Citizens for Safe Water Around Badger submitted formal public comments today urging the Wisconsin Department of Natural Resources to adopt stronger soil cleanup standards that are more protective of children and expectant mothers.

“CSWAB supports many of the additions and clarifications in the proposed revisions to NR 720, particularly new language requiring the assessment of human health risks posed by vapor intrusion of volatile soil contaminants into homes and buildings,” the group wrote.  “However, there are several specific areas within the proposed rule which we believe may not be sufficiently protective of children and expectant mothers for certain routes of exposure such as dermal absorption.”

CSWAB is particularly critical of proposed language addressing risks associated with chemical mixtures.  At the former Badger Army Ammunition Plant, the carcinogenic explosive dinitrotoluene (DNT) is a mixture of six different isomers which has contaminated groundwater and nearby drinking water wells.  The Wisconsin groundwater enforcement standard for a mixture of DNT isomers is more protective than standards for the individual isomers.  CSWAB believes the same approach should be used for soils.

“Given the significant potential for uncertainty, contaminant mixtures warrant an extra level of protection rather than a compromise in excess cancer risk.  This is especially critical in the calculation of risks associated with prenatal exposure to pesticides and endocrine disruptors,” CSWAB wrote.  “For this reason, we strongly recommend that cumulative excess cancer risk for exposure to mixtures be at least or more protective than for individual contaminants.”

Public comments on the proposed NR 700 rule series which address the investigation and remediation of contaminated properties must be received by the WDNR on or before May 31, 2012.  A series of five public hearings was held earlier this month at locations throughout the state.

CSWAB NR 720 formal comments to WDNR May 2012 (PDF file)