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Madison-Kipp Corp.

Madison-Kipp Corp. is a century-old aluminum and zinc die cast factory located in the Atwood neighborhood of Madison, Wisc. The factory is adjacent to homes, a community center, food gardens and 200 feet from an elementary school. With abutting property lines, many houses are within 50 feet of the actual factory. Pollutants include PCBs, dioxins, PCE, TCE, vinyl chloride, heavy metals along with many greenhouse gases. Dr. Lorne G. Everett, an international hydrogeology expert who has investigated hundreds of contaminated sites worldwide, calls Kipp “one of the most contaminated sites that I’ve ever worked with.”

More Alarming PCB Hotspots Along City Bike Path Next to Goodman Center; Public in the Dark

More Alarming PCB Hotspots Along City Bike Path Next to Goodman Center; Public in the Dark

Kipp’s Sludge Garden Saga continues… an Arcadis (Kipp’s consultants) report dated August 6, 2014 includes data generated in April and May of this year showing the highest PCB hotspots found to date–550 ppm and 1020 ppm–from soils excavated at the far west edge of the raingarden (see pg. 13 of above report), right next to where a Kipp storm drain pipe emptied contaminants into the raingarden area for decades. These levels are far higher than in previous rounds of excavation in the raingarden, which also revealed many PCB hotspots.

The highest PCB level found in recent excavations, 1020 ppm, is 1457 times the DNR’s industrial direct contact residual contaminant level (RCL) of 0.7 ppm and 5100 times the non-industrial (residential) RCL of 0.2 ppm.[1],[2]

Oddly, the Arcadis report does not mention the sources of the PCBs. Moreover, it does not state the depth of these samples, making it very difficult to assess what the past and current sources of the PCBs might be, how and where the contaminants might travel over time, and how likely it is that people will be exposed to them now or in the future in different contexts.

Though some soils in the raingarden area with the highest detections of PCB have been removed, soils in much of the area could not be excavated because of buried utility lines, and the full extent of the contamination remains unknown. Contaminated runoff from the northern part of the Kipp property continues to discharge from the stormwater pipe that drains into the raingarden, as Kipp removes/repaves parking lots and constructs the groundwater extraction system. Soils in the northern parking lot area, where most of this work is occurring, are among the most contaminated soils on the site.

The City of Madison land on which these hotspots were found is next to a heavily used city bike path along which many children bike and play every day (see here and here) and just across from the ill-advised Goodman Center children’s splash pad, currently under construction. Throughout the excavations, no signs have ever been posted to let people know what is going on and to keep children and pets away.

To date, this PCB data has not been shared with the public by Kipp, DNR, or another agency. It is not posted on the DNR website and it is not in the Hawthorne Library.[3] Why not?

 

[1] Though government agencies are using the industrial RCL, given that this is public land feet away from a public bike path and a community center, the lower, more protective non-industrial (residential) RCL should be used.

[2] Four samples analyzed just last week to the west of these hotspots under Kipp’s driveway (leased from the City of Madison) showed much lower levels of PCBs, but consultant reports again do not include the depths of the samples, or even maps of their locations, making it difficult to assess the importance of these findings.

[3] Several years ago, people in the Kipp neighborhood asked DNR to place hard copies of critical Kipp and government documents relevant to Kipp’s soil and groundwater pollution (including consultant reports as well as DNR and other agency reports and communications, etc) in the Hawthorne Library for people who do not have internet access. Although there are several large Arcadis reports in the library, the recent raingarden data is not there and to date none of important Kipp-related DNR and other agency documents have ever been placed there other than a few very old DNR reports on Kipp’s site investigations.

 

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A “Healthy and Safe Place” for “Good Clean Fun”?

A “Healthy and Safe Place” for “Good Clean Fun”?

Is this a safe place for children to frolic in a splash pad? Here are some of the toxic contaminants and safety risks not visible in the above photo…

A post in today’s Cap Times online raises important questions about whether the children’s splash pad planned at the Goodman Community Center will be a “healthy and safe place” for “good clean fun,” as the center’s Executive Director Becky Steinhoff assured us it will be in the May/June issue of the Eastside News.

Adding to questions raised in previous posts, there is a glaring omission in considerations about the safety of this location for a splash pad. Trucks carrying chlorine, toxic chemicals, and hazardous wastes to and from Kipp—and spewing hazardous diesel fumes—will rumble just feet past the children’s splash pad many times a day, every day.

Aluminum die casting is inherently toxic and dangerous, and Kipp has a lousy health and safety record. As we outlined in a previous post, between 1998 and Feb. 2014, the Madison Fire Department/EMS (emergency medical services) made 172 calls to Kipp for fires, explosions, accidents, and/or worker health problems and injuries.[1]

Kipp uses, stores, and transports chlorine, in addition to numerous other highly toxic chemicals. Chlorine is a highly toxic gas that can cause severe health problems (including death) to people exposed to high enough levels. Severe health effects from chlorine inhalation can occur within minutes—well before HazMat teams can get to the scene. The highest potential for such a release near Kipp is during the transport of chlorine; for details, see Kipp’s “Hazardous Materials Incident Initial Response Guidelines.” . With all the trucks going in and out of Kipp for well installation, remediation, etc., the chances of such an accident have likely increased in recent years.[2]

What will happen if there is a chlorine truck accident involving a chlorine release next to the splash pad while children are playing there? What plan does Goodman Community Center have in place for such an incident at its facility? Not long ago, community members asked Goodman Center staff this question and they had never heard of such a plan; they were clearly unprepared. How will the center staff handle such a chlorine or other toxic material accident next to a crowded splash pad? How will kids at an outdoor splash pad “shelter-in-place” if a chlorine spill happens 50 feet away?

[1] The actual number of fires, accidents and injuries is probably higher than this, since Kipp likely tries to avoid calling the Fire Department unless the accidents reach a certain severity level.

[2] Emergency Planning and Community-Right-To-Know (EPCRA)

MKC uses, stores, transports, and releases many highly hazardous chemicals, and is required to follow Emergency Planning and Community-Right-To-Know laws—see here for federal regulations and here for Dane County. Hazardous chemicals at Kipp include chlorine, propane, sodium hydroxide, nitrogen, fluorides, molten aluminum, fuel oils, lubricants and many more. The use, storage, and transport of chlorine are among the most potentially dangerous situations at and around Kipp. According to the “Hazardous Materials Incident Initial Response Guidelines” for Madison Kipp, “the worst-case scenario would involve chlorine being released directly to the outside of the facility during transport.”

Chlorine’s health effects: Permissible Exposure Level–1 ppm; detectable odor threshold–over 1 ppm; 3-5 ppm–slight irritation of the nose and upper respiratory tract; 5-8 ppm–irritation of the respiratory tract and eyes; 10 ppm– immediately dangerous to life and health; 15-20 ppm–immediate severe irritation of the respiratory tract, intense coughing and choking; 30 ppm–shortness of breath, chest pain, possibly nausea and vomiting; 40-60 ppm–development of chemical bronchitis and fluid in the lungs, chemical pneumonia. Prolonged exposure over 50 ppm will cause unconsciousness and death.

Two types of “vulnerability zones” for chlorine accidents at Kipp were modeled in Kipp’s Haz Mat Guideline document. One is the area in which chlorine levels could reach 1/10 of the IDLH (immediately dangerous to life and health)—or the level that “poses a threat of exposure to airborne contaminants when that exposure is likely to cause death or immediate or delayed permanent adverse health effects or prevent escape from such an environment.” The 1/10 factor is added to protect especially vulnerable people, such as those with respiratory disease or illness. The IDLH for chlorine is 10ppm so the 1/10 IDLH is 1ppm. An alternative vulnerability zone based on ERPG-2 (Emergency Response Planning Guidelines), or “the maximum airborne concentration below which it is believed that nearly all individuals could be exposed for up to one hour without experiencing or developing irreversible or other serious health effects or symptoms which could impair an individual’s ability to take protective action.” The ERPG-2 for chlorine is 3 ppm.

Vulnerability zones for chlorine releases are: 3.1 miles at 1 ppm (1/10 IDLH), 1.9 miles at 3 ppm (ERPG-2) “in the worst case scenario, dangerous or deadly levels of chlorine contamination may reach a distance of between .1 and .25 miles downwind of the source within a matter of minutes following the initial release.” Later, the document states that “The lead time for a HAZMAT incident could be from 15-40 minutes. As a result, this short time may not allow for a safe evacuation…An evacuation under these circumstances may expose the population to dangerous toxic chemicals and the decision may be made to shelter-in-place.” The document then lists 11 “shelter-in-place” recommended instructions.

**********

Do you live in the Kipp Neighborhood? If there is a chlorine accident at Kipp or an accident involving a chlorine truck on a street in the neighborhood:

-How will you know? Is there any system in place to immediately notify you and others in the neighborhood?

-Do you/your family know what the “shelter-in-place” steps are? Do staff at Goodman Community Center/Lowell School?

-Is the community prepared? Are people near Kipp even aware that the potential exists for such an accident?

If you live in the Kipp neighborhood, contact your elected officials, public health agencies, Madison Fire Department and OSHA, with questions. Ask them to look into whether Kipp is following EPCRA laws. Ask them to initiate a public meeting to help prepare residents, schools, and community centers for a chlorine and/or other hazardous chemical accident at or around Kipp. Always include your street address when contacting your political representatives.

Madison Alder Marsha Rummel: 608-772-4555, district6@cityofmadison.com

Senator Fred Risser: (608)266-1627, sen.risser@legis.wisconsin.gov

Representative Chris Taylor: (608) 266-5342, Rep.Taylor@legis.wisconsin.gov

John Hausbeck (Epidemiologist, Madison Dane County Public Health): 608.243.0331, JHausbeck@publichealthmdc.com

Henry Nehls-Lowe (Epidemiologist, Department of Health Services): 608-266-3479, Henry.NehlsLowe@dhs.wisconsin.gov

Dave Bursack, Dane County Local Emergency Planning Committee: 608-266-9051,

Madison Fire Department: 608-266-4420, fire@cityofmadison.com

Occupational Safety and Health Administration (Madison Office): (608) 441-5388

 

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“Forgotten” Kipp Toxic Hotspot Bubbles to the Surface Next to Goodman Community Center

“Forgotten” Kipp Toxic Hotspot Bubbles to the Surface Next to Goodman Community Center

Now that the neighborhood class action lawsuit against Kipp is settled [1] and Madison-Kipp has paid a total of $7.2 million dollars to homeowners near the factory, Kipp and government agencies would like all questions about risks to people living, working, and playing on properties adjacent to the factory to just go away.[2] With the Goodman Community Center about to build a children’s splash pad less than 50 feet from one of Kipp’s most toxic areas, unanswered questions about risks to people who spend time at the center, especially children and pregnant mothers, are more relevant than ever.

Just how toxic is the northern part of the Kipp property and the adjacent city property? Here’s a visual summary. Where did these high levels of contaminants come from? Do they pose potential risks to people at the Goodman Center? In a memo on April 30, 2013 (pg. 4) Dr. Lorne Everett, expert in the class action lawsuit, noted:

Considering the proximity of the Goodman Community Center (immediately north of Madison-Kipp) to high on-site PCE concentrations in soil vapor and given the fact that high levels of groundwater contamination are found even farther north, it appears that groundwater and/or soil vapor under the Goodman Community Center are impacted with Madison-Kipp’s contamination. It would be prudent to conduct soil vapor and subslab sampling at the Goodman Center but the Arcadis report completely omits a discussion of this off-site threat.”

Since the class action lawsuit was settled, even more data has been released that indicate testing at Goodman would be “prudent”—especially before allowing children to frolic at a splash pad just feet away.

Instead, Kipp and government agencies seem to be digging their heads deeper and deeper in the sand. Read on…

High Soil Vapor Results along City of Madison Bike Path

The most recent publicly available data from the northern boundary of Kipp’s property and on the City of Madison property between Kipp and the Goodman Center begs for more testing of groundwater, soils, and vapors on the Goodman property. Three rounds of soil vapor tests (two in 2012, one in April 2013) just south of the bike path on City of Madison property—only about 20-30 feet from where the splash pad will be—have shown increasing levels of vapors in the soil only about 7-8 feet down. In April 2013, the soil vapor probe directly across from the splash pad area (VP-6) showed alarmingly high vapor levels: PCE: 19,000 µg/m3; TCE: 6,100 µg/m3; cis 1, 2 DCE: 8,200 µg/m3; trans-1, 2 DCE: 320 µg/m3; Vinyl chloride: 340 µg/m3.

Shhhhh….Kipp Doesn’t Want Anyone to Notice…

Madison-Kipp seems to be purposely trying to downplay (or hide?) these important results on how contaminated the north side of their property is and how their operations have contaminated the City of Madison property adjacent to it. The most recent soil vapor data was part of the 2013 Kipp Annual Report not released till April 2014.[3] The very high VP-6 results were tucked away at the end of a huge table in a separate document (p. 152) that was not included with the actual Annual Report document, and now doesn’t seem to be easily accessible anywhere. Results were reported in ppbv (parts per billion by volume), which looks much lower than the more standard reporting units of µg/m3 (micrograms per cubic meter).

Oddly, Kipp consultants used the less protective, non-residential screening levels with an attenuation factor of 0.001 for deep soil gas to indoor air (vs residential attenuation factor of 0.01), which allowed these very high vapors levels not to be flagged as exceeding the “Wisconsin Residential Deep Soil Gas Calculated Screening Levels.”[4] Using the deep soil gas, non-residential attenuation factors and screening levels in this context is questionable, for a number of reasons (and depend on who is the focus of the risk assessment—see discussion below). The groundwater at this location tends to be very shallow; in spring 2014 the groundwater was only a few feet down and all the 7-8 feet deep vapor probes on the bike path were under water. Also, the probes are on public property (City of Madison), not Kipp’s property.[5],[6]

Further, the text of the Annual Report doesn’t mention these high vapor probe results and the fact that vapor levels at VP-5 and VP-6 have increased significantly in recent tests. Instead, it states disingenuously that “In general, the 2013 data are consistent with previous vapor probe data.” In fact, the 2013 VP-5 and VP-6 levels are significantly higher than the previous tests. For instance, vapor probe 6 levels for just PCE went from 63 ppbv (413 µg/m3) on 3/3/2012 to 190 ppbv (1245 µg/m3) on 10/26/12 to 2900 ppbv (19,000 µg/m3) on 4/29/13—increasing by 46 times from the first to the third test. PCE breakdown products TCE and vinyl chloride, which are even more toxic than PCE, also increased significantly at this probe and at VP5. The obscure placement of these results, use of deep soil gas attenuation factors and non-residential screening levels, use of ppbv instead of ug/m3 in reports, and dishonest discounting of them in the Annual Report seem to be attempts to make it more likely that the few people who ever see find these results buried in reports will skim over them without notice.

What Potential Exposures are Being Assessed? Exposures to Workers, Children at Goodman, or Anyone At All?

The kind of attenuation factors and screening levels risk assessors choose typically depend on whether nearby buildings (into which vapors might enter) are industries, businesses, homes, schools, community centers, etc.—which in turn determines what kinds of people might be exposed to vapors and to what extent.

If the goal is to assess vapor risks to workers in the Kipp factory, non-residential attenuation factors and screening levels would be more defendable (though still problematic).[7] However, the original reason for the probes along the bike path, as far as we understand (based on our conversations with Henry Nehls-Lowe at Department of Health Services),[8] was to explore, moving outward from Kipp, how far vapors extend away from Kipp towards Goodman Community Center. The more protective residential attenuation factors and screening levels are typically used for schools, daycares, and community centers such as Goodman. In other words, if the goal is to assess potential risks to people at the Goodman Center building, the residential attenuation factor of 0.01 should be used—which would put these levels well over the residential screening levels, indicating that more testing should be done.

Why are the vapor probes along the bike path in the first place?

While the levels found at vapor probes along the bike path raise big red flags about the Goodman property, because they suggest that there is a strong contaminant source nearby, they do not tell us whether or not vapor intrusion might be occurring inside the Goodman Community Center building.

EPA’s OSWER Draft Guidance for Evaluating the Vapor Intrusion to Indoor Air Pathway from Groundwater and Soils (Subsurface Vapor Intrusion Guidance (OSWER is the Office of Solid Waste and Emergency Response) [9] recommends that buildings be assessed for vapor intrusion when they are “within approximately 100 ft laterally or vertically of known or interpolated soil gas or groundwater contaminants” and the “contamination occurs in the unsaturated zone and/or the uppermost saturated zone.” (p. 16).   The EPA OSWER guidelines also highlight that “It is important to consider whether significant preferential pathways could allow vapors to migrate more than 100 feet laterally. For the purposes of this guidance, a “significant” preferential pathway is a naturally occurring or anthropogenic subsurface pathway that is expected to have a high gas permeability and be of sufficient volume and proximity to a building so that it may be reasonably anticipated to influence vapor intrusion into the building. Examples include fractures, macropores, utility conduits, and subsurface drains that intersect vapor sources or vapor migration pathways.”(emphasis in original) Building conditions, weather, water table fluctuations, other buildings, barometric pressure, and all sorts of other factors can also influence vapor intrusion in buildings. In some contexts buildings further away from deeper groundwater sources can have more vapor intrusion problems than those closer to sources.[10] Give all of this, repeated tests in the subslab of the Goodman building (which is within 100 feet of contamination on Kipp and city property) in several locations in the building over time (in different seasons) would be the more appropriate way to assess, or rule out, vapor intrusion and potential exposures to people there.[11]

Kipp, Wisconsin Department of Natural Resources (DNR), and Department of Health Services (DHS) have repeatedly claimed that the groundwater contamination under Goodman is too deep to cause vapor intrusion. However, to date, as far as we know, just two groundwater samples have been taken on the Goodman site– from only one shallow depth (7-17 feet) from a well far from the Goodman building on the east side of the property. The August 2013 sample found PCE at 1.4 µg/L, and the October 2013 sample was less than 0.17 ug/L PCE. Based on this, Kipp’s CEO Tony Koblinski assured the public in his March 19, 2014 presentation (Part 2, 15-16 minutes in) that they had verified, with a “no detect” that “there isn’t any PCE in the shallow groundwater that would cause a soil vapor concern” at Goodman. These limited groundwater results, at one depth, hundreds of feet from the Goodman building, are nearly meaningless as far as assessing vapor intrusion there.

Also, as far as we know, Kipp has not investigated any potential preferential pathways, such as sanitary sewers and storm sewers, electric and gas lines, etc., all around and in between Kipp and the Goodman Center that could have routed shallow level contamination offsite, causing soil and groundwater contamination and/or vapor intrusion along these conduits. Mapping these preferential pathways is supposed to be one of the very first steps in developing a “Conceptual Site Model” (CSM) in the initial stages of site investigations for VOC contaminated sites (as MEJO and our collaborators pointed out to the DNR/DHS/PHMDC/Water Utility and city engineering team when we met with them in February 2012).

Do government agencies really think enough is known to rule out vapor intrusion at the Goodman Community Center, from contaminated groundwater and/or shallow soils on Kipp’s northern boundary, or both? Interestingly, DNR’s vapor intrusion expert Terry Evanson, in an April 15 2013 memo reviewing Kipp’s Site Investigation report, stated that: “The vapor pathway, including all buildings at risk, both on and off-site, needs to be addressed in the SI” (site investigation) (highlights added). Yet as of spring 2014, even with the planned splash pad, neither Kipp nor DNR have any intention of testing soils, soil gas or vapors anywhere near or in the Goodman building—or groundwater beneath it. Just as troublingly, soils on the site, which had significant contamination due to past industrial activities, haven’t been tested for contaminant levels since before the site was remediated (no confirmation/post-remediation soil testing was done by the consultants).[12],[13]

We are not surprised that Kipp is denying that there could be problems at Goodman related to their operations. We are not surprised Kipp is ignoring evidence, scientific studies, and government guidances on assessing pollution and health risks. We are not surprised that Kipp is not very concerned about environmental laws or exposing children to toxic pollution. But why do some government agencies seem to be going along with this approach as well? Perhaps it is because Kipp’s law firm Michael Best and Friedrich advised them to stay away from the City of Madison public property adjacent to Kipp as well as the Goodman Center?[14] Perhaps all these entities are worried about the messy political can of worms a more thorough investigation of Goodman site might uncover, because Kipp has supported Goodman Center financially for years and City of Madison property is in between Goodman and Kipp? Perhaps they don’t want anyone to uncover the evidence that Kipp lubrication division, KLS Lubriquip, which used PCE, operated and/or stored materials at the Goodman site in the past (see our previous article)?

What’s the Vapor Source for High Levels Along Bike Path?

The increasing contaminant trends at the two vapor probes (VP-5 and VP-6) along the bike path strongly indicate that there is a high contaminant source nearby. What might it be? Contaminated groundwater was just inches below Vapor Probe 6 when the April 2013 vapor tests were done, so contaminant vapors may have come from the groundwater itself. Though shallow VOC levels at the nearest water table well (Well 1) in 2012-2013 tests were not particularly high, in levels at Well13, just feet to the south of that, have been consistently the highest at the sight (though the shallowest measurements are 44 feet and the water table is well above that). However, Kipp has not shared all the data about groundwater results near these vapor probes. Groundwater data from “temporary wells” on the Kipp site in 2012, never shared with the public, showed the following levels at B51, at the northeast corner of the Kipp building, not far from VP-6: 1500 µg /L PCE, 500 µg /L TCE, 4078 ug/L cis/trans DCE, 890 ug/L vinyl chloride. These results are particularly concerning because of the very high levels of PCE breakdown products (TCE and vinyl chloride), which are considerably more toxic than PCE.[15] It is not clear how deep these tests were.

In addition to groundwater, there is another likely source of the contaminated vapors at VP-5 and VP- 6—highly contaminated soils along the former storm sewer that runs from the contaminant hotspot on the northern edge of the building, along the northern edge of the property, and empties into the former raingarden. The end of the pipe that emptied into the raingarden, uncovered in the most recent excavation of the raingarden (see photo above), emptied much of the highly contaminated wastewater from Kipp’s processes into this area for many decades. Several other storm sewer pipes—most likely including some from the contaminated areas further south on the Kipp site—drain into this pipe.

Where did the contamination that went into the ditch and storm sewer come from? According to the 2012 deposition of former Kipp “environmental manager” Jim Lenz during the recent class action lawsuit, there were storm drains all over Kipp’s northern parking lot. Apparently Kipp built storm drains purposely routed north, which joined together into one pipe that emptied into the rain garden area (which then routes runoff to the northeast corner of the property). The contamination entering this “contaminant watershed” came from leaking above ground PCE tanks that drained into the ditch, vapor degreasers along the east side of the plant that vented outside (condensing contaminants onto the soil), and other contaminated areas on the site. Some PCE and various other wastes were purposely dumped outside by Kipp workers, and according to Mr. Lenz one dumping area was off the northern corner of the building (near the northern end of the ditch that connected to the storm sewer pipe). After the parking lot was paved, the oils on the parking lot, which included PCBs, PCE, and other contaminants, ran off to the north over the surface and via underground storm sewer drains.[16] There is evidence that Kipp employees continued to dump chlorinated compounds and other toxic wastes into storm and sanitary sewers through the 1990s if not longer.

Kipp Waste Ditch and Storm Sewer Were Focus of Investigations in the 1990s

Though most recent documents cite 1993-94 as the first discovery of Kipp’s groundwater and soil contaminant problems, engineering consultants (and likely DNR and Kipp as well) knew Kipp might have a groundwater problem when testing at the Kupfer Ironworks site in1986 found some chlorinated compounds in groundwater that were attributed to Kipp operations.[17] It isn’t clear what happened after this initial discovery of chlorinated compounds at the Kupfer site, but in 1993 PCE was found at the Brassworks property and again attributed to Kipp. In 1994, the DNR asked Kipp to formally investigate the contamination, after which a series of investigations by Kipp consultants Dames & Moore was launched.

Dames and Moore’s investigations focused on the northern ditch and storm sewer through the 1990s, after which these sources abruptly disappeared from reports. Dames and Moore noted in one of its first reports, on Dec. 14 1994, that “It is probable that the chlorinated VOCs discovered in the soils at the Madison-Kipp site is (or was), within the “watershed” which contributes to the ditch.” (italics added). Reports clearly diagramed the location of the ditch and storm sewer (e.g., 1996 Dames & Moore Kipp report, March 1997 Dames and Moore report and May 1997 Dames and Moore report; downloading documents can take some time).

All the consultant reports throughout the 1990s outline extremely high levels of soil, soil gas, and groundwater CVOCs (chlorinated volatile organic compounds) as well as benzene, xylene, toluene, and napthalene contamination throughout the ditch and storm sewer area. Reports are clear that the ditch and sewer route were significant contaminant sources that had already impacted groundwater. For instance, the March 20, 1996 Dames & Moore report says: “…soil sample analyses reveal a source area for chlorinated VOCs” in an area “coincident with a former drainage ditch, which extended from the building at the south end (upgradient, adjacent to the former above ground PCE tank), northward until it terminated at the northeast corner of the building. At the terminus, a pipe transferred runoff from the ditch to the storm sewer.” Interestingly, according to this report, the PCE tank “was taken out of service several years ago, the ditch was filled in and the area paved in 1995”[18] (italics added).

The 1995 document reported extremely high levels of CVOCs in soil gas down to 18-20 feet.[19] Consultants admitted that this ditch/storm sewer area is a “source for the transport of chlorinated compounds to the water table” and that “contaminants have migrated into the sandstone bedrock.” However, consultants proposed to do a pilot study on potential remedial options and initiate groundwater extraction and containment.[20]

The March 18 1997 Dames & Moore document reported that the extraction well (EW-1, which appears to be near where MW 13 is currently) along the sewer drain, 10-20 feet off the northeast tip of the factory, had 150,000 µg/L PCE. [21] Again, the report highlights the storm sewer as the source of contaminants. The May 30, 1997 Dames & Moore document, which didn’t mention EW-1,reported stunningly high levels of PCE in shallow soils (2-4 feet) at GP-9, a boring just off the northeast corner of the building: 6,440,000 µg/kg PCE; 126,000 µg/kg TCE; 30,900 µg/kg cis-1,2, dichloroethylene, as well as high levels of benzene compounds, xylenes, toluene, and naphthalene. They also found high levels of most of these compounds 8-10 feet down at this location. Just feet away from that, “beneath a drain pipe which is covered with thick concrete,” where a catch basin pipe joined with the storm sewer pipe, and further along the storm sewer drain, very high levels of CVOCs were found in soils.

Consultants dropped plans for excavating and propose a site specific standard of 1000 ug/kg for soils…

Despite these high levels, consultants concluded that “complete soil remediation by means of excavation” was “technically and economically infeasible” because “the depth of impacted soil (18 to 20 feet) would result in the need for areally (sic) extensive excavation or significant shoring requirements for soil stability” and “utilities and other obstructions would likely prohibit either of these options.” Instead, Kipp and its consultants proposed “a modified excavation” of 8-10 feet of soils in two areas, combined with soil vapor extraction, to remediate soils impacted above “site-specific residual contaminant levels” (RCL). Consultants came up with  “site-specific” groundwater and soil RCLs based on equations (from a 1982 paper) and some problematic assumptions about “natural attenuation,” plume size at that time, and groundwater depth. Based on this, consultants recommended a site specific RCL for soils of 1000 µg/kg (or 1 mg/kg)—over 200 times the DNR’s soil to groundwater pathway “residual contaminant level” (RCL) of 4.54 µg/L for PCE in soils.

Kipp’s Northern Hotspot Was Never Adequately Remediated (but after 2000 it disappears from reports)

Oddly, consultant reports after 2000 lack any discussions of the ditch/storm sewer route or any other preferential pathways.[22] Dames and Moore’s 1999 and 2000 reports discounted soil vapor extraction as not feasible “due to the low permeabilities of the soil unit containing the highest concentration of PCE.”[23] Further, the consultants concluded that the previously planned excavation of the two hotspots was “unworkable” because of proximity to the 100-year old building, buried utilities, and because the most contaminated areas were in high levels of vehicle traffic.

Instead, they decided to inject an oxidizing reagent (BiOx) that would “react with the VOCs to chemically degrade them to harmless by-products.” Several bioremediation treatments were done in 1998 and 1999, and verification samples were taken in 1999. The March 21, 2000 report highlights a significant reduction in PCE concentration, but after the BiOx treatments, several verification samples still exceeded the 1000 µg/kg site specific RCL for PCE significantly in the northern hotspot area. The GP-9 area off the northernmost corner of the building had 329,000 ug/kg after remediation, 329 times Kipp’s site specific RCL and over 72,000 times the DNR’s soil to groundwater pathway RCL. PCE breakdown products were also present in significant quantities after the treatment, as were petroleum constituents.

Regardless, after the 2000 report, testing along the storm sewer route seems to have stopped. The ditch and storm sewer were no longer included in maps and diagrams in reports, and there are no further discussions of this major source area on the northern part of the site. During the 2000s, reports occasionally referred to a “former source area” or “previously defined source areas,” and a couple mentioned successful remediation there, but they did not identify or map where they were, or report any data from the storm sewer area.

All attention instead shifted to another source area (the former degreaser vent area) along the eastern side of the plant. This source was significant, and important given the proximity of homes, but the disappearance of any explicit discussions about the ditch and storm sewer was sudden and likely not an accident. Though the BiOx treatment had reduced the levels of contaminants in some particular hotspot areas, levels remained high in soils throughout that area and very high in the groundwater beneath it.[24]

Why did maps and discussions of the storm sewer source disappear? Interrogations in the class action lawsuit deposition of Jim Lenz, an engineer who worked at Kipp during this time, suggest that Kipp’s law firm Michael Best and Friedrich may have instructed the consultants to stop testing along the storm sewer route at some point.[25] Our speculation is that they did not want attention brought to the fact that contamination had likely spread offsite to the north and northeast—including onto and beneath homes, the city bike path property, and the Goodman Center site.

Zoom forward to 2014: Kipp northern hotspot still there (shhhh)…

Whatever caused the shift in focus away from the northern hotspot area and storm sewer over a decade ago, it worked. Government agency staff either never knew about it (because they didn’t bother to read older reports?), or they forgot about it, and/or they were pressured by Kipp and its law firm not to investigate or discuss it. Other than a couple of the larger Arcadis site investigation reports that review the consultant reports from the 1990s, thousands of pages of Arcadis consultant documents avoid explicitly discussing this critical hotspot area and preferential pathway. None of the numerous maps in Arcadis reports diagram the location of the storm sewer and the other storm drain pipes in the northern parking lot that connect to it. Even the reports outlining contamination and remediation of the raingarden, which received wastes from this storm sewer for decades, do not diagram or discuss it. In fact, the 2013 Site Investigation report, absurdly, says “The rain garden captures precipitation runoff from an adjoining bike path”—with no mention of the storm sewer, PCBs coming off Kipp’s parking lot, etc.[26]

As the earlier consultant reports did, Arcadis Site Investigation reports in 2012 and 2013 review the reports in the 1990s that discuss the storm sewer route, but then disingenuously give the impression that the BiOx remediation adequately reduced contaminant levels along the storm sewer route—e.g., the May 2012 report notes: “Enhanced biodegradation was implemented at the two former vapor degreaser vent areas and the former drainage ditch to address impacted soil. Post-remediation sampling indicated that the remedy was successful at decreasing VOC concentrations.” The 2013 report is even more misleading (and in fact, outright incorrect), noting that after remediation, “The data showed that concentrations of PCE were reduced to below the Site-specific residual contaminant level (RCL) of 1 mg/kg established for the remedy.” In fact, several borings throughout the northern area had contaminant levels hundreds of times above 1 mg/kg (1000 ug/kg) after remediation and thousands of times above the DNR’s soil to groundwater RCLs.

Given the above, it is not surprising that significant levels of contaminants remain in soils along the storm sewer route. Moreover, the groundwater in the northern part of the site, in the area where the ditch drainage pipe and older maps suggest that the storm sewer pipes come together, is where the most contaminated wells on the Kipp site are to this day—see the recent plume maps released by Arcadis. Groundwater well MW-13 has significantly higher levels of PCE than any of the other wells (see pg. 16 of above document). Most troubling, groundwater and soil data from the northern area suggest that the BiOx used in the remediation in the late 1990s, rather than breaking the PCE into “non-toxic byproducts” (as consultants claimed it would in their reports), broke PCE down into its far more toxic degradation byproducts trichloroethylene and vinyl chloride. The two northernmost shallow wells near the storm sewer route—MW-1 and MW-13—continue to have very high levels of PCE and its more toxic breakdown products TCE and vinyl chloride.

These results are highly relevant to considering risks to people at the Goodman Center property, much less than 100 feet away from Kipp. Yet, city/county and state public health agencies, and the DNR, have apparently given the stamp of approval to Goodman Center to build a splash pad only about 20-30 feet away from Kipp’s northern hotspot, without even requiring the testing they are required to do according to their “Cap Maintenance Plan.”

Why are they burying their heads in the sand (errr….toxic sludge)?

Questions, comments, corrections, additions? We welcome them–please send to info@mejo.us. THANKS!!

 

[1] Also see here

[2] In previous stories, we have raised questions about risks to children at the Goodman Community Center just north of Kipp and whether Goodman Center leaders followed DNR laws—see here and here and here. Government officials have repeatedly assured us and Goodman owners that these kids are not exposed to Kipp’s pollution, and therefore are not at risk.

[3] This data wasn’t released until April 2014, a full year after the samples were gathered

[4] In the last revisions of the DNR’s NR 700 regulations (which include vapor intrusion regulations and risk assessments), the state decided to adopt standard/screening levels for VOCs 10 times higher, or 10 times less protective of health, than the previous levels.

[5] Bike path probes are 7-8 feet deep and in the wet spring of 2013, groundwater was 8-10 feet down. Spring 2013 vapor probe data was only available for VP6, just inches above the groundwater, but the others (VP3-VP5) were under water.

[6] This raises further questions about who is actually legally responsible for this situation at this point, and any effects it might have on Goodman property.

[7] However, industrial screening levels for vapor intrusion are completely unprotective of workers based on scientific literature. These levels are highly influenced by industry and corporate lobbying and standards allow workers to be exposed to very high levels of contaminant vapors that are likely to cause health problems over the long term.

[8] Nehls-Lowe is the vapor intrusion expert at the DHS who is the lead person making decisions about vapor intrusion and public health risks at Madison-Kipp and other contaminated sites all over the state. In several conversations with him since 2011 about how DHS is assessing vapor intrusion risks at the site, he explained this step by step approach to assessing the potential for vapor intrusion off the Kipp property, moving slowly outward from Kipp. Mr. Nehls-Lowe does not think contaminated groundwater is a source of vapor intrusion in buildings anywhere off the Kipp site because clay soils act as barriers. He does not think that the EPA conceptual site model document (link below) is relevant to the Kipp situation. He does not believe, based on the existing data, that Kipp’s contamination has caused contaminant vapor intrusion into nearby homes—but that any vapors found in these homes are likely from household products.

[9] Also, see here and here

[10] Like EPA guidances, DNR vapor intrusion guidances say that testing the subslab of buildings is much more relevant to understanding risks to people in buildings than testing outdoor soil vapors.

[11] See EPA’s 2012 Conceptual Site Model Scenarios for the Vapor Intrusion Pathway.

[12] In recent years, the Goodman Center has done a couple spot soil tests for raised bed gardens along the bike path where soils were removed and replaced before remediation.

[13] Even if Kipp groundwater/soil contamination didn’t exist, children and other people at the Goodman site are exposed to the factory’s significant toxic air pollution (dioxins, chlorine, hydrochloric acid, PAHs, metals, particulates, oil mists from die casting, etc), much of which is uncontrolled and unmonitored. Also, industries formerly at the Goodman site are known to have used chlorinated compounds, including PCE and others. The site was remediated, but consultant documents in the DNR database show it has significant levels of contaminants, including lead, arsenic, and PAHs, remaining in soils below the two feet of new soil added after the contaminated soils were removed. Excavation for the splash pad will remove soils many feet below the 2 feet of “clean” soils placed on top of the contaminated soil. Yet as of May 2014, the DNR had no intention of asking Goodman to test the soils before, during, or after the splash pad construction, even though it is required by DNR’s regulations. Apparently nobody, even the DNR, minds that they didn’t follow these regulations last time they excavated, so this time around the laws don’t seem to matter either.

[14] When the vapor probes along the bike path were first proposed in early 2012, Michael Best attorney David Crass wrote the following in a March 14, 2012 email to Steve Tinker, Mark Giesfeldt, Patrick Stevens, Matt Moroney, Michael Schmoller, Henry Nehls-Lowe, Thomas Dawson, and Linda Hanefeld: “Installation of soil vapor probes is not recommended on the public bicycle path north of the Site for several reasons. First, the public bicycle path is located over former railroad tracks and a railroad right-of-way. It is highly likely that chemicals associated with these uses will be present and negatively interfere with the sampling results. Second, historic PCE use has been documented at the Goodman Center property, which will lead to questions regarding origins of any results and will infect any future decisionmaking regarding the results. Third, soil vapor sampling is only useful for evaluating (or estimating vapor intrusion) if the data are collected near a building. As Terry Evanson has said time and again, soil vapor data is of little consequence in the environment unless it is nearby buildings which can then be of concern. The collection of soil vapor samples in an open area will not provide any additional information on the potential migration of CVOCs into nearby buildings.”

[15] We located it in an open records request.

[16] Kipp consultant documents in the 1990s say this area wasn’t paved till 1995, though other documents say the parking lot was paved as early as the 1970s.

[17] Not surprisingly, many documents written by Kipp or their consultants throughout the years and recently have implied that this contamination was from past Kupfer operations (Kipp is trying to blame someone else).[18] So Kipp decided to pave this over after discovering really high levels of contaminants there? Also, other documents say the parking lot was paved much earlier, in the 70s. And, when was “several years ago”?

[19] Chemicals like toluene are known to degrade materials used in sewer drain pipes—causing contaminants to leach through pipes into the soils (and then groundwater) beneath the pipes.

[20] It is not clear what happened during this time, but presumably Kipp began to extract groundwater, which is why an extraction well (EW-1) appeared on their maps in 1997.

[21] EW-1 is on a map in the 1997 report, but no others after that, other than one mention in the 2005 report. The purpose and depth of this well remain unclear. Was Kipp extracting groundwater from this well from 1997 to 2005 or longer?

[22] DNR only recently started asking Kipp to assess preferential pathways—but so far we see no evidence that Kipp consultants are doing so even now (or if they are, the data is not being shared publicly).

[23] This is quite ironic given that currently (2014) soil vapor extraction is being used to remediate contaminated soils at Kipp, and consultants are implying that it is effective (though there are no data yet to verify this claim).

[24] Interestingly, there was one mention of the northern hotspot in the March 25, 2005 consultant report. Well EW-1 (the extraction well, off the northernmost tip of the plant in the remediated hotspot), was mentioned as having “elevated concentrations of CVOCs” (chlorinated volatile organic compounds). Ironically, it says “unlike other locations where the constituents are typically PCE an TCE, samples from EW-1 yielded elevated concentrations of other daughter products, including cis-1, 2, DCE and vinyl chloride, suggesting that natural degradation is occurring.”

[25] See page 220 of Jim Lenz deposition (pg. 55 of the PDF).

[26] Here’s the full quote from the Feb.12-Jan.13 Site Investigation: “There is a feature identified as a “rain garden” located adjacent to the northeast property line (Figure 2-3). The rain garden is a demonstration project completed by the city of Madison to illustrate how runoff of precipitation in an urban setting can be reduced through the use of vegetated areas. The rain garden captures precipitation runoff from an adjoining bike path. While not a habitat for sensitive species, this area was identified as part of the investigation scoping because rain gardens are designed to retain storm water and facilitate infiltration to groundwater. Care was taken during the investigation to reduce the potential for runoff contacting investigative activities.”

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More Unanswered Kipp Questions: Was KLS Lubriquip at the Goodman site in the Past?

More Unanswered Kipp Questions: Was KLS Lubriquip at the Goodman site in the Past?

Madison-Kipp Corporation originated as Kipp Lubricator Company in 1898. Kipp’s lubricator operations were later called Kipp Lubricator Systems (KLS), KLS International, or KLS Lubriquip at different times. The lubricator division at the Madison facility, also at times known as the “Products Division,” was separate from the Die Cast Division, called Kippcast. In 1989, Kipp sold KLS to Illinois-based IDEX Corporation, but operations stayed in Madison for some time afterwards. Former Kipp employees recall that the company kept the same name and employees. [1]

Where did KLS Lubriquip operate before and after Kipp sold the division to IDEX? According to the 2012 class action lawsuit deposition (see pg. 33-36, pg. 9 of the PDF) of Kipp’s former employee Jim Lenz, who worked at the factory from 1980 to 2011, Kipp’s Lubricator Division operated out of 201 Waubesa Street plant, while the Die Cast Division operated out of the Atwood building. He said the Lubricator Division was called Lubriquip around 1983-84, but also that Kipp changed the names of both the die casting and lubricator divisions “several times.” Mr. Lenz claims that “the two divisions didn’t talk to each other,” but in 1983 or 1984 the Die Cast Division gave the Lubricator Division (Lubriquip) the PCE vapor degreaser, which they used till they “moved out of the building.” He said he did not know how long Lubriquip used the vapor degreaser after that, and it’s not clear when the division left the building.[2]

Where did KLS Lubriquip go after this? Did the company take the PCE vapor degreaser with them? Presumably so. Though KLS Lubriquip eventually operated from a facility at 2041 Stoughton Road [3], there is some evidence that they may have operated and/or stored materials closer to the Waubesa Kipp facility for some time at the former Kupfer Ironworks property at 149 Waubesa Street, currently the Goodman Community Center.[4] 

Evidence that KLS Lubriquip may have been at the Goodman Community Center Site:

The 2002 Kipp Phase 1 Environmental Site Assessment by Robert Nauta of URS consulting lists KLS Lubrication Systems in the RCRA Generators List (pg. 5-3) at 149 Waubesa Street, the site of the current Goodman Community Center. Later in the document, the “Map Findings” database section (pg. 21-22), KLS Lubrication Systems, owned by Lubriquip, Inc., is listed at 149 Waubesa Street. The “record date” associated with Lubriquip is 1980 and the “contact” is William Clapp. Under “other pertinent activity identified at site” (RCRA Information System), with “activity name,” Durline Scales is listed. The “impact” listed is “soil contamination,” with a notification date of June 16, 1987 and closing date of June 29, 1987. The “responsible party” is not reported, nor are any other details about the spill.[5] DNR’s Mike Schmoller is the contact listed, since he was the project manager for the site at the time.

In Kipp’s 2006 Phase 1 Environmental Site Assessment, written by the same consultant under a different company name (RSV Engineering), 149 Waubesa Street is not listed in tables included in the front section of the report. However, in the “Map Findings” database section of the report, on pg. 33, the owner listed with 149 Waubesa Street is Lubriquip Inc., classified as a “small quantity generator,” and again with the contact name William Clapp. KLS International is no longer listed. Under “other pertinent environmental activity identified at site,” the Atwood Community Center is listed under “activity name” (since they owned the building by that time) and the soil contamination incident in 1987 is also listed. Details about the spill are all “not reported” and no “responsible party” is listed. Mike Schmoller was also the DNR contact at that time.

Strangely, the 2010 Kipp Phase 1 Environmental Site Assessment [6] again written by Robert Nauta, now with his own consulting firm (RJN) lacks any mention of KLS International or Lubriquip, though 149 Waubesa Street and/or Kupfer Ironworks are listed in some tables. This report is notably scant and lacking critical and well-documented information about the Kipp property that is highly relevant to the site investigations and risk assessments.[7]

Did KLS Lubriquip—owned by Kipp or another entity—operate or store something at 149 Waubesa Street? Or were these connections between KLS Lubriquip and 149 Waubesa Street database errors or typos? If KLS Lubriquip was at the site–for how long, and what did the company do there?

We emailed Mike Schmoller and his supervisor Linda Hanefeld at the DNR with these questions. Here is the response we received from Ms Hanefeld:

Without doing a complete file review and looking for this information (our records are available for your review), we do not recall having any documentation regarding KLS International and/or Lubriquip operating at the Goodman Center so we are not in a position to answer your question.”

Hmmm. Mr. Schmoller’s name is listed as the contact for both the 2002 and 2006 ESA document listings for KLS Lubriquip because he was the DNR site manager for the 149 Waubesa Street site when it was Kupfer and Durline. He is still the site manager for the Goodman Community Center site. Notes in his handwriting, on the first page of DNR’s 1984-2006 Kipp waste manifest records, printed in 2012 (so the notes were likely written that year), mention KLS and suggest that KLS used PCE from 1984 to 1987 (presumably while still at 201 Waubesa, but that’s not clear).[8]

So does Mr. Schmoller really not recall anything about whether or not KLS Lubriquip was at the Goodman site after they moved out of the Waubesa Street building, and if they were there, what they did and for how long? Or, is he unwilling—or not being allowed by his superiors at the DNR—to share his knowledge of this with us?

Since the DNR won’t answer our questions, we are back to a familiar place—asking you, citizens out there, for your insights:

Does anyone who was around the east side in the 1980s and 1990s recall anything about KLS or Lubriquip being at 149 Waubesa Street, at the Kupfer or Durline buildings or properties?

-What might have prompted Kipp to give its vapor degreaser to KLS Lubriquip in 1983 or 1984 (if we can assume Jim Lenz’ account is accurate), then shortly thereafter move out of the building, and then sell the company?

Please share your insights! Write to info@mejo.us

 

 

 

[1] Because the company changed its name several times, and was owned by different entities, for simplicity we are going to refer to it mostly as “KLS Lubriquip” unless records we reviewed used a particular name.

[2] The assertion that the Lubricator and Die Cast Divisions “didn’t talk to each other” is difficult to believe, given they were in the same facility, doing related work, for the same company.

[3] Where it operated till 2006 when it was bought by Graco.

[4] Long-time Kipp neighborhood residents recall Kipp storing containers of unknown materials (perhaps wastes?) on the 149 property during the 1980s and/or 1990s.

[5] In 1987, Kupfer Ironworks was no longer in business at the site (the company closed in 1985), and Durline didn’t buy the property till 1990.

[6] For some reason, the 2010 Phase 1 ESA is hidden in Appendix B of a 2012 report by Kipp’s current consultants, Arcadis. The actual Appendix is not on this link (see above for link to Appendix).

[7] These significant gaps are troubling, given that Mr. Nauta had worked for Kipp since the 1990s, so he was extremely familiar with the site.

[8] If Kipp stopped using PCE in 1987, why were they still shipping PCE out as wastes through 2006? Was this PCE they had sitting around in storage after they stopped using it? Or….???

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How Far North is the Kipp Plume? Kipp Doesn’t Want The Public to Know…

How Far North is the Kipp Plume? Kipp Doesn’t Want The Public to Know…

At a March 19, 2014 community presentation, Madison-Kipp Corporation’s CEO Tony Koblinski presented Kipp pollution maps and invited citizens to view them after his talk, noting that “when you get a chance to look at the data, you’ll be able to see all the values on each of those.” But when MEJO President began to photograph maps after the presentation, Mr. Koblinski rushed over to intervene, hurriedly turning them over to the white side. “These aren’t quite ready for prime time!” he said, obviously highly agitated. “They’ll be in the public record, in the Annual Report, in two or three weeks.”

It was very awkward behavior for a corporate CEO in a public venue—and especially ironic given he stated in the opening of his talk that Kipp wants to “reestablish Kipp’s reputation and standing” and “communicate openly with our neighbors” in an “honest and open dialogue.” (Mr. Koblinski’s presentation was likely written and carefully vetted by Kipp’s law firm, Michael Best & Friedrich.)

Why would Kipp present maps at a public meeting, invite people to view them, but not allow them to take photographs?

Before Mr. Koblinski turned the maps around, I had already snapped a photo of a north-south groundwater cross-section map dated October 2013, with the reluctant permission of the Arcadis consultants standing there. This map was also presented in Mr. Koblinski’s talk. Again, why was a map based on five-month old data not yet “ready for prime time”—and if it wasn’t ready, why was it presented at all? We don’t know, but have some speculations. Read on…

Respecting Mr. Koblinski’s request, I did not share the photos I took in March, but waited for the release of the Annual Report  by the DNR on April 8, 2014. The report includes no data and no maps, and is devoid of specific information other than a summary of Arcadis activities in 2013. Though a separate electronic report  released on April 8 includes groundwater data, none of the cross-section or other isoconcentration groundwater maps were posted on the DNR website.

I emailed DNR about the maps and was told that they were too big for Arcadis to send via email,[1] but hard copies of the maps were at Hawthorne library. DNR offered to ask Arcadis for a CD with the maps and make it available to me. I asked DNR to instead get the maps electronically from Arcadis and post them on the website so that any interested citizens can more easily access them.[2] DNR sent me a CD but has not posted the maps on their website for others to access (as of May 13).

In the meantime, I went to Hawthorne library and found the maps in bound reports.[3] The October north-south cross-section plume map there has the same title and date as the one I photographed at the March 19 meeting. Though all the numbers on the map are blurry and nearly impossible to make out, those listed for the northernmost well (Well 27 off Milwaukee Street) appear to be the same as on the map I photographed after the March public meeting: 1.6 ug/L and 11 ug/L.

A Tale of Two Maps

Strangely, however, the shapes of the plumes on the two maps are slightly different—especially towards Well 27. The map  presented at the March public meeting (in Part 2 of the presentation here) depicts the northern tip of the plume just barely reaching Well 27. The map  included in the Annual Report at Hawthorne (also shown with captions above) while having the same title and date, and showing the same numbers (blurrily), clearly shows that the plume goes much further than Well 27 (off the map to the north) and is more substantial vertically at that well.

So presumably, the map actually included in the Annual Report, with the more significant vertical plume depicted at Well 27, was the one Kipp felt was “ready for prime time” while the earlier one wasn’t. But in fact, both maps are misleading because neither includes the actual vertical profiling contaminant levels from Well 27 in November 2013—levels that were much higher than the numbers written on the maps. These tests found PCE levels of 40 and 25 ug/L, and TCE levels of 22 and 16 ug/L at 135-145 feet and 150-160 feet (respectively), as well as significant levels of the breakdown product cis-1,2, dichloroethylene (DCE). Arcadis also identified a significant fracture at 140 feet deep in November—which would be a key preferential pathway for the contaminants to travel underground to the north.

Data Not Shared with Public or City of Madison

We know that DNR and Kipp knew about this vertical profiling data in mid-December 2013. Apparently, neither shared this important information with the City of Madison, and Mr. Koblinski didn’t share it with the public at the March 2014 meeting. In fact, he presented groundwater maps that omitted this data and depicted a plume that pretty much tapered off before reaching Well 27 (with just the tip of the plume at that well). Other isoconcentration maps he presented, which he didn’t allow us to photograph, also made it appear as if no contamination over the enforcement standard of 5 ug/L had ever been found at Well 27. Further, he didn’t mention the underground fractures Arcadis had located. Research shows that such fractures can act as “contaminant superhighways,” through which contaminants can travel quickly—and far away—from contaminant sources.

Instead, Mr. Koblinski said “most of the contamination is under the building footprint,” referring to the Kipp building. He noted that the contamination doesn’t go deeper than 170 feet, which is incorrect (see Arcadis tables linked to above). He declared that the Kipp plume “tends to flatten out…it gets weaker and weaker, it’s diluted, it diffuses into the bedrock, and Mother Nature, though wounded, begins to take care of it. It biodegrades, and over time, it cleans up.”

Troublingly, to support these absurd and scientifically incorrect statements, Kipp’s CEO showed the public misleading maps that omitted critical data. Moreover, he didn’t show some important maps at all—such as the map showing how far the plume may have traveled to the east and west of Kipp. More discussion about this below…

Deep Contamination Going North, or South…or Whatever Direction Kipp Wants it To Go?

Mr. Koblinski stated in his talk that “movement of groundwater is generally downward and predominantly to the south”—which contradicts data and maps above showing significant levels of contaminants in deep groundwater 1400 feet north of Kipp (and beyond). Kipp consultant reports have stated since the 1990s that the deep groundwater is moving north. Was Mr. Koblinski purposely trying to mislead the public, or was that a misstatement? Consultant reports also say repeatedly that shallow and intermediate-level groundwater around Kipp is going south/southeast/southwest. Perhaps Mr. Koblinski was confusing deep and shallow groundwater? Either way, this begs the question we have asked again and again over the last few years: If the shallow and mid-level groundwater is going south, why hasn’t there been any groundwater testing directly to the south and southwest of Kipp, and only limited testing to the southeast (Well 25)?

DNR Doesn’t Want to Know How Much Further North the Plume Has Gone Either? What About East & West?

According to the Annual Report, Kipp doesn’t plan to install any more groundwater monitoring wells—not even to the north of Well 27 at Oak St/Milwaukee Street, where the contaminant levels are well above enforcement standards and the tip of the plume has clearly not been defined. DNR doesn’t plan to ask Kipp to install another monitoring well further north of Well 27.

The extent of the Kipp plume to the east and west of the plant, not discussed at all at the March 19 meeting, has also not been defined. Contaminant levels found in October 2013 at Monitoring Wells 14 and 16 (approximately 450 feet west and east of Kipp, respectively) are orders of magnitude above the enforcement standards (the depictions of the east-west extents of the plume in this map are Kipp consultants’ estimations—there is no actual monitoring data to back this up as far as we know). The extent of the plume to the west is of particular concern, since Well 14, to the west of Kipp, has levels of up to 970 ug/L PCE at 135-145 feet and 640 ug/L at 170-178 feet. Levels of TCE and DCE are also substantial at these depths.

So…how far does the plume go to the north? To the south, east, and west? If no more wells will be installed, we’ll never know how wide and deep the plume is—until contaminants show up in one or more of our drinking water wells. Perhaps they already have? As noted above, plumes can travel several miles from the source in preferential pathways such as underground fractures. Several Water Utility wells on north/east sides of Madison within five miles from Kipp (Well 11, Well 15, Well 8, Well 9) already have had some PCE, TCE, and/or DCE contamination for some time. Could any of this contamination have come from Kipp? It’s possible, given that the plume has been traveling deep underground through fractures and other pathways since the late 1940s, and several drinking water wells in a few mile radius around Kipp have been pulling the contaminant plume around in various directions–depending on which wells were used (or not), when, and how much they were pumping (see later story).

Some of our analysis is preliminary, since we don’t have access to all of the information. Regardless, one thing seems pretty clear based on our experiences and the information we have been able to piece together: Kipp doesn’t want people to know how far north the plume has reached, and at what levels.

Lacking maps, to help visualize how wide and deep the plume might be in groundwater under the neighborhood, we put together a very rough map based only on the most recent data from the furthest offsite wells (October 2013 for Wells 14, 15 16, 25, and November-December 2013 for Well 27), summarized below—so people could see the extent of the plume at this point.[4]

 

[1] Arcadis has provided countless maps and diagrams to DNR in electronic form in the past couple years to post online. Why are they unable to do so for these figures?

[2] Many people cannot go to Hawthorne Library and/or cannot afford to copy these maps.

[3] The maps cannot be easily photocopied (they are large and an awkward size in bound reports). Photographs I took are not clear because the maps are creased from folding.

[4] To keep it simple, data from all depths were combined for each contaminant.

 

Summary below of most recent data from:http://mejo.us/wp-content/uploads/2014/05/arcadisTables1213.pdf

 

FAR NORTH (Well 27, off Milwaukee St.)(November 2013 data is vertical profiling data)

11/24—135-145 feet: PCE 40ug/L, TCE 22ug/L, cis-1,2-DCE 13 ug/L

11/25—150-160 feet: PCE 25ug/L, TCE 16ug/L, cis-1,2-DCE8 ug/L

11/25—160-170 feet: PCE 3 ug/L, TCE 1 ug/L, cis-1,2-DCE .47 ug/L

12/26—130-140 feet: PCE 1.8ug/L, TCE 1.3ug/L, cis-1,2-DCE .85 ug/L

12/26—170-180 feet: PCE 11ug/L, TCE 7.2ug/L, cis-1,2-DCE4 ug/L

 

NORTH (Wells 9/15 Wirth Park)***

10/4/13–64-69 feet: 34 ug/L, TCE 7.4, cis-1,2 DCE 18 (Well 9, all the rest from Well 15)

10/8/13—PCE, 88-92 feet: 220 ug/L, TCE, 19 ug/L, cis-1, 3 DCE 20 ug/L

10/8/13—PCE, 100-105 feet: PCE 690ug/L, TCE 72ug/L, cis-1, 2 DCE 76 ug/L

10/8/13—PCE, 120-125 feet: PCE 1800ug/L, TCE 190ug/L, cis-1, 2 DCE 220 ug/L

10/8/13—PCE, 142-146 feet: PCE 840ug/L, TCE 130ug/L, cis-1, 2 DCE 140 ug/L, vinyl chloride .76 ug/L

10/8/13—PCE, 177-187 feet: PCE 100ug/L, TCE 12ug/L, cis-1, 2 DCE 16ug/L, vinyl chloride .34 ug/L

***Well 9 was the original, shallower well. Well 15 was installed later, and is a deeper well. They are right next to each other at the same location.

 

EAST (Well 16, corner of Dixon and Fairview)

10/9/13—PCE, 80-84 feet—.76ug/L, rest below detection limits

10/9/13—PCE, 106-116 feet—94ug/L, TCE 13ug/L, cis-1, 2 DCE 10 ug/L

10/9/13—PCE, 140-144 feet—37ug/L, TCE 6.1ug/L

10/9/13—PCE, 175-179 feet—3.7ug/L, TCE .98ug/L

 

WEST (Well 14, just off Corry St.)

10/8/13—70-75 feet, all below detection limits

10/8/14—100-105 feet, 1.7 ug/L PCE

10/8/13—PCE, 135-145 feet—970ug/L, TCE 53ug/L, cis-1, 2 DCE 27 ug/L, vinyl chloride, .53 ug/L

10/8/13—PCE, 170-178 feet—640ug/L, TCE 37ug/L, cis-1, 2 DCE 22 ug/L

 

SOUTHEAST (Well 25, southeast of Lowell School, sentinel well for Well 8)***

10/9/13—PCE, 120-130 feet—3.1ug/L, MC 5.3ug/L

10/4/13– PCE, 160-170 feet—all under detection limits

***This data is also too limited in time and depths to say yet what is happening at this well. There have only been three sets of tests at two depths on this well. The last set of tests, in October 2013 (shown above) showed the highest levels of PCE and methylene chloride of the three tests. Methylene chloride levels were well over the Preventive Action Limit and slightly over the Enforcement Standard. PCE was not far under the Enforcement Standard. Far more tests at different depths need to be done on this well before drawing conclusion about how far and deep the plume is at the sentinel well.

 

Well 26S, (Goodman Parking Lot)***

8/23/13—PCE, 6.8-16.8 feet: PCE 1.4 ug/L, rest below detection limits

10/9/13—all below detection limits

***These results (from only two dates at only one narrow range of depths) aren’t remotely adequate to assess what is beneath the Goodman property in groundwater, nor does it tell us anything about potential vapor intrusion problems inside the Goodman Center, which is the most important issue to assess as far as risks to people there. To assess risks to people there, vapor tests need to be done in the subslab of the center and in indoor air. Yet Mr Koblinski said during his March 19 2013 presentation that Well 26S results confirm that there are no vapor problems on the Goodman property. To draw this conclusion from this limited data is scientifically inadequate and, moreover, highly unethical from a public health standpoint given that many at-risk children and elderly spend a lot of time at this center.

 

Preventive Action Limit (PAL):

Tetrachloroethylene (PCE)–.5 ug/L

Trichloroethylene (TCE)–.5 ug/L

Cis- 1, 2-dichloroethylene (DCE)—7ug/L

Vinyl chloride (VC)–.02 ug/L

Methylene chloride (MC)–.5 ug/L

 

Enforcement Standard (ES):

Tetrachloroethylene (PCE)–5 ug/L

Trichloroethylene (TCE)–5 ug/L

Cis- 1, 2-dichloroethylene (DCE)—70 ug/L

Vinyl chloride (VC)–.2 ug/L

Methylene chloride (MC)—5 ug/L

 

 

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Kipp’s Former Raingarden–Now SludgeGarden–Even More Toxic Than We Knew…

Kipp’s Former Raingarden–Now SludgeGarden–Even More Toxic Than We Knew…

Yesterday we obtained a Figure from the City of Madison with more PCB data from soils excavated from the Kipp raingarden, on City of Madison property just north of Kipp, next to the public bike path and across from the Goodman Community Center. The PCB levels found around the edges of the former garden, now a toxic pit , are even higher than those reported in our previous post.

We don’t know exactly when these soils were excavated and tested, but the figure we have was dated April 22, 2014, Earth Day. The highest level— 85 ppm PCBs, orders of magnitude above both the residential direct contact RCL of .22 ppm and the industrial RCL of .74 ppm—were found on the north side of the raingarden, near the bike path, next to the raingarden sign.

These highly PCB contaminated soils are still there; in fact, we didn’t know it, but we were standing pretty much on the 85 ppm PCBs when we took many of our photos. The areas with the highest levels will be excavated, but MGE requires a 10-foot buffer for excavation around telephone poles, and other underground utilities also have to be avoided.

All around this excavation pit, children are playing and people are walking/biking. Goodman teen workers are putting food scraps in the compost piles just feet away. Though there is a flimsy short plastic fence around the garden, there are no signs anywhere to let people know that the area is a toxic soil excavation, with high levels of PCBs still remaining.

Questions this raises:

Why are there no signs anywhere around the excavation pit/pond to let people know what is being done and to alert them to the high PCB levels there?

How deep were these PCBs found? Why weren’t other contaminants besides PCBs (PCE, TCE, vinyl chloride, metals, dioxins) also tested in the 2nd round?

How long have the City, Public Health Madison Dane County, the Department of Health Services, the Department of Natural Resources (DNR), Kipp, and other government officials had this excavation PCB data? Did they plan to share it with the public? Why hadn’t they as of May 2 2014? Would anyone even know about the PCB contamination that remains there if we didn’t happen to ride our bikes past the excavation and if we hadn’t started asking questions?

Did the government entities listed above share this data and other details about the excavation with people in the nearby neighborhood, neighborhood association (SASYNA), Goodman Community Center, daycares, etc? Did they engage people in the neighborhood in discussions about how/when the excavation would occur, keep them apprised of the test results, and talk to them about the best ways to communicate with nearby residents and assure that children and pets do not play in and around the excavation area?

If the areas around the telephone poles and other utilities will not be excavated, will the PCBs in those soils remain in place indefinitely? These PCB hotspots are in highly-used public areas. Will there be signs alerting people about the PCB contamination there?

What is the long-term plan for this area? If the raingarden is rebuilt (as is planned, after more excavation) and continues to gather and concentrate PCBs and other contaminants—will the raingarden have to be excavated every few years to remove the high levels of contaminants? Is this really the best plan? What does the neighborhood want?

Is it really a good idea for Goodman to build a children’s SPLASH PAD just across the bikepath from this garden, very near where Kipp stored barrels of waste in the past on what is now Goodman property?  

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World’s Workers Rise Up in Celebration and Protest on May Day–from Common Dreams.org

World’s Workers Rise Up in Celebration and Protest on May Day–from Common Dreams.org

(May Day Rally in Bangladesh. AP Photo. A.M. Ahad)

Demanding dignity and end of economic status quo that undermines labor rights and fair treatment, world’s labor force celebrates and activates. Read the full Common Dreams article here.

Meanwhile, who is standing up for the health, safety, and dignity of Madison Kipp non-unionized workers?

Workers at Madison-Kipp Corporation

(Kipp workers, photo from madison.com)

In previous posts (see here and here) we posed many questions about what is being done to protect these workers from toxic exposures. These non-unionized workers are, understandably, not likely to “rise up” without union protection to demand a safer workplace, for fear of being fired–as happened to other workers who asked questions about risks in the factory. To date, we have received no answers to our questions from Madison Kipp or any of the government agencies responsible for protecting workers and public health.

Kipp’s HR manager and CEO said independent industrial hygienists hired by their insurance companies have monitored inside the factory and everything is A-OK. If that’s the case, why won’t they share the monitoring data? We’re still waiting….

 

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Madison Kipp: Making a Beautiful Difference?

Madison Kipp: Making a Beautiful Difference?

See the beautiful difference: Kipp Raingarden to Kipp Sludgegarden.

Previous story about the Kipp raingarden here. A raingarden was built by middle school children in 2006 next to Madison-Kipp Corporation. High levels of PCBs, PCE and other contaminants were found there in August 2012, AFTER it was excavated the first time to create the garden! Another excavation occurred in early 2014 to remove the PCBs found in the first excavation.

These pictures were taken on Earth Day 2014 after the 2nd excavation. NOTE: The open pit–full of toxins–is right next to the Goodman Community Center, directly across from the compost pile area.

Kipp raingarden photo gallery is here.

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Is Kipp A Safe Place to Work? Cleaning Employee Fired by Contractor for Asking

Is Kipp A Safe Place to Work? Cleaning Employee Fired by Contractor for Asking

(Madison-Kipp Worker Pouring Molten Aluminum)

–Madison Kipp Corporation’s non-unionized manufacturing workers, and contractors brought in to clean and do other work at the factory, are at ground zero for exposures to myriad toxic chemicals emitted in aluminum die casting processes, vapors from the giant plume of toxic volatile organic compounds (VOCs) beneath the plant, and polychlorinated biphenyls (PCBs) contaminated soils being excavated all over the site. See previous posts for more background.

Yet Kipp’s CEO Tony Koblinski assured people in a community presentation on March 19 2014 that Kipp has “good people and good jobs” and is “a company in control.” [1] Further, he asserted “people like working at Kipp, they always have.”

Kipp workers we have talked to over the years do indeed seem like good people, but the stories they told us about working there are not about “good jobs” in a factory that is “in control.” Those we have talked to—usually after they quit—not only did not like working at Kipp, but they did not feel safe or healthy there.

Our review of records, in fact, shows that Kipp’s manufacturing workers and contractors have very legitimate reasons to be concerned about their health and safety. Madison Fire Department (MFD) and Occupational Safety and Health Administration (OSHA) records on Kipp from 1990 to the present indicate that the place is anything but safe for workers. From 1998 through Feb. 2014, Madison Fire Department/Emergency Medical Services (EMS) paid approximately 172 visits to the Kipp facilities on Waubesa and Atwood Ave.[2] [3] Disturbingly, well over half of these calls—we counted 113—were “emergency medical service” (EMS) calls for worker injuries and/or health problems. Some reasons for EMS calls:  chest pains, difficulty breathing, dizziness, possible heart attacks or seizures, passing out from heat, low blood pressure/fainting, lacerations/loss of blood, finger amputations, fingers caught in machines, molten metal burns, burns from propane explosion, worker hit or pinned by forklift, hit over the head, falls, sprains, and more. The first two—chest pains and breathing problems—were listed many times. Either Kipp workers are not very healthy people to begin with, or something in the facility is causing these frequent health problems—or both.[4]

Since 1990, the facility has had numerous molten metal spills, explosions, and fires—most caused by ignition of highly combustible metal dusts and filings. In addition to being obvious immediate threats to worker safety, smoke and fumes from fires and materials used to extinguish fires are often toxic and associated with respiratory problems, cancer and other long-term health problems.[5]  Kipp’s MFD and OSHA records also raise serious questions about how prepared residents near the factory, and staff at Goodman Community Center and Lowell School, are for a chlorine or other chemical accident at Kipp (or an accident involving a truck transporting chemicals to/from there on roads in the neighborhood). For more info, see here.

Cleaning worker is fired for asking if Kipp is safe, requesting not to work there

In February 2014, a worker with existing respiratory problems, who had cleaned for the company Environment Control for five years, contacted MEJO about having headaches and respiratory problems when cleaning at Kipp (which he had recently been assigned to). Several employees of this company who had cleaned at Kipp before him had already quit because they did not want to work in the foundry. He asked his managers that he be transferred to another cleaning job, but they said he would have to prove that the factory was not safe before they would take him off the Kipp job (how could a worker possibly do this?). They told him if he had a health evaluation by a doctor, validating his respiratory problems and connecting them to exposures at Kipp, they might transfer him. Not having health insurance, he could not afford to see a doctor.

He began to search for information about the kinds of toxic contaminants he might be exposed to at Kipp, and sent documents he found (including some written by top scientific experts on the kinds of contaminants found at Kipp) to his managers. Unwilling to read or believe the information he provided, they continued to refute his concerns and demand that he continue cleaning at Kipp (several hours a night, five nights a week).

Frustrated, he eventually contacted MEJO with questions. He suspected that what he was breathing in Kipp was aggravating his lungs and causing headaches. Also, he recalled that for 2-3 weeks in Jan/Feb., while PCB contaminated concrete and soils (again, see this story) were being excavated to install new machines, piles of dirt were sitting all over on the factory floor.[6] Was anything done to reduce/eliminate PCB dust levels in factory air, to protect all workers in the plant? Were workers informed of the contamination? Did they have protective gear?[7]  According to the worker, no, no, and no.[8]

He said practices in the factory seemed very sloppy.  One day while cleaning he noticed a sign in the factory that said “number of days since last accident.” The number there that day was “10.” Factory workers told him 10 days without an accident “is pretty good for Kipp.” This is a factory that is “in control”? Hmmm….

When queried, Kipp assured managers at Environment Control that the factory was perfectly safe. Kipp presented the company with a document (apparently written by Kipp’s insurance company) stating that Kipp is safe.[9]  Rather than showing concern for their employee’s health, and considering the legitimate evidence he brought forward, Environment Control managers chose to believe whatever evidence Kipp and their insurance company gave them.[10]

Sadly, in late March, after continuing to request that he not work at Kipp, the cleaning worker was fired. Apparently Environmental Control considers its employees expendable.

Kipp workers, neighbors, and others have complained of health problems for decades

Many former Kipp workers have shared stories of disturbing health and safety problems in the factory over the years. In 1996, a person who worked at Kipp through 1989 (but believed that the conditions there remained unsafe or got worse after that) wrote a summary of some of the unhealthy conditions in the factory and environmental problems. Another former worker said that there were cases in which workers collapsed from fumes.

Kipp workers aren’t the only ones who have experienced health problems at Kipp. In July 1994, a DNR employee, investigating an odor complaint submitted by a neighbor, smelled a “metallic, solvent-like odor.” Her official statement about this incident says that within five minutes of leaving the plant after the investigation: “I experienced a dizzy, woozy feeling. My face and fingers felt numb and tingly, my heart was pounding, and I found my breathing rapid and shallow. My proprioreception was disrupted and I did not believe I could safely drive.”

In the last few years, there have been similar odd cases of people suddenly suffering health effects near Kipp.  In 2009, the Fire Department responded to situation in which a 10-year old child walking back from a school field trip felt faint and laid down on the grass on Atwood Avenue in front of the Kipp factory (it is unclear whether this incident was connected to any Kipp emissions—but it raises questions). In 2012, a bicyclist was riding on the bike path behind the Atwood plant, smelled a noxious odor that he connected with Kipp, and became nauseous.

Hundreds of reports have been submitted to local agencies over the last two decades by residents in the neighborhood about noxious smells from Kipp—especially the smell of chlorine and/or a “waxy/oily/burnt” smell. According to a 2001 report, “Evaluation of Community Exposure to Emissions from Madison Kipp Corporation,” people “identified both of these odors as the cause of acute illness including asthma attacks, sore throat, nausea vomiting etc.” and goes on to say “it is reasonable to assume that reports of chlorine odors originate from the aluminum melting and drossing process” and “emission of chlorine from this process is the most likely source of these odor complaints.” It also notes that “waxy/oily/burnt” smell in the neighborhood is from the die casting process but that “the chemical composition of this odor is unknown.”

Odor complaints have continued in recent years.[11] In early 2013, a resident on S. Marquette St., next to Kipp, emailed public health agency staff saying that 5 or 6 times in the last several years, he and his wife had “noticed the strong smell of burning rubber or plastic emitting from the basement stairs in our home,” particularly after heavy rainstorms or large snow melt-off events.” He noted that the smell “is not dissimilar to one of the odors that we occasionally smell outdoors and that the neighborhood generally associates with MKC.” He recalled a day in late 2012 in which “several in our neighborhood reported smelling a chlorine smell coming from the MKC property,” and he personally detected a “fairly strong burning rubber smell outdoors.”

Despite all of these worker and neighborhood complaints over the years, public health agencies have insisted many times that there are no harmful exposures in the neighborhood around Kipp—even while admitting many times in the 2001 report that there is not enough data to make this determination. As we described in previous articles (see here and here), a group of citizens from the community worked with government health agencies for nearly two years to develop a health study in the Kipp area, but the study was eventually dropped, for reasons that are unclear. Many suspect that Kipp played a role in shutting the study down.

Meanwhile, none of the DNR or public health agency reports, documents, or communications to date (we have reviewed thousands of pages of them) have even mentioned, let alone expressed concern about, potential exposures to workers inside the plant. Apparently manufacturing workers, most of whom are citizens of Madison and Dane County, are not included in their definition of “public health.”

Many respiratory irritants and toxins emitted in aluminum die casting facilities…

The fired cleaning worker’s aggravated respiratory symptoms and headaches in the factory parallel Madison Fire Department visits to the factory to attend to workers with chest pains, breathing problems, dizziness, and related symptoms. Moreover, Kipp’s terrible worker health, safety and OSHA records indicate that Kipp is doing far from an adequate job inside the factory protecting their workers from exposures to harmful chemicals, regardless of whether or not they meet standards (which is unknown, due to lack of adequate data). Many existing workplace health standards, heavily influenced by industry lobbying, are known to be far too lax and not adequate to protect workers’ health.

What are Kipp’s workers exposed to?  Releases from Kipp’s stacks aren’t all the same as what’s in factory air, but can tell us something about what chemicals the facility uses and emits into factory air.

As of 2004, EPA’s Toxics Release Inventory (TRI) listed the following as top air releases in aluminum die casting industries all over the U.S: aluminum (fume or dust), trichloroethylene, tetrachloroethylene, zinc (fume or dust), zinc compounds, copper, hexachloroethane, glycol ethers.[12] Unfortunately, it is increasingly difficult to find out what comes out of Madison-Kipp stacks in particular—in part due to industry’s political lobbying to keep this information out of the public realm, inadequate monitoring and lax regulatory approaches [13] .  Madison-Kipp’s 2012 DNR Air Emissions Inventory Report lists the following emissions: carbon monoxide, nitrogen oxides, particulate matter, hydrogen chloride, and “reactive organic gas” or ROG (otherwise known as volatile organic chemicals or VOCs). Many of Kipp’s most toxic emissions, however, are not reported on Kipp’s air inventories—or were in the past but are no longer .[14] [15] [16]  For instance, Kipp also emits dioxins and furans (among the most toxic compounds ever studied), aluminum salts, fluorides, fluorinated compounds, chlorine, chlorinated and chlorofluorinated compounds, numerous metals, polycyclic aromatic hydrocarbons (PAHs), and several other toxic compounds that are not listed on the inventories.

Just as problematically, the chemical composition of emissions from Kipp’s die casting processes—which include reactive organic gases (ROGs), polycyclic aromatic hydrocarbons (PAHs), small particulates, metals, and a mix of other contaminants found in oil mists associated with metalworking fluids used as die lubricants (discussed in more detail later)—have never been assessed.[17] The “emissions factors” used to assess the levels of ROGs and particulates emitted from the die casters are old and inadequate (based on tests done in the mid-90s), and Kipp has added many more die cast machines since the time they were developed. So the estimated levels of ROGs and particulates on inventories are likely too low. (Several years ago, Kipp raised its stacks higher in order to disperse these compounds, associated with the “waxy/oily/burnt” smell nearby residents have complained about for years, further out into the community. Given this, it defies common sense (and science) to assert–as Mr. Koblinski did on March 19–that none of the PAHs and other contaminants found in nearby residential soils are from the facility. The elaborate (but problematic) statistical analyses by Kipp’s consultants, and comparisons to background samples obtained by government agencies (which certainly included some of Kipp’s PAHs, dispersed widely around the community via taller stacks) do not prove that none of the PAHs and other contaminants found in soils offsite came from Kipp).

As a result of inadequate reporting and data gaps, it is difficult for citizens or workers to track what Kipp is really emitting outside or inside the plant. Efforts by the Madison Department of Public Health (now called Public Health Madison Dane County, PHMDC) to assess exposures in the Kipp neighborhood were aborted because of limited or no air monitoring. Ultimately the agency concluded in its 2001 report that there were too many data gaps to draw any conclusions, and recommended more air monitoring. Unfortunately, 13 years after this report was written, no further air monitoring around Kipp has been done.

What are workers breathing inside Kipp?

Many of the compounds emitted from Kipp’s stacks are likely found to some degree inside the factory, where workers are exposed to a number of them at the same time. Unfortunately, even less information is publicly available about chemical exposures inside Kipp than is available about outdoor emissions.[18] Regardless, several of the compounds listed above and known to be emitted from, and found inside, aluminum die casting facilities, can aggravate respiratory problems and a range of other health effects. Kipp workers have also been breathing unknown levels of toxic vapors from beneath the plant, which include tetrachloroethylene (PCE), trichloroethylene (TCE), vinyl chloride (VC), and other VOCs known to aggravate respiratory problems and headaches. Most of these chemicals are also associated in scientific studies with a number of serious long-term health problems, including cancer.

Next we discuss some of the above compounds that are most likely aggravating respiratory and other acute problems among workers. We discuss the sparse data available from monitoring inside of Kipp, what it can (or cannot) tell us about exposures to Kipp workers, and government agency actions (or lack thereof) related to Kipp workers’ health and safety.

If you have read this far, and are interested in learning more about what we have learned, please email us at info@mejo.us.



[1] The talk was most likely written by Kipp’s law firm, Michael Best & Friederich

[2] These numbers are approximate (possibly underestimated) due to gaps in records; they also don’t include Fire/EMS calls to the Sun Prairie facility.

[3] While some of these recorded calls were false alarms, we have heard that many times there are close calls (near-miss accidents and fires, etc) for which nobody ever calls the Fire Department, in part because management wants to keep the official fire call record as low as possible. Consequently, the official number of calls in records is likely an underestimate of the actual number of accidents, fires, and worker illnesses.

[4] Kipp’s lowest-end manufacturing workers, contractor cleaning employees, and temporary workers include ex-offenders, homeless people, and a significant proportion of minorities. Sadly, statistics show that these groups are likely to be much less healthy than more privileged people—making them even more vulnerable to health problems from exposures to contaminants in Kipp. Many also lack health insurance. This is a significant environmental justice issue that has been completely ignored by Kipp and the government agencies responsible for protecting public health in Madison/Dane Co. and Wisconsin.

[5] A fire on August 1, 1992 sent four firefighters to the hospital after they inhaled noxious fumes. The Aug. 2 1992 Madison newspaper article on this fire, titled “Molten Flames,” says that the building filled with smoke and noxious fumes.

[6]  He only found out about it after coming across it on the MEJO website.

[7] Some of the precautions EPA recommends when excavating contaminated soil: “Handling contaminated soil requires precautions to ensure safety. Site workers are trained to follow safety procedures while excavating soil to avoid contact with contaminants…Site workers typically wear protective clothing such as rubber gloves, boots, hard hats, and coveralls. These items are either washed or disposed of before leaving the site to keep workers from carrying contaminated soil offsite on their shoes and clothing…Workers monitor the air to make sure dust and contaminant vapors are not present at levels that may pose a breathing risk, and monitors may be placed around the site to ensure that dust or vapors are not leaving it. Site workers close to the excavation may need to wear “respirators,” which are face masks equipped with filters that remove dust and contaminants from the air…

[8] Now the new machinery is installed, the dirt was hauled away, and the floors cleaned up. The area was re-painted and is clean and shiny.

[9] From what we understand (not having seen this document), the last inspection in Kipp for insurance purposes was 3 years ago.

[10] Mr. Koblinski said in his March 19 presentation that the company’s current priorities include “managing health risks to employees” and “communicating openly with the neighborhood.” If this is the case, the company should openly share the health and safety assessments done inside the factory by insurance companies and other third parties. If they are unwilling to share these assessments, what are they hiding?  On the other hand, if the assessments are comprehensive and state of the art, and show that the factory is safe, that would be reassuring to workers and the neighborhood. So why won’t Kipp share them?

[11] In the weeks just before this article was written, residents near Kipp have reported increased odors from the plant, including a particularly acrid smell that seems new to them.

[12] Dalquist and Gutkowski, 2004

[13] Again, see previous articles

[14] In Wisconsin, industry (likely including MKC) lobbied to not report certain emissions on public inventories at all unless they were modeled at over NR 438 levels. See previous article describing some of these issues, particularly as they relate to dioxins and chlorinated compounds, among Kipp’s most toxic emissions.

[15] Given that Kipp purportedly no longer uses tetrachoroethylene (PCE) (and it is not clear whether they still use trichloroethylene, TCE), it is unknown whether Kipp has or still does emit these compounds from its stacks; PCE, TCE, and their breakdown product, vinyl chloride, have never been tested for in Kipp’ air stack emissions. They are being emitted (and monitored) from soil vapor extraction (SVE) systems on the site. It’s unknown what compounds Kipp used to replace PCE—and what kinds of emissions might be associated with these replacement chemicals

[16] MEJO has asked government agencies several times what Kipp replaced PCE/TCE and PCBs with, but have never received answers.

[17] Levels of ROGs listed on Kipp’s inventories have increased significantly in recent years, from 17.4 tons in 2008  to just over 26  tons in 2012 (2013 and 2014 levels are not available yet). Of course, these levels do not include VOCs being emitted from vapor extraction systems all over the site.

[18] Air monitoring in aluminum die casting facilities has been relatively scant—in part due to die-cast industry’s competitiveness, success in withholding proprietary information about the chemicals they use, and resistance to any monitoring in their plants.

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So Sorry, DNR! Here’s the full transcript of the Jan. 29 2014 MEJO-DNR meeting

So Sorry, DNR! Here’s the full transcript of the Jan. 29 2014 MEJO-DNR meeting

(MEJO President, Dr. Maria Powell)

In a meeting on March 21st, two DNR managers and two DNR lawyers scolded MEJO President, Dr. Maria Powell, for audiotaping the January 29 meeting with four DNR staff and posting only a partial transcript of the meeting. DNR legal counsel, Lacey Cochart, asked that we post the entire meeting transcript.

Honoring this request, MEJO staff (who are not professional transcribers) spent nearly 14 hours transcribing the tape of the entire meeting, which is here. The one hour, 20 minute long meeting included DNR’s explanation for their threat of $700 fees to MEJO to ask further questions, as well as their responses to MEJO’s questions about their open records policy, decisions about posting public comments, environmental justice policy, assessment of Kipp worker exposures, assessment of contaminants in air emissions, and more. Enjoy!

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