Defense Environment Alert

an exclusive biweekly report on defense policies for cleanup, compliance and pollution prevention

Vol. 16, No. 11

May 27, 2008

EPA, STATE PROBE PCB RISKS FROM HEAT TREATMENT AT ARMY AMMUNITION SITE

Wisconsin regulators and EPA are looking into possible releases of toxic polychlorinated biphenyls (PCBs) that could result from a heat treatment being used by the Army at a former Wisconsin ammunition plant to prepare metal parts coated with explosives residues for recycling. The probe could have implications for other Army ammunition plants that similarly heat-treat scrap metal, sources say.

The inquiry responds to concerns raised by activists living near the Badger Army Ammunition Depot, WI, about the Army's resumption of the procedure following a four-year moratorium.

The procedure, first introduced by the Army at Badger several years ago, involves thermal treatment of painted metal parts in a special oven to remove any remaining explosives residues, but may release PCBs from the paint into the air, activists fear.

An Army source says that the procedure is commonplace on active Army ammunition plants, where scrap metal must be cleansed of any explosives under military regulations prior to recycling. "We test for PCBs before we treat scrap metal," the source says in a written response to questions. "The level of PCB contamination determines how we handle it, in accordance with environmental standards," says the source, citing EPA standards for handling PCBs.

The latest controversy over PCBs follows earlier clashes between EPA and the Army over open-burning of buildings containing PCBs, a procedure EPA has refused to allow despite Army pressure to do so at former ammunition plants including Badger (Defense Environment Alert, Sept. 5, 2006, p11).

Under pressure from activists, the Badger site has now suspended the heat treatment of painted metal parts afterre-starting the procedure last year, a spokesman for the site confirms.

An EPA source says, "It is uncertain what actually happens" when PCB-containing paint is placed in the thermal oven, which uses a relatively low heat of around 450 degrees Fahrenheit rather than the much higher temperatures used to actually burn materials in certain other procedures. "We don't know at this point if PCBs would be released," the source says.

EPA has requested additional data from cleanup managers at Badger on the materials being treated in the oven and the precise conditions of its operation. The EPA source confirms that federal regulations on PCB releases under the Toxic Substances Control Act (TSCA) apply to the procedure in question.

Under TSCA, items with PCB levels of more than 50 parts per million (50ppm) cannot be treated in the oven, but the activist group Citizens for Clean Water Around Badger (C SWAB) says that some items at Badger are painted with coatings containing up to 22,000 ppm. The group claims that this information is contained in data that the company Plexus Scientific supplied to the Wisconsin Department of Natural Resources (WDNR), following the company's sampling at the site on behalf of the Army.

CSWAB therefore asked the base to stop processing the metal parts in question, and the Army has now complied, four years after a similar freeze was self-imposed by the Army after C SWAB intervened the first time theprocessing technique was employed.

"We stopped while we review the situation. We are asking for additional assistance" from various Army entities, including legal advisors and the Army Environmental Command, according to the Army contractor who manages the Badger facility. The source adds that "my goal is to do as much recycling here as possible," rather than just putting metal parts into a landfill. Recyclers pay the Army for scrap supplied from the site.

In a 2003 letter to the Army, WDNR says that Aroclor 1254, a common PCB used in paints, oils, waxes and tires, is probably released during the thermal treatment. "Aroclor 1254 has a relatively low vapor pressure, but under heating to 450 degrees F it is likely that the Aroclor 1254 did volatilize out of the paint," when the oven was running, the letter says. The letter, however, downplays the environmental impact that likely resulted from the processing done up until 2003 at Badger, given that the great majority of items treated in the oven did not contain PCBs. CSWAB s letter to the Army is available on InsideEPA.com. See page 2 for details.