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RAAP Frequently Asked Questions

DEQ responds to questions directly related to regulated activities and permit actions related to environmental laws under its authority.

Learn more about the Radford Army Ammunition Plant.

What is the current regulatory action being considered at RAAP?

As of September 2019, DEQ is considering issuing a permit for the construction and operation of certain hazardous waste storage and treatment equipment. The Class 3 Modification to the Subpart O Permit for RAAP is required to be issued before the RAAP facility can construct and operate the new units.

The permit outlines operating conditions for the following:

  •  The Grinder Building (identified as Building 613), where wastes will be transported before treatment, ground into small pieces prior to being mixed with water into a slurry and then incinerated in the rotary kiln incinerators. The structure houses the permitted hazardous waste storage tanks, including the makeup, decant and three kiln storage tanks, as well as the grinder tanks. The others (the firewater collection tanks) are not hazardous waste storage or treatment tanks. It also includes a separation system that can be used to prepare the wastes for offsite shipment if necessary.
  •  Rotary Kiln Incinerators 616 and 617, where the slurried wastes will be thermally treated in accordance with permit requirements “maximum achievable” control technology. 
  • The Contained Burn Chamber (CBC) where hazardous wastes that cannot be slurried will be thermally treated using “maximum achievable” control technology.
  •  The CBC and Car Bottom Storage/Loading Building (referred to as the Loading Building and identified as Building 614), where hazardous wastes will be brought prior to treatment and configured into batches for treatment in the CBC. It is also the location where metal items targeted for decontamination will be loaded onto carts for the Car Bottom Oven.

Can the public make comments proposed waste permit?

The public can submit comments on the proposal during a 61-day comment period that ends Nov. 12, 2019.

A public information meeting will be held at the Radford Public Library (30 West Main Street, Radford, VA 24141) on Wednesday, Oct. 9, 2019, from 7-8 p.m. and a public hearing will be held on Oct. 23, 2019, at 7 p.m. at the Radford Public Library.

All persons who believe the tentative decision to grant this permit is inappropriate must raise all ascertainable issues and submit all available arguments and factual grounds supporting their position by Nov. 12, 2019. DEQ will also accept comments from the public by e-mail. All comments received must include the full name, mailing address and phone number of the person generating the comments.

Comments are addressed after the close of the 61-day comment period and each person that has submitted comments will receive a written response from DEQ. When making the final determination to issue the permit, DEQ will consider all written comments received during the comment period, any oral or written statements received during the public hearing and the requirements of VAC 20-60-264 and 270 of the VA Hazardous Waste Management Regulations. The Director will grant or deny the draft permit according to the permitting procedures of 9 VAC20-60-124.

What kinds of comments can be made by the public?

Comments directly related to the action(s) being proposed must be considered by DEQ. Specific comments are more useful, but all comments related to the proposed regulatory action are considered.

What are the most recent permit actions related to the RAAP?

Both the Subpart O permit, for the incinerator complex (known as Explosive Waste Incinerators or EWI), and Subpart X permit, for the open burning ground (OBG), are currently being renewed. Human health and ecological risk assessments for both renewal permits are currently being developed and the results of those reports will be used to identify any additional permit limits determined to be protective of human health and the environment.

On May 3, 2018 a Class 1 modification to the current Subpart O permit for the incinerator was submitted to incorporate language detailing the process of sawing motor grains and stick propellants to allow for treatment in the EWI and diverting the wastes from being treated at the OBG. The modification was approved on August 24, 2018.

On May 10, 2019 a Class 1 modification request to the current Subpart X permit for the OBG was submitted to incorporate language into the waste analysis plan to clarify how the RAAP facility determines a waste to be reactive as well as several modifications to update the referenced laboratory procedures associated with waste analysis. The modification was approved on May 23, 2019.

On March 22, 2013, RAAP proposed to add one groundwater monitoring well down gradient to the OBG and discontinue sampling of one well located up gradient to the OBG. The proposed modifications relating to the groundwater monitoring have been approved. For more information, see June 18, 2013, letter from DEQ.

What is the open burning ground?

The open burning ground (OBG) is an area at the plant  where waste propellant is incinerated.  This type of waste, which is considered hazardous, contains contaminants, e.g., 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, ground water 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 at the open burning ground.  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 in each wastes. 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. (See diagram

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.

What are the regulations that govern the treatment of waste propellant at the RAAP open burning ground?

The Radford Army Ammunition Plant (RAAP) Hazardous Waste Management Unit (HWMU) 13 or open burning ground is regulated under (40 CFR 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.

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 waste propellants that are burned/ignited nearby?

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 (VPDES) 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 EPA-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.

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Virginia Department of
Environmental Quality
P.O. Box 1105
Richmond, VA 23218
(804) 698-4000

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