In late September, after more than half a century of Army occupation of Makua Valley with never so much as a by-your-leave to the residents of Hawai’i, the federal Environmental Protection Agency announced that the public would have an opportunity to weigh in with its views on at least one aspect of Army activities at Makua.
The announcement came in the form of a public notice issued by the EPA. As part of its permit issuing process, the EPA is required to solicit public opinion on a draft permit under which the Army will be able to continue the destruction of weapons and other munitions (and evidently several other miscellaneous items) at Makua Valley. While many people might be led to think that, because this involves issuance of a new permit, it must therefore involve new activities, quite the contrary is true. The activities that will be covered by the new permit are probably as old as the Army’s occupation of Makua Valley itself.
The permit, to be issued under terms of the federal Resource Conservation and Recovery Act, is for the Army to operate a hazardous waste treatment facility. It will replace an interim permit that the EPA granted in 1982. The hazardous waste consists of all manner of ammunition, grenades, explosive charges, rockets, missiles, blasting caps, igniters, firing devices, and fuses – among other things. According to Army statements in the draft permit that it submitted to the EPA, and which is the subject of the public comment, the material to be destroyed at Makua Valley is “unserviceable military ordnance” that is no longer needed. It may have become too old to use safely, for example, or various treaty terms may require its destruction.
The waste munitions are destroyed at Makua in a 14-acre area about a mile and a half mauka of Farrington Highway, the coastal road. Depending on the nature of the munitions, they are either placed in a pit and are detonated – a process called “open detonation” – or they are placed on the ground, doused with fuel, and set ablaze “open burning.” (The Army states that under the new permit, open burning will henceforth occur only in stainless steel burn pans that might be up to 20 feet long. The pans are needed, the Army says, to ensure that potentially hazardous ash does not contaminate the soil.)
Exempt Activities
One of the most controversial claims in the Army permit concerns the extent of activity regulated at Makua. If the permit is granted, the Army states, up to 1,600 tons a year of munitions will be disposed of at the OB/OD facility. However, this quantity refers only to waste munitions that are brought to Makua Valley from other Defense Department and Hawai’i National Guard facilities in the state. The Army’s disposal of unserviceable munitions related to its own training exercises in Makua Valley are held by the Army to be exempt from any RCPA regulation.
Here’s how the Army tells it:
“Unserviceable military ordnance is treated (demilitarized) at the open burning/open detonation (OB/OD) unit onsite. Demilitarization of unused and faulty ordnance and munitions associated with training is conducted at the OB/OD area (on an as-needed basis) onsite immediately upon completion of each training exercise. These OB/OD operations, as well as other military training activities which include Explosive Ordnance Disposal (EOD) training, are considered exempt from RCRA….
“The military training activities at MMR and the use of the OB/OD area for EOD training, as well as its location within a target impact area, are the primary sources of and reason for contamination at the MMR OB/OD unit, but these sources are exempt from RCRA regulations. The energetic material items historically treated by OB/OD at MMR which are subject to requirements … are of the same type but are of a quantity that is minuscule compared to those generated by impact range activities” (emphasis added).1
So how much does the Army intend to burn or detonate at its Makua hazardous waste facility each year? All the Army will say is that 1,600 tons more than four tons per day, on average – represents only a “minuscule” portion.
A Sad History
The Resource Conservation and Recovery Act allows the EPA to undertake RCRA Facility Assessments (RFAs) to determine the potential for environmental contamination at a given regulated facility. And, if the EPA finds that a release has occurred or is likely to, it has the authority to order corrective action, usually as a condition of the permit.
As a first step in this RFA process, the EPA Region Ix, responsible for enforcement in Hawai’i, hired a consultant to do a preliminary review. The consultant, Science Applications International Corporation, presented the results of its preliminary review to the EPA in August 1991. “Because of the incomplete information on all of the areas identified” in the preliminary review, SMC recommended that a visual on-site inspection be done to fill in the gaps.
The follow-up inspection was not done. Nonetheless, the SAIC report and other historical documents provide a good deal of background on past waste disposal activities at Makua Valley.
Bombs Away
The earliest disposal of explosives at Makua Valley most certainly occurred during the war years. After the war, use of the valley for live fire exercises as well as munitions disposal continued. When hostilities ceased, many of the chemical weapons, including mustard gas, stockpiled in Hawai’i, were reported to be disposed of at Makua. In a de-dudding operation that occurred in 1949 and 1950, more than 11,000 rounds of ammunition were cleared from the firing range and exploded on the site.
The intensity of activity waxed and waned with U.S. military engagements abroad. During the 1950s, planes practiced dive-bombing at Makua Valley. At least one plane crashed into the pali. Unexploded bombs were found from time to time – most recently in 1983, when scientists looking for endangered tree snails found two 1,000-pound, box-finned bombs dating from the 1950s. The bombs were detonated in place at high elevations in Ko’iahi Gulch.
Ordnance disposal activities at Makua Valley picked up again during the Vietnam War. According to the SAIC report, “during the late 1960s and early 1970s, many tons of ordnance returned from Vietnam were disposed of at the site. Reportedly, 350 900-pound napalm bombs were destroyed at Makua in 1982…. Large quantities of white phosphorous have also been disposed of.”
SAIC found that the Army’s disposal of non-traditional weapons and material was not relegated only to the past. “Smoke grenades and a riot-control agent, o-chlorobenzylidene malononitrile (CS) are occasionally disposed of.” the report said. Also, “in 1980 or 1981, Mr. Roy Takekawa of the University of Hawai’i witnessed the destruction of ethers at Makua. He described the product of the reaction as a ‘big fire ball.'”
Extra Service
The Army also accommodated Tripler Hospital, giving it permission in 1989 to dispose of “two kilograms of picric acid that has passed its shelf life, as well as future quantities of picric acid”…a substance more explosive than TNT and which may release toxic gases when burned. The University of Hawai’i has also disposed of picric acid at Makua.
At the time the SAIC report was written, Tripler Hospital was seeking the Army’s permission to dispose of 200 30-gram canisters (approximately 84 pounds) of ethylene oxide gas. The canisters were old, the report stated, and showed signs of severe deterioration. The report continues: “These canisters may be at least 11 years old. Ethylene oxide gas … is used in the medical profession to sterilize surgical instruments. Ethylene oxide gas is a known carcinogen.”2 (The fire power of ethylene oxide is uncertain; its use in warfare is not documented. Nonetheless, sandwiched between “40-mm target practice, tracer,” and “TOW missiles (inert),” ethylene oxide pops up in a list of “authorized ordnance/demolition items” included in the RCRA draft permit as Table C.2.7-2.)
The Army conducted its own site assessment of Makua Valley as part of a much larger survey of potential environmental contamination at Army facilities in Hawai’i.3 According to that assessment, Makua Valley was contaminated with metal fragments and dust, and unexploded ordnance. More than 80 tons of toxic and hazardous chemicals and materials were burned each year, the assessment stated. Contamination of both ground water and surface water was suspected.
To the Limits
The Army states in its permit that it is now limited to detonating or burning no more than 300 pounds of ordnance at a time. However, it also states that it intends to increase the quantity of munitions it can dispose of at anyone time to 2,000 pounds, “following completion of a series of fire-control roads near the OB/OL) area.”
In fact, until 1989, the Army routinely burned up to 2,000 pounds of ordnance at a time and its interim permit appears to permit this. Although the documents relating to consultation with the Fish and Wildlife Service are silent on limiting the quantity of ordnance disposed of at any one time, it is possible that the Army decided on its own to go with the lower figure for the time being.
The Elusive Creeper Plant
As long as the permit is, its discussion of the impact of ordnance disposal activities on endangered plants and animals is brief. Less than half a page is given over to the subject.
Despite its brevity it contains a dismaying number of bloopers. “The Makua Valley is home to the O’ahu tree snail (Achatinolla [sic]) a gastropod found nowhere else but on this island and is a federally endangered species.”
The O’ahu honey creeper, one of Hawai’i’s endangered birds, is described as a plant! “While its presence in Makua Valley has never been confirmed,” the permit states, “Fire-protection procedures developed for the O’ahu tree snail would also be protective of the O’ahu creeper.” No mention is made of the federally listed endangered or candidate endangered species of plants in Makua Valley.
Scanty Information
In other respects, too, the draft permit is missing the type of information that is critical in determining whether the regulations on OB/OD activity are sufficient. For example, despite the Army’s long tenure at Makua Valley, it states that it has no good data on soil characteristics. This becomes significant when the draft permit discusses potential pathways for contamination. The computer model used to predict overland run-off requires information on the moisture content and density of soil in the waste management unit, as well as the distance from the surface to the saturated zone (that is, the level of the water table). The Army permit states: “If specifics on soil properties are not available, typical values are provided by the [computer] program. These values were used” in the computer modeling. The soils in the OB/OD unit were assumed to be “silty clay.”
The Army permit refers to soil contamination tests conducted in 1985 to bear out its claim that contamination at the site is minimal. It cannot provide details as to the sample sites, however, nor can it provide other important information as to the test conditions.
The hydrogeology of the valley is not discussed, so that it is impossible to know whether the underground water sources that may be contaminated by activities at Makua are drawn on elsewhere. The discussion of stream drainage of the valley is flawed by assumptions that the Army itself acknowledges do not hold. For example, it states: “Surface water flow in Makua Stream was estimated by assuming the rainfall of the stream’s drainage area flows uniformly throughout the year… In reality, the stream flows only a portion of the year.”
Over and over, the draft permit describes the precise calculations that result in predictions that, as a consequence of the regulated activities, the air, water and soil will be contaminated at concentrations no higher than the parts-per-billion or -trillion level. Yet inasmuch as the calculations are based only on the explosives disposed of by the regulated activity – and omit the far greater sources of contamination released during unregulated Army activities – the calculations are of no value as indicators of potential impacts on health or the environment.
How to Comment
RCRA provides for a 45-day comment period on draft permits. The initial deadline for comment on the Army’s permit was set for November 13, 1992. Following several protests to the EPA that this did not give sufficient time to the community to review such a long, complex document, the deadline has been extended to February 11, 1993.
Copies of the permit are available for review at the state Department of Health’s Solid and Hazardous Waste Branch (on the second floor of 5 Waterfront Plaza – also known as Restaurant Row -500 Ala Moana Boulevard, Honolulu); at the EPAs Pacific Islands Contact Office (in Room 5124 of the Federal Building across the street from Restaurant Row); and at the Pearl City Regional Library.
Comments should be mailed to U.S. EPA Region Ix, Attention: Vern Christianson (H3-2), 75 Hawthorne Street, San Francisco, California 94105.
1 See “Draft Permit for Open Burn/Open Detonation, U.S. Army, Makua Military Reservation,” page B-1 (Facility Description).
2 SAIC report, page 10.
3 See “Draft Solid Waste Management Report for Army Properties,” prepared for U.S. Army Toxic and Hazardous Materials Agency, August 1990.
Volume 3, Number 5 November 1992