Without any public notice or opportunity for public comment, the Wisconsin Department of Natural Resources (WDNR) has quietly approved an Army proposal that eliminates or significantly reduces regular testing of private wells near Badger Army Ammunition Plant. Of the 75 private wells that have been regularly tested by the U.S. Army in recent years, 55 will no longer be tested or will be tested less frequently.
U.S. Congressman Mark Pocan has asked EPA headquarters to respond to a November 12 letter from Citizens for Safe Water Around Badger (CSWAB) which asks the agency to “assist in facilitating and securing an opportunity for public participation and formal comment on all permit modifications, including the recent changes in private well testing, and other decision-making.” CSWAB also asks EPA to reinstate regular meetings of the Badger Restoration Advisory Board (RAB) which would allow local government and area residents to discuss such issues with the Army as well as state and federal regulators.
“The first and only indication of the Army’s May 14, 2013 Private Well Sampling Reduction Plan and the WDNR’s September 4 final approval was the appearance of both final documents in the public repositories sometime in mid-September,” CSWAB wrote to EPA officials.
According to the Army’s application to the WDNR, the changes were proposed because groundwater contamination had either been detected infrequently or not detected in recent years. A total of 24 private wells will no longer be regularly tested by the Army, in accordance with the WNDR approval.
Some drinking water wells will continue to be tested but the frequency of testing will be significantly reduced. Altogether, 31 drinking water wells – including the Village of Prairie du Sac Well #3 and four water wells at the Dairy Forage Research Center farm – will not be tested as often. Most wells will be tested annually instead of quarterly.
“A significant number of contaminant detects have occurred in the spring, with no detects recorded in corresponding sampling during the fall months. In other cases, detects were recorded for late fall, with no indication of contamination in the spring,” cautioned Lori Huntoon, a professional hydrogeologist hired by CSWAB to review the WDNR plan. “Sampling and analysis should be conducted quarterly, to allow for evaluation of seasonal fluctuations of contaminants.”
The testing requirements for 20 private wells did not change. The residences are located in the Weigand’s Bay area in the rural Town of Merrimac and all will be tested annually. In December 2012, low levels of the explosive DNT were detected in groundwater monitoring wells outside the plant boundary near Ruthe Badger Lane. According to the Army’s report, DNT was not detected in these wells in June of this year.
“Based on sampling conducted during June 2013, DNT continues to be detected in off-site monitoring wells, irrigation wells, and residential water supply wells, at levels exceeding both the Preventative Action Limit and the Enforcement Standards,” Huntoon added. “The question is, why is the sampling of residential water supply wells being reduced at such a significant turning point in remediation of the site?”