Citizen group pushes for halt to open burning at Radford Army Ammunition Plant

Alyssa Carpenter hadn’t reached the age of 30 when she had her thyroid removed.

A former student at Virginia Tech in Blacksburg, she began getting sick after she graduated. Eventually, doctors found her thyroid was extremely diseased and suspected it could be cancerous.

Now, aged 28, even though her thyroid has been removed, health problems remain. She deals with lethargy and nausea, takes synthetic hormones, and must visit the hospital frequently to have her blood drawn and medication adjusted.

“It’s really hard to find wellness after your thyroid is gone,” Carpenter said. “Carrying groceries inside basically makes me very dizzy. It’s exhausting … and costly. I’m basically chronically ill for the rest of my life.”

Carpenter thinks the problems can be traced back to the Radford Army Ammunition Plant, a roughly 7,000-acre complex in Montgomery and Pulaski counties that manufactures propellants for munitions and rockets used by the U.S. Army.

Specifically, she believes her health problems are linked to contamination resulting from the RAAP’s open burning of hazardous wastes — a practice banned by the U.S. Environmental Protection Agency in 1980 but allowed at the Radford facility through an exception permitting open burning and detonation of waste explosives. She lived within a mile of the plant during her undergraduate studies.

The RAAP currently operates under permits issued by the EPA and Virginia’s Department of Environmental Quality. BAE Systems, its owner and operator, says the facility “fully abides” by state and federal laws for hazardous waste disposal.

But Citizens for Arsenal Accountability, a community organization in Southwest Virginia that is asking for a halt to open burning at RAAP, says more needs to be done.

In a report released this September in collaboration with Earthjustice and the Center for Progressive Reform, the group, which Carpenter helped found and co-leads, says pollution from the facility “has continued for too long without adequate oversight or accountability.”

The group is asking for six changes: end open burning at the facility, have a third party assess alternative technologies that could be used, close the old incinerators, improve transparency and community involvement, improve compliance and conduct assessments on cumulative hazard and community health.

Munitions and explosives waste

The RAAP was built in 1940 at a cost of $40 million and employed as many as 23,000 workers during World War II.

Today, the facility manufactures propellants for U.S. Army munitions and rockets under a contract with the U.S. Department of Defense. As part of its operations, it discards waste through open burning and open detonation of munitions and explosives in a pit along the banks of the New River, as well as operating incinerators.

In 1980 the EPA banned the open burning and open detonation of all hazardous waste. But the agency granted an exception for the disposal of waste explosives after pushback from the military, which argued that no other alternative technologies were available at that time.

The RAAP has continued to open-burn and incinerate waste under 10-year permits that were last approved by the Virginia Department of Environmental Quality in 2021.

DEQ spokesperson Aaron Proctor said the facility’s latest open-burn permit reduced the amount of waste that could be processed in the pit by 51%. A risk assessment didn’t find any hazardous emissions “above regulatory thresholds,” he added, and the incinerators have been found through regular testing to be in compliance with national emissions standards for hazardous air pollutants.

Claire Powell, a spokesperson for BAE Systems, said, “Radford meets – or is well within its emission limits – and has reduced emissions substantially (greater than 40%) for several categories in the last five years, including open burning of waste propellant products.”

Softer tone emerges in meetings between community, military over munitions plant pollution

“The permitted open burning ground weight limits are never actually reached,” she said. “(A)s an example in 2020, RFAAP only used 5% of the currently permitted limit.”

She also pointed to a 2017 DEQ and Virginia Tech study that found lead levels below the national ambient air quality standard.

Environmental and health impacts

But several pages of the report detail pollutants linked to the facility’s open burning and detonation of waste.

Perchlorate, a chemical that can impact the uptake of iodine in the thyroid gland and interfere with the organ’s function, has been found in the groundwater, the report states.

The plant is regularly listed by DEQ as the state’s largest emitter of toxic and hazardous chemicals, releasing ammonia, copper, lead, nitrate, nitric acid, and nitroglycerin, among other compounds.

Drone air monitoring by university researchers and federal agencies on open burning emissions at RAAP also found elevated levels of arsenic, lead, and cadmium, which can lead to respiratory irritation, neurological damage in children, and lung damage, respectively.

Polychlorinated biphenyls (PCBs) were detected by the U.S. Department of Health and Human Services in stormwater outfalls into the New River.

A 2017 ProPublica report found that at least one additional person out of every 19,000 people living in the area of the plant would likely develop cancer over a presumed 70-year lifetime.

The plant has also been issued numerous permit violations for problems, including not complying with the Clean Air Act in seven of the past 12 quarters. One EPA enforcement action against the RAAP called it “a facility of significant environmental concern for its surrounding community.”

Safer alternatives

Citizens for Arsenal Accountability argues that today, open burning and detonation are no longer the only solutions to dispose of the kind of hazardous waste the RAAP produces.

“We cannot keep relying on outdated technology to dispose of hazardous waste and toxic chemicals,” Carpenter states in the report. “We require the safest, most advanced technology to safeguard our community against toxic pollution.”

A recent EPA memo, citing a 2019 report from the National Academies of Science, Engineering, and Medicine, details several alternative technologies now available to handle munitions waste. They include taking apart munitions the opposite way they are put together through a process called a reverse assembly, using a water abrasive to segment the munitions, and dry-ice blasting.

The federal agency “has been working with the Virginia Department of Environmental Quality and Department of Defense to review the Radford open burning activities,” said spokesperson Catherine Milbourn. “Radford AAP has evaluated alternatives and is re-examining the waste streams to reduce explosives-contaminated wastes.”

Milbourn said that the EPA is working on a proposed rule to revise the regulations for open burning and open detonation in light of new alternative disposal technologies. Those regulations are intended to be proposed in fiscal year 2023.

The Radford facility is in the process of opening a new waste incinerator complex that the company says will almost completely eliminate the need for open burning. DEQ has approved the permit for the complex, which is required to be operational by Oct. 1, 2026.

That will come after the plant eliminated its coal-fired powerhouse in 2017, in addition to other improvements that have led to a reduction in the amount of open-burning waste being treated by 50%, Powell stated.

But in deciding to make the complex, RAAP failed to sufficiently analyze other alternative technologies that would produce less pollution than incineration, Citizens for Arsenal Accountability says. The report says that RAAP did have an alternative assessment done several years ago, but it cited technology reviews that were, in some instances, done 30 years before recent developments in alternative technologies.

Carpenter said the group isn’t asking for the plant to close, just for changes to be made.

“We just want a safe and healthy community,” she said.

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