The proposed remedy for groundwater contamination emanating from the former Badger Army Ammunition Plant may not comply with Wisconsin groundwater laws, according to a new report released today by Citizens for Safe Water Around Badger (CSWAB).
“The Wisconsin Groundwater Law (Wisconsin Act 410) protects each aquifer regardless of its potential use, value or vulnerability,” said Lori Huntoon, a professional hydrogeologist hired by CSWAB to monitor groundwater cleanup at Badger.
“Allowing the military to shut down the current groundwater remediation system, without further measures in place to reduce the continued migration of contaminants to groundwater, does not provide adequate protection to the sand and gravel aquifer,” Huntoon said. “This and the proposed installation of a municipal water supply system in lieu of additional cleanup closely resemble aquifer classification, which is not allowed under the State’s Groundwater Law.”
The concern about the long-term recovery of groundwater resources near the Badger Army Ammunition Plant comes on the heels of a proposal by the U.S. Environmental Protection Agency (EPA) Superfund office to ease its policy which requires contaminated groundwater to meet health-based drinking water standards – a policy shift that CSWAB believes will place both local and the nation’s groundwater resources at even greater risk than before.
“If approved, EPA’s proposal would be a clear and powerful incentive away from environmental protection and pollution prevention,” said CSWAB Executive Director Laura Olah. “Why should the Department of Defense and other large-scale hazardous waste generators invest in technologies and practices that protect and restore groundwater when EPA suggests they may be let off the hook when contamination becomes pervasive or difficult to remediate?”
Olah believes EPA’s proposal also conflicts with Wisconsin’s long-standing commitment to protecting both groundwater quality and quantity.
“Assuring an adequate supply of clean groundwater is critical for both public health and the State’s economy, particularly agriculture,” Olah emphasized. “We believe that EPA’s proposal contradicts State laws and rules intended to preserve the quality and quantity of water available for ourselves and for the future.”
In October 2012, the military formally proposed ending active pump-and-treat of a major groundwater contaminant plume from Badger Army Ammunition Plant that flows near the Village of Prairie du Sac. The shutdown was conditionally approved by the Wisconsin Department of Natural Resources two months later in December. The principal groundwater contaminants are solvents and the explosive DNTwhich is classified as a probable human carcinogen.
From 2002 through March of 2012, levels of total DNT in groundwater inside Badger consistently exceeded the state’s health-based standard of 0.05 parts per billion (ppb). Total DNT in one monitoring well fluctuated from less than 1 ppb in 2001 to a high concentration of almost 10 ppm in 2002, then increased to over 1,000 ppb total DNT from 2009-2011 and 500 ppb in 2012. This level of DNT indicates that there continues to be a source impacting the groundwater.
“The Army needs to implement better control of the source area before the groundwater can naturally recover,” Huntoon cautioned. “The alluvial sand and gravel aquifer of the Wisconsin River Basin, as well as underlying aquifers, should be protected to the extent possible in order to provide adequate water supply for current use as well as into the future.”
EPA says it plans to consult with States on whether or how to weigh groundwater uses when setting cleanup objectives. The title and focus of the upcoming annual meeting of the Association of State and Territorial Solid Waste Management Officials (ASTSWMO) in Washington, DC later this month will be “Challenges with Groundwater: Protection of the Environment vs. Cost of Remediation”. Invited participants include officials from EPA headquarters and the U.S. Department of Defense.