Activities at 28 closing Army ammunition production facilities with a total of number of more than 16,000 buildings and structures could be affected.
In a July 7 letter to the Army, the EPA asks for a detailed response to questions about the status of demolition of buildings, management and storage of PCB wastes, research on destruction or removal of paint, and operation of decontamination ovens.
Army facilities that the EPA has identified as having PCB contamination include the Badger Army Ammunition Plant in Wisconsin, the Sunflower Army Ammunition Plant in Kansas, Iowa Army Ammunition Plant, Cornhusker Army Ammunition Plant in Nebraska, as well as the Kansas Army Ammunition Plant and the Ravenna Arsenal in Ohio.
Polychlorinated biphenyls are mixtures of up to 209 individual chlorinated compounds - either oily liquids or solids that are colorless to light yellow with no smell or taste. Some PCBs can exist as a vapor in air.
PCBs have been used as coolants and lubricants in transformers, capacitors, and other electrical equipment because they don't burn easily and are good insulators. The manufacture of PCBs was stopped in the U.S. in 1977 because of evidence they build up in the environment and can cause harmful health effects. Products made before 1977 that may contain PCBs include old fluorescent lighting fixtures and electrical devices containing PCB capacitors, and old microscope and hydraulic oils.
The Department of Health and Human Services has concluded that PCBs may reasonably be anticipated to be carcinogens. The EPA and the International Agency for Research on Cancer have determined that PCBs are probably carcinogenic to humans.
PCBs also are linked to other adverse health effects on the human immune system, reproductive system, nervous system, and endocrine system.
The EPA inquiry comes as good news to community activists who have been challenging the military's use of thermal treatment to decontaminate objects that contain PCBs, lead and other toxins.
Badger Army Ammunition Plant (Photo courtesy CSWAB)
"It took six years of dedicated work to get this issue to the forefront," said Laura Olah, executive director of the nonprofit group Citizens for Safe Water Around Badger.
"The EPA's action is a critical first step in protecting nearby families and workers from exposure to PCBs and other toxins that are being handled and disposed of as part of base closure and realignment," she said.
Nitrocellulose-based propellants were manufactured at Badger during World War II, the Korean War, and the Vietnam War. The largest ammunition plant in the world when it was built during World War II, Badger is currently the site of demolition and remediation projects being conducted in preparation for property transfer to state and federal agencies.
The decontamination oven, located on the west side of Badger Army Ammunition Plant near the Bluffview community, is an example of an uncontrolled and unpermitted source of toxic emissions caused by the thermal treatment of contaminated metal objects.
Early in 2008, Badger provided state and federal regulators with test results for paint samples taken from cross sections of plant equipment and piping that were analyzed for both lead and PCBs.
The Army reported lead concentrations as high as 260,000 parts per million, ppm. By comparison, lead paint is defined as having concentrations greater than 5,000 ppm.
The Army also reported PCB concentrations as high as 76,000 ppm in paint samples.
Paint containing PCB concentrations greater than 50 ppm is regulated by the EPA as "PCB bulk product waste" and the decontamination oven is considered a form of disposal subject to regulation if used to decontaminate any materials covered with such paint.
The oven uses heat to degrade potential explosive residues on pipes, valves, and other equipment before it is sold as salvage. Equipment is placed into the oven and the temperature is raised to 450° F for several hours – a process that could volatilize PCBs.
Fugitive emissions are released directly to the open air and surrounding environment as the oven has no air emissions controls. Olah says testing near a former oven at Badger found elevated levels of PCBs in surrounding soils.
The federal Toxics Substances Control Act gives EPA the authority to regulate PCBs. Once in the environment, PCBs do not readily break down and therefore may remain for long periods of time cycling between air, water, and soil.
Copyright Environment News Service, ENS, 2009. All rights reserved.