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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