Photo: Foam at the Starkweather Creek/Olbrich Park boat launch on October 24 (Wisconsin State Journal)
Recent news about alarming levels of the highly toxic “forever chemicals” known as “PFAS” (per and polyfluoroalkyl substances) in Starkweather Creek in Madison, Wisconsin–downstream of the airport and Truax Air National Guard base– saddened many Madisonians, especially those of us who live near the creek and care about it.[1]
PFAS compounds have been associated with a plethora of health problems, including high cholesterol, immune, thyroid, and metabolic dysfunction, developmental problems, inability to get pregnant, kidney and liver cancer, and other cancers.
Of the six surface water sites tested for PFAS in Wisconsin, Starkweather Creek was found to have by far the highest levels. The DNR’s October 7, 2019 public release included a table showing 270 ppt of PFOS in the creek (just one of the 19 PFAS compounds detected) at Fair Oaks Avenue. This testing was done in June 2019. One month later, in July 2019, even higher levels—360 ppt of PFOS—were found. In this round of testing, total PFAS levels amounted to 822 ppt at this location, but this data wasn’t shared in the October 7 release. The full three rounds of Starkweather testing from June-August 2019 were not posted on the DNR’s PFAS webpage until some time after October 7 (it isn’t clear when).
These screaming high levels of dangerously toxic PFAS compounds inspired a Skull & Crossbones Starkweather graphic in a recent issue of The Isthmus (see below left).
PFAS data was also gathered from April through June 2019 from Dane County Regional Airport stormwater outfalls into Starkweather Creek—upstream of the samples reported above. PFAS levels at the stormwater outfall at the airport that receives runoff from a large part of the Truax base (including the known PFAS hotspot) were as high as 815 ppt for PFOS alone, and almost 875 ppt for the rest of the PFAS combined. So in sum, the total PFAS levels at this outfall were about 1690 ppt.
Airport stormwater results were not posted on DNR BRRTS till October 7—six months after the first data was gathered.
High PFAS levels in water—even higher in foam and fish
The highest levels of PFOS found in creek water were a few hundred feet from one of Lake Monona’s popular fishing locations for, at the mouth of Starkweather Creek as it flows into Lake Monona in Olbrich Park. Many shoreline anglers, including low-income and minority people who rely on this fish as a food source, fish there.
These PFAS compounds have been in the creek and its fish for decades–so anglers who eat their catch have likely been eating them for decades as well.
PFOS can build up in fish to much higher levels than in the water (sometimes thousands of times higher). Many scientific studies to date have shown that PFOS, unlike PCBs and mercury, tends to build up to higher levels in smaller fish (like panfish) than in larger fish.
Why don’t we have any PFAS data from Starkweather fish? See our previous post here. With funds provided to DNR by the City of Madison–after MEJO successfully advocated for them—the agency gathered some Starkweather Creek fish last summer and sent them to labs for testing. However, results aren’t yet available, and won’t be available till sometime in mid-2020.
In the meantime, responding to this October 7, 2019 DNR letter, on October 29 Public Health Madison Dane County (PHMDC) posted a draft letter to “landowners” near Starkweather Creek and a draft sign to post next to the creek. The sign assures people that if they follow current PCB and mercury advisories, they will be protected from harmful PFAS exposures.
Current PCB and mercury advisories say men and women over child-bearing age can eat “unlimited” numbers of panfish. With no Starkweather fish data, it is pure speculation that this level of consumption is safe. Worse, scientific studies to date showing that panfish can have some of the highest PFOS levels strongly indicate that this advice may allow, or even promote, dangerous consumption levels and PFAS exposures.
Foam PFAS levels likely much higher than water, but OK for people and pets to play in?
On October 24, foam was discovered at the mouth of Starkweather creek by a DNR staffperson; it is currently being tested for PFAS. Residents in the nearby neighborhood reported foam sightings along the Lake Monona shoreline for weeks before this. PFAS levels in foam are usually far higher than those in the water. In testing on September 18, 2019, foam tested on the Peshtigo River in northeast Wisconsin had 17,000 ppt PFOS, while water had 6.2 ppt. In other words, the foam had about 2,742 times more PFOS in it than the water.
PFOS was just one of the PFAS compounds found in the foam there; the total for other PFAS compounds found in the foam was over 14,388 ppt—for a grand total of 31,388 ppt including the PFOS.
Extrapolating from the Peshtigo data, considering only PFOS—if the foam at Starkweather Creek had 2,742 times more PFOS in it than the water, levels in foam would be 98,712 ppt. Is it safe for people, especially children, to interact with this foam—while wading, boating, fishing, or swimming?
The draft sign by Public Health Madison Dane County (PHMDC) warns of a “possible chemical exposure hazard” and advises: “Wash your hands after wading or playing in the water or foam.” If PFOS levels in foam are this high–or even one-tenth this high–is it really OK to “play” in this foam? And if people do “play” in the foam, where will they wash their hands? There are no hoses next to the creek. And if they wade—or swim–in the foam, how will they wash the rest of their bodies? Where?
For pets, PHMDC’s draft sign says: “Do not let your pet drink the water or foam and rinse pets after contact with the water or foam to avoid them licking PFAS that may be on their fur.” Again, where will people wash off their dogs?
In comparison, the Michigan Department of Health & Human Services recommends that “you avoid foam on lakes and rivers impacted by a PFAS contamination site. Foam on these lakes and rivers can have much higher amounts of PFAS than water.” The MDHHS also advises that people “not allow their pets–especially dogs–to come in contact with or swallow the foam.”
In other words, Michigan advises that if you don’t know for sure that the foam has PFAS in it, or what the levels are, if you know the water body is impacted by PFAS, you should avoid any foam you encounter and not let your pets near it either.
In our opinion the Michigan approach is the responsible, precautionary approach that we would also expect from our public health department here in Madison/Dane County. Why are they instead suggesting that playing in foam is OK?
No public input on the public outreach and engagement (or lack thereof)
On October 31, we asked DNR to share all the lab reports on BRRTS so the public could access them. We also asked about public input on their draft letter and Starkweather signs, since we’d like to comment on the proposed language for them, who they are being sent to (or not), sign placement, and more. We haven’t received a reply as of November 12.
We think the signs should advise people not to interact with the water, play with the foam, or eat the fish until more PFAS testing is done–and when that information is known, appropriate advice can be developed. Further, the letter should be sent not only to “landowners,” but to the many renters, including those in low-income public housing all along the creek. It should be translated into Spanish, Hmong, and potentially other languages spoken in these low income areas.
Related to the above, there should be at least one, and preferably several, public meetings in the communities adjacent to Starkweather Creek to discuss the PFAS in Starkweather Creek, how and where to best communicate with and engage people about the health risks, and what should be done about the contamination.
Wisconsin DNR regulation NR 714 states that “to promote effective and meaningful public participation and notification, responsible parties shall conduct all necessary public participation and notification activities, unless otherwise directed by the department. Responsible parties shall evaluate the need for and the level of public participation and notification,” based on: “(a) Threats. Known or potential threats to public health, safety, or welfare or the environment that may be reduced by providing information to the public” and “(b) Public concern. Level of public concern about a specific site, facility, or discharge or the number or status of sites, facilities, or discharges which require a response action within a particular geographic area.”
These two criteria are clearly met in the case of the high levels of PFAS in Starkweather Creek. One of the key responsible parties in this case is Dane County, as owner of Dane County Regional Airport and Truax Field land–and apparently PHMDC, a city-county agency, is taking on the NR 714 requirements on the county’s behalf.
Why isn’t PHMDC facilitating any public engagement about the PFAS in Starkweather Creek per NR 714—such as holding a public meeting in the community? Were they “otherwise directed” by DNR? The October 7 letter doesn’t include any requirements for public engagement beyond a letter to homeowners and signs along Starkweather Creek.
MEJO and others in the community have asked the city, the county, the state, and the Air National Guard for public meetings to discuss the PFAS contamination in our drinking water, waterways and fish for well over a year. All of our requests have been met with total silence.
What are these government agencies and officials afraid of? Perhaps they are afraid of being held accountable by the public? If this is so, elected officials are complicit in not forcing public agencies to share information and respond to citizens’ requests for public meetings.
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1. With several other Atwood neighborhood residents, I co-founded the non-profit group Friends of Starkweather Creek in the early 2000s. I left the group in 2005 after moving to the Northside, but have been investigating stormwater discharges that affect Starkweather Creek since 2017. From 2017-2018 MEJO was funded by EPA to engage the community in learning about stormwater issues affecting Starkweather Creek and in April 2019 we published this report about that work.
