State regulators have determined that a water supply system proposed by the U.S. Army as the primary final remedy for groundwater contamination at Badger Army Ammunition Plant could help protect public health but, by itself, will not meet environmental protection laws.
“Such a system could be effective in mitigating human health risks, but it will not meet the statutory requirement for restoring the environment to the extent practicable,” the May 24 letter from the Wisconsin Department of Natural Resources (WDNR) to the U.S. Army says.
The Army’s proposed remedy for restoration of groundwater is to allow residual contaminants to naturally disperse and degrade without human intervention. The Army forecasts that over many decades, levels of contaminants found in groundwater will naturally decline on their own.
The WDNR letter asks for additional evidence to substantiate the report’s predictions for each of the three identified groundwater contaminant plumes that have migrated beyond the plant boundary to nearby wetlands, springs and surface water.
Under the Army’s plan, local dairy farmers, graziers, stables, and other farm operators would be expected to abandon their existing livestock wells and pay for water from a municipal system that would be built by the Army and later operated by rural townships.
“Clean water protects public health but it also supports local agribusiness, hunting, fishing, recreation, tourism and food production – it is the foundation of our rural economy,” said Laura Olah, Executive Director of Citizens for Safe Water Around Badger. “The WDNR’s actions are protecting these interests.”
The Army has proposed a multi-year study that would involve the shut-down of a massive groundwater extraction and treatment system (MIRM) that captures toxins before they move beyond the plant boundary to the Wisconsin River at Prairie du Sac.
“Before we would authorize a shut-down of the MIRM and approve of natural attenuation on a trial basis, the Army will need to illustrate that natural attenuation has a reasonable probability of restoring groundwater to the extent practicable,” the WDNR letter said.
Groundwater contaminants found at Badger include carcinogenic solvents and the explosive DNT. Certain forms of DNT have not been shown to biodegrade and have been detected in groundwater monitoring wells located several miles from the hazardous waste sites where they originated.
CSWAB is hoping that the Army will be required to test contaminated soils for all six isomers (forms) of DNT as part of the current investigation. Soil testing to date has been limited to only two of the six known forms of this carcinogenic compound.
The Army had planned to petition for the creation of a water district by July 2011. The preparation of a new revised proposal will require a change in the Army’s project schedule, the WDNR acknowledged.
(Photograph: Lower Wisconsin Riverway at Prairie du Sac, CSWAB.)