2013 CPEO Military List Archive

From: Lenny Siegel <lsiegel@cpeo.org>
Date: Thu, 14 Feb 2013 18:07:46 -0800 (PST)
Reply: cpeo-military
Subject: [CPEO-MEF] REUSE, WETLANDS: "CSWAB ACTION ALERT: Badger Soil Cleanup May Not Be Protective"

Begin forwarded message:

From: "Laura Olah" <cswab@merr.com>
Subject: CSWAB ACTION ALERT: Badger Soil Cleanup May Not Be Protective
Date: February 14, 2013 9:17:50 AM EST

Badger Soil Cleanup May Not Be Protective

If approved, a proposal by the U.S. Army could prohibit camping, prairie restoration, and other conservation activities on portions of the Sauk Prairie Recreation Area.

The Wisconsin Department of Natural Resources (WDNR) is accepting public comments on the military’s proposed cleanup remedy at the Settling Ponds site – a 60-acre meadow wetlands area that spans the width of the former Badger Army Ammunition Plant property. 

The proposed remedy – partial excavation of contaminated soils and sediments – will leave some residual contamination above state standards.  The WDNR’s February 7 preliminary determination letter says that institutional controls will be implemented to protect human health and the environment.  These controls will include listing on the Department's GIS Registry for Soil and Groundwater Contamination and restrictions on land use included on property deeds. 

Deed restriction language is expected to prohibit camping and activities that would disturb vegetative cover – such as prairie restoration and invasive species removal – on land that is slated for transfer to the State of Wisconsin as part of the Sauk Prairie Recreation Area.   Other portions of the Settling Ponds have or will be transferred to the U.S. Department of Agriculture, the Wisconsin Department of Transportation, and the Bluffview Sanitary District. 

Disturbance of vegetation by future site visitors and workers is to be avoided as plant root systems will be relied upon to bind contaminated soil particles and prevent them from becoming airborne or exposed and posing a risk to human health, according to the Army’s proposal.  Residual soil contaminants include lead, explosives, chromium and other environmental toxins. 

While additional excavation of contaminated soils, earthen capping or other remedial action could minimize or even eliminate risks to humans and wildlife, neither the State nor the Army are proposing this additional effort. 

CSWAB is calling for additional cleanup of residual soil and sediment contamination.  We believe that cleanup can and should be more protective and allow for unrestricted future use.  This level of cleanup is supported by the Badger Reuse Plan – a cooperative agreement developed and endorsed by local, state, federal and tribal interests at Badger, including the WDNR and the State of Wisconsin.


  • WRITE:  The WDNR is inviting the public to comment on the proposed remedy at the Settling Ponds.  Public comments will be accepted until March 11, 2013.  The Department will accept only written comments (by letter or e-mail) during the comment period.  Comments on the Alternative Feasibility Study for the Settling Ponds may be sent by letter or email to: Will Myers, Wisconsin Department of Natural Resources, 3911 Fish Hatchery Road, Fitchburg, WI 53711, will.myers@wisconsin.gov 
  • ATTEND:  The WDNR will also be hosting a public informational open house on February 20, 2013 from 5:00 until 7:00 pm at the River Arts Center Gallery, 105 9th Street, Prairie du Sac.  CSWAB will have an informational table at this meeting.
  • NETWORK:  Forward this action alert to a friend.  This is one of those times when numbers count.


According to a technical review by Dr. Peter deFur – an expert hired by CSWAB to review the Army study – proposed increases in soil remediation goals and the elimination of at least seven contaminants of concern are not protective of all human and ecological receptors.

“The remedial goals are insufficient for (the explosive) DNT because the (Army’s study) does not address the combined mixture of all 6 isomers, which could be conducted using basic assumptions used by the state of Wisconsin in developing groundwater standards for DNT,” deFur said.  “Toxicologists with the Wisconsin Division of Health found that the lesser isomers of DNT (2,3-, 3,4-, 3,5-, and 2,5-DNT) are as toxic or more toxic than 2,4- and 2,6-DNT.”

“The Army needs to determine concentrations of the other four DNT isomers in soils at the Settling Ponds site and use an approach similar to that used by Wisconsin for groundwater,” deFur added.

“Furthermore, using the industrial standard for soil lead is inappropriate for children and the risks need to be recalculated with higher exposures and the lower blood lead reference value,” deFur concluded.  “The (Army) has not demonstrated that the industrial DNT standards for 2,4 DNT and 2,6 DNT are appropriate and protective for recreational exposures for children and expectant mothers.”

A complete copy of Dr. deFur’s report and other documents are available online at www.cswab.org .

Laura Olah, Executive Director
Citizens for Safe Water Around Badger (CSWAB)
Merrimac, WI  53561


Lenny Siegel
Executive Director, Center for Public Environmental Oversight
a project of the Pacific Studies Center
278-A Hope Street
Mountain View, CA 94041
Voice: 650-961-8918 or 650-969-1545
Fax: 650-961-8918

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