This report is presented by Earthjustice’s Community Partnerships Program and the Center for Progressive Reform in partnership with Citizens for Arsenal Accountability.
Executive Summary
At military bases across the country, the Department of Defense (DoD) has for decades relied on a practice known as open burn/open detonation (OB/OD) to destroy excess, unserviceable, or obsolete military munitions, including small arms cartridges, rockets, mortars, missiles, and other items.
Open burn and open detonation harm the environment and human health as these practices result in the uncontrolled release of toxic constituents directly into the air, soil, and groundwater. This report focuses on one of the facilities that continues to use open burning to destroy munitions in close proximity to elementary schools, community members, and college students – the Radford Army Ammunition Plant (RAAP or the Arsenal) in Radford, Virginia.
RAAP has released millions of pounds of harmful toxins and heavy metals into surrounding communities and the environment as a result of its day-to-day operations. The facility has made matters worse with its long record of violations and lack of compliance with permitting requirements. As a result, nearby residents face pollution burdens that create an elevated risk of asthma and cancer compared to the rest of the state. On top of all of this, RAAP and the Virginia Department of Environmental Quality (VDEQ) have also failed to provide sufficient transparency about operations at the Arsenal. Community members are often left in the dark not knowing what they are being exposed to or what is being done to ensure they are protected.
In 2021, VDEQ renewed two ten-year hazardous waste permits for RAAP – one to continue open burning and a second that allows the continued use of two existing incinerators along with the construction of a new incinerator complex that will contain multiple hazardous waste units, including two incinerators and a contained burn chamber. These permits lack crucial protections and information that community members need. The open burning permit allows RAAP to open burn hazardous wastes for another decade even though safe alternatives exist now. Further, the incinerator permit allows the continued use of old incinerators that have been in operation since the 1970s along with the new incinerators that were supposed to replace them. All of this means that RAAP is permitted to operate numerous hazardous waste burning units at once, exacerbating concerns that nearby communities will be exposed to significant amounts of toxic pollution indefinitely. Additionally, RAAP never assessed the cumulative impacts of all of these operations occurring together, and instead piecemealed each risk assessment to only look at one process at a time even though that is not how community members experience toxic hazards. VDEQ also failed to sufficiently engage in outreach to community members during the permitting process, with many people unaware of the permit renewal processes at all and others provided with insufficient time to adequately comment on highly technical and complex documents.
The harmful pollution from RAAP has continued for too long without adequate oversight or accountability. As such, Citizens for Arsenal Accountability make the following recommendations:
- End Open Burning at RAAP: Open burning of hazardous wastes at RAAP must end, and the facility should put in place the safest alternative technology.
- Third-Party Alternatives Assessment: An alternatives assessment should be conducted by a neutral third party to ensure that the facility has chosen the most environmental and health protective option.
- Close the Old Incinerators: The two old incinerators at RAAP must close once an alternative technology is in place, pursuant to a transparent and enforceable schedule.
- Improve Transparency and Community Involvement: VDEQ and RAAP should make greater efforts to ensure that community members are aware of what is happening at the facility, including, for instance, creating an online repository of information.
- Improve Compliance: VDEQ must ensure that there are consequences for noncompliance and that the facility takes affirmative steps to make sure that violations do not continue to occur.
- Conduct a Cumulative Hazard Assessment & a Community Health Assessment: Virginia legislators should allocate funding so that a cumulative hazard assessment and a community health assessment can be conducted by a neutral third-party.
