June 2002

Open Burning of Buildings at Badger: A Solution or More Pollution?

On June 19, the Wisconsin Department of Natural Resources (WDNR) met privately with representatives of the U.S. Army, General Services Administration, and Plexus Scientific Corporation, a consulting firm working for the military.  The Army, as part of the decontamination and demolition process at Badger, contracted with Plexus to evaluate buildings on the installation for residual explosive risk.

According to WDNR staff present at the meeting, open burning is being discussed as a means to decontaminate highly sensitive buildings where nitroglycerine and nitrocellulose are present in raw form or have permeated wooden structural members.  Residual nitrocellulose and nitroglycerine could be an explosive risk to workers and other onsite personnel performing building demolition, salvaging, or related activities.  One means of addressing this residual contamination is burning the buildings.  This approach, however, places the environment and human health at risk. 

According to a Plexus report prepared for the Army at Sunflower Army Ammunition Plant in Kansas, open burning of explosive-contaminated structures produces toxic emissions including nitrous oxide.  “Open burning will also cause the release of hazardous materials such as asbestos, lead, zinc, and potentially harmful combustion products from electrical materials, preservative coatings on equipment, paints, plastics, and other construction materials into the atmosphere and potentially into soils, groundwater, and surface water,” the Plexus report said. 

The 1996 report, which was submitted to the Kansas Department of Health and Environment for review, found that burning is “not environmentally friendly.” “During an open burning materials are changed from a solid form and are released to the atmosphere where they will certainly be deposited over a large area resulting in contamination of soil and surface water,” Plexus said. 

Exposure to airborne vapors and dust generated during burning is also a potential risk to workers and others who might be exposed to toxic emissions and nearby plants and animals; deposited materials could affect both soil and surface water bodies in the area surrounding the burn site, Plexus concluded.

So far, only preliminary work has been conducted at a few of the buildings at Badger and the Army has not come forward with a formal proposal at this time, the WDNR said.  Preliminary findings indicated, however, that approximately 100 buildings could be considered for open burning.

 

November 2002

Groups Seek Alternative to Burning Buildings at Badger

A coalition of 31 organizations is urging the U.S. Army to seek an alternative to open burning old buildings at Badger Army Ammunition Plant.  This approach, the groups maintain, places the environment and human health at risk.  As many as 100 buildings are being considered for open burning.

“Open burning produces harmful combustion products from electrical materials, preservative coatings on equipment, paints, plastics, and other construction materials,” said Bruce Barrett, a physician and member of Madison Physicians for Social Responsibility. “Open burning of explosive-contaminated structures produces toxic emissions including nitrous oxide, lead vapors, and dioxins.”

Badger Army Ammunition Plant, located at the base of the Baraboo Hills and Devil’s Lake State Park, is being decommissioned.   The U.S. Army is discussing open burning as a means to decontaminate sensitive buildings where nitroglycerine and nitrocellulose are present in raw form or have permeated wooden structural members.  The groups are very concerned about the potential environmental, ecological, and human health risks of burning these buildings.

“During open burning materials are changed from a solid form and are released to the atmosphere where they are deposited over a large area resulting in contamination of soil and surface water,” said Liz Wessel, Executive Director of Wisconsin’s Environmental Decade.  “Airborne vapors and dust generated during burning are not only a risk to nearby residents, they are also a risk to workers, area farmers, and other people that lease property inside Badger.”

According to the Wisconsin Department of Health and Family Services, the small particles in wood smoke can worsen heart conditions by preventing oxygen from reaching tissues.  Breathing difficulties such as asthma may increase in adults or children if they breathe too much smoke.  Other health problems aggravated by burning include lung infections such as acute pneumonia and bronchiolitis.  Allergies can be worsened, WDHFS said.

“Cleaning up the Badger Army Ammunition Plant is already a difficult situation given all the years of exposure both onsite and in the community to the hazardous chemicals and waste from decades of explosives manufacturing,” said Laura Olah, Executive Director of Citizens for Safe Water Around Badger.  “Additional contamination is only going to make a bad situation worse.”

Other organizations that signed the letter include Citizens Natural Resources Association of Wisconsin, Clean Water Action Council of Wisconsin, Concerned Citizens of Newport, Families and Friends for Social Responsibility, Glenview Prairie Preservation Project, Interfaith Justice and Peace, Midwest Environmental Advocates, Midwest Treaty Network, Peace Action Wisconsin, Madison Chapter of Physicians for Social Responsibility, Rock Valley Fellowship of Reconciliation, Wisconsin’s Environmental Decade, Wisconsin Network for Peace and Justice, Wisconsin Public Interest Research Group (WISPIRG), and the Wolf Watershed Educational Project.

 

February 2003

Groups Join Opposition to Burning Buildings at Badger

A coalition of 31 environmental, health, peace, conservation, and social justice groups organized by CSWAB is urging the U.S. Army to seek an alternative to the open burning of old buildings at Badger Army Ammunition Plant.  This approach, the groups maintain, places the environment and human health at risk.  As many as 100 buildings are being considered for open burning.

“Open burning produces harmful combustion products from electrical materials, preservative coatings on equipment, paints, plastics, and other construction materials,” said Bruce Barrett, a physician and member of Madison Physicians for Social Responsibility. “Open burning of explosive-contaminated structures produces toxic emissions including lead vapors, lead particulates, and dioxins.”

The U.S. Army is discussing open burning as a means to decontaminate sensitive buildings where nitroglycerine and nitrocellulose are present in raw form or have permeated wooden structural members.  The groups are very concerned about the potential environmental, ecological, and human health risks of burning these buildings.

“During open burning materials are changed from a solid form and are released to the atmosphere where they are deposited over a large area resulting in contamination of soil and surface water,” said Liz Wessel, Executive Director of Wisconsin’s Environmental Decade.  “Airborne vapors and dust generated during burning are not only a risk to nearby residents, they are also a risk to workers, area farmers, and other people that lease property inside Badger.”

According to the Wisconsin Department of Health and Family Services, the small particles in wood smoke can worsen heart conditions by preventing oxygen from reaching tissues.  Breathing difficulties such as asthma may increase in adults or children if they breathe too much smoke.  Other health problems aggravated by burning include lung infections such as acute pneumonia and bronchiolitis.  Allergies can be worsened, WDHFS said.

Organizations that have formally opposed open burning include Citizens Natural Resources Association of Wisconsin, Clean Water Action Council of Wisconsin, Coalition for Peaceful Skies, Concerned Citizens of Newport, Families and Friends for Social Responsibility, Glenview Prairie Preservation Project, Interfaith Justice and Peace, Midwest Environmental Advocates, Midwest Treaty Network, Peace Action Wisconsin, Madison Chapter of Physicians for Social Responsibility, Rock Valley Fellowship of Reconciliation, Wisconsin’s Environmental Decade, Wisconsin Network for Peace and Justice, Wisconsin Public Interest Research Group (WISPIRG), and the Wolf Watershed

            “Our group sees the issue of open burning at Badger as one of the most pressing and urgent crises that faces Wisconsin at this time,” said Pat Conway, spokesperson for the Coalition for Peaceful Skies.  “We oppose it and we urge all citizen groups to join in the opposition to such a dangerous and destructive plan.” 

 

February 2003

Baldwin Asked to Help Find Safe Alternative to Burning

Citizens for Safe Water Around Badger is asking Congresswoman Tammy Baldwin to help find a safe alternative to open burning of as many as 100 explosive-contaminated buildings at Badger Army Ammunition Plant – a proposal that will cause more pollution at the closing military base.

In a letter sent on January 13, CSWAB said that funding should be invested in the research and development of alternative technologies that meet the military’s criteria but do not place human health and the environment at risk.  The group proposes that Badger be utilized as pilot site.  The proposal could create job opportunities for workers displaced by base closure and could also bring needed federal dollars into Wisconsin. 

Disposing of unwanted buildings at closing military facilities is a challenge facing communities across the country and is not unique to Badger.  Each year hundreds of buildings are burned by the Department of Defense, placing human health and the environment at unnecessary risk and exacerbating environmental damage caused by past military activities.                    

“Environmental cleanup at Badger is already a highly complex and challenging problem,” CSWAB wrote to Baldwin.  “The last thing we need is more contamination”.

Finding an environmentally-friendly solution is also consistent with the recommendations of the Badger Reuse Committee, an independent advisory group funded with Baldwin’s help.  Last year, the committee of local and tribal governments, state and federal agencies, and other interested groups approved a plan that stipulates future activities should pose no risk to people or the environment and should not pose the threat of additional contamination of the Badger property.  Planned future uses include conservation, agriculture, education, and recreation.

According to the Army, the first burn could occur as early as February or March.  In order to give federal legislators time to find funding and other support for the project, we are also asking that the proposed open burning be delayed.

 

March 2003

Open Burning Proposal Ignores Risks to Children and Infants!

               The DNR’s assessment of cancer risks associated with inhalation of toxic emissions from open burning buildings at Badger only evaluated risks to adults.  In addition to other omissions -- including no assessment of non-cancer risks, ecological risks, environmental risks, and cumulative risks – the DNR did NOT assess risks to CHILDREN AND INFANTS!! 

            DNR officials said children were not included in their study because (1) the current EPA method for evaluating risk to children is old, (2) the new EPA method will not be finalized for at least 6 months, (3) even if the new method was available, this type of assessment could take as long as a year, and (4) there are other more significant air emission sources that require the Department’s attention. 

            Ironically, the EPA published findings this week that infants and toddlers have a 10 times greater cancer risk than adults when exposed to certain chemicals. (See article on other side for more information.)  The federal government is proposing tougher environmental guidelines that would take into account the greater hazards to the very young.

            PLEASE write a letter demanding assessment of all risks to children and infants for all routes of exposure (not just inhalation) BEFORE any burning is done at Badger.  Your letter should also include a strong recommendation that IF burning is ultimately approved, comprehensive environmental monitoring should be conducted.  (The DNR’s current plan contains NO requirements for monitoring air, soil, or surface water.) 

Send your written comments by March 17 to:    

Barbara Pavliscak, Air Management
Wisconsin Dept of Natural Resources
1500 N. Johns Street
Dodgeville, WI 53533    
Barbara.Pavliscak@dnr.state.wi.us
(608)935-1927

If open burning is ultimately approved, the DNR will establish a notification list for anyone that would like to know in advance when a burn is going to occur.  If you would like to receive written notification of an upcoming burn, include your request and your contact information with your comments.

For more information contact:

Citizens for Safe Water Around Badger
E12629 Weigand’s Bay South    Merrimac, WI  53561
Phone (608) 643-3124   Fax (608) 643-0005
info@cswab.org

 

March 2003

Open Burning Requires Careful Assessment of Health Risks to Adults and Children

By Ann T. Behrmann, MD

 

Barbara Pavliscak
Air Management
Wisconsin Dept. of Natural Resources
1500 N. Johns Street
Dodgeville, WI 53533      

Dear Ms Pavliscak;

As a pediatrician practicing in South Central Wisconsin, I am very concerned about the potential health risks posed by open burning hazardous materials at Badger Army Ammunition Plant(BAAP), particularly the risks to children's health. According to a report provided by the Army's consultant, Plexus Scientific, air emissions from burning buildings will include lead, polychlorinated biphenyls (PCBs), benzene, and other pollutants. While cancer risks posed by inhalation of these toxins were assessed for adults, there was no assessment of cancer risk to children.

A report released by the U.S. Environmental Protection Agency on 3/5/03 stated that fetuses and children under 2 years of age have a 10 times greater cancer risk than adults when exposed to specific gene-damaging chemicals.  The same report indicated that children from 3 to 15 may face at least a three fold greater risk than an adult if exposed to specific mutagenic chemicals.  As you are well aware, children are particularly vulnerable to health risks from environmental toxins. Children, because of their greater body surface area, eat proportionately more food, drink more fluids, and breathe more air per pound of body weight than an adult. As a result, they inherently have a greater risk of significant health effects (through increased absorption of a toxin) from the same environmental threat.

Not only are children at greater risk of cancer, the continued growth and development of a child's immune, endocrine, gastrointestinal and nervous systems and their relatively immature detoxifying systems via the liver and kidney, from fetal development through age 15, put them at greater risk of permanent damage to their brain and other vital organs with exposures to chemicals classified as neurotoxins, endocrine disruptors and teratogens as well as known carcinogens.

The safe and effective clean up of contaminated buildings (as well as soils and ground water) at the BAAP is critically important.  Before the Wisconsin Department of Natural Resources (WI DNR) considers open burning of these buidings, it is imperative that a complete environmental assessment of air, soil and water pollution from this open burning be done first.  Burning will cause, no doubt, an increase in airborne particulate matter, a pollutant closely linked to increased respiratory illness such as asthma and emphysema.  The release, not only of carcinogens, but also of particulates, and of chemicals classified as teratogens, neurotoxins, and endocrine disruptors must be carefully studied for ALL age groups.  Measures of potential exposure from inhalation of airborne contaminants as well as exposure to soil and further ground water pollution from open burning should be examined as well.

Should the WI DNR determine, through this careful environmental assessment, that the potential risks of open burning to the exposed workers and adjacent communities will not affect their health, then it is imperative that comprehensive environmental monitoring of on and off site air, water and soil quality be undertaken by the responsible party.  These assessments must then be reviewed in an ongoing manner by the WI DNR.  Not only adults working at BAAP, but also families with small children as well as pregnant women who live in neighboring communities, will be exposed to changes in air quality from open burning.  Some of these same families all ready have been exposed to volatile organic compounds polluting their water systems via longstanding off site ground water run off from BAAP.  Any environmental and health assessment should certainly factor in this past and ongoing exposure when determining health risks for these populations.

The citizens who work and those families who live as neighbors to the BAAP depend on the wise decision of the WI DNR to safe guard their health.  A decision whether to allow open burning of contaminated buildings at BAAP should not be made without a comprehensive assessment of all the possible health risks to exposed children and adults.  I ask as a health professional that the WI DNR to do its foremost as a scientific governmental agency to ensure that public health will not be compromised by the proposed open burning of buildings at Badger.

Sincerely,

/s/Ann T. Behrmann MD
Pediatrician, Group Health Cooperative
Madison, Wisconsin

 

May 2003

Neighbors Ask Attorney General to Stop Open Burning:
Analysis Shows Air Emissions Will Exceed Safe Standards

        Nearby residents today asked Attorney General Peg Lautenschlager to take legal action to stop a plan to open burn approximately 100 buildings at Badger Army Ammunition Plant.

        On behalf of Citizens for Safe Water Around Badger (CSWAB), attorneys with Midwest Environmental Advocates have requested the action based on new findings that the calculations used in the WDNR’s approval are flawed.  A technical consultant hired by the groups found that the proposed open burning of explosives-contaminated buildings will exceed air quality standards. 

        The WDNR’s air modeling approach contains a significant error,” said Charles J. Gantzer, Ph.D.  “The WDNR’s approach assumed a heat content of wood that is 16 times higher than the actual heat content of wood.  When the correct heat content is used, the estimated inhalable particulate concentrations are 2.7 times above the National Ambient Air Quality Standards.”

        This is the second time the WDNR’s air emissions projections were in error.  Gantzer analyzed a previous study and found the WDNR had underestimated particulate emissions by a factor of 5. 

         “The proposed open burning will violate Wisconsin law which requires open burning to be conducted in a pollution free manner,” said Attorney Melissa Scanlan. “The Attorney General can take action to abate or prevent a nuisance from occurring, including a violation of state law.”

         “I live next to the plant and have three children,” explained Laura Olah, Executive Director of CSWAB.  “Families in our community have already been exposed to pollution in their drinking water, mercury contamination in the river, and toxic air emissions produced when Badger was operating. We’ve had enough.  The Army must be required to comply with the law just like everybody else.”

             According to the Wisconsin Department of Health and Family Services, the small particles in wood smoke can worsen heart conditions by preventing oxygen from reaching tissues.  Breathing difficulties such as asthma may increase in adults or children if they breathe too much smoke.  Other health problems aggravated by burning include lung infections such as acute pneumonia and bronchiolitis.  Allergies can also be worsened.

            “During open burning materials are changed from a solid form and are released to the atmosphere where they are deposited over a large area resulting in contamination of soil and surface water,” Olah said.  “Airborne vapors and dust generated during burning are not only a risk to nearby residents, they are also a risk to workers, area farmers, and other people that lease property inside Badger.”

             Other organizations that have formally opposed open burning at Badger include Citizens Natural Resources Association of Wisconsin, Clean Water Action Council of Wisconsin, Concerned Citizens of Newport, Families and Friends for Social Responsibility, Glenview Prairie Preservation Project, Interfaith Justice and Peace, Midwest Environmental Advocates, Midwest Treaty Network, Peace Action Wisconsin, Madison Chapter of Physicians for Social Responsibility, Rock Valley Fellowship of Reconciliation, Wisconsin’s Environmental Decade, Wisconsin Network for Peace and Justice, Wisconsin Public Interest Research Group (WISPIRG), and the Wolf Watershed Educational Project.