Defense Environment Alert 03/09/04

Defense Environment Alert

an exclusive biweekly report on defense policies for cleanup, compliance and pollution prevention

Vol. 12, No. 5--March 9, 2004

BURNING OF PCB-CONTAMINATED ARMY BUILDINGS MAY SET TSCA PRECEDENT

Residents near a former Army ammunition plant in Wisconsin are raising health concerns over an Army plan to "open burn" buildings containing high levels of polychlorinated biphenyls (PCBs), saying EPA's potential approval of the plan could set a precedent making it easier for other military bases and private-sector sites to open burn bulk PCB product waste.

At press time, the group Citizens for Safe Water Around Badger (CSWAB) was circulating a sign-on letter among citizen, environmental and tribal organizations that will urge EPA Region V to block the Army's open burning plan. The Toxic Substances Control Act (TSCA) limits the disposal methods for bulk product PCBs to licensed incinerators or certain types of landfills. But the law also allows EPA to approve alternate disposal methods if the alternatives "will not pose an unreasonable risk of injury to health or the environment," according to the PCB disposal rule.

Although the Wisconsin Department of Natural Resources approved the Army's plan last year, no buildings have been burned yet because paint inside some of the structures slated for demolition contain PCBs at levels that exceed 50 parts per million (ppm), according to EPA and other sources. CSWAB says PCBs in paint have been detected at Badger Army Ammunition Plant at levels as high as 22,000 ppm.

EPA is still trying to determine whether the plan poses unacceptable risks, an EPA Region V source says. The Army has conducted a risk assessment finding that open burning would be safe, and Region V is currently conducting its own analysis of the data the military used in its risk assessment, the source says. "We would hope to complete the evaluation in the next few weeks."

The Army commonly disposes of buildings contaminated with explosives residue through open burning because it says normal demolition methods could put workers at risk of an explosion. But Region V officials are unaware of the military ever burning buildings that contained PCBs at levels greater than 50 ppm, the Region V source says. "It's not your typical disposal method," the source says of the Army's plan.

"The only good news is that EPA officials are still at the information-gathering stage and that the Army has not submitted a formal application for the exemption" from TSCA disposal regulations, CSWAB says in a Feb. 20 statement. "Our goal is to ... prevent the uncontrolled release of PCBs, dioxins, and other toxins to the environment." The group says at least 100 buildings are slated for open burning at the site over the next 10 years.

The Army maintains that open burning is the only safe way to demolish the buildings at Badger because of the explosive safety risk from the residue of nitrocellulose and nitroglycerin, two explosives that were used in the manufacture of gun propellants, dynamite and rocket paste. Normal demolition techniques will not work for these buildings because the compounds are highly explosive, Army sources say.

Nitrocellulose can spontaneously ignite due to sparks, impact friction, or static discharge. And shock friction and heating of all types must be avoided in handling nitroglycerin, the sources say.