory loopholes. It is within your authority to do so and incentivize use of better, modern technologies, and it will save our nation the heartbreak of further damaging the environment and health of communities, including our nation’s service members, from exposure to toxic pollution.

Sincerely,
As noted above, to add your group please fill out this FORM.

Co-signers so far include…
California Communities Against Toxics Rosemond CA
Citizens for Safe Water Around Badger (CSWAB) Merrimac WI
Climate Action Campaign at the Humboldt UU Fellowship Bayside CA
CODEPINK Bay Area Berkeley California
Cosmic Poetry Sanctuary Vancleave MS
Grassroots Environmental Education Port Washington New York
Common Ground Rising Albuquerque New Mexico
Rachel Carson Council Bethesda Maryland
Air Alliance Houston Houston TX
Pennsylvania Interfaith Power & Light Lancaster PA
Environmental Justice Ministry Cedar Lane Unitarian Universalist Congregation Bethesda Maryland
7th Generation Advisors Los Angeles California
Putnam Progressives Putnam N.Y.
Vote Climate Minneapolis MN
Greenpeace USA Washington DC
Beyond Plastics Bennington Vermont
Endangered Species Coalition Litchfield ME
Plastic Pollution Coalition Washingtion DC
Turtle Island Restoration Network Galveston Texas
Don’t Waste Arizona Phoenix Arizona
The Last Plastic Straw Aguadilla PR
The Revolving Door Project New York New York
EIP Austin Texas
Earth Action, Inc. Fort Walton Beach Florida
Milwaukee Riverkeeper Milwaukee WI
Cease Fire Campaign Merrimac WI
The Quantum Institute Glovesville New York
The Story of Stuff Project Berkeley California
Human Nature Petrolia california
Earthjustice Washington D.C.
Wisconsin Resources Protection Council La Crosse Wisconsin
Animals Are Sentient Beings, Inc Watertown Massachusetts
Unitarian Universalist Environmental Justice Ministry Chevy Chase Maryland
Project Outreach: The Frac Sand Sentinel Chippewa Falls Wisconsin
Westfield Residents Advocating For Themselves Inc (WRAFT) Westfield MA
Alaska Community Action on Toxics Anchorage Alaska
Therapists for Peace & Justice Oakland CA
Terra Advocati San Antonio Texas
Beaverdam Creek Watershed Watch Group Greenbelt MD
Breathe Project Pittsburgh PA
Plastic Free Future Pacifica California
FreshWater Accountability Project Grand Rapids OH
Moms Clean Air Force Washington, DC and National DC
WaSaTiBlockclub Detroit Mi
Sierra Club Detroit MI
Buckeye Environmental Network Columbus OH
Vessel Project of Louisiana Sulphur Louisiana
Valley Watch, Inc. Evansville IN
SEE (Social Eco Education) Los Ángeles County Ca
EcoMadres Washington, DC National
Micah Six Eight Mission Sulphur Louisiana
Californians Against Waste Sacramento CA
Institute for Local Self-Reliance Washington DC
Climate Reality Massachusetts Southcoast Fairhaven MA
Clean Air Action Network of Glens Falls Glens Falls NY
Vidas Viequenses Valen Vieques Puerto Rico, 00765
RootsAction.org Sacramento California
Sustainable Tucson Tucson AZ
GreenRoots Chelsea MA
Kentucky Environmental Foundation Berea KY
Cherokee Concerned Citizens Pascagoula Mississippi
Physicians for Social Responsibility/Florida Tampa Florida
MoveOn.org HobokenRESIST Hoboken New Jersey
West Plains Water Coalition Spokane Washington
Zero Waste Washington Seattle WA
Carrizo/Comecrudo Tribal Nation of Texas Floresville TX
Protect All Children’s Environment Chapel Hill North Carolina
350 Seattle Seattle WA
Center for Public Environmental Oversight Mountain View California
Cherokee Concerned Citizens Pascagoula Mississippi
Mossville Environmental Action Now MEAN Lake Charles Louisiana
Texas Campaign for the Environment Austin TX
Zero Waste Ithaca | BYO – US Reduces Ithaca New York

As noted above, to add your group please fill out this FORM