Coalition Seeks to Block U.S. Army's Open Burn of PCBs

MADISON, Wisconsin, March 23, 2004 (ENS) - A coalition of 67 organizations is formally opposing open burning of polychlorinated biphenyls at the Badger Army Ammunition Plant – a proposal that the groups fear would set a national precedent and open the door to similar exemptions at military and civilian facilities across the United States.

In a letter sent Monday to the U.S. Environmental Protection Agency (EPA), the groups are opposing a move by the U.S. Army to seek an exemption to a federal EPA law that prohibits open burning of wastes containing more than 50 parts per million of polychlorinated biphenyls (PCBs).

PCB concentrations in paint in certain buildings at Badger have been detected as high as 22,000 parts per million – more than 400 times the permissible limit set by the EPA.

“The mere thought of open burning PCB contaminated materials is preposterous,” said Craig Williams, director of the Chemical Weapons Working Group. “EPA regulates burning such materials by requiring 99.9999 percent destruction, even in incinerators. In the Badger proposal there is zero control; zero monitoring; and, zero ability to determine the quantity of this probable human carcinogen released into the environment.”

The powerhouse on the Badger Army Ammunition Plant site. (Photo courtesy U.S. Army)

Developed and operated by the Army as a production facility for powder propellants between 1942 and 1975, the plant has been decommissioned and is now considered surplus. The property contains some 1,400 buildings, most of them abandoned, and extensive plant infrastructure including rail lines, a heating plant, roadways and bunkers. Many of the structures must be demolished due to structural problems or contamination with explosive residues

Negotiations are underway to transfer the property jointly to the state of Wisconsin, the Ho-Chunk Nation, and the U.S. Department of Agriculture Dairy Forage Research Branch.

The Badger Army Ammunition Plant (BAAP) is set on 7,354 acres of land in Sauk County, Wisconsin. It is bordered on the north by Devil's Lake State Park, and surrounded by farmland. BAAP is about seven miles south of the town of Baraboo with a population of 11,500, and seven miles north of Sauk City/Prairie du Sac with a population of 6,300.

Addressing explosive contamination is a necessary first step to the removal of buildings and the release of the BAAAP to the public. Buildings must be decontaminated before transfer of property may occur. For some of the buildings at BAAAP, "conventional destruction or demolition techniques would be inadequate and dangerous for the workers as well as any person who may come in contact with the demolition debris during transport or disposal. Therefore, open burning will be used to decontaminate and demolish buildings with explosive risk, under a comprehensive set of required conditions," the Army states in the Environmental Assessment of its landfill expansion plan.

The Army is preparing a separate Environmental Assessment for the proposed open burning of structures at BAAAP, as required under federal regulations. The EPA must complete an evaluation of the open burning plan before the Army’s Environmental Assessment can be finalized. Then it will be published and a public information meeting will be held. But now the Army has applied for an exemption from this process.

In 2001, the Army conducted a groundwater investigation of the Deterrent Burning Ground at Badger. The investigation was in response to detections of dinitrotoluene in groundwater in the northeast portion of the installation. (Photo courtesy U.S. Army)

But however logical and necessary open burning of the BAAP buildings may seem to the U.S. Army and state regulators, the environmental coalition views the proposed burning with horror.

“Decades of scientific research have shown that PCBs, dioxins and furans are major public health threats. Concentrations in the environment, and in the food chain, are already too high,” warned Dr. Bruce Barrett with Madison Physicians for Social Responsibility. “Open burning of paints, plastics, and PCB-contaminated materials like that proposed at Badger would is foolhardy, and dangerous. Children, pregnant women, and their fetuses are especially vulnerable. Birth defects and developmental delays could easily result.”

Human exposure to these contaminants is a concern because of the wide range of adverse health effects including reproductive and developmental effects, immunologic effects, liver damage, and cancer. Some PCBs can mimic or block the action of hormones from the thyroid and other endocrine glands, affecting normal growth and development.

"PCBs and dioxins are potent xenoestrogens that are biologically active at extremely low doses. They are very persistent and bioaccumulate in wildlife and people,” said Dr. Warren Porter, professor of aoology and environmental toxicology at the University of Wisconsin. “Xenoestrogens have been linked to increases in breast cancer, heart problems in developing embryos, reduced sperm counts, neurotoxic, immune, and hormonal effects."

Contaminated sediment has had to be dredged from Gruber's Grove Bay in Lake Wisconsin adjacent to the Badger Army Ammunition Plant. (Photo courtesy U.S. Army)

In addition to Wisconsin, decontamination of buildings by fire has occurred or is proposed at military sites across the nation including Joliet Arsenal in Illinois, Ravenna Army Ammunition Plant in Ohio, and Indiana Army Ammunition Plant. PCB concentrations at these other facilities did not exceed the federal threshold of 50 parts per million, but officials in some states have issued public health advisories prior to each burn.

"The Army has recently begun to open burn some of the abandoned buildings at the closed Army Ammunition Plant near Charlestown, Indiana. After some complaints, the Department of Environmental Management is now issuing health notices prior to each burn,” said Richard Hill, president of Save the Valley. “These notices advise local residents that there is ‘potential for adverse health effects associated with smoke from the fire’ and that concerned people should stay indoors during the burn.”

From Puerto Rico Robert Rabin with Committee for the Rescue and Development of Vieques has plenty of experience with the consequences of military burning.

“Open burning and detonation by the US Navy for decades on Vieques put into our environment a long list of dangerous military toxics we believe are responsible for the health crisis our people suffer,” Rabin said. “Vieques has the highest cancer case rate in all of Puerto Rico; there are no other significant sources of contamination."

“We strongly oppose open burning of PCBs at Badger Army Ammunition Plant because it would set a national precedent and open the door for similar exemptions at military and civilian facilities across the U.S., like Vieques,” Rabin said.

In its letter to the EPA, the coalition warns that emissions from burning BAAP buildings would also threaten the ecological and cultural health of the Sauk Prairie which stretches across 14,000 acres from the Wisconsin River to the Baraboo Range and nearby Devil’s Lake State Park.

"The Badger property is home to nearly 600 species of plants, butterflies, mammals, reptiles, amphibians, aquatic species, and birds. Grassland birds, in particular, have been able to thrive at the plant, making it one of the most critical habitat areas in the Midwest for this rapidly declining group," the coalition writes.

The environmental groups favor non-thermal technologies, including biological deactivation, mechanical demolition and disposal, hydroblasting, inerting, and many others, that they say have been successfully implemented at military bases across the country.

Whether or not the Army gets permission to conduct the open burns, it has plans to build a new landfill in which to place construction and demolition debris from removal of structures on the property. Secondary waste streams would consist of asbestos products, and up to five percent would be waste soil, concrete, and waste ash from the burned buildings, if permission is granted.