Elevated PFAS Levels Identified in 1300 Cleveland Ave. Groundwater
The combined concentrations of PFOA and PFOS at two well locations at 1300 Cleveland Avenue were above the Department of Health Services (DHS) recommended groundwater Enforcement Standard (ES) of 20 ng/L. Another round of groundwater testing will be helpful in determining next steps, according to the Department of Natural Resources (DNR).
Per a Status Report dated February 9, 2023 on the DNR’s public-facing online database, the City of Wausau’s December 2022 groundwater testing at the Cleveland Avenue property revealed elevated levels of PFAS above the DHS recommended standards.
“DHS’s health-based recommendation for PFOA and PFOS remains current and valid”
Records show that while the Wisconsin Natural Resource Board (NRB) did not advance the DHS’s Cycle 10 recommended groundwater standards to the governor and legislature, the DHS did not alter its recommendation of 20 ppt, individual or combined, for PFOA and PFOS. In a May 19, 2022 DNR letter for another Wisconsin site, state regulators communicated that the “DHS’s health-based recommendation for PFOA and PFOS remains current and valid.”
Per the letter, if an established groundwater standard is absent, such as with PFAS, Wis. Admin. Code § NR 722.09(2)(b)2. indicates that “a responsible party may be required to develop a site-specific standard in cooperation with the department of health services to protect public health safety and welfare.”
Site’s groundwater flow direction is anticipated to be east-southeast toward the Wisconsin River
According to a site report by the City’s environmental consultants, GEI, the “groundwater flow direction is anticipated to be east-southeast toward the Wisconsin River which is located approximately 0.5 mile from the site.”
PFAS groundwater results in Wausau are apparently limited to date and, therefore, it is unknown — in terms of objective quantitative confirmation — how many, and which, Wausau sites may be contributing sources to local groundwater concentrations. In January 2023, the DNR issued a PFAS fish consumption advisory for Lake Wausau, which is fed by the Wisconsin River.
Historically, there have been other concerns about unrelated contamination and different contaminants entering the Wisconsin River in the Thomas Street neighborhood via the groundwater in the subsurface. According to DNR records, pentachlorophenol from the Wauleco site (formerly the Crestline and SNE site) continues to discharge into the Wisconsin River east of monitoring well W-10A by Riverside Park (there is no pipe discharging penta into the river, rather the subsurface area where contaminated groundwater flows into the river is the concern). Past results show that even the rock scrapings in the river off of Riverside Park had pentachlorophenol in them. Records also show that TCE, reportedly from the 3M Property, was also historically discharging into the river via the same groundwater mechanism and location by Monitoring Well W-10A.
Source of Cleveland Avenue PFAS Groundwater Contamination Still Apparently Uncertain
In the report detailing the PFAS groundwater results at Cleveland Avenue, GEI suggested that there may be an upgradient source and communicated its position, presumably on behalf on the City of Wausau, that further groundwater assessment at the site “is not warranted”:
“We reiterate our opinion from the SIR submitted to the WDNR in February 2022, that PFAS are not a contaminant of concern at this site. Our opinion is based on there being no known source of PFAS at the site, no detections of PFAS in shallow soil/fill above currently established soil standards, and no detections of PFAS in soil at depth nearer to the groundwater interface, and the groundwater sampling results summarized above. Accordingly, it is our opinion that further groundwater assessment at this site is not warranted.” [Emphasis Added]
In recent years, the City of Wausau repeatedly resisted performing environmental tests in the Thomas Street neighborhood — from Riverside Park to 1300 Cleveland Avenue — despite indications of potential problems and numerous requests from neighborhood residents and the community at large. In those instances, when testing was later performed, sampling results indicated exceedances of state standards intended to be protective of public health and the environment.
Cluster of Current and Former Industrial Sites in Neighborhood
1300 Cleveland Avenue, itself part of the former Connor Forest Industries, is surrounded by other former or current industrial properties.
The former Crestline/SNE property is located just north of the property, along with the 3M Company site. 3M Company’s former massive dump is located just to the southwest of 1300 Cleveland Avenue.
Other properties, like the former Marathon Rubber, known for its past waterproof products and rainwear, among other items, is located northwest of the Cleveland Avenue site.
Reportedly, the former Connor Forest Industries property that the City of Wausau purchased had a history of illegal waste dumping on it, along with illegal waste burial and landfills. Historically, numerous drums were removed from the property — from both its surface and subsurface — and, while unknown waste was noted to be present in drums excavated from the soil, there is no record that the waste inside the drums was ever tested to determine its constituents.