Cynthia Giles, Assistant Administrator
Office of Enforcement and Compliance Assurance U.S. Environmental Protection Agency
William Jefferson Clinton Building
1200 Pennsylvania Avenue, N. W.
Mail Code: 2201A
Washington, DC 20460 Giles-Aa.cynthia@Epa.gov
SENT BY ELECTRONIC MAIL
RE: Proposed Open Burning of M6 Propellants at Camp Minden, Louisiana
Dear Assistant Administrator Giles,
We, the undersigned organizations, join Louisiana residents, workers and families in their call for a safer alternative to open burning of hazardous wastes at Camp Minden.
We oppose the plan by the U.S. Environmental Protection Agency to OPEN BURN 15 million pounds of abandoned M6 propellants at Camp Minden, Louisiana. By definition, open burning has no emissions controls and will result in the uncontrolled release of toxic emissions and respirable particulates to the environment. M6 contains approximately 10 percent dinitrotoluene (DNT) which is classified as a probable human carcinogen.1
Concerns for the potential human health risk created by open burning/open detonation as well as for environmental impacts on the air, soil, and water have required the military to identify and develop alternatives to open burning/open detonation treatment.2 Moreover, as the EPA’s plan provides for the safe handling and transport to an open burning area, these wastes could be similarly moved to an alternative treatment facility or system.
While we support the EPA’s initiative to require the U.S. Army to clean up and dispose of these improperly stored explosive wastes, we do not support open burning as a remedy given the inherent and avoidable risks to human health and the environment.
1U.S. Environmental Protection Agency, Technical Fact Sheet, Dinitrotoluene (DNT), January 2014.
2 US Army Corps of Engineers Construction Engineering Research Laboratories USACERL Technical Report 98/104, Alternatives to Open Burning/Open Detonation of Energetic Materials, A Summary of Current Technologies, August 1998.
Laura Olah, Citizens for Safe Water Around Badger, Wisconsin Dolores Blalock, ArkLaTex Clean Air Network, LLC, Louisiana
Marylee M. Orr, Executive Director, Louisiana Environmental Action Network/Lower Mississippi Riverkeeper, Louisiana
Devawn Palmer-Oberlender, Environmental Patriots of the New River Valley, Virginia Pamela Miller, Executive Director, Alaska Community Action on Toxics, Alaska
Craig Williams, Chemical Weapons Working Group, Kentucky
Erin Brockovich & Bob Bowcock, California
United Tribe of Shawnee Indians, Principal Chief, Jim Oyler, Kansas
Tim Lopez, Director, Voluntary Cleanup Advisory Board, Colorado
Greg Wingard, Executive Director, Waste Action Project, Washington
Mable Mallard, Philadelphia Community Right To Know Committee, Pennsylvania Doris Bradshaw, Defense Depot Memphis Tennessee - Concerned Citizens Committee Isis Bradshaw, Youth Terminating Pollution, Tennessee
Kaye Kiker, Community Organizer, Citizens Task Force, Alabama
Wilbur Slockish, Columbia River Education and Economic Development, Oregon
Al Gedicks, Executive Secretary, Wisconsin Resources Protection Council, Wisconsin
Doris Bradshaw, Military Toxics Project, Tennessee
Peter Galvin, Center for Biological Diversity, California
LeVonne Stone, Fort Ord Environmental Justice Network, California
Marylia Kelley, Executive Director, Tri-Valley CAREs (Communities Against a Radioactive Environment), California
Josh Fast, Educator, PermanentGardens.com, Louisiana
Ronnie Cummins, Organic Consumers Association, Minnesota
Paul Orr, Lower Mississippi Riverkeeper, Louisiana
Marcia Halligan, Kickapoo Peace Circle, Wisconsin
Kathy Sanchez, EJ RJ, Tewa women United org., New Mexico
J. Gilbert Sanchez, CEO, Tribal Environmental Watch Alliance, New Mexico
David Keith, Valley Citizens for a Safe Environment, Massachusetts
Forest Jahnke, Crawford Stewardship Project, Wisconsin
Maria Powell, President, Midwest Environmental Justice Organization, Wisconsin
Evelyn Yates, Pine Bluff for Safe Disposal, Arkansas
Cheryl Slavant, Ouachita Riverkeeper, Louisiana
Jean E. Mannhaupt, President, Park Ridge @ Country Manors Home Owners Assoc., New York
Stephen Brittle, President, Don’t Waste Arizona
Alison Jones Chaim, Executive Director, Physicians for Social Responsibility Wisconsin
Jill Johnston, Southwest Workers Union, Texas
Robert Alvarado, Committee for Environmental Justice Action, Texas
Phyllis Hasbrouck, Chair, West Waubesa Preservation Coalition, Wisconsin
John LaForge, Nukewatch, Wisconsin
Guy Wolf, Co-Director, DownRiver Alliance, Wisconsin
Don Timmerman & Roberta Thurstin, Casa Maria Catholic Worker, Wisconsin
LT General Russel Honore (Ret), GreenARMY, Louisiana
John LaForge, The Progressive Foundation, Wisconsin
Paul F. Walker, Ph.D., Director, Environmental Security and Sustainability, Green Cross International, Washington, DC
Cynthia Sarthou, Executive Director, Gulf Restoration Network, Louisiana
Lenny Siegel, Executive Director, Center for Public Environmental Oversight, California
John E. Peck, Executive Director, Family Farm Defenders, Wisconsin
Lois Marie Gibbs, Executive Director, Center for Health, Environment and Justice, Virginia
Willie Fontenot, Conservation Chair, Delta Chapter of the Sierra Club, Louisiana
Kimberlee Wright, Executive Director, Midwest Environmental Advocates, Inc., Wisconsin
Elizabeth O'Nan, Director, Protect All Children's Environment, North Carolina
Frances Kelley, Louisiana Progress Action, Louisiana
Patrick Seymour, ISIS institute MilWaste Project, Massachusetts
Christina Walsh, Executive Director, cleanuprocketdyne.org, California
Glen Hooks, Chapter Director, Arkansas Sierra Club, Arkansas
Laura Ward, President, Wanda Washington, Vice President, FOCUS, Inc (Family Oriented Community United Strong, Inc.), Florida
Ed Dlugosz, President, NJ Friends of Clearwater, New Jersey
Anne Rolfes, Founding Director, LA Bucket Brigade, Louisiana
Monica Wilson, GAIA: Global Alliance for Incinerator Alternatives, California
Dean A. Wilson, Atchafalaya Basinkeeper, Louisiana
Robin Schneider, Texas Campaign for the Environment, Texas
Lara Norkus-Crampton, Coordinator, Minneapolis Neighbors for Clean Air, Minnesota Haywood Martin, Chair, Sierra Club Delta Chapter, Louisiana
Mitzi Shpak, Executive Director, Action Now, California
Jane Williams, Executive Director, California Communities Against Toxics, California Robina Suwol, Executive Director, California Safe Schools, California
Renee Nelson, President, Clean Water and Air Matter (CWAM), California
Lisa Riggiola, Citizens For A Clean Pompton Lakes, New Jersey
Stephanie Stuckey Benfield, Executive Director, GreenLaw
James Little, member, Western Broome Environmental Stakeholder Coalition, New York Sparky Rodrigues, Malama Makua, Hawaii
Barry Kissin, Fort Detrick Restoration Advisory Board, Maryland