Archive for September, 2014

The Inheritance Myth: Time To Talk Frankly About Cancer

The Inheritance Myth: Time To Talk Frankly About Cancer

By Dr. Kristine Mattis, MEJO Board Member, Counterpunch, September 17, 2014.

In a September 2014 article in the Journal of the American Medical Association, Dr. Mary-Claire King – the woman who first discovered the so-called breast cancer gene BRCA1 – and her colleagues suggested that all women should undergo routine medical screening for this gene as well as BRCA2.  Of course, it seems reasonable that women should know if they carry these mutant allele forms of these genes, because the mutant genes confer a greater risk for breast cancer and ovarian cancer in women who have the mutants than in women who do not.

There has been some discussion about Dr. King’s proposal in newspapers and on the radio, but the dialogue inevitably has two tremendous pieces of the cancer puzzle missing: cause and prevention. In fact, too much cancer information tends to be myopic, neglecting to mention essential elements of the global portrait of cancer etiology. Conventional wisdom about cancer tends to end up promulgating misinformation and misinterpretations, not sound science. Dr. King’s piece, as well the highly publicized bi-annual Stand Up to Cancer celebrity charity telethon, which raises money for cancer treatment, have done nothing to provide more clear information to the public that could help avert this all-too-common but potentially highly preventable scourge that has caused suffering upon and taken the lives of so many of our friends and family.

First and foremost, it is important to emphasize that cancer is NOT heritable. Actor Piece Brosnan proclaimed on the aforementioned telethon that cancer was a “wretched inherited disease.” It certainly is wretched, but is not inherited nor is it really a single disease.

Most inherited diseases such as cystic fibrosis, Tay-Sachs, or Huntington’s disease are relatively rare, because on a population level, the processes of evolution and natural selection promote the disappearance of the genes that produce the disease, unless those genes also confer some benefit. Some inherited diseases are less rare because of their unique side-benefits. Sickle-cell anemia, for example, can confer a beneficial trait, because those who carry only one allele (one of the two in a gene pair that is inherited from mother and father) for sickle-cell do not have the harsh symptoms of the disease, but do instead have an increased resistance to malaria.

In contrast, the BRCA1 and BRCA2 mutant genes do not cause cancer; they merely make it more difficult for your cells to repair damage done to your DNA. When your cells are exposed to a cancer-causing agent (i.e., a carcinogen) such as ionizing radiation, certain natural and synthetic compounds, certain viruses, and some endocrine disrupting chemicals, to name a few, they have mechanisms to repair the damage that agent may cause to your DNA. But if the damage is too severe or widespread, or if the cell lacks that mechanism for repair, as in the case of those who have the “breast-cancer genes,” your risk of contracting cancer is increased.

It is basic scientific knowledge that cancer is not inheritable, but in light of the discovery of various genes that confer increased susceptibility to cancer, this fact is not always well understood by the population at large. Only 5-10% of people who contract any type of cancer have any sort of inherited genetic susceptibility. Therefore, the focus on inherited mutant alleles leaves out the majority 90-95% of people suffering from cancer. While it is true that the minority 5-10% who do have these mutant alleles have a much greater risk for disease than the rest of us, they do not have an inherent “predisposition” to cancer. Labeling these genes as “cancer genes” or even “genetic predispositions” is a terrible misnomer. These genes increase susceptibility to cancer when exposed to cancer causing agents.

In Dr. King’s article, she mentions that the risk of developing cancer when you have a genetic susceptibility is significantly higher for women born more recently than for women born long ago, and that this phenomenon has been confirmed in numerous studies. Indeed, women born today who have the BRCA1 or BRCA2 gene have two to three times as much risk for developing cancer as women of previous generations. This, again, should make it clear that these genes do not themselves cause cancer. But Dr. King explains this trend away by saying it is due to earlier ages of menarche and later ages of childbearing now. Once again, while these occurrences are correlated to increased risk for cancer, they are not in and of themselves causes of cancer. The cause related to early menarche and late childbearing probably is due to increased exposure to estrogens, which can indirectly influence a cascade of cancer-causing cellular events. More importantly, the reason for earlier and earlier ages of menarche is most likely to due our increased exposures to synthetic estrogens, not better nutrition, as Dr. King postulates. But passing off these two risk factors off as primary causes of the increase in breast cancers incidences is disingenuous.

More and more we are learning that many of the over 80,000 synthetic chemicals that humans have constructed over the course of the last century or so not only directly cause DNA mutations that lead to cancer, but mimic estrogen in our bodies, which indirectly lead to cancer. These chemicals are in food we eat, the air we breathe, the water we drink, and the endless industrial products we produce and consume. They are quite often the products and processes of industry, and are not essential to maintain a comfortable life on this planet. In addition, the radiation we receive from sources such as diagnostic exams via x-ray, CT scan, and other radiologic medical procedures are being shown to contribute to excess cancers. For example, the UK Committee on Medical Aspects of Radiation in the Environment recently stated that one out of 2000 people will contract cancer due to abdominal CT scans – otherwise known as an iatrogenic cancer. This may seem a fairly small risk, unless you are that one person who has had an unnecessary CT scan and then is diagnosed with a preventable cancer because of it. Furthermore, scientists are finding more and more evidence that non-ionizing radiation, such as the radiofrequency radiation transmitted by cell phones, cell phone towers, wireless internet, and wireless water and electrical metering devices, is also a possible carcinogen. (The World Health organization places it in the same carcinogen class as the human papillomavirus.) The ubiquity of carcinogens and the ubiquity of our exposure to them, synergistically and cumulatively, is far more likely to be the cause of our plague of cancer diagnoses; it is far more likely that because women are more exposed to these carcinogens than in previous generations, the risk for women who have the BRCA mutant alleles is greater than in previous generations of women. Moreover, the risk for women who do not carry the BRCA mutant alleles and who are better able to repair the DNA in their cells, while relatively lower, is also increasing in more recent generations.

But for some reason, this plain and simple fact that exposure to carcinogens can and does lead to cancer is always absent in the medical discussion of cancer. Part of the reason may be that medical practitioners are rarely, if ever, versed in environmental health, so they are not even educated about environmental toxicology and the myriad diseases caused by environmental exposures. But part of the reason is likely political and economic. Real biological causes of cancer seem to be verboten because scientists and scholars who speak these truths are condemned, defamed, and discredited by the powerful industrial public relations machine, which has multi-billions of dollars worth of revenue to protect, as it maintains the businesses and industries that introduce so many of the carcinogenic products in our world.

Another important clarification in discussing cancer is that diagnosis does not equal prevention. In an Orwellian twist of double-speak, health care professionals have delineated different forms of “prevention” and have decided that the diagnosis and screening for cancer is what they deem “secondary prevention.” In truth, diagnosis is not prevention at all and should not be termed as such. But diagnosis is obviously necessary in a country where cancer afflicts more than 30% of the population. A problem when you combine diagnostic techniques that are in and of themselves carcinogenic, with people who have genetic susceptibilities to cancer, is that through the use of radiological diagnostics, the medical profession is inadvertently increasing the susceptibility of the already susceptible population even more. Consequently, when doctors propose that women with the BRCA1 and  BRCA2 mutant alleles start mammograms sooner in life and have more mammograms than other women, they are thus exposing these women, whose cells do not have the right machinery to combat carcinogens, to even more carcinogens than the average person (since mammograms use radiation). Thus, if we are indeed to screen all women for the mutant BRCA alleles, we should at least be using ultrasound and MRI (which are harmless diagnostic procedures, as far a science currently understands) when vigilantly monitoring them for cancer, rather than increasing the carcinogen exposure in a population who are already inherently less able to deal with it.

What does all this mean for women who have the mutant alleles for breast and ovarian cancer susceptibility? Too often, the onus for protecting oneself from cancer is put on the victims of the disease. Doctors discussing the call for universal BRCA gene screening say that women can then know about their susceptibility and then embark on better diet and exercise regimens to help prevent the disease. Certainly, a good, clean, healthful diet of whole foods and a semi-rigorous and regular exercise routine are always to be applauded, but the idea that these lifestyle measures prevent cancer actually flies in the face of scientific evidence that is continually accumulating. The New York Times published an article in its April 21, 2014 edition entitled, “An Apple a Day, and Other Myths” in which they illuminated that the consensus among the tens of thousands of scientists who study cancer and diet is that “when it comes to cancer there was little evidence that fruits and vegetables are protective or that fatty foods are bad.”

When discussing cancer, the lack of conversation about our ubiquitous exposures to carcinogens is highly negligent. A few causes seem to be safe for conversation. We readily speak of the human papillomavirus (HPV) and the chemical benzopyrene, which is produced when food is burnt. Often, we do not even mention any sort of safe or acceptable levels of exposure to these organisms or chemicals; we assume that no level of exposure is necessary. But the tens of thousand of other chemicals, products, and pollutants that cause cancer, to which we are universally and often unnecessarily exposed, are rationalized as unproblematic at the levels with which we use them. Moreover, the acute scientific and medical focus on genetic susceptibilities in the minority of patients, instead of research into the etiology of cancer in the majority of patients, demonstrates that cause and prevention are not priorities. It also dooms us to failure in the fight against this disease. But that does not have to be. We can work to eliminate the underlying causes of cancer. Many of these processes and products are completely unnecessary in our lives and contribute to other global harms such as climate change. Until we can have a frank conversation about cancer that includes all of the primary elements contributing to the disease, additional screening for genetic susceptibility (for women who actually have access to health care – and many still do not) will be of little help and we will be even farther from combating this horrendous blight.

Kristine Mattis received her PhD from the Nelson Institute for Environmental Studies at the University of Wisconsin-Madison. As an interdisciplinary environmental scholar with a background in Biology and Earth System Science, her research focuses on environmental risk information.

Copyright 2014 Kristine Mattis.

This work is licensed under a Creative Commons Attribution 4.0 International License

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Is the City of Madison Following Its Pesticide Policies?

Is the City of Madison Following Its Pesticide Policies?

While in Warner Park on September 8 2014, I saw a Madison Parks employee spraying Roundup[1] near the Warner Park Community Recreation Center (WPCRC), including along sidewalks just a few feet from the center’s bike racks, where many people, including young children, walk, bike, and play. It was a breezy day.[2]

A few hours later, biking through the park again on my way home, I didn’t see any standard warning signs. Two days later, walking through the park, I noticed one sign, under some shrubs, near a raingarden in a corner of the parking lot hundreds of feet from the center’s entrance and bike racks where I had seen Roundup applied two days earlier.[3] It was not at all “readily visible,” as required by the policy. The raingarden was fenced off, and it appeared as if plants in the raingarden were sprayed (presumably to eradicate non-native and/or invasive plants).[4] I walked around the raingarden and saw no other signs.

Madison’s Pesticide Policies

Citizens in many U.S. cities, including New York City, have questioned the use of Roundup and other pesticides in parks and other public places because of growing evidence of their toxic effects on animals, plants, and insects, which can lead to cascading effects on whole ecosystems over the long-term, and the health risks they pose to pets and people (e.g., see herehere, here and here and many more…).

Since at least 1991, Madison citizens have advocated for –and elected officials have passed—various policies restricting pesticides in the city. Unfortunately, it seems that these policies are being ignored, are not enforced, and/or are perhaps “forgotten” over time.

In 1991, the Madison Common Council passed Resolution 47.702, which called for limits on the use of pesticides in Madison.[5] In 2002, citizens raised concerns about the rising use of Roundup in city parks, after which Mayor Bauman issued a moratorium on its use and directed several city committees to review the use and safety of Roundup.

We haven’t yet located records of exactly what these committees decided, but presumably their reviews led to the development of the city’s Integrated Pest Management (IPM) policy in 2004. That year, the Public Health Commission also recommended the formation of a “subcommittee of pesticide experts that could assist staff with the evaluation of plans and pesticide use reports.” This subcommittee was directed, per Madison General Ordinance (MGO) 7.01(1)(a), to meet every year to review agencies pesticide use reports to see how well they complied with the city’s IPM policy and submit these reports to the Board of Health.

It appears that the IPM policy developed in 2004 is still Madison’s current pesticide policy (though the subcommittee was recently dissolved—see below). The purpose of this policy is described as follows:

“The purpose of this policy is to eliminate or reduce pesticide use to the greatest possible extent. The City of Madison agrees with the US EPA that “all pesticides are toxic to some degree, and the commonplace, widespread use of pesticides is both a major environmental problem and a public health issue.” For this reason, all departments will evaluate and give preference to non-pesticide management practices and use reasonably available alternative pest control methods, will minimize their pesticide use through Integrated Pest Management, and will use least risky pesticides as a last resort.” (highlights added).

Further elaborating on the conditions in which pesticides may be used (as a last resort), the document notes, “Chemical pesticide may be considered if: a. The non-toxic methods of pest control, such as Cultural Controls, Physical Controls, Mechanical Controls, and Biological Controls have been shown to be ineffective; And; b. Monitoring has indicated that the pest will cause unacceptable health or safety hazards, or an unacceptable reduction in the intended use of the property.”

Will the small plants growing on the edge of the Warner Park parking lots cause “unacceptable health or safety hazards or an unacceptable reduction in the intended use of the property”? It’s hard to imagine how they would do so. Our guess is that these Roundup applications were done for aesthetic reasons, which is not in line with an IPM approach.

Did Parks staff consider and/or try alternative methods to eradicate the harmless vegetation before resorting to Roundup? Parks staff and volunteers did use alternatives in the past. According to the 2009 IPM report for the Madison Parks Department (see bottom of pg. 17) in 2009 an organic herbicide called Ground Force (made of citric acid, garlic extract vinegar and yucca extract) was used for weeds in the WPCRC parking lot. No synthetic pesticides were used on the WPCRC property at all. What organic alternatives, or other types of strategies, were tried this year before resorting to Roundup?

Regardless of Parks’ rationale for using Roundup in this context, if it was following IPM policy, the non-chemical alternatives that were attempted before resorting to Roundup, and the success/failure of these attempts, should have been recorded. Moreover, the amounts and types of pesticides used in the recent treatment—as well as the amounts of types of all pesticides used during 2014 (to date) in Warner Park and previous years—would be recorded.[6] Were they?

Pesticide Policy Committee eliminated in 2013

It’s not clear how well city agencies are following IPM policies currently, especially since the ongoing oversight process established 2004 is no longer in place. In May 2013, Mayor Soglin and Public Health Madison Dane County decided to eliminate the Pesticide Policy Committee, repealing MGO 7.01(1)(a). A May 30 2013 PHMDC document explains the reason for eliminating the committee:

“The Pesticide Management Advisory Subcommittee has been a great help to the Board of Health and PHMDC staff. With the subcommittee’s help, most City of Madison agencies have become more adept at applying integrated pest management (IPM) principles and have sought out pesticide professionals that support these principles.”

After highlighting this apparent success in implementing IPM, however, the document goes on to hint at problems assuring that all agencies complied with the policy, in part because the subcommittee had little power: “However, PHMDC staff and subcommittee members have been frustrated at times when City agencies have not made changes or improvements identified in the annual reports. The current policy places the responsibility for change on the board, committee, or commission that has oversight over the agency in question (Paragraph 5d). If this body does not support change in the agencies practice based on recommendations of the subcommittee, neither PHMDC nor the subcommittee have authority to pursue further action to ensure compliance.”

Recent documents indicate that the pesticide policy is still in effect despite the dissolution of the committee. The Pesticide Management Report for 2012-2013 states the following:

“…Reduction of pesticide use is important because misuse or overuse of pesticides is both an environmental problem and a public health issue…The Policy on Pesticide Use on City Property will remain in effect and Departments will be required to submit annual use reports/plans to Health, but review of the reports will be internal within Health.  The plan for the future will be a more informal review and to make the reports available for public comment/review, most likely online….While not perfect, it was felt that the majority of City Agencies have adopted IPM principles and practices since the Policy was implemented in 2004, and formal oversight by the committee was not needed.  Also factoring, was the difficulty in maintaining a full committee in recent years.” (underlining added)

If most agencies “have adopted IPM principles and practices” and “formal oversight by the committee” is “not needed,” then PHMDC should have detailed reports of their pesticide uses and amounts for 2014 and previous years, as well as alternatives attempted. We located only one fairly thorough report online from Parks for 2009 (linked to above), but no others. For other departments and years since 2004, we were only able obtain electronic copies of “Pesticide Management Reports.” These reports are not available to the public online as far as we can tell.

Further, the “Pesticide Management Reports” are not IPM reports; they are very brief summaries by PHMDC staff that do not include any pesticide use details. For instance, the 2012-2013 Pesticide Management Report (linked to above), which is similar to all the other reports, simply states “yes” under compliance for the Parks Division, and under “Successes and Commendations” it says “Good use volunteer efforts in non-chemical control.” Under “Concerns,” it says “none.” In 2014, as we recently witnessed, Parks decided that Roundup should be used around Warner Park Center parking lots and raingardens and it is not clear whether non-chemical controls were attempted. We would like to know what the rationale was for these applications, what alternative were considered, what quantities of pesticides were used, and where they were applied.

In sum, if IPM is indeed being followed by City of Madison agencies, then reports with specific IPM details should be available to the public online, with opportunities for the public to comment and provide input on them–the “plan for the future” stated by PHMDC in the 2012-2013 document cited above. At this point we are not aware of online IPM reports or opportunities for citizen comments.

We look forward to online, detailed IPM reports for City of Madison agencies, as well as opportunities to provide comments and input on them. Hopefully this plan will be implemented soon.


[1] The applicator told me what she was spraying.

[2]The pesticide applicator was wearing shorts, a short-sleeved shirt, and no protective gear (not even gloves). This seems inadequate to protect the applicator from dermal, eye, and/or inhalation exposures from pesticide spills or aerial drift. Typical guidelines usually wear latex/rubber gloves, protective eyewear, long pants, long-sleeved shirts, etc.

[3]According to Madison’s IPM policy, “A standard notification plan that provides, at a minimum, readily visible posting for a period of 24 hours prior to a pesticide application (when possible) and a minimum of 48 hours following the application. These time intervals may be extended based on health or safety concerns. For areas that receive pesticide applications on a regular basis, permanent signs will be posted.”

[4]Raingardens are created to facilitate the infiltration of water downward to groundwater—in part, to prevent potentially harmful runoff from going into surface water. It is a good thing to keep pesticides from running off into surface water, but if pesticides are sprayed on raingarden plants (native or not), they and/or their breakdown products (often just as if not more toxic than the active pesticidal ingredients) may filter down into groundwater. This is a troubling tradeoff. What quantities of pesticides were sprayed on this raingarden? What alternatives were attempted?

[5]The details of this policy are uncertain. Some newspaper articles give the impression it restricted pesticide use in the entire city, and others suggest it restricted use only on Madison Metropolitan School District properties. We are still doing research to learn the specifics of this past policy.

[6]According to Madison’s 2004 IPM Policy: All departments will maintain appropriate records on pest monitoring data collected, pest control actions attempted (both non-chemical and chemical), and results of pest control activity. All departments will submit by February 1st an annual report to the Public Health Commission. This report will contain the following information:

a. Completed Pesticide Application Summary for all pesticide applications made in the previous year. Application data must include: purpose, location, and amount of each pesticide product applied, including the amount of active ingredient.

b. Annual summary of non-chemical pest control activities.

c. Estimated size of the total area managed for each pest problem in a given year. The area managed will likely exceed the area treated.

d. A summary of any complaints received regarding use or the perceived need for use of pesticides, including the date complaint(s) was (were) received and thenature of the complaint(s).

e. A pest management plan for the coming year. The plan will contain the following information for each type of pest problem:

1. Definition of Roles. Identify who will: serve as the IPM Coordinator, perform pest monitoring, evaluate pest control alternatives, decide which pest control alternative to use, and implement pest control measures.

2. Pest Management Objectives. Identify the action thresholds (i.e., pest population levels) to be used to decide when some type of action should be taken to control the pest problem.

3. Monitoring Plan. Describe the methods to be used to monitor the pests and the frequency of monitoring.

4. Control Method Selection. Describe the types of pest control methods to be evaluated and the criteria used to choose the appropriate control method.


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Where does the raingarden pipe originate? (Kipp Question # 3896? We’ve lost count…)

Where does the raingarden pipe originate? (Kipp Question # 3896? We’ve lost count…)

At long last, one MEJO question (unlike most we have asked, which remain unanswered) has been answered!! [1] Storm water runoff entering the pipe that empties into the raingarden originates at a storm drain in Kipp’s Waubesa/Atwood parking lot (see here and here; blow up to at least 200% to see map). After entering the storm drain in the corner of this parking lot, the water moves north, along the western edge of Kipp’s Atwood plant (behind all of homes on Waubesa) in an open concrete ditch and a concrete pipe beneath. The pipe then goes under the Kipp building. After going under the building, it gathers waste water from various drain pipes in Kipp’s facility and northern parking lot (including the pipe that for decades captured highly contaminated wastes from the former toxic waste “ditch” area; see story and maps here)—before it veers northeast and empties into the Kipp “raingarden” (aka Sludge Garden). As it travels behind the homes on Waubesa, it captures waste water and runoff coming off Kipp’s roof and pipes on the west side of the Kipp facility, which drip into an open concrete ditch with catchment drains emptying into the storm sewer pipe beneath the ditch. As the map depicts, here is a large “catch basin” right behind 233 Waubesa, just before the sewer pipe goes under the Kipp building.

[1] We won’t bore anyone with the long convoluted story about the rather ridiculous means we had to resort to in order to get a specific answer to this question…

Of course, this one answer raises even more “unanswered questions” Here are some from MEJO and the community:

How deep is this storm drain?? When was it built? What has drained/dumped/leaked into it over the years? What drains into it now? In what condition is it? (e.g., how leaky is it?)

Did the DNR first obtain this 1994 storm sewer map from Kipp on June 16, 2014 (after MEJO asked repeatedly where the raingarden pipe came from)? Did they really not know about the route of this storm sewer drain before?

Why don’t any of the Arcadis reports to date depict this the full length of this storm sewer? (many reports don’t show it at all)

Why doesn’t Kipp have a more recent storm sewer map? Why doesn’t DNR ask them for one? Why did DNR not share this (or a more recent storm sewer map, if they have one) with MEJO, given that our repeated questions about the raingarden pipe’s origins led DNR to ask Kipp for the map in the first place? (MEJO eventually found the map in an open records request). What do they not want MEJO and the public to know?

Did DNR ever share this map with other agencies (DHS, PHMDC, EPA, city engineering) involved in assessing the PCB contamination in the backyards of the Waubesa St homes, Kipp raingarden contamination, and/or other Kipp pollution issues?

Could this storm drain have anything to do with the PCBs found in the backyards of the Waubesa homes (excavated May 20-June 27, 2013)?

Did the PCB contaminated soils in the backyards on Waubesa Street and along Kipp’s western edge wash down into the open ditch and storm drain into the raingarden before, during, and/or after excavation? (PCB contaminated soils from the Waubesa excavation were piled on the north parking lot for a while, which also drains into the raingarden).

If DNR knew about the route of this storm drain before June 2014 (e.g., before/during the investigations/excavations of the PCBs in the yards on Waubesa Street), why don’t any of the reports on the PCB investigations on Waubesa St, which include numerous maps of this area, depict it or mention it in any way?

Where were the PCB “base” and “wall” data points in Arcadis PCB reports relative to this storm drain, the catchment basins, etc?

Could the large catchment basin behind 233 Waubesa depicted in the Arcadis map be related to the relatively higher levels of PCBs found right about at that spot?

Why does the 1994 map not depict the sanitary sewer lateral that runs in between 253 and 257 Waubesa Street—see this map. Was this sanitary lateral built later? When? Might this lateral have anything to do with the higher levels of PCE vapor found in 253 Waubesa and 257 Waubesa St. homes (subslab vapor levels in these homes were much higher than other homes on Waubesa)?

There are many more questions….please send yours to and we’ll add them.

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According to DNR’s strange math, Kipp’s PCE plume has reached or passed Well 8, but has not made it to Lake Monona…What?

According to DNR’s strange math, Kipp’s PCE plume has reached or passed Well 8, but has not made it to Lake Monona…What?

Recent updates from DNR and PHMDC (see most recent one here) on the ongoing Kipp pollution nightmare are full of careless errors, misleading statements, and critical omissions. Citizens deserve better from their public servants in government agencies.

As we wrote in our previous post, the PHMDC “evaluation” of Goodman Center splash pad health risks included incorrect “residual contaminant level” (RCL) numbers as well as other miscalculations.

DNR updates also include errors and problematic claims. Here’s one example. Answering the question posed by the community, “Will Lake Monona be affected by MKC’s groundwater contamination, since it is moving south?” DNR responded:

Before the full system of groundwater monitoring wells was in place to collect data concerning the tetrachloroethene (PCE) plume, this question was unable to be answered. Now that a volume of data has been produced by the 16 wells surrounding MKC, an analysis can be done to determine the fate of the contaminated plume of groundwater. It is believed PCE from the Kipp facility has been in the environment for approximately 40 years; the plume has stabilized. Since the regional hydraulic gradient for the deep aquifer does run southeast, the plume has extended an estimated 1,900 feet towards Lake Monona. However, because it appears the plume has stabilized, there will be no danger of it reaching Lake Monona, which is still approximately 800 feet away. Arcadis’ evaluation of the PCE plume can be accessed here.

These statements are nonsensical—here’s why:

-DNR says “It is believed PCE from the Kipp facility has been in the environment for approximately 40 years.” (DNR doesn’t say who “believes” this.) Yet countless DNR and Kipp documents say that Kipp started using PCE in the 1940s—and it is well-documented that PCE and numerous other chemicals, most of which are highly persistent in the environment, were purposely dumped from, emitted from vents, and/or spilled and leaked from the facility since then. Do the math. If Kipp started using PCE in the 40s, their PCE and its breakdown products have been “in the environment” (soil, groundwater, air, plants, fish, wildlife, people) for somewhere between 65-74 years, not 40 years.

-The DNR statement above says the plume “has extended an estimated 1900 feet towards Lake Monona.” On pg. 2 the Arcadis evaluation of the PCE plume cited says that “Municipal Unit Well 8 (Unit Well 8) is located approximately 1,400 feet southeast of the site.” Again, do the math. DNR’s statement suggests that the plume has reached or even passed Well 8 (depending on where you measure from).[1] Though many suspect that the plume reached and passed Well 8 a long time ago, this is likely not what the DNR intended to say, given that they and Kipp have stated repeatedly in recent updates that the plume has not reached Well 8. (Why doesn’t PCE show up in well tests? More on that in a future story…).

-Based on the numbers in the DNR update, Lake Monona is about 2700 feet away from Kipp measuring on a line to the southeast (going through Well 8).[2] The lake is approximately 1734 feet from the Kipp property edge on a line to the southeast going through Well 8. Even if one measures from the center of the Kipp site, the lake is not 2700 feet away.

-There is insufficient evidence to say that the plume has “stabilized.”[3] The edges of the plume have not yet been defined. Kipp’s consultants’ evaluation of the plume (link above), claiming that it has “stabilized,” uses a problematic methodology and is still under evaluation by independent experts. The Arcadis analysis has not been accepted by the Madison Water Utility as the final word on the plume.[4]

-Lake Monona is only 1550 feet from the Kipp measuring along a straight line south from Kipp’s property line. Numerous Kipp consultant documents going back to the 1990s say the shallow and intermediate depth groundwater was traveling south as well as southeast. Given the rate of travel in surface and groundwater, PCE and other contaminants would have made it to the lake by now.

-Though assessing “preferential pathways” such as storm and sewer drains by which PCE and other toxic contaminants could have spread over decades in many directions from Kipp should be one of the first steps in developing a conceptual site model (CSM)—and is among the most critical components of a CSM—DNR and Kipp have never done so (as far as we know, and we have asked repeatedly). There are many storm and sanitary sewer drains all over Kipp leading out in every direction (see here and here).

It is well documented that Kipp put PCE wastes down storm and sewer drains for decades—well into the 1990s and likely later. Contaminated soils and other materials being excavated all around the Kipp site, including some that are contaminated with PCBs and PCEs, are still going down storm drains. Some storm drains from Kipp empty into Starkweather Creek, which drains into Lake Monona. Others go to the south/southeast and empty directly into Lake Monona. Sanitary sewer drains, which send water to the Madison Metropolitan Sewerage District, usually leak sooner or later. Sanitary sewer drains leading out from Kipp most likely leached PCE into soils and groundwater all along their pathways, including several going towards Lake Monona.

In sum, it is scientifically unfounded to state that “there is no danger” of the PCE plume reaching Lake Monona. In fact, based on the available science, it is likely that PCE and other toxic chemicals from Kipp made it to Lake Monona a long time ago via surface water and sediments, as well as via groundwater. People who eat fish from Lake Monona, including many subsistence anglers, have likely been eating Kipp’s pollution for a long time.

Sadly, since the DNR and Kipp have repeatedly refused to assess preferential pathways, and refused to test groundwater directly to the south of Kipp, we will never have any data to show whether or not that is the case.  Obviously, Kipp and the DNR do not want to know the truth about this—and most definitely do not want citizens to know.

To be continued…

[1] Even if the distance is being calculated from the purported center of the plume in the northern parking lot, 1900 feet would put the plume about at Well 8.

[2] Again, even if the distance is calculated from the center of the plume, this number is way too high.

[3] Note that even the DNR can only say “it appears” the plume has stabilized

[4] Kipp obviously has a strong bias towards concluding that the plume has stabilized and will not reach the lake. Why would the DNR indicate to the public that Kipp’s consultant’s analysis of the plume is unbiased and conclusive science—and is the final word? Who does the DNR work for—Madison Kipp or the citizens of Wisconsin? Sadly, it appears to be the former.



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