|Date:||Wed, 22 May 1996 09:49:43 -0700 (PDT)|
|Subject:||Badger AAP Cleanup Reversed|
From: Laura Olah <firstname.lastname@example.org> ****** 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.
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