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The Ohio EPA and U.S. Army at Ravenna Army Ammunition Plant are seeking public comment on whether or not to clean up contaminated soils at an area known as the Winklepeck Burning Grounds. Obviously the proposed cleanup of the 200-acre site is necessary; the Army’s own studies verify that contaminant levels constitute a significant risk to human health. The real question is – is this enough?
You should know that proposed cleanup goals (the highest allowable contaminant concentration that can be left after soils are excavated) at Ravenna will not afford adequate protection of human health and the environment when compared to facilities elsewhere. This is due in part to the fact that Ravenna limits its evaluation of risk to soldiers to direct dermal contact with soils and fails to address other equally plausible routes of exposure such as inhalation of fugitive dust and emissions, incidental ingestion, and exposure through the human food chain (consumption of food crops, wild game, dairy products, fish, etc.).
The principal contaminants of concern at the Winklepeck Burning Grounds are Polycyclic Aromatic Hydrocarbons (PAHs) and the explosive RDX. PAHs are a group of more than 100 chemicals; some are suspected carcinogens. RDX is a suspected human carcinogen if inhaled or ingested, and is a relatively common contaminant at military facilities.
For example, after World War II, the military turned over a 34,000-acres parcel in Illinois to the DOI for use as a National Wildlife Refuge. The cleanup goals for soils at the Crab Orchard Refuge were based on protecting refuge employees, site workers, hunters/hikers, and site trespassers. Like the soldiers at Ravenna, they are not present at the facility on a full-time basis. The recommended soil cleanup goal for RDX at the Crab Orchard Refuge is 6 mg/kg. The proposed goal at Ravenna, however, is more than 100 times higher or 617 mg/kg.
In addition to RDX, levels of PAHs in soils at Ravenna are also elevated. One of the more prominent is benzo(a)pyrene, classified by the EPA as a known animal carcinogen and a suspected human carcinogen.
In 1994, a soil removal was conducted at Cape Canaveral Air Force Station in Florida to “eliminate potential unacceptable human health risk to current and future site workers and to reduce potential risk to hypothetical future residents”. The EPA-recommended remedial goal for benzo(a)pyrene was 0.1 mg/kg. By comparison, the proposed cleanup goal at Ravenna is 75 times higher or 7. 5 mg/kg. The same holds true at other military facilities. At the Joliet Arsenal in Illinois, a cleanup goal of 0.1 mg/kg was recommended for benzo(a)pyrene based on cancer risk. According to the Army, the most likely human receptors at Joliet (now the Midewin National Tallgrass Prairie) include “recreational park users, industrial workers, and USDA prairie workers and volunteers”. At the Badger Army Ammunition Plant, my neighbor here in Wisconsin, the U.S. EPA has approved a health-based goal for benzo(a)pyrene in both surface and subsurface soils of 0.4 mg/kg (compared to 7.5 mg/kg at Ravenna). The 7,400-acre base is closing and will be soon transferred to new owners for agriculture, conservation, and recreation.
Clearly, not only are the citizens of Ohio getting the short end of the stick, so are its soldiers. According to Ravenna’s proposal, the “Range Maintenance Soldier” is the population at highest risk from exposure to unsafe levels of site toxins.
You can do your part to get a stronger and equitable cleanup by participating in the current public comment period. Written comments must be postmarked by January 8, 2006 and are to be submitted to the Ravenna Army Ammunition Plant Facility Manager, Building 1037, 8451 State Route 5, Ravenna, OH 44266.
In order to make sure your comments receive the attention they deserve, copies should be sent to your federal representatives and the U.S. EPA. A public meeting is also scheduled for Tuesday December 20 at the Newton Falls Community Center beginning at 5 pm.
Laura Olah, Executive Director
Citizens for Safe Water Around Badger
The principal contaminants of concern at the Winklepeck Burning Grounds are Polycyclic Aromatic Hydrocarbons (PAHs) and the explosive RDX. PAHs are a group of more than 100 chemicals; some are suspected carcinogens. RDX is a suspected human carcinogen if inhaled or ingested, and is a relatively common contaminant at military facilities.
For example, after World War II, the military turned over a 34,000-acres parcel in Illinois to the DOI for use as a National Wildlife Refuge. The cleanup goals for soils at the Crab Orchard Refuge were based on protecting refuge employees, site workers, hunters/hikers, and site trespassers. Like the soldiers at Ravenna, they are not present at the facility on a full-time basis. The recommended soil cleanup goal for RDX at the Crab Orchard Refuge is 6 mg/kg. The proposed goal at Ravenna, however, is more than 100 times higher or 617 mg/kg.
In addition to RDX, levels of PAHs in soils at Ravenna are also elevated. One of the more prominent is benzo(a)pyrene, classified by the EPA as a known animal carcinogen and a suspected human carcinogen.
In 1994, a soil removal was conducted at Cape Canaveral Air Force Station in Florida to “eliminate potential unacceptable human health risk to current and future site workers and to reduce potential risk to hypothetical future residents”. The EPA-recommended remedial goal for benzo(a)pyrene was 0.1 mg/kg. By comparison, the proposed cleanup goal at Ravenna is 75 times higher or 7. 5 mg/kg. The same holds true at other military facilities. At the Joliet Arsenal in Illinois, a cleanup goal of 0.1 mg/kg was recommended for benzo(a)pyrene based on cancer risk. According to the Army, the most likely human receptors at Joliet (now the Midewin National Tallgrass Prairie) include “recreational park users, industrial workers, and USDA prairie workers and volunteers”. At the Badger Army Ammunition Plant, my neighbor here in Wisconsin, the U.S. EPA has approved a health-based goal for benzo(a)pyrene in both surface and subsurface soils of 0.4 mg/kg (compared to 7.5 mg/kg at Ravenna). The 7,400-acre base is closing and will be soon transferred to new owners for agriculture, conservation, and recreation.
Clearly, not only are the citizens of Ohio getting the short end of the stick, so are its soldiers. According to Ravenna’s proposal, the “Range Maintenance Soldier” is the population at highest risk from exposure to unsafe levels of site toxins.
You can do your part to get a stronger and equitable cleanup by participating in the current public comment period. Written comments must be postmarked by January 8, 2006 and are to be submitted to the Ravenna Army Ammunition Plant Facility Manager, Building 1037, 8451 State Route 5, Ravenna, OH 44266.
In order to make sure your comments receive the attention they deserve, copies should be sent to your federal representatives and the U.S. EPA. A public meeting is also scheduled for Tuesday December 20 at the Newton Falls Community Center beginning at 5 pm.
Laura Olah, Executive Director
Citizens for Safe Water Around Badger