Site History

Historical Image of site

Badger Army Ammunition Plant (AAP) was constructed in 1942 to produce single-base and double-base propellant for cannon, rocket, and small arms ammunition. The installation was the largest propellant manufacturing plant constructed in World War II, and the plant continued to provide propellants for the Korean and Vietnam conflicts. The plant operated until March 1975 when all production facilities and many support functions were placed on standby status. The Army maintained Badger AAP in a standby status until 1998 when the installation was declared excess to the Army’s needs. Since 1998, the Army has been preparing the former Badger AAP for ownership changes.

Disposal of propellant waste in open burn pits and tanks, and discharge of production wastewaters to open ditches and ponds during operations of the plant, have resulted in contamination of soil and sediment on the installation, and groundwater on and off the installation. Contaminated soil has been investigated and remediated; all soil contamination above state standards has been removed. To date, four groundwater plumes have been identified. Monitoring of groundwater indicates that the plumes are stable or decreasing through natural attenuation. Click here to view a map of the plumes and sampling locations.

Environmental investigation actions at the former Badger AAP began in January 1977. Studies identified propellant grains, dinitrotoluene (DNT), nitroglycerine, organic solvents, and lead compounds and acids in former production areas. Groundwater investigations in the late 1970s discovered that some volatile organic compounds (VOCs) had migrated through the soil into the groundwater and then migrated southward with groundwater flow. Contamination from production waste discharge water has been identified in man-made settling ponds which were formerly emptied into the water of Lake Wisconsin. In 1987, an in-field condition report (IFCR) was issued by WDNR; the report has been updated over the years to keep it current with additional findings and decisions. A RCRA Part B permit for hazardous waste operations and storage was issued for the installation in 1988. The license was renewed in 1998 for storage only, and was no longer needed as of 2003 when the installation closed. Contaminants of concern (COCs) include explosives; metals; petroleum, oils and lubricants (POL); polychlorinated biphenyls (PCBs); VOCs, and semi-volatile organic compounds (SVOCs) affecting groundwater, sediment, and soil.


Regulatory Framework

The Defense Environmental Restoration Program (DERP) statutory authority is defined in 10 United States Code (USC) § 2701-2710. The program goals are included in 10 USC § 2701(b), which states:

“Goals of the program shall include the following: (1) identification, investigation, research and development, and cleanup of contamination from a hazardous substance, or pollutant or contaminant; (2) correction of other environmental damage (such as detection and disposal of unexploded ordnance) which creates an imminent and substantial endangerment to the public health or welfare or to the environment; (3) demolition and removal of unsafe buildings and structures, including buildings and structures of the DoD at sites formerly used by or under the jurisdiction of the Secretary.”

When Congress established the DERP, they directed that Department of Defense (DoD) cleanup efforts be consistent with the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). CERCLA requires that cleanup efforts at federal facilities be conducted in accordance with the requirements in Section 120, 42 USC § 9620. Executive Order 12580 delegates authority for implementing CERCLA to various federal officials, including the DoD. The Army uses CERCLA as the primary legislative authority for managing environmental cleanup. Where the Army’s military mission required a Resource Conservation and Recovery Act (RCRA) permit, RCRA Corrective Action may be an appropriate legislative authority for managing DERP cleanup. Badger AAP executed nearly all final actions through 2009 under DERP and RCRA Corrective Action; however, with the expiration of the RCRA Part B permit and the transfer of property outside of Army control, the remaining cleanup decisions will be executed under the Army’s delegated CERCLA authorities and the substantive requirements of Wisconsin state law and regulations.