Holston smoke from open burningCSWAB has asked the U.S. Environmental Protection Agency (EPA) to determine if contaminants discovered  at the former Badger munitions site in Wisconsin could also be present at Tennessee’s Holston Army Ammunition Plant near Kingsport.

In a July 20 letter to the PCB Coordinator for EPA Region 4 in Atlanta, Georgia, CSWAB asks officials if wastes subjected to open burning or thermal treatment at Holston are tested for PCBs (polychlorinated biphenyls), asbestos and other federally-regulated substances.  (Photo: Emissions from open burning at Holston.)

In 2003, Army testing at the Badger Army Ammunition Plant in Wisconsin revealed that paint on buildings, pipes, tanks and other applications had PCB concentrations as high 22,000 parts per million (ppm) – more than 400 times the federal threshold of 50 ppm. The discovery of regulated levels of PCBs in wastes at Badger halted a proposal to burn more than 1,300 excess buildings as part of the base closure process.

Open burning of PCB-contaminated wastes not only causes the uncontrolled release of PCBs, it disperses 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.

In 2006, after extensive multi-program discussions, EPA Headquarters confirmed that the burning of buildings with regulated levels of PCBs was prohibited and could not be approved pursuant to the Toxic Substances Control Act (TSCA). Ultimately, TSCA/PCB issues and local citizen opposition stopped the Army’s plans for open air burning in Wisconsin. Instead, buildings were treated using a non-thermal approach, preventing the uncontrolled release of pollutants to the environment.

There are three main types of wastes that are burned at the Holston plant, according to Army reports. The first is bulk raw explosives that have become contaminated through contact with the manufacturing floor or out-of-spec product unsuitable for use or reprocessing. This waste is burned normally each week in open burn pans.

The second type of waste consists of explosives-contaminated small articles such as plastic bags, paper towels, filters, personal protective equipment, and dewatering filter socks. This material is placed in a steel cage and is generally burned once a week even though it is permitted daily.

The third type of waste is large articles that may be contaminated with explosives and includes various materials, piping from buildings, process vessels, building demolition material including concrete, and possibly soil surrounding these areas. This material is placed in large piles at the burning ground, according to Army contractor reports.

If comprehensive analysis for TSCA-regulated substances has not and is not being conducted at Holston, CSWAB has recommended that all open burning, thermal treatment and heating of wastes be suspended until the Army can demonstrate full compliance with applicable federal regulations.

“As the regulatory agency responsible for enforcing TSCA regulations, we are requesting EPA’s assistance in assuring that open air burning and thermal treatment of explosives-contaminated wastes at Holston are in compliance with these regulations,” said Laura Olah, Executive Director of CSWAB. “Tennessee regulators that we contacted were not aware of any such testing at Holston.”

PCBs are the only chemical class specifically named in TSCA because Congress recognized that the chemical and toxicological properties of PCBs pose a significant risk to public health and the environment. TSCA also provides for the regulation of asbestos.

CSWAB Holston EPA TSCA Inquiry CSWAB July 2015