Screen Shot from "EPA cleanup - what's the public's right to know?" shows a photo of Radford Arsenal's Open Burning Ground by EPA used by WDBJ7 and obtained from the Environmental Patriots of the New River Valley via a Freedom of Information Act request. I originally posted this piece at 7:09 PM on 5/23/14 and updated it at 2:36 PM on 5/24/14 to clarify that it was the New River Environmental Patriots which obtained the EPA report and provided it to WDBJ7 as indicated by
If you use public or well water in the New River Valley or breathe the air, your health may be compromised by the Radford Army Ammunition Plant in Pulaski and Montgomery Counties (not Radford, as indicated at the link by the Virginia Department of Environmental Quality: cities are independent in Virginia.) Despite Army's plan to clean up the plant, it operates open burning grounds and dumping into the New River in karst terrain.
In the past local media acted as a megaphone for the arsenal. That's changing
Read first, this 2010 Roanoke Times Report report by Laurence Hammack, which while it included some information on the pollution, led with praise by environmental regulators. (He's usually better at investigating: consider his award winning coverage of supermax prisons).
Compare it with the special report by Orlando Salinas at the CBS affiliate, WDBJ7 which reported that the EPA issued a unique permit as a way to protect the economic development of the facility instead of the Superfund permit warranted by the EPA's own investigation.
At Citizens' Request, the CDC is studying pollution by the Arsenal
The deadline to comment is tonight. I'll put up more particulars later, but I wanted to provide folks with sample letters from Palmer-Oberlender and Gregory Nelson of the Environmental Patriots of the New River Valley (EPNRV) with their public comments to the Center for Disease Control Agency for Toxic Substances and Disease Registry (ATSDR) on a health consultation study which leaves much to be desired. Both invite you to cut and paste or otherwise adapt their letters found at the bottom of this entry, if you'd like to go on record. Please send something before midnight to:
ATSDRRecordsCenter@cdc.gov
Use Radford Army Ammunition Plant Comments as the subject with the facility ID VA1210020730 and be sure to include your name and complete address. If you want to cite the exact study, it is "Health Consultation Evaluation of Potential for Chemicals Released to Groundwater or Surface Water to Affect Drinking Water In Nearby Community of the Radford Army Ammunition Plant Radford Virginia EPA Facility ID VA1210020730." If you can't meet that deadline due to the small amount of notice I am providing you might want to ask that the comment period be extended.
The CDC "Let us Down"
Devawn Palmer-Oberlender has been working on this issue since 2006). She has organized other citizens to form EPNRV and reminds us that the Arsenal "has been the largest polluter in the Commonwealth of Virginia for over ten years. Despite this dubious distinction, the facility as currently operated by BAE Systems (whose Chairman of the Board is Michael Chertoff) fails to protect the surrounding community from toxic emissions coming out of the plant daily."
When NRVEP asked the ATSDR for an assessment of exposure they believe they were
"let down" by a decision to fund the study through the Department of Defense and omit data relevant to exposure risk.
She and the group are hopeful that the resignation of ATSDR's Director resulting from conflicts with the contaminated Marines from Camp Lejeune "sets a positive precedent for communities subjected to contamination from military bases to get the kind of thorough, scientific assessment that this agency of the Centers for Disease Control is charged with providing."
She wonders whether "the decades long obfuscation of the facts about our toxic exposure may also be related to the recent Washington Post and NPR reports on the Inspector General having been blocked from investigating certain EPA sites by their heretofore unknown office of homeland security."
A proper study of the arsenal's pollution should monitor perchlorate
Perchlorate is a marker since it is used to produce rocket fuel, fireworks, flares and explosives. Palmer-Oberlender notes that Arsenal burns not only its own waste but that of "Grucci Fireworks and other tenants "who are not producing anything for military use." She calls this "a violation of environmental law and the public trust."
Back in 2008 Barbara Boxer called for perchlorate regulation
Juliet Eilperin, who at the time was reporting on environmental issues for the Washington Post quoted Boxer as saying
Perchlorate has been a serious, persistent and widespread problem which threatens the health of our families, especially our children...For the Bush EPA to walk away from this problem and shrug off this danger is, in my view, unforgivable and immoral.
Perchlorate remains unregulated
While this chemical can disrupt the thyroid’s ability to produce hormones needed for normal growth and development, it is still unregulated by the EPA.
The industry (including Aerojet, American Pacific Corporation, ATK and Lockheed Martin) works "cooperatively" with the U.S. Environmental Protection Agency to try to convince it to keep the chemical unregulated, which in an Orwellian twist it calls increasing "scientific and medical understanding of perchlorate's risk to human health." In addition, it has a website disingenuously called the Perchlorate Information Center to convince the public that perchlorate is not and endocrine disruptor. (Yeah, kind of like how the tobacco industry told us smoking was GOOD for our health.) By the way, I used a no follow link for what should be called the Disinformation Center so as not to boost the page rank in searches.
Stop forcing us to choose between our jobs and health
It's time for some environmental justice here in Appalachia. We too often hear that it's jobs OR health, a choice that we shouldn't have to make.
I've written before on the rhetoric of the coal industry and the so-called War on Coal. It appears that what President Eisenhower called the military-industrial complex is using the same arguments and the EPA took its marching orders. Isn't it time for them to reverse course and shouldn't the Center for Disease Control be helping us provide data on what is at stake.
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Devawn Palmer-Oberlender's Comments on the ATSDR Study
I am very, very concerned for the people that live in our area because the Radford Army Ammunition Plant Assessment did not include test results from the U.S. Army in 2010, confirming that ground water at 16 of 16 test wells across the Main Manufacturing Area (MMA) have significant perchlorate contamination. The sinkholes at the Open Burning Ground (OBG) and other places in the MMA where the perchlorate persists to this day present constitute an identified point source for cross-contamination through the Karst features beneath all of the MMA. Numerous sinkholes identified by the Virginia Dept. Of Mines & Minerals confirms their potential to serve as conduits for toxins to travel into wells off site. These documented sinkholes in the MMA, including those beneath the Open Burning Ground where perchlorate may have been a component in each of the 233 open burns conducted last year alone, are the "smoking gun" that ought to compel ATSDR to require additional well testing. The widespread perchlorate contamination in soil, surface and groundwater, at RAAP according to the U.S. Army and results from private contractors at RAAP over decades, are facts that cry out for a more thorough risk assessment to safeguard our community.
Clearly, the ongoing contamination of groundwater, soil and surface waters by disposal of waste from Grucci Fireworks at the OBG makes the presence of perchlorate in 4 of 5 wells tested by the Sierra Club a significant finding. It is highly unlikely that the private wells tested were contaminated with perchlorate from any source other than the operations at RAAP. A more sensitive test to differentiate whether it is ammonium perchlorate in these private wells would help to delineate the point source. The data are clear and it seems only prudent and in the interest of public safety to recommend that all municipal and private wells in the areas surrounding RAAP be tested to confirm or disprove cross-contamination from RAAP. The Federal Facility which is the source of the contamination has a moral, if not legal, obligation to pay for the testing that will ensure citizens are not subject to drinking their toxic waste as disposed of by open burning to the air we breathe and ultimately "rains out" and into the water our children drink. Please see the attached maps from the HHRA of 2005 illustrating the dispersal pattern and reason for our concern. The attached EPA document on perchlorate as an "emerging contaminant" discusses dispersal through soil and substantiates the likelihood that the perchlrote found in 80% of wells tested around RAAP last year is coming from the production and disposal at the facility.
The findings of CH2MHill in their 2005 assessment of the Open Burning Ground performed for Alliant Techsystems included maps of contaminant distribution which are attached. Perchlorate is known to readily leach from the soil where it falls after each burn. As this and other toxins become part of the GW recharge in this Karst aquifer, the potential for widespread diffusion into wells outside of the RAAP boundary is very real. Please note that the CH2MHill study of the OBG indicates "special receptors" for the particulate matter which are upstream of the intake for the Blacksburg/Christiansburg/VPI Water Authority in addition to numerous points on the river downstream of the OBG.(see River Receptors map). The combination of air dispersal over a wide area and direct deposition into the New River, which serves as a source of drinking water and recreational fishing, is of great concern to our community, especially those using wells and municipal water. (see Receptor Grid map). The source of perchlorate already found in four private wells is likely to be the Radford Arsenal, which can be confirmed with more extensive and accurate testing. Please note the attached EPA guidance document which confirms how perchlorate moves in soil, the association of perchlorate with the production that has taken place at RAAP since 1941 and most importantly, the importance of this ongoing source of perchlorate, barium, aluminum, chromium and other toxins being emitted from the "skid burns" at the Open Burning Ground. It is incumbent upon your agency to assess our risk to exposure through air and the migration of GW off site of the Arsenal. The tests cited in your report confirming perchlorate in 4 of 5 wells tested simply cannot be ruled out as coming from the documented point sources at RAAP without more testing and analysis.
Therefore, we implore your agency to recommend testing of all drinking water wells within a three mile radius of the MMA boundary to rule out this route of exposure. The community in this "impact zone," cannot and ought not be asked to bear the financial burden to test for contaminants from the production and waste disposal processes at RAAP. The Dinitrotoluene isomers, chromium other chemicals included in the permit for the OBG at RAAP are specific to their production and unlikely to have any other source - agricultural or otherwise. The EPA called for this thorough, extensive testing of all DW wells within a two mile radius of EACH contaminated site in 1992, but that testing was never done. The EPA Deficiency Report for the Hazard Rating Score assigned to RAAP in 1992 makes clear that their risk assessors considered this testing essential to an honest characterization of the risk we face from RAAP. Please afford us the testing and complete risk assessment that was called for by EPA over two decades ago and is now warranted given the detection of perchlorate in wells off site of the facility. Independent testing by an EPA certified lab is the only way for your agency to conclude with certainty that perchlorate and other contaminants unique to RAAP have not migrated through the Karst terrain into the 180 plus private and two municipal wells in the exposure zone shown on the maps from the CH2MHill Risk Assessment of 2005.
Money should not be an issue for this Federal Facility to fund the widespread testing required at this site. The private contractor operating the facility, BAE Systems, along with the Department of Defense, who owns the facility and paid for this assessment, have the resources at their disposal to finance the testing that will rule out a clear and present threat to the health and safety of our children who drink water and breathe air every day that may be contaminated with the endocrine-disrupting chemical, perchlorate and other RAAP generated toxins. Just think what that public money could do to ensure public safety by testing the water and ambient air quality. I do not believe our tax dollars should be spent for water treatment plants in foreign lands while neglecting to provide for homeland security by protecting this Appalachian community from the environmental impact of munitions and fireworks production at RAAP. It is unconscionable for our military and enormous pentagon budget to be directed outside of America while at the same time we are not testing water quality and air quality beyond the Arsenal boundary, manufacturing both critical weapons for soldiers as well as fireworks and ammunition being produced solely for the private market. We ask for due diligence and the DoD funding for this assessment to be extended to protect the health and safety of our community around the A rsenal, both workers and families subjected to daily toxic emissions from RAAP. Please consider the EPA's own TRI data which indicates the health risk we face from RAAP is five orders of magnitude higher than for Americans living around similar chemical manufacturing facilities nationwide, even though emissions from the OBG are not reported on the TRI!
http://oaspub.epa.gov/enviro/rsei.html?facid=24141SDDSRPOBOX
We urge a more in-depth review of ambient air quality downwind of the OBG and well water testing with our tax dollars , as allocated by the Department of Defense for this assessment. Please note also that the MMA is not located in Radford and the dispersal map shows it is the people living in Pulaski and Montgomery Counties which surround the MMA ought to be the target audience for study and information. It seems that no one in the one mile radius map on page 4 of the report was contacted about the public meetings nor asked for input about their well water quality. The number of private wells noted on page 7 is a small fraction of those currently in use in this same area. U.S. Census records for 2010 and data readily available from both Montgomery and Pulaski County officials who must approve each new private well, confirm that there are now over 180 private wells in this vicinity, not the small number extracted from data in the 1990's. In fact, a large subdivision, built to accommodate HUD subsidized housing has been built since the 2010 Census at the corner of Route 114 and Prices Fork Road and may be using water supplied by RAAP or a source well. There are a lot of children being born and growing up there who deserve a thorough assessment of their exposure risk.
Thank you very, very much for requesting input from those who care about our community, especially for the future of our environment and for our fellow citizens.
Gregory Nelson's Comments
Dear ATSDR and Dr. Forrester,
Environmental Patriots invited me to a meeting with Dr. Dyken on April 30th at the Inn of Virginia Tech. I met your representatives and discussed with them my concerns about growing up less than a mile from the horseshoe bend area in Montgomery County Virginia. My mother after having cancer twice was advised by her endocrinologist at Duke University not to drink her private well water. I am deeply concerned about the lack of study in your report regarding the open burning ground and soil contamination.
Thus, I have prepared formal public comments:
This is notification of formal submission of the following public comments for the "Health Consultation Evaluation of Potential for Chemicals Released to Groundwater or Surface Water to Affect Drinking Water In Nearby Community of the Radford Army Ammunition Plant Radford EPA Facility ID: VA1210020730"
Comment # 1
On Page 38 the report states, “Second, private wells near RFAAP are unlikely to be affected by releases from the facility. Therefore, contaminants from RFAAP in drinking water from private wells near RFAAP are unlikely to harm people’s heath.”
This conclusion is based on failure to include into the model of risk assessment contamination from airborne particulates from the Open Burning Ground (OBG) passing into the groundwater as a result of rainfall in the nearby community identified in the 2005 Risk Assessment of the Open Burning Ground conducted by CH2MHill INC. While ATSDR officials claim that no data exists on the fallout of the open burning ground or air quality monitoring the Atomic Energy Commissions testing at Operation Buster-Jangle in 1951 and further above ground nuclear operations shows the long history of technologies and science for monitoring air quality. The government has used them for decades in the Nevada Proving Ground Activities. Given that drones can be outfitted with air quality monitors the excuse that no data exists is unacceptable and warrants the further investigation of the connections between soil, air and water contamination at the facility. Testing of the emissions from the OBG must be conducted using over 60 years of air quality monitoring technologies and sciences that were developed during the above ground nuclear testing project at the Nevada Proving Ground combined with the Department of Defense’s robust drone program.
Comment # 2
The failure to include contaminated soil in the report ignores the fundamental connection between land, air and water. When it rains the water passes through the contaminated soil and absorbs contaminates therefore, your report must include a study of soil. By only focusing on the water under the site this report ignore the potential pathways soil and air contamination can enter the water. As water is in the air in the form of water vapor your report is inadequate and does not begin to capture the interdependencies between soil water and air contamination. This lack of scientific rigor fails the community who are asking for robust science with the best available technology used in detection, monitoring, and cleanup of this RCRA site.
Comment #3
While the report claims “It is physically impossible for substances released to move upstream against the flow of the New River…” , the above conclusion is unacceptable when considering fluid mechanics of a diffusion gradient through a porous medium in the ground water under the plant. Since the surrounding area and the facility sit upon Karst topography with multiple sink holes identified in the Virginia Department of Mines and Minerals map under the facility and specifically the open burning ground. The report cannot and should not assume the ground water contamination chemicals list identified on pages 63-70 of the report is moving only in the flow of gravity with the river. Rather, the fluid dynamics and mechanics of a diffusion flow process in a porous medium dictates that diffusion can occur against the force of gravity . A simple at home experiment illustrates this effect. Using a Rubber Maid container filled with water on a 30 degree angle with sand and porous limestone with a small 2cm hole on the downhill side of the container, in order to simulate flow, indicates that if food coloring is added at the lowest point of the apparatus the food coloring diffuses upwards through the porous medium against gravity overcoming the 30 degree angle on which the experiment is placed. Furthermore adding food coloring at the bottom of a cup with an eye dropper shows how the material will propagate upwards in the vessel against the flow of gravity.
Comment #4
Your conclusion of page 39 states, “ATSDR does not have site-specific recommendations for well testing since this evaluation showed private wells are unlikely to be affected by RFAAP. However, ATSDR recommends that all private well users monitor the quality of their water well.” You are attempting to have your cake and eat it at the same time by basically saying there is no problem. Given that your report indicates that the presence of perchlorate in the 4 out of 5 wells tested by the Sierra Club in close proximity to the facility. Given on page 26, Table 7, the Sierra Club well testing of 5 private wells within close range of the arsenal found Perchlorate in 4 out of 5 wells, a chemical signature of activities of the Arsenal, placing the burden on residents to test wells for chemicals not considered in Virginia Tech’s extension office water testing program, is unjust and violates the principles of Executive Order 12898 on Environmental Justice. You should consider the diffusion flow process through a porous medium and mandate testing be done on the polluters expense in accordance with the March 1992 HRS Scoring Deficiency Responses as part of the Army Corps of Engineers Preliminary Assessment Report Addendum for the Radford Army Ammunition Plant. By placing the burden of testing on home owners who cannot afford the rigorous testing for obscure chemicals generated by operations at the arsenal this report mirrors the efforts of the Atomic Energy Commission officials in St. George Utah to hid the effects of nuclear testing on the communities. The failure to collect data is not an excuse for why data cannot be collected.
Comment #5 The ATSDR Assessment did not include test results from the U.S. Army in 2010, confirming that ground water at 16 of 16 test wells across the Main Manufacturing Area (MMA) have significant perchlorate contamination. The sinkholes at the Open Burning Ground (OBG) and other places in the MMA where the perchlorate persists to this day present constitute an identified point source for cross-contamination through the Karst features beneath all of the MMA. Numerous sinkholes identified by the Virginia Dept. Of Mines & Minerals confirms their potential to serve as conduits for toxins to travel into wells off site. These documented sinkholes in the MMA, including those beneath the Open Burning Ground where perchlorate may have been a component in each of the 233 open burns conducted last year alone, are the "smoking gun" that ought to compel ATSDR to require additional well testing. The widespread perchlorate contamination in soil, surface and groundwater, at RAAP according to the U.S. Army and results from private contractors at RAAP over decades, are facts that cry out for a more thorough risk assessment to safeguard our community.
Comment #6
Clearly, the ongoing contamination of groundwater, soil and surface waters by disposal of waste from Grucci Fireworks at the OBG makes the presence of perchlorate in 4 of 5 wells tested by the Sierra Club a significant finding. It is highly unlikely that the private wells tested were contaminated with perchlorate from any source other than the operations at RAAP. A more sensitive test to differentiate whether it is ammonium perchlorate in these private wells would help to delineate the point source. The data are clear and it seems only prudent and in the interest of public safety to recommend that all municipal and private wells in the areas surrounding RAAP be tested to confirm or disprove cross-contamination from RAAP. The Federal Facility which is the source of the contamination has a moral, if not legal, obligation to pay for the testing that will ensure citizens are not subject to drinking their toxic waste as disposed of by open burning to the air we breathe and ultimately "rains out" and into the water our children drink. Please see the attached maps from the HHRA of 2005 illustrating the dispersal pattern and reason for our concern. The attached EPA document on perchlorate as an "emerging contaminant" discusses dispersal through soil and substantiates the likelihood that the perchlorate found in 80% of wells tested around RAAP last year is coming from the production and disposal at the facility.
Comment #7
The findings of CH2MHill in their 2005 assessment of the Open Burning Ground performed for Alliant Techsystems included maps of contaminant distribution which are attached. Perchlorate is known to readily leach from the soil where it falls after each burn. As this and other toxins become part of the GW recharge in this Karst aquifer, the potential for widespread diffusion into wells outside of the RAAP boundary is very real. Please note that the CH2MHill study of the OBG indicates "special receptors" for the particulate matter which are upstream of the intake for the Blacksburg/Christiansburg/VPI Water Authority in addition to numerous points on the river downstream of the OBG.(see River Receptors map). The combination of air dispersal over a wide area and direct deposition into the New River, which serves as a source of drinking water and recreational fishing, is of great concern to our community, especially those using wells and municipal water. (see Receptor Grid map). The source of perchlorate already found in four private wells is likely to be the Radford Arsenal, which can be confirmed with more extensive and accurate testing. Please note the attached EPA guidance document which confirms how perchlorate moves in soil, the association of perchlorate with the production that has taken place at RAAP since 1941 and most importantly, the importance of this ongoing source of perchlorate, barium, aluminum, chromium and other toxins being emitted from the "skid burns" at the Open Burning Ground. It is incumbent upon your agency to assess our risk to exposure through air and the migration of GW off site of the Arsenal. The tests cited in your report confirming perchlorate in 4 of 5 wells tested simply cannot be ruled out as coming from the documented point sources at RAAP without more testing and analysis.
Comment #7
I implore your agency to recommend testing of all drinking water wells within a three mile radius of the MMA boundary to rule out this route of exposure. The community in this "impact zone," cannot and ought not be asked to bear the financial burden to test for contaminants from the production and waste disposal processes at RAAP. The Dinitrotoluene isomers, chromium other chemicals included in the permit for the OBG at RAAP are specific to their production and unlikely to have any other source - agricultural or otherwise. The EPA called for this thorough, extensive testing of all DW wells within a two mile radius of EACH contaminated site in 1992, but that testing was never done. The EPA Deficiency Report for the Hazard Rating Score assigned to RAAP in 1992 makes clear that their risk assessors considered this testing essential to an honest characterization of the risk we face from RAAP. Please afford us the testing and complete risk assessment that was called for by EPA over two decades ago and is now warranted given the detection of perchlorate in wells off site of the facility. Independent testing by an EPA certified lab is the only way for your agency to conclude with certainty that perchlorate and other contaminants unique to RAAP have not migrated through the Karst terrain into the 180 plus private and two municipal wells in the exposure zone shown on the maps from the CH2MHill Risk Assessment of 2005. Comment # 8
Money should not be an issue for this Federal Facility to fund the widespread testing required at this site. The private contractor operating the facility, BAE Systems, along with the Department of Defense, who owns the facility and paid for this assessment, have the resources at their disposal to finance the testing that will rule out a clear and present threat to the health and safety of our children who drink water and breathe air every day that may be contaminated with the endocrine-disrupting chemical, perchlorate and other RAAP generated toxins. Comment # 9
Please note also that the MMA is not located in Radford and the dispersal map shows it is the people living in Pulaski and Montgomery Counties which surround the MMA ought to be the target audience for study and information. It seems that no one in the one mile radius map on page 4 of the report was contacted about the public meetings nor asked for input about their well water quality. The number of private wells noted on page 7 is a small fraction of those currently in use in this same area. U.S. Census records for 2010 and data readily available from both Montgomery and Pulaski County officials who must approve each new private well, confirm that there are now over 180 private wells in this vicinity, not the small number extracted from data in the 1990's. In fact, a large subdivision, built to accommodate HUD subsidized housing has been built since the 2010 Census at the corner of Route 114 and Prices Fork Road and may be using water supplied by RAAP or a source well. There are a lot of children being born and growing up there who deserve a thorough assessment of their exposure risk.
