The ‘Insane’ Plan To Burn 80,000 Pounds Of Chemical Explosives, Out In The Open, Every Day For A Year
Just a few miles away from the population center of Minden, Louisiana, 15 million pounds of military explosives are sitting in cardboard boxes, waiting to detonate.
The massive stockpile of explosive M6 propellant has been stored at a Louisiana National Guard military training site called Camp Minden since 2010, when the U.S. Army sold it to a company to be destroyed. But the company, Explo Systems, never actually disposed of it — they just left it in the boxes. Now the M6 is rapidly deteriorating, and by August, its risk of spontaneous combustion will greatly increase.
The Environmental Protection Agency, the U.S. Army, and two Louisiana state agencies have put forth a solution: Burn it. Burn the M6 in the open over the course of one year. Put it in trays, light it on fire, and let the smoke and fumes drift into the air. A year-long schedule would amount to 80,000 pounds of chemicals burned each day.
“We believe this would be the largest chemical burn of its kind in U.S. history,” said Frances Kelly, director of organizing for Louisiana Progress Action, and one of the loudest opponents of the plan. “It’s very scary.”
As Kelly and others in Minden fight for an alternative disposal, it’s sparked a bigger conversation about open munitions burning far beyond Louisiana. Across the country, the military regularly disposes of its huge stockpile of excess and obsolete explosives, propellants, and munitions by burning them. The regulations surrounding these burns are confusing, sometimes bypassing environmental review until after a burn has been agreed to. What’s more, these open burns have largely flown under environmentalists’ radar, despite well-documented evidence showing long-term public health and environmental risks.
“Most people don’t realize it, but most munitions are never used in war,” said Lenny Siegel, the director of the Center for Public Environmental Oversight. “Most sit around, become out of date, and are never fully used. The Army’s way of dealing with that is not fully comprehensive.”
America’s Wartime Leftovers
Siegel is a California-based environmental activist. What makes him different than most, though, is that he spends much of his time speaking up about military contamination issues. He’s been doing it for the last 25 years.
When it comes to ammunition, propellants, explosives — anything that falls into the category of ‘munitions’ — “It’s a constant flow,” Siegel said. “[The Department of Defense] is constantly producing stuff. And they don’t use it all.”
Specifically, the Army — which is in charge of dealing with unusable munitions for the Department of Defense — had more than 557,000 tons (1.1 billion pounds) of munitions that needed to be demilitarized as of 2010, according to a recent report from the U.S. Government Accountability Office. A 2008 report from the non-profit Association of the United States Army said it costs about $2,200 per ton to demilitarize this stockpile, putting estimated disposal costs at around $1.2 billion.
Open burning and open detonation is the least expensive and most commonly used form of disposal, the report noted. But as more environmental concerns have come to light, the more expensive methods of closed burning and recycling are becoming preferred.
Still, it’s unclear exactly how much open burning is happening today, and according to Siegel, that’s because the process as a whole is unorganized.
“The Army does not have a comprehensive program for disposal of its serviceable munitions,” Siegel said. “You can’t go to the Army and say ‘give me a report on your munitions disposal.'”
When asked about the amount of munitions that are disposed of by open burn, Army spokesperson Dave Foster told ThinkProgress that more than 18 million pounds of propellant were burned through 12 open burn projects in fiscal year 2014. So far in fiscal year 2015, he said three open burn projects have been funded to destroy 2.5 million pounds of propellant.
Propellant, however, is just one form of munitions. Foster wasn’t able to provide the total amount of munitions burned at all the Army’s facilities, but he did provide numbers for three: the Crane Army Ammunition Activity in Indiana, the Hawthorne Army Depot in Nevada, and the McAlester Army Ammunition Plant in Oklahoma.
For fiscal year 2014, Foster said 10 million pounds of munitions were burned at Crane; 1.4 million pounds were burned at McAlester, and no munitions were burned at Hawthorne. In fiscal year 2013, 1.7 million pounds of munitions were burned at Crane, 2.8 million pounds were burned at McAlester, and 292,000 pounds were burned at Hawthorne. Similar numbers were provided for fiscal years 2010, 2011, and 2012. As with Foster’s estimation of the amount of propellant burned, it’s unclear if the numbers include burns by the Army alone, or if they include burns that have been conducted by contracted companies.
Either way, the figures do make one thing clear: if the proposed open burn at Camp Minden is approved, it would amount to more munitions burned than at each of the three government-owned facilities every year combined, and nearly as much total propellant burned by the Army in the entirety of 2014. That, according to Siegel, is “a highly unusual situation.”
‘Like A Stampede Coming At The House’
When the EPA first announced its intention to have an open burn of the 15 million pounds of M6 this past October, it was met with loud and fierce opposition from community members in Minden who feared what a huge chemical burn would do to their long-term health. Nothing like this had ever been approved by the EPA before.
“I think people are concerned because of the science, what these chemicals could do,” Kelly said. “Louisiana does have a long history of environmental problems, we have cancer, we don’t want any more.”
Eventually, as community opposition was elevated to a national audience, the EPA announced it would consider other disposal options for the explosives. But still to this day, open burn remains on the table.
CREDIT: Graphic by Dylan Petrohilos
Still, Minden has a unique need to get rid their explosives, and most people are well-aware of what could happen to deteriorating M6 if it isn’t moved or destroyed. And that’s because some of it already exploded.
Two years ago, resident Melissa Downer said she was locking up her dogs in her garage, about 15 miles from Camp Minden, when she heard a massive boom. “It sounded like a stampede coming at the house, and all of a sudden they ran into the door,” she said. “It was horrifying.”
The explosion on October 15, 2012, happened in just one of the 97 bunkers that were being used to store M6 at Camp Minden. It shattered windows as far as four miles away and generated a 7,000-foot mushroom cloud, according to the EPA. Four hundred homes and a school were evacuated, and a local jail was forced to follow in-shelter procedures. No one was injured.
But the most significant impact of the explosion was not the shattered windows — it was the Louisiana State Police’s discovery of those other 96 bunkers containing 15 million pounds of M6 and eight million pounds of other improperly stored explosives. The discovery was shocking. No one, aside from Explo Systems, knew about them before the incident. The police directed Explo to secure the material.
Downer, a stay-at-home mom with three children aged 3, 7, and 9, said the community’s reaction was relatively mild. This one was particularly big, but explosions just happen sometimes in Minden, a military community and former home to an Army Ammunitions Plant. What’s more, national news was covering the story like wildfire, so it seemed like things were being taken care of.
“Immediately I thought, ‘OK, it’s being handled,'” she said. “And it was under the radar for the next two years.”
Opening The Door For Open Burn
According to court documents, the Army in 2010 paid Explo $8.6 million to recycle the M6 and reprocess it into explosives used by the mining industry. This sale essentially wiped the Army’s hands clean of responsibility for the M6.
But in the months following the explosion, Explo went bankrupt. The M6 suddenly belonged to nobody. And since Louisiana owned Camp Minden, the state was forced to take ownership of the explosives.
CREDIT: Screenshot from EPA internal dissent document
The state, however, didn’t know what to do with a massive pile of deteriorating M6. So the EPA — and then subsequently the Army — stepped in to try and find a solution. The Army dispatched a team to the site, and in a report dated April 18, 2013, recommended significantly reducing the amount of M6 stored at Camp Minden as soon as possible. “The preponderance of evidence indicates that the probability of an explosives event directly related to the long-term storage of M6 propellant at Minden is likely,” the report found.
The Army made no recommendation for which type of disposal method to use. Ultimately, the four agencies agreed to sell it to a company that could remove and destroy it. That company, according to the agreement, would be required to “employ the use of on-site open burning in burn trays.”
It’s not clear why, exactly, the four agencies decided that burning was the best solution for the M6, or why it was made a requirement. When asked via e-mail, Foster referred ThinkProgress to the EPA. “It was a decision by the EPA to conduct open burning of the M6 propellant,” he said. But David Gray, the EPA representative tasked with handling the Camp Minden situation, was unwilling to say it was the EPA’s decision. “It has certainly been characterized that we did it alone,” he said, “but we are of the perspective that the agreement was signed by four parties.”
For his part, Foster said it wasn’t unusual that the Army would sign off on such an agreement. “It is my understanding the U.S. Army conducts, at the installation level, open burning of propellants because it burns cleanly,” he said.
‘This Isn’t Just Crazy. This Is Insane.’
Not everyone agrees, however, that open burning of propellants burns cleanly. Particularly Brian Salvatore, a chemistry professor at Louisiana State University at Shreveport.
“I only started recognizing how serious this threat [of open burn in Minden] was when I heard about what the solution was. I thought, well if the solution is this crazy, something is going on here,” Salvatore told ThinkProgress in a phone conversation last month. “When I looked up the chemicals, I thought, ‘this isn’t just crazy. This is insane.'”
CREDIT: Graphic by Dylan Petrohilos
Not all propellants are created equal, but M6 is a particularly risky propellant to burn, Salvatore explained. M6 — essentially a smokeless gunpowder — is mostly made of nitrocellulose, which literally vaporizes things. But to make it really useful, chemicals need to be added. For M6, those chemicals include dinitrotoluene, which slows down the combustion; dibutylphthalate, to prevent the flash; and diphenylamine to stabilize the nitrocellulose.
“The additives are the main problem,” Salvatore said. “These things are the volatile organics we should be worried about.”
Dinitrotoluene is the worst one to be released into the air, Salvatore said. It is classified as a probable human carcinogen, with chronic exposure likely to produce organ damage, particularly in the liver and kidneys where to molecule is metabolized. Dibutyl phthalate is also not great — exposure has been linked to a high rate of birth defects in males, including “defects in the structure of the penis,” according to the Centers for Disease Control and Prevention.
If these chemicals are released, Salvatore said, they have the potential to travel long distances by attaching to particulates — for instance, dust. And they’re almost guaranteed to be released during an open burn, because M6 often does not completely combust when subjected to open burning, according to a 2013 study published in the Journal of Hazardous Materials. That, among other reasons, is why Canada placed a ban on open burning of gun propellant in 2010.
“You can’t even combust one ounce of this in Canada, and here they’re planning to combust 15 million pounds,” he said. “It’s incredible.”
‘[A] Relatively Uncontrolled, Dirty, Polluting Technology’
EPA documents discussing Camp Minden show there was at least slight disagreement within the agency on whether to conduct the open burn. In one document discussing the plan, for example, an unnamed EPA representative strongly discouraged the practice. “Because alternatives to open burning are available, we should not require, or even encourage, [open burning] in this case,” the document reads. “[O]pen burning … is a relatively uncontrolled, dirty, polluting technology that should therefore be reserved for situations when there are no practical alternatives.”
There seems to be little precedent within the EPA for how to handle a burn this large, and to ensure it’s done with minimal environmental impact. David Gray, who has worked at the EPA since 1987 and overseen Region 6 since 1995, said he’s never worked on a project associated with the open burning of propellant.
“I wouldn’t want to say the agency has never done it in some department, but I certainly haven’t done one, and I think it’s fair to say that I definitely don’t know of another experience where we’ve dealt with 15 million pounds of propellant,” Gray said.
Representatives from the EPA did not answer inquiries from ThinkProgress about the number of open munitions burning cases that the agency has been involved in, but noted that an open burn can be regulated either by the Resource Conservation and Recovery Act (RCRA), or the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), also known as Superfund.
“Whether and how the burning is addressed by these authorities depends on the specific circumstances,” EPA spokesperson Laura Allen said via e-mail.
Usually, Allen said, entities wishing to open burn any explosives in the United States need to obtain a permit under RCRA, the law that governs hazardous waste disposal. Hazardous waste is not legally allowed to be burned in the open, but there’s an exception for explosives because of their propensity to blow up.
In Minden, however, the burn is being conducted under CERCLA, because it’s being counted as a “cleanup action.” As it turns out, the M6 has already contaminated soil, groundwater, and surface water surrounding the plant. Because of that, the burn is being treated as a “time critical removal action” under CERCLA, Allen said.
For people in Minden concerned about potential environmental impacts, dealing with the regulatory process has been frustrating. CERCLA is exempt from issuing environmental impact statements — meaning, no environmental assessment was done before the burn was agreed to. With CERCLA, the environmental impact statement “comes later,” Gray said, after a contractor has been chosen to perform the open burn. “Whoever conducts it has to come forward with an environmental plan, then they do a trial burn, and they demonstrate that it can be done within the environmental regulations.”
Because CERCLA agreements are carried out through the courts, no one in Minden knew an open burn was in the works until the agreement had already been signed. There was no public debate. Gray acknowledges that circumventing the public was not ideal.
“There really wasn’t an opportunity for an enhanced public dialogue,” he said. “It didn’t allow for this public input that was so important.”
Burning Beyond Minden
Fortunately for concerned parties, the public was able to put enough pressure on the EPA to reconsider only allowing open burn. Gray takes credit for convincing the Army, the Louisiana National Guard, and the Louisiana Department of Environmental Quality to revisit the decision. “We pushed everyone to pause and to create this public process and to do it in a way that is also open to alternatives,” he said.
Now, public meetings to dicuss alternative disposal methods are underway in Minden — options like recycling and closed burns. But in other communities across America, open burns are happening without much public debate and, some argue, without sufficient air quality monitoring.
CREDIT: CONCERNED CITIZENS OF THE CAMP MINDEN M6 OPEN BURN FACEBOOK PAGE
While not to the scale of the Camp Minden proposal, many military munitions plants near population centers are currently utilizing open burning on a daily basis. At the Radford Army Ammunition Plant in Virginia, British company BAE Systems holds a RCRA permit allowing for the open burn of 8,000 pounds of “munitions constituents” every day. At the Holston Army Ammunition Plant in Tennessee, open burn is regularly conducted on a powerful explosive called RDX. The Redstone Arsenal in Alabama, “hazardous energetic waste” is regularly burned.
In those communities, many residents are concerned about the pollution those burns are potentially leaving behind. Devawn Oberlender, director of the Environmental Patriots of the New River Valley, is arguably the biggest opponent of the open burning at Radford, which is one of the largest polluters in Virginia.
“There’s an elementary school a mile downwind of our open burning ground,” she said, “and the kids there are exposed to more toxic exposure than other schools.”
She’s not wrong. In 2008, a USA Today investigation found that Belleview Elementary School, which neighbors the Radford Arsenal, has some of the worst air quality in the country. Much of that pollution is in the form of chromium, which can be toxic.
It’s hard to say whether or not the pollution comes from the Radford Arsenal. The Army has insisted that only trace amounts of chromium are present in the energetic material burned and that their emissions to do not violate the limits set for them by the Virginia Department of Environmental Quality. Oberlender said there is no ambient air quality monitoring downwind of Radford. Justine Barati, the director of public and congressional affairs for the Army’s Joint Munitions Command, said air quality controls were in place.
“In accordance with our permits, we use a variety of air emission monitoring technologies and techniques including compliance sampling, production controls, and real-time continuous emissions monitors,” she said. “All data is shared with regulatory agencies.”
‘Only … Where There Are No Alternatives’
According to EPA documents, the agency’s “long‐standing position” under RCRA and the Clean Air Act is that open burning of munitions is appropriate “only in situations where there are no alternatives … [It] is not necessarily cheaper and more expedient than other options, and will result in an environmental mess that someone will need to clean up.”
There are alternatives to an open burn — many of which are now being considered at Camp Minden. “Probably the most attractive” in terms of minimizing the environment impact is something called transportable rotary kiln incineration, according to EPA documents. That’s essentially a large, transportable closed kiln that gets brought in to a facility for waste disposal.
The Army has put aside nearly $20 million to be used for disposal of the M6 in Minden, and right now a decision is scheduled to be made by March 18. But as the clock ticks, Siegel noted the situation just gets more and more tricky.
“It is a risk management argument over what’s most dangerous,” he said. “Both sides have a case. When EPA says they’re worried about public safety and they want to burn the stuff, they might be right. I happen to support the other side of the argument.”
Whatever is chosen, Minden mother Melissa Downer said she hopes it can be done without the pile of explosives going up in smoke.
“They’re going to make Minden a ghost town if they burn it,” she said. “I can’t just sit here and let them do it … I don’t really know what to do except shout it from the rooftops.”