Study of Fire Training Area Doesn’t Measure Up

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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.” To view the entire report, visit their website at www.cswab.org.

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

Citizens for Safe Water Around Badger – www.cswab.org

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:

(Tested parameters and site contaminants are denoted in “bold” type.)

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.

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