CSWAB Victory Sets National Precedents for Munitions Cleanups

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The State of Wisconsin has adopted groundwater standards for previously-unregulated munitions contaminants that set national precedents for the protection of public health and the environment. Wisconsin is the first state to establish groundwater standards for all six isomers of the carcinogenic explosive dinitrotoluene (DNT). The state has also set an enforceable standard for perchlorate, a toxic constituent in solid propellants, which will be the lowest in the nation.

Citizens for Safe Water Around Badger (CSWAB) first petitioned for regulation of DNT in 2006 when it became evident that adequate cleanup of Badger Army Ammunition Plant and other contaminated military sites would only be achieved with enforceable standards. With the new rules in place, the group will petition the Army to expand environmental testing of soils and sediments to include all six isomers of DNT. The precedent-setting standard will also be significant for hundreds of waste sites across the country contaminated with DNT where it is often found as a byproduct of TNT manufacturing and disposal.

No other state has established standards for the less-common isomers of DNT which have affected hundreds of wells in and around the Badger munitions plant. Wisconsin will regulate all six isomers of DNT as a single entity and the enforcement standard will be 0.05 parts per billion (ppb). In March of this year, total DNT concentrations in groundwater at Badger were as high as 2,200 ppb.

Wisconsin has also adopted a groundwater standard of 1 ppb for perchlorate – an oxidizer in solid propellants for rockets, missiles, fireworks and explosives. California adopted a drinking water standard of 6 ppb in 2007, and Massachusetts set a drinking water standard of 2 ppb in 2006.

CSWAB played an important role in reducing the initially-proposed perchlorate standard from 7 to 1 ppb. The group submitted hundreds of pages of public testimony, including a technical memo from a leading scientist with the Natural Resources Defense Council, supporting a more protective standard for perchlorate.

Toxicologists with the Wisconsin Bureau of Public Health reviewed CSWAB’s submittals and agreed that the lower threshold was necessary to protect several population subgroups, such as breast-fed babies, that may be affected by very low levels in food or water. Perchlorate can disrupt the uptake of iodide in the thyroid, potentially interfering with thyroid function and negatively affecting fetal and infant brain development and growth.

The new rules are expected to go into effect by early 2011.

Examples of U.S. Sites where DNT has been identified as a Contaminant of Concern:

  • Region I: Camp Edwards Study Area (MA)
  • Region II: Vieques, Puerto Rico (DNTs are potential contaminants of concern; investigations are still pending)
  • Region III: Radford Army Ammunition Plant (VA), Fort Belvoir – Engineering Proving Ground site (VA)
  • Region IV: Alabama Army Ammunition Plant, Milan Army Ammunition Plant (TN), Volunteer Army Ammunition Plant (TN)
  • Region V: Badger Army Ammunition Plant (WI), Former DuPont Barksdale Works (WI), Savanna Army Ammunition Plant (IL), Joliet Army Ammunition Plant (IL), Ravenna Army Ammunition Plant (OH), Twin Cities Army Ammunition Plant (MN)
  • Region VI: Fort Wingate Army Depot (NM), Louisiana Army Ammunition Plant (LA), Longhorn Army Ammunition Plant (TX)
  • Region VII: Weldon Spring Ordnance Works (MO), Nebraska Ordnance Plant, Iowa Army Ammunition Plant, Sunflower Army Ammunition Plant (KS), Cornhusker Army Ammunition Plant (NE)
  • Region VIII: Pueblo Chemical Depot (formerly Pueblo Army Depot)
  • Region IX: Hawthorne Army Depot (NV)
  • Region X: Umatilla Army Depot (UT)
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