Above: Giant drain pipes in Bridges Golf Course, which receive PFAS-contaminated stormwater from the former Truax landfill and Burke sewage plant–and former Oscar Mayer factory area–before discharging via the “golf ditch” into Starkweather Creek
Who is responsible? Oscar Mayer, the U.S. military, MMSD, MGE, Madison, Dane County, and more. Will they do anything about it? Probably not, given that they are all in bed together. It’s the same old sad story: everyone is to blame, so nobody is to blame. Read the toxic saga below…
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Highly toxic forever chemicals known as PFAS are draining via stormwater systems into Starkweather Creek from the former Burke sewage plant, Truax landfill–and probably Oscar Mayer. It’s no surprise.
The former Burke sewage treatment plant, just northeast of the Highway 30 and Packers Avenue interchange, has a complex, sordid–and confusing– history, described in more detail here and here. The former Truax Landfill, just north of the sewage plant and now covered by Bridges Golf Course, has a similar messy past. The two sites are adjacent and overlapping. To better visualize where these sites are, see here (web browser) or here (android-iphone).
Ownership of the whole area–considered part of “Truax Field– is befuddling to sort out, and has shifted over the years. The City of Madison built the sewage plant in 1914, and in years after that it was owned/operated for various periods of time by the city, Oscar Mayer, and/or the Madison Metropolitan Sewerage District (MMSD). The U.S. military operated it during WWII. The landfill area began as a city-run pig farm garbage disposal (“piggery farm”) and open burning dump in the 1920s; the unlined, unapproved landfill was owned/operated primarily by the city (and at times, Oscar Mayer) until 1972 when it closed and was sold to Dane County. Bridges Golf Course was built on it by private developers in 1999-2000, on leased Dane County land.
At this point most of the area is owned by Dane County, other than parcels purchased by Shopko in 1981 (now Pick ‘n Save) and just recently by MGE.
Beginning in the early 1900s and through the 1970s, the landfill and sewer plant received myriad hazardous and toxic wastes from the City of Madison, Oscar Mayer, the military, the University of Wisconsin, Rayovac, other local industries, construction companies and numerous other entities.
Oscar Mayer & Company sent huge quantities of wastes to both sites, and also spread its processing and sewage sludge over a large area around them; read more of that stinky history here. The majority of Oscar Mayer’s sludge wastes are still there, buried under the golf course.
Adding to this mess, abandoned former U.S. military nuclear rocket bunkers remain in the northwest corner of the landfill, largely hidden behind berms of old landfill wastes. This area was leased to the U.S. military for some time.
In the last couple of years, significant amounts of PFAS have been found in soils and groundwater beneath the former sewage plant–and in spring 2021, in the stormwater drainage system. This is no surprise, given what went into the landfill, the wastes sent to the sewage plant, and what was likely in Oscar Mayer’s processing sludges spread all over the area for decades. Oscar Mayer manufactured plastic packaging and pesticides (both known to involve PFAS compounds) along with other toxic chemicals and materials that could contain PFAS.
PFAS levels higher in stormwater than in shallow groundwater
Oddly, the highest levels of PFAS found to date were in the stormwater system that drains into the outfall depicted on the left above (hereafter called the “west outfall”), which takes stormwater from the former Oscar Mayer factory area and a part of the neighborhood north of it (Sherman neighborhood, west of Packers Ave). The outfall depicted on the right (hereafter called the “north outfall”) takes stormwater from the Truax landfill/nuclear bunker area. Stormwater in the system leading to the north outfall has never been tested as far as we know.
The two outfalls meet behind Pick ‘n Save, as depicted in the photo, and then flow through the Bridges “golf ditch” to Starkweather Creek, a little over 1000 feet to the east.
(Photo below–the golf ditch flowing into Starkweather Creek. In 2019 testing, reported in 2020, MEJO and East Madison Community Center teens found high levels of PFAS in sediments at the creek at this location.)
The storm pipes leading to both outfalls travel through old sewage sludge and hazardous landfill wastes, shallow groundwater, and surface waters that in 1989 were found to be contaminated by the Army Corps of Engineers (ACE) with chlorinated solvents, numerous (unspecified) “fluorinated organic compounds,” many toxic metals, petroleum compounds, and more. The ACE scored the area high enough on the “Hazard Ranking System” list to be considered under Superfund–even without considering PFAS compounds, though they certainly were there (“unspecified fluorinated organics”). In recent tests–again, no surprise–PFAS compounds were found in these sludges.
Where is the PFAS in the stormwater system leading to the west outfall coming from? Where is it going? Will DNR require any of the potentially responsible parties (MGE, Oscar Mayer,** City of Madison, Madison Metropolitan Sewerage District, Dane County, the U.S. military) to investigate these pathways, per NR 716 regulations–and whether they have traveled under adjacent neighborhood homes and businesses? Will the DNR require potentially responsible parties to test the PFAS in the storm system leading to the north outfall?
**The term “Oscar Mayer” includes Oscar Mayer & Co and all the corporate entities that have owned it-General Foods, Phillip Morris, Kraft-Heinz, and most recently Reich Rabin, industrial real estate developers.
Will responsible parties be asked to test for the numerous other toxic contaminants in addition to PFAS–PCE, TCE, metals, petroleum compounds– found in the landfill and sewage wastes in the past, but never cleaned up?
For more gory details and further questions, read on…
MGE purchased some of the toxic mess for an operations facility in 2019
In 2019, MGE purchased a part of the former sewage plant area from Reyco Madison, Inc./Poynette Development for $5.5 million.[1] The MGE parcel is just northeast of the HW30/Packers interchange and immediately south of the former nuclear rocket berms and Truax landfill.
MGE hired consultants SCS to complete Environmental Site Investigations (ESAs) and other investigations per DNR laws. In 2020, SCS found significant levels of PFAS in shallow groundwater under the site (see more details here).
In the most recent investigations, in spring 2021, SCS tested PFAS in the stormwater drainage system leading to the west outfall. The results were summarized in a May 2021 report. Significant levels of PFAS were found: up to 69 ppt PFOS & PFOS (46 ppt PFOA, 23 ppt PFOS) and 379 ppt total PFAS. [2]
In line with previous rounds of testing, PFAS was again found over enforcement standards in shallow groundwater wells on the parcel. “The three wells where PFAS exceeds the proposed ES are located in areas where Seymour identified buried wastewater treatment sludge,” consultants concluded.
It is puzzling that the stormwater PFAS levels are higher than the levels found in the shallow groundwater so far at the site. Why would levels in stormwater (close to the surface) be higher than those in the groundwater beneath it? Unfortunately, all of the testing done to date has been too limited horizontally and vertically to answer these questions or understand the extent of the contamination and its impacts on people and the environment.
For decades the stormdrain system that sends water to the west outfall also received storm and wastewater from the highly contaminated Oscar Mayer site, and the neighborhood to the north of it–and it still receives stormwater from these areas. A 1984 city landfill report documented leachate plumes moving west into this neighborhood from the landfill and sewage plant–threatening city municipal wells as well as Oscar Mayer’s wells (one of the company’s wells was already known to be contaminated with PCE/TCE by then, and others were found to be contaminated shortly after this). These leachate plumes have spread widely since then, but nobody has delineated where they are now, per DNR laws.
Both the west and north outfalls also receive stormwater that travels over contaminated surface soils and wastes at the old landfill, sewage plant, and Bridges golf course–where PFAS-containing pesticides could have been used over the years (and may still be used).
Where is the PFAS traveling? According to MGE’s consultants’ vague and contradictory conclusions, the PFAS–magically–doesn’t leave the site!
MGE’s consultants concluded that “Groundwater flow at the site appears to be influenced by the network of storm sewers that run east-west mid-way across the site.” But they did not discuss what the sources of PFAS into this system might be or where it is migrating.
They did note that “Measurements indicate that the water level gradient in the storm sewer is essentially flat (subject to survey and measurement errors)“–suggesting that the stormwater doesn’t flow anywhere offsite– but also stated that “the expected flow direction is east toward outfall at the ditch that discharges to Starkweather Creek.”
Based on just one sample of Starkweather Creek water, with lower PFAS levels than in the stormwater system, they concluded that the PFAS in the stormwater is not affecting the creek. With data from only three groundwater wells to the west and one to the south–and none to the east, where they said stormwater and groundwater water is traveling–they opined that “PFAS concentrations greater than the proposed ES do not appear to be migrating off site in groundwater.”
Hmmm. “Do not appear to be migrating offsite in groundwater?” How convenient for MGE to conclude this! If it admitted that PFAS could be traveling offsite, per NR716, MGE might be required by DNR to test further along these migration pathways and assess effects on any “receptors” (people, fish, wildlife, etc).
PFAS are “forever chemicals.” They do not just disappear. If they are not migrating offsite in the storm sewers and ditches into the creek, nor traveling offsite in the groundwater–ads MGE’s consultants vaguely (and laughably) suggest–where are they going? Straight downward into the deeper groundwater? If so, shouldn’t deeper groundwater be tested? To date only relatively shallow groundwater tests have been done.
Again: Will DNR ask MGE to take more Starkweather creek samples, including sediments? Will the agency ask MGE to test more offsite groundwater, in all directions, to see where the PFAS is traveling underground?
Will the agency ask MGE to test all the myriad other contaminants found in the leachate under this area in the past–TCE, PCE, PAHs, metals, petroleum compounds–and how/where they have migrated from the site?
Only if the community and elected officials demand it.
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[1] Reyco (formerly Reynolds Company) was formed by Ed and David Reynolds, sons of Henry Reynolds, who was Madison mayor from 1961-1965. The Reynolds brothers bought the property from the Madison Metropolitan Sewerage District in 1981.
[2] The Wisconsin DHS proposed groundwater standard for PFOA + PFOS is 20 ppt. For surface waters, the most recently proposed standards are (copied and pasted from DNR document):
“For PFOS, the proposed level of public health significance is 8 ng/L for all waters except those that cannot naturally support fish and do not have downstream waters that support fish. For PFOA, the proposed level of public health significance is 20 ng/L in waters classified as public water supplies under ch. NR 104, and 95 ng/L for other surface waters”
The DNR previously proposed standards of 2 ppt for PFOS and 35 ppt for PFOA, but Wisconsin Manufacturers and Commerce, industries/businesses, utilities, municipal groups and others potentially affected financially by these more stringent standards lobbied DNR to proposed the increased levels. These standards have not been promulgated into law yet; they still need to go through public comment periods and Legislative approval.
