Escalating pressure from the Department of Defense has prompted administrators at the Wisconsin Department of Natural Resources (WDNR) to step back from an order which would have made the Army responsible for testing contaminated soils for all six isomers (forms) of the explosive DNT. The WDNR is now seeking support from the U.S. Environmental Protection Agency (EPA) before pushing the military for improved environmental testing at Badger Army Ammunition Plant.

On October 26, the EPA announced that it will be establishing a Provisional Peer-Reviewed Toxicity Value (PPRTV) for the carcinogenic compound – a move that is expected to provide the additional leverage needed to require improved testing and cleanup at Badger and other contaminated federal facilities. Regional agency officials asked EPA Headquarters to establish a PPRTV after reviewing formal recommendations from CSWAB on the need for improved monitoring for DNT at other military sites including Longhorn Army Ammunition Plant in Texas and Radford Army Ammunition Plant in Virginia.

The EPA’s decision is significant given the military’s refusal to address all six DNT isomers when conducting environmental investigations and soil cleanup at Badger. On October 11, the Army issued a formal letter refusing to comply with the State’s September 15 directive.

The military then hired a public relations firm to broadcast a media release saying that it could not justify spending already limited funds to conduct additional testing at Badger. The Army also announced that it would stop all further clean up of DNT-contaminated areas until it received a satisfactory response from the WDNR.

On November 1, WDNR officials temporarily recanted a decision which would have required the Army to test contaminated soils for 2,3-DNT, 2,5-DNT, 3,4-DNT and 3,5-DNT.

“It has come to our attention that the United States Army and the United States Environmental Protection Agency (EPA) are currently examining the issue of testing for these isomers on a nationwide basis through EPA’s Technical Support Project, Federal Facilities Forum,” the state officials wrote. “DNR will defer any further action on this matter until after the deliberations by the Federal Facilities Forum have been completed.”

The forthcoming PPRTV will be the first EPA toxicity value to address mixtures containing all six DNT isomers. The new federal values are expected to help in calculating health risks associated with exposure to contaminated soils, drinking water and air. They are also expected to help in calculating the potential for DNT to migrate from soils to groundwater.

At the same time, EPA officials emphasized that the WDNR does not have to wait for any action from EPA to enforce state environmental regulations that apply at Badger. EPA plans to release the PPRTV in the fall of 2012 which may be too late for a number of cleanup decisions at Badger.

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