CSWAB Questions Hulsey’s Rationale

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Dear Mr. Hulsey,

We have received a copy of your memo regarding the potential for
utilizing Badger Army Ammunition Plant as a “temporary secure work camp
for state Probation and Parole Holds and other state prisoners.” I am
contacting you, as per your letter, for more information about your
recommendations, specifically documentation or studies that support your
proposal as in the best interest of public health and safety, as your
heading suggests.

As you know, CSWAB has been actively monitoring the cleanup and
restoration of the Badger property for nearly a dozen years. All the
information available to us concludes that there are numerous potential
health hazards present at Badger, particularly associated with buildings
and infrastructure.

I presume you know, through your research supporting your current
position, that the Environmental Baseline Survey (EBS) of the closing
Badger facility was initiated by the U.S. Army Industrial Operations
Command in 1998. This report describes the property’s environmental
conditions and will be used to determine the property’s suitability for
transfer.

The purpose of the EBS was to classify discrete areas at Badger into
one of seven standard environmental-condition-of-property types
according to guidance developed by the U.S. Department of Defense and
the Army Materiel Command. The original EBS report, published in August
1998 by Plexus Scientific Corporation, was rejected by the Army; a
revised version of the report was released to the public in March 1999.

While many environmental concerns at Badger were previously identified
during the Installation Restoration Program, the report identified
additional conditions having the potential for significant environmental
and human health impact.

The EBS identified several safety and environmental concerns that may
affect MUCH of the property. Propellant contamination in wastewater
lines could pose a safety hazard if disturbed. Additionally, wastewater
lines may have leaked and could have resulted in soil contamination.
BAAP has requested funding to evaluate these concerns.

Both the operating contractor and the agricultural lessees have used
pesticides at BAAP. The pesticides Monuron, Atrazine, Sevin, Solvit,
Lasso, 2,4-D, Bladex, Thimet, Dalaphon, Furadan, and Simazine were known
to have been used and stored at BAAP between 1974 and 1976. Monuron was
used as a soil sterilant for all vegetation on transformer banks, tank
farms, railroad sidings, and ballast along tracks. Solvit was used for
control of mice and rats, and 2,4-D was used for Canadian and musk
thistle. Since 1987, an outside contractor conducts pesticide
application mainly for tenant activities.

Soils contaminated by the storage, mixing, or handling (but not
application) of pesticides and herbicides are a special waste and may be
a RCRA hazardous waste because of the characteristic of toxicity.
Pesticides, such 2,4-D and atrazine, are suspected to have reproductive
and endocrine-disrupting effects in humans and wildlife according to the
World Wildlife Fund Canada.

Chlorodane is known to have been used to treat soils within earthfilled
barricades at the Indiana Army Ammunition Plant in Charlestown, Indiana.
Past use of herbicides along fence lines at Illinois’ former Joliet
Arsenal are a suspected source of elevated levels of arsenic in adjacent
soils.

Lead was originally added to paint to increase the paint’s durability
and its ability to withstand the elements. Lead can cause permanent
damage to the brain and many other organs, and causes reduced
intelligence and behavioral problems. It can also cause abnormal fetal
development in pregnant women. The Consumer Product Safety Commission
banned the use of lead-based paint in residences in 1978.

Virtually all structures (e.g., buildings and tanks) at BAAP were built
before 1978. All painted surfaces on structures built before 1979
should be assumed to be painted with lead-based paint unless analytical
testing indicates otherwise. Exterior surfaces that were painted with
lead-based paint may have caused some localized soil contamination due
to deterioration of the paint (i.e., leaching, chalking, or flaking).
The levels of lead in soil from paint deterioration are generally
highest along the drip line.

Metal structures, such as water towers or tanks, were sandblasted and
painted regularly. Sandblasting of structures generates fine particles
of paint. Metal surfaces were often painted with paints containing
heavy metals such as lead for corrosion protection. Although the
sandblasting of an elevated structure could spread the generated chips
over a fairly wide area, the greatest concentration of chips would be
expected immediately beneath the structure.

The majority of reported spills and releases of hazardous materials
since 1975 were acids; applied limestone was the common response
action. Spills ranged from 10 gallons to more than 8,000 gallons.
Other spills include 7,000 gallons of 100 percent benzene released on
March 13, 1972 at the Main Ball Powder Plant. The spill occurred inside
a process building during transfer of benzene from a storage tank to an
interior process vessel. The benzene discharged to the floor and
eventually to the settling ponds through the general-purpose industrial
sewer. Other spills include 5,000 gallons of #2 fuel oil discovered in
1991 and 600 gallons of liquid fertilizer in 1981. The Army reports no
records exist for spills that may have occurred prior to 1975.

These are just a few examples of the potential and known environmental
health risks associated with residual contamination resulting from
decades of active production at Badger Army Ammunition Plant. I would
like to understand why you view conditions such as these as desirable
for your proposal. I look forward to your reply and the studies
specific to Badger that support your recommendations.

Sincerely,
Laura Olah
Executive Director

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