RIVERSIDE PARK Citizen Testing Goals, Suggestions, and Documentation July 23, 2019
What raised community concerns about Riverside Park? 2006 private soil samples near the culvert in the park revealed WDNR direct contact • soil exceedances for dioxins & furans 1 The samples were taken in relation to a lawsuit involving WAULECO and Sentry • Insurance 2 Plaintiffs alleged that (penta-related) dioxin contamination stemming from the site • west of the park had caused certain illnesses including cancer and – in some cases – death 2 Some residents not involved in the suit learned of the results years later and • community awareness grew 2 1 Email and spreadsheet attachment from Matt Thompson (WDNR) to Tom Kilian, 3/14/18 2 https://www.wsaw.com/home/headlines/Wausau_Residents_Sue_over_chemical_contamination_126517628.html
The City of Wausau was Aware of the Lawsuit and Used Plaintiff Deaths as an Example to Support Its 2013 EPA Grant Application Services Suitable for all categories business and personal presentation farmers ensure that we will bring the best of the market. Source: Application for U.S. EPA Brownfields Planning Grant, City of Wausau, WI – FY2013, Page 3, 3 Blue Highlights Added
What raised community concerns about Riverside Park? Residents also learned of substantial contamination and spills at the 3M Company • property which borders the park to the west Included significant oil and petroleum spills 1 • 3M/Arcadis records from the DNR show 3M contamination impacted soil in the public • park to the east 2 CCW video/photo documentation suggests that runoff of storm water into the park may • have occurred until fairly recently 3 Past outfall (#005) outlet bordering 3M property appears to be in the park • 4 1 https://dnr.wi.gov/botw/GetActivityDetail.do?adn=0337298678&siteId=643700 2 3M Downtown, Arcadis Diagram, Approximate Extent of Residual Soil Contamination (2013) 3 https://www.youtube.com/watch?v=6Q658LazPrw
Citizen goals of future park testing Determine if, over time, soil levels in park have declined enough to now be within • Wisconsin Soil Cleanup Standards (WSCS) levels If so, this outcome would be very positive • If not, 1) fully define the extent and area of contamination which exceeds WSCS • And, if not, 2) implement remediation or controls of this area as laid out in state • administrative code Remediation process must include a meaningful public involvement process • 5
Citizen goals of future park testing Additional goal: define a background value for arsenic in the neighborhood that is truly • representative DNR increased its RCLs of certain heavy metals several years ago based on a USGS study • of Wisconsin background values However, the background value used for arsenic is now relatively high because it uses • the highest arsenic value out of roughly 650 statewide samples (barring a few outliers) 1 Based on very limited sampling: arsenic level of 8 mg/kg appears unrepresentative of • background here (may be closer to 2-4 mg/kg given sample results) Would be inexpensive. Asking for the government’s help. • Could then be used in the park assessment • 6 1 Summary of Department of Natural Resources (DNR) Responses to Public Comments on RR Program Guidance, RR-991 December 2015
Summary of Department of Natural Resources (DNR) Responses to Public Comments on RR Program Guidance, RR-991 – ARSENIC BACKGROUND VALUES (Highlight Added) 7
Dioxin & Furan Direct Contact Soil Exceedances, Exceedances Based on State’s Codified Cancer Risk Levels ( Source: Spreadsheet Created by WDNR | Provided in March 14, 2018 Email as an Attachment) 8
Pentachlorophenol Analysis was Done on Culvert Inlet and Discharge Samples in 2006 Results for Penta were a Non-Detect (Blue Highlight Added), No Indication of Active Leaching of Penta from Unrelated Structures 9
Pentachlorophenol Analysis was Done on Culvert Inlet and Discharge Samples in 2006 Results for Penta were a Non-Detect No Indication of Active Leaching of Penta from Unrelated Structures 10
Regarding Dioxins, PCBs and Calculated Risk in the Neighborhood: DNR Internal Email, 4/12/18 Services (Emphasis Added) Suitable for all categories business and personal presentation farmers ensure that we will bring the best of the market. “An aside: Absent in the data submitted are dioxin-like PCBs (those with TEFs). So whatever dioxin risk was calculated from the submittal should still be considered an underestimate .” Source: 4/12/18 Email from Aristeo Pelayo (WDNR) to John Morris (WDNR) Subject: Re: TEFs for Total Isomer Groups 11
Regarding Relevance of PCB Testing: Tens of Industrial Buildings Demolished at WAULECO and Additional Unrelated Industrial Buildings Demolished in Close Proximity Services Suitable for all categories business and personal presentation farmers ensure that we will bring the best of the market. Source: Environmental Demolition Plan for the WAULECO, Inc. Site , Keystone (KER), January 1992. Blue Highlight Added 12
Top (Circa 1974) | Bottom (2016) 13
Overlay of Historical and Recent Park Imagery with Transparency (Note Location of Former Industrial Structures to Modern Day Park) 14
Elevation Data, Park & Industrial Properties | County Wide 2 Ft. Contours (2012) | County GIS | Note Decline in Elevation Areas 15
Corresponds with Storm Water Map| Attachment of 7/24/18 WDNR Email from Melissa Yarrington to Matt Thompson | Note Pathway of Runoff from Culvert Outlet Area 16
2000 Photo – Marathon County GIS – Industrial Properties Bordering Park – Potential Runoff 17
CCW Documentation Showed Runoff and Ponding in Park During and After Rain Events (Stemming from Area North of Culvert, Near Undemolished Structure) View park runoff footage at roughly 1 minute and 5 seconds in this CCW YouTube Video: https://www.youtube.com/watch?v=6Q658LazPrw&start=65 18
CCW Video and Photo Documentation Showed Runoff and Ponding in Park During and After Rain Events View park runoff footage at roughly 1 minute and 5 seconds in this CCW YouTube Video: https://www.youtube.com/watch?v=6Q658LazPrw&start=65 19
After Ponding Area Dried, a Gray Silty Residue was Left on Grass and Foliage 20
After Ponding Area Dried, a Gray Silty Residue was Left on Grass and Foliage 21
Limited Heavy Metals Sampling (CCW, Samples Collected in October 2018) 22
Limited Heavy Metals Sampling (Samples Collected October 2018) Runoff/ponding area shown in pictures of park Near roadway on Thomas St. Prior to Project Northwest area of park away from runoff area 23
Image Showing Past Location of Outfall (#005) Sign and Potential Discharge Area in Park 24
Source: REMEDIAL ACTION PLAN FOR FORMER UST SITES 3M DOWNTOWN WAUSAU FACILITY, WAUSAU, WISCONSIN, OCTOBER 1992 25
Apparent Culvert Inlet Location | Difficult to Identify Under Brush and Foliage | Not Fenced In (July 2019) 26
Photo of Original Culvert Photo Location (Taken in 2006) 27 Source: Screen Shot of Portion of Lawsuit Documents taken from WI DHS Records
Culvert Inlet Location | Looking West – Culvert Inlet on East Side of Fence (July 2019) 28
Near Culvert Inlet Area Looking South/Southeast – Note the Close Proximity of the Residential Backyard (July 2019) 29
Exposure Calculations CCW Note: TEF-Adjusted Culvert Inlet level was 105 ng/kg according to DNR records Source: Appendix, Exposure Calculation: Average Daily Intake of Dioxin for Riverside Park Users and Thomas/River Street Residents, Wisconsin DHS Toxicologist 30
Suggested Testing Zones 1. Soil area near fence line separating industrial property from park 2. Wooded area/forest, including those near former demolition areas 3. Depressed elevation zone where runoff and ponding have been suspected 31
Suggested Dioxin Sampling Depth and Method 1.At the base of the A-Horizon (topsoil) 2.Between 4” to 8” in depth 3.EPA Method 1613B 32
Non-Dioxin Soil Sampling/Analysis 1. Suggesting that no composites be used • Soil levels are not anticipated to be homogenous across different depths and points • Concern Dilution of “hot spot” areas could occur 2. Depth of deeper samples will be important. Would like to discuss options and rationale with REI/Mr. Lassa 33
Requesting 1. A citizen monitor present during sampling events 2. Split samples be provided 34
Questions on Inclusion in Current Proposal 1. Inclusion of mercury in metals 2. Inclusion of tetrachloroethylene, trichloroethylene vinyl chloride, acetone, methylene chloride, 2-butanone 3. Inclusion of benzo(a)anthracene, benzo(k) fluoranthene, other PAHs, etc. 4. Question on titanium dioxide for REI 5. Requesting dioxin-like PCBs (with TEFs) be added 35
Citizens for a Clean Wausau www.CleanWausau.com cleanwausau@protonmail.com 36
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