CONCERNS ABOUT THE DOA STATE ARCHIVE FACILITY, 202 S. Thornton/201 S.
Dickinson, Madison, WI, DEMOLITION AND CONSTRUCTION: Reasons for Testing DOA
Building before Demolition, Apprehension about Fugitive Dust and Water Management
From letter to Neil Carney, Ayres Associates
Written by Maria Powell, Phd, president
Midwest Environmental Justice Organization
(MEJO)
Community-Based Participatory Researcher
Madison, 53704
mariapowell@mejo.us
This summary prepared by:
Diane Michalski Turner, PhD
303 S. Dickinson St, #1
Madison, WI 53703
dmturner643@gmail.com
608.294.9048
(c) 608.957.6465
608‑240-1485
Summary
1. The Environmental Assessment done by Ayres Associates (2013) for the DOA does not
mention tetrachloroethylene (PCE) in the soils and groundwater of the DOA property.
2. More testing needed to understand extent of PCB contamination of soils, groundwater
throughout site, and building materials.
3. Inadequate/unclear plans for preventing human exposures to toxic dust during demolition
and construction.
4. Inadequate/unclear plans for controlling sediment and other runoff to Yahara River and Lake
Monona during demolition and construction.
5. Inadequae/unclear plans for storm water management for the new facility.
Details
1. The Environmental Assessment done by Ayres Associates (2013) for the DOA does not
mention tetrachloroethylene (PCE) in the soils and groundwater of the DOA property.
Concern: PCE exposure is associated with various cancers and neurological problems for all
ages and with birth defects for children exposed through their prenatal development.
http://www.atsdr.cdc.gov/sites/lejeune/tce_pce.html
What is known:
 Because large metal parts, e.g., gun barrels for navy ships, were produced in the
building, large amounts of solvents – PCE and TCE - may have been used (1995 Limited
Phase I Environmental Site Assessment)
 2006 PCB and TCE (Trichloroethylene [TCE] is a volatile organic chemical (VOC) used
primarily as an industrial solvent) over Preventive Action Levels were found in the center
courtyard.
 PCE and TCE were found in shallow groundwater far from the courtyard indicating that
PCE had spread in shallow groundwater to other parts of the site.
 In 2010 the DNR closed the site despite the fact that only limited shallow soil and
groundwater tests were done and most other areas, including areas with high potential
to have PCE contamination were never tested.
 In 2013, from available reports:
1) no groundwater tests for PCE and other VOCs were done.
2) the few soil VOC tests did not include areas cited above that had PCE
contamination
3) areas likely to have PCE contamination based on past uses, i.e., machine shops,
were not tested
What this means:
 There can be a significant PCE plume of groundwater under the site, usually only 8 – 10 feet
from the surface.
 The plume and its depth make for a potential for vapor intrusion at this site, for nearby
residents, and for those who will occupy construction over the demolished site.
2. More testing needed to understand extent of PCB contamination of soils, groundwater
throughout site, and building materials.
Concern: PCBs (Polychlorinated biphenyls) Toxic effects such as endocrine disruption and
neurotoxicity are also associated with other compounds within the group.
http://www.epa.gov/wastes/hazard/tsd/pcbs/index.htm
What is known:
 Given previous industrial processes in the building, quantities of PCBs could have been
considerable.
 Ayres’s Environmental Assessment I does not mention PCBs.
 Environmental Assessment II notes PCBs detected in the past, for this assessment no
PCBs were detected in soil on the site, with the exception of GP—2 from 5 – 7 feet
down.
 Four borings for 2013 Environmental Assessment in one small section of the site are
too few to understand the extent of the PCB contamination of the block-long structure
 Total PCBs were found to exceed the RCL for protection of groundwater.
 Sources and pathways of PCBs, such as storm and sewer routes were not considered
What this means:
 Possible PCBs found in building materials, but these have not been tested.
 Critical to test building materials because Environmental Assessment states some
building materials will be ground on site to be utilized as fill in the new construction.
3. Inadequate/unclear plans for preventing human exposures to fugitive toxic dust during
demolition and construction.
Concern: Demolition and construction will go on over two years disrupting soils,
groundwater, and building materials containing PAHs, lead and other metals, PCBs, PCE, and
other contaminants.
What is known:
 The Environmental Assessment does not describe how people living in the area will be
prevented from exposures for this long time.
What this means:
 Contaminants in soils and buildings need to be identified properly in order to
apply proper demolition plans that fully control the release of fugitive dust from
contaminated areas.
4. Inadequate/unclear plans for controlling sediment and other runoff to Yahara River and Lake
Monona during demolition and construction.
Concern: Contaminants from this site already have gone into the Yahara River and Lake
Monona for decades.
What is known:
 Site consultant reports from the 1990s note that sewer lines from the courtyard that
was heavily contaminated with PCB and PCE ran to former the UST area and then
directly discharged into the Yahara River.
 Existing standards allow 5 tons of sediment per acre to leave sites; this site is 5 acres.
 The Environmental Assessment says that the “site [will be] manipulated . . .to facilitate
storm water drainage.”
What this means:
 Storm water will be routed to drain quickly into the Yahara River.
 Possibility of contaminated soils and debris entering the Yahara River exists.
 State-of-the-art controls of run-off should be used because of the probability of
contaminants on the site.
 PCBs, PCEs, etc. should be identified to prevent those contaminating building materials
and soils from entering the Yahara River and then Lake Monona through sediment and
other runoff.
5. Inadequae/unclear plans for storm water management for the new facility.
Concern: Storm water system will be routed to route runoff quickly and into the Yahara River.
What is known:
 Roof drain and storm system will be routed through a storm water management
system via stormwater catch basins and underground detention storage facilities
before entering the City of Madison storm sewer system that is directed north to the
Yahara River.
What this means:
 Contaminants emitted via air and other pipes and processes could enter storm water
routed to the Yahara River and Lake Monona.
 Contaminants potentially emitted from the new facility should be anticipated along
with plans for preventing their release into soils, air, groundwater, and surface water
around the site.