The highly contaminated Darwin Road burn pit area at the Dane County Regional Airport was used by the city, county, and military from the 1950s-1980s. Above, the airport’s cell phone lot being constructed there in the spring, 2018.
In early 2019, Steve Verburg of the Wisconsin State Journal reported that Madison and Dane County were waiting for the military to test the heavily contaminated fire-training burn pits at the airport. The city, county, and military had used the burn pits since the 1950s.
By 1986, the city and county knew the Darwin burn pit was likely very contaminated with hazardous compounds, but handed off further investigations to the military in 1988. The military found significant toxic contamination there, and reported it in 1989, but no cleanup was ever done. Nineteen years later, in June 2018, DNR asked all three parties to further investigate the burn pits for PFAS (but not any of the other hazardous chemicals found there in the 80s).
Now, thirty-two years later, the city and county are using the same tactic again–handing the toxic mess off to the military. On May 23, 2021 Chris Hubbuch reported on Madison Mayor Rhodes-Conway’s response to the Sustainable Madison Committee’s April 27 recommendations for city actions to address Truax Field’s PFAS problems.[1]
As for the city’s role in cleaning up the burn pits, Rhodes-Conway wrote:
“The City is involved in work related to two on-site fire training areas (also called “burn pits”) because we are a former owner of the airport (until 1974) and we are likely a former user of the fire training areas…It is good news that the main known sources of pollution – the Truax site and the burn pits – are being included in the National Guard’s remedial investigation. The remedial investigation is one stage of the Federal CERCLA clean-up process, and we are hopeful that federal funding will continue through the following stages for full remediation…”
Hmmm, apparently things changed once Rhodes-Conway was elected. Steve Verburg’s 2019 article said: “I certainly don’t want the city to go it alone,” former Ald. Satya Rhodes-Conway said in an interview after emerging with Soglin from Tuesday’s primary. “I want us to collaborate and partner with all concerned. (But the) bottom line is we can’t wait and we can’t pass the buck. … We need to know what the threats are.”
Does handing off responsibility for testing and remediating the burn pits to the military put the health of Madison residents and the environment first and foremost? NO
Dickering for years over who is responsible for toxic pollution at Truax Field, and then handing the mess off to the military, has been a popular strategy for the city and county since the 1980s, if not longer–see here and here.
The U.S. military is certainly responsible for much of the toxic pollution at the Truax base and should pay to clean it up ASAP. That said, the county currently owns nearly all of the Truax Field land, including the burn pits. As Mayor Rhodes-Conway admitted, the city was an owner of the airport through 1974 and provided fire services there.
The total PFAS levels in shallow groundwater at the Darwin burn pit, right next to Starkweather Creek, are the highest measured to date at Truax Field. The Madison Fire Department definitely (not just “likely” as the Mayor wrote) used this burn pit for decades, as well as the highly contaminated Pearson burn pit at MATC-Truax.
What is the county doing? During the pandemic, county officials decided to spend about $1 million of public funds on further testing of the airport storm sewer systems, an experimental technology that hasn’t worked to date, testing to identify specific sources, and plugging up holes in sewers pipes.
This strategy seems destined to fail. The widespread (but still undefined) groundwater plume under Truax Field will continue to leach into the creek even if storm drains leaking PFAS into it are sealed. Meanwhile, the DNR has not asked Dane County to delineate the horizontal and vertical extent of the PFAS plume, per NR 716. How can they develop effective remedial strategies without knowing how deep and wide the contamination extends?
Further, most of the county’s storm system plugging efforts and experimental PFAS filtration technologies will be upstream of the known PFAS hotspots at the burn pits. So while the county tinkers with experimental strategies, high levels of PFAS in the soils and shallow groundwater at the burn pits downstream of them will continue to ooze into the creek and through city neighborhoods, many of them low income areas with high proportions of people of color.
Accountability to the community? Community engagement?
If the community had any say in how this $1 million of county funds (our money) should be spent we likely would have advised that the county use some or all of it to remediate the burn pits right away, to the extent possible, instead of waiting for the military to do so. But the community had no say in this. Elected officials other than the Mayor and County Executive also had no say.
Instead, the city and county will again hand off further investigations to the U.S. military, guided by the cumbersome, slow-moving, federal CERCLA (Superfund) process–which at this point will likely allow them to use more lenient groundwater PFAS standards (70 ppt for PFOA/PFOS) instead of the state’s proposed standards (20 ppt for PFOS/PFOA).
Will the burn pit contamination be fully assessed and cleaned up under CERCLA? How long will this take? As I wrote last year, CERCLA is no panacea. The last CERCLA-led investigations at the Truax ANG base from 1988-2012 took over two decades and the contaminants were never fully investigated or cleaned up. Many are still there. PFAS was not included.
Also, the CERCLA process will be led by federal officials from elsewhere, not accountable to the local community. Will they meaningfully engage the community? Will they engage the community at all? Again, based on the CERCLA experience from 1988-2012, which we only found out about many years later through an open records request, it doesn’t seem likely. Though federal laws require community engagement. and National Guard Bureau asked the Air National Guard to develop a “community relations plan,” there is no evidence that community engagement ever happened. Will it be any different this time?
Obviously, one key reason the city and county are happy to hand the burn pit investigations and remediation over to the military is because then they don’t have to pay for it. But we don’t even know if the feds will cough up the funds for remediation–note that Mayor Rhodes-Conway said “we are hopeful that federal funding will continue through the following stages for full remediation.” Hopeful?
Perhaps another reason the city and county like this arrangement is because they can wash their hands of it and pass it on to federal military officials who do not have the same kind of accountability to the community they have? These military officials are people nobody in the community knows, who are not our neighbors, who cannot be voted out of office. When PFAS investigations drag on and on, and no cleanups happen, city and county officials can point to the big bad mysterious U.S. military, operating in dark, closed-door meetings elsewhere. Not our fault, they will say!
If the city and county really care about the health of their residents, Starkweather Creek, and all the Yahara Lakes–and understood what environmental justice means–they will start cleaning up these burn pits NOW, even while contaminant investigations throughout the rest of Truax Field are ongoing.
For the longer history of this convoluted mess, read on…
City and county have major responsibilities for the burn pit contamination
The Madison Fire Department used the two burn pits for fire training for decades. MFD still uses the Pearson St.-MATC training area now–though nobody (even DNR!) seems to know if MFD ever used PFAS foam there. Below is a photo I took there during MFD training about two months ago (early April 2021).
For some time, the city was responsible for fire protection at the ANG base itself. In 1969, the Wisconsin State Journal reported that “city firemen” would be taking over fire protection at the base from the Air National Guard. (The military was using firefighting foam with PFAS by this time, if not earlier).
As for where MFD did fire training, in 1988, City Engineer Dave Benzschawel, referring to the Darwin Road burn pit, told local reporters (see here and here):
“The site at Truax…was also used heavily by the Madison Fire Department until 1986 for practice in putting out fires……fuel and solvents were set afire, and what did not ignite soaked into the ground and may also be responsible for some of the contamination.” Further, he said, this had “created problems because the groundwater table is only eight to 11 feet below the surface.”
City and county bickered for three years and then turned over investigations to the military
The 1988 article also says “The city and Dane County have been arguing over who should pay for the study and cleanup costs.” Benzschawel commented that ” If we’re lucky the Department of Defense and Corps of Engineers will spend a significant amount of money…” Sound familiar?
Investigations were indeed turned over to the military, and in the next few years, reports were produced by military contractors with details and data from the burn pits. This 1988 “Preliminary Assessment” done by a military consultant describes the Darwin Road burn pit:
“The area used for fire training exercises by the ANGB is located on the east side of International Avenue at Darwin Road. The site consists of a rectangular open earth area, approximately 600 by 800 feet. There is no lining or containment structure for the area. This location has been used by the ANGB since the early 1950s in conjunction with other agencies over the years for various fire training exercises. The fire training area is not located on current ANGB property. It is currently owned by Dane County. Fire training exercises have been discontinued at the site since August 1986. At that time, the director of the Dane County Municipal Airport/Truax Field ordered a halt to all training exercises until an assessment could be made as to the environmental consequences of continued training exercises.” (pg. 39 of pdf, highlights added).
The 1989 full final report, “Investigation Report, Contamination Evaluation, Truax Field” included the Truax landfill and former Burke sewage treatment plant south of the airport–all part of the giant Truax Field contamination mess. An excerpt from the 1989 report describes how the Darwin Road burn pit was used:
“The burn pit is located about 200 feet north of Darwin Road and 400 feet east of International Lane...According to Mr. William Skinner, Air National Guard Fire Chief, the area was used for fire-fighter training during the period 1953-1987. It may have been used prior to 1953. It is believed to have been constructed by the DOD. Training exercises were conducted by U.S. Air Force personnel during the 1950 ‘s and 1960 ‘s, by the Air National Guard, and later by the City of Madison, Dane County, and volunteer fire departments. Mr. William Skinner estimated that fire training took place ten to fifteen times per year.
Flammable liquids such as JP-4 jet fuel, kerosene, gasoline, diesel fuel, waste oil, and probably solvents and hydraulic oil were burned. Paints may have also been burned here by the City of Madison. On each day that training occurred, 500 to 1000 gallons or more of liquid were used. It was spilled onto the ground, ignited, and then extinguished. Several fires were started and extinguished each day. The fuel remaining after training exercises soaked into the ground, evaporated or was carried away by surface run-off. It appears possible that some may have entered the creek 400 feet to the east, The practice was terminated in December 1987. The Burn Pit Area is irregularly shaped and has dimensions of about 200 feet by 100 feet. The area was blackened and void of vegetation. Some standing water was noted in July 1988. The area is a former swamp and has a shallow groundwater table. It appears from surface stains that surface runoff from the Burn Area migrates to the south.”
The 1989 final Truax Field report also included a hand-drawn map depicting the location of the burn pit in relation to Starkweather Creek, and the following information about the contaminants eventually found there:
“Groundwater near the practice burn pit (Site TG-3) was found to contain numerous organic chemicals present in fuels or solvents, and elevated levels of petroleum hydrocarbons. During installation of TG-3, cuttings from a depth of 24 feet exhibited elevated organic vapor meter readings and the odor of petroleum was noted. During well development and sampling, water in the well exhibited a strong solvent odor.”…“A sample of standing water in a ditch near the practice burn pit (TW-3) was found to contain organics present in fuels or solvents (including methylene chloride, benzene, toluene, 1,2-transdichloroethylene, thiobismethane, and tetrachloroethylene) Petroleum hydrocarbons and lead were also found in TW-3. These analytical results further confirmed groundwater and soils analyses which are evidence of contamination related to the practice burn pit.” (pg. 1-2, 1989 report).
PFAS was not tested at the site in 1988-89. Though by this time, industries producing PFAS had already found evidence of serious PFAS toxicity (PFOS in particular, used in military AFFF), and the U.S. Navy was aware by the 1970s that AFFF could cause environmental problems,[2] it is unclear whether other military entities were aware of this then.
On November 29, 1990, DNR’s Carol McCurry wrote to the Wisconsin Air National Guard asking about ongoing contamination investigations at the base, and raising questions about the 1989 Envirodyne report:
“In addition to the underground tanks and the spills referred to in ‘the above mentioned report, other areas of concern exist. These areas are identified in a March, 1989 entitled, “Engineering Report Contamination Evaluation Truax Field Madison, Wisconsin,” prepared for the U.S. Army Corps of Engineers, by Envirodyne Engineers, Inc. In particular, the areas identified as the ‘burn area’ and the ‘JP4 tank area’ are of concern to the Department. The Department is unclear about the relationship of these areas to WANG activities. What agency has responsibility for completing the investigation at those sites?” (highlights added)
I never found any response to McCurry’s 1990 question. The DNR later investigated the “JP4 tank area” (jet fuel tanks), but other than the 1988-89 report, in 2018 I found nothing more in any DNR or ANG files about this “burn area.”
Thirty years went by, with no clean up by city, county, or military
In spring 2018, I discovered that the airport cell phone parking lot was being built nearly on the old burn pit area, and alerted the DNR. On June 18, 2018 DNR sent the city, county, and ANG a letter requesting that they “conduct a soil, groundwater and surface water investigation at the site this summer. The study should describe the full nature and extent of PFA contamination.”
On July 2, 2018, DNR wrote me, in response to my questions about the burn pit: “We have checked our files and determined that no remediation has been performed in this area and no testing of PFAS has been conducted.”
But in back-room meetings later in July, city and county officials decided to hand off responsibility for these county-owned sites to the U.S. military. The Wisconsin Air National Guard’s July 31, 2018 letter to DNR offered to take over investigations at these sites—on their terms and their timeline—and then Mayor Paul Soglin and Michael Kirchner, Dane County Airport’s Director of Engineering, agreed. Undoubtedly, city and county attorneys helped craft the deal.
Below: Darwin Road burn pit area in April 2019, with new cell phone lot completed behind it. Stormwater runoff goes directly to Starkweather Creek (not visible just to the right of the fence)
In spring 2019, PFAS was tested at airport stormwater outfalls and Starkweather Creek was sampled that summer. PFAS levels, not surprisingly, were very high.
These results weren’t released publicly till October 7, 2019. DNR sent a responsible party letter to the city, county, and Air National Guard pertaining to the Starkweather Creek contamination. On October 11, 2019, DNR sent a separate responsible party letter to the Dane County Regional Airport for the airport’s storm sewer system contamination.
For the next year and more, the city and county tried to claim they weren’t responsible, dickered over who was more or less responsible, and had numerous meetings with the Air National Guard that were closed to the public and elected officials. So nobody really knows what deals were made.
In January 2020, more Starkweather Creek water and fish results were released publicly. Levels were alarming.
In December 2020, the first “preliminary” burn pit PFAS data was released publicly. The PFAS levels in groundwater under the burn pits were astounding–the highest total PFAS levels found at Truax Field to date.
And now, instead of taking actions to clean this up right away, the city and county are happy to hand it off to the U.S. military–as they did over 30 years ago. No cleanup resulted.
Will it this time?
- The Mayor said she didn’t know why the PFAS Task Force didn’t happen. Here’s how the PFAS Task Force was born and died. The Mayor’s proposed communication strategy is a positive step forward, but is nothing like what the PFAS Task Force was intended to be. The city clearly doesn’t want to give its residents or alders a real voice or place at the table in decisionmaking about PFAS. It also wants to keep its non-public discussions with other key actors in the PFAS mess (the county, the Air National Guard) behind closed doors.
- The investigation was part of the Defense Environmental Restoration Program (DERP), intended to “identify and remedy environmental problems at facilities formerly owned and operated by the DOD.” The DOD entities that operated on the site (Army, Army National Guard, Air Force/Air National Guard) used the Truax Field landfill, former Burke sewage treatment plant, and burn pit areas since the 1940s for disposing of military sewage and toxic wastes, and for fire training. The City of Madison and Dane County also used the landfill, sewage treatment plant, and burn pits at various times.
