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Executive Summary

Report Body

Military Munitions
Impacts on Communities and the Environment
Types of Sites Contaminated with Munitions
Sources of Contamination
Common Contaminants and Health Dangers
Unexploded Ordnance (UXO)
Open Burning/Open Detonation (OB/OD)
Impacts on Cultural and Historic Sites
Contamination of Food Supplies and Drinking Water
Impacts on Endangered Species and the Environment
Regulation of Military Munitions and Ranges
Conclusion

Case Studies

Badger Army Ammunition Plant
Fort Richardson, Eagle River Flats Impact Area
Jefferson Proving Ground
Panama
Makua Valley, Hawai’i
Massachusetts Military Reservation
Okinawa
San Diego, California
Sierra Army Depot
Vieques, Puerto Rico

Appendices

A - Abbreviations and Acronyms
B - Glossary
C - Superfund Sites with UXO Contamination
D - Sites with Interim Permits for OB/OD
E - Types of Unexploded Ordnance

Military munitions pose environmental and human health dangers at each step of their life cycle. Production sites (such as materials processing facilities and ammunition plants), testing sites (such as labs and proving grounds), firing sites (training ranges and areas of conflict), and disposal sites (including burial pits and open burning/open detonation sites) may all contaminate the environment and threaten public health. Dangers at all types of sites exist from both unexploded ordnance (UXO), which poses an immediate safety danger, and toxic munitions chemicals, which pose acute and long-term dangers to human health and the environment.

Up to 25 million acres of land and water at several thousand sites in the U.S. are already contaminated with unexploded ordnance (UXO), toxic explosive compounds and their byproducts, toxic propellants, and heavy metals. More sites are being identified every year. The Department of Defense (DoD) estimates that about 16 million acres of land already transferred to other agencies or the public are potentially contaminated with UXO and munitions constituents. The Army alone has as many as 2,000 sites contaminated with explosives. Federal facilities contain at least thirty large and medium-sized sites containing over one million yards of soil contaminated with the explosive TNT. A 1998 Environmental Protection Agency (EPA) survey of just 266 closed, transferred, and transferring (CTT) and inactive military ranges found that UXO was found on 85% of the ranges. Over 50% of the ranges were known or suspected to contain chemical or biological weapons.

Hundreds of billions of dollars will be required to clean up existing contamination on military training ranges, to say nothing of ongoing pollution from munitions production and use. DoD has estimated its liability for cleanup of UXO at over $100 billion, and the cost to cleanup only closed, transferred, and transferring training ranges at $40-$140 billion. A Navy researcher has estimated that clearing UXO at the Navy’s ranges would cost $36 billion, and treating chemical contamination in the soil would cost $33 billion.

Sources of toxic contamination from munitions and their constituents at military testing and training ranges may be divided into several categories. Small arms ammunition contaminated thousands of ranges across the country with lead. UXO poses an immediate safety danger and also corrodes, leaching hazardous munitions constituents into soil and groundwater. Heavy metals and toxic explosive compounds enter the environment when munitions don’t detonate completely and when UXO corrode. Propellants contaminate firing positions, impact areas, and neighborhoods downwind. Pyrotechnics release white phosphorus and various other toxins. Unused munitions buried by troops during training or for disposal decay and release their constituents. The open burning/open detonation (OB/OD) of munitions in the open air releases tens of thousands of pounds of metals, explosives, propellants, and other toxins into the air, which travel for miles.

There is abundant and growing evidence of the damage to human health and the environment caused by military munitions and ranges.

• At the Massachusetts Military Reservation on Cape Cod, toxic munitions constituents contaminated the only drinking water supply for 500,000 neighbors of the base, forcing the shutdown of municipal wells. Burning of excess artillery propellant at firing positions was linked to increased lung cancer in people living nearby. Throughout the 1980s, women on the Upper Cape near the base were 64% more likely to be diagnosed with lung cancer than women in the rest of the state.

• Since 1940, the U.S. Navy has used three-quarters of the island of Vieques, Puerto Rico for bombardment, munitions disposal, and other activities. There is strong evidence that heavy metals and other munitions toxins move in the air from the bombing range to the civilian areas. The toxic explosive compound RDX was found in drinking water supplies in civilian areas in the late 1970s. In 2000, excessive levels of mercury were found in the hair and fingernails of 45% of Vieques residents tested. Vegetables and plants growing in civilian areas are highly contaminated with lead, cadmium, and other heavy metals. From 1985-1989, Vieques children aged 0-9 were 117% more likely to contract cancer than children of the same age on the main island of Puerto Rico. Children aged 10-19 were 256% more likely to contract cancer. A 2001 study found that Vieques residents are 73% more likely to suffer from heart disease than residents of the main island, 64% more likely to develop hypertension, 58% more likely to have diabetes, and 18% more likely to be diagnosed with asthma.

• White phosphorus and other toxic munitions constituents contaminated the fragile estuarine salt marsh of Eagle River Flats at Fort Richardson, Alaska. Subsistence fishing grounds have been rendered unusable by the Native Alaskans who have historically used these resources. Munitions contamination killed thousands of waterfowl every year for almost two decades before the Army released even a draft cleanup plan. UXO may exist in, on, and/or under up to 2 million acres of lands and waters outside the current boundaries of the base.

The regulation (or often the lack thereof) of military munitions and ranges is a complex matter involving federal, state, Tribal, and local laws as well as various governmental and nongovernmental actors. A plethora of agencies and authorities are involved in some aspect of regulation of military munitions and ranges, including: the EPA (both headquarters and the regions); DoD (including the Secretary of Defense, the Defense Environmental Restoration Program, the Department of Defense Explosives Safety Board, and the armed services); other federal agencies; tribes; states; and the public (through various public participation programs, citizen suits, and political action). A variety of laws, regulations, and both formal and informal agreements may be invoked depending on the circumstances.

Regulation of military munitions and ranges occurs primarily under two statutes: the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA, known as the Superfund law); and the Resource Conservation and Recovery Act (RCRA). CERCLA provides for cleanup of contaminated sites and accidents, spills, or other releases of hazardous substances to the environment. RCRA governs solid waste, including hazardous waste, from cradle to grave. Either or both of these laws may be applied to munitions contamination depending on the circumstances. The Safe Drinking Water Act, the Clean Air Act, and the Clean Water Act have also been applied by states and EPA to protect public health and the environment from munitions contamination.

The DoD has historically fought attempts to regulate military munitions and firing ranges, and usually attempts to force any response to munitions contamination to occur under CERCLA, where DoD is the lead agency. DoD oversees CERCLA response actions at its own sites and EPA cannot impose a more protective cleanup process than the DoD chooses. At all CERCLA sites not listed on the National Priority List, EPA cannot act to protect public health and the environment from munitions contamination even in the face of an imminent and substantial endangerment.

In 1992, Congress passed the Federal Facilities Compliance Act, which for the first time subjected federal agencies to RCRA’s cradle-to-grave regulation of hazardous wastes. Because RCRA was originally written to govern private sector wastes, Congress directed EPA to write a regulation balancing the need for oversight of military munitions with the DoD’s need to train and fight. Instead of balancing these interests, EPA undermined the intent of Congress by completely exempting munitions at active firing ranges from RCRA unless DoD specifically collects them for disposal. EPA’s surrender to DoD ensured that millions of pieces of UXO will remain on military ranges leaching their toxic contaminants into the environment. RCRA does allow EPA to issue binding orders to protect public health and the environment from imminent and substantial endangerment by munitions contamination. DoD is seeking a Congressional exemption to remove this authority. Communities near active ranges continue to demand protection from munitions contamination.

Human health, the environment, cultural and historic sites, and subsistence food supplies have already been harmed by munitions contamination. More people are exposed to UXO and chemical contamination from munitions every day because of failures of policy and will by DOD, EPA headquarters, and other federal regulatory agencies. Many states and some EPA regions have taken the lead in addressing the problem, but often without adequate support from Washington. Action is desperately needed to protect communities, ensure cleanups protective of human health and the environment, and prevent additional contamination.

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Military munitions are "all ammunition products and components produced or used by or for DoD or the U.S. Armed Services for national defense and security, including military munitions under the control of the Department of Defense, the U.S. Coast Guard, the U.S. Department of Energy, and National Guard personnel." The term includes a variety of devices used to deliver an explosive, chemical, or pyrotechnic charge to a target. Military munitions include propellants, explosives, pyrotechnics, chemical agents, incendiaries, rockets, missiles, bombs, mortar rounds, artillery shells, small arms ammunition, mines, grenades, cluster munitions, and components of these items. The term does not include nuclear weapons and materials.

Military munitions may be fired or launched (projectiles such as artillery shells and small arms ammunition, mortars, rifle grenades, rockets, and missiles), dropped (bombs, dispensers, and submunitions), placed (mines), or thrown (hand grenades).

This report focuses on conventional munitions (those that are not biological, chemical, or nuclear). However, brief sections on chemical and depleted uranium munitions are included below.

Weapons and ammunition have been used for at least two thousand years, but the munitions of today are a far cry from the stones, spears, and other munitions used in past centuries. The weapons of today contain a wide variety of chemical compounds and heavy metals that are hazardous to human health and the environment.

The term conventional munition is used to denote a piece of ordnance which is not nuclear, chemical, or biological. The bulk of a conventional munition is the explosive train, which is composed of a sensitive but not very powerful initiating compound or mixture, which detonates a booster compound, which detonates a less sensitive but more powerful explosive compound such as RDX or TNT (see below). The three parts of the explosive train are generally called the fuze, the booster, and the main charge.

The fuze (as distinguished from "fuse") contains the primer/detonator and is the most critical part of a munition. It must be able to arm and detonate at – and only at – the appropriate time. Fuzes may be designed to initiate the detonation on impact, at a specific time, or in proximity to a target. There are twenty-nine families of fuzes, which are generally classified as either mechanical or electrical. Booster charges, generally consisting of a small amount of moderately sensitive explosive, amplify the force generated by the fuze to ensure complete (or high-order) detonation of the main charge.

The main charge of a munition produces most of the explosive force and requires a large initiating shock to detonate. These explosives are designed to achieve specific effects based on the intended purpose of the mention. Main charges are more stable secondary explosives (see below) such as TNT, RDX, C4, and others.

Primary or initiating explosives – those used to initiate the explosive train and detonate a booster charge or main charge – include lead adzide, lead styphnate, and mercury fulminate.

Secondary explosives – more powerful compounds formed to detonate under specific circumstances and therefore used as boosting explosives or main charges – include TNT (trinitrotoluene); RDX (1,3,5-hexahydro-1,3,5-trinitrotriazine, also known as cyclonite, hexogen, royal demolition explosive, or research development explosive); HMX (octahydro-1,3,5,7-tetranitro-1,3,5,7-tetrazocine, also known as octogen or high melting explosive); and tetryl (2,4,6-trinitro-phenylmethylnitramine). According the the Army Corps of Engineers, "TNT and RDX constitute the largest quantity of secondary explosives used in military applications, because they are major ingredients in nearly every munition formulation." These explosive compounds also contain various other substances (such as powdered metals, plasticizing oils, and waxes) used as stabilizers and fillers, and may contain production impurities including various isomers of dinitrotoluene and dinitrobenzene.

The main body of a munition is called the casing, which contains the main explosive charge. Casings are designed to achieve a specific purpose – such as fragmenting to injure or kill personnel, or piercing armor – based on the intended use of the munition.

Propellants are used for propulsion: to move the munition forward. As noted later in this report, propellants are classified as either single-based, double-based, or triple-based (or composite) based on their constituents. All the components of small arms ammunition are usually held together by a cartridge case, while in larger types of ammunition the propellant is packed in separate combustible bags.

Although the terms "inert", "dummy", and "practice" or "training" munition (and more recently "green" ammunition) are often used interchangeably, the munitions themselves and their environmental and human health impacts are distinctly different. These munitions may and often do contain explosive, toxic, or hazardous components.

According to a Department of Defense policy on munitions, "wholly inert" ammunition would mean a munition that has never been employed and has never contained reactive materials. Once an item is employed as a component of a military munition, it is no longer considered "wholly inert."

Dummy munitions are reproductions produced from a variety of materials for many purposes, such as display, instruction, or special tests.

In practice or training munitions, the main charge is replaced by an inert filler. Fillers may be either non-toxic or toxic, and include concrete, wax, sand, plaster, antifreeze (to simulate chemical agents), water, and molasses. Practice munitions do usually contain some type of high-explosive spotting charge, as well as fuzes, primers, igniter charges, and propellants – all of which may contain hazardous or toxic components.

The DoD has recently developed so-called "green" ammunition. The new "green" small arms ammunition is based on tungsten rather than lead. Unfortunately, even this ammunition still requires toxic propellants to be fired. An official at U.S. EPA Region 1 concluded that a 2001 study "indicates that small arms firing over time deposits high levels of those propellants."

In July of 1917, the Bureau of Mines officially started research and development of chemical and biological weaponry at American University in Washington, D.C. Chemical weapons have been manufactured in the form of blistering agents such as mustard gases and lewisite, or nerve agents such as sarin and VX. These agents are disbursable through projectiles or mortar shells, bombs, rockets or missiles, submunitions or bomblets and spray tanks. The military lists twenty-five different types of chemical combinations as some of the agents produced for chemical weapons. Blistering agents cause respiratory tract problems, eye irritation and blistering of the skin. Nerve agents impair breathing, inhibit nerve conduction and can cause nausea and vomiting and ultimately death.

Chemical weapons and chemical weapons production facilities are scheduled for destruction under the treaty commonly known as the Chemical Weapons Convention, signed on January 13, 1993 and ratified by Congress on April 25, 1997.

Opposition to incineration of chemical weapons by national groups such as the Chemical Weapons Working group and local community groups has forced the military to explore alternative disposal methods. However, the Army’s preferred method of disposal still seems to be incineration because of the emphasis on cost effectiveness.

Stockpile chemical weapons are those stored at arsenals such as Pine Bluff Arsenal. Non-stockpile chemical weapons are any chemical munitions found at sites other than the stockpile sites during cleanup or that have resurfaced where they have been buried and forgotten. Officials at the Department of Defense maintain that records of chemical weapons disposal were not adequately or accurately kept. The military has identified 38 sites where non-stockpile chemical weapons have been discovered, but hundreds of sites are suspected to contain chemical munitions. Sites that have been labeled "no further action" by the military have later been found to contain chemical weapons and related contamination.

The most widely publicized site of chemical weapons contamination is Spring Valley, a neighborhood in Washington, D.C. Chemical weapons contamination was discovered in January 1993, some time after the Army Corps of Engineers had declared the area uncontaminated. Elevated levels of arsenic were found in soil samples in the neighborhood. Low levels of arsenic are known to cause decreased production of red and white blood cells. Two children in Spring Valley died from aplastic anemia, a disease so rare that only about 1,000 deaths per year have been attributed to the condition; yet in one year two were from the same community. Even though scientists have not conclusively linked arsenic and aplastic anemia, the deaths should be cause for precaution. Yet the Agency for Toxic Substances and Disease Registry’s (ATSDR) report on contamination in Spring Valley concluded there was no danger to community members.

To date, over $50 million has been spent to clean up the contaminants affecting this affluent community where ambassadors and other government officials live. Still, members of the Spring Valley Restoration Advisory Board are critical of some of the methods used for assessment and cleanup. They complain that military contractors took soil samples from sites where landscapers had already replaced contaminated soil. Even though millions of taxpayer dollars have already been spent on this site, community members feel it has not been enough and that the military continues to resist full disclosure and cleanup. This experience demonstrates two critical points. First, that all communities tend to be treated badly by the DoD, regardless of their racial and economic status. Second, that some communities – usually middle-class or wealthy areas with predominantly white populations – usually receive much better responses from DoD and regulatory agencies once problems are brought to light.

Public involvement is crucial for establishing the methods to be developed and used to destroy both stockpile and non-stockpile chemical weapons. The lack of adequate public involvement stems from the fact that the methods used to inform the public are often inadequate and untimely. The Chemical Weapons Working Group, a national oversight, non-governmental organization, provides up-to-date information on their website at www.cwwg.org.

The ultimate recycling horror story of our lifetime is depleted uranium (DU) munitions. Natural uranium is mined and enriched for use in nuclear weapons and nuclear reactor fuel. During the enrichment process, a small amount of the U-235 isotope is extracted. The radioactive waste from this process – composed of 99% U-238 – is called depleted uranium (DU). DU is low-level radioactive waste; it is about 60% as radioactive as natural uranium and has a half-life of 4.5 billion years. It has been accumulating for sixty years and the U.S. stockpile exceeds a billion pounds. The U.S. military began developing DU for use in armor piercing weaponry and tank armor in the 1960s.

DU is both toxic and radioactive. As a chemically toxic heavy metal, it can cause kidney and lung damage. As a radioactive substance, it emits alpha radiation, which irradiates powerfully for short distances. Alpha radiation cannot penetrate the skin, but can irradiate lung cells and other cells in the body if inhaled or ingested. U-238 decays into two principal isotopes. These emit beta radiation, which can travel through up to 1,000 cells, and gamma radiation, which can travel through about 200 cells.

The ingestion of minute quantities of uranium in food or drinking water can cause irreparable damage to the kidneys. When uranium weapons burn, corrode or are machined, uranium oxide dust is created. When inhaled, small particles (those less than 5 millionths of a meter, smaller than the eye can detect) can lodge in human lung tissue, exposing the host to a growing dose of alpha or beta radiation. This can cause lung cancer in people of all ages, and is particularly hazardous to children.

When depleted uranium is alloyed with titanium, it becomes extremely dense. It is also "pyrophoric," which means it burns upon impact. Uranium weapons were developed not only because they promised to be effective, but also because the metal itself is very cheap.

The U.S. military has tested DU rounds at various firing ranges around the country and used depleted uranium weaponry in the Gulf War, Bosnia, and Kosovo. The military contends that DU does not damage the environment or cause health problems, but their claims are based on incomplete data. No research by the U.S. military has been conducted in battlefield areas.

A study done by the United Nations Environmental Programme’s Depleted Uranium Assessment Team found airborne DU particles at two sites a full two years after the use of DU. The study also pointed out that the danger of contaminated groundwater is high and underlined the importance of monitoring water quality.

Uranium particles were found as far as 26 miles downwind of a production facility in Colonie, New York in 1980. NL Industries Uranium Weapons factory was forced to close. At another manufacturing plant in Concord, Massachusetts radioactive materials have contaminated surface water, ground water and land. Independent testing by a local grassroots organization found DU at 18 times the background level.

Over 200,000 servicemen and women in the Gulf War may have been exposed to toxic and radioactive DU dust by friendly fire, moving through areas contaminated by DU, entering destroyed Iraqi vehicles, and cleaning up battlefields. Military leadership failed to warn, equip, or train cleanup crews to prepare them for DU contamination, despite the existence of DoD training materials. Over 100,000 veterans have diagnosed and undiagnosed illnesses related to the Gulf War.

U.S. Representative Cynthia McKinney of Georgia has sponsored a bill to suspend the use and sale of depleted uranium munitions. The bill would also require studies of the contamination of DU and effects on military personnel and civilians near DU facilities. MTP applauds this type of bill and the efforts of like-minded members of Congress to continue working to protect the health of innocent people in all parts of the world as well as those who serve our country in uniform.

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Military munitions pose environmental and human health dangers at each step of their life cycle. Production sites (such as materials processing facilities and ammunition plants), testing sites (such as labs and proving grounds), firing sites (training ranges and areas of conflict), and disposal sites (including burial pits and open burning/open detonation sites) may all contaminate the environment and threaten public health. A recent study of techniques to analyze explosives contamination in the environment noted:

Close to 2,000 Formerly Used Defense Sites (FUDS) are known or suspected to contain unexploded ordnance (UXO). Dangers at all types of sites exist from both unexploded ordnance (UXO), which poses an immediate safety danger, and chemical contamination by munitions constituents, which can pose both acute and long-term dangers to human health.

Up to 25 million acres of land and water at several thousand sites in the U.S. are already contaminated with unexploded ordnance (UXO), toxic explosive compounds and their byproducts, toxic propellants, and heavy metals. More sites are being identified every year. DOD estimates that about 16 million acres of land already transferred to other agencies or the public are potentially contaminated with UXO and munitions constituents. The Army alone has as many as 2,000 sites contaminated with explosive constituents. Federal facilities contain at least thirty large and medium-sized sites containing over one million yards of soil contaminated with the explosive TNT. An EPA survey of just 266 closed, transferred, and transferring (CTT) and inactive military ranges found that UXO was found on 85% of the ranges. Over 50% of the ranges were known or suspected to contain chemical or biological weapons.

Hundreds of billions of dollars will be required to clean up existing contamination on military training ranges. DOD has estimated its liability for cleanup of UXO at over $100 billion, and the cost to cleanup only closed, transferred, and transferring training ranges at $40-$140 billion. A Navy researcher has estimated that clearing UXO at the Navy’s ranges would cost $36 billion, and treating chemical contamination in the soil would cost $33 billion.

Human health, the environment, cultural and historic sites, and subsistence food supplies have already been harmed by munitions contamination. More people are exposed to UXO and chemical contamination from munitions every day because of failures of policy and will by DOD, EPA headquarters, and other federal regulatory agencies. Many states and some EPA regions have taken the lead in addressing the problem, but often without adequate support from Washington. Action is desperately needed to protect communities, ensure cleanups protective of human health and the environment, and prevent additional contamination.

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A great variety of locations have been and continue to be contaminated by the production, testing, use, and disposal of conventional military munitions. Several types of sites contaminated with unexploded ordnance and munitions constituents are described below.

Munitions Production – Because DOD and its contractors operated a variety of munitions production facilities for decades before any environmental regulation existed, these facilities are often highly contaminated with munitions constituents and other substances. The persistence of munitions constituents in soil and groundwater for decades and their mobility over several miles is great cause for precaution at any site where munitions are made, fired, or destroyed.

At the Badger Army Ammunition Plant in Wisconsin, groundwater near the propellant burning ground was contaminated with carbon tetrachloride and trichloroethene, and residential wells were contaminated with carbon tetrachloride at 80 parts per billion (more than 15 times the safe level). Other groundwater contaminants at the facility include tetrachloroethene, 1,1,1-trichloroethane, chloroform, 2,4-DNT, 2.6-DNT,nitrates, cadmium, chromium, lead, sulfates, and benzene. In March, 2001, the munitions constituent dinitrotoluene was found in monitoring wells at the fenceline at 3-6 micrograms per liter ( ug/l), far above the Public Health Groundwater Quality Standard of 0.5 ug/l.

A variety of other ammunition plants exhibit even worse contamination. Groundwater just west of the city of Grand Island, Nebraska was contaminated with the explosive compound RDX at up to 100 parts per billion (ppb), well above the federal standard of 2 parts per billion for drinking water, by the Cornhusker Army Ammunition Plant, prompting officials to ban residential water wells in the area. In Middletown, Iowa, the Iowa Army Ammunition Plant contaminated groundwater 5-6 miles from the plant with RDX in concentrations 10 to 20 times safe levels. Ground water at the Louisiana Army Ammunition Plant is contaminated with RDX up to 27,000 ppb and TNT up to 25,000 ppb. In 1978 -1979, the Army found the aquifer under the Milan Army Ammunition Plant in Tennessee contaminated with RDX, HMN, 2,4,6-TNT, and 4-DNT. In January 1994, one of three city wells was closed because it was contaminated with RDX at over 4 ppb. The other two wells showed RDX in lower concentrations. There are other examples.

Munitions Testing – Military munitions are tested at various DoD and private labs as well as at military testing ranges, generally called proving grounds. Jefferson Proving Ground (JPG) in Indiana, an Army testing range, was founded in 1940-41 to test bombs, propellants, grenades, and high explosives. The facility – which includes about 55,000 acres – closed in 1995. While various chemical contaminants exist at JPG, the two primary dangers are unexploded ordnance (UXO) and depleted uranium. Over 25 million rounds were tested at JPG from 1941 to 1995. The 51,000-acre Northern Firing Range Area contains an estimated 1.5 million UXO. Cleanup of the firing range will cost from $2 billion to $8 billion and long-term monitoring will be required for at least 25 years. From 1984 to 1992, the Army tested about 220,500 pounds of depleted uranium shells at JPG. There is an estimated 150,000 pound of DU remaining on or in the ground in a 1,250 acre area. The Army proposed to walk away from this contamination, performing no remediation and no monitoring.

Aberdeen Proving Ground (APG) in Maryland, also an Army test range, covers 80,000 acres of land and water on Chesapeake Bay. APG is included on the National Priorities List as one of the most contaminated sites in the U.S. One million UXO litter firing ranges and an additional four million UXO sit in surface waters next to the facility, including Chesapeake Bay. In May 2002, the munitions constituent perchlorate was found in groundwater within 300 feet of the city of Aberdeen’s drinking water wells. A recent report concluded that "distinct groundwater plumes consisting of explosive chemicals are more rare [than sporadic detections], but they do exist. In general, they are present at shell washout facilities, munitions disposal areas, munitions cleaning facilities, and bombing fields."

Munitions Firing and Training – Over two million acres of land in the United States are designated as firing range impact areas. The Army and National Guard operate more than fifty firing ranges in thirty-three states. The Navy has more than 21 major ranges covering 2.4 million acres. The Air Force lists 14 munitions-contaminated ranges on over 3.6 million acres. Shells frequently land not only within but outside of range boundaries in public and private lands and waters.

The Massachusetts Military Reservation (MMR) is perhaps the best known example of munitions contamination at a training range. In 1997, EPA Region 1 halted firing at the base because it concluded that contamination of drinking water supplies by munitions constituents posed an immediate and substantial threat to public health. Over 66 billion gallons of the sole drinking water supply for 500,000 people and 70,000 homes and businesses is contaminated with the explosive RDX and other toxic compounds. Explosives contamination has been found in about half the 200 monitoring wells in the Camp Edwards section of MMR, and the contamination in 53 wells exceeds EPA’s health advisory level.

Munitions Disposal - Several decades of negligent disposal of munitions and propellants has littered the U.S. with UXO and explosives chemical contamination. A study of characterization of explosives contamination in the environment noted that "during World War I, World War II, the Korean War, and the Viet Nam War" munitions wastes were often disposed of in "unlined lagoons, which could not contain species such as munition charges." For decades, troops often buried munitions they could not or did not fire in training areas. These caches of munitions stay under the ground until someone stumbles upon them during cleanup, construction, or other activities. Like all other abandoned munitions, they will eventually decay and release components into the soil and groundwater.

It should not be assumed that current techniques for munitions disposal are protective of human health and the environment; in fact, the reverse is true. Current military practices such as open burning/open detonation of surplus munitions and burning of excess propellant create widespread toxic air pollution and, through deposition, soil and groundwater contamination as well.

At the Massachusetts Military Reservation on Cape Cod, troops routinely burned excess propellant in the open air at artillery and mortar firing positions. In a 1991 study, Boston University researchers found an association between these firing positions and lung and breast cancer in people living nearby. The authors recommended and end to the practice of burning propellant.

Various military facilities continue to dispose of munitions by open burning/open detonation (OB/OD), a practice which releases thousands of pounds of toxins into the air at sites across the country. More information on this practice can be found in the open burning/open detonation section of this report.

Formerly Used Defense Sites (FUDS) – FUDS may be any of the types of sites listed above, or other types. Up to 2,000 FUDS are known or suspected to contain unexploded ordnance. Some FUDS – such as the Spring Valley neighborhood in Washington, DC – contain buried chemical weapons and related contamination. Many FUDS doubtless contain soil and groundwater contamination by explosives and propellant compounds, but for the most part no one has looked.

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A full assessment of all sources of environmental contamination, human health impacts, and cultural and economic damage originating from military munitions is well beyond the scope of this report. However, it is possible to identify some major issues. According to a recent report by the Center for Public Environmental Oversight (CPEO), sources of toxic contamination from munitions and their constituents at military testing and training ranges may be divided into several categories.

Small Arms Ammunition – Until very recently, most U.S. small arms ammunition contained lead, which has been found in the environment at various sites. Any of the thousands of small arms ranges scattered across the country is a potential source of lead contamination.

Unexploded Ordnance (UXO) – Five to ten percent of munitions that are fired, launched, or dropped do not explode as designed. These munitions are known as unexploded ordnance or UXO. As noted previously, up to 25 million acres of lands and waters at several thousand sites in the U.S. are contaminated with millions of pieces of UXO. UXO may sit on or just under the surface, several feet underground, on top of boulders, or in trees. UXO poses an extreme safety danger to anyone in the area. Many children and adults both within and outside the U.S. have been injured or killed by U.S. military UXO. UXO will also corrode and release their constituents – including metals and explosive compounds – into the environment.

Explosives and Metals – Explosive compounds and heavy metals can and often do enter the environment when munitions are produced, when they detonate, and if they fail to detonate as designed. According to the CPEO, "when a conventional high-explosive munition detonates, it releases a large variety of chemical compounds and metals into the environment." Low-order detonations (in which the munition does not explode completely) seem to produce greater amounts of explosives contamination than high-order (complete) detonation, which fully combust the explosive compound. Many explosives and their degradation products are very mobile in groundwater and persist in the environment for long periods of time (at least decades). Even when munitions detonate as designed, heavy metals including lead, cadmium, chromium, nickel, copper, and barium remain and can contaminate air, soil, and water. As noted immediately above and in the UXO section later in this report, munitions that fail to detonate are also major sources of contamination.

Propellants – The chemicals that move explosives forward are called propellants. Military munitions use several types of propellants, including single-based propellants (such as nitrocellulose; these may also contain 2,4-dinitrotoluene), double-based propellants (containing, for example, nitrocellulose and nitroglycerine), and triple-based (nitrocellulose, nitroglycerine, and nitroguanidine). Propellants may be found near and downwind of firing positions and may also be found in impact areas. Open burning/open detonation of propellant may also be a source of contamination. Surplus artillery propellant bags have been routinely burned at artillery firing positions; the propellants may spread some distance through the air. As noted elsewhere, burning of propellant has been associated with health problems in neighbors of the Massachusetts Military Reservation on Cape Cod.

Pyrotechnics – Pyrotechnics are intended to produce light, heat, smoke, or noise, and include tracers, flares, incendiaries, photoflash compounds, and smoke generators. Contaminants originating from pyrotechnics include red and white phosphorus; barium and strontium; perchlorates; polyvinyl chloride; titanium tetrachloride; and hexachloroethane and hexachlorobenzene. The Eagle River Flats range at Fort Richardson, AK – a fragile coastal wetland – is heavily contaminated with white phosphorus from pyrotechnics, which killed thousands of waterfowl each year for over a decade.

Burial Sites – For decades, troops have buried munitions that they can’t or don’t fire in the field. In some place, large numbers of munitions were consciously buried as a disposal method. These caches of munitions stay under the ground until someone stumbles upon them during cleanup, construction, or other activities. Like all other abandoned munitions, they will eventually decay and release components into the soil and groundwater.

Open Burning/Open Detonation (OB/OD) Sites – Military munitions – as well as large varieties of other military wastes – are routinely disposed of through open burning/open detonation or OB/OD. In open burning/open detonation munitions and other wastes are incinerated at relatively low temperatures with little or no environmental controls. OB/OD sites and the surrounding environment are usually contaminated with munitions constituents, PCBs, dioxins and furans, perchlorate, and other toxic substances. The practice of burning artillery propellant bags noted above is essentially a small-scale and form of OB/OD. The OB/OD section of this report contains more information on these practices.

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Military munitions contain dozens if not hundreds of toxic and hazardous components that pose extreme dangers to human health and the environment. These substances may be divided into three basic categories: metals; explosive compounds and their degradation products; and propellants. There are a variety of good sources of information on these contaminants, though less is available on the health effects of many. A list of common contaminants and some basic information about each follows.

Ammonium Nitrate – May be found in propellant or main charge. Linked to various health effects, including fall in blood pressure, nausea and vomiting, collapse and coma.

Barium Nitrate – An oxidizing compound found in some incendiary mixtures and single-based propellants. Ingestion can result in gastroenteritis, muscular paralysis, decreased pulse rate, and ventricular fibrillation.

Benzene – Used as a starting material for the development of explosives. Linked to aplastic anemia and leukemia.

Cadmium – Heavy metal linked to respiratory tract cancer and kidney damage.

Chromium – Heavy metal linked to respiratory tract cancer.

Composition A, B, and C – Explosive compounds.

DEGDN – A propellant. Causes acute renal failure.

Dinitrotoluene or DNT (including 2,4-DNT and 2,6-DNT) – A component of single-base propellants. A probable human carcinogen. Can cause anemia, liver necrosis, and other effects.

Explosive D – An explosive compound used as a main charge. Causes nausea, vomiting, coma, and seizures, among other effects.

Hexachloroethane – Used in some smoke ammunition. Linked to kidney and liver damage, and is a possible human carcinogen.

HMX – Used as a booster or main charge, and in pyrotechnics and incendiaries. Linked to damage to the nervous system and liver.

Hydrazine – Used in rocket propellants and fuels. A known human carcinogen. May cause liver, kidney, and respiratory damage and harm reproductive organs.

Lead – Lead adzide and lead styphnate are used as primary charges or intiators. Lead damages the central nervous system in children and the peripheral nervous system in adults. Lead adzide can cause anemia, kidney and brain damage, and other effects. Lead styphnate causes widespread organ and systemic effects on the central nervous system, immune system, and kidneys.

Mercury – Mercury fulminate is used as a primary charge or initiator. Linked to renal failure, shock and circulatory collapse, gastrointestinal problems, and other effects.

Nitrocellulose – The primary component of propellants, smokeless powders, rocket fuel, mortar increments, and some explosives. Animal studies suggest it is largely non-toxic to humans, but data is not available regarding human toxicity from drinking water and other exposures.

Nitroglycerine – Component of double- and triple-base propellants, also may be found in main charge. Linked to methemoglobinemia (reduced oxygen content of the blood); impacts circulatory system.

Nitroguanadine – Component of triple-base propellants. Little information is available on its toxicity.

Perchlorates – Common ingredient in propellants; also found in pyrotechnics. Damages the thyroid, which is especially dangerous to fetuses, infants, and children. Also causes acute health effects.

PETN - Booster, main charge, pyrotechnics, incendiary. Irritates the eyes and skin and causes headaches, weakness and drop in blood pressure.

Picric Acid – An explosive used as a main charge. Causes serious problems in the central nervous system, as well as blood cell damage, acute hepatitis, and other effects.

RDX – Very common secondary explosive used as booster or main charge, and in pyrotechnics and incendiaries. Damages the central nervous system and is a possible human carcinogen.

Tetrazene – An initiating explosive. Can cause mucous membrane destruction, pulmonary edema, death.

Tetryl – A common explosive during World Wars I and II as a booster charge; no longer used. Indications of various health effects, including nosebleeds, nausea, and vomiting. Its carcinogenicity has not been studied.

TNT – A very common secondary explosive used as a main charge. Is both mutagenic and carcinogenic; linked to effects on brain, liver, blood, reproductive organs, kidneys, urinary bladder, and eyes.

White Phosphorus - Used in pyrotechnics and incendiaries. Contact with the skin while burning may cause burns and liver, heart, and kidney damage. Causes reproductive effects. Inhalation of vapors may irritate the nose, throat, lungs, skin, eyes, and mucous membranes. Ingestion may cause liver, heart, or kidney damage, as well as vomiting and death.

Obviously a complete exposition of the health dangers posed by all these substances is well beyond the scope of this report. We present some information here to demonstrate the need for precautionary action to prevent additional exposures and clean up existing contamination. It is important to note that the question of cumulative effects from the variety of contamination at military ranges and other munitions contamination sites is never addressed. Scientists have not found a method to determine the effects and document them in an irrefutable manner. Common sense tells us that if we are being exposed to more than one contaminant then the effects of each contaminant must interact with the others in some adverse manner.

A 1998 EPA survey of project managers at 206 closed, transferred, and transferring (CTT) and inactive military ranges found widespread health dangers. The report concluded that:

There is abundant and growing evidence of the damage to human health and the environment caused by military munitions and ranges. The consequences for communities are very real.

At the Massachusetts Military Reservation on Cape Cod, toxic munitions constituents contaminated the only drinking water supply for 500,000 neighbors of the base, forcing the shutdown of municipal wells. Burning of excess artillery propellant at firing positions was linked to increased lung cancer in people living nearby. Throughout the 1980s, women on the Upper Cape near the base were 64% more likely to be diagnosed with lung cancer than women in the rest of the state.

Since 1940, the U.S. Navy has used three-quarters of the island of Vieques, Puerto Rico for bombardment, munitions disposal, and other activities. There is strong evidence that heavy metals and other munitions toxins move in the air from the bombing range to the civilian areas. The toxic explosive compound RDX was found in drinking water supplies in civilian areas in the late 1970s. In 2000, excessive levels of mercury were found in the hair and fingernails of 45% of Vieques residents tested. Vegetables and plants growing in civilian areas are highly contaminated with lead, cadmium, and other heavy metals. From 1985-1989, Vieques children aged 0-9 were 117% more likely to contract cancer than children of the same age on the main island of Puerto Rico. Children aged 10-19 were 256% more likely to contract cancer. A 2001 study found that Vieques residents are 73% more likely to suffer from heart disease than residents of the main island, 64% more likely to develop hypertension, 58% more likely to have diabetes, and 18% more likely to be diagnosed with asthma.

The effect of contamination from heavy metals is well documented, but the military continues using them in the munitions that litter every state and many other countries. As noted above, lead is a common component of small arms ammunition, and lead adzide and lead styphnate are used as initiating explosives in various munitions. Lead is known to affect the production of blood cells, reproductive system and behavior. The risks of lead poisoning are greatest for children and pregnant women. Children have a tendency to ingest greater amounts in relation to their body weight. Pregnant women are at risk for miscarriage and damage caused to the developing child. Lead adzide and lead styphnate cause even worse health effects.

The toxic effects of explosive compounds have not been extensively studied. They are becoming more known because of rapidly increasing evidence of widespread environmental contamination by these substances and the exposure of military neighbors to their effects. Even the existing state of the science presents great cause for alarm, especially when combined with the experiences of communities exposed to these toxins.

The range of health problems in humans and animals associated with exposure to these components of munitions include seizures, nausea and vomiting, decreased body weight, liver and kidney damage, anemia, skin irritation, cataracts, and harmful effects on the immune system. Many of these substances are suspected or proven to cause cancer in humans. According to the U.S. Army Corps of Engineers, "secondary explosives [those most prevalent on military sites] are considered carcinogenic and mutagenic."

TNT persists in the environment for at least decades and is very mobile in groundwater. Millions of feet of soil in the U.S. are contaminated with TNT. It is both mutagenic (causes birth defects) and carcinogenic, and may damage the liver, blood, reproductive organs, kidneys, and other organs in humans. It is also thought to cause blood, liver, immune system, and reproductive system damage in wildlife.

RDX can also move long distances in groundwater and may persist there for long periods of time. Groundwater at hundreds of sites across the country is contaminated with RDX. It affects the central nervous system and may cause cancer in humans. In wildlife, RDX may cause neurological damage and harm the liver and reproductive system.

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Unexploded ordnance (commonly known as UXO) presents both an immediate safety danger (from explosion) and a long-term health threat (from toxic contamination) to thousands of communities. DoD defines "explosive ordnance" as any munitions, weapon delivery system, or ordnance item that contains explosives, propellants, and chemical agents. UXO consists of these same items after they (1) are armed or otherwise prepared for action, (2) are launched, placed, fired, or released in a way that they cause hazards, and (3) remain unexploded either through malfunction or design.

Up to 25 million acres of land acres on thousands of sites in the U.S. may contain unexploded ordnance, most of which result from weapons testing and troop training activities conducted by the Department of Defense (DoD). This property includes active military bases, formerly used defense sites (FUDS), and base realignment and closure (BRAC) sites. Approximately 16 million acres already transferred from DoD to other federal agencies and the public, and at least 2,000 formerly used defense sites are known or suspected to contain UXO. Fifty-nine military sites listed on the federal Superfund National Priorities List (the most contaminated sites in the country) are contaminated with UXO.

UXO may be found at the ground surface or partially or fully buried as deep as 30 feet or more below the ground surface. Ordnance stabilized by parachute may be completely buried, but the parachute may appear at the surface. UXO may also be found fully intact or in parts or fragments. All UXO, whether intact or in parts, presents a potential hazard and should be treated as such.

UXO may be encountered as isolated munitions or as one of many in a given area. The density and type of UXO in an area depends on the intensity and proximity of troop training and weapons testing activities, the degree of UXO cleanup already conducted, and the types of ordnance used. UXO such as dispensers, missiles, rockets, or projectiles may still contain submunitions, or those submunitions may have been scattered across a large area. If any UXO is found, one should assume that other UXO are in the area.

UXO casings may have deteriorated depending on the type of material used, the length of time since deployment, and the elements to which they were exposed. UXO that has deteriorated presents a particular hazard because it may contain chemical agents that could become exposed. Environmental contamination and human health damage caused by corroding UXO are addressed in more detail elsewhere in this report.

In April 1998, the Defense Science Board (DSB) Task Force on Unexploded Ordnance Clearance, Active Range Clearance, and Explosive Ordnance Disposal Programs, composed primarily of retired generals and former Defense appointees, released a report on Unexploded Ordnance Remediation. The Task Force found that:

More recently, DoD has estimated the cost to clean up UXO at over $100 billion, and the U.S. General Accounting Office estimates the cost to clean up UXO on just closed, transferred, and transferring ranges at up to $140 billion. The total DoD budget for cleanup for all active facilities and Base Realignment and Closure (BRAC) sites is approximately $1.7 billion per year.

The DSB Task Force found that the Department of Defense, as a whole, lacked specific cleanup goals, objectives, or management plans for UXO, and recommended the establishment of a focal point within the Environmental Security office to address the Department's unmet management responsibilities. The report suggested that the Deputy Undersecretary of Defense for Environmental Security [DUSD(ES)] "take the policy lead for DoD UXO remediation efforts, in coordination with other relevant DoD components." The report also endorsed stable funding. It said the Environmental Security office should:

The Task Force actually suggested two UXO line items: one for remediation and one for research, development, test, and evaluation (RDT&E). DoD has recently taken some steps to address safety hazard posed by UXO, if not the chemical contamination issues, and Congress has also become involved.

In late 2001, Congress included several provisions on UXO championed by Representatives Earl Blumenauer (D-Oregon) and Bob Riley (R-Alabama) in the 2002 Defense Authorization Act. Congress mandated that DoD complete by May 31, 2003 and update annually an inventory of unexploded ordnance, discarded military munitions, and munitions constituents at defense sites other than operational ranges. DoD will be required to consult with states and tribes to develop a process to prioritize these sites, and provide an opportunity for public comment on the prioritization protocol. The legislation bars DoD from using its prioritization of sites to avoid regulation. Other provisions established program elements in DoD’s budget to track cleanup of UXO, discarded munitions, and munitions constituents, and required DoD to produce both an interim and final report on projected costs for the cleanup of ordnance at both operational ranges and at other defense sites (including former ranges and disposal sites). For the first time, Congress and the public will be able to find out the true scope of UXO and munitions chemical contamination at non-operational DoD ranges and track spending to remedy these dangers.

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Open burning/open detonation (OB/OD) is a form of uncontrolled incineration. Open detonation and open burn operations are used to destroy excess, obsolete, or unserviceable munitions and energetic (i.e., explosive) materials, including UXO and surplus propellant. In open burning, materials are destroyed by self-sustained combustion after being ignited. In open detonation, a charge is used to detonate and destroy the munitions and energetic materials. In the past, these operations occurred at land surface or in pits. OB/OD is more acceptable when munitions, such as those recovered in a firing range, are unsafe to move. Pressure on DoD and EPA to stop OB/OD activities has been increasing, and the practice may eventually be abandoned, at least for large-scale munitions disposal. Some minimal environmental controls have recently begun to be used for some OB/OD operations. However, EPA has concluded that "harmful emissions may pose human health and environmental risks and are difficult to capture sufficiently for treatment." Safer alternatives for munitions disposal – including the controlled detonation chamber (the "Donovan" chamber) already exist.

During the process of open burning and detonation of munitions, airborne contamination is dispersed into the atmosphere and toxic residues are left in the soil. According to a report by the Weizmann Institute of Science in Israel and the University of Florida, OB/OD causes serious contamination of the surrounding environment. Burning common explosives produces toxic gases such as nitric oxide and carbon monoxide. In an attempt to measure and identify emissions from the burning of propellants, Sandia National Lab conducted the so-called "Bang Box" tests. Emission factors from these tests included toxic and carcinogenic substances such as carbon monoxide, methane, benzene, 2,4 dinitrotoluene (2,4 DNT), 2,6 dinitrotoluene (2,6 DNT) and nitrogen oxides.

At many training and firing ranges, the areas where OB/OD operations took place are the most contaminated sites on the ranges. According to EPA, underlying soil and groundwater may become contaminated with byproducts of incomplete combustion and detonation. These contaminants may include explosive and propellant compounds, heavy metals, dioxins, and other hazardous substances.

There is little doubt that people living near military ranges and disposal sites have been exposed to emissions and particulates from OB/OD operations. Residents miles downwind of OB/OD sites are at risk for increased cancers and respiratory problems. Two communities on opposite sides of the country - but both in proximity to OB/OD activities - exhibit high incidences of lung cancer.

At the Massachusetts Military Reservation (MR) on Cape Cod, a Boston University study found a relationship between residence proximity to the artillery training area, where propellant bags were burned, and the risk of lung and breast cancer. Other OB/OD operations also occurred at the base over the past several decades. Studies of open detonation operations at MMR found that explosive residues are emitted into the air during these actions, and are commonly deposited on the soil in concentrations significantly above action levels. From 1982-1990, women living in census tracts near the base were 64% more likely to be diagnosed with lung cancer than women in the rest of the state.

In Utah, open detonation and burning has been used for years for the disposal of military propellants, explosives and pyrotechnics at Toole Army Depot. While the state of Utah has some of the lowest cancer rates in the country, a comparison of cancer rates shows the incidence of lung cancer in Toole County, home of the Depot, is well above the state average from 1966 to 1990.

In the early 1980's, dozens of military installations were granted "interim" status under RCRA Subpart X (see appendix), which allowed them to conduct open burning and open detonation (OB/OD) of munitions without RCRA permits. Regulations promulgated in 1987 required these facilities to apply for permits in 1988. Any facility that did not apply for a permit by November 8, 1988 automatically lost its interim status on November 8, 1992. At least one facility, the Sierra Army Depot (California's largest toxic air polluter, according to recent EPA data), did not apply for a permit in 1988 as required, but continued OB/OD through the 1990's without action by the EPA. Since 1988, seventy installations have submitted Subpart X permit applications for Open Burning/Open Detonation (OB/OD) units. As of mid 1998, EPA was still allowing many OB/OD sites to operate under interim status and treat hazardous waste (munitions) by burning and detonation at low temperatures in the open with little or no pollution controls.

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Indigenous communities and their cultural, spiritual, and historic sites are often heavily and uniquely impacted by military munitions. Because many Indigenous cultures are inextricably linked to the environment and traditional practices, military contamination of food sources can devastate the way of life of these peoples. Impacts on subsistence food supplies are addressed in the section on contamination of these resources. We present two examples of egregious impacts on cultural, spiritual, and historic sites here.

The Hawai’ian island of Kaho’olawe – 28,000 acres about six miles southwest of Maui – was inhabited for over a thousand years by native Hawai’ians before the U.S. military for target practice at the outset of the Second World War. Kaho’olawe was an important training ground for kahuna (priests) and navigators. Decades of Navy training denied Native Hawai’ians access to the island, which is a wahi pana (sacred place) and a pu’uhonua (place of refuge and spiritual regeneration), destroyed religious and cultural sites, and contaminated the land and water with tens of thousands of pieces of unexploded ordnance. After a decades-long struggle led by the Protect Kaho’olawe ‘Ohana, the island was formally returned to the State of Hawai’i in 1994 in anticipation of its eventual transfer to a Native Hawai’ian sovereign entity. The ‘Ohana continues to lead the struggle to hold the DoD to its (and Congress’) commitments to cleanup UXO on the island and return it to a state "reasonably safe for human habitation."

The Army has trained in Makua Valley on O’ahu, Hawai’i since the 1940s. DoD appropriated the entire valley when World War II broke out, evicting families, but did not return the land after the war as promised. Makua contains Indigenous Hawai’ian sites and artifacts – including heiau (temples), burial grounds, and fishermen’s shrines – dating back 900 years. Fifty years of training, firing, and munitions disposal have destroyed homes, the local church and Indigenous Hawai’ian temples, and contaminated soil and groundwater. The Army’s occupation of Makua continues to deny the community access to these sacred lands.

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Munitions chemical contamination is insidious. It can work its way into water supplies and into the food chain, poisoning people who eat contaminated plants and animals, drink contaminated water, or even eat plants from gardens watered with contaminated water.

Individuals and communities that eat fish that they catch, game that they hunt, and plants that they gather or grow may also be exposed to munitions toxins. Certain toxins and radioactive isotopes accumulate in plant and animal flesh and move up the food chain until they reach human bodies. These substances tend to persist in animal and human tissue for long periods, accumulating to harmful levels over months and years. Indigenous communities and other populations that eat large amounts of fish and other local plants and wildlife are most exposed. Many Indigenous communities depend on wild fish, plants, and game for subsistence and also for the preservation of traditional ways of life. The end of subsistence fishing, hunting, and gathering means the end of these communities and their culture. They may be wiped out by munitions contamination of their food supply.

Unexploded ordnance (UXO) and munitions constituents contaminated – and still contaminate – traditional hunting and fishing grounds on and around Fort Richardson, Alaska. Since 1949, the Army has fired ordnance including high explosives, smokes, and illumination flares into the sensitive estuarine salt marsh of Eagle River Flats, leaving 10,000 pieces of UXO. These munitions continue to leach toxic substances into the environment, and pose a safety danger to hunters and others who enter the area because no physical barriers prevent access. Both UXO and chemical contamination has precluded subsistence hunting and fishing by area tribes. White phosphorus contamination in the Flats killed thousands of waterfowl each year for almost two decades before the Army released a draft cleanup plan. UXO may also exist in, on, and/or under up to 2 million acres outside the current boundaries of Fort Richardson. There has never been a systematic attempt by the Army to identify areas likely to contain UXO or to investigate or remedy either the safety or toxic hazards either within or outside the current boundaries of the base.

Mercury released by operations at the Badger Army Ammunition Plant contaminated fish eaten by neighbors of the site. In late 2000, the Wisconsin Bureau of Environmental Health sent letters to at least 21 homes near the plant warning residents who had at some point received permits to fish at the ballistics pond on the plant property that the fish were contaminated with mercury. The letter noted that "the Army recommends to permit holders that they eat no fish from the ballistics pond." Plant neighbors had caught and eaten fish from this pond for years before the mercury contamination was finally discovered. In water, mercury becomes methylmercury, an unusually toxic form that accumulates in fish tissue. Methylmercury can cause nuerological damage and death in humans in small amounts. Mercury crosses the placenta to contaminate fetuses in the womb, and can damage memory and other skills in exposed children. There is no way to remove mercury from fish tissue before consumption.

Munitions constituents have contaminated drinking water wells and supplies in several communities around the country, exposing people to dangerous toxins. Many munitions constituents and their degradation products are mobile and persistent in groundwater and pose severe threats to human health. There is little documentation easily available to the public about the scope and severity of contamination of drinking water supplies near military firing ranges across the country. We do know that the scale of munitions contamination of soil and groundwater is very large; we just don’t know how many drinking water supplies have been contaminated, primarily because adequate testing and monitoring has never been done.

At the Massachusetts Military Reservation (MMR) on Cape Cod, decades of munitions firing and disposal contaminated the sole source drinking water aquifer for half a million permanent and seasonal residents of the Upper Cape. A January, 2000 EPA letter to the DoD notes that:

More recently, perchlorate was found in drinking water supply wells in the town of Bourne, forcing the shutdown of several wells. To date, explosives contamination has been found in about half of the 200 monitoring wells installed on Camp Edwards (one part of MMR); contamination in 53 exceeds EPA’s health advisory levels. Because of pollution from MMR, the Upper Cape could face a drinking water shortfall of 11 million gallons a day by 2020.

Neighbors of the Trojan Explosives plant in Mapleton, Utah have been exposed to RDX and nitrates in their drinking and irrigation water. Neighbors of the facility used contaminated water to drink, shower, water gardens, fill swimming pools, and fill ponds from which they ate fish. Several neighbors have been diagnosed with non-Hodgkins lymphoma. Plaintiffs in several lawsuits allege negligent practices by Trojan and charge that the company knew about the water contamination as early as 1981 but did not warn the neighbors. In 1986, the company found RDX in one of its groundwater monitoring wells at 10.7 parts per million (5,500 times the federal health advisory level). Private wells near Trojan showed concentrations of RDX at 23 parts per billion (ppb), 16 ppb, and 12 ppb. The federal health advisory level is 2 ppb.

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While military munition impacts on human health are often most reported, damage to plants, wildlife, and the environment is also widespread and equally significant. Damage to air, soil, and water may persist for generations, or in the case of radioactive contamination, for thousands or millions of years. Large areas of land and water in the U.S. contaminated with UXO and toxic substances from military munitions is unsafe for housing, schools, and many other uses, and will be for the foreseeable future. Military munitions contamination adds significantly to the heavy load of toxic contamination already borne by the environment that sustains all life on the planet. Endangered and threatened plant and animal species – already pushed to the brink of extinction by human activities – are in some cases danger of being pushed over the edge by military munitions.

Makua Valley in Hawai’i is home to over 40 endangered species, including one found nowhere else on earth. Forty years of Army training and disposal operations at Makua have wreaked havoc on these species. Native forest has been destroyed by over 270 fires caused by military activities.

White phosphorus and other toxic munitions constituents contaminated the fragile estuarine salt marsh of Eagle River Flats at Fort Richardson, Alaska. As noted above, subsistence fishing grounds have been rendered unusable by the Native Alaskans who have historically used these resources. Munitions contamination also killed thousands of waterfowl every year for two decades before the Army released even a draft cleanup plan.

As readers will doubtless gather from the rest of this report, there are countless other examples of damage to natural resources and species caused by military munitions and firing ranges.

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The regulation (or often the lack thereof) of military munitions and ranges is a complex matter involving federal, state, Tribal, and local laws as well as various governmental and nongovernmental actors. A plethora of agencies and authorities are involved in some aspect of regulation of military munitions and ranges, including: EPA (both headquarters and the regions); DoD (including the Secretary of Defense, the Defense Environmental Restoration Program, the Department of Defense Explosives Safety Board, and the armed services); other federal agencies; tribes; states; and the public (through various public participation programs, citizen suits, and political action). A variety of laws, regulations, and both formal and informal agreements may be invoked depending on the circumstances. The currently shifting landscape of statutory and regulatory authority, as well as the large cast of actors on these issues, makes it difficult to present a straightforward or unequivocal analysis of when, where, how, and why munitions and ranges are – or are not – regulated. The laws applied and the parties involved often differ from site to site. This section attempts to address in a reasonably structured manner the major laws, regulations, and issues involved.

Regulation of military munitions and ranges occurs primarily under two statutes: the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA, known as the Superfund law); and the Resource Conservation and Recovery Act (RCRA). CERCLA provides for cleanup of contaminated sites and accidents, spills, or other releases of hazardous substances to the environment. RCRA governs solid waste, including hazardous waste, from cradle to grave. Either or both of these laws – in addition to others – may be applied to munitions contamination depending on the circumstances.

Two legal issues often prevent application of federal environmental and public health laws such as RCRA and CERCLA to federal agencies, including the Department of Defense. The doctrine of sovereign immunity – literally a remnant of the days when kings and queens were above the law – means that federal laws cannot be applied to the federal government itself unless Congress specifically, completely, and unequivocally waives that immunity. The unitary executive theory – adopted by the U.S. Department of Justice – holds that because the entire Executive Branch of the federal government is one entity headed by the President, federal agencies cannot bring suits against each other. One of these doctrines – sovereign immunity – is universally accepted throughout the U.S. legal system, and the other – unitary executive – is simply a position adopted by the Executive Branch but not universally recognized elsewhere. Taken together, these two legal doctrines prevent any application of either the routine or enforcement provisions in environmental and public health laws to the DoD unless Congress has clearly and unequivocally waived federal immunity and explicitly granted EPA or other relevant agencies the authority to issue binding orders or take legal actions against other federal agencies to enforce the law.

The Department of Defense Explosives Safety Board (DDESB) was established by Congress in 1928 to provide objective advice to the military on explosives safety and to prevent hazardous conditions arising from the explosive and environmental effects of military munitions. The DDESB establishes and oversees implementation of explosive safety requirements throughout the DoD, and is authorized to resolve issues between explosives safety standards and environmental standards. While DDESB directives are binding on DoD munitions cleanups in addition to any other regulatory requirements, like the policies of the Defense Environmental Restoration Program (DERP – see below) they are not enforceable by other federal agencies, states, tribes, or the public.

Enacted in 1980 and amended in 1986, CERCLA created broad federal authority for systematic identification and cleanup of highly contaminated sites that threaten human health and the environment. The blueprint for CERCLA implementation is the National Oil and Hazardous Substances Pollution Contingency Plan (generally referred to as the National Contingency Plan or NCP). CERCLA provides for action when there is a release or threat of a release of a hazardous substance into the environment, especially when the release or threat of release poses an imminent and substantial endangerment to public health. CERCLA requires investigation of releases or potential releases, as assessment of risk to the public, and, if there is an unacceptable threat to the environment or human health, consideration of cleanup options, documentation of decisions, and finally actions to address the contamination.

CERCLA authorizes two kinds of actions to respond to contamination (generally known as "response actions"):

Sites addressed under CERCLA may be divided into two categories:

Although CERCLA is administered and primarily implemented by the federal government, states, tribes, and the public play a significant role in CERCLA implementation. Recently some states – especially Colorado – have been pursuing more active roles in investigation and cleanup at military CERCLA sites in order to protect the health and welfare of their residents. This development has tended to encourage more protective cleanups because states can step in when EPA – often under national pressure from DoD – fails to act.

Congress appeared to waive federal sovereign immunity under CERCLA in Section 120, which clarified that:

However, the CERCLA sovereign immunity waiver is not clear and unequivocal enough to accomplish its goal. In reality, EPA, states, tribes, and the public cannot hold DoD accountable to CERCLA in the same manner as other entities. Problems in the waiver and various Executive Branch orders and decisions often frustrate the application of CERCLA at military sites.

The CERCLA sovereign immunity waiver passed by Congress is not clear enough to allow full application of the law to federal facilities. Courts have ruled that CERCLA does not waive federal immunity from state laws at sites no longer owned or operated by federal agencies, even when those agencies clearly contaminated the site. At least one court has ruled that the waiver does not allow civil penalties to be awarded for past violations by a federal agency under CERCLA. DoD claims that CERCLA does not waive immunity from state cleanup standards, but merely requires it to comply with the standards it deems appropriate. States may attempt to enforce their standards, but the lack of an unambiguous waiver and federal resistance usually force states to give up or undertake time-consuming and expensive litigation.

The CERCLA statute grants the authority to implement the law to the President of the U.S. President Reagan’s Executive Order (EO) 12580 empowered EPA to manage most of the CERCLA program, but delegated to DoD the authority at most military CERCLA sites. At sites listed on the NPL, DoD is the "lead agency," meaning that it has responsibility for CERCLA responses at its own sites. EPA must concur with DoD’s decisions about the site (formalized in a ROD, or Record of Decision), but cannot impose a more protective cleanup process as it can at private sector sites. At non-NPL sites (the vast majority of sites that require a response under CERCLA), DoD must simply consult with EPA, states, and tribes, but retains complete authority to make decisions on its own in all situations except removal actions that are emergencies. EO 12580 prevents EPA from ordering a cleanup at a military facility without approval by the Department of Justice (charged with representing both agencies).

EPA’s authority under CERCLA Section 106 to act to protect public health and the environment in the case of an imminent and substantial endangerment is critical to fulfilling CERCLA’s promise that the dangers posed by environmental contamination will be promptly addressed. Unfortunately, EPA cannot utilize even this essential authority at most DoD sites. The terms of a Clinton Executive Order and a 1998 memorandum of understanding between EPA and other federal agencies cripples EPA’s ability to protect the public from munitions contamination under CERCLA. At non-NPL sites, the authority to address imminent and substantial endangerment of human health and the environment under Section 106 of CERCLA resides with the DoD itself rather than EPA. The problem with this arrangement is clear: even in the face of an immediate danger to public health, EPA cannot force DoD to act under CERCLA. The health of the environment and DoD’s neighbors at these sites depends solely on its voluntary cooperation. The history of DoD’s failures to protect the public does not provide great cause for optimism in these cases.

Congress amended CERCLA in 1986 by passing the Superfund Amendments and Reauthorization Act (SARA), with the intent of clearing up complex areas of the law that had been encountered in its first six years. SARA required that CERCLA actions take into consideration existing state and federal regulations and laws. It increased state involvement in every phase of the program. Possibly the most important change was the requirement that EPA revise its Hazard Ranking System to more accurately reflect the relative degree of risk to human health and the environment posed by uncontrolled hazardous waste sites placed on the NPL.

SARA Section 211 formally established the Defense Environmental Restoration Program (DERP) by statute (DoD had operated an installation restoration program since the mid-70s). The law requires that the DERP be carried out in consultation with EPA, states, and tribes, and that state, tribal, and local governments be able to comment on response actions (except in emergencies). Three goals were established for the DERP:

It is critical to note that other agencies, states, tribes, and affected communities have little or no independent recourse if military facilities fail to comply with DERP requirements. This situation renders DERP requirements essentially unenforceable when voluntary compliance fails.

RCRA (pronounced "rick-rah") created a federal program to control solid waste (including hazardous waste) from generation to disposal (from "cradle to grave"), including generation, transportation, treatment, storage, and disposal. RCRA regulates not only day to day management of wastes but also the cleanup of releases to the environment, whether intentional or accidental. The law focuses only on active and future facilities and does not address abandoned or historical sites (which are regulated under CERCLA). Subtitle C of RCRA created a strict system of permits, transportation manifests, and treatment, handling, and disposal standards. Subtitle G authorizes EPA to issue binding orders or seek court injunctions to protect health or the environment from "imminent and substantial endangerment" by hazardous waste, and empowers citizens to sue for injunctions if EPA fails to act.

The definition of solid waste in the RCRA statute passed by Congress in 1978 is broader than the definition adopted by EPA in the regulations implementing the law. Materials can only be regulated as hazardous waste under the strict Subtitle C system if they meet the narrower EPA definition. However, citizen suits and EPA orders and actions taken under the Subtitle G "imminent and substantial" endangerment provisions occur under the broader statutory definition. These distinctions become critically important in the regulation of military munitions and firing ranges.

Because the DoD resisted compliance with RCRA, in 1992 Congress passed the Federal Facilities Compliance Act, or FFCA (Section 6001, as amended by PL 102-386). The FFCA clarified that federal facilities are subject to all provisions of federal, state, interstate, and local hazardous waste laws and regulations. The law also specifically empowers EPA to issue binding orders to other federal agencies under RCRA, and empowers both EPA and the states to impose fines and penalties against federal facilities that violate RCRA. Unfortunately, much of the FFCA’s promise to protect communities endangered by DoD waste – including military munitions and related contamination – has not been met.

Because RCRA was originally written to govern private sector wastes, Congress directed EPA to write a regulation (known as the "Munitions Rule") balancing the need for oversight of military munitions with the DoD’s need to train and fight. Section 107 of the FFCA mandated that the Munitions Rule (1) determine when military munitions become hazardous waste and therefore subject to regulation under RCRA Subtitle C; and (2) ensure that when munitions are considered hazardous waste they are safely stored and transported.

When EPA failed to write the rule in a timely manner, MTP sued to force the rulemaking to proceed. In a court-negotiated settlement, EPA agreed to produce the regulations by October 31, 1996. Because Congress failed to approve the federal budget that year, the deadline was extended to December 2, 1996. EPA ultimately issued the final Munitions Rule in February 1997.

When the Munitions Rule was finally issued, EPA undermined the intent of Congress by completely exempting all munitions at operational firing ranges from RCRA’s definition of hazardous waste unless and until DoD specifically collects them for disposal. EPA’s surrender to DoD ensured that millions of pieces of UXO will remain on military ranges leaching toxic contaminants into the environment. EPA also surrendered on transportation standards, ruling that munitions that would otherwise be regulated as hazardous waste under Subtitle C are exempt from those provisions as long as they are transported in accordance with DoD standards.

MTP challenged the Munitions Rule in Court, arguing that EPA acted contrary to law when it determined that munitions deposited on or off operational ranges are not a RCRA solid waste and therefore will never be considered a hazardous waste. Although the court ruled in favor of EPA, the challenge to the Rule’s obvious surrender to the Pentagon’s political and cultural clout galvanized affected communities to organize and seek out other means to protect themselves from munitions contamination (see below).

The Munitions Rule issued in 1997 postponed final action on the statutory status of used or fired munitions at non-operational (closed, transferring, and transferred, or CTT) military ranges, and the regulatory status of used or fired munitions that are recovered and then treated on-range at a CTT range. EPA deferred to DoD to write this section of the regulation, known as the "Range Rule." DoD produced a draft Range Rule in 1997, and a final draft Range Rule in 1999. EPA, states, tribes, and communities forced DoD to withdraw its proposed rule in November 2001 because of its many problems, including the failure to follow either RCRA or CERCLA processes and its failure to protect public health and the environment. In March 2000, DoD and EPA agreed to management principles for ordnance at CTT ranges, which serve as interim guidance until a Range Rule is adopted. As of this writing, no new draft Range Rule has been proposed by either agency.

Despite EPA’s surrender to DoD on the Munitions Rule, the FFCA does provide at least one tool to protect communities from munitions contamination at active ranges. The FFCA specifically authorized EPA to issue binding orders under RCRA to protect public health and the environment from imminent and substantial endangerment by federal agencies’ hazardous wastes. EPA Region 1 used this authority at the Massachusetts Military Reservation on Cape Cod because of munitions contamination of the only available drinking water supply for 500,000 people. DoD is currently seeking a Congressional exemption to remove this authority.

Historically, the DoD has argued that because of its mission (national defense) it should not be held to the same laws and standards as other agencies, private companies, and individuals. Military munitions and firing ranges have been no exception to this pattern. As noted above, the DoD argued successfully that it is capable of regulating its own munitions and operational ranges, despite over a hundred years of evidence to the contrary. Perhaps more importantly, the DoD attempts to avoid accountability to EPA, states, tribes, and the public even when laws and regulations apply. The DoD consistently seeks to address munitions contamination (including unexploded ordnance) under CERCLA rather than RCRA, and even seeks to use the CERCLA provisions that allow EPA and others the least input and recourse.

At the former Ford Ord in California, the Army argued for a decade that cleanup of UXO was not covered by the Federal Facilities Agreement for the base, that UXO is not a hazardous substance, that UXO is not subject to regulation under CERCLA, and that EPA had no authority over UXO cleanups. It took a suit by the Fort Ord Toxics Project to force the Army to submit to CERCLA and EPA regulations on UXO cleanup and perform a CERCLA remedial investigation/feasibility study for cleanup of UXO on the base. More recently, the Army attempted to prevent regulatory and public involvement in its cleanup of ordnance and explosives by claiming that its cleanup was a "removal" action, despite the fact that the effort had been underway for six years and was clearly part of a plan to implement a permanent solution to the contamination.

At the Massachusetts Military Reservation (MMR) on Cape Cod, EPA Region 1 was forced to issue binding orders under the imminent and substantial endangerment provisions of the Safe Drinking Water Act and RCRA to protect public health from immediate dangers posed by munitions contamination. Region 1 resorted to the orders only after years of refusal by the military to investigate and correct existing contamination and ongoing practices that clearly endangered the facility’s neighbors. The DoD contested the third of these orders – which required cleanup of the contamination – arguing that investigation and cleanup at MMR should occur only under the CERCLA Federal Facility Agreement (where EPA conveniently has no authority to issue binding orders to DoD). Fortunately for the community around MMR, EPA rejected this challenge.

Not surprisingly, states, EPA regions, tribes, and the public often prefer to use RCRA rather than CERCLA as an enforcement tool at military ranges and other sites with munitions contamination. RCRA provides much clearer and stronger means to protect public health and the environment and compel compliance with the law.

EPA Headquarters’ surrender to the DoD on the Munitions Rule did not solve the problem of dangers posed by thousands of military sites contaminated with UXO and munitions constituents. The public, tribes, states, and EPA regions have been forced to seek out means other than regulation of munitions under RCRA Subtitle C to protect human health and the environment. Fortunately, other tools do exist and are beginning to be used.

EPA Region 1’s use of the Safe Drinking Water Act (SDWA) to protect human health from immediate and substantial endangerment caused by munitions contamination of the sole source drinking water aquifer for 500,000 people on Cape Cod is probably the best known example of the application of a law other than RCRA and CERCLA to military munitions and firing ranges. Contamination at the Massachusetts Military Reservation (MMR) and EPA’s orders under the SDWA are covered more fully in the MMR site profile later in this report.

The Clean Air Act (CAA) has also been invoked to prevent damage to human health and the environment by military munitions contamination. Because the CAA can be enforced by U.S. EPA, local officials, and the public, it provides an unusual avenue for community action to prevent exposure to munitions toxins. The Sierra Army Depot site profile later in this report provides more information on the successful struggle of the Pyramid Lake Paiute Tribe and others downwind of Sierra to use the Clean Air Act to protect their health.

The Clean Water Act (CWA) may also apply to military munitions, but problems with the law’s waiver of federal sovereign immunity limit its ability to fully address munitions contamination. Under the CWA, the DoD must generally apply for and receive a permit to discharge munitions into waters. Unfortunately, an incomplete waiver prevents EPA from fining the military or issuing binding orders to enforce compliance with the law.

Over the past decade, affected communities, states, and tribes have sought out available tools to protect their health and environment. Pressure on the DoD to clean up toxic contamination and prevent ongoing pollution has increased at the local, regional, and national levels. The application of the SDWA, CAA, CWA, and other statutes to military munitions and firing ranges – despite EPA headquarters’ surrender to the Pentagon on the Munitions Rule – reflects the reality that people being poisoned will always find means to protect themselves.

The DoD’s response to these challenges has usually been to seek statutory exemptions that forestall any independent oversight of its activities. In May 2002, the DoD presented to Congress a package requesting blanket nationwide exemptions for all military munitions, training ranges and activities, and related operations from critical provisions of the Clean Air Act, RCRA, CERCLA, the Endangered Species Act, the Marine Mammal Protection Act, and the Migratory Bird Treaty Act. Despite the agency’s repeated promises to work with states, tribes, and affected communities, the exemption proposals were developed without any consultation with those groups. DoD’s proposals were presented to the House Armed Services Committee less than a week before markup of the 2003 Defense Authorization Act, to which the Pentagon wanted its proposals attached. At the time of this writing, Congress is still considering DoD’s proposals.

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While defending our country, the Department of Defense has consistently poisoned communities through its production, testing, use, and disposal of munitions. Military firing ranges – as centers for the constant use of munitions – are often extremely contaminated and pose grave threats to public health and the environment. Residents of communities all over the world suffer chronic and acute health effects caused by the constituents of military munitions, and are endangered by unexploded ordnance. DoD has resisted efforts to investigate and remedy munitions contamination, and has sought special status above the law.

Community organizations that publicly question the impacts of military munitions and firing ranges, and challenge the DoD to protect their communities from its own practices, are often branded unpatriotic fanatics or even accused of intentionally undermining national security. The Department of Defense is under the mistaken impression that anyone who challenges its indiscriminate use and disposal of munitions is unpatriotic or treasonous. On the contrary, because we believe that the democratic process is what makes the United States strong and that our military exists to defend us from harm, even at its own hands, we have a duty to express our beliefs and question decisions that will affect our lives and the lives of our descendents.

How unpatriotic is it to want to protect the health of your community? How fanatical is it to want clean water to drink and uncontaminated food to eat? Does it make sense to poison communities in order to defend them?

The importance of holding our military responsible for its actions is apparent in light of the chronic disease and death associated with chemical contamination from munitions and the acute safety danger posed by unexploded ordnance.

Federal and state laws can only protect communities when those affected by military contamination and pollution are involved in the decision-making process and have unrestricted access to information about existing contamination, ongoing pollution, and cleanup options. Affected communities, tribes, and states must be full partners, not bit players, in the oversight of military munitions and firing ranges.

As should be clear by now, inadequate waivers of sovereign immunity, failures of policy and will by EPA headquarters, and cultural deference to the military have combined to allow expended or discarded military munitions and their byproducts to contaminate air, soil, water, and subsistence food supplies and damage human health. Despite a variety of statements by Congress that federal agencies and facilities should be treated the same as everyone else, communities poisoned by munitions contamination and endangered by UXO still receive less protection than communities affected by private facilities.

Human health, the environment, cultural and historic sites, and subsistence food supplies have already been harmed by munitions contamination. Military munitions and firing ranges and the poisons they release often remain largely unregulated until a catastrophe – such as contamination of the sole drinking water supply for half a million people – has already occurred. Many states and some EPA regions have taken the lead in addressing the problem, but often without adequate support from Washington. Action is desperately needed to protect communities, ensure cleanups protective of human health and the environment, and prevent additional contamination. Communities, tribes, and states will continue to seek out the means to protect themselves and organize to demand military accountability to our laws.

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Contact: Laura Olah, Citizens for Safe Water Around Badger (CSWAB), (608) 643-3124 or info@cswab.org

Badger Army Ammunition Plant (BAAP) was constructed in 1942 in Sauk County, Wisconsin, near the city of Baraboo. The plant was operated intermittently over a 33-year period to produce single- and double-base propellant for cannon, rocket and small arms ammunition. Plant operation was terminated in March 1975 and all production facilities and many support functions were placed on standby status. In November 1997, the Army announced there is no longer a national strategic need for Badger and the facility was closed.

Through previous studies at BAAP, it was discovered that during plant operation, various types of chemicals were processed and were disposed through open ditches, landfills, ponds, or through open burning. These materials, which include dinitrotoluenes (DNT), organic solvents, and acids, have percolated into the sand and gravel aquifer that lies directly beneath BAAP. In an effort to curb the migration of these contaminants, an interim groundwater extraction, treatment and discharge system was constructed. Construction began in October 1989 and operations began in May 1990.

Various investigations at BAAP have identified contamination of groundwater, sediments, and surface soils at the facility. Groundwater is the sole supply of drinking water for residents within a 4-mile radius of BAAP. Community water supply wells within the 4-mile radius of the facility serve the towns of Prairie du Sac (pop. 2,640) and Sauk City (pop. 2,700). A plume of carbon tetrachloride and trichloroethene-contaminated groundwater extends to the south of the Propellant Burning Ground Area. Although an Interim Remedial Measure (IRM) has been implemented to treat dinitrotoluene (DNT) and volatile organic contaminants in groundwater in the vicinity of the Propellant Burning Ground, a plume of trichloroethene and carbon tetrachloride contaminated groundwater extends downgradient of the capture zone of the system. Residential wells located in the glacial till aquifer were contamianted with carbon tetrachloride above the maximum contaminant level (MCL), and replacement wells in the bedrock aquifer have been installed.

Additional contaminants identified in the groundwater in the vicinity of the Propellant Burning Ground include trichoroethene, chloroform, 2,4-DNT, 2,6-DNT, and nitrates. Groundwater in the vicinity of the Deterrent Burning Ground and Existing Landfill is contaminated with chloroform, trichloroethene, 1,1,1-trichloroethane, 2,4-DNT, 2,6-DNT, cadmium chromium lead, sulfates, and nitrates. The groundwater in the Oleum Plant and v Pond Area contains elevated sulfate concentrations. Contaminants associated with the Rocket Paste Area groundwater include nitrates, sulfates, lead, cadmium, 1,1,1-trichloroethane, trichloroethene, tetrachloroethene, and 2,4-DNT. Nitrate and sulfate concentrations are elevated in samples collected from monitoring wells in the vicinity of the Nitroglycerine Pond Area, the Old Acid Area, and New Acid Area. Cadmium was detected at concentrations above background levels in the Old Acid Area. Benzene is a contaminant of groundwater in the Old Fuel Tank Area.

Inorganic contaminants identified in sediments associated with drainage-ways and ponds at the facility include aluminum, lead, mercury, and sulfate. Organic contaminants in on-site sediments include nitroglycerine, 2,4-DNT, and diethyl phthalate. Off-site sediments in Gruber's Grove Bay contained nitrocellulose, diethylphthalate, di-n-butyl phthalate, and lead. Adjacent to and downgradient of the facility are Lake Wisconsin and the Wisconsin River. Extensive recreational uses include swimming, boating, and fishing. Sensitive areas identified include the bluffs adjacent to the eastern shore of the Wisconsin River near Prairie du Sac and Sauk City, which serve as wintering grounds for the American bald eagle (Haliaeetus leucocephalus), which is a federally listed threatened species in Wisconsin.

Soil contamination in the Propellant Burning Ground with carbon tetrachloride, trichloroethylene, 2,4-DNT, 2,6-DNT, n-nitrosodiphenylamine, phthalates, arsenic, copper, lead, and mercury has been identified. Soils in the vicinity of the Deterrent Burning Ground contain the same contaminants with the exception of arsenic and mercury. Elevated concentrations of nitrate and sulfate are present in Oleum Plant and Old Acid Area soils.

The RI/FS process has been completed. The RCRA permit modification of January 6, 1996 has been approved and finalized, but significant portions are being challenged by the Army.

The active years at Wisconsin's Badger Army Ammunition Plant have exacted a toll on the environment. In recent years, the U.S. Army has spent tens of millions of dollars on environmental studies documenting soil and groundwater contamination at dozens of sites at BAAP, however, virtually no resources have been devoted to identifying occupational exposures to former workers and the potential health effects these people may suffer. According to the Wisconsin Division of Health, very little information is available regarding potential occupational exposures at the plant. Occupational exposures were never monitored and consequently, no records exist.

In 1990, in response to community concerns about these exposures, the Wisconsin Division of Health conducted a health survey. The study confirmed that communities near the Badger plant have a significantly higher incidence of cancer deaths; the incidence of non-Hodgkins lymphoma and kidney/ureter cancer deaths are 50% higher than the balance of the state.

On the west side of the plant is a series of "Contaminated Waste Area Pits". It has been estimated that as much as 500 gallons per week of 2,6-DNT (a component of explosives), benzene, diphenylamine, and chlorinated solvents were dumped in these pits from 1966-1970. These contaminants have, over the years, moved through the soil column and reached groundwater more than 100 feet below the surface. The U.S. Army has proposed excavation and incineration of contaminated soils as a possible remediation technology. This proposal, however, places nearby rural residents - including residents of the Bluffview Retirement Community - at unnecessary and excessive risk. The Army's own reports describe the potential impacts to public health and the environment: "Air quality impacts from incinerators can pose a potential risk to the community during remedial action if highly concentrated wastes are burned. Potential adverse effects as a result of implementing incineration include (1) releases of low levels of products of incomplete combustion during process upsets, and (2) releases or particulate matter containing heavy metals." Moreover, burning of chlorinated solvents is known to produce dioxins, one of the most toxic substances known to mankind.

Citizens for Safe Water Around Badger (CSWAB) was organized in 1990 when the community learned private drinking water wells near the Badger Army Ammunition Plant were polluted with high levels of cancer-causing chemicals. Although the Army documented extensive soil and groundwater contamination, this information never reached nearby residents and as a result three families living near the plant drank poisoned water for over 15 years. Levels of carbon tetrachloride were found in drinking water at 80 parts per billion; the safe standard is only 5. The founders, Alison Jones Pena and Laura Olah, believed community involvement could have prevented this tragedy and consequently organized CSWAB both to empower and to protect nearby residents and plant workers from further harm.

Of the 40 contaminated military sites in Wisconsin, the Defense Environmental Restoration Account has cited Badger as the most contaminated; 32 areas within the plant are polluted with solvents, toxic metals and explosive wastes. Environmental cleanup efforts, however, remain at a virtual standstill - held hostage to a politicized process, regulatory apathy and a lack of federal funds. Environmental cleanup costs have been estimated as high as $250 million - the legacy of production that spanned three wars and over fifty years.

The land for the Badger Ordnance Works was procured by the government on March 1, 1942 and construction was started mid-year in 1942. The powder plant displaced about 60 farmers. Many of the farms had been in the families for several generations; the neighborhood was closely knit and many families were related. This upheaval shattered the lives of virtually everyone living at that time in eastern Sumpter.

Active production of smokeless powder commenced at Badger Army Ammunition Plant in January 1943, and continued until September 1945, when the plant was placed on standby status. During this time, Badger employed about 7,500 people and manufactured 271 million pounds of single- and double-base propellant. The facility was reactivated during the Korean conflict during which approximately 286 million pounds of propellants were manufactured. Badger was reactivated in late 1965 and produced about 890 million pounds of propellants; the base returned to inactive status in 1975 and remains on standby to this day.

During active production years, facilities like Badger's Old Acid Area were used for production of nitric acid from ammonia. During this process, poisonous nitrogen oxides were released from rooftop vents. These gases had a red color and were irritating, and during temperature inversions, the Old Acid Area was enveloped in a brown haze. Open burning of waste propellants dispersed metal-contaminated ash to the environment.

Contamination occurred in areas such as the Propellant Burning Grounds, located on the west side of the plant near Highway 12. It has been estimated that as much as 500 gallons per week of 2,5-dinitrotoluene, benzene, diphenylamine, and other cancer-causing chemicals used in the manufacture of propellants were dumped in a series of waste pits at the Propellant Burning Grounds from 1966-1970. Over the years, these chemicals soaked into and affected the soils deep underground. Groundwater is rainwater and melted snow that has seeped into the soils and collected underground. We now know the waste pits are the principle source of a three-mile long plume of contaminated groundwater that has moved offsite and has reached the Wisconsin River, polluting private drinking water wells in its path.

Both carbon tetrachloride and chloroform, the chemicals discovered in nearby private wells in May 1990, can cause cancer and other illnesses in humans, depending on the amount and duration of the exposure. Liver tumors are most likely, but tumors also could form in lungs and kidneys, state health officials say.

In June 1990, nearby residents organized a meeting at the Sauk Prairie Community Center and CSWAB was formed. Within a month, the group called for a meeting with Army officials and successfully lobbied for off-site testing of 17 private wells near the Northeast corner of the plant, another area threatened by groundwater pollution. Months later, CSWAB uncovered a deliberate effort by Olin Corporation, the operating contractor at the plant, to edit test results from private drinking water wells resulting in the deletion of all data that exceeded health standards. The EPA now requires Badger to report all test results directly to homeowners.

In August of 1990, the Army announced that MetaTRACE, the company responsible for a facility-wide environmental study at Badger, had plead guilty to fraud. Another $6 million study was initiated to re-do much of this work. This same year, the Army began drilling two replacement private wells. CSWAB successfully lobbied Congress for DoD cleanup funds for Badger. Only one other site was selected for such funds.

In January 1991, Congressman Klug and Senator Kasten lobbied for the controversial $425 million Superconducting Magnetic Energy Storage (SMES) test model to be built at Badger. The technology was originally developed to store the tremendous amounts of energy needed to power directed energy weapons for use in ballistic missile defense or for use as an anti-satellite weapon. CSWAB, supported by previous efforts to block the proposal, successfully organized local residents in opposition to the experimental project. The electromagnetic effects of SMES - known to affect reproduction, cause embryotic changes, and cause leukemia and related cancers - were projected to extend 3,300 feet into the air. The project was not funded and consequently never built. This same year, Badger applied to the Wisconsin Department of Natural Resources for a permit to open burn up to 2,500 pounds per day of waste propellants. CSWAB organized a campaign to block the permit, including full page ads in the Shopper Stopper which were donated by the publication's owners Bart and Char Olson, and led to the Army's November 30, 1993 announcement that they would "discontinue the open burning and drop the application process." If the permit had been awarded, the facility could have released as much as 13,688 pounds per year of lead, making Badger the second highest emitter of lead in the State of Wisconsin.

In 1994, CSWAB successful petitioned the Department of Defense to establish a citizen advisory board - only one of five suc