{"id":2258,"date":"2025-10-06T13:41:41","date_gmt":"2025-10-06T17:41:41","guid":{"rendered":"https:\/\/pilr.richmond.edu\/?p=2258"},"modified":"2025-10-20T13:44:55","modified_gmt":"2025-10-20T17:44:55","slug":"the-radford-army-arsenal-environmental-regulations-and-the-community-health-impacts-of-virginias-largest-polluter","status":"publish","type":"post","link":"https:\/\/blog.richmond.edu\/pilr\/2025\/10\/06\/the-radford-army-arsenal-environmental-regulations-and-the-community-health-impacts-of-virginias-largest-polluter\/","title":{"rendered":"The Radford Army Arsenal, Environmental Regulations, and the Community Health Impacts of Virginia\u2019s Largest Polluter"},"content":{"rendered":"

\"\"<\/p>\n

Written by Anna East, L\u201927<\/strong><\/p>\n

Sitting on the edge of the New River lies the Radford Army Ammunition Plant, a sprawling compound that is the only active domestic military propellant manufacturer for the US government.[1]<\/sup><\/span> The plant is also the largest polluter in Virginia, and many local residents worry the safety measures employed by Virginia Department of Environmental Quality (VDEQ) are insufficient to protect the health of the community.\u00a0<\/span><\/p>\n

The Radford Army Ammunition Plant (“RAAP”) was the largest source of toxic chemicals released into the environment in Virginia in 2023.[2]<\/sup><\/span> That year, RAAP released more than five times the amount of toxic inventory chemicals than the facility with the second highest documented releases.[3]<\/sup><\/span> In 2020, RAAP’s emissions of chemicals included 842 pounds of lead compounds, 1,343 pounds of nitric acid, and 62,792 pounds of nitroglycerin.[4]<\/sup><\/span> Part of these releases originated from RAAP’s Hazardous Waste Management Unit (HWMU) 13, an open burning ground used to dispose of waste explosives that are deemed too dangerous to dispose of in any alternative manner.[5]<\/sup><\/span><\/p>\n

These releases were permitted by Virginia Department of Environmental Quality (VDEQ), a state agency which works in partnership with the Environmental Protection Agency (EPA) to administer state and federal environmental laws and regulations for air quality, water quality, water supply, and land protection.[6]<\/sup><\/span>\u00a0 VDEQ issues permits to RAAP to ensure their emissions, including emissions from their open burn area, comply with the federal Clean Air Act, Resource Conservation and Recovery Act (RCRA), and Clean Water Act (CWA).[7]<\/sup><\/span> Additionally, VDEQ oversees permitting for the state Virginia Pollutant Discharge Elimination System program which regulates traceable discharges of chemicals in surface waters.[8]<\/sup><\/span><\/p>\n

RAAP is located approximately 5 miles northeast of Radford, Virginia, straddling the line between Montgomery and Pulaski Counties.[9]<\/sup><\/span> The New River runs directly through the compound.[10]<\/sup><\/span> RAAP is within a two mile radius of two elementary schools, and within a ten mile radius of Radford University and Virginia Tech.[11]<\/sup><\/span> At Belview Elementary, located two miles from RAAP, the risk of exposure to emissions linked to cancer is five times higher than the EPA’s recommended limit, according to a 2022 report from VPM, a public media news agency.[12]<\/sup><\/span><\/p>\n

Legal Status of Open Burn Pits and EPA’s Proposed New Rulemaking\u00a0<\/b><\/p>\n

RAAP’s open burn pit is regulated under the RCRA.[13]<\/sup><\/span> Specifically, RAAP is considered a Miscellaneous Unit and is regulated by 40 CFR \u00a7264(X) which provides in part that facilities “must be located, designed, constructed, operated, maintained, and closed in a manner that will ensure protection of human health and the environment.”[14]<\/sup><\/span>\u00a0<\/span><\/p>\n

The EPA banned the practice of open burn pits for hazardous waste in 1980.[15]<\/sup><\/span> However, due to military pushback, the EPA made an exception for Open Burn\/Open Destruction of military munitions that could not be disposed of safely in any other way.[16]<\/sup><\/span> This variance was intended to be a stopgap until the technology for disposing of munitions advanced to the point that a safer alternative became available.[17]<\/sup><\/span> Those safer technologies now exist.[18]<\/sup><\/span> The Netherlands, Sweden, Canada, and Germany have all severely limited or banned open burning and detonation, yet still are able to dispose of their excess military munitions safely.[19]<\/sup><\/span><\/p>\n

It appears that the United States may be slowly implementing similar guidelines. The EPA is currently proposing a new rule regarding implementation of new technology alternatives to open burning for waste explosives.[20]<\/sup><\/span> Two separate reports published in 2019 by the EPA and the National Academies of Sciences, Engineering, and Medicine determined that safe alternatives are available for managing many waste explosives.[21]<\/sup><\/span> In the interim, the EPA issued a memo with guidance for current open burn\/open detonation facilities which emphasized the importance of facilities adhering to current open burn\/open detonation guidelines, as well as the importance of community involvement in permitting on a site-specific basis.[22]<\/sup><\/span><\/p>\n

RAAP Violations<\/b><\/p>\n

Some community members in the Radford area contend that RAAP is falling short of its statutory obligations. According to the EPA Facility report, as of February 2024 RAAP was categorized as being in violation of RCRA and has been in violation for 5 of the past 12 quarters.[23]<\/sup><\/span> Additionally, as of March 2025, RAAP was categorized as “Significant\/Category 1” noncompliance with the CWA, with violations in the past 9 out of 12 quarters.[24]<\/sup><\/span> A ProPublica report from 2017 found that the EPA determined RAAP violated their hazardous waste permits 50 times since 1980.[25]<\/sup><\/span> These violations included mishandling or mischaracterizing explosive waste, violating standards for incinerators and improperly monitoring groundwater.[26]<\/sup><\/span>\u00a0<\/span><\/p>\n

The PACT Act and Burn Pits Health Impacts on Veterans\u00a0<\/b><\/p>\n

Adding to community concerns is the news surrounding military burn pits used overseas which contributed to veterans developing cancer and other chronic diseases.[27]<\/sup><\/span> In 2022, Congress passed the Sergeant First Class (SFC) Heath Robinson Honoring our Promise to Address Comprehensive Toxics (PACT Act) which expanded Veteran\u2019s Administration health benefits to veterans exposed to military burn pits in locations overseas.[28]<\/sup><\/span>\u00a0<\/span><\/p>\n

However, the open burning conducted at RAAP is supposed to be safer from the burn pits military veterans were exposed to overseas. In 1987, the EPA concluded open burning of non-explosive materials could not be conducted in a manner that protected human health and the environment.[29]<\/sup><\/span> Military burn pits overseas included an array of materials such as plastics, rubber, chemical mixtures and medical waste.[30]<\/sup><\/span> In contrast, the quantity, make up of materials, and timing of the burns in the open burn pit at RAAP are limited by their permits issued by VDEQ.[31]<\/sup><\/span> Those limits are based on the Multi-Pathway Risk Assessment conducted before the permit was issued, a study which is intended to ensure the open burning posed no unacceptable risks to human health and the environment.[32]<\/sup><\/span> Theoretically, the permitting process means the open burn pit at RAAP is safer than those at military sites overseas because military sites were largely unregulated until 2009, and what regulations did exist were often ignored.[33]<\/sup><\/span> Nevertheless, both military open burn pits and domestic open burn pits are widely recognized as posing health risks to the surrounding environment and communities, despite the protective measures currently in place.[34]<\/sup><\/span><\/p>\n

Community Concerns<\/b><\/p>\n

The EPA acknowledges that open burn pits have the potential to severely impact the health of the surrounding communities.[35]<\/sup><\/span> In the 2019 interim memo mentioned above, the EPA notes that community groups expressed concern regarding the exposure to contaminants through inhalation from plumes of smoke that may drift from open burn areas.[36]<\/sup><\/span> The EPA also acknowledged the community group concerns that many open burn areas are located in communities that are of environmental justice concern and are more vulnerable to the detrimental effects of toxic exposure from open burn areas due to the cumulative effects of additional pollution burdens.[37]<\/sup><\/span> The military maintains that the EPA standards ensure open burn pits are operating in a manner that is safe for the environment and human health.[38]<\/sup><\/span>\u00a0However, a ProPublica report alleges that the systems the EPA uses to set standards for pollutants are “little more than educated guesses.”[39]<\/sup><\/span> ProPublica states that the models are too speculative to rely on when considering the effects of open burn operations on human health.[40]<\/sup><\/span><\/p>\n

Specifically with respect to RAAP, Radford community members allege that they are suffering from an increased incidence of cancer, thyroid disease, and pulmonary fibrosis due to RAAP’s emissions.[41]<\/sup><\/span> The community members are concerned that the risk assessments performed by VDEQ do not adequately reflect the real risks associated with living near RAAP.<\/span>[42] <\/sup>Therefore, some community groups including Citizens for Arsenal Accountability and EarthJustice are calling on the Virginia Legislature to set aside funding for an impartial third party cumulative hazard assessment and community health assessment.[43]<\/sup><\/span><\/p>\n

Conclusion\u00a0<\/b><\/p>\n

The continued existence of the RAAP’s practice of open burning brings into question whether environmental legislation in the United States should create more of an emphasis on continued community health testing near areas of hazardous waste disposal. Although RAAP continues to operate with permits issued by VDEQ, the fact that violations of those guidelines occur with relative frequency means the surrounding community will continue to be concerned. And, considering there has not been a comprehensive community health study regarding the effects of RAAP’s pollutants, the question as to whether the regulations RAAP is operating under are doing enough to protect the surrounding public remains. This is despite the fact that RAAP is making significant progress to move away from the practice of open burning.[44]<\/sup><\/span> A new Energetic Waste Incinerator\/Contaminated Waste Processor Complex is set to be completed in June 2026, which is projected to reduce the amount of open burning by 95%.[45]<\/sup><\/span> However, the community\u2019s concerns will not end with the cessation of open burning; if RAAP’s emissions caused the chronic illnesses that many community members are suffering from, the legacy of the prolonged open burn area and RAAP emissions overall will persist for years to come.<\/span><\/p>\n

 <\/p>\n

\u2014<\/p>\n

Photo: BAE Systems Photo, View from the air of the Radford Army Ammunition Plant and the New River <\/span>in <\/span><\/i>Virginia Tech, <\/span>The History, Radford Army Ammunition Plant History<\/span><\/i>, <\/span>ACR Fralin Life Science (<\/span>last visited Oct. 3, 2025) https:\/\/acr.fralinlifesci.vt.edu\/2018-RAAP\/RAAP-History.html.<\/span><\/p>\n

[1] <\/sup>C. Frances, <\/span>Taking on the Biggest Weapons Manufacturing Plant in the US<\/span><\/i>, <\/span>New Internationalist <\/span>(July 16, 2024), https:\/\/newint.org\/campaigns\/2024\/taking-biggest-weapons-manufacturing-plant-us.<\/span><\/p>\n

[2] <\/sup>Env’t Prot. Agency, <\/span>2023 TRI Factsheet: State \u2013 Virginia<\/span><\/i>, <\/span>Toxics Release Inventory Program,\u00a0 <\/span>https:\/\/enviro.epa.gov\/triexplorer\/tri_factsheet.factsheet_forstate?pYear=2023&pstate=VA&pParent=NAT ( visited September 29, 2025). <\/span><\/p>\n

[3] <\/sup><\/span>See id.<\/span><\/i><\/p>\n

[4] <\/sup>Hilary Fung, Abrahm Lustgarten & Lena Groeger, <\/span>Toxic Fires: Across the Country, Military Sites Burn Hazardous Waste Into Open Air<\/span><\/i>, <\/span>ProPublica <\/span>(July 20, 2017), https:\/\/projects.propublica.org\/graphics\/burn-sites. <\/span><\/p>\n

[5] <\/sup><\/span>Radford Army Ammunition Plant<\/span><\/i>, <\/span>Va Dep’t Env’t Quality<\/span>, https:\/\/www.deq.virginia.gov\/news-info\/shortcuts\/topics-of-interest\/radford-army-ammunition-plant (last visited September 29, 2025).<\/span><\/p>\n

[6]<\/sup><\/span>About Us<\/span><\/i>,<\/span> V<\/span>a<\/span> D<\/span>ep’t Env’t Quality,<\/span> https:\/\/www.deq.virginia.gov\/news-info\/about-us (last visited Sept. 29, 2025).<\/span><\/p>\n

[7] <\/sup><\/span>Supra <\/span><\/i>Note 4.<\/span><\/p>\n

[8] <\/sup><\/span>Id. <\/span><\/i><\/p>\n

[9] <\/sup><\/span>See Long-Term Stewardship Assessment Report Radford Army Ammunition Plant<\/span><\/i>, <\/span>Env’t Prot. Agency, <\/span>1 (2019), www.epa.gov\/sites\/default\/files\/2020-02\/documents\/radford_army_ammo_lts_report_oct_2019.pdf<\/span><\/p>\n

[10] <\/sup><\/span>Radford Army Ammunition Plant<\/span><\/i>, <\/span>Virginia Places (<\/span>last visited Oct. 3, 2025) http:\/\/www.virginiaplaces.org\/military\/radford.html.<\/span><\/p>\n

[11] <\/sup>Meg Schiffres, <\/span>Residents link cancer-causing emissions to health problems in Radford<\/span><\/i>, <\/span>VPM (<\/span>Feb. 14, 2022, 8:00 PM), https:\/\/www.vpm.org\/news\/2022-02-14\/residents-link-cancer-causing-emissions-to-health-problems-in-radford.<\/span><\/p>\n

[12] <\/sup><\/span>Id.<\/span><\/i><\/p>\n

[13]<\/sup><\/span>Supra <\/span><\/i>Note 4; 40 C.F.R. \u00a7264(X) (2025).<\/span><\/p>\n

[14]\u00a0 <\/sup>40 C.F.R. \u00a7264(X) (2025).<\/span><\/p>\n

[15] <\/sup><\/span>Open Burning and Open Detonation (OB\/OD) of Waste Explosives Under the Resource Conservation and Recovery Act (RCRA)<\/span><\/i>, <\/span>Env’t Prot. Agency, <\/span>1 (2022) https:\/\/rcrapublic.epa.gov\/rcraonline\/details.xhtml?rcra=14946.<\/span><\/p>\n

[16]\u00a0 <\/sup>Revisions to Standards for the Open Burning\/Open Detonation of Waste Explosives, 40 CFR \u00a7\u00a7 124, 260, 264, 265, 270, 271 (proposed Mar. 20, 2024).<\/span><\/p>\n

[17]\u00a0 <\/sup><\/span>Id. <\/span><\/i><\/p>\n

[18]<\/sup><\/span>See supra <\/span><\/i>Note 13.<\/span><\/p>\n

[19]\u00a0 <\/sup>Abrahm Lustgarten, <\/span>Open Burns, Ill Winds<\/span><\/i>, <\/span>ProPublica <\/span>(July 20, 2017), https:\/\/www.propublica.org\/article\/military-pollution-open-burns-radford-virginia.<\/span><\/p>\n

[20]\u00a0 <\/sup><\/span>Explosive Hazardous Wastes<\/span><\/i>, <\/span>Env’t Prot. Agency, <\/span>(Feb. 26, 2025),<\/span> https:\/\/www.epa.gov\/hwpermitting\/explosive-hazardous-wastes.<\/span><\/p>\n

[21] <\/sup><\/span>Id<\/span><\/i>. <\/span><\/p>\n

[22] <\/sup><\/span>Supra <\/span><\/i>Note 13.<\/span><\/p>\n

[23] <\/sup>Env’t Prot. Agency, <\/span>Detailed Facility Report<\/span><\/i>, <\/span>Enf’t & Compliance Hist. <\/span>https:\/\/echo.epa.gov\/detailed-facility-report?fid=110000601867 (last visited Sept. 29, 2025).<\/span><\/p>\n

[24] <\/sup><\/span>Id. <\/span><\/i><\/p>\n

[25] <\/sup><\/span>Supra <\/span><\/i>Note 3.<\/span><\/p>\n

[26]<\/sup>\u00a0<\/span>Id.<\/span><\/i><\/p>\n

[27] <\/sup><\/span>See, e.g., <\/span><\/i>U.S. Dep’t of Veteran’s Aff. <\/span>Exposure to Burn Pits and Other Specific Environmental Hazards<\/span><\/i>, <\/span>Disability Benefits <\/span>(Apr. 9, 2025), https:\/\/www.va.gov\/disability\/eligibility\/hazardous-materials-exposure\/specific-environmental-hazards\/#what-burn-pit-and-other-toxic-; Leo Shane III, <\/span>What are military burn pits? And why are veterans worried about them?<\/span><\/i>, <\/span>MilitaryTimes<\/span> (Mar. 29, 2022), https:\/\/www.militarytimes.com\/news\/burn-pits\/2022\/03\/29\/what-are-military-burn-pits-and-why-are-veterans-worried-about-them\/.<\/span><\/p>\n

[28] <\/sup>U.S. Dep’t of Veteran’s Aff. <\/span>Exposure to Burn Pits and Other Specific Environmental Hazards<\/span><\/i>, <\/span>Disability Benefits <\/span>(Apr. 9, 2025), https:\/\/www.va.gov\/disability\/eligibility\/hazardous-materials-exposure\/specific-environmental-hazards\/#what-burn-pit-and-other-toxic-.<\/span><\/p>\n

[29] <\/sup><\/span>Supra <\/span><\/i>Note 13.<\/span><\/p>\n

[30] <\/sup>Leo Shane III, <\/span>What are military burn pits? And why are veterans worried about them?<\/span><\/i>, <\/span>MilitaryTimes <\/span>(Mar. 29, 2022), https:\/\/www.militarytimes.com\/news\/burn-pits\/2022\/03\/29\/what-are-military-burn-pits-and-why-are-veterans-worried-about-them\/.<\/span><\/p>\n

[31] <\/sup>Va Dep\u2019t of Env\u2019t Quality, <\/span>Radford Army Ammunition Plant<\/span><\/i>, <\/span>Topics of Interest (<\/span>last visited Oct. 3, 2025) https:\/\/www.deq.virginia.gov\/news-info\/shortcuts\/topics-of-interest\/radford-army-ammunition-plant. <\/span><\/p>\n

[32] <\/sup><\/span>Id.<\/span><\/i><\/p>\n

[33] <\/sup><\/span>See <\/span><\/i>Xinyu Wang, Taylor A Doherty , Christine James <\/span>Military Burn Pit Exposure and Airway Disease: Implications for our Veteran Population <\/span><\/i>Annals of Allergy, Asthma & Immunology 1, 2 (2023) <\/span>https:\/\/pubmed.ncbi.nlm.nih.gov\/37343826\/ (US Department of Defense released regulations on burn pits in 2009); Julia Harte, <\/span>U.S. Troops Burned Waste in Hazardous Open Pits while Safer Incinerators Sat Idle<\/span><\/i>, <\/span>The Center For Public Integrity <\/span>(Feb. 12, 2015) https:\/\/publicintegrity.org\/national-security\/u-s-troops-burned-waste-in-hazardous-open-pits-while-safer-incinerators-sat-idle\/ (many regulations were ignored).<\/span><\/p>\n

[34] <\/sup><\/span>See, e.g., <\/span><\/i>Dan Ross, <\/span>Why the Military is Still Allowed to Use Open Burning and Detonation to Destroy Hazardous Waste Explosives in the U.S.<\/span><\/i>, <\/span>NewsWeek <\/span>(May 16, 2017, 7:00 AM) https:\/\/www.newsweek.com\/2017\/06\/16\/open-burning-military-toxic-hazardous-waste-explosives-detonation-environment-609619.html. <\/span><\/p>\n

[35] <\/sup><\/span>Supra <\/span><\/i>Note 14. <\/span><\/p>\n

[36] <\/sup><\/span>Supra<\/span><\/i> Note 13.<\/span><\/p>\n

[37]<\/sup>\u00a0<\/span>Id. <\/span><\/i><\/p>\n

[38]<\/sup><\/span>\u00a0Supra <\/span><\/i>Note 17.<\/span><\/p>\n

[39] <\/sup><\/span>Id.<\/span><\/i><\/p>\n

[40] <\/sup><\/span>Id.<\/span><\/i><\/p>\n

[41] <\/sup><\/span>See supra <\/span><\/i>Note 17; <\/span>Earthjustice\u2019s Community Partnerships Program & the Center for Progressive Reform, <\/span>An Explosive Problem: The Radford Arsenal\u2019s Toxic Operations<\/span><\/i> (2022), <\/span>https:\/\/earthjustice.org\/wp-content\/uploads\/open_burn_9-19-22.pdf.<\/span><\/p>\n

[42] <\/sup><\/span>See <\/span><\/i>Earthjustice\u2019s Community Partnerships Program & the Center for Progressive Reform, <\/span>An Explosive Problem: The Radford Arsenal\u2019s Toxic OperationsAn Explosive Problem: The Radford Arsenal’s Toxic Operations<\/span><\/i>, 4<\/span> (2022), <\/span>https:\/\/earthjustice.org\/wp-content\/uploads\/open_burn_9-19-22.pdf.<\/span><\/p>\n

[43] <\/sup><\/span>Id. <\/span><\/i>at 15. <\/span><\/p>\n

[44] <\/sup><\/span>RAAP Hightlights Environment Progress<\/span><\/i>, <\/span>NRVNews<\/span> (Sept. 24, 2025) https:\/\/nrvnews.com\/raap-hightlights-environment-progress\/.<\/span><\/p>\n

[45]<\/sup>\u00a0<\/span>Id. <\/span><\/i><\/p>\n

 <\/p>\n","protected":false},"excerpt":{"rendered":"

Written by Anna East, L\u201927 Sitting on the edge of the New River lies the Radford Army Ammunition Plant, a sprawling compound that is the only active domestic military propellant manufacturer for the US government.[1] The plant is also the largest polluter in Virginia, and many local residents worry the safety measures employed by Virginia Department of Environmental Quality (VDEQ) are insufficient to protect the … Continue reading The Radford Army Arsenal, Environmental Regulations, and the Community Health Impacts of Virginia\u2019s Largest Polluter<\/span><\/a><\/p>\n","protected":false},"author":6592,"featured_media":0,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[51366,67126],"tags":[],"class_list":["post-2258","post","type-post","status-publish","format-standard","hentry","category-blog-post","category-recent-posts"],"jetpack_featured_media_url":"","_links":{"self":[{"href":"https:\/\/blog.richmond.edu\/pilr\/wp-json\/wp\/v2\/posts\/2258","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/blog.richmond.edu\/pilr\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/blog.richmond.edu\/pilr\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/blog.richmond.edu\/pilr\/wp-json\/wp\/v2\/users\/6592"}],"replies":[{"embeddable":true,"href":"https:\/\/blog.richmond.edu\/pilr\/wp-json\/wp\/v2\/comments?post=2258"}],"version-history":[{"count":2,"href":"https:\/\/blog.richmond.edu\/pilr\/wp-json\/wp\/v2\/posts\/2258\/revisions"}],"predecessor-version":[{"id":2261,"href":"https:\/\/blog.richmond.edu\/pilr\/wp-json\/wp\/v2\/posts\/2258\/revisions\/2261"}],"wp:attachment":[{"href":"https:\/\/blog.richmond.edu\/pilr\/wp-json\/wp\/v2\/media?parent=2258"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/blog.richmond.edu\/pilr\/wp-json\/wp\/v2\/categories?post=2258"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/blog.richmond.edu\/pilr\/wp-json\/wp\/v2\/tags?post=2258"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}