In response to growing concerns about potential air emissions from the recently-reactivated decontamination oven at Badger Army Ammunition Plant, Citizens for Safe Water Around Badger (CSWAB) has asked the Army to voluntarily stop thermal treatment of wastes containing paints with high concentrations of PCBs and lead.

Recently released data from the Army indicates that lead has been detected in paint at concentrations as high as 100,000 parts per million (ppm).  By comparison, lead paint is defined as having concentrations greater than 5,000 ppm.  The Army also reported PCB concentrations as high as 59,000 ppm, far above the 50 ppm threshold set by EPA.  Interpretation of this data is currently a point of discussion between WDNR, EPA, and the Army.

Dioxin, which is considered one of the most toxic man-made chemicals ever made, is a common impurity in PCBs.  Both Dioxins and PCBs have demonstrated serious toxic effects and are now under strict regulation. PCBs were banned in the early 80s, but can still be found in soil and sediments, in old paint, concrete, and light fittings.

According to the WDNR, temperatures in the decontamination oven can liberate PCBs to the air and the surrounding environment.  The primary form of PCB used in paint was Aroclor 1254.  In a July 2003 letter to CSWAB, WDNR officials said that it is “likely” that the Aroclor 1254 will volatilize out of paint when heated in the oven at Badger.

The WDNR’s Air Management program subsequently asked that PCB-containing materials not be introduced into the oven “until such time as information is gathered to qualify what happens to any PCB-contaminated paint when exposed to the elevated temperatures in the oven.”

Until recently, the Army complied with this request and did not permit painted material in the decontamination oven in 2006 but permitted a “limited amount” in 2007.

The decontamination oven, located on the far west side of the plant near the Bluffview community, is used to degrade residual explosive material that may be present on pipes, flanges, and other equipment. Equipment is placed into the oven and the temperature is raised to 450° for approximately 2 hours.  These items are then considered safe for sale or reuse.

CSWAB is encouraging the Army to remove PCB and lead paint on equipment prior to placement in the decontamination oven using non-thermal techniques such as hydro-washing with water.  Paint chips are readily filtered from wastewater and then safely disposed.

Lead is added to paint as a pigment, to increase durability, and resist moisture that causes corrosion. Paint with significant lead content is still used in industry and by the military. For example, leaded paint is sometimes used to paint roadways and parking lot lines.

Cease and Desist Request Pending Regulatory Review and Public Participation (.pdf file)

Decontamination Oven Data, March 2008  (.pdf file)