RIVERSIDE PARK Citizen Testing Goals, Suggestions, and Documentation - - PowerPoint PPT Presentation

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RIVERSIDE PARK Citizen Testing Goals, Suggestions, and Documentation - - PowerPoint PPT Presentation

Oct 14, 2023 222 likes •591 views

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

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RIVERSIDE PARK

Citizen Testing Goals, Suggestions, and Documentation

July 23, 2019

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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 & furans1

  • The samples were taken in relation to a lawsuit involving WAULECO and Sentry

Insurance2

  • 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 – death2

  • Some residents not involved in the suit learned of the results years later and

community awareness grew

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

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The City of Wausau was Aware of the Lawsuit and Used Plaintiff Deaths as an Example to Support Its 2013 EPA Grant Application

Source: Application for U.S. EPA Brownfields Planning Grant, City of Wausau, WI – FY2013, Page 3, Blue Highlights Added

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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 spills1
  • 3M/Arcadis records from the DNR show 3M contamination impacted soil in the public

park to the east2

  • CCW video/photo documentation suggests that runoff of storm water into the park may

have occurred until fairly recently3

  • Past outfall (#005) outlet bordering 3M property appears to be in the park

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

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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
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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
  • f 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

1 Summary of Department of Natural Resources (DNR) Responses to Public Comments on RR Program Guidance, RR-991

December 2015

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Summary of Department of Natural Resources (DNR) Responses to Public Comments on RR Program Guidance, RR-991 – ARSENIC BACKGROUND VALUES (Highlight Added)

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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)

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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

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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

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Regarding Dioxins, PCBs and Calculated Risk in the Neighborhood: DNR Internal Email, 4/12/18 (Emphasis Added)

“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

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Regarding Relevance of PCB Testing: Tens of Industrial Buildings Demolished at WAULECO and Additional Unrelated Industrial Buildings Demolished in Close Proximity

Source: Environmental Demolition Plan for the WAULECO, Inc. Site, Keystone (KER), January 1992. Blue Highlight Added

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Top (Circa 1974) | Bottom (2016)

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Overlay of Historical and Recent Park Imagery with Transparency (Note Location of Former Industrial Structures to Modern Day Park)

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Elevation Data, Park & Industrial Properties | County Wide 2 Ft. Contours (2012) | County GIS | Note Decline in Elevation Areas

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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

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2000 Photo – Marathon County GIS – Industrial Properties Bordering Park – Potential Runoff

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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

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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

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After Ponding Area Dried, a Gray Silty Residue was Left on Grass and Foliage

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After Ponding Area Dried, a Gray Silty Residue was Left on Grass and Foliage

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Limited Heavy Metals Sampling (CCW, Samples Collected in October 2018)

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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

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Image Showing Past Location of Outfall (#005) Sign and Potential Discharge Area in Park

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25 Source: REMEDIAL ACTION PLAN FOR FORMER UST SITES 3M DOWNTOWN WAUSAU FACILITY, WAUSAU, WISCONSIN, OCTOBER 1992

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Apparent Culvert Inlet Location | Difficult to Identify Under Brush and Foliage | Not Fenced In (July 2019)

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Photo of Original Culvert Photo Location (Taken in 2006)

Source: Screen Shot of Portion of Lawsuit Documents taken from WI DHS Records

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Culvert Inlet Location | Looking West – Culvert Inlet on East Side of Fence (July 2019)

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Near Culvert Inlet Area Looking South/Southeast – Note the Close Proximity

  • f the Residential Backyard (July 2019)
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Exposure Calculations

Source: Appendix, Exposure Calculation: Average Daily Intake of Dioxin for Riverside Park Users and Thomas/River Street Residents, Wisconsin DHS Toxicologist CCW Note: TEF-Adjusted Culvert Inlet level was 105 ng/kg according to DNR records

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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
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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

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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

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Requesting

  • 1. A citizen monitor present during sampling events
  • 2. Split samples be provided
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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,

  • ther PAHs, etc.

4. Question on titanium dioxide for REI 5. Requesting dioxin-like PCBs (with TEFs) be added

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Citizens for a Clean Wausau www.CleanWausau.com cleanwausau@protonmail.com