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Dec.

16, 2014

RE: Draft Environmental Assessment, State Archive Preservation Facility, DFD Project No. 09H2L
Mr. Carney:

Thank you for releasing the Draft Environmental Assessment for public review and comments. Our
summary comments are below and details attached.

In general, we are not opposed to the proposed location for the facility. The facility will provide better
storage for the important Wisconsin Historical Society and Veterans Museum materials and incorporates
some beneficial environmental features. The proposed facility appears to be an improvement over the
existing and past structures and uses. The Native American ceremonial grounds included in the proposed
facility are critical and welcomed, as long as they are planned and carried out at all stages with the
meaningful engagement and support of Native American groups whose sacred objects will be stored at the
facility and will use the ceremonial grounds (see below).

However, several critical issues are not adequately addressed in the Draft Environmental Assessment (EA).
The document downplays or neglects several toxic contaminant issues related to the sites past 100 + years
of heavy industrial uses. It doesnt adequately address how the entities managing different aspects of the
project will protect the health of the neighborhood and surrounding environment and waterways while the
building is being demolished and a new facility is being constructed.

Further, the public and other interested or affected parties have not been provided adequate opportunity
to review and comment on this substantial project, which is in the middle of a residential neighborhood
and next to the Yahara River and Lake Monona. Most immediate neighbors were not aware of the project
until a few weeks ago when they happened to see a sign posted on the building. Further, the Environmental
Site Assessments (ESA Phase I and II, over 1000 pages of information highly critical to the charge of the EA)
were not included with the EA first released to the public, and werent made publicly available until Dec. 8.
In other words, the public had 8 days to review thousands of pages of documents highly relevant to the
charge of the environmental assessment.
It is not known whether the Wisconsin Intertribal Repatriation Committee has been given adequate (or
any) opportunities to review the proposal and engage in discussions and decisions about it. If not,
engagement with this group should be facilitated immediately before further decisions are made.

The Environmental Assessment document states that it has been prepared in accordance with the
Wisconsin Environmental Policy Act (WEPA) and Wisconsin Administrative Code Chapter ADM 60 to
determine whether an Environmental Impact Statement (EIS) is required for the project (pg. i). We
believe this project requires an Environmental Impact Statement, and that further investigation of
site contamination is needed, for the reasons outlined in the attached document.
Thank you for taking the time to consider our comments.
Sincerely,

Maria Powell, PhD


President, Midwest Environmental Justice Organization (MEJO)
Community-Based Participatory Researcher
Madison, WI 53704
mariapowell@mejo.us
608-240-1485

Issues requiring further investigation or explanation:


1. More testing needed to define the scope of PCE contamination of soils and groundwater
throughout the 201 Dickinson/202 Thornton site. The Environmental Assessment doesnt mention
PCE found in the past in the soils and/or groundwater at the site. In the early/mid 1990s,
tetrachloroethylene (PCE) over the Preventive Action Levels (0.5 ug/L) and approaching the Enforcement
Standard (5 ug/L) were found in shallow groundwater in an area in the north central part of the site. Very
limited tests were done at that time. A 1995 Limited Phase I Environmental Site Assessment for the site
stated that Because the site produced large metal parts, such as gun barrels for naval vessels, large
quantities of solvents may have been used. In 2006, soils with 5100 ug/kg of PCE, 110 ug/kg TCE, and
PCBs (at unknown levels) were found in soils in a cistern in the center courtyard of the site. PCE and TCE
levels over PALs were also found in one test in shallow groundwater on the southwest corner of the site,
indicating that the PCE had spread in shallow groundwater to other parts of the site far from the first area
where it was detected. The highly contaminated cistern and soils were removed and replaced, but in 2007,
17 and 20 ug/L PCE were found in shallow groundwater near the historic cistern. The site was closed by
the DNR in 2010, despite the fact that only limited shallow soil and groundwater tests were done and most
areas of the site, including areas with high potential to have PCE contamination, were never tested.

In the most recent tests (2013), unless we are missing data, no groundwater tests for PCE and other VOCs
were done and the relatively few soil VOC tests did not include areas cited above that had PCE
contamination in the past, or other areas that are likely to have PCE contamination based on past uses (e.g.,
machine shops).

The sites 100+ years of industrial uses and the above data indicate that there could be a significant PCE
plume in groundwater under the site (usually only 8-10 feet down). Tests to date have been far too limited
to assess whether or not this is the case. The sources of the PCE were not identified and quantities used
were never estimated, though the history of the site indicates that they could be quite substantial. Only
very shallow groundwater monitoring was done. Pathways by which PCE and other contaminants may
have traveled throughout and off the site, such as storm and sanitary sewers, were never evaluated.

Given the above, there is a potential for vapor intrusion at this site, which could pose a health threat to
people working in the new facility as well as nearby residents. Therefore, it would be prudent to do further
testing to assess (or rule out) shallow groundwater PCE and/or other VOC contamination. If the potential
for vapor intrusion exists on the site, vapor mitigation should be considered in the new facility plans.

2. More testing needed to understand extent of PCB contamination of soils, groundwater


throughout site, and building materials. PCBs are the most toxic contaminants identified on the site to
date (and are well known to be contaminated with even more toxic dioxins). Given the past industrial uses
of the facility, the quantities of PCBs used could have been considerable and in several locations of the site.

The EA doesnt mention PCBs. The ESA Phase II document (not initially shared with the public) notes that
PCBs were detected on the property in the past (that older data isnt included as far as we can tell), but
notes that in 2013, no PCBs were detected in soil on the site, with the exception of GP-2 from 5-7 feet
down and Total PCBs were found to exceed the RCL for protection of groundwater. This indicates that
there are some PCB problems. However, the very few PCB tests done in 2013 (just four borings in one small
part of the site) are insufficient to understand the extent of the PCB contamination on the site. Nine Aroclor
(PCB mixtures), and possibly congeners/homologues, should have been measured. Also, sources of PCBs
and pathways by which they could have traveled throughout the site and off site, such as storm and sewer
routes, should have been considered.
Further, it is very possible that PCBs are found in building materials (concrete, walls, etc), but this has not
been tested. This is critical information. The EA notes that some site materials will be ground onsite to be

utilized as fill for the new facility. If these materials have PCBs in them, this strategy is obviously not
appropriate. Moreover, the building demolition will release contaminated dusts into the neighborhood and
contaminated sediments into groundwater and nearby waterways, where they will eventually affect
wildlife, fish, and people who eat fish from Yahara River and Lake Monona, including many low income,
minority subsistence anglers for whom this fish is an important food source.

In sum, more PCB testing of soils, groundwater, and building materials throughout the site should be done
to better understand the extent of the PCB contamination. With this information, project managers will be
more able to develop the appropriate state-of-the-art strategies to prevent human and environmental
exposures to PCBs (and other contaminants) during demolition and construction. Without this information,
unidentified PCB contaminated materials are more likely to be released into the neighborhood and
waterways, and possibly re-buried on site or incorporated into the new facility.

3. Inadequate/unclear plans for preventing human exposures to toxic dust during demolition and
construction. This is one of the most critical public health issues that the EA has not adequately addressed.
According to the EA, demolition and construction will be going on for well over two yearsdisrupting soils,
groundwater, and building materials containing PAHs, lead and other metals, PCBs, PCE, asbestos, and
other contaminants. The EA does not address how exposures to people living in the neighborhood and site
workers will be prevented during this very long period of time. Dust contaminated with toxins will be
released from building materials and soils during demolition and construction and potentially inhaled by
workers and neighboring residents. As outlined above, contaminants in soils and buildings need to be
identified adequately in order to develop appropriate demolition plans that fully control the release of
dusts from contaminated areas.
4. Inadequate/unclear plans for controlling sediment and other runoff to Yahara River and Lake
Monona during demolition and construction. Runoff with sediments (containing phosphorus), PCBs,
PCE, metals, PAHs, etc pose risks to Yahara River and Lake Monona wildlife, fish, and people who eat fish.
Lake Monona is already listed as impaired by the DNR for PCBs and phosphorus. It is well known that the
Lake Monona and other Yahara lakes are heavily negatively impacted by excessive phosphorus runoff,
causing algae blooms and exacerbating eutrophication. Contaminants from this site have already entered
the Yahara River and Lake Monona for many decades via direct runoff, air deposition from the facilitys
emissions, and via sanitary and storm sewers. Site consultant reports from the 1990s say that tiled
catchment area was in the courtyard where the heavily PCE and PCB contaminated cistern wasand that
sewer lines ran from this to the former UST area and then directly discharged to the Yahara River.
Consultant reports in the 90s indicated that this was likely a conduit for contamination, and at one point
recommended testing the sewer outfall. However, this was never done. To date, storm and sanitary routes
have not been assessed as contamination conduits offsite and to the Yahara River.

To address stormwater management, the EA vaguely defers to existing government entities and
regulations, noting that Because water quality and erosion control measures will be in place during and after
construction, it is unlikely that these aquatic resources will be affected by the project. Based on our
experiences with stormwater runoff and erosion control at other construction sites, these statements are
not reassuring. We know that existing standards allow up to 5 tons of sediment per acre to leave sites and
contractors are often very sloppy in following requirements (or ignore them altogether). Regulators often
do not notice obvious and significant violations, or enforce them if they are noticed. Given the
contamination on this site, a lot of sediments, including some highly contaminated sediments, could enter
the Yahara River and Lake Monona during the demolition and construction of the new facility.

The EA also notes that It is expected that minimal soil will be removed from the site, and excavated materials
will be used where possible to balance fill areas. The minor existing trees scrub and brush will be removed
and the site manipulated to facilitate building and pavement construction and to facilitate stormwater
drainage. What does the site manipulatedto facilitate stormwater drainage mean? This suggests that
stormwater will be routed to drain quickly offsite into the Yahara River (and then to Lake Monona); if so,

this is highly problematic. Also, again, contaminated soils should not be used for fill, so contamination
should be thoroughly identified before excavation and demolition so contamination is not re-buried onsite.

We propose that this project should go to the fullest extent possible not to further impair the Yahara River
and Lake Monona. Given the size of this site, the types/levels of contaminants there, and the proximity of
the Yahara River and Lake Monona, the best available, state-of-the-art approaches should be used to
control runoff during demolition and constructiongoing beyond inadequate existing standards and
regulations. Stormwater and erosion management should be monitored closely at all stages of the project.
Before demolition begins, as outlined above, PCB, PCE, PAH, and metal contaminated soils, shallow
groundwater, and building materials should be more thoroughly identified throughout the site in order to
better prevent their release offsite in runoff water and/or sediments. All storm and sanitary sewer routes,
past and present, should be clearly identified on the site (as well as their offsite discharge locations) in
order to develop the most thorough and appropriate runoff and erosion control strategies during
demolition/construction.

5. Inadequate/unclear plans for stormwater management for the new facility. The EA only minimally
addresses this, saying that raingardens and other engineered infiltration systems will not be built on the
site because of the contamination. We agree that raingardens are not appropriate at this site because they
would encourage toxic contaminants in the soils to infiltrate down to the groundwater. However, the
document also states that The roof drain and storm sewer system will be routed through a stormwater
management system via stormwater catch basins and underground detention storage facilities before
connecting into the existing City of Madison storm sewer system which is ultimately directed north to the
Yahara River. Again, this suggests that stormwater systems will be designed to route runoff quickly and
directly to the Yahara River.

While this design is likely intended to prevent flooding, it raises other questions that need to be addressed.
What contaminants might the new facility emit via air and other pipes and processes that would get into
stormwater routed directly to the Yahara River and Lake Monona (e.g., emissions from air conditioning
systems, etc)? To predict stormwater runoff and broader environmental impacts of this facility, and
prevent any future pollution to the environment, 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. 1

Some of the above information should be included in the Storm Water Pollution Prevention Plan (SWPPP) required
for the DNR WPDES permit for the site (required under the U.S. EPA Clean Water Act). However, we know from DNR
document reviews for other facilities that SWPPP plans submitted by facilities are often lacking many important
details about facility emissions and other potential sources of contamination in stormwater runoff, and DNR doesnt
enforce violations related to stormwater pollution prevention requirements. Consequently, Best Management
Practices (BMPs) to prevent contamination from entering runoff from these facilities are also inadequate or
nonexistent. This facility should be required to be accurate and comprehensive in any future SWPPPs it submits to
DNR, and use state-of-the-art practices to prevent toxic contamination from entering runoff.