Protocol Health Risk Assessment of MMR

["Laura Olah" <olah@speagle.com>]

Citizens for Safe Water Around Badger
E12629 Weigand's Bay South
Merrimac, Wisconsin 53561
(608) 643-3124

U.S. Army Center for Health Promotion and Preventive Medicine
ATTN: MCHB-DC-EHR (CPT Deborah Hastings)
5158 Blackhawk Road, Bldg 1677
Aberdeen Proving Ground, MD 21010-5422

September 22, 1997

Dear CPT Hastings,

Thank you for forwarding a copy of the Health Risk Assessment Protocol 
for Open Burning of Propellant Bags, Masschusetts Military Reservation 
(MMR), MA, Project No. 30-EJ-6995-97 dated July 1997 submitted by the 
U.S. Army Center for Health Promotion Medicine and Preventative 
Medicine.

Having only time to do a preliminary review of the proposed study and 
realizing the official comment period has already passed, we are 
presenting our initial recommendations at this time.

Based on our review of results reported as Average Emission Factors for 
Propellants Burns from the so-called Bang Box test as well as other 
voluminous studies conducted at the nearby Badger Army Ammunition Plant 
in conjunction with their application for a RCRA permit for open burning 
waste propellants - we strongly recommend the following parameters be 
added as identified chemicals of concern to be included in your 
analyses. These recommendations are made with the recognition that the 
Bang Box tests were conducted under extremely restrictive conditions 
which may give us some insight as to the potential environmental impact 
of burning bags of propellants at MMR, however, these results do not 
readily correlate with nor necessarily represent real world exposures 
or, more specifically, circumstances at MMR. 

Recommended (additional) parameters for inclusion:
· Chromium (Cr)
· Barium 
· Nitrogen Oxide
· Nitrogen Dioxide 
· 2,6 - DNT (Dinitrotoluene)
· Carbon Monoxide
· Carbon Dioxide
· Vinyl Chloride 
· Non-methane hydrocarbons (i.e. propane, ethane, acetylene, and 
 other light hydrocarbons)
· 1-Nitropyrene
· 2-Nitronaphthalene
· 2,5 Diphenyloxazole

Thank you for your consideration of our letter and we look for to 
receiving information about the progress of your investigation. 

Sincerely,

Laura Olah
Executive Director

cc: John DeVillars, Regional Administrator, Region I, USEPA
 Community members