NORTH FREEDOM — Twenty years ago, the Army began a massive cleanup effort at what was once the world's largest ammunition factory.
Most of Badger Army Ammunition Plant’s buildings were demolished, its 7,500 acres about 30 miles northwest of Madison divided to be used for agriculture and recreation. The groundwater there was tested by the Army regularly to determine the effects of rocket propellant, gunpowder production and several toxic chemical spills.
To insulate local residents from any groundwater contamination, the Army proposed a solution — a $20 million municipal water system to serve 400 households living near the former plant, the majority in the town of Merrimac. The system would create a separate source of clean water, which would come from a well unaffected by Badger plant contamination. The Army would pay to hook up homes to the system so they would no longer have to rely on private wells that could be at risk for contamination.
In 2010, the Army said it could have the system up and running in about three years.
Seven years later, there is still no system.
The Army now says it is on hold indefinitely while it does more testing and reevaluates whether it had the authority to propose the municipal water system in the first place.
The Army’s decision to pull back frustrates residents, local officials, conservationists and lawmakers who want answers and accountability. They want the Army to fulfill its promise. They want assurances that their drinking water isn’t contaminated.
That lack of assurance highlights an ongoing problem at Badger: no one knows the full scope of contamination, if it exists, where it is, how much is there and how it might affect drinking water in the future.
“They sold a bill of goods and didn’t deliver the final product,” said Tim McCumber, the Merrimac town administrator, who has been working on the water system issue since 2010. “We only knew they were pulling the plug because of (U.S. Sen. Tammy) Baldwin’s office.”
The Army continues to test private, residential groundwater wells around the area for contaminants, but the plant’s full toll on the groundwater and soil continues to be murky. Though the Army has eradicated some contaminants at Badger, the cleanup effort has been focused on specific, risky areas of the plant rather than the whole site. There have been no comprehensive tests and data collection on chemical dumps or their effect when the plant was in operation, or since it has closed. Contaminants can also migrate through soil and water, making identifying and eliminating them difficult.
The Army has found four plumes — sections of groundwater full of toxic contaminants — from the Badger Army site that has contaminated drinking water. Bits of water pollution move from those sections and pollute private wells. The Army monitors the plumes through separate wells and has tested private wells to check for contamination since the plant shut down.
For those who live near Badger, possibly contaminated water has meant that home values have stagnated and some must rely on bottled water, McCumber said. But those who want a more secure source of water are left waiting.
The Badger Army Ammunition Plant was built in 1942 for World War II and was one of 77 government-owned, contractor-operated plants that supplied explosives and propellant ammunition used by the U.S. military to launch rockets. It was active through 1945, then was closed and reactivated to make ammunition for the Korean and Vietnam wars through 1975. Over the course of its operation, Badger Army employed more than 23,000 workers.
Now it is a vast, picturesque prairie land with patches of trees and long grasses, shrubs and wildflowers. There are a handful of buildings left, including a rickety wooden train depot next to tracks running through the site. Roads once used by military vehicles are overgrown and rutted. The site was divided and is now owned by three entities: the Wisconsin Department of Natural Resources, the U.S Department of Agriculture Dairy Forage Research Center and the Ho-Chunk Nation. Parts of the site run by the DNR have become the Sauk Prairie State Recreation Area where people can hunt, hike, bike or birdwatch. The USDA uses the land for research and the Ho-Chunk Nation is working on clearing away invasive brush and hopes to put bison on the land.
The towns of Sumpter, Prairie du Sac and Merrimac border portions of the Badger site. Merrimac is the closest, with the most residents possibly affected by groundwater issues. The town of about 1,000 people on Lake Wisconsin is a popular vacation destination and is near Devil’s Lake State Park.
The municipal water system promised to the town of Merrimac stalled in April when the Army notified Sen. Tammy Baldwin’s office that its representatives had “acted prematurely and beyond their area of authority” and said the municipal water system would be “inconsistent with our authority under the Defense Environmental Restoration Program,” a federal program that directs how former military sites are cleaned.
McCumber said he doesn’t understand what is causing the delay. He has been working with Army officials since they approached the town with the proposal and has tried to educate and inform residents about the plan and what it means.
“We were told they were going to get final sign-off and get funding in May 2015,” McCumber said of the Army. “I know they had to get approval every step of the way.”
The Army now says it did not get proper approval for the project to comply with federal law. It specifically failed to properly fill out and annotate a key piece of paperwork called the “Decision Document,” said Cathy Kropp, a spokeswoman with the U.S. Army Environmental Command.
“A required step in the cleanup process was not completed prior to the review leading up to the selection of a groundwater remedy. Approval of that remedy in the Decision Document is required by the Assistant Chief of Staff for Installation Management (ACSIM) before implementation,” Kropp said in an email.
“After review of the Decision Document, which included construction and operation of a public drinking water system near the former BAAP as part of the proposed remedy, the Army’s environmental and legal experts concluded that Army’s construction and operation of a public drinking water system is not authorized within the Army’s existing legal and funding authorities.”
The Army said it has developed a “path forward” with the Wisconsin DNR, which initially approved the municipal water system plan and the stipulations attached to it.
The Army has scheduled a meeting for July 26 at 6 p.m. at the Sauk City Public Library, 515 Water St., in Sauk City, to share the plan.
At the meeting, the Army will answer questions and update residents on the latest groundwater sampling results and overall progress of cleanup. The latest monitoring data was published May 31, Kropp said, and is available for the public to review at the library.
The Army will also discuss the status of the public water system and the “next steps in the cleanup process and solutions for continued assurance of safe drinking water for residents potentially impacted by past operations at the former BAAP,” Kropp said.
The Wisconsin DNR said it has not “been officially told that the Army is not going to install a municipal drinking water system,” according to agency spokesman Andrew Savagian.
“If so, the Army would need to provide an alternative remedy for groundwater to the municipal water supply system that they previously proposed and DNR approved,” Savagian said in an email.
While the state and the Army figure out what’s next, lawmakers want accountability.
“The bottom line is that it was an Army ammunition plant, and they have obligations under the change in ownership of the property to make sure that water is safe,” said U.S. Sen. Tammy Baldwin, who has been working on drinking water issues at Badger since 1998. “I believe we have to hold the United States Army accountable to their legal obligations of the people of Sauk County and the proximity of Badger Army Ammunition Plant.”
Baldwin said she has pushed for more information and transparency from the Army about what happened to delay the project after years of planning, millions of dollars spent, and approval from Army officials. In a 2016 response letter to Baldwin after she asked for an update on the system’s progress, the Army said the approval process was set to conclude in 2017 and construction completed in 2020.
“There were water contamination issues from day one. There have been lots of issues with communication between neighbors of the landowners who simply want answers and reliable information,” Baldwin said. “One of the things we’ve tried to do is push for clear communication, push for reliable answers and push for action.”
U.S. Sen. Ron Johnson has also asked for accountability.
In a June 18 letter to J. Randall Robinson, acting assistant secretary of the Army for Installations, Energy and the Environment, Johnson asked the Army to continue with the water system.
“I've been told your predecessor, Katherine Hammack, personally gave her word that this important drinking water system would be installed at the Army’s expense,” Johnson wrote. “I urge the Army to begin construction of the municipal water system as soon as possible. I also request that the Army share an updated timeline for completion of this project with the citizens of Sauk County.”
An agreement approved by the state DNR in 2012 allowed the Army to reduce groundwater testing, which it has done, in exchange for building the system, which it has not. McCumber is urging state and federal lawmakers to push the Army to comply and the state DNR to hold them to it.
“They’re in violation of that approval from the DNR,” McCumber said. “The DNR needs to take enforcement action.”
The DNR disagrees and said the Army has not officially backed out, but merely changed the plan. The agency said installation of the water system was never a condition to changes of how the Army is monitoring water contamination at Badger.
“There are no current violations. The Army proposed a public water system as part of their 2011 Revised Feasibility Study and the DNR approved that plan. The Army, like other responsible parties, is allowed to change their plans as long as they are protective of human health and the environment,” said Jason Lowery, a hydrogeologist at the DNR who works on Badger Army issues. “The DNR’s recent approvals for the Army to shutdown the treatment system and revisions to their monitoring program (which included installation of some new wells) were not conditional upon the Army installing the public water system.”
Lowery said the Army is set to submit a new plan to the agency this fall.
Since 2012, the Army has gradually phased out testing, according to the DNR. That reduction in testing had already started in anticipation of the water system, McCumber said.
Since the decrease, the Army has not found contamination in any private wells. If it did, it is required to notify the DNR and determine a course of action which could include replacing the well or increasing testing, according to the DNR.
But if the Army is testing fewer wells, there’s no way to know if a resident’s well is or is not contaminated, McCumber said.
The water system was meant to be a safety net insurance policy, eliminating all risk that a private residential well was contaminated, McCumber said. If that never materializes, testing must increase, he said.
“We want them to go back to their pre-2010 monitoring levels,” he said. “People need a resolution to this problem.”
The Army has not said it will do that, but has assured lawmakers and McCumber in letters over the last several months that it is committed to protecting human health and the environment at Badger.
A persistent problem at Badger is that no one knows how much contamination exists, how it travels underground and when or if it will continue to contaminate drinking water.
McCumber said he cannot tell homeowners in Merrimac that their wells are not or won’t ever be contaminated.
“Nobody here will ever know what that ultimate health risk is, if it exists,” he said.
McCumber said he has worked with lawmakers representing the district where Badger sits, including Sens. Baldwin and Johnson, former U.S. Rep. Tom Petri, state Sen. Jon Erpenbach, D-Middleton, and Rep. Dave Considine, D-Baraboo.
“Regardless of what the Army ends up doing, the DNR needs to keep testing,” said Erpenbach. “This isn’t anything Merrimac did to itself, this is what the Army did to Merrimac… rather than testing a well here or there, I would hope they are testing everything, “ Erpenbach said.
Though there has been no ammunition production at Badger Army for more than two decades, it is unclear to what degree there was dumping of toxic chemicals at the factory prior to shutdown. In 1983, a hazardous materials and pesticide management study by the Army found “no accurate records exist as to type or quantities that may have found their way into the environment.”
A primary contaminant of concern at Badger Army is dinitrotoluene, or DNT. It is an explosive chemical compound first found by the Army in groundwater at Badger in 2010 and at varying levels in groundwater since then. DNT is used in ammunition production. It is not found naturally in the environment and is considered toxic to most organisms, according to the Environmental Protection Agency.
The EPA has labeled DNT as a high-risk contaminant because it can be released into ground or surface water. It absorbs well into the soil and has low volatility, unless degraded by light or oxygen.
“Releases to water are important sources of human exposure and remain a significant environmental concern,” according to a 2015 EPA fact sheet.
The cleanup approach for both groundwater and soil at Badger, and other military sites across the country, is “monitored natural attenuation.”
Monitored natural attenuation is a process where the Army monitors the site, but essentially does nothing, allowing the environment to naturally break down any contaminants.
An earlier attempt to ensure that groundwater was clean was an expensive “pump and treat” method. The Army pumped millions of gallons of groundwater near the Badger Army site, cleaned it, then dumped it into the Wisconsin River in an attempt to capture contaminants. But the effort was minimally effective. In 2011, shortly before the abandoning the effort, the Army recovered 18 pounds of contaminants.
Other cleanup projects included implementing a “soil vapor extraction system” from waste pits on the site in the late 1990s and excavation of contaminated soils.
In 2012, the state DNR approved the monitored natural attenuation approach.
“The Army has concluded that (natural attenuation) processes, such as dispersion, absorption, dilution and volatilization are having a stabilizing effect on the volatile organic compounds in groundwater,” the DNR wrote to the Army at the time. “Natural attenuation (NA) is a common groundwater contamination remediation strategy in Wisconsin. Compliance with Department administrative codes and policies is required for monitored natural attenuation (MNA) to be the acceptable final remedial alternative.”
Some residents and local officials are skeptical of that approach.
“The Army can’t guarantee this problem will ever go away and there’s no guarantee the monitored natural attenuation will work,” McCumber said.
Soil contamination is another area of concern for local citizen groups monitoring cleanup at Badger. The Army has done some cleanup of contaminated surface soil from the chemical dump sites, including scraping and testing surface soils as it demolished buildings.
The Army also partially excavated two major dumping sites, put contaminated soil in landfills and capped them, but a comprehensive soil study for the entire Badger site was never done.
The Army and the state DNR put deed restrictions in place for certain sections of land to prevent activities that could disturb the soil there in order to minimize potential exposures.
Laura Olah, executive director of Citizens for Safe Water Around Badger, or CSWAB, feels more should be done.
“The soils in certain areas at Badger pose a risk to plants and animals and people if disturbed,” said Olah, whose house borders the site. “The way they’re looking to protect people is to limit the use of that land. The Army was able to leave some tainted soil because of deed restrictions on certain uses and activities.”
“We pushed the cleanup as far as we could for these sites but in terms of ecological risk, that falls to the facility to conduct any additional testing in more areas,” Olah said.
She has been working on water issues at Badger for more than two decades and still has her well tested by the Army.
“Nationally, the conversation has turned from, ‘What’s the best possible cleanup?’ to ‘How much contamination can we leave behind and still get some closure?’” she said. “All we’re doing is deferring the problem for contaminants that don’t break down in the environment. It’s still going to be there.”
The Army and the DNR have responded to some concerns from residents and lawmakers. The DNR issued guidelines earlier this year for how much DNT should be permissible in drinking water and the Army issued a new plan for testing more wells last month.
CSWAB petitioned the DNR in 2015 to create Health Advisory Levels, or HALS, for DNT and the products it degrades into. The DNR issued the Health Advisory Levels in April. The drinking water guidelines are the first of its kind at the state or federal level for four DNT byproducts, according to CSWAB.
The creation of HALS is crucial, Olah said, because some DNT byproducts don’t degrade naturally and can potentially be more toxic than the original DNT compound. There is still a gap in understanding and data in how DNT breaks down and its effect on the soil and groundwater.
“We have no data,” she said. “How much DNT is still in the subsurface soil and what does that mean if that would all migrate down to groundwater? What’s the extent of the problem going to be? How long are these plumes going to be there? Those are some questions.”
State regulators can now use the advisory levels at Badger as benchmarks when evaluating cleanup plans and water test results.
In response to HALS, the Army has agreed to test its monitoring wells and a few private wells this fall to ensure they are within the state’s drinking level guidelines.
In a June 22 proposal, the Army said it would test 17 monitoring wells and three private wells during the September 2017 sampling round. Groundwater samples will be collected from each of the four plumes.
“The laboratory will analyze the water samples utilizing a Wisconsin Department of Natural Resources (WDNR) approved method for each DNT breakdown product,” according to the proposal.
The Army said the new testing is a piece of its plan, but is not comprehensive. It will put the results of its sampling in the information repository at the Sauk City Public Library when results are available, said Kropp, the Army spokewoman.
“While no regulatory standard exists for the monitoring or cleanup of Dinitrotoluene (DNT) breakdown products, the Army will conduct sampling for several DNT breakdown products to assess and monitor the natural attenuation of DNT contamination,” Kropp said.
The move is significant, said Olah. Testing wells regularly for the specific DNT contaminant helps ensure that private sources of water are clean, which protects residents whether or not a public water system is built, she said. Her group has not taken a position on whether the system is a viable solution.
“Irrespective of this municipal water system, we still have this ongoing effort to remediate groundwater,” Olah said. “Even if you have municipal water there’s still responsibility required, responsibility to restore the groundwater. That has to continue even if we were to have a municipal water system now. That would not relieve the Army of that responsibility because we still need clean groundwater.”
“You’d be surprised that people often don’t know where their drinking water comes from,” Olah said. “It’s one of those things you take for granted.”