Hazardous Waste Open-air Incineration at Radford Army Ammunition Plant (RAAP) under Scrutiny in Permit-renewal Process During 2015; Drone Monitoring Started in September 2016; Closed Incinerator in Design Phase in 2016-17; Groundwater Corrective Action Permit Under Review in Early 2016

Hazardous Waste Incineration Issue at RAAP

June 2015 initial post – June 29, 2015, was the deadline for the Radford Army Ammunition Plant (RAAP), to submit to the Virginia Department of Environmental Quality (DEQ) an application to renew its permit for open-air burning and detonation of hazardous wastes generated at the facility.

The 4600-acre facility, built during World War II and located along the New River in Montgomery and Pulaski counties, Va., is currently the only military-propellant manufacturer in the United States.  The propellant production results in waste containing various hazardous chemicals, such as barium, chromium, and mercury.  The practice of open-air burning of the waste is not unique to RAAP—NASA’s Wallops Island Facility on Virginia’s Eastern Shore and the Naval Surface Warfare Center near Fredericksburg also have such permits—but is done a larger scale at RAAP than at other facilities in Virginia.

RAAP’s burning has drawn attention and raised concerns from some local citizens because of the plant’s location near residences, one school, and farmland.  In July 2015, the plant’s military commander, Lt. Col. Alicia Masson, told The Roanoke Times that the plant is in the process of designing a new closed incinerator that would be used for “the majority” of the waste now undergoing open burning. Lt. Col. Masson told the newspaper that no implementation schedule has been set yet, nor is expected performance data yet available, but that she expects it to be a “marked improvement” over the current practices.

RAAP’s 10-year DEQ permit for open-air incineration was set to expire in October 2015, and a DEQ spokesman stated that the permit renewal request would get close scrutiny because of the concerns that have been raised.  DEQ information about the open air incineration permit-renewal process and the agency’s other regulation of the RAAP is online at http://www.deq.virginia.gov/ConnectWithDEQ/EnvironmentalInformation/RadfordArmyAmmunitionPlant.

Update 3/17/16 – In early March 2016, RAAP Commander Lt. Col. Alicia Masson told The Roanoke Times that the Arsenal was continuing to investigate designing a closed incinerator for the hazardous waste burning, that drone aircraft would be used to monitor air emissions from the current open-air burning, and that the facility plans to convert its coal-fired power plant to burning natural gas within the coming 12 months (source: Air monitoring, new incinerator planned for Radford ammunition plant, Roanoke Times, 3/6/16).

Update 4/12/16 – In early April 2016, the Montgomery County, Va., Public Service Authority (PSA) announced that recent tests of two wells used to supply water to the Authority showed low levels of the chemical perchlorate.  The RAAP is located in Montgomery County.  According to the U.S. EPA (online at https://www.epa.gov/fedfac/technical-fact-sheet-perchlorate, as of 4/12/16), “perchlorate is a naturally occurring and mad-made [chemical]…commonly used as an oxidizer in solid propellants, munitions, fireworks, airbag initiators for vehicles, matches, and signal flares; …also used in some electroplating operations; and found in some disinfectants and herbicides.”  According to the PSA’s executive director, the levels found in the county wells were below any health-advisory levels or standards.  Local citizens have raised concerns that the RAAP’s open burning could be a source of perchlorate that could be transported some distance.  On April 5, 2016, the director of the Public and Congressional Affairs Joint Munitions Command stated that the RAAP does not burn perchlorate in its open air waste burning.  Perchlorate has been found for years in RAAP groundwater, but RAAP officials assert that contamination has not spread to wells beyond the RAAP property.  The PSA wells that had perchlorate are located  several miles upstream of the RAAP.  Some local citizens have called for more comprehensive groundwater testing to try to determine the possible sources of perchlorate in the PSA wells, and Bill Hayden, Virginia Department of Environmental Quality (DEQ) spokesperson, said that the DEQ intended to follow up with Montgomery County officials about the recent perchlorate findings.  The PSA executive director, however, said in early April that the PSA had no plans for continuing to test the two wells where the perchlorate was found.  Sources:  Perchlorate levels detected in two Montgomery County water systems, Roanoke Times, 4/3/16.  Montgomery County officials have no plans to further study perchlorate found in wells, Roanoke Times, 4/6/16.

Update 5/5/16 – In early May 2016, Virginia Tech announced that tests of wells on the university’s Kentland Farm—located in Montgomery County, directly across the New River from the RAAP—had found low levels of perchlorate, along with barium, chromium, and dioxins/furans in two out of five wells tested.  The perchlorate levels in the two wells were 1.25 parts per billion (ppb) and 0.78 ppb, compared to a 15-ppb level that the EPA currently uses as its Interim Lifetime Drinking Water Health Advisory level (see EPA Fact Sheet noted above).  The executive summary of the report, prepared for the university by consulting firm Draper Aden Associates of Blacksburg, Va., stated that “low-level detections of contaminants of concern in Kentland Farm groundwater were below applicable screening levels,” according to the Roanoke Times’ May 4, 2016, article on the report.  In response to the findings, RAAP Commander Lt. Col. Alicia Masson reiterated that the RAAP does not currently use or burn perchlorate (see 10/5/16 update below).  As noted above, perchlorate is present in some agricultural chemicals as well in some propellants, munitions, and other products, raising the question of whether the university’s farm operations could potentially be the source for perchlorate in those wells.  Source: Perchlorate found in wells at Virginia Tech’s Kentland Farm, Roanoke Times, 5/4/16.

Update 5/16/16 – At a community meeting on May 12, 2016, RAAP Commander Lt. Col. Alicia Masson said that drone flights to monitor air over open-burning sites will be conducted Sept. 19-30, 2016; and that the design for closed containers to replace the open air burning is to be nearly complete (90 percent) by August 2017.  More air testing at Radford arsenal promised, Roanoke Times, 5/12/16.  Additional sources:  Radford Army Ammunition plant plans to reduce open toxic waste burns—A new incinerator is being designed to handle the toxic wastes now burned outside, Roanoke Times, 7/26/15.  Permit for Army plant near Radford to burn explosive waste is up for renewal, Richmond Times-Dispatch, 6/14/15; and MilitaryBases.com, “Radford Army Ammunition Plant Army Base in Radford, VA,” online at http://militarybases.com/radford-army-ammunition-plant-army-base-in-radford-va/, accessed 6/16/15.

Update 10/5/16 – In late September, RAAP began drone flights to gather emissions from its open burning operations, part of a series of tests to determine the contents of the emissions.  The test results are expected by the end of 2016.  One early result, however, is that the plant reported that some perchlorate materials had been burned at the plant, despite RAAP Commander Masson’s contention in May 2016 that the plant does not burn perchlorate, a substance that has been detected in Montgomery County wells across the New River from the plant.  Commander Masson stated that it is more accurate to say that perchlorate is rarely burned at the plant.  Radford arsenal uses drone to sample smoke from controversial burn, Roanoke Times, 10/3/16.

Groundwater Corrective Action Permit Issue at RAAP

Separate from the open-air incineration permit issue, from 1989 to 2014 the RAAP was under a Corrective Action Permit from the U.S. EPA to clean up some several areas of contaminated soil and groundwater. In August 2014, the EPA issued a “Corrective Action Final Decision,” stating that any further remediation of groundwater contaminants would be left to natural attenuation, but also that the plant must continue groundwater monitoring and maintain “institutional controls.” As of February 2016, the RAAP was applying to the Virginia DEQ to renew its groundwater Corrective Action Permit in accordance with the 2014 EPA decision.  A public hearing on the permit application was to be held February 10, 2016, in Radford.  Information from the EPA on that part of the RAAP story is available online at http://www.epa.gov/reg3wcmd/ca/va/webpages/va1210020730.html; information from the DEQ on the corrective action permit request is available online at http://www.deq.virginia.gov/Programs/LandProtectionRevitalization/PublicNotices.aspx (as of 2/8/16).  Additional source: Radford arsenal cleanup going well, regulator says, Roanoke Times, 1/28/16.

Ongoing List of Other Media Accounts on Both Issues (oldest listed first):

Permit renewal raises questions for Radford arsenal, Appalachian Voices, 6/15/15.
Radford ammunition plant seeks fresh permit for controversial open burning, Roanoke Times, 6/28/15.
Activist Erin Brockovich focuses attention on New River Valley, WSET TV-Lynchburg, 3/30/16.
Life on the Fence Line of the Radford Arsenal, WVTF FM-Roanoke, 4/18/16.
Protestors rally for Radford Arsenal to stop burning hazardous waste, WSLS TV-Roanoke, 4/20/16.
Radford ammunition plant launches switch from coal to gas, Roanoke Times, 4/21/16.
Residents rally against Radford Army Ammunition Plant, WSLS 10 TV-Roanoke, 5/4/16 [protest by citizens outside of U.S. Sen. Tim Kaine’s (D-Va.) office in Roanoke on May 4, 2016].
RAAP LTC Alicia Masson Leads With Environmentalism, WVTF-FM – Roanoke, 5/10/16.
WSLS 10 investigates pollution at the Radford Army Ammunition Plant, WSLS TV-Roanoke, 5/17/16 [6 min./45 sec. video, featuring views from inside the plant].
Va. Tech group to scrutinize Radford arsenal pollution, Roanoke Times, 4/19/17.

New River Arsenal Falls Jun15 2008

Arsenal Falls, part of the New River section that passes through the Radford Army Ammunition Plant, photographed here on June 15, 2008.

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