Public Comments Needed to Ban Open Burning and Open Detonation of PFAS, Toxic and Carcinogenic Explosive Materials

See Tell EPA to BAN Open Burning of PFAS, Toxic Munitions! CEASE FIRE CAMPAIGN Action Alert at the end of the Update

Did you know the federal Departments of Defense and Energy, NASA and the private industry sector currently operate more than 60 open burn pits across the U.S. and its territories – causing the uncontrolled release of PFAS and other toxic chemicals to the environment?  Open detonation and open burning of these dangerous energetic hazardous wastes result in environmental contamination and places the health of soldiers, workers and neighbors at risk.

In New Mexico, opening burning and open detonation are permitted by the New Mexico Environment Department at Holloman Air Force Base, Los Alamos National Laboratory and Sandia National Laboratory.

For nearly 50 years, the Environmental Protection Agency (EPA) has exempted open burning and open detonation activities at federal and private sector sites from regulation.  A proposed EPA rule would allow these uncontrolled releases to continue.  Communities that live in the shadows of these sites say the proposed rule does not go far enough to protect public health and the environment and urge the complete ban.

Now is the time to raise your voice with the members of the national CEASE FIRE Campaign to require EPA to ban open burning and open detonation of these wastes and clean up the sites.  The CEASE FIRE Campaign seeks to protect human health and the environment by calling for the immediate implementation of safer alternatives to open air burning, detonation and incineration/combustion of military munitions.  The Campaign states, “A complete ban is the only way to provide fair and equitable treatment to communities by protecting ALL communities.”  https://cswab.org/cease-fire-campaign/about-the-campaign/#:~:text=The%20CEASE%20FIRE%20Campaign%20seeks%20to%20protect%20human,air%20burning%2C%20detonation%20and%20incineration%2Fcombustion%20of%20military%20munitions.

The Campaign emphasizes that only a ban will protect communities, incentivize the development of safer treatment technologies and secure federal funding for the deployment of alternative technologies.

Four New Mexico non-governmental organizations are involved in the Cease Fire Campaign.  They are:  Citizen Action New Mexico https://www.radfreenm.org/index.php , CCNS http://nuclearactive.org/ , Tewa Women United https://tewawomenunited.org/ , and the Tribal Environmental Watch Alliance.

Jane Williams, of the California Communities Against Toxics, said, “The taxpayers have spent hundreds of millions of dollars to cleanup contaminated soils and groundwater from past releases at burn pits across the country; we don’t need to add more pollution to that burden.  EPA needs to enact a ban on the open burning of these dangerous chemicals which pollute our air, water, and soils if we are to protect the environmental justice communities hosting these facilities.”

Public comments are due on or before Monday, May 20^th, 2024.  Even if you signed a petition in the past, we need EVERYONE to submit comments via the Federal Register today.   Numbers matter.  Share this Update with friends and family.  For talking points and instructions to submit comments, see below.

CEASE FIRE CAMPAIGN ACTION ALERT

Tell EPA to BAN Open Burning of PFAS, Toxic Munitions!

The Environmental Protection Agency (EPA) is requesting public comment on proposed regulations that will allow for the open burning and detonation (OB/OD) of waste explosives. In communities across America, open burning and detonation of energetic hazardous waste results in the uncontrolled release of toxic heavy metals, PFAS, energetic compounds, perchlorate, nitrogen oxides, dioxins and other carcinogens to the environment, placing the health of our soldiers, workers and neighbors at risk.

How and Where to Submit a Comment:

The DEADLINE for public comment is Monday May 20, 2024.

Comments can be submitted through the online form on the Federal Register website OR use this full link:  https://www.federalregister.gov/documents/2024/03/20/2024-05088/revisions-to-standards-for-the-open-burningopen-detonation-of-waste-explosives

Click on the green Submit A Formal Comment button on the right side of the page.

Instructions:  Include the Docket ID Number EPA–HQ–OLEM–2021–0397 in your comments.

Comments received may be posted without change to https://www.regulations.gov/​, including any personal information provided.

Alternative ways to submit comments: 

Mail to:  U.S. Environmental Protection Agency

EPA Docket Center, OLEM Docket, Mail Code 28221T

1200 Pennsylvania Avenue NW

Washington, DC 20460

Hand Delivery or Courier to:    EPA Docket Center

WJC West Building, Room 3334

1301 Constitution Avenue NW

Washington, DC 20004

The Docket Center’s hours of operations are 8:30 a.m.–4:30 p.m., Monday–Friday (except Federal Holidays).

Suggested CEASE FIRE CAMPAIGN Talking Points:

Only a BAN on OB/OD will:

• Prevent the uncontrolled release of PFAS and other toxic and carcinogenic emissions to the environment.
• Incentivize the development of newer safer treatment technologies.
• Readily secure federal funding for the deployment of alternative technologies.
• Encourage the development and transition to “green” munitions.
• Protect the integrity and sustainability of natural systems including soil, water, air and biodiversity.
• Prevent the uncontrolled release of emerging unregulated toxic chemicals like RDX and PFAS.
• Close de facto exemptions to the Clean Air Act, the Clean Water Act, and other environmental standards and laws.
• Only a BAN will provide fair and equitable treatment for all communities by protecting ALL communities.

p.s. Even if you signed a petition in the past, we still need EVERYONE to submit a comment via the federal register today!

Tips for How to Submit a Public Comment:

• Be respectful and polite in your comments.
• Get personal, share your experiences, and why you care. Personal messages carry more sentiment and weight which are more meaningful and can have a bigger impact on policymakers.
• Avoid pre-written copy-and-paste templates. New practices have passed that make it so pre-written templates only get counted once. Meaning if multiple people submit the same exact comment, it will only be recorded once. Make it personal and unique to make sure it is counted.
• Cite relevant data that supports your comment.

1. Friday, May 3^rd, 2024 from noon to 1 pm MT – Join the weekly peaceful protest for nuclear disarmament on the four corners of Alameda and Sandoval in downtown Santa Fe with Veterans for Peace, CCNS, Nuclear Watch NM, Loretto Community, Pax Christi, Nonviolent Santa Fe, New Mexico Peace Fests, and others. Join us!

2. Monday, May 13^th – Friday, May 17^th – Public Hearing before the New Mexico Water Quality Control Commission (WQCC) about the proposed New Mexico Environment Department’s Wastewater Reuse Rule at the NM Capitol. Case No. WQCC 23-84 (R).  NMED proposes to “solve” the oil and gas industry’s enormous waste problem by reusing toxic fracking waste, aka produced water, for “agriculture, irrigation, potable water supplies, aquifer recharge, industrial processes or environmental restoration.  https://www.env.nm.gov/events-calendar/?trumbaEmbed=view%3Devent%26eventid%3D172190191 – links to the public notices and links to participate virtually.

To review the filings in the case:  https://www.env.nm.gov/opf/docketed-matters/ , scroll down to the Water Quality Control Commission green tab, click on WQCC 23-84:  In the Matter of Proposed Rule 20.6.8 NMAC – Ground and Surface Water Protection – Supplemental Requirements for Water Reuse. 

Sign the New Energy Economy petition to NMED to withdraw its produced water reuse rule.  https://newenergyeconomy.salsalabs.org/nmed-withdraw-produced-water-reuse-rule/index.html?eType=EmailBlastContent&eId=4d528081-2d60-4940-b04c-c75c3d84fbfe

For more information:  https://www.newenergyeconomy.org/

3. From Wednesday, March 6 to May 15 (Bi- Weekly) from noon to 1 pm Mountain Time – UNM Climate Change and Human Health ECHO Program: Global Nuclear and Environmental Threats Critical to Climate Change and Human Health. https://iecho.org/echo-institute-programs/climate-change-and-human-health

May 15th – Environmental Justice and Environmental Toxicities Panel –  a 90-minute session.  The panel speakers are: 

• • Yohanna Barth-Rogers, MD, Chief Medical Officer, UMMA Community Clinic, Los Angeles, CA
  • Dino Chavarria, Tribal Superfund Working Group, Santa Clara Pueblo, NM
  • Jackie Medcalf, Texas Health & Environment Alliance (THEA) Founder and Executive Director, Houston, TX
  • Sterling Stokes, Campaign Manager for the Portland Harbor Community Coalition, OR

4. Wednesday, May 22^nd at 1 pm MDT webinar – Join DOE’s Consent-Based Siting Consortia for a Public Roundtable on Successes in Siting one or more federal consolidated interim storage facilities for commercial spent nuclear fuel. To register:  https://pnnl.zoomgov.com/webinar/register/WN_yP30QO6WTLqHjSJw-Kifqw?utm_medium=email&utm_source=govdelivery#/registration

 Submit your questions prior to the meeting:  consentbasedsiting@hq.doe.gov

From DOE’s May 1, 2024 post:   DOE Releases Interactive Tool for Audiences Wishing to Learn More About DOE’s Plans to Manage Spent Nuclear Fuel StoryMap to help communities evaluate interest and suitability in being considered as a potential host for a federal consolidated interim storage facility for commercial spent nuclear fuel.

The U.S. Department of Energy (DOE) released an interactive StoryMap for audiences wishing to learn more about federal consolidated interim storage of commercial spent nuclear fuel.

The “Integrated Waste Management (IWM) StoryMap: Consent-Based Siting for Consolidated Interim Storage,” is a free, easy-to-access tool on DOE’s approach to identifying one or more locations for siting facilities to store spent nuclear fuel on an interim basis. It details DOE’s concept for an integrated waste management system, federal consolidated interim storage design and operations, potential benefits and impacts, among other topics.

Tags: California Communities Against Toxics, CCNS, Cease Fire Campaign, Citizen Action New Mexico, Department of Defense, Department of Energy, Environmental Protection Agency, EPA, HAFB, hazardous wastes, health of soldiers workers and neighbors, Holloman Air Force Base, Jane Williams, LANL, Los Alamos National Laboratory, NASA, New Mexico Environment Department, open burn pits, PFAS, Sandia National Laboratory, Tewa Women United, Tribal Environmental Watch Alliance