Invitation to Co-Sign Comments to EPA
Laura Olah / Citizens for Safe Water Around Badger
(January 4, 2021) — Every year, Tennessee’s Holston Army Ammunition Plant is permitted to open burn 1,250,000 pounds of toxic munitions wastes that may contain as much as 15% PFAS by weight. (PFAS chemicals — aka “forever chemicals” — are Per- and poly-fluoroalkyl substances, including Teflon, Viton, and Viton-A.) US EPA and Tennessee regulators have announced that they are accepting public comment on this practice.
To have the greatest impact, we are inviting you to co-sign our comments — individuals and organizations are both welcome!
A win in Tennessee is an important first step in stopping open burning at military sites everywhere!
ACTION: Please sign on comments to EPA opposing open burning of PFAS here! (You do NOT have to be from Tennessee to sign on.) Deadline to sign on is January 15, 2021.
Want to learn more before you sign on?
The complete URL is: https://docs.google.com/forms/d/e/1FAIpQLScHJ70_d1qBN1j9A7eb5Gdi6wV22Ur7xBE-96Zeq0Lqg1JFkg/viewform
Petition to EPA: Opposing Burning PFAS Munitions
Laura Olah / Citizens for Safe Water Around Badger
(January 4, 2021) — Who can sign-on? As these public comments address both federal and state environmental health policy, all US residents (from any state or territory) are free to sign on. Questions? Contact Citizens for Safe Water Around Badger (CSWAB.org) at info@cswab.org or phone (608) 643-3124.
THE LETTER
Public comment opposing burning of PFAS and other highly toxic munitions wastes at Holston Army Ammunition Plant in Tennessee.
Travis Blake, Division of Air Pollution Control
Tennessee Department of Environment and Conservation
air.pollution.control@tn.gov
Regional Administrator Mary Walker
ATTN: César A. Zapata, Director
Land, Chemicals and Redevelopment Division
United States Environmental Protection Agency, Region 4
Zapata.Cesar@epa.gov
PUBLIC COMMENT SENT BY ELECTRONIC MAIL
Dear Mr. Drake and Mr. Zapata,
The Tennessee Department of Environment and Conservation, Division of Air Pollution Control is reopening two existing major source operating permits issued to BAE Systems Ordnance Systems Inc. (BAE) at Holston Army Ammunition Plant, subject to provisions of the Tennessee Air Pollution Control Regulations.
A major source-operating permit is required by both the Federal Clean Air Act and the Tennessee Air Pollution Control Regulations. EPA will perform a 45-day review concurrently with the state public comment period. Both agencies are accepting public comment on draft conditions and permit modifications.
The proposed permit modifications include a condition that expressly prohibits open burning of asbestos, which we support, but the condition fails to address other highly toxic waste constituents in this same waste treatment stream, particularly PFAS.
Exposure to PFAS has been shown to affect growth and development, reproduction, thyroid function, the immune system, injure the liver and increase risk for certain cancers.
The current permit conditions allow Holston Army Ammunition Plant to annually open burn as much as 1,250,000 pounds of munitions wastes that may contain as much as 15% PFAS by weight. PFAS are not destroyed in an open fire and are therefore widely dispersed to the air and the surrounding environment where they accumulate in people, as well as fish, wildlife and food crops.
At higher temperatures, poisonous hydrogen fluoride gas may be generated. Hydrogen fluoride is a listed hazardous air pollutant subject to regulation by US EPA and authorized states under the Clean Air Act, as are other air emissions from open burning at Holston.
At other Department of Defense sites — like the Blue Grass Army Depot in Kentucky — the military is expressly prohibited from open burning PFAS and dozens of other toxic wastes. Both Blue Grass and Holston are located in EPA Region 4. And we are adamant that Tennessee residents, workers and environment are afforded the same level of protection as their Kentucky neighbors.
Therefore, we request that the permit condition prohibiting open burning of asbestos (or other appropriate condition) be EXPANDED to include the following which are gleaned from the Blue Grass permit:
Specifically, the Permittee shall not treat, by either open burning or open detonation, munitions or wastes that contain any of the items or substances listed below:
• Hazardous waste from offsite sources
• Ammunition that is 0.50 caliber or smaller
• Municipal waste
• Dunnage
• Containerized gases
• Oil
• Pesticides
• Herbicides
• Ammonium perchlorates
• Dioxins or furans
• Titanium tetrachloride
• Polychlorinated biphenyls (PCBs)
• Flechettes
• Rounds containing submunitions
• White phosphorus
• Red phosphorous
• Colored smoke
• Hexachloroethane (HC) smoke
• Napalm
• Riot control agents
• Biological agents
• Choking agents
• Nerve agents
• Blood agents
• Blister agents
• Incapacitating agents
• Chemical warfare materiel
• Components of liquid filled rounds or chemical warfare materiel
• Nuclear components or devices
• Naturally occurring radioactive materials
• Depleted uranium (DU)
• Any liquids or items containing free liquids
• Asbestos
• Munitions wastes that are a potential source of Per- and polyfluoroalkyl substances (PFAS), including Teflon, Viton, and Viton-A. This also includes both short and long chain PFAS
• Waste Military Munitions with a different chemical composition from those already being treated at Holston
Source document: Hazardous Waste Facility Permit, Open Burning and Open/Buried Detonation (OB/OD) Section, Blue Grass Army Depot, KY8-213-820-105 AI: 2805 Activity: APE20040007, November 2018.
Online at https://cswab.org/wp-content/uploads/2018/12/Bluegrass-Army-Depot-OBOD-Final-Permit-Nov-2018.pdf
IMPORTANT NOTE:
These public comments are not to be construed as supporting ANY open burning at Holston — the public notice specifies that regulators are only accepting comment on proposed conditions and permit modifications and our comments are submitted in this specific context.
Thank your careful consideration of our comments and recommendations.
Sincerely,
(Responses to date: 49 organizations, 142 individuals.)
Laura Olah is the Executive Director of Citizens for Safe Water Around Badger and National Coordinator of the Cease Fire Campaign. CSWAB, E12629 Weigand’s Bay South, Merrimac, WI 53561. (608) 643-3124. info@cswab.org, www.twitter.com/CSWAB, www.facebook.com/cswab.org, www.facebook.com/ceasefirecampaign
