UPHE Opposes Hazardous Waste Storage

A hazardous waste permit has been approved that would allow the continued open air burning of hazardous munitions wastes at the ATK Bacchus Facility – Naval Industrial Reserve Ordnance Plant (NIROP) in West Valley City. UPHE is in complete objection to this permit that would result in excessive risk to human and environmental health. Learn more here.

We submitted comments on the draft permit renewal for Hazardous Waste Storage and Treatment Permit ATK – Bacchus Facility – NIROP in West Valley City, Utah. Read those comments below:

On the Utah Department of Environmental Quality website, addressing the ATK Launch Systems Bacchus Hazardous Waste Facility, the following comment is made: 

“This assessment determined that all groundwater and human exposures to the contamination are currently under control.” 

UPHE beg to differ. As long as this facility is allowed to burn reactive hazardous waste, or any kind of waste, human exposure is not “under control,” nor does the term “under control” have any meaning regarding public health risk. The State of Utah and the EPA have an obligation to the residents of Salt Lake City to put an end to this badly outdated and dangerous practice. 

Burning waste is a source of some of the most toxic emissions (Hazardous Air Pollutants–HAPs) of modern industry. Burn pits in particular are an anachronistic, inappropriate, and completely unnecessary means of disposing of waste. The medical literature has greatly expanded in recent years and defies traditional toxicology assessments, revealing the broad based health consequences of even minimal exposure to the toxins emitted by incinerators, even more so, burn pits. 

Pentagon and non-government scientists are finally agreeing that these types of burn pits led to a wide variety of illnesses among US soldiers in Afghanistan and Iraq, so why would anything that resembles that practice be permitted in the greater Salt Lake Valley? A list of diseases that have been shown to be associated with exposure to burn pits emissions includes the following: central nervous system disorders, reduced liver or kidney function, stomach, respiratory, and skin cancer, skin lesions, leukemia, chronic bronchitis, cardiovascular conditions, constrictive bronchiolitis, autoimmune disorders, Crohn’s disease, infertility, migraines, throat infections, eczema, and multiple sclerosis. Fetal development in particular is jeopardized by minimal exposure to HAPs. 

Over 30 years ago Congress banned American industries and local governments from disposing of hazardous waste in these open burn pits after concluding the obvious–that they represented health and environmental hazards. But at the same time they gave the military an exemption that was supposed to be temporary, but has been left in place ever since. Twenty-five years ago the Senate passed a resolution that ordered the Defense Depart to stop the practice as soon as possible, but the practice continues. 

Pollution from any combustion is always a health hazard. Incineration of any material, but especially hazardous materials, always fails in what should be the goal of waste management, i.e. isolating hazardous materials from the public and the environment. In fact incineration is virtually guaranteed to increase the public’s health risk from the waste material in all cases, and that is especially true of material that is hazardous to begin with. Furthermore, this is not just an issue for West Valley City. Incinerator emissions have been proven to travel hundreds of miles. 

In the case of burning munitions waste, beyond the common, well recognized health hazards of particulate emissions, these burn pits emit additional toxins. 

In a typical year, burn pits like this can spew thousands of pounds of heavy metals and carcinogens legally into the atmosphere. At other pits like this, the burning has exceeded the permits and the military has misled the pubic about the chemicals that are burned. 

These open burn operations, whether they are operated by private contractors and/or the Department of Energy, have led to 54 separate federal Superfund declarations and have exposed the people who live near them to health hazards that will continue for multiple generations. 

Any defense of this practice cannot be based on anything that comes close to representing current science. The concept that small amounts of deadly compounds are safe has been thoroughly debunked by thousands of studies, including regarding chemicals and metals known to be in the emissions of these burn pits–heavy metals like lead, mercury, and cadmium, and chemicals like perchlorate, PFAS compounds, and nitroglycerine. 

If burn permits were always adhered to they would still be unacceptable health hazards. But ProPublica investigated the 51 active military run burn sites throughout the country and more than 145 others that had been previously operated. They found permits had been violated thousands of times over the past 37 years, with a variety of violations, such as improper storing and disposing of toxic material, and exceeding pollution thresholds. Many of these sites have had to be declared superfund sites. 

UPHE will not go into detail about the toxic profile of each of the chemicals and heavy metals typically found in emissions from these burn pits. It should be well known by regulators that there is no safe amount of exposure to the profoundly neurotoxic heavy metals, lead and mercury. Dioxins and PAHs (polycyclic aromatic hydrocarbons) are almost always components of virtually any type of waste combustion. They are some of the most well studied toxic chemicals known, showing harm to public health at barely detectable concentrations. 

But we will mention details about two chemical hazards, perchlorate and PFAS or C8 compounds, that may be less well known to regulators. The burned waste contains toxic perchlorate, which often contaminates nearby drinking water wells as well as airborne emissions. Perchlorates are endocrine disruptors that affect the normal growth and development of infants and children. Perchlorate inhibits the uptake of iodine into the thyroid, reducing the production of thyroid hormone. For the first 18-20 weeks after conception, fetal organ development, including of the brain, is almost completely dependent on thyroid from the mother. Even brief exposure to compounds like perchlorate that inhibit the production of maternal or fetal thyroid hormone during intrauterine life or infancy, can have lifelong consequences including impaired brain development, lowered IQ, impaired motor skills, and inhibited cognitive and language development. 

This risk is magnified given that one in five pregnant women are deficient in dietary iodine, enhancing the ability of perchlorate to reduce thyroid production. 

A supposedly safe threshold of 15 ppb in drinking water was set by the EPA in 2005, based on a National Academy of Sciences study, but was left unenforced. But like with so many toxins, the research has moved far beyond the assumptions behind those “safe” standards. Unfortunately, the EPA has not. There is strong evidence that many toddlers in this country consume enough perchlorate in their food and water that they exceed even that out-of- date threshold. 

The EPA under the Trump Administration announced in May 2020 that they intended to ignore both the science and a court order, and won’t regulate the amount of perchlorate in drinking water. That abandonment of responsibility to protect public health should play no role whatsoever in whether a Utah state agency issues a permit allowing continued emissions of perchlorate to be scattered over the Salt Lake Valley. The American Academy of Pediatrics lambasted the EPA for even considering not regulating perchlorate, writing: 

“Perchlorate causes goiters and damages the nervous system of fetuses and children. Research has identified a well-established causative association between perchlorate ingestion and thyroid hormone disruption…When fetuses are exposed during pregnancy, perchlorate endangers a child’s development. Children born with even mild, subclinical deficiencies in thyroid function may have lower IQs, higher chances of being diagnosed with attention-deficit/hyperactivity disorder (ADHD), and visuospatial difficulties.” 

Burn pit emissions also contain toxic chemicals known as PFAS (perfluoroalkyl substances) or C8 compounds. PFAS are widely used in military flares and pyrogen igniters for solid propellants for rocket motors. 

In the world of industrial chemistry, compounds that are composed of eight carbon atoms in a running chain are known as C8. PFAS compounds are extremely resistant to break down anywhere–in the environment or in the plant and animal kingdoms, including humans. Longer chained fluorinated alkyls also tend to degrade until they reach a derivative state of eight carbons atoms, and at that point there is essentially no further break down. This means that even if all C8 compounds were banned, there would still be increasing levels in the environment. 

These compounds are now found in newborn babies, breast milk, umbilical cord blood, every type of wildlife ever tested, from polar bears to Asian tigers. One of the main companies that marketed and sold C8 compounds had put a safety threshold for water for human consumption at 1 ppb. By 2003, tests showed that the blood of the average adult American had four to five times that amount. So we are all already exposed to more of these compounds than can be considered safe. 

Open burning does not destroy PFAS. Once released to the air from the burn pits, PFAS are carried miles away from the combustion site. Often referred to as “forever chemicals,” PFAS persist in the environment indefinitely. Research links PFAS to 55 different diseases and essentially these compounds do not break down in the body, even over decades. 

For the Division to allow these toxic chemicals and heavy metals in any amount to be showered over the Salt Lake Valley represents a serious health hazard and is simply indefensible. This is all the more true given that burning is completely unnecessary, and can be replaced by other, safer, waste management techniques such as burial. 

UPHE urges the Division to deny any permit that allows continued burning of hazardous waste at this facility.