Hazardous wastes that cannot be incinerated because they are too contaminated and may explode are processed at the RAAP Hazardous Waste Management Unit (HWMU) 13 or open burning ground. It is regulated under 40 CFR Part 264 Subpart X (as incorporated by 9 VAC 20-60-264) that limits the type and amount of hazardous waste propellant that is burned at the site. These regulations require that units are constructed, operated and maintained in a way that will prevent unsafe releases of pollutants into the groundwater, surface water, wetlands, soil or air.
Radford submitted the renewal application for the Open Burning Grounds RCRA permit on June 15, 2015. As part of the renewal process, a revised Multi-Pathway Risk Assessment (MPRA) report addressing human health and ecological impacts of the thermal treatment operation was required. The purpose of the report was to demonstrate that there were either no unacceptable risks at the current permitted throughputs or to propose lower throughputs until an acceptable risk is met. The MPRA report was approved on October 5, 2020 and a draft permit was prepared for public notice and comment. The final permit was issued on August 18, 2021, and is effective for 10 years.
How does the open burning ground work?
The open burning ground (OBG) is an area at the plant where waste propellant is processed by burning. This type of waste is considered hazardous, containing contaminants like small metal objects that cannot be safely processed by the equipment at the facility’s incinerator. As a result, open burning is conducted in a monitored process that is subject to strict hazardous waste regulations and contaminant feed rates. Prior to environmental laws, these wastes were burned directly on the bare ground, causing pollutants to accumulate in the soil and, in some areas, contaminate ground water. Today, groundwater is protected through environmental permits, corrective actions and site monitoring.
An environmental permit is required for processing all hazardous wastes and sets forth the conditions for safe burning. For example, all wastes are burned on steel pans that are lined with six inches of clay or ceramic to insulate the metal from the heat of an open fire. These pans are inspected daily and may be covered in the event of precipitation. The permit also limits the amount of waste that can be burned and the concentration of contaminants. The Department of Defense's Safety Procedures for open burning operations restricts the facility to lighting only four or five of the 16 total pans per day, also minimizing the release of pollutants into the air.
Does the open burning ground permit consider the impact of pollution on neighboring homes and schools?
Yes. The permit was developed based on the results of human health risk assessments, ecological risk evaluations and operational inspections. Permits are written so that facilities comply with these regulations, specifying that no open burning operation will pose a threat to human health or the environment.
How is the environment protected from waste treated at the open burning ground?
DEQ issued a permit in 2005 that protects human health and the environment and meets all requirements under the state and federal laws and regulations that govern its operation. The OBG permit specifies that only reactive and certain ignitable types of waste propellants may be burned at this site, and limits pollutant concentrations in the waste propellant for each burn event. The permit specifies how RAAP must measure and calculate the concentrations of pollutants in the waste propellants that may be burned at any time. These restrictions are based on the results of human health and risk assessments.
Are people (boaters, swimmers, anglers, etc.) who use the New River protected from nearby waste propellants?
Yes. The open burning ground permit is in place to protect public health in recreational settings. The plant is located along the New River where citizens fish, swim and boat. During waste incineration, RAAP posts scouts at two observation points on the New River in front of the open burning site. Waste will not be burned if anyone is seen in the monitored area. Operators turn on flashing red lights along the river to alert boaters that waste burning is about to begin. A warning siren is also sounded, as well as the following announcement:
“Warning. The burning ground of the Radford Army Ammunition Plant is about to begin burning operations. Evacuate the river area immediately.”
If anyone is seen in the burning area, they are first given a verbal warning. Burning will not commence until the area is clear, and waste is ignited only when the operators are sure that no one is on the river or surrounding shoreline.
Does pollution runoff from the open burning ground contaminate the New River?
The Radford facility uses tile drains to prevent contaminants from entering the New River via storm water runoff. These drains transport runoff from the open burning site to a “storm water management pond,” which is closely monitored under the requirements of the Virginia Pollutant Discharge Elimination System permit.
How is groundwater protected from pollutants at the open burning ground?
As part of its permit, the RAAP maintains a groundwater compliance network of wells around the open burning ground (OBG) and monitors the groundwater in the uppermost aquifer. The network currently consists of two up gradient wells and five down gradient wells. The facility proposed to add one down gradient well and discontinue sampling of one up gradient well (these changes to the compliance network constituted the Class 2 permit modification that was approved by DEQ on June 18, 2013). Groundwater samples taken from these wells twice a year are analyzed and compared (or screened) against Groundwater Protection Standards (GPS) to identify the presence of hazardous waste derived constituents, to verify that the pollution plume is not expanding down gradient, laterally or vertically) and to verify that there are no unacceptable releases into down gradient areas, such as the New River.
How does the public know that the Radford plant is conforming to the regulations that govern burning operations?
To ensure compliance with state and federal regulations, DEQ carefully reviews facility records and formally inspects OBG operations at least once per year. The Environmental Protection Agency (EPA) requires DEQ to inspect all permitted units and hazardous waste management activities. An inspection often occurs after burning pans have been loaded with waste, but before burning, allowing DEQ to ensure that waste propellants conform to the permitted requirements. DEQ periodically inspects pans during or after a burn under safe conditions. The facility is required to keep operational records detailing the composition of the materials that are burned. DEQ reviews the records to ensure compliance with the allowable amounts. The calculations for each pollutant and each burn event are reviewed to ensure that the pollutants are within the permitted concentration limits.
What is the standard for perchlorate in groundwater at the open burning ground?
As of September 2011 perchlorate results are screened against the groundwater protection standard (GPS) of 26 micrograms per liter (or parts per billion, ppb). This standard is based on the published EPA risk-based screening level. By letter dated June 14, 2012, DEQ advised RAAP “to also screen the data against the EPA interim health advisory goal of 15 ppb recommended for drinking water.” Since the GPS for perchlorate was established (26 ppb), the facility has exceeded the standard twice in one monitoring well (13MW4). The approved permit requires RAAP to screen perchlorate against the more stringent risk-based level of 15 ppb.
What happens when pollution at a facility exceeds groundwater standards?
When a facility exceeds a groundwater protection standard, the facility enters into a corrective action program to implement a selected remedy and monitor the nature and extent of the contamination. RAAP has already entered the corrective action program and in accordance with its OBG permit, is implementing a “monitored natural attenuation” program. Monitored natural attenuation -- which means the contaminant is allowed to break down and decrease naturally – is allowed when pollution concentrations are low, appropriate subsurface conditions exist, the contaminant concentrations are trending downward, and the expected period of time for contaminant concentrations to fall below the groundwater protection standard is within a reasonable timeframe. The corrective action program at the open burning ground must demonstrate compliance with the groundwater protection standard for three consecutive years before termination of the program can be requested. Any existing or new health advisory or maximum contaminant levels will be considered in future decision-making regarding the groundwater program at the open burning ground.
What water quality standard is used for protecting groundwater?
The open burning ground is not a source of drinking water, so a groundwater protection standard is established. Groundwater protection standards are based on U.S. Environmental Protection Agency-approved risk-based screening levels for tap water and maximum contaminant levels when available. These standards are intended to ensure that contaminated groundwater does not present a risk to human health. A maximum contaminant level is the highest level of a contaminant that is allowed in drinking water. MCLs are set as close to the maximum contaminant level goals as feasible using the best available treatment technology.
