Citizens for Safe Water Around Badger: Badger soil cleanup may not be protective

An environmental scientist has reviewed the Army’s Feasibility Study for a major site at the Badger Army Ammunition Plant and found that proposed changes in the level of soil cleanup may not be protective of human health and wildlife.

According to a technical review by Dr. Peter deFur – an expert hired by Citizens for Safe Water Around Badger to review the Army study – proposed increases in soil remediation goals and the elimination of at least seven contaminants of concern are not protective of all human and ecological receptors.

“The remedial goals are insufficient for (the explosive) DNT because the (Army’s study) does not address the combined mixture of all 6 isomers, which could be conducted using basic assumptions used by the state of Wisconsin in developing groundwater standards for DNT,” deFur said. “Toxicologists with the Wisconsin Division of Health found that the lesser isomers of DNT (2,3-, 3,4-, 3,5-, and 2,5-DNT) are as toxic or more toxic than 2,4- and 2,6-DNT.”

“The Army needs to determine concentrations of the other four DNT isomers in soils at the Settling Ponds site and use an approach similar to that used by Wisconsin for groundwater,” deFur added.

“Furthermore, using the industrial standard for soil lead is inappropriate for children and the risks need to be recalculated with higher exposures and the lower blood lead reference value,” deFur concluded. “The (Army) has not demonstrated that the industrial DNT standards for 2,4 DNT and 2,6 DNT are appropriate and protective for recreational exposures for children and expectant mothers.”

The Army’s proposal updates a previously approved Feasibility Study from 1994 in which the Army proposed, and the State of Wisconsin approved, remedial goals for contaminated soil at the 60-acre Settling Ponds site. The Army now proposes to significantly revise the remedial goals for soil that will remain following excavation and placement in a landfill on site.

A complete copy of Dr. deFur’s report is available online at http://www.cswab.org.