Earlier this month, at a public meeting of the Restoration Advisory Board for the former 7,400-acre Badger Army Ammunition Plant, the Army reported that of the eight PFAS chemicals detected in groundwater at the southern plant boundary in 2018, concentrations of one PFAS (PFOS) exceed new federal health-based guidelines.
The Department of Defense (DOD) recently issued a memorandum explaining how new health-based Regional Screening Levels issued by EPA will apply to PFAS investigations within the DOD cleanup program. The DOD memo identifies health-based screening levels for 6 PFAS compounds – PFOS, PFOA, PFBS, PFNA, PFHxS and HFPO-DA (Gen-X*) – in groundwater and soil.
In 2018, the highest concentration of PFOS reported in groundwater at Badger was 14 parts per trillion (ppt) – exceeding the new federal screening level of only 4 ppt. Elevated levels of PFOS were detected in a group of groundwater monitoring wells located upgradient of private wells at and near Keller Road in Sumpter Township. The Army has not reported any sampling for PFAS at Badger since 2018.
Last Friday, August 19, CSWAB asked officials with the U.S. Army Environmental Command in Fort Sam Houston, Texas to consider off-site testing for PFAS. Officials told us that an exceedance of Regional Screening Levels is currently not sufficient cause to test downgradient drinking water wells. Officials said that they do not have the authority to test nearby residential wells at this time. The military said it will consider CSWAB’s additional request to provide nearby residents with a written summary of current groundwater conditions relevant to PFAS so that community members could make informed decisions about their well water.
The Army did confirm that the exceedance of Regional Screening Levels for groundwater will trigger a requirement for additional study at Badger and a formal Remedial Investigation is planned. However, given the Army’s current funding cycle, the expanded study will not be initiated until sometime next year, officials said.
In the interim, it is important to note that Regional Screening Levels are NOT the only measure of safety for groundwater as a source for domestic water. The U.S. EPA recently issued a new interim drinking water health advisory of only 0.02 ppt for PFOS – far below the detected 14 ppt at Badger.
Therefore, CSWAB has also approached the Wisconsin Department of Natural Resources, asking that the agency review the current monitoring and private well testing requirements at and near Badger for PFAS, and to assess the potential risk to nearby residential wells. An official response from WDNR is currently pending.
In 2018, more than 100 people, including members of the local Restoration Advisory Board, co-signed a resolution organized by CSWAB asking that the Army test all public and private drinking water systems within a four-mile radius of Badger for PFAS. The resolution also asked that the Army include PFAS analysis in its then-upcoming testing of approximately 300 residential wells near the former military base. The recommended testing was never conducted.
Of interest to local residents, the highest concentrations of PFAS in groundwater at Badger were detected next to Settling Pond #2 – the site of the underground fire in 2020 ignited by a prescribed burn conducted by the Wisconsin Department of Natural Resources.
Per- and polyfluoroalkyl substances (PFAS) are toxic man-made chemicals that are very persistent and mobile in the environment, creating huge groundwater contaminant plumes that readily migrate miles from source areas. Exposure to certain forms of PFAS is associated with low infant birth weights, effects on the immune system, cancer and thyroid hormone disruption.
*The Army has not sampled for Gen-X at Badger Army Ammunition Plant.
FOR MORE INFORMATION:
See maps on pages 34 and 35 of the PFAS Preliminary Assessment for Badger.
Courteous questions about Army policy and decisions may be directed to: clayton.m.dayoc.civ@army.mil
Courteous questions about the WDNR-approved plan for testing groundwater and residential wells near Badger may be directed to luke.lampo@wisconsin.gov
DOD Guidance Memo PFAS Regional Screening Levels July 2022