Post-cleanup concentrations of mercury in soil at the former Badger Army Ammunition Plant are still more than 70 times higher than ecological screening levels.
The first warning of trouble occurred when a routine prescribed burn of vegetation by the Wisconsin Department of Natural Resources (WDNR) ignited an underground fire that burned from August 26-28, 2020. Despite millions spent on cleanup, residual soil contamination at the former Badger Army Ammunition Plant still poses a risk to human health and the environment.
The underground fire happened on land that is now owned by the State of Wisconsin and includes a series of interconnected settling ponds that received industrial and sanitary wastewater during the plant’s active production years. The fire occurred within the 5.4-acre Settling Pond #2 (map).
One month after the fire, the WDNR issued a letter to the Army requesting a response action to include additional soil testing, describing the incident as producing “multi-colored smoke and high intensity flames.”
The Army recently published the soil testing results which indicate that the explosive dinitrotoluene (DNT) is present at levels that exceed the soil cleanup goals approved by the WDNR in 2014. Soil sampling in June 2021 detected two forms of DNT (2,4-DNT and 2,6-DNT) at concentrations as high as 87 mg/kg, exceeding the soil cleanup goal of only 11.4 mg/kg. According to the USEPA, DNT is “considered toxic to most organisms, and chronic exposure may result in organ damage.”
Even more concerning, the total concentration of DNT in soil may actually be higher than the Army reports. The WDNR has still not required the Army to test contaminated soils for the additional four forms of DNT (2,3-DNT, 2,5-DNT, 3,4-DNT and 3,5-DNT) present at Badger. All six forms have been found in groundwater at levels exceeding Wisconsin’s Groundwater Enforcement Standards.
The Army’s site investigation also identified dozens of other contaminants that do not have enforceable soil cleanup goals including benzene, dibutyl phthalate, ethyl ether, mercury, nitrocellulose, naphthalene, aluminum and diphenylamine.
EPA Region 5 soil screening levels for protecting wildlife suggest that these unregulated contaminants may be problematic. For example, mercury concentrations are reported as high 7.2 mg/kg – far above the ecological soil screening level of only 0.1 mg/kg.
Between 2009 and 2012, the Army removed approximately 71,500 cubic yards of contaminated soil from the settling ponds. The Army will be conducting additional soil sampling later this year and the scope of work is still pending.
WDNR has an opportunity now to require more comprehensive testing to include all forms of the explosive DNT.
HOW TO HELP:
To voice your support for better soil testing at Badger Army Ammunition Plant, you may send a courteous email to WDNR via Mark.Aquino@wisconsin.gov encouraging the department to:
(1) order expanded soil testing for ALL forms of the explosive DNT at Badger, and
(2) identify soil cleanup goals for all detected contaminants.
NOTE: The Army has announced that the public Restoration Advisory Board meeting originally scheduled for next week is postponed and will be held on April 21, 2022 at 6:30 pm. Details to follow.
MAP of Settling Pond 2 Site Inspection Report Underground Fire Feb 2022