EPA Region 4 Administrator Mary Walker has rejected CSWAB’s citizen petition for intervention that would prohibit open air burning of PFAS and other hazardous chemicals at Holston Army Ammunition Plant in Tennessee – a practice that constitutes an ongoing imminent and substantial endangerment of human health and the environment. Together with Volunteers for Environmental Health and Justice based in Kingsport, Tennessee, our petition was submitted in July 2019.

We asked that EPA take immediate steps to assure that Tennessee residents and workers are afforded the same protections as other states within Region 4. In November 2018, the Kentucky Department for Environmental Protection expressly prohibited open burning and open detonation of PFAS-contaminated wastes at the Blue Grass Army Depot near Richmond.  Our petition asked that similar limitations be required at the Holston facility in Tennessee.

Administrator Walker’s August 8, 2019 letter promises only that the agency will continue to participate in discussions with Tennessee regulators, rather than use its authority to directly challenge the uncontrolled release of toxic emissions from munitions disposal at Holston – a practice that has persisted for more than 60 years.

In 2012, the U.S. Army at Holston Army Ammunition Plant reported that it expected to generate approximately 120,000-150,000 pounds net explosive weight per year requiring disposal in the burn pans over the next five years; this waste stream included nonconforming plastic bonded explosives which are known to contain PFAS, a group of highly toxic chemical compounds.

Our petition emphasized that open burning could result in air deposits of PFAS onto soil and surface water, which could readily migrate to groundwater.

According to federal health officials, exposure to PFAS may affect growth, learning, and behavior of infants and older children, interfere with the body’s natural hormones, affect the immune system, and increase the risk of cancer.

CSWAB VEHJ Citizen Petition EPA Region 4 Open Burning PFAS July 2019
EPA Region 4 Admin Response to Citizen Petition CSWAB VEHJ August 2019

Photograph: Open burning of hazardous waste at Holston Army Ammunition Plant in Kingsport, Tennessee.