Nearly 300 people – including representatives of 72 civic, environmental, veterans and health organizations from around the nation – have issued a joint statement <https://cswab.org/wp-content/uploads/2021/01/Public-comment-to-EPA-TDEC-opposing-open-burning-of-PFAS-by-U.S.-Army-FINAL-SIGNED-16-Jan-2021.pdf
> calling on state and federal regulators to prohibit open air burning of PFAS and other toxic chemicals at the Holston Army Ammunition Plant in Tennessee. The burning, which has been going on for decades, produces toxic smoke that often envelops neighboring homes in the city of Kingsport.
The letter follows a recent announcement <https://cswab.org/wp-content/uploads/2020/12/Holston-Clean-Air-Act-Title-V-Modifications-and-Public-Notice-Dec-2020.pdf
> that U.S. EPA Region 4 and the Tennessee Department of Environment and Conservation intend to re-issue a Title V (Clean Air Act) permit that will allow the Army to annually open burn as much as 1,250,000 pounds of munitions wastes that may contain as much as 15% PFAS by weight.
“PFAS are not destroyed in an open fire and are therefore widely dispersed to the air and the surrounding environment where they accumulate in people, as well as fish, wildlife and food crops. At higher temperatures, poisonous hydrogen fluoride gas may be generated,” the commenters emphasized. “Hydrogen fluoride is a listed hazardous air pollutant subject to regulation by U.S. EPA and authorized states under the Clean Air Act, as are other air emissions from open burning at Holston.”
Exposure to PFAS has been shown to affect growth and development, reproduction, thyroid function, the immune system, injure the liver and increase risk for certain cancers.
For this reason, military sites like the Blue Grass Army Depot <https://cswab.org/wp-content/uploads/2020/12/Bluegrass-Army-Depot-OBOD-Final-Permit-PFAS-prohibition-Nov-2018.pdf
> in Kentucky are expressly prohibited from burning PFAS and dozens of other toxic wastes including pesticides, dioxins, PCBs, white and red phosphorus, and depleted uranium. Both the Blue Grass and Holston Army bases are located in EPA Region 4.
“We are adamant that Tennessee residents, workers and environment are afforded the same level of protection as their Kentucky neighbors,” the joint statement concludes.
The national effort was coordinated by Citizens for Safe Water Around Badger <https://cswab.org/action-alert-u-s-military-is-open-burning-pfas/
> – a grassroots organization that has been monitoring military cleanups for 30 years – in collaboration with Volunteers for Environmental Health and Justice <https://www.facebook.com/Volunteers-for-Environmental-Health-and-Justice-210370109297120/
> in Tennessee.
The U.S. Army at Holston Army Ammunition Plant has announced that it will be hosting an online (virtual) public meeting on Thursday, January 28, 2021 starting at 4:30 PM CST. For more information, visit Holston’s facebook page.
* * *
The organizations emphasize that the submitted joint public comments are not to be construed as supporting ANY open burning at Holston – the public notice specifies that regulators are only accepting comment on proposed conditions and permit modifications and our comments are submitted in this specific context.
References for this action include 35 reports and scientific studies posted here <https://cswab.org/action-alert-u-s-military-is-open-burning-pfas/