Road Oil at Badger AAP A Report and CALL TO ACTION by Citizens for Safe Water Around Badger

Jun 28, 2005

Citizens for Safe Water Around Badger has found that historical use of road oil at Wisconsin’s Badger Army Ammunition Plant can be substantiated and that an investigation of the potential environmental and human health consequences is warranted. This report contradicts the Army’s long-standing claim that road oil was never used at Badger and that pursuing this issue is of no value.

Historic Use of Road Oil

The historic use of road oil is not unique to the military.  Used oil was applied to gravel roads as a dust suppressant for many years.  It was most commonly used in rural areas which often had a high proportion of unpaved roads and used oil markets (burning and re-refining) were located some distance away.

“Road oil” refers to any heavy petroleum oil that is used as a dust suppressant and surface treatment on roads and highways.  The use of road oil has declined in recent years because of reductions in the proportion of unpaved roadways, the presence of highly toxic contaminants in used oils (PCBs, dioxins, furans), competition from other used oil end uses (re-refining), and new environmental regulations.  Used mineral-based crankcase oil (used motor oil or used engine oil) contains polycyclic aromatic hydrocarbons (PAHs) and may contain metals such as aluminum, chromium, copper, iron, lead, manganese, nickel, silicon, and tin.

The 52,000-Gallon Tank

U.S. Army records confirm that road oil was indeed present at Badger – and in extremely large quantities.  A July 1983 report published by the U.S. Department of Army documents that Badger Army Ammunition Plant had a 52,000-gallon above ground tank that was used for storing road oil.  A 1977 building inventory by the U.S. Army identified the same facility as “road oil storage”.  By comparison, other used oil storage tanks at Badger hold only 500 to 1,000 gallons.

Badger Army Ammunition Plant has an extensive network of more than 130 miles of roads.  While many of the roads in the core industrial area are paved, the majority of outlying roads at Badger are unpaved.

Drinking Water and Surface Water Resources at Risk

The outwash plain in the western portion of Badger is highly susceptible to infiltration and leaching of contaminants found in road oil because of the highly permeable sand and gravels.  Clays in the eastern sector have a lower permeability but have slopes up to 60 percent which increases surface water runoff.

Surface water runoff from the majority of the Badger property flows south and east to the Wisconsin River and Lake Wisconsin.  The northwest portion of Badger is within the Otter Creek watershed which flows to the southwest and eventually empties into the Wisconsin River.

There are 13 ponds within the Badger site; some of the ponds are formed in borrow pits or are old farm ponds.  Others are natural kettle ponds.  Previous biological surveys have indicated these surface water resources provide valuable habitat for unique fauna, particularly aquatic beetles and amphibians.  The largest water body on the site is the 7-acre Ballistics Pond, which drains about 1000 acres north of the plant and 450 acres of plant property.

Groundwater is the sole supply of drinking water for residents living within a 4-mile radius of Badger.  Two major aquifers are present below Badger Army Ammunition Plant: the outwash aquifer and the underlying sandstone bedrock aquifer.  The outwash aquifer is comprised almost entirely of sand and gravel.  Both are water table aquifers and are hydraulically connected beneath most of Badger.

Worst Case Scenarios Caused by Road Oil

At Lone Star Army Ammunition Plant in Texas, a road oil burial site caused contamination of soils, groundwater, and sediment.  In 1973-1974 an estimated 7,500 gallons of road oil was disposed of in an earthen pit in this area.  Oil was observed on the surface at this site in 1987.  Metals in soils exceeded health-based screening values included arsenic and vanadium.  In groundwater, metals exceeding health-based screening values included beryllium, cadmium, manganese, nickel and zinc; volatile organic compounds (VOCs) were also detected.  Arsenic was detected in nearby sediments exceeding health-based screening values.

In 1982, the nation turned its attention to the town of Times Beach, Missouri when EPA, in a dramatic move for safety, closed it down after discovering dangerous levels of dioxin. The Agency blocked off roads to the town and placed security guards to patrol the site around the clock. Thus began one of the most extensive cleanups in Superfund history.  Years prior, the town regularly had waste oil sprayed on its streets and parking lots to control dust.  Unfortunately, some of that oil was contaminated with dioxin, an unwanted chemical byproduct of certain manufacturing processes.  Upon discovering the contamination, EPA had to permanently relocate more than 2,000 people and demolish all of the homes and businesses.

Wide Beach Development is a 55-acre suburban development of 60 homes located in a small community in New York State.  From 1968 to 1978, the Wide Beach Homeowners’ Association applied about 155 cubic meters of waste oil to the local roadways to control dust. Some of the oil was contaminated with polychlorinated biphenyls (PCBs).  As a result, roads, driveways, parking spaces, storm drains, and homes were contaminated from the oil applications.  In 1980, workers excavated soil from around the roadways while installing a sanitary sewer line in the development.  Unaware that a PCB problem existed, some residents used this soil as fill in their yards and in a community recreational area.  Subsequent sampling revealed PCBs in the air, road dust, soil, vacuum cleaner dust, and water samples from private wells.  Final cleanup actions commenced in March 1990 and the treatment of contaminated soils was completed in September 1991.  In all, more than 36 thousand tons of PCB-contaminated soils and sediments from the site’s roadways, drainage ditches, driveways, yards, and wetlands were treated.

Health Risks Associated PCBs, Dioxins, and Furans

Human exposure to PCBs is a concern because of the wide range of adverse health effects including skin irritation, reproductive and developmental effects, immunologic effects, liver damage, and cancer.  Dioxins and furans can cause a number of health effects, including cancer.  People exposed to dioxins and furans have experienced changes in hormone levels. High doses of dioxin have caused a skin diseased called chloracne.  Studies show that animals exposed to dioxins and furans experienced changes in their hormone systems, changes in the development of the fetus, decreased ability to reproduce and suppressed immune system.

Recent Laws Banning Road Oiling

On September 10, 1992, the U.S. Environmental Protection Agency (EPA) banned the use of used oils for road oiling or as dust suppressants due to the tendency for used oils to contain hazardous wastes or be contaminated with hazardous or toxic constituents.  For these same reasons, Wisconsin Administrative Code NR 590.05(4) specifically prohibits the use of used oil for dust suppression or road treatment.

RECOMMENDED ACTION

The Wisconsin Department of Natural Resources should formally require the U.S. Army to conduct a comprehensive investigation of the potential environmental and human health risks associated with historical use of road oil at Badger Army Ammunition Plant.

Public participation in this environmental health issue is important.  Community members, including local and tribal government, are encouraged to contact the WDNR and voice support for this study.  Contact: Steve Ales, Wisconsin Department of Natural Resources, 3911 Fish Hatchery Road, Fitchburg, WI 53711; telephone (608)275-3310; stephen.ales@dnr.state.wi.us

Sources:

  • United Nations Environment Programme, Secretariat of the Basel Convention, Basel Convention Technical Guidelines on Used Oil Re-Refining or Other Re-Uses of Previously Used Oil, Basel Convention on the Control of Transboundary Movements on Hazardous Wastes and Their Disposal, September 1995.
  • County of Santa Barbara Planning and Development Energy Division, Oil and Gas Glossary, undated.
  • United Nations Environment Programme, Secretariat of the Basel Convention, Basel Convention Technical Guidelines on Used Oil Re-Refining or Other Re-Uses of Previously Used Oil, Basel Convention on the Control of Transboundary Movements on Hazardous Wastes and Their Disposal, September 1995.
  • Department of the Army, Headquarter, United States Army Armament, Munitions, and Chemical Command, Environmental Assessment for Total Plant Operations, Badger AAP, July 1983.
  • U.S. Army Toxics and Hazardous Materials Agency, Installation Assessment for Badger Army Ammunition Plant, May 1977.
  • General Services Administration, Preliminary Highest and Best Use Analysis, Badger Army Ammunition Plant, May 15, 1998.
  • U.S. Army Toxics and Hazardous Materials Agency, Installation Assessment for Badger Army Ammunition Plant, May 1977.
  • U.S. Army Toxic and Hazardous Materials Agency, Master Environmental Plan for BAAP, January 1998.
  • U.S. Agency for Toxic Substances and Disease Registry, Public Health Assessment, Lone Star Army Ammunition Plant, Texarkana, Bowie County, Texas, Appendix C.  July 9, 1999
  • U.S. Environmental Protection Agency, Superfund Redevelopment Program, Times Beach One-Page Summary, June 24, 2004.
  • U.S. Environmental Protection Agency Region 2, Wide Beach Development, New York, NPL Listing History, Site Description, undated.
  • U.S. Environmental Protection Agency, 40 CFR Parts 260, 261, 266, 271 and 279, Hazardous Waste Management System; Identification and Listing of Hazardous Waste; Recycled Used Oil Management Standards, [FRL-4153-6], RIN: 2050-AC17, 57 FR 41566, September 10, 1992.