Wisconsin Groundwater Standards for Explosives Will Set Precedent

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A precedent-setting move by the Wisconsin Department of Natural Resources (WDNR) is being applauded by rural neighbors of the Badger Army Ammunition Plant but is expected to draw strong opposition from the U.S. military.

The WDNR recently received approval from the Natural Resources Board to hold public hearings related to the addition of 15 new substances to the State’s groundwater quality standards including all forms of dinitrotoluene (DNT) – a carcinogenic explosive that has contaminated dozens of drinking water wells near Badger in the rural townships of Merrimac, Sumpter and Prairie du Sac.

If approved by the legislature, Wisconsin will set a precedent for other states, and could be significant for over a hundred sites across the country contaminated with DNT.

Based on recommendations from senior toxicologists at the Wisconsin Division of Public Health, all 6 isomers (forms) of DNT will be regulated as a single entity.  The proposed standard is 0.05 parts per billion – equivalent to the current Health Advisory Level (HAL) recommended by state health officials.

The Army opposed the establishment of the HAL altogether.  In an August 17, 2007 submittal to the Wisconsin Division of Health, the U.S. Army Center for Health Promotion and Preventive Medicine wrote: “The current toxicology database for the minor isomers of DNT is not sufficient to support development of a health advisory for these isomers”.

“The lack of enforceable groundwater standards – state or federal – places disadvantaged community members at disproportionate risk, especially if they do not have the resources or capacity to pay for a new well or take other actions to protect their health,” said Laura Olah, Executive Director of Citizens for Safe Water Around Badger (CSWAB).  “If their drinking water is no longer potable, these families may be unable to sell their home, they may lose their mortgages, and they will certainly lose value in their property.”

While CSWAB is endorsing the proposed groundwater standard for DNT, the group is hoping for a more protective standard for perchlorate – the main ingredient of rocket and missile fuel.  Perchlorate acts on the thyroid gland to inhibit its ability to make the thyroid hormones that are necessary for normal infant and childhood growth and brain development.

CSWAB would like the State’s proposed standard reduced from 7 to 1 part per billion (ppb) – a level that is consistent with recommendations from the National Resource Defense Council, Environmental Working Group, and others.  As recently as September, CSWAB co-signed a nationally circulated letter encouraging the U.S. Environmental Protection Agency (EPA) to establish a more protective reference dose and promulgation of a maximum contaminant level that is no higher than 1 ppb for perchlorate.

In Wisconsin, the 2,3-DNT isomer has been detected in 103 groundwater and private water wells at concentrations as high as 2,200 ppb.  The 3,4-DNT isomer has been detected in 37 wells at levels as high as 419 ppb.  The 3,5-DNT isomer has been detected in 20 wells at concentrations as high as 23.9 ppb and the 2,5-DNT isomer has been detected in wells at concentrations as high as 1.5 ppb.

All of the DNT isomers have been detected in groundwater in and around Badger.  DNT contamination has also been found at other sites in Wisconsin including the former DuPont Barksdale Works Site in Bayfield.

Written comments on the amendments to ch. NR 140, Wis. Adm. may be submitted until December 30, 2009 via U.S. mail to: Mike Lemcke, Wisconsin DNR, Bureau of Drinking Water & Groundwater, PO Box 7921, Madison, WI, 53707 or by email to: Michael.Lemcke@Wisconsin.gov.  Written comments, whether submitted electronically or by U.S. mail, will have the same weight and effect as oral statements presented at the public hearings.  For more information or a copy of the proposed rule and fiscal estimate contact Mike Lemcke at – (608) 266-2104.  The hearings will be held on the following dates at the locations listed:

  • December 11, Madison – 10 a.m., in the State Natural Resources Building (GEF 2), Room G09, 101 South Webster St.
  • December 14, Baraboo – 10 a.m. at the Sauk County – UW Extension, West Square Administration Building, Room B30, 505 Broadway.
  • December 15, Eau Claire – 10 a.m. at the Eau Claire State Office Building, Room 139, 718 West Clairemont Ave.
  • December 15, Stevens Point – 4 p.m. at the UW-Stevens Point, Communications Arts Center (CAC), Room 211, 1101 Reserve St.
  • December 16, Oshkosh – 10 a.m. at the UW-Oshkosh, Halsey Science Center, Room 259, 921 Elmwood Ave.

Citizens for Safe Water Around Badger (CSWAB) formally petitioned the state to regulate all forms of DNT in 2006.  The group was organized in 1990 when rural families near Badger Army Ammunition Plant learned that private drinking water wells were polluted with high levels of cancer-causing solvents.  The group continues to serve as a local watchdog and national leader on military cleanups.  For more information, visit their website at www.cswab.org or telephone (608)643-3124.

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