DOD Toxic Releases

[Lenny Siegel <lsiegel@igc.org>]

From: Lenny Siegel <lsiegel@igc.org>

DOD RELEASES FIRST TOXICS RELEASE INVENTORY (TRI) 
REPORT

For the first time, the Department of Defense has submitted a 
nationwide report on its toxic releases. As required by a 1993 
Executive Order, the DOD has submitted detailed data, by installation, 
to the Environmental Protection Agency and the states in those 
installations are located. The nationwide report, covering calendar year 
1994, summarizes releases at 131 Defense installations - including 
contractor-operated facilities, many of which had previously complied 
with the TRI - that met the threshold reporting requirements.

The combined release of TRI chemicals by reporting DOD installations 
totaled 11.46 million pounds in 1994. DOD points out: "By 
comparison, private industry releases for the TRI reporting year 1993, 
the most current available, were 2.8 billion pounds. Thus, DoD 
represents a small portion of those total TRI releases, approximately 
.41%." DOD suggests that this is because it is a downstream user of 
chemicals, not a manufacturer.

The totals, by type of release, were as follows. Note that the weights 
apply to the toxic constituents, not the total waste.

TOTAL RELEASES
11,464,110 pounds

ON-SITE
Total 7,434,549 pounds
Air 7,244,137
Land 97,363
Water 92,659
Injection Wells 390

OFF-SITE
Total 4,029,561 pounds
Waste Disposal Facility 2,595,698
Waste Treatment Facility 1,333,449
Publicly Owned Treatment Works 100,414

Total reported releases of three chemicals - all solvents - exceeded one 
million pounds: dichloromethane (methylene chloride), methyl ethyl 
ketone (MEK), and 1,1,1, trichloroethane (TCA or methyl 
chloroform). The fourth on the list, ethylene glycol, is primarily used 
as an airplane de-icer. The top ten chemicals, listed below, accounted 
for 68% of the reported releases in 1994.

RELEASES BY CHEMICAL

Dichloromethane 2,225,154 pounds
Methyl Ethyl Ketone 1,488,138
1,1,1 Trichloroethane 1,231,470
Ethylene Glycol 588,067
Toluene 444,500
Phenol 411,988
Zinc Compounds 409,180
Tetrachloroethylene 359,039
Hexachloroethane 351,370
Hydrochloric Acid 298,896

DOD says it has "made enormous progress" in reducing its use and 
release of ozone-depleting substances: "In just five years, the 
Department decreased its use of halon from 10,325,000 pounds in 
1990 to 231,000 pounds in 199; and its use of CFCs 
[chlorofluorocarbons] from 14,588,000 pounds in 1990 to 313,000 in 
1995." It neglects to mention that TCA, third on its list, is also an 
ozone-depleting substance.

Ten installations, all off which are industrial activities, accounted for 
52% of the reported releases. Two, Lockheed-Martin and Vought 
Aircraft, are contractor-operated. Two others, Kelly and McClellan 
Air Force Bases, were just approved for closure, although the 
government is looking for ways to continue at least some of their 
operations under private ownership.

RELEASES BY FACILITY

Tinker Air Force Base, Oklahoma 1,569,614 pounds
Robins Air Force Base, Georgia 776,616
Pine Bluff Arsenal (Army), Arkansas 721,364
Lockheed-Martin (Air Force), Marietta, Georgia 554,555
Anniston Army Depot, Alabama 548,073
Vought Aircraft Company (Navy), Dallas, Texas 462,481
Hill Air Force Base, Utah 367,909
Kelly Air Force Base, Texas 344,631
McClellan Air Force Base, California 340,750
Jacksonville Naval Air Station, Florida 325,648

Given the experience with private companies' TRI reporting, it will 
probably be a few years before all DOD installations get their numbers 
right (or at least as accurate as they will ever be). However, DOD is 
already using the data to make plans to reduce its releases: "In a pilot 
initiative the Department is calling Toxics Reduction Investment and 
Management, DoD intends to first identify and quantify the industrial 
and maintenance processes that produced the releases, then identify 
the military specification, standard, procedure, and other technical 
document that requires the process to use the TRI chemical. This 
analysis, although it cannot be used as the sole basis for prioritization, 
will provide valuable assistance to the Department in developing its 
pollution prevention investment strategy, managing environmental 
technology efforts, and prioritizing the revision of standardized 
documents."