Badger AAP Cleanup Reversed

[olah@igc.org]

From: Laura Olah <olah@speagle.com>

****** WARNING: This is a long file ******

MEMO

From: Laura Olah, Executive Director, Citizens for Safe Water Around 
Badger (CSWAB)
Date: May 15, 1996
RE: Badger Army Ammunition Plant - Cleanup Plans Reversed

 As a representative of CSWAB, I was recently invited by US 
Environmental Protection Agency (Region V) to attend a meeting at their 
regional offices in Chicago. In attendance were representatives of 
Badger Army Ammunition Plant (David Fordham), the Army Environmental 
Center (James Daniel), the Army Industrial Operations Command based in 
Rock Island, Illinois (Bob Radkiewicz), USEPA (Norm Niedergang, Margaret 
McCue, Shirley Dorsey, Harriet Crome, Bob Egan and Karl Bremer), and the 
Wisconsin Department of Natural Resources (Mike Netzer and Marty 
Herrick). 

 The Army requested the meeting to propose abandoning approved 
cleanup plans for two priority areas at BAAP: (1) Propellant Burning 
Grounds and (2) Settling Ponds/Disposal Area. 

The Army cited the following as reasons for their backpedaling:
-- Cuts in federal DERA (Defense Environmental Restoration Account) funds 
from $450 million to $250 million [$75 million of the $250 million is 
reserved for cleanup at the Rocky Mountain Arsenal]. Of the $6.5 
million allocated for cleanup at BAAP for the current fiscal year, $4.5 
will be utilized exclusively to support the groundwater treatment 
facility (MIRM), leaving only $2 million for facility-wide cleanup, far 
short of BAAP's original cleanup budget of $20 million.
-- The Army cited Wisconsin soil cleanup standards as much more 
conservative than what they can afford to do".
-- Environmental/health risks in BAAP's recent $6 million RI/FS (Remedial 
Investigation/ Feasibility Study) were overly conservative.

The Army now proposes to:
-- Remove and/or treat only 30 feet of contaminated soils at the 
Propellant Burning Grounds (rather than go down 120 feet). [The waste 
pits at the PBG are the source of a 3-mile long plume of contaminated 
groundwater that has migrated several miles off-site; principal 
contaminants are carcinogens including carbon tetrachloride, 
trichloroethylene and chloroform.]
-- Utilize institutional controls (fencing and long-term monitoring of 
groundwater) to address surface and subsurface soil contamination in the 
Settling Ponds area, rather than soil solidification and a soil cover 
estimated to cost $60 million. Principal contaminants are lead and 
dinitrotoluenes.

Potential and Real Impacts of BAAP's proposal to abandon approved cleanup 
plans: 

-- As federal funding decreases, the Army proposes decreasing levels of 
cleanup. 
-- The Department of Defense is challenging a legal and binding cleanup 
approval with the Wisconsin DNR, undermining the State's authority to 
regulate and protect its natural resources and human health.
-- The Department of Defense proposes exemptions not afforded to private 
industry or individuals. 
-- Huge expanses of land at Badger could be fenced off as unsuitable for 
development, human habitation, or even wildlife habitat.
-- Many community members do not have the resources to continually test 
their drinking water wells for contaminants associated with Badger, 
violating federally-mandated environmental justice principles to provide 
low-income people with equal protection of human health and their 
environment.
-- Groundwater resources and nearby drinking water wells may be at 
increased risk as pollutants will continue to migrate to groundwater. 
-- Many pervasive contaminants are bioaccumulative and readily enter the 
food chain, potentially increasing risk to human health. Fencing will 
not prohibit wildlife, including game animals, from foraging and nesting 
in these areas.
-- Without effective cleanup, risks to residents and workers may be 
compounded; a 1990 study of the communities near the Badger plant by the 
Wisconsin Division of Health documented elevated numbers of male 
kidney/ureter cancer and female non-Hodgkins lymphoma deaths.
-- Any exemptions, if granted to BAAP, will spur demands from other 
contaminated military and civilian sites in Wisconsin for similar 
concessions.

Conclusions:

 The issues and decisions at hand are complex and a solution not 
readily found principally because the Army has not provided adequate 
treatability studies, field work, or data to support their previous or 
new proposals. In fact, many of CSWAB's objections to the EPA's pending 
RCRA permit for BAAP are based on the lack of data and treatability 
studies. 
 Moreover, simply throwing more dollars at BAAP may not give us 
the answers we are looking for; the Army contends they padded their 
original cleanup proposal by over $100 million. In the meantime, 
regulatory agencies are pressing the community and CSWAB to support 
funding of the Army's original cleanup proposals.
 Given the lack of hard data, I believe the onus falls to the Army 
to prove their past and current proposals ensure optimal protection of 
human health and the environment, support environmental justice 
principles, promote uniform compliance with State standards, encourage 
optimal cleanup of other military sites in Wisconsin, and ensure 
conformity with the Federal Facilities Compliance Act. For the time 
being, it appears cleanup at Badger is effectively stopped in its tracks.

 Note: CSWAB will be meeting with WDNR Secretary George Meyer and 
Congressman Scott Klug's office this week to gather more information that 
may help clarify the situation with BAAP. I have also updated Senators 
Kohl and Feingold; follow-up scheduled after meeting with Meyer.