A new report released today challenges more than a dozen Army proposals to weaken cleanup goals at the closing Badger Army Ammunition Plant – a move that could save the military tens of millions of dollars in cleanup costs but would leave higher levels of ecological toxins in the environment.

Concerned about the potential long-term risks to the local ecology, CSWAB hired noted wildlife toxicologist Dr. Peter deFur to comment on an Army study that suggests soil contaminant levels at Badger do not pose a risk to wildlife.

DeFur, an Affiliate Associate Professor in the Center for Environmental Studies at Virginia Commonwealth University and President of Environmental Stewardship Concepts, concluded that the Army’s assessment is flawed and fails to show that the cleanup goals previously approved by the WDNR and USEPA are inappropriate.

“The document does little to accurately determine the risks to wildlife in and around Badger,” deFur said. “The report fails to evaluate the potential effects of organic compounds such as nitroglycerin and dinitrotoluene.”

“By not evaluating all compounds present at the site, the military has underestimated the risks to the local ecosystem,” he added.  “Specific wildlife toxins, such as aluminum and tin, were identified as concerns in previous studies but were completely absent in this study.”

“By protecting wildlife, we assure that this land will be safe for hunting, farming, grazing, and conservation,” said Laura Olah, CSWAB’s Executive Director.  “The Army should stick to their commitment to the level of cleanup that was approved by both the Wisconsin Department of Natural Resources and U.S. Environmental Protection Agency in 1993.”

Located at the base of the Baraboo Hills, it is anticipated that the 7,400-acre plant will soon be transferred to new owners, including the Ho-Chunk Nation and the State of Wisconsin.  A portion of Badger has already been transferred to the U.S. Department of Agriculture for its Dairy Forage Research Center.

(Full text of the report is posted below.)


CSWAB has established a fundraising goal of $15,000 to pay for Dr. deFur’s continued work to assess potential risks to human health and the local ecology, including the Army’s proposal to open burn PCB-contaminated buildings – a plan that will release dioxins and other highly toxic substances to the environment.  So far, we have raised only half the needed funds.  Additional support is also needed to help pay for printing, postage, media outreach, and internet expenses for this campaign.  Please consider an extra gift to support this important work!  Every gift, no matter how small, will make a difference!

(Your donation is tax-deductible. Checks should be made payable to CSWAB and mailed to us at E12629 Weigand’s Bay South, Merrimac, WI 53561.)

Comments on the Ecological Risk Assessment No. 39-EJ-1410-96: Settling Ponds and Rocket Paste Area, Badger Army Ammunition Plant, Baraboo, WI. Dated July 9-25, 1996

Prepared by Environmental Stewardship Concepts on Behalf of CSWAB

January 27, 2005


In 1993, a Remedial Investigation (RI) was conducted to determine the risk to wildlife at the Badger Army Ammunition Plant (BAAP). Using computer modeling, the study determined that animals such as shrews, small birds, and others were at great risk due to heavy metal soil contamination.  The RI served as a basis for the establishment of environmental cleanup goals approved by the Wisconsin Department of Natural Resources and U.S. Environmental Protection Agency. After a 1994 report by the U.S. Army Center for Health Promotion and Preventative Medicine (USACHPPM) indicated that the 1993 RI may have overestimated risks to terrestrial organisms, USACHPPM was tasked with reevaluating the impact of metals on wildlife at the facility. The study was conducted during July of 1996, and focused on three species thought to be representative of the wildlife at the site: the short tailed shrew, the eastern meadowlark, and the red fox. The study concluded that wildlife was unlikely to be affected by the contamination at the site. Dr. Peter deFur of Environmental Stewardship Concepts was contracted by Citizens for Safe Water Around Badger (CSWAB) and asked to provide comments on this report.
General Comments

The document does little to accurately determine the risks to wildlife in and around the BAAP. The report focuses on metals, but makes no effort to evaluate the potential effects of organic compounds even though organic compounds such as nitroglycerin and dinitrotoluene are contaminants that were used in the production of ammunition at the facility. Two key metals were also not adequately investigated in the report: aluminum and tin. Both of the metals were found in large amounts in the previous 1993 RI, but were “inadvertently” not sampled in this study. Strangely, aluminum and tin were also not tested during the Small Animal Survey detailed in Appendix C. In the RI, aluminum was found to pose the greatest risk at one sampling location, Settling Pond 4. The fact that these metals were not sampled in either study is troubling, and is evidence of, at the least, gross negligence. In the risk assessment, risks to wildlife were extrapolated from data within the RI rather than sampling the actual levels present in soils and wildlife. This is absolutely unacceptable.  Considering the findings of the previous RI, there was no excuse for these two compounds not to be tested.

A limited number of species were specifically examined in the risk assessment and do not present an adequate representation of the ecosystem at BAAP. No primary consumers (completely herbivorous animals) were evaluated, and neither were any top predators. The species that was selected as a secondary consumer (red fox) is not fully carnivorous, and does not adequately represent those species at the top of the food chain. Risks to the red fox may have been further underestimated due to a flaw in the design of the study. Risks to foxes and short tailed shrews were examined independently, even though the short tailed shrew was included in the risk assessment as a representative of all small mammal species – a primary component of the diet of red foxes. A more accurate method would have been to have included the risk assessment data for short tailed shrews with that of red foxes.

The risk assessment also fails to address other potential sources of exposure besides through the food chain. Organisms can be exposed to harmful metals through drinking contaminated water and also through the inhalation of contaminated dust. Neither of these pathways was examined in the Risk Assessment, resulting in an underestimation of the risks to wildlife.

A major problem in both the Small Mammal Survey and the Ecological Risk Assessment is the location of reference areas. Usually, undisturbed locations are chosen as reference areas because they can provide an accurate point of comparison between potentially impacted areas and those unaffected by human influence. The reference locations of the two mentioned studies are anything but free from human influence. Reference locations in the Risk Assessment and Small Mammal Survey were located across the street from a Nitric Acid Plant, and located in areas dedicated to the production of hay by local farmers. By not selecting appropriate reference locations, the risks to wildlife may have been significantly underestimated.

Many of the toxicological assumptions regarding target animals were flawed. The data used to determine toxicological reference values (TRVs) was based on outdated literature (some dating back to the 1950’s) or focused on compounds not related to the risks associated with the BAAP. This led to the overestimation of TRVs, sometimes by orders of magnitude. Also not accounted for is the potential for harmful interactions between metals. Simultaneous exposure to several metals found in high concentrations at BAAP has been found to have adverse effects greater than what would normally be expected (ATSDR, 2001). Though the ATSDR Interaction Profile detailing these additive effects wasn’t published until 2001, there was sufficient information in the literature at the time available to USACHPPM to consider the potential for such interactions to occur. Notwithstanding the other flaws in the calculations of TRVs, this omission alone has likely caused the risk assessment to greatly underestimate risks at the BAAP.

Specific Problems with the Calculations of TRVs

TRV values – quantitative measures of the toxicity of a chemical to wildlife – were consistently underestimated through a variety of means. Outdated literature was constantly used, one citation was published over 40 years prior to when the Risk Assessment was issued. Sometimes the least toxic forms of metals were evaluated in the TRV. This resulted in the consistent overestimation of TRVs for target organisms, in particular short tailed shrews.

Listed below are specific issues with the calculations of TRVs for each metal. Whenever possible, alternative studies have been cited below as points of comparison. Studies from 1996 or earlier were selected to illustrate that the authors of the risk assessment had ready access to more accurate and up to date literature.

Aluminum: The reference for aluminum toxicity in shrews and red foxes are unacceptably out of date. At the time of the report’s publishing, the Ondreicka study cited was 30 years old. Minimal effort would have been required to find a more current study. A brief search found a 1989 study with a much lower toxicity threshold in mice (Golub et al, 1989).

Arsenic: The studies cited for arsenic toxicity are far out of date. A significant body of research has been performed on arsenic, much of it prior to the 1996 report. Effects thresholds for chronic exposure to arsenic have been consistently lower than those cited.

Cadmium: Behavioral alterations have been noted in mice at as low a dose of 0.4 mg/kg/day (Baranski et. al, 1983). This is well below the 1 mg/kg/day cited in the report.

Chromium: The 1975 Ivankovic and Preussmann study cited on chromium toxicity in shrews evaluates the least toxic form of chromium (chromium III). Chromium VI has long been determined to be the most toxic form of the metal and should be evaluated when determining TRVs (ATSDR, 2000). The unusually high value in comparison to other organisms should have been a red flag. The TRV that was calculated for eastern meadowlarks used an unpublished study as a reference. Studies available to the public should always be used for the sake of transparency.

Copper: The study used to determine the TRV in meadowlarks is incredibly out of date. At the time of publishing, the report cited was over 35 years old. This is unacceptable.

Lead: Lead has consistently been found to cause a wide range of adverse effects at incredibly low doses. The TRV value for shrews is a gross overestimate. Van Gelder (1978) found that pregnant mice exposed to the 8.0 mg/kg/day value estimated as the TRV had 100% reproductive failure. This implies that the TRV should have been estimated much lower.

Mercury: TRV values for shrews are gross underestimates. A two year study by Dieter et al found significantly higher mortality rates in mice at doses as low as 1.9 mg/kg/day. This is well below the 13.2 mg/kg/day used in the report.

Nickel: TRV levels are greatly underestimated. Smith et. al. found lower levels of pup survival after mothers were exposed to 1.3 mg/kg/day. This is well below the estimated TRV for shrews of 40/mg/kg/day, and may imply that TRV values for other species were also overestimated.

Selenium: The study cited in the calculation of the shrew TRV is dated 1954. While the data concurs with that of the current literature, a more current study should have been cited.

Zinc: TRVs for shrews and foxes are underestimated. A 1977 study found adverse effects in mice as low as 70 mg/kg/day, well below the 160 mg/kg/day estimated as the TRV.

Issues with the Small Mammal Survey

The small mammal study cited several times within the report had a number of limitations in design that prevent it from being a reliable source of data in the main report. The study took place over 4 consecutive days, thereby restricting its usefulness in making assumptions regarding the long-term ecological health at the facility. Sample sizes were also too small to perform any sort of accurate statistical analysis, and this is noted by the authors. Despite these admitted statistical limitations, lower metal concentrations found in small mammal tissues are still cited as evidence of lower risk to red foxes. The accuracy of tissue concentrations obtained in the study is also questionable. The exact method used to sample tissues is unclear, however it is mentioned that all animals tested were skinned before they were analyzed. This may have prevented some of the metals stored in those tissues from being analyzed. It is not clear (because the methods are not explained) if the concentrations obtained are calculated from the weight of the animal at the time of capture or after skinning.

The conclusions of the Small Animal Survey are also questionable. Success rates for the traps set at three study areas (SP3, RPE, and RPW) were significantly lower than at other areas. The authors determined that lower success rates were due to lower population densities related to less desirable habitat, but do not seem to consider other factors such as contamination as playing a role. A similar assertion was made regarding a discrepancy in the ratio of juvenile to adult voles. In a normal small mammal population, there are significantly more juveniles than adults. Sampling found the opposite occurring at Badger. The report states that adverse ecological effects may be occurring to push down juvenile populations, but is not mentioned in the conclusions of the Survey. Even though the study was limited by the previously mentioned statistical problems, the report should have at least been consistent in the use of its data.

The most unfounded assertion of the study is that the very presence of small mammals at contaminated sites is evidence of low risk to small mammal populations. Populations of all types of animals, even those that are sensitive to environmental stressors, have been found to be both present and reproducing at contaminated sites. Only surveys conducted over a long periods of time using more relevant reference areas can make accurate conclusions regarding the health of animal populations. This survey did neither.


The Ecological Risk Assessment and Small Mammal Survey do not accurately evaluate the risks to wildlife at BAAP and fail to show that the 1993 RI may have overestimated risks to terrestrial organisms.  By not evaluating all compounds present at the site, USACHPPM has underestimated the risks to the local ecosystem. Most troubling is the absence of aluminum and tin sampling in the report given findings from the previous RI indicating widespread contamination of the two compounds at the site. The Risk Assessment was also hampered by poor study design. The three species selected for evaluation do not provide an accurate representation of the ecosystem of BAAP. USACHPPM consistently underestimated the TRV values used to calculate risk. These issues combined with the poor selection of reference sites has led to the underestimation of risks to wildlife at BAAP.

About the Author:

Dr. Peter L. deFur is president of Environmental Stewardship Concepts, an independent private consultant, serving as a technical advisor to citizen organizations and government agencies. He is an Affiliate Associate Professor in the Center for Environmental Studies at Virginia Commonwealth University where he conducts research on environmental health and ecological risk assessment.  Dr. deFur is President of the Association for Science in the Public Interest (ASIPI) and on the board of the Virginia Conservation Network (VCN).  To view Dr. deFur’s Curriculum Vitae go to http://pldefur.home.igc.org/curr_vitea.htm.


Aughey, E, L. Grant, B.L. Furman, et al. 1977. “The effects of oral zinc supplementation in the mouse.” Journal of Comparative Pathology. 87:1-14.

ATSDR, 2000. “Toxicological Profile for Chromium.”

Baranski B. 1984. “Behavioral alterations in offspring of female rats repeatedly exposed to cadmium oxide by inhalation.” Toxicology Letters, 22:53-61.

Dieter, M.P, G.A. Boorman, C.W Jameson, et al. 1992. “Journal of Toxicology and Environmental Health” 36(4):319-340.

Golub, M.S, J.M. Donald, M.E. Gershwin, and C.L. Keen. 1989. “Effects of  Aluminum Ingestion on Spontaneous Motor Activity in Mice.” Neurotoxicology and Teratology. 11(3): 231-235.

Smith M.K, George E.L, and J.A. Stober. 1993. “Perinatal toxicity associated with nickel chloride exposure.” Environ Res 61:200-211.

Van Gelder, G.A. 1978. “Lead and the Nervous System.” Toxicity of Heavy Metals in the Environment. Oehme, F.W. Ed. Marcel Dekker, New York, NY. Pg 101-121.


Citizens for Safe Water Around Badger (CSWAB) is working to mobilize and empower rural communities near Wisconsin’s Badger Army Ammunition Plant in support of a sustainable future that will protect and restore the integrity of soil, water, air, and biological diversity.

E12629 Weigand’s Bay South,
Merrimac, WI  53561
(608) 643-3124