Remedial Goals for Soils at BAAP

[Laura Olah <olah@speagle.com>]

[THIS IS A LONG MESSAGE]

Hi everyone,

I've received a considerable number of inquiries regarding the cleanup at
Badger and have prepared the following. I appreciate everyone's support and
interest. I'm sorry I cannot respond to each of your individual messages and
hope I have answered most if not all of your questions. Community organizers
that have a critical need for additional documentation should, however, feel
free to contact me by way of follow-up. (The following text is also
available as a Word document as some may prefer this format.)

Thanks bunches,
Laura

-- 
Laura Olah, Executive Director
Citizens for Safe Water Around Badger
E12629 Weigand's Bay South
Merrimac, Wisconsin 53561
olah@speagle.com
Phone (608)643-3124 Fax (608)643-0005
Website http://www.speagle.com/cswab

REMEDIAL GOALS FOR BADGER ARMY AMMUNITION PLANT 

Prepared by: 
Citizens for Safe Water Around Badger (CSWAB)
E12629 Weigand's Bay South
Merrimac, WI 53561
Laura Olah, Executive Director 
olah@speagle.com

FACILITY BACKGROUND

Site Location and History

Badger Army Ammunition Plant (BAAP) is located in south central Wisconsin,
approximately 9 miles south of Baraboo, Wisconsin. The BAAP facility covers
approximately 7,354 acres within the townships of Sumpter and Merrimac in
Sauk County. The facility is bounded by U.S. Route 12 on the west, Devil's
Lake State Park on the north, and private farmland on the south and east. 
Wisconsin State Highway 78 and Lake Wisconsin border the facility on the
southeast. BAAP is owned by the Department of the Army and operated by Olin
Corporation. 

Construction of the BAAP facility began in 1942 to meet the increased demands
for propellants and explosives for World War II. Operation of the facility
began in January 1943. The plant was placed on stand-by status in September
1945. 

The facility was reactivated in 1957 and produced propellants until 1958,
when it was again placed on standby status. The most recent production
period for the plant began in early 1966 and ended in March 1975, during
which nitrocellulose, ball powder, rocket propellant and smokeless powder
were manufactured. In March 1975, the Department of Defense ordered
production to cease and subsequently placed the facility on stand-by status
once again. The facility remains in stand-by status at this time. 

REGULATORY HISTORY

The U.S. Army and Olin Corporation have been jointly issued a RCRA Permit by
the U.S. EPA and the Wisconsin Department of Natural Resources (WDNR). The
State portion allows the facility to store up to 10,000 gallons of hazardous
waste in containers at the facility. 

At the time of the permit issuance, the State of Wisconsin had not received
authority to administer the Hazardous and Solid Waste Amendments (HSWA) to
the Solid Waste Disposal Act. HSWA provide authority to U.S. EPA to
establish additional permitting requirements for hazardous waste management
facilities beyond the scope of existing regulations, if necessary to protect
human health and the environment. The State has been subsequently authorized
to administer individual provisions of HSWA. However, because the State had
not received authorization to address the HSWA requirements by the date on
which the RCRA Permit was originally issued to the U.S. Army (as owner) and
Olin Corporation (as operator), the U.S. EPA issued its own permit, jointly
with the State permit, addressing the HSWA requirements. The conditions
contained in both the State permit and the Federal permit constituted the
RCRA Permit. 

The Federal permit required the permittees to institute an Interim Measure
(IM) to remediate contaminated groundwater at the PBG, and to begin an
investigation of 11 areas at the facility. To date, the RCRA Facility
Investigation (RFI) and the Corrective Measures Study (CMS) have been
completed. The IM, installed to remediate groundwater at the PBG, has been
found through additional investigation to be inadequate. This SB addresses
the additional action to be taken at the PBG which is designed to intercept
the plume of contaminated groundwater emanating from the PBG at the facility
boundary. 

In April 1993, the RI was completed for Badger. It identified the types,
concentrations, and locations of contamination at the installation. The
Feasibility Study (FS), completed in August 1994, looked at the possible ways
to treat the contamination identified in the RI and recommended remedies for
each site. The regulators agreed with the Army's recommendations for
remedies. These have been incorporated into the In-Field Conditions Report
modifications of June 1995 and the RCRA permit modification of January 6,
1996, the equivalent of a CERCLA Record of Decision (ROD). 

GEOLOGY AND HYDROGEOLOGY

The geologic setting at BAAP is generally characterized by a thick sequence
of unconsolidated deposits (mostly sands and gravels) overlying sedimentary
and metamorphic bedrock of Cambrian and Precambrian age. At the surface,
most of BAAP is covered by a 5 to 10 feet thick layer of loess. 

The unconsolidated deposits generally thicken from north to south at BAAP. 
At the northern boundary, soil deposits are thin or absent, however, the
unconsolidated materials quickly thicken as the bedrock surface dips steeply
toward the south. The bedrock surface drops approximately 150 to 200 feet
across the northern third of BAAP, and appears flat across the southern
two-thirds. 

The principal groundw\ater flow system beneath BAAP occurs in the
unconsolidated overburden soils. The aquifer is unconsolidated, receiving
recharge from precipitation and discharging groundwater to the Wisconsin
River south of the Wisconsin Power and Light dam located at Prairie du Sac. 
In general, groundwater flows toward the southeast in the northwestern
portion of the site, and toward the south throughout much of the remainder of
the site, with some southwesterly flow near Lake Wisconsin along the eastern
base boundary. 

MEDIA CLEANUP STANDARDS

As part of the RFI, U.S. Army conducted a baseline risk assessment which
included a human health evaluation and an environmental assessment. The
baseline risk assessment was used to determine whether there is an
unacceptable risk to human or ecological receptors. Subsequent to the
finalization of the RFI Report, the State issued its proposed NR 720 rule. 
This proposed rule establishes numeric soil cleanup standards for some
constituents based on human health and based on protection of groundwater. 
For those chemicals without listed numeric standards, it establishes
procedures for calculating cleanup standards and procedures for calculating
alternative cleanup standards. Applying the lowest of the human health and
protection of groundwater standards for each Compound of Concern (COC) yields
soil cleanup levels that are more stringent than those calculated using the
criteria used in the baseline risk assessment for human health. Therefore,
the levels shown as cleanup goals for protection of human health and
protection of groundwater were developed using criteria in the proposed State
rule. Soil cleanup levels for protection of ecological receptors were
developed using the original risk assessment criteria contained in the Final
RFI Report. Groundwater quality was compared to State and/or Federal
groundwater standards or risk-based concentrations. 

Based on these assessments, actual or threatened releases of hazardous
constituents from the BAAP facility, if not further addressed by proposed
remedies, or one of the other remedies considered, may present a current or
potential threat to human health and the environment. 

Risks to terrestrial receptors at BAAP were quantitatively evaluated using
HQs, which were calculated for each COC by dividing the estimated exposure
level, in terms of total body dose (TBD), by the toxicological benchmark (the
RTV). To calculate acute exposure HIs, the site-specific exposure point
concentration of each COC was divided by the acute RTV; chronic exposure HIs
were calculated by dividing the site-specific exposure point COC
concentrations by the appropriate chronic RTV. This conservative approach
provides a screening level evaluation of potential effects of individual COCs
on terrestrial ecological receptors. 

Cumulative HIs were determined by summing the HQs for each chemical. A
hazard ranking system developed by USEPA (1989a) was used to characterize the
potential risk associated with exposures to BAAP contaminants. Cumulative HI
scores were classified using the following USEPA (1989a) ranking system: 

 HAZARD INDEX EFFECTS EXPECTED
 HI < 0.1 No Adverse Effects
 0.1 < = HI < 10 Possible Adverse Effects
 HI > = 10 Probable Adverse Effects

This ranking system considers potential ecological effects to individual
organisms, and does not evaluate potential population-wide risks. 
Contaminants may cause population reductions by affecting birth and mortality
rates, immigration, and emigration (USEPA, 1989a). In many circumstances,
acute (or chronic) effects can occur to individual organisms with little
potential population or community level effects; however, as the number of
individual organisms experiencing toxic effects increases, the probability
that population-level effects will occur also increases. The number of
affected individuals in a population presumably increases with increasing HI
values; therefore, the likelihood of population-level effects occurring is
generally expected to increase with higher HI values. 

The TBD estimates the combined effects of exposure to contaminated BAAP
surface soil. The TBD for each constituent was compared to the acute and
chronic RTVs to develop acute and chronic HIs. Cumulative acute and chronic
HIs were determined by summing the acute and chronic HQs for each
contaminant; these results were evaluated using the hazard ranking scheme
described above. 

The following sections present the Media Cleanup Standards (MCSS) for two of
the areas at the BAAP facility which require corrective action. 

PROPELLENT BURNING GROUNDS

Surface soil sampling, subsurface sampling and ground water sampling
performed during the RFI, and subsequent evaluation indicates the following
compounds exceed cleanup standards for protection of human health or
protection of groundwater per the proposed NR 720 rule, or exceed acceptable
ecological risks from exposure using U.S. EPA risk guidance. Following the
compound name is the MCS for the compound. 

SURFACE SOIL MEDIA CLEANUP STANDARDS

COMPOUNDS OF CONCERN MEDIA CLEANUP STANDARDS (mg/kg)

2,4 DNT 4.29 (1)
Carcinogenic polyaromatic hydrocarbons
(CPAH) (benzo (a) anthracene and pyrene) 0.40 (1)
Arsenic 16 (2)
Copper 25 (2)
Mercury 0.38 (2)
Lead 30 (2)
Selenium 0.70 (2)
Zinc 81.3 (2)

NOTES: 
1. Protection of human health per proposed NR 720 Rule.
2. Background concentration, greater than proposed NR 720 Rule
concentration and/or ecological risk concentration.

SUBSURFACE SOIL MEDIA-CLEANUP STANDARDS

COMPOUNDS OF CONCERN MEDIA CLEANUP STANDARDS (mg/kg)
2,4 DNT 1.0 (2)
2,6 DNT 1.0 (2)
CPAH 0.40 (3)
Benzene 100.35 (3)
Tricloroethylene 0.037 (5)
Arsenic 2.5 (4)
Chromium 10.4 (4)
Lead 3.97 (4)
Selenium 0.449 (4)
Zinc 80.800 (5)

NOTES:
1. Carcinogenic PAHs consisting of: benzo(a) anthracene, benzo(a)pyrene,
benzo(b) fluoranthene. benzo(k)fluoranthene, chrysene,
dibenzo(a,h)anthracene, and indeno (1,2,3-cd) pyrene.
2. Detection limit
3. Protective of human health per proposed NR 720 Rule. 
4. Background concentration, which is greater than proposed NR 720
concentration for protection of groundwater.
5. Protective of groundwater per proposed NR 720 Rule.

NITROGLYCERINE POND/ROCKET PASTE AREA

NITROGLYCERINE POND SURFACE SOIL MEDIA CLEANUP STANDARDS

COMPOUNDS OF CONCERN MEDIA CLEAN-UP STANDARD (mg/kg)
Lead 30 (1)
Mercury 0.38 (1)
Nitroglycerine 3.6 (2)

(1) Background concentration
(2) Acceptable risk-based concentration is the result of an ecological
risk evaluation for terrestrial receptors.

SOURCES:
* Installation Action Plan for Badger Army Ammunition Plant, February 
25, 1998
* Plan Modification of the September 14, 19876 In-Field Conditions
Report Approval: Approval of Corrective Measures Selected in the Final
Feasibility Study Report/Corrective Measures Study Report for Badger
Army Ammunition Plant, June 1, 1995
* Remedial Investigation/Feasibility Study Badger Army Ammunition Plant,
August 1994
* USEPA - Region 5 - RCRA Permit issued to U.S. Army and Olin
Corporation for the Badger Army Ammunition Plant Facility, October 30,
1988 and subsequent modifications