[CPEO-MEF] Badger AAP (WI) fire training area

[Lenny Siegel <lsiegel@cpeo.org>]

Citizens for Safe Water Around Badger
March 4, 2005

PRESS RELEASE

Study of Fire Training Area Doesn't Measure Up 

WISCONSIN ? An environmental investigation at Badger Army Ammunition
Plant is less comprehensive than typical investigations at other similar
military sites, according to a report released today by Citizens for
Safe Water Around Badger (CSWAB).  

The group compared environmental investigations at Fire Training Areas
at 12 U.S. military bases and found that Badger was the only facility
where passive soil gas collection was the only investigative method
utilized and aromatic VOCs (principally solvents) were the only tested
contaminants.  As a result, CSWAB believes risks to human health and the
environment may not be fully characterized especially when compared to
other sites.  

For all other eleven (11) fire training sites, environmental testing
included a wide range of other potential contaminants including metals,
SVOCs (semi-volatile organic compounds), pesticides, dioxins, furans,
explosives, fluorotelomer sulfonates (found in fire-fighting foams),
TRPH (Total Recoverable Petroleum Hydrocarbons), BTEX (Benzene, Toluene,
Ethylbenzene, and Xylenes), and others.  

Testing at other bases found that persistent contaminants such as lead
and pesticides were the ?drivers? in several remedial decisions, not
VOCs.  At the fire training area at Joliet Army Ammunition Plant in
Illinois, for example, the Army identified metals as the primary
contaminant of concern, resulting in a cleanup that required excavation
of approximately 185 cubic yards of contaminated soils.  Activities at
these former burning sites typically included pouring spent fuels,
solvents, and other wastes onto the ground and igniting them for
firefighting exercises.  

The group has asked the Wisconsin Department of Natural Resources to
consider expanding the scope of work for the Fire Training Area at
Badger to include a broader range of contaminants and methods for
investigating surface soil, subsurface soil, and groundwater quality.  
Additional study is needed, the group says, to assure the success of
wildlife, sustainable agriculture, recreation, and other desired future
uses.  

CSWAB?s report is the first in a series that will review sites for which
the Army at Badger has recommended ?no further investigation?.   

                                                                *   *   *

Environmental Investigations at Military Fire Training Areas: 
Badger Army Ammunition Plant and other U.S. Bases

Citizens for Safe Water Around Badger  
March 4, 2005

Introduction:  

The goal of this report is to determine if the scope of investigation at
the Fire Training Area at Wisconsin?s Badger Army Ammunition Plant
(Badger) is comparable to similar facilities, and to provide the public,
future owners, regulators, and the U.S. Army with information that will
help assure optimal protection of human health and the environment,
including the success of wildlife, sustainable agriculture, recreation,
and other desired future uses.  This report looked at twelve (12) fire
training facilities at bases throughout the U.S.  This is the first in a
series of reports that will review sites for which the Army at Badger
has recommended ?no further investigation?.

Summary of Findings: 

Badger is the only facility where passive soil gas collection was the
only investigative method utilized and aromatic VOCs (principally
solvents) were the only tested contaminants.  For all other eleven (11)
fire training sites, testing included a wide range of other potential
contaminants including metals, SVOCs, pesticides, dioxins, furans,
explosives, fluorotelomer sulfonates, TRPH (Total Recoverable Petroleum
Hydrocarbons), BTEX (Benzene, Toluene, Ethylbenzene, and Xylenes), and
others.  Both groundwater and soil testing were required as part of the
site assessments.  It is important to note that persistent contaminants
such as lead and pesticides were the ?drivers? in several remedial
decisions, not VOCs.

The investigation at the Fire Training Area at Badger Army Ammunition
Plant appears to be far less comprehensive than typical investigations
at other similar military sites.  As a result, risks to human health and
the environment may not be fully characterized especially when compared
to other sites.  Further, the degree of confidence that the public,
future owners, and the regulatory community may have in the Fire
Training Area investigation at Badger is expected to be much lower when
compared to other communities and at other similar sites.   

Recommendations:  

In order to resolve these deficiencies, the Wisconsin Department of
Natural Resources and USEPA should consider expanding the scope of work
for the Fire Training Area at Badger Army Ammunition Plant to include a
broader range of contaminants and methods for investigating surface
soil, subsurface soil, and groundwater quality. 

Overview of Sites:

Kentucky Air National Guard 

            In 1997, Ogden Environmental and Energy Services conducted
an investigation of the former Fire Training Area, 123rd Airlift Wing,
Kentucky Air National Guard, Standiford Field, Louisville, Kentucky. 
The Installation Restoration Program was initiated by the Air National
Guard (ANG) to evaluate potential contamination to the environment
caused by past practices at its installations. The Preliminary
Assessment (PA) identified the location of a former Fire Training Area
(FTA). Closure activities in Aug 1995 included placement of a cap. State
regulations in this karst area require 30 years of monitoring of the
surface water at a nearby spring.  The suite of analytes included: (1)
VOCs, (2) SVOCs, (3) PCBs, (4) dioxin, and (5) TAL (Target Analyte List)
metals. 

 Seneca Army Depot, New York State

            Starting in the 1960?s the Fire Training and Demonstration
Pad at the Seneca Army Depot was used for fire control training. 
Groundwater was tested for VOCs, SVOCs, total petroleum hydrocarbons,
and metals.   Surface and Subsurface Soil was tested for VOCs, SVOCs,
pesticides, and metals.  High levels of lead were also found in samples
containing high VOCs and SVOCs.  Metals and pesticides were detected at
levels above CVs.  

            Since 1977, the Fire Testing Pit area was used one or two
times each year for fire fighting training exercises, which involve
igniting and extinguishing fuels. The area around the pit was used to
store burned vehicles and fuel drums.  Groundwater was sampled for VOCs,
SVOCs, pesticides, PCBs, explosive compounds, and metals, including
arsenic, beryllium, lead, and zinc.  Documentation of the scope of work
for surface and subsurface soil could not be found, however the Army
reports SVOCs were detected in soils at levels exceeding CVs.  
Manganese was detected as high as 120,000 ppm, well above the reference
dose for children (RMEG) of 7,000 ppm.  

Iowa Army Ammunition Plant 

            The Fire Training Pit at Iowa Army Ammunition Plant is a
40-by-60-by-2-foot area that was used by firefighters from 1982 to 1987.
 Fifty-five gallons drums of solvents or fuels were placed in the Fire
Training Pit and set ablaze.  Soils and groundwater were tested for
VOCs, SVOCs, explosives, and metals.  Contaminants of concern at the
site include metals, VOCs, and SVOCs.  Groundwater contained elevated
levels of metals, VOCs, and SVOCs.  Surface water contains elevated
levels of explosives.

            Metals contamination in soil and sediment was highest
(greater than 1,000 ppm) in the center of the pit.  Contaminated soils
were removed and stored in the on-site CAMU and soil repository.

Joliet Army Ammunition Plant, Illinois

            A 50-acre site in the west central portion of the Load,
Assemble and Pack (LAP) Area was used for open combustion of refuse and
contained a fire training site. The fire training area and soils east of
demolition pits have metals contamination.  Areas within the berms have
metals and explosives contamination. Berm soil will be landfilled;
approximately 7.5 acres will be capped.  A Groundwater Management Zone
(GMZ) has been established.   According to the 2001 Installation Action
Plan, this was considered interim ROD site and final remedial goals had
not been established for soils.  Long term groundwater monitoring will
be continued.

Fort Lewis, Washington 

            In September 1986, a field investigation was conducted at
the Old Fire Fighting Training Pit to assist in the preparation of a
Resource Conservation and Recovery Act (RCRA) Part B permit application
for Fort Lewis. Twenty test pits were dug within a 100-ft-diameter area
thought to encompass the Old Fire Fighting Training Pit. Twelve
composite soil samples were collected and analyzed for 56 SVOCs using
EPA Method 8270.  

            In September 1987, three borings were advanced to a depth of
10 ft using a 4-inch diameter hollow-stem auger.  Eight soil samples
were collected using a split-spoon sampler and analyzed for SVOCs and
VOCs, pesticides and PCBs, and dioxins and dioxin homologues.  

            Between September 1993 and July 1994, Woodward-Clyde
conducted a limited field investigation to determine if the previous
practices at the Old Fire Fighting Training Pit resulted in
contamination of the uppermost aquifer beneath the site.  The
investigation included installation of three monitoring wells, an
evaluation of the groundwater gradient, and groundwater sampling and
analysis.  Groundwater samples were collected in November and December
1993 and analyzed for VOCs, SVOCs, low-level PCBs, metals, cyanide, and
dioxins and furans. 

                     

Iowa Army Ammunition Plant

            The former Fire Training Pit at Iowa Army Ammunition Plant
was an unlined pit that measured approximately 40x16x2 feet used from
1982 to 1987. During training sessions, 55-gallon drums of solvents and
petroleum products were set ablaze and then extinguished by fire
fighters.  Soil and groundwater were tested for VOCs, SVOCs, metals,
dioxins and furans.  In 1998, a soil cleanup effort removed 5200cy of
contaminated soil, half of which was thermally treated. The remaining
soil was landfilled or backfilled. This action is believed to have
removed the contamination source.

Tyndall Air Force Base, Florida

            This site was used from 1943 to 1952 and from 1968 to 1980
for fire training. Fires were deliberately set by igniting Petroleum,
Oil, and Lubricants (POL) waste after it was poured onto old aircraft.
This site may also have received POL waste directly from a tank. Prior
to 1971, a protein foam was used to put out the fires during the
training. Since 1971, aqueous film-forming foams have been used to douse
the fire. These foams consisted of fluorocarbon surfactants with a
petroleum base, also known as Aqueous Film Forming Foams (AFFF). 
Fluorotelomer sulfonates (FtS) were detected in groundwater at levels as
high as 14,600 µg/L at Tyndall Air Force Base; at Wurtsmith Air Force
Base in Michigan, at contaminant levels in groundwater were reported as
high as 182 µg/L.  Documentation for other parameters was not found. 

Air Training Command, Texas

            According to the Air Force Center for Environmental
Excellence, the Air Training Command (ATC) historically leased
facilities at Hondo Airport as an off-base installation for the 1st
Flight Screening Squadron.  Hondo Airport is located some 70 miles West
of San Antonio.  As part of routine operations, the Air Force conducted
fire training on-site.  A 50 foot (ft) diameter circular area of
stressed vegetation and darkened soil remains from the fire training
operations.  Additionally there is evidence that used oil from unknown
sources and tar from sealing runway cracks were disposed within this 50
ft area.

            In accordance with the Scope of Work for the Site Assessment
of the Hondo Fire Training Area, groundwater was tested for Total
Recoverable Petroleum Hydrocarbons (TRPH), Benzene, Toluene,
Ethylbenzene, and Xylenes (BTEX) , VOCs, and SVOCs.  Soil borings were
analyzed for TRPH, BTEX, Volatiles, Semivolatile Organics, lead, Benzene
Extractable (Toxicity Characteristic Leacheate Procedure), and Total
Organic Halogens (TOX).

U.S. Defense General Supply Center, Virginia 

            According to the 1993 Public Health Assessment for the U.S.
Defense General Supply Center, both surface and subsurface soils at the
Fire Training Area contain contaminants of concern, including heavy
metals.  Soils were analyzed for arsenic, beryllium, lead, nickel,
benzene, 1,2-dichloroethane, 1,1-dichloroethylene, 1,2-dichloroethylene,
1,2-dichloropropane, tetrachloroethylene, trichloroethylene, PAHs
(polyaromatic hydrocarbons), chrysene, and indeno(1,2,3)pyrene.  VOCs
were detected in soil gas assays at the National Guard Area and the Fire
Training Area.  Contaminants of concern in groundwater included arsenic,
beryllium, chromium (hexavalent), lead, carbon tetrachloride,
1,1-dichloroethylene, methylene chloride, tetrachloroethylene,
1,1,1-trichloroethane, and trichloroethylene.  

            Chlordane, arsenic, beryllium, chromium (hexavalent), and
lead were identified contaminants of concern in soil ? none of which
were identified through soil gas surveys at the fire training area.  

Fort Richardson, Alaska

            According to the Alaska Department of Environmental
Conservation Contaminated Sites Database, in May 1985, environmental
testing indicated that the surface soil in fire training pit 2 at Fort
Richardson had high levels of cadmium, lead, and zinc. Used petroleum
products from the motor pools were burned at the fire training pits.
These materials were stored on site in 55 gallon drums prior to use in
fire training drills. Approximately 1,500 to 2,300 gallons/year of
wastes were burned at each fire training pit.  In 1991, a surface soil
sample collected from a stained area contained tetrachloroethene (PCE)
485 ug/kg, bis(2-ethylhexyl)phthalate 4100 ug/kg, diesel 20000 mg/kg,
and lead 543 mg/kg. Subsurface samples contained significant levels of
acetone 283 ug/kg and TCE 46 ug/kg. 

 Pantex Plant, Texas

            The Fire Training Area Burn Pits site at Pantex occupies
approximately 1.7 hectares (4.25 acres). The main features of interest
at the site are two underlined burn pits, (Pit 1 and Pit 2), which were
used to contain training fires staged at the site, a crawl tube formerly
used in fire/smoke training exercises, a former tank and storage area
for drums of waste solvents and fuels used to set training fires, and a
shallow unlined drainage ditch that periodically received runoff from
the pits and surrounding areas. 

            The nature and volume of materials used in the past fire
training exercises are only partially documented.  Waste solvents, as
well as fuels and oils (some possibly containing polychlorinated
biphenyls), were reportedly burned in Pit 1.  Before 1985, approximately
208 liters (55 gallons) of toluene, and 380 liters (100 gallons) of
dimethylefromanide were reportedly burned in Pit 2.  The extinguishing
agents used included protein foam, ABC-type dry chemical mixtures, 1211
Halon, Aqueous Film-Forming Foam, and water. The Fire Training Area Burn
Pits site was used from 1973 until 1990 for Pantex Plant Fire Department
personnel training exercises. The site was used approximately twice a
year. 

            An interim corrective measure was initiated to remove the
upper 0.6 meters (two feet) of contamination (primarily pesticides and
metals) during the summer of 1995. Hot spots (isolated areas that exceed
acceptable levels of contamination) were removed to meet Risk Reduction
Standards. After excavation, appropriate offsite disposal of
contaminated soil was followed by confirmation sampling to document
compliance with the Risk Reduction Standards cleanup levels.
Approximately 1,041.2 cubic meters (1,370 cubic yards) of soil were
removed. The Draft Final Interim Corrective Measures Closure report was
submitted to regulators in November 1995. 

Badger Army Ammunition Plant, Wisconsin

            According to the Army?s 2004 Remedial Investigation (RI),
facility plans from 1971 document a ?new paved practice area? and an
?existing fire fighting area? south of Fire Station #1.  The concern was
surface spillage associated with fire training exercise.  Nine passive
soil gas collectors were installed for three weeks, removed, and
analyzed for aromatic VOCs.  No VOCs were detected in any of the soil
gas collectors.  Army contractors have recommended no further
investigation of the Fire Training Area.  

Sources:

·        Public Health Assessment, Seneca Army Depot, Agency for Toxic
Substances and Disease Registry (ATSDR), March 2000.

·        Public Health Assessment, Iowa Army Ammunition Plant, ATSDR,
December 28, 1999 

·        First Quarterly Monitoring Report for the Former Fire Training
Area Deliverable 2B, 123rd Airlift Wing, Kentucky Air National Guard,
Standiford Field, Louisville, KY, Ogden Environmental and Energy
Services, 1998.

·        Public Health Assessment, Tyndall Air Force Base, Florida,
ATSDR, July 2000.

·        Installation Action Plan for Joliet Army Ammunition Plant, U.S.
Army, March 2001.

·        Quantitative Determination of Fluorotelomer Sulfonates in a
Groundwater System, Department of Chemistry and Department of
Environmental & Molecular Toxicology, Oregon State University, undated.

·        Decision Document for the Storm Water Outfalls/Industrial
Wastewater Treatment Plant, Pesticide Rinse Area, Old Fire Fighting
Training Pit, Illicit PCB Dump Site, and the Battery Acid Pit, Fort
Lewis, Washington, U.S. Army Forces Command

·        Fort Lewis, Washington, December 2000

·        Scope of Work Site Assessment: Hondo Fire Training Area, Air
Force Center for Environmental Excellence, September 1993.

·        Public Health Assessment, U.S. Defense General Supply Center,
Virginia, ATSDR, April 1993.  

·        Site Report for Ft. Rich OUD Landfill/Fire Training Area,
Alaska Department of Environmental Conservation Contaminated Sites
Database, May 1985.  

·        Pantex Plant, 1996 Baseline Environmental Management Report,
U.S. Department of Energy, Office of Environmental Management.

·        Follow-up Remedial Investigation, Non-ERA Eligible Sites,
Badger Army Ammunition Plant, U.S. Army, January 2004.  

Citizens for Safe Water Around Badger (CSWAB) is working to mobilize and
empower rural  communities near Wisconsin?s Badger Army Ammunition Plant
in support of a sustainable future that will protect and restore the
integrity of soil, water, air, and biological diversity.  For more
information contact: CSWAB, E12629 Weigand?s Bay South, Merrimac, WI 
53561 (608) 643-3124 or info@cswab.org.  Our website is
http://www.cswab.org Laura Olah, Executive Director

Citizens for Safe Water Around Badger E12629 Weigands Bay S Merrimac, WI
53561 phone: (608)643-3124 fax: (608)643-0005 email: info@cswab.org
website: www.cswab.org



  

-- 


Lenny Siegel
Director, Center for Public Environmental Oversight
c/o PSC, 278-A Hope St., Mountain View, CA 94041
Voice: 650/961-8918 or 650/969-1545
Fax: 650/961-8918
<lsiegel@cpeo.org>
http://www.cpeo.org
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