In response to Wisconsin DNR concerns about increasing concentrations of the explosive dinitrotoluene (DNT) in groundwater near Badger Army Ammunition Plant, the Army will be increasing the frequency of groundwater and drinking water sampling in several areas at and near the former military base.
At the northeast corner of Badger near Weigand’s Bay in the Town of Merrimac, off-site groundwater monitoring wells have detected DNT as high as 0.232 ug/L (micrograms per liter), exceeding the safe standard of 0.05 ug/L. Groundwater and drinking water testing for DNT will now increase from semi-annual to quarterly. Testing for volatile organic compounds will continue on an annual basis. The closest downgradient residential well has no DNT exceedances, the Army said.
On the far west side of Badger in the Town of Sumpter, DNT concentrations in groundwater have increased dramatically at the former Propellant Burning Grounds. In May of this year, DNT was detected in groundwater at 420 ug/L, far above the 0.05 ug/L standard. The Propellant Burning Grounds are the source of a groundwater contaminant plume that has moved beyond the plant boundary and is discharging to the Wisconsin River just north of the Village of Prairie du Sac.
Earlier this week, the Army issued a statement that DNT was detected at 0.062 ug/L in a private drinking water well in the Water’s Edge neighborhood. “The Army has coordinated with the WDNR, notified the homeowner on 10 July and offered bottled water while we conduct further sampling and assess what actions may be needed,” the Army said.
The important story at Badger Army Ammunition Plant is about what is NOT happening.
State regulators have not enforced and the Army has not complied with a number of critical requirements found in the Wisconsin Department of Natural Resources (WDNR) 2012 groundwater remedial approval which would help inform the best path forward.
For example, in accordance with this permit approval, the Army was to investigate contaminants retained in source area soil associated with known groundwater contaminant plumes. This data would show whether the worst is over, in terms of migration from contaminant source areas, or if there is a significant uncontrolled mass of contamination that threatens groundwater. Never happened.
The WDNR issued permit requirements to conduct adequate saturated and unsaturated soil sampling to determine the nature and extent of site contaminants adsorbed onto the soil. Such testing, the WNDR said, was imperative as “back-diffusion of adsorbed waste constituents appears to be a major contributor to the groundwater plumes’ stability, fully characterizing the adsorbed waste mass is necessary to evaluate natural attenuation as a possible remedial alternative.” Never happened.
While the Army has detected elevated levels of all six forms of DNT in groundwater, the Army has only tested soils and contaminant source areas for 2 forms of DNT. Not one teaspoon of soil at Badger has ever been tested for the remaining 4 forms of DNT. Hence, the adage often applied to Badger – don’t look, don’t find.
These investigative blinders also include two highly toxic contaminants (1,4-Dioxane and PFAS) that the Army has NEVER included in its groundwater or drinking water monitoring at and near Badger. Both have been found in groundwater at other military bases like the Twin Cities Army Ammunition Plant in Minnesota and Fort McCoy here in Wisconsin. CSWAB has petitioned for PFAS testing at Badger since 2005.
In order for Badger neighbors and local government to make an informed decision about the future of our groundwater, we need comprehensive data. For example, do we need to invest additional resources in groundwater monitoring, a municipal water system and/or do we need to invest in controlling the source area and stopping more contamination from reaching groundwater?
The proposed water system will only alleviate the Army’s responsibility to test private drinking water wells. State and federal law require the restoration and protection of groundwater quality and for good reason – at the end of the day, municipal water IS groundwater.
REMINDER: July 25 Meeting
The Army is hosting a public meeting on environmental conditions at the former Badger Army Ammunition Plant on July 25 from 6 p.m. – 9 p.m. in the gallery at the Sauk Prairie School District’s River Arts Center at 105 Ninth Street in Prairie du Sac.
REFERENCES:
CSWAB 2005 Petition for Better Testing at Badger Fire training Areas
Groundwater Remedy Approval WDNR Badger Army June 2012
Groundwater Remedy Public Comment and WDNR Responses 2012
Dinitrotoluene DNT Fact Sheet EPA 2017
1,4-Dioxane Fact Sheet Wisconsin Division of Health 2013
PFAS Community Campaign Fact Sheet July 2018
Open Burning Detonation Sites as Potential Sources of PFAS
Map Groundwater Summary Sept 2017
WDNR Memo Unregulated Contaminants Authority PFAS 2018
Map Groundwater Significant Exceedances May 2018
Army Cover Letter Groundwater Resampling Data June 2018
WDNR Request to Army in Response to Exceedances June 2018
Army Groundwater Sampling Work Plan to WDNR July 2018