Posts Tagged ‘Well 8’

Kipp Pollutes, DNR Stonewalls

Saturday, March 3rd, 2012

Wisconsin Department of Natural Resources (WDNR) continues to do Madison Kipp Corporation’s bidding.

For decades WDNR has covered up the corporation’s willful & wanton toxic pollution in contravention of the Clean Water Act and the Clean Air Act. Now WDNR is covering up public comment.

A detailed list of links to public comment & background information on Kipp can be found here. Much of it will not be found on the DNR’s public comment site. (However, the best DNR-published comment is from the neighborhood association, Schenk-Atwood-Starkweather-Yahara (SASY) (pdf).)

Below is my letter to the DNR secretary regarding her latest stonewalling. The emails below also were cc’d to several elected officials at state & local levels as well as several relevant WDNR officials and SASY.

Please keep in mind, this is no accidental oversight; others involved in this process have admonished relevant DNR administrators—for months—for not having posted my comment.

-Mike

***

March 2, 2012

Dear Secretary Stepp,

Below you will find a copy of my emailed comment dated 10/21/2011 regarding Madison Kipp Corporation’s pollution.

I asked that you enter this comment into the record. To date, my comment has not been included in the record at: http://dnr.wi.gov/topic/Brownfields/kipp.html#tabx4

I have an acknowledgement of receipt of this communication from your office through other communication. Thus, I once again insist that my comment be included in all public record regarding Madison Kipp Corporation.

Sincerely,

Michael D. Barrett

***

October 21, 2011

Dear Ms. Stepp,

Please enter this communication into the record with respect to Madison Kipp “Scope of Work” (SOW) and the Wisconsin Department of Natural Resources (WDNR).

At the recent neighborhood dog & pony show put on by WDNR, we witnessed professional malfeasance on an epic scale. In addition to doing everything possible to shut out the public from the process, WDNR employees promulgated lies, half-truths, dissembling and exhibited willful ignorance. To wit:

  • Your presenter, Michael Schmoller “felt” that there is no danger of Kipp pollution polluting our water supply because of a shale formation. Apparently Mr. Schmoller has not kept up with research of the last several years conducted by Professor Ken Bradbury. That research has found that the shale formation is completely permeable; so much so that viruses from surface waters have been detected in the deep aquifer from which we draw our drinking water. If viruses can move through from surface to our deep aquifer, so can toxins.
  • Your presenter claimed that he was not aware of contamination on Goodman Center land. I have seen a 2008 WDNR document, addressed to Goodman management which states unequivocally that contamination exists, and is from an “off-site source.”
  • The “Scope of Work” (SOW) is not designed to put the priority on assessing and mitigating the most likely routes of human exposures in the neighborhood–vapor intrusion into homes and other buildings. Appropriate mitigation depends on appropriate assessment of the plume and the vapor intrusion in the first place–if the vapor intrusion problems are not adequately and thoroughly assessed, the mitigation will not be adequate either.
  • Because the SOW does not fully map the plume (not even close), it is impossible to say how many homes/buildings might be affected by vapor intrusion, and in turn impossible to know which homes/buildings to monitor and then to mitigate if needed.
  • Ken Wade’s proposal is a good start, and should be followed, but doesn’t appear to fully map the plume either.
  • Testing a total of 14 homes is completely inadequate; it doesn’t begin to help risk assessors understand the potential scope of the vapor intrusion problems. Given the levels of contaminants that have been spreading in the shallow and deep groundwater for many years and probably decades and what is already known about their locations and levels in groundwater, the plume is likely under a much wider area than just these 14 homes.
  • The locations selected for monitoring do not make sense from a public health standpoint–e.g., they do not appear to be designed to put the priority on understanding and mitigating the most likely routes of significant and direct human exposure (vapor intrusion into buildings). For example, why are you only testing just at the edge of yards on the boundaries with Kipp? Why aren’t you going straight to monitoring closer to where people are living–e.g., testing subslabs and in-home vapors? That’s the monitoring that would be most relevant to people’s potentially most significant exposures.) Given the point below, you could test the edge of the yard and find no detect and there could still be significant vapor in the subslab and possibly the home.
  • Related to the above, single (one-time) tests of soil vapor (in locations that don’t make sense) to determine if vapor extraction or the installation of in-home vapor mitigation systems is completely inadequate on a number of levels. Single tests are not adequate to determine if there is a soil vapor problem. As noted in this paper– http://onlinelibrary.wiley.com/doi/10.1111/j.1745-6592.2009.01216.x/pdf–adequate sampling of vapor intrusion requires repeated tests over space and time because “measured concentrations of volatile organic compounds…can vary considerably from month to month and season to season. Sampling results from any one location at any given point in time cannot be expected to represent the range of conditions that may exist at neighboring locations or at other times. Recognition of this variability is important when designing sampling plans and risk management programs to address the vapor intrusion pathway.” Because soil gas samples can vary so much over space and time, a much larger number of sample locations over multiple times are needed to accurately characterize the contaminant distribution in soil gas.
  • The SOW completely ignores monitoring soils around and vapor intrusion under/in buildings very close to Kipp, and in particular the Goodman Center. Why? While Schmoller said he “felt” that Goodman wouldn’t have vapor intrusion problems, there is no data justifying his belief, and he never explained his reasoning. Regardless of his “feelings” on this, I think it’s a no-brainer that Goodman should be tested, just to make sure.*
  • The impacts, current & future, on Well 8 [Olbrich Sledding Hill] must be documented and modeled; this would include an increased withdrawal scenario. If Well 8 is filtered for Manganese and Iron, which is under consideration (pilot tests very soon if not already), this will also draw the Kipp contaminants into the well faster/sooner.
  • The neighborhood is already getting water from PCE/TCE contaminated wells–Well 11 and Well 15. The Schenk-Atwood area drinks water from a combination of Wells 8, 11, 15 (and 29?). Well 15 has the worst PCE contamination. Any additional PCE/TCE and related contaminants that end up from Well 8 will only add to existing levels from those wells.
  • This is an environmental justice issue: While most middle/upper middle class people can afford a filter, most low income people cannot. The poor should not be poisoned. Most especially, they should not be poisoned for being poor.
  • Put all relevant Kipp SOW/legal documents at Hawthorne Library and make them available for download. ALL documents–even the embarrassing/sensitive ones.
  • The vapor dispersal system you have proposed is so 1960s. Dilution-the-best-solution-to-pollution? Wrong. And it contravenes the agreement my government and I, as a citizen, came to through the Clean Water Act and the Clean Air Act.
  • The public engagement process so far has been highly inadequate on a number of levels. For starters, the neighborhood had less than a week to comment on this SOW; that is not even close to adequate. It is clear that WDNR sees public comment as completely token.
Ms. Stepp, clean up your mess.
Now.
Completely.
Dig up the source contaminant.
Remove it from the site.
All of it.
Dispose of it properly.
Make the perpetrator pay for all of it.*
Plus significant penalties.
Your agency has had decades to fix this problem. Do your job as you promised the US Environmental Protection Agency you would.
Sincerely,
Michael D. Barrett
*As good conservatives love to say, ‘you do the crime, you do the time.’

 

 

 

 

Madison Water Utility to Deliver Brown Water to Eastside Taps this Summer

Tuesday, May 25th, 2010

Tuesday evening, 5/25/2010, the Water Utility Board will be meeting:

4:30 PM WATER UTILITY BOARD 119 E. OLIN AVE. ROOMS A & B (pdf of agenda here)

Though the topic is not on the agenda, eastsiders are concerned about the Utility’s plans to open the spigot on Well 8 this summer.

This is the well that sits atop the Olbrich sledding hill. It serves the near east side (Atwood & environs). It has:

a) high manganese levels (the element that causes dirty brown water around here), and,

b) high bacteria counts (given the drawdown of the aquifer, the aquifer is now likely supplied by lakewater rather than the natural order of things, aquifer-feeding-into-lake).

Given the routine summertime drawdown of our aquifer (generally caused by obsessions with green lawns in August), the Utility — spurred by the Fire Department — goes into desperation mode and opens this dirty well during peak-demand summer months.

Eastsiders are, shall we say, concerned. And rightly so. Several of our leading lights are submitting comment about the need for a better, safer policy with regard to our water supply.

The overarching point is: The Water Utility needs to follow the sustainability, conservation path rather than the business-as-usual consumption-at-all-costs path.

Below are some of the emails constituting public comment submissions on the idea of adding such a dangerous water source to our drinking water.

***

From fae dremock

Sent : Saturday, May 22, 2010 8:58 PM

To : Larson, Alan

Subject : Well 8: keep it offline

Hi, Al–

Well 8 has long been pumping water into taps used for drinking water by older residents, folks with heart conditions, pregnant women, and your children.

All of those groups are considered at risk at the high levels of manganese and iron reported in Well 8 water– which in fact led to citizen concern and to utility investigation into the need for filtration of Well 8.

The high iron levels are also correlated (perhaps also causative) of increased bacterial growth in the well.

The Madison water utility has already reported that Well 8 NEEDS filtration, and the well was turned off to avoid using that well’s water as drinking water.

If we had an adequate summer conservation program in place and well disseminated in the neighborhoods in that pressure zone, the Well would not need to be turned back on. We even have ways of doing this outlined in the utility’s standard operating procedure for citizen process– which was approved by the common council.

We should NOT being turning Well 8 back on– in its current unfiltered state. And the utility doesn’t need the added publicity of citizen blowback or independent epidemiological studies of high manganese and high iron health effects on at-risk populations in Madison, whether seniors or young children or pregnant mothers.

Either filter Well 8, or keep it shut down.

Please include this email under Public Comment on the May 25 Water Utility Board Agenda–in case I am unable to attend the May 25 Board meeting in person.

Sincerely,

Fae Dremock

Former member of the citizen water utility working group for Well 3 and a member of the citizen committee that worked with the water utility to create the SOP on citizen process.

Also, press card-carrying member of the National Science Writers Association.

***

From: Steven Klafka

Subject: City Well 8 Operating Schedule for 2010

To : “Larson, Alan”

Date : Thursday, May 20, 2010, 3:44 PM

Al Larson,

Probably because of my involvement on the Well 8 citizens advisory committee, I have seen recent emails regarding the operation of Well 8 this summer beginning in late June. As has been suggested, I think the Water Utility should seriously consider not operating Well 8 this summer, and not until a new filtration system is installed at Well 8 or in combination with other wells on the eastside.

As shown in the attachment to the January 2009 project scoping document, Well 8 iron levels are several times the taste threshold and twice the level at which laundry and plumbing staining occurs. Manganese levels are at the taste threshold, and exceed levels where it can coat water pipes and discolor water. Periodic variations above the average levels reported in the scoping document would be more noticeable. The manganese levels are well below the EPA lifetime health advisory value, but the potential for health effects merits more serious consideration of our options.

The neighborhood residents around Well 8 has shown to be great environmental advocates. If the water utility suggested that neighbors reduce excessive summertime water usage so Well 8 is not required, I think they will respond positively.

Thanks for considering my comments.

Steve Klafka

508 Elmside Boulevard

Madison, WI 53704

(608) 249-0231

***

Subject : Re: Please filter or keep Well 8 turned off this summer

Date : Thu, 20 May 2010 16:31:33 -0500

From : Betty Chewning

Organization : University of Wisconsin – Madison

To: Grande, Joseph , Lawrence Lundy

Mr Grande:

Thank you for sharing my comments at the Water Board meeting.  Could you share these as well?

It looks like you intend to keep Well 8 with its elevated iron and manganese levels going this summer.  You didn’t say whether you would filter it. My neighbors and I would like to know if you are going to do this.

I’m very interested in moving forward a sustainability approach to water management. City government is constantly faced with tradeoffs, which I understand having been a member of the Madison Park Commission for the past 9 years. I don’t mean to oversimplify your challenge, but my question is why not work much more on the conservation side of the question rather than assuming you need to keep #8 in service?  Let’s work together to encourage a sustainable mode of water use by Madison’s fine residents and industryl/ businesses?  We (your agency and those of us interested in sustainability ) can ask people/ business to use less.  The sustainable Atwood effort is trying to think about this issue. For example, with city or university help we or the city could establish per capita goals.  Through their water bills we could give people feedback of whether they are below, above, or at average use on their bills? ( I have a prius and the feedback on my second by second mileage has been powerful in changing my driving behavior to conserve gas).   This could be augmented with public education on formulas that each household could use to determine their own goal based on number of people in the household.  People could be taught to read their own meters and given shared equipment for doing that if needed. How hard would it be to put up on the City Water Utility web the list of behaviors that can help households, businesses and industry conserve water in the summer ( in addition to the formulaes). We use a sustain dane rain barrel to collect water for all of our plants in the summer for example.What are the resources such as this that can build the city’s capacity to conserve water. Not keeping your water running when brushing your teeth is a small start that Dr.Gilbert White, a prominent international water management expert from Univ. of Chicago,  advocated years ago just to raise consciousness that water is a scarce commodity.  The use of gray water certainly deserves discussion. Sounds like a grad student or internship project to me.  What do you think?

The translation of what is known both about human behavior and sustainable water practice and behavior is very exciting. What do you think about engaging the community in a full fledged public, industry and business education campaign on priority behaviors we can engage in to minimize our water use in Madison?  I would be happy as well as many others to help you think about it. This could be an exciting time rather than the contentious time that I”m afraid has marked well water discussions in the past. Just know that you are not alone if you choose to move in the direction of conservation and sustainability.

By the way, don’t misunderstand my point re. the serious health issues concentrated on my block. We (you and I) are all being exposed to numerous small chemical risks.  There is actually little done to estimate the interactive effects of all these small risks.  I simply don’t want my family to have another small exposure when there is no need for it.  And that is the real issue here.  If sustainability, which should happen anyway, were a central theme of madison’s policy we wouldn’t need for any elevated levels from well #8.  I sincerely and respectfully ask for your leadership on this.

Betty Chewning

***[The following message is from Water Utility a staffer]

Grande, Joseph wrote:

Thank you, Ms. Chewning, for your message regarding the planned operation of Well 8 later this year.  I have requested that your message be entered during the public comment period at next Tuesday’s Water Board meeting.

A filter at Well 8, or other Madison wells, would improve the aesthetic quality of the water and reduce the staining of clothes, shower curtains, and plumbing fixtures.  Comprehensive testing at the residential tap has shown that, when Well 8 operates, iron and manganese levels are indeed above the aesthetic threshold (i.e. the national secondary drinking water level) but well below levels deemed potentially unhealthy.  The primary problem with groundwater minerals like calcium (hardness), iron, and manganese is that they produce visible residues that are a nuisance.  Iron and manganese accumulate in water mains over time and periodically lead to discolored water at the tap.  The Water Utility already limits the operation of Well 8 to reduce the likelihood of discolored water at the residential tap.  Our flushing program further helps to lessen the chance of colored water by removing the mineral sediment before it can become a problem.

We plan to operate the well during the summer months (late June through early September) when water demands are higher due to outdoor water use.  Last year the well pumped 43 million gallons or about 1 million gallons per day and we anticipate similar operations this year. Seasonal wells, including Well 8, are important supply points to meet often unpredictable summer water demand.  They also serve as important backup supply during system problems (power outage, unplanned maintenance need, etc.) or major fire that could require additional supply.  As in previous years, we will monitor manganese and iron levels at the residential tap during the time when the well operates.  Test results from 2007-2009 are available on our website, www.madisonwater.org.

The Water Utility is committed to improving water quality throughout the water system and particularly at Well 8.  A Citizen Advisory Panel (CAP) was formed last year to allow citizen input into how the water quality concerns at Well 8 are addressed.  In addition, a consultant was recently hired to evaluate a host of treatment and operation alternatives not only for Well 8 but the entire near eastside.  The study should be completed by next summer, at which point a preferred alternative will be selected.  I encourage you to contact Al Larson (copied on this message) to become part of the CAP so that your concerns and preferences are incorporated into the planning process for improved water quality.

Finally, I am saddened to hear about the coincidental adverse health of several neighbors.  However, to my knowledge, the minerals impurities and the levels typically found in water pumped from Well 8 are not associated with these specific health conditions.  I believe Public Health Madison Dane County can more appropriately address your health-related concerns.  Jeff Lafferty (242-6491) is a good resource at Public Health.

Please feel free to contact me directly (266-4654) if you have any other water quality questions.

Sincerely,

Joseph Grande

Water Quality Manager

Madison Water Utility

608-266-4654

***

From : Foxcroft, Melanie A – DHS

Sent : Monday, May 24, 2010 3:32 PM

Subject : PUBLIC COMMENT for May 25 Board Agenda

To : Greg Harrington Water Utility Board Chair

Please include my comment below under the PUBLIC COMMENT portion of the May 25 Board Agenda, thanks!

I request that the Madison Water Utility educate and support efforts by residents in the Well #8 area to conserve water this summer, including: collect “grey” water from their households to re-use on their gardens; plant more drought-resistant lawns and garden plants (including seed & plant suggestions); reduce watering lawns (be proud of your brown lawn!); collect rain water from downspouts to use on gardens; and similar measures.

While there may be a perception that Madison has water to waste, I contend that simple water re-use and conservation measures by individuals may have a major impact on water use, limiting drawdown from wells and aquifers that have challenged water quality/quantity including well #8.  The Madison Water utility can support this by including conservation information in their bills; by initiating a concerted public announcement/education campaign; by delivering downspout collection devices free to ALL households much as trash collection bins were delivered free; offering neighborhood workshops on how to connect the devices and conserve water; limiting certain types of fertilizers; and similar measures.

A little education and awareness can go a long way!

Keeping farm phosphorous out of our lakes is a Dane County issue, but we can start locally.  THANK YOU

***

Consider sending your own message about keeping our water clean to the folks at the Water Utility Board here:

ARobb – at – madisonwater.org