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Posts Tagged "PCE"

EPA proposes the first chemical ban in 27 years–TCE

EPA proposes the first chemical ban in 27 years–TCE

From Environmental Defense Fund, by Jennifer McPartland, Ph.D., a Senior Scientist with the Health Program.

Today, EPA issued a proposed rule to ban uses of trichloroethylene (TCE) as a spot cleaning agent in dry cleaning and as an aerosol spray degreaser in commercial and consumer settings. This marks the first time in 27 years EPA is proposing to restrict the use of a chemical and represents a significant milestone under the Lautenberg Act.

The proposed ban is long overdue for a chemical that is highly toxic and produced in very high volumes (255 million pounds annually). TCE is classified as a known human carcinogen by numerous authoritative bodies, including the National Toxicology Program (NTP), the Agency for Toxic Substances and Disease Registry (ATSDR), EPA’s Integrated Risk Information System (IRIS), and the International Agency for Research on Cancer (IARC). Many studies of TCE also reveal additional health impacts including but not limited to immune toxicity, developmental toxicity (e.g., fetal cardiac defects), and neurotoxicity (e.g., Parkinson’s disease).

Read the rest here.

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City of Madison not requiring Kipp to measure PCBs in raingarden?

City of Madison not requiring Kipp to measure PCBs in raingarden?
This pictogram was used in this post; the splash pad has since been completed

 

Since August we have tried to get the following information from the City of Madison on behalf of Kipp neighbors, to no avail.

The current City lease with Madison-Kipp Corp. for its rain garden property calls for annual testing for PCBs. The lease was signed June 4, 2015, so the first year’s baseline test results should be available.

The lease also calls for a storm water management annual maintenance certification.

We have asked the city for the annual PCB results and maintenance certification, and have received no response. The only conclusion that we can reach is that the City has not required Kipp to test the rain garden for PCBs nor has Kipp filed its required storm water management annual maintenance certification.

The tests and certification are important because 1) they’re required in Kipp’s lease, 2) Kipp’s pollution goes into the raingarden, down storm drains, and into Starkweather Creek and Lake Monona, and 3) there’s no evidence that toxic chemicals from Kipp are not continuing to pollute the watershed, let alone the raingarden, bike path, and areas adjacent to both. See this link.

The City owns the land in question, so it is choosing not to require that pollution be monitored and controlled on our public land.

If you would like to see the City follow the law and its own contract, please contact Ald. Marsha Rummel at district6[at]cityofmadison.com to request that it does so. The City drives this process and so has the power to make it so.

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Why “safe” levels of toxic chemicals may not be safe

Why “safe” levels of toxic chemicals may not be safe

“There’s no problem; toxic exposure is too low to cause any harm” is a common response by pubic officials when citizens raise concerns about toxins in the environment, such a PCBs or atrazine.

MEJO board member Kristine Mattis explains why this assurance may not be accurate in this article published at Counterpunch Online:

Toxic Curve Ball: Why Outdated Assumptions to Determine “Safe Levels” of To…

By now, a large number of consumers are aware of the hazards of the synthetic compound bisphenol-A (BPA). Effect… [MORE]

 

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

These statements are nonsensical—here’s why:

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

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

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

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

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

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

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

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

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

To be continued…

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

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

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

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

 

 

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Kipp Offers Water Utility Some Advice: Run Olbrich Well 24/7!

Kipp Offers Water Utility Some Advice: Run Olbrich Well 24/7!

In a February 26, 2014 email Madison-Kipp Corporation advised the Madison Water Utility to pump the Olbrich Well (Well 8) full-time, after the Water Utility Board asked for assurance from the Wisconsin DNR that Well 8 will not be impacted by Kipp’s contamination plume.

Apparently the Water Utility is considering using Well 8 full-time again, despite knowing that the well is very likely connected to the upper aquifer, making it highly vulnerable to the significant contamination spreading from Kipp. This information, found in Kipp’s consultant report on DNR website, flies in the face of repeated assurances from the Madison Water Utility and Kipp over the last several years that Well 8 is protected from Kipp’s contamination by the Eau Claire shale layer. See footnote for more information and a link to the report.

In the Feb. 26 email, Kipp’s consultant, at the request of Kipp CEO Tony Koblinski, asserted that “all of the data, information, and best available science indicate that Unit Well 8 will not be impacted by PCE in groundwater at the Madison Kipp site if Well 8 operates 24/7.” In support of this, among other things, Kipp claims that “the vertical extent of PCE has been delineated at the Madison Kipp site,” “is not deeper than 170 feet,” and the “the PCE plume has stabilized and is no longer expanding.”

These claims are completely unsubstantiated by evidence. The vertical and horizontal extents of the Kipp plume have never been fully delineated, as this memo describes, and communications among government officials also state. Since nobody knows how deep and wide the Kipp plume really is—because there hasn’t been enough testing— it is impossible to verify that the plume is “stabilized” and “no longer expanding.”

This raises many questions. One big one: Why would it be to Kipp’s advantage to pump Well 8 full time? We speculate on this and other questions in an upcoming post. Please send your thoughts on this to info “at”mejo.us

*************************

The Well 8 log is in the last 3 pages of this report. On p. 9 of the report, it states:

“The City of Madison drinking water source is groundwater from various sandstone bedrock formations. Municipal Unit Well 8 is the closest municipal well to the Site and is approximately 1,400 feet southeast of the Site (Figure 1). Municipal Unit Well 8 is cased to 280 feet bls, below the Eau Claire shale aquitard, and is an open bedrock well across the Mount Simon Formation from 280 to 774 feet bls (McCarthy, 1945). According to the Unit Well 8 boring log (Appendix C), dynamite shots were used in a nearby test borehole at depths of approximately 380 feet, 430 feet, 480 feet, and 530 feet to fracture the bedrock between the test and Unit Well 8 borehole to increase the specific capacity of Unit Well 8. After the boreholes were connected by fracturing the bedrock, Unit Well 8 was tested at a pumping rate of approximately 1,965 gallons per minute with 65 feet of drawdown, yielding a specific capacity of approximately 30 gallons per minute per foot of drawdown.”

The “test well” they are referring to above is not cased through the Eau Claire shale. This means it is open to the upper aquifer. Because the test well and the production well have been connected (via dynamite shots), essentially the two wells are connected. In sum, this means that Well 8 is very likely connected to the upper aquifer through the test well hole. Government officials at city, county, and state agencies have known about this for some time, but have never shared this information publicly.

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Neighbors Settle for $7.2 Million But Many Kipp Environmental Injustices Still Not Addressed

The immediate neighbors around the Madison-Kipp Corp. factory settled their two class action lawsuits on Monday, July 15. The immediate neighbors and their attorneys will receive a total of $7.2 million and there will be additional pollution remediation at those plaintiffs’ properties. The $4.6 million federal court settlement can be found here; the $2.6 million state court settlement will be posted later.

Meanwhile, Kipp continues to pollute; nothing about its operations has changed and existing PCE plumes and PCB problems continue to affect children of color and the elderly at the Goodman Community Center (a neighbor that did not join the class action lawsuit), as well as Lowell Elementary School,  adjacent businesses, a wide swath of the surrounding Atwood neighborhood, a water well and Lake Monona.

A partial list of ongoing concerns:

  • The U.S. Environmental Protection Agency continues to negotiate with Madison-Kipp about the EPA Notice of Violation issued last fall regarding serious air pollution violations involving chlorine, dioxin, and other hazardous air pollution emissions.
  • The PCB remediation around Kipp continues (will DNR ever test for dioxin, a contaminant found in PCBs)? Dioxins are among the most toxic chemicals ever studied
  • Preferential pathways for PCE contamination (utility corridors, sewers, storm drains) were never addressed at Kipp. So the full extent of shallow contamination offsite is unknown–which means the full extent of vapor intrusion in homes and businesses around Kipp is also unknown.
  • The extent of the PCE plume still isn’t fully defined; How deep is it? How far north does it go? How far south? Has it reached the lake?
  • Children at the Goodman Community Center are building raised-bed gardens about 50 feet from the most contaminated area at Kipp
  • High levels of contamination sit right under Goodman’s Ironworks Café. Nobody has assessed the depth of this contamination and whether it is causing vapor intrusion in the café. Why not?
  • The Wisconsin Department of Justice lawsuit regarding PCBs is still active
  • The Madison Water Utility is still unsure if it can use Well 8, down plume from Kipp’s PCE contamination and next to Lake Monona in Olbrich Park

To date, no public agencies nor elected officials have addressed–or even mentioned in reams of reports to date–pollution exposures to children at the Goodman Community Center and Lowell Elementary School. Are they completely unaware of what environmental justice means?

When will this change?

 

 

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Kipp’s PCE contamination under–and past–Lowell School?

Kipp’s PCE plume on its way to drinking water well and Lake Monona

At the May 28 Madison Water Utility Board meeting, staff reported the following (from the minutes):

Madison Kipp Corporation/UW #8 Sentinel Well:

“Groundwater at the Madison-Kipp Corporation (MKC) facility continues to be monitored for VOCs. A new monitoring well (MW-25) was recently installed at the intersection of Ludington Avenue and Center Avenue, approximately 600 feet northwest of Unit Well 8. Preliminary sampling indicates low levels (1.6 ug-3.3 ug/l) of tetrachloroethylene (PCE) exist at a depth of 100-130 feet below the surface here. It appears that the edge of the PCE plume has reached this location. Conformational sampling has been conducted at this location and the pending result will be used to verify the presence and concentration of this compound. The installation of the sentinel well, proposed to be installed adjacent to Elmside Circle Park, remains on hold.”

In other words, the Kipp contaminant plume is under [and past] Lowell School. The phrase “the edge of the PCE plume has reached this location” implies that PCE just got there, but it is very likely the plume reached past Lowell School years ago [hence various breakdown products of PCE present in Well 8, which is past the school in Olbrich Park at the shore of Lake Monona.

Kipp should also pay for additional monitoring wells to the south and in the direction of Olbrich Park to determine the extent of its PCE plume in that direction. Who knows how many other homes and businesses have PCE under them?

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New Data Maps Show Widespread Kipp Pollution

New Maps Show Alarming & Widespread Groundwater Contamination Around Kipp

Using just-released data at the Madison-Kipp 101- year old industrial site and surrounding neighborhood, Dr. Lorne G. Everett has produced new maps that illustrate the probable range of Kipp’s groundwater pollution. The maps show much more widespread volatile organic compound (VOC) contamination than the DNR previously believed existed at the site. The VOCs found in the groundwater include PCE, TCE, cis-1,2,-DCE and vinyl chloride. The new data suggest groundwater pollution goes well beyond Kipp’s property into the surrounding Atwood neighborhood, as far as Circle Park and Wirth Court Park. This new data suggest that more remediation will be necessary in a far larger area.

Everett Kipp plume maps

Dr. Everett is a retired “scholar of great distinction” at University of California at Santa Barbara. He is an internationally recognized expert who has conducted extensive research on subsurface characterization and remediation. He is Chairman of the ASTM Task Committee on Groundwater and Vadose Zone Monitoring. [Everett Resume]

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