[CPEO-MEF] Open Burning Plan Does Not Safeguard Human Health and the Environment

[info@cswab.com]

Following are formal comments on the proposed open burning of
explosives-contaminated buildings at Badger Army Ammunition Plant
submitted by Paul Herr, an environmental scientist and neighbor of the
closing base.

 

--

 

March 12, 2003

Open Burning Plan Does Not Safeguard Human Health and the Environment

By Paul Herr

 

Dean Packard

North Air Team Supervisor, South Central Region

Department of Natural Resources

W7303 County Hwy. CS

Poynette, WI    53955

 

Dear Dean:

 

I enjoyed meeting you at the Public Information Meeting for the "Plan
for Disposition of 3X buildings at the Badger Army Ammunition Plant".  I
will try to be succinct in my comments regarding the plan (Plan
#157005530-PL01).  My overall assessment of the open-burning portion of
the demolition plan is that it represents an extraordinary variance from
the normal and prudent handling of hazardous wastes.  It should include,
therefore, extraordinary precautions to safeguard human health and the
environment.  The current plan, as described by Plexus, the Army's
consultant, does not do this.  The main weaknesses in the plan are:

 

1.	The risk assessment described by Plexus in the public meeting
was incomplete because it did not address the cumulative cancer risk
from all exposure pathways--it just evaluated inhalation risk.
Ingestion and dermal-contact pathways (resulting from contaminated
soils) were not evaluated. 
2.	The risk assessment was based on exposure of an "average adult".
It should have been based on the cancer risk to children because
children have a greater vulnerability to carcinogenic compounds than
adults. 
3.	Given the large uncertainties in the risk assessment, the plan
should have included comprehensive monitoring of actual impacts during
the burning and sampling of soils to measure the fallout of contaminated
ash and other particulates. The plan contains no mention of monitoring
of either air, water or soils.  

 

Based on my experience as an environmental scientist, the Plexus plan
does not meet the standard-of-care that I am accustomed to in the
environmental industry.  It may cause more problems than it solves.

 

The Badger Plant operated during periods of national emergency and at a
time when we didn't understand the health and environmental dangers of
toxic chemicals.  Large volumes of toxic materials were used, and
disposed-of, in the most expedient fashion-often by pouring them into
the ground.  This expedient path resulted in a 200-million-dollar
cleanup and impacts to human health and the environment.   Now the Army
again wants to do the expedient thing-implement a plan with an
incomplete risk assessment and no ground-truthing to establish the
actual impacts. 

 

The Army claims that open-burning is the only safe way to demolish some
of the buildings.  The Army also claims that open-burning will be more
expensive than other disposal options.  Even if these statements are
true, the open-burning should be done in a responsible and safe manner

 

The New York Times published an article on March 6, 2003 titled
"Military Seeks Exemptions on Harming the Environment".  The article
states that:

 

"The Pentagon wants to override current regulations that govern the
disposal of hazardous waste and the cleanup of contaminated sites".  

 

The glaring omissions in the Plexus plan give the impression that the
Army is trying to override Wisconsin's environmental regulations, or at
least cut-corners.  It is the DNR's responsibility to fight such
shortcuts and omissions and protect the citizens of Wisconsin.   

 

I am the environmental geologist who made a 3-minute statement at the
end of the public meeting in Baraboo.  I worked at the Badger Plant as a
groundwater consultant for a couple of years in the mid 1990's.  I am
familiar with the contamination problems that exist outside of the
buildings at Badger. I have had several industrial tours of the Badger
Plant with Olin engineer, Dennis Thurow, so I am familiar with the
general conditions inside the buildings.  I own a home in the Town of
Merrimac approximately 200 yards east of the east-perimeter fence at
Badger.  I have two children, Pauline, age 6, and Christopher, age 9,
who play within sight of the Badger property.

 

I have been an environmental consultant for 15 years and have worked at
hazardous waste sites across the U.S.  My focus has been on geology and
hydrogeology and the design of remedial investigations. I've had some
exposure to air-pollution issues in meetings and conversations with my
colleagues who are specialists in the field.

 

INCOMPLETE RISK ASSESSMENT THAT DOES NOT ADDRESS CONTAMINATED FALLOUT
AND THE RESULTING DERMAL AND INGESTION RISK FROM CONTAMINATED SOILS

 

The risk assessment presented by Plexus is incomplete.  It does not
investigate all vectors (pathways of potential exposure). The
risk-assessment should have included an assessment of all routes of
exposure--including exposure to soils contaminated from contaminated
fallout from the burning (dermal and ingestion risk).  The total amount
of lead emitted from the burning could exceed 720 pounds over a 10-year
period (based upon Plexus's assumptions).  A risk assessment that does
not investigate the "dermal-contact and ingestion risk" from
contaminated soils is partial and incomplete.  The cumulative exposure
from all vectors could result in a significantly higher cancer risk than
the risk reported by Plexus in the public meeting.  The air-modeling
results that were presented at the meeting are unconvincing because they
show only part of the picture.

 

It is my understanding that the risk assessment for the open-burning
plan was calculated using the inhalation cancer-risk to adults.  Why
wasn't the risk-assessment conducted for children, the most sensitive
receptor?  Here are two articles I found on the internet that suggest
that the risk assessment for the open-burning may understate the cancer
risk because it was based on adult exposure to the pollutants, not
child-exposure.  If these facts bear-out, it would be negligent to
proceed with the burning until the risk to children, the most sensitive
receptor, has been assessed.  

 

Articles from the Internet Pertaining to Cancer Risk in Children

 

Article 1

 

EPA to limit cancer risks for babies Infants, toddlers 10 times more
vulnerable to some chemicals ASSOCIATED PRESS

 

WASHINGTON, March 3 - Infants and toddlers have a 10 times greater
cancer risk than adults when exposed to certain gene-damaging chemicals,
the government said Monday, in proposing tougher environmental
guidelines that would take into account the greater hazards to the very
young.

 

IF ITS guidelines are made final, the Environmental Protection Agency
would for the first time require that the substantially greater risk to
children be weighed in the development of regulations covering a variety
of pollutants.

 

While scientists have long known that very young children are more
vulnerable than adults to gene-harming chemicals, this is the first time
the EPA has formally proposed calculating the difference in assessing
the danger from some pesticides and other chemicals.

 

The guidance on cancer and children, which must still be reviewed by
EPA's panel of science advisers and has to be subjected to a lengthy
process before becoming final, is part of a broader reassessment of how
the EPA evaluates cancer risk.

 

Article 2

 

"While the ARB's (California Air Resources Board's) risk estimates are
alarming on their own, they actually understate the urgency of the
cancer threat because they are calculated over the entire lifetime of an
"average" adult. As the state's own risk assessment agency has noted,
the scientific literature is filled with studies demonstrating that
exposures to carcinogens early in life result in a greater possibility
of getting cancer compared to the same exposures later in life. In other
words, children are more susceptible to getting cancer from the
pollutants in outdoor air. But children are also more exposed to those
pollutants because of their different behavior patterns and their
physiology. Because children breathe more air relative to their body
weight, their exposure to air contaminants is higher relative to
adults."

 

 

MONITOR CHEMICALS  EMITTED FROM THE PROPOSED OPEN-BURNING

 

Monitoring of air, soil and water needs to be added to the Army's
open-burning plans because of the inherent uncertainties in the risk
assessment.  The proposed burning will be too complex, and too full of
unknowns, to predict the impacts with any degree of certainty.  The
estimated quantities of toxic materials in the initial 10 buildings
slated for burning may be too conservative.  Human error may result in a
burn occurring at the wrong time and under inappropriate meteorological
conditions.  An undocumented subsurface pipe filled with explosive
residue may detonate and release a large cloud of contaminated dust.
For this reason, the plan requires ground-truthing-monitoring the actual
exposures that occur downwind of the burn areas during the burning.  The
current plan contains NO MONITORING WHATSOEVER!

 

Environmental consultants, environmental cleanup workers and factory
workers who are exposed to materials such as asbestos, lead,
formaldehyde, benzene, and arsenic are required to have their workspace
monitored for these OSHA-regulated compounds.  Personal air-sampling
pumps are typically used to measure the worker's exposure to these toxic
materials.  Why wouldn't the Army apply the same monitoring logic to the
residents who live just downwind of Badger?  The same OSHA-regulated
contaminants will be wafting though residential areas near Badger during
the burning.  Why doesn't the Army burning plan include monitoring to
measure the actual exposure of local residents and the environment?
Instead the Army is relying on modeling results that are crude estimates
of exposure, at best.

 

Here is a hypothetical situation that illustrates my point.  I suspect
that Plexus and Army employees will observe the burning activities at
Badger from an upwind direction. They will do this because it is the
prudent thing to do.  Plexus is fully aware of the inherent
uncertainties, assumptions, and estimates in their technical analysis.
Unfortunately, local residents do not have the option to move their
homes to upwind locations.  It is the DNR's responsibility to monitor
the actual exposure of nearby residents to toxic discharges from the
burns, and call off the burning if real exposures materially exceed the
predicted ones.  I am a firm believer in Murphy's Law-what can go wrong,
will go wrong.  It is the DNR's responsibility to cover all the bases
and make sure that nothing "can go wrong".  I heard many "hedge" words
throughout the Plexus presentation: "we estimate", "we think", and "we
assume".  These are  synonymous with saying-WE JUST DON'T KNOW. 

 

POTENTIAL SOIL CONTAMINATION FROM THE PROPOSED BURNING

 

Plexus estimated, in their 1,000-ton-burn model for the first 30
buildings, that 240 pounds of lead would be released to the atmosphere.
This is roughly equivalent to the yearly lead discharge from a
coal-fired power plant (according to Plexus).  This is a significant
quantity of lead.  At least a power plant discharges its lead from
300-foot-high stacks.  The emissions at Badger will be at ground-level.


 

Plexus estimated that 90 buildings might require burning.  Using the
same assumptions as the first 30 buildings, this would result in the
release of 720 pounds of lead over a 10-year-period (more or less).
This is a significant amount of lead.  Who knows, the actual amount of
lead could be much larger. Maybe 300 buildings will be burned, not 90.
Plexus' lead estimates could be dramatically too low, since they are
based on only 3 samples per building and many surfaces were assumed to
be clean based on visual inspection rather than sampling and analysis.  

 

I would like to know how much of the estimated 720 pounds of lead will
be deposited in my front yard .  Wouldn't it be sad if the burning plan
at Badger produced a wide zone of hazardous soil contamination in the
surrounding area--turning parts of Devils Lake State Park into a
hazardous waste site?  This would be just another example of expedient
disposal of hazardous chemicals at Badger creating an even bigger
problem for the people of Wisconsin.  

 

Devils Lake, one of the clearest and unique lakes in Wisconsin, lies
less than 3-miles north of Badger.  Devils Lake State Park, the most
popular park in Midwest, borders the Badger Plant to the north.  How
many pounds of lead, chromium, arsenic and PCBs are going to land on
this precious resource?  The DNR is spending over a million dollars to
remove phosphorus contamination from Devils Lake.  It seems
counterproductive to then re-contaminate the lake with hazardous
compounds.  What about the 1.5 million visitors to Devils Lake State
Park?  How will their recreational experience, and health, be affected
by the burning activities at Badger.  At this point, the Army doesn't
even have an estimate of the deposition of hazardous, persistent
chemicals, much less a plan to monitor these impacts.

 

Barbara Pavliscak mentioned that the DNR's and Plexus' air-modeling did
not include predictions of heavy metal deposition on the area around
Badger.  Barbara said that the EPA model that predicts deposition is
highly complex.  She also stated that the current deposition-model has
been de-certified by the EPA and that the new model will not be out for
6 months.  My answer is-don't allow burning until you have some handle
on where the heavy metals, and other persistent toxic chemicals, are
going to end up.  Why not wait for six months until you can
intelligently evaluate the long-term threat to soils.  

 

Whether-or-not heavy metal deposition is modeled, it is critically
important to conduct baseline soil sampling-and-analysis for heavy
metals, PCB's, asbestos and dioxin before burning commences and then
yearly sampling during the 10-year burning-phase that follows.   If soil
contamination reaches dangerous levels in, or around, Badger, burning
should be discontinued.  This is the only prudent thing to do.

 

SUGGESTED ADDITIONS TO THE DEMOLITION PLAN

 

I will conclude with some suggestions for improving the Plexus
demolition plan:

 

*	Plexus stated to me, during the question-and-answer session,
that they tried to evaluate the actual concentrations of hazardous
compounds in the smoke at the Joliet Army Ammunition Plant in Illinois.
As I recall, they used a crane to suspend a sampling device over a
burning building.  Plexus stated that the sampling attempt showed no
detectable hazardous compounds in the smoke.  This is an exceptional
claim that requires exceptional proof.  There are probably hundreds of
research articles that look at precisely this issue--emissions from the
burning of leaded paint.  Did Plexus review the available scientific
literature before making their claim?  What procedure did Plexus use to
obtain their sample at the Joliet site?  Was the procedure ASTM or EPA
approved?  It is not credible to claim that all of the toxic materials
will either stay on the ground (in the ash) or be totally destroyed by
the combustion process.  Even if all the heavy metals remain in the ash,
ash will also be part of the smoke plume--especially if there are
detonations inside the buildings, which is likely according to Plexus.  

 

Here is an excerpt from the PROACT website that indicates that lead is
volatilized by heat (PROACT provides environmental research to the U.S.
Air Force).

 

Physical techniques include paint removal using abrasives or heat. Use
of abrasives is discouraged as this method can generate large amounts of
lead containing dust. Use of heat guns at high temperatures can cause
volatilization of lead and create a potential exposure hazard.

 

If a heat gun can volatilize lead from paint, then burning a building
will too.  The burning proposed for Badger will be optimized to create
maximum heating, so much of the heavy metal content in the paint may be
volatilized to the atmosphere.

 

*	Roughly 30 samples were taken to establish the quantity of lead
paint in the 10 building slated for burning.  This equates to 3 samples
per building.  Most of the wooden building surfaces were not sampled
because, according to Plexus' visual inspection, the paint had
apparently pealed off of the wood.  Most of the samples were taken from
pipes and other equipment, not wood.  The Army should not simply assume
that the bulk of the wooden building materials are clean, they should
prove that they are clean with random testing.   Large quantities of
leaded paint were used on the 90 buildings that Plexus estimated will be
burned. It is currently unaccounted for. This lead has to be somewhere,
and part of it may end up being burned.  Samples of supposedly-clean
wood should be analyzed for possible contamination from exposure to
paint, chemical vapors, liquids, and wood preservatives.  The following
article appeared on the PROACT website (PROACT provides environmental
research services to the U.S. Air Force). 

 

Paint Stripping - Chemical strippers can release lead from the coating
which can potentially be absorbed by underlying wood substrates. When
new (non-lead) paint is applied, the lead remaining in the wood after
stripping can be re-absorbed by the fresh paint, thus creating a new
potential hazard. It is recommended an XRF analysis of the newly painted
surface be performed to verify the new coating is free of lead hazards.

This article explains how an apparently paint-free surface could contain
lead. The lead can be transported into the wood by paint-stripping with
solvents.

*	The estimated quantities of toxic materials remaining in the
buildings slated for burning is critical.  Plexus should double-check
their estimates by reviewing Army manifests and purchase records for
Badger.  For example, if 10,000 board-feet of treated lumber was
purchased for Building 5012, then 10,000 board-feet of treated lumber
should be accounted for in that building.  This exercise may uncover
toxic materials that have not been anticipated or accounted for. 

 

*	Plexus estimates that up to 135 buildings will require selective
demolition--demolition in which explosive-contaminated equipment will be
removed from non-burn buildings and placed in buildings that are slated
for burning.  Plexus estimated that there will be 240 pounds of lead
paint in the first 30 buildings that are burned.  Does this estimate
include lead paint on the equipment from the non-burned buildings that
will be placed into the burned buildings?  If not, when will the
modeling be re-run with the correct quantities of hazardous materials? 

 

*	Why is the public comment period for this major step at Badger
only 14 days, when 30 days of public comment is more typical.  The
Badger Plant is one of the most significant hazardous waste sites in
Wisconsin.  The 14-day comment period announced at the public meeting
gives the impression that the process is being rushed in order to
minimize public input.   The open-burning portion of the
building-demolition plan is a potential environmental nightmare for the
citizens of Wisconsin, so it should be done thoughtfully and thoroughly.


 

*	What would happen if there is a major underground detonation
during the open-burning--for example, a detonation inside a large
underground pipe, sump or cavity beneath the floor slab.  Plexus
emphasized that the buildings slated for burning are saturated with
explosive residues and hence pose an unacceptable risk to demolition
workers. A small underground explosion has already occurred at Badger in
building 9024 with enough force to lift the 200-ton floor slab.  What if
a larger underground detonation creates a dust cloud that moves
contaminants along the ground as a gravity current--a mixture of dust
and air like the one that rolled along the ground after the World Trade
Center collapse?   What if this dust cloud settles on a residential
area?  Has this possibility been assessed?  The EPA has a computer model
for modeling gravity currents.  This model was used to assess
particulate exposure in the vicinity of the World Trade Center.  Perhaps
you could research the applicability of this model to a large subsurface
detonation at Badger. 

 

*	One way to monitor the heavy-metal exposure to children is
through blood tests.  The demolition plan could be modified to include
random heavy-metal testing in children and infants in the affected area.
Doctors in the community could be alerted to the symptoms of heavy-metal
exposure.  Here is an excerpt from a study conducted at Harvard
University that describes lead monitoring in children. 

 

Howard Hu, M.D.
Channing Laboratory, Harvard University



Special Considerations: Environmental Exposures, Children, and
Reproductive Toxicity

Lead exposure and toxic outcomes comprise issues that go far beyond the
work place. The use of lead in consumer products, particularly as an
additive of gasoline (resulting in the widespread atmospheric dispersion
of combusted lead oxide) and a major ingredient of paint, water pipes,
plumbing solder, and food cans, has resulted in exposure at a low to
moderate level to almost all segments of society. This may have
ramifications in terms of risk of hypertension and kidney disease, as
noted previously, in addition, for children, a generation of sensitive
prospective studies has convincingly demonstrated that low-level lead
exposure in children less than 5 years of age (with blood lead levels in
the 5-25 mug/dL range) results in deficits in intellectual development
as manifested by lost intelligence quotient points.[2
<http://home.mdconsult.com/das/article/body/jorg=journal&source=MI&sp=11
536704&sid=51395503/N/200127/#R0983002> ] As a result, in 1991, the US
Centers for Disease Control (CDC) lowered the allowable amount of lead
in a child's blood from 25 to 10 mug/dL and recommended universal blood
lead screening of all children between the ages of 6 months and 5 years.
The CDC also has specific treatment recommendations for children who
have elevated blood lead levels (http://www.cdc.gov/nceh/lead/lead.htm),
and clinicians should cooperate closely with local health authorities
who are empowered to investigate and manage home lead exposures.

 

*	The open-burning plan at Badger requires a pilot test to
establish proof-of-technology.  The pilot test can be carefully
monitored to determine if the modeling results are credible.  University
researchers should be invited to participate. 

 

*	The Army's demolition plan does not include a contingency plan
in the case there is a major, unforeseen event--like a large underground
detonation.  If a carefully-engineered structure, like a Space Shuttle,
can explode over Texas, then it is certainly possible for a
miscalculation to occur during a complex demolition project.  The
contingency plan could include an evacuation plan for local residents
and a residential cleanup plan in the event that the modeled exposures
are exceeded. 

 

*	.        Plexus maintains that there is no safe alternative to
open burning.  Has Plexus looked at the possibility of cryo-demolition
(demolition at low temperatures)?  Our cold Wisconsin winters might
provide a safe environment for demolition.  Nitroglycerine is highly
stable at low temperatures, as the following citation indicates: 

 

"Late in the 1860s, workers found that nitroglycerine that had been
frozen was almost impossible to detonate, and so manufacturers began to
freeze it for shipment. However, this was clearly a stopgap solution."

 

 

In summary, the Badger Plant was operated during periods of national
emergency and at a time when we didn't understand the health and
environmental dangers of toxic chemicals.  Large volumes of toxic
materials were used, and disposed-of, in the most expedient
fashion-often by pouring them into the ground.  This expedient path
resulted in over 200 million dollars in environmental damage.  Now the
Army again wants to do the expedient thing-implement a plan that does
not fully assess the risks of open-burning and contains no provision for
sampling of air, soil or groundwater downwind of the burning. This
"expedient plan" is a potential environmental disaster for the citizens
of Wisconsin.  An unprecedented waiver from the environmental laws of
Wisconsin requires an unprecedented level of ground-truthing and
monitoring.  The current plan contains none.  The overall burning  plan
is seriously flawed in it's current form and should not be allowed to
move forward into the implementation phase. I would like a written
response from the DNR to the questions and concerns outlined in this
letter.

 

 

 

Sincerely,

 

 

Paul Herr, MS. MBA

Professional Geologist

 

 

 

--

Laura Olah, Executive Director

Citizens for Safe Water Around Badger

E12629 Weigands Bay S

Merrimac, WI 53561

phone: (608)643-3124

fax: (608)643-0005

email: info@cswab.com

website: http://www.cswab.com <http://www.cswab.com/> 

 

 

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