Dear Editor: The Army has released its long-anticipated groundwater study for Badger Army Ammunition Plant, comparing possible cleanup remedies based on risk to public health. An initial review of the draft 717-page document by CSWAB quickly reveals that the study design underestimates these risks.

As part of its calculation of risk, the Army proposes an arbitrary distinction between onsite and offsite groundwater. When making its risk management decisions, the Army said it considered a cumulative cancer risk one-in-a-million for offsite groundwater and a less protective one-in-ten-thousand risk for onsite groundwater.

However, the aquifers under and around Badger function as unified hydrogeological units and groundwater is not a static system. Contaminants found at source areas inside Badger will inevitably move with groundwater to the surrounding community.

Moreover, for two of the four groundwater contaminant plumes originating from Badger, the Army included only one form (isomer) of the explosive DNT in its health risk calculations — however, all six isomers of DNT are found at Badger.

This omission is significant as toxicological studies indicate that when both 2,4-DNT and 2,6-DNT are present, their combined ability to increase cancer risk is more than just additive, and may be synergistic or multiplicative.

Collectively, these and other factors contribute to the underestimation of risk to environmental health and ultimately, the amount money that the military will be required to invest in cleanup.

Want to know more? The Army is hosting a public meeting on Dec. 5 at 6 p.m. in the Auditorium Leahy Theater at Sauk Prairie High School.

Laura Olah

Executive director, Citizens for Safe Water Around Badger (


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