Letter from Tom Roushar, Department of Natural Resources State of Wisconsin
Department of Natural Resources
ENTITY CONTACT REPORT FORM Form 4500-94 5-84
File Code: 4530-3
Name of Entity Madison-Kipp Date of Contact: July 13, 1994
Time of Contact: 0700h [7:00 a.m.]
Conferred With: Arnie Dalsoren, Mgr. of Plant Engineering & Maintenance
Type of Contact: Field Check
RE: Odor Investigation
Odor noted from 0630-0650. One odor was a metallic solvent-like smell on Waubesa and Marquette Streets; another was a foundry-like burning/acrid odor on Atwood Ave. I spoke briefly with a passerby who indicated that the metallic odor was frequently but transiently present. On calm summer days she said the smell just hangs in the air. It occurs frequently in the mornings. She thought it came from Madison-Kipp or Durline Scales. She also indicated there was a noise problem which was not present at the time we spoke. The wind was blowing from the NE, judged by a high flag, but wind conditions in the neighborhood were highly variable in direction around the neighborhood. Prevailing winds cannot be used in evaluating air quality in this area.
I determined the source of the metallic odor was most likely from Madison-Kipp.
The acrid odor was definitely from this source. I entered the plant to
investigate. The Plant Manager was not present, and I was told that "no one
is in charge." Arnie was familiar with the processes, and accompanied me
around the facility.
On entering the zinc area downstairs on the south (Atwood) end of the plant,
there was a very strong smell similar to natural gas, Throughout the tour,
Arnie stated he either could not smell the odor, or that it smelled "normal"
to him. This is not uncommon for people working in the presence of certain
odors for a length of time.
Within a few minutes of leaving the plant (less than 5 min. ), I experienced
a dizzy, "woozy" feeling. My face and fingers felt numb and tingly, my heart
was pounding, and I found my breathing rapid and shallow. My proprioception
was disrupted, and I did not believe I could safely drive. I knew my sense
of small was affected because I could barely smell the raspberry soda I was
drinking, which ordinarily has a strong, distinctive odor. This was at 0730h.
The symptoms subsided and I drove around Durline Scales. I detected no activity
besides a worker outside taking measurements by a frame structure.
Submitted By Lynda L. Cutts Date July 14, 1994
[This is a copy of a July 1994 Wisconsin Department of Natural Resources [WDNR] internal file memo by WDNR investigator Lynda Cutts, regarding Kipp's emissions. The body of the memo is quoted verbatim (emphasis ours); the memo format has been slightly altered for clarity on the Web. The original memo is in WDNR Southern District Air Management files.]
Chlorine Demagging Operation
Letter from Tom Roushar, Department of Natural Resources employee to Jack Schroeder at Madison-Kipp
October 14, 1994
Dear Mr. Schroeder,
In a September 2, 1994 letter, your attorney, Donald Gallo, asks for my reasons for requesting a standard operating procedure for your chlorine demagging operation.
My reasons for calling the existing procedure inadequate are many. The procedure in use, dated February 10, 1992, requires the process operator to manually charge chlorine gas until air pollution is created. "Maximum chlorine flow is determined by slowly increasing the rate until white smoke is observed. Then decrease the flow rate until the white smoke disappears." This practice results in an unnecessary emission of a hazardous, malodorous, and particulate form of air pollution. This air pollution is not controlled in any way and your practice does nothing to prevent the emission. There are also several complaints received about your facility that concern chlorine type odors.
Revising this procedure so you may comply with air pollution control emission limits is one immediate step in your overall facility compliance study. The study is, however, proceeding very slowly and you are again requested to revise and submit the chlorine demagging process standard operating procedure immediately. You were first asked to submit this procedure on March 15, 1994. You were again asked to comply with the request on August 26, 1994. I disagree with your attorney and insist that you can prepare a revised standard operating procedure just for the chlorine demaggiing operation. I agree with your attorney that the overall standard operating procedure can wait until emission testing and evaluation is complete. Please submit a revised standard operating procedure for the chlorine demagging process by October 28, 1994. If you would like to discuss these items, please write or call me at (608) 273-5603.
Compliance Unit Leader
Cc: Bureau of Air Management-AM/7
Soil and Water Contamination
DAMES & MOORE
Mr. Patrick McCutcheon
Madison-Kipp Corporation, Madison, Wisconsin
Dear Mr. McCutcheon:
In previous mobilizations, Dames & Moore has identified two potential source areas of tetrachloroethene (PCE) loading to the groundwater at the Madison-Kipp Corporation (MKC) site. One area of impacted soil was found at the northeast comer of the facility. This location is the downgradient end of a former drainage ditch, which originated at former above ground PCE tank. A second area was found approximately 250 feet south of the first area, at the location of a vent from a former PCE vapor degreaser (see Figure 1).
ADDITIONAL GEOPROBE SOIL SAMPLING
In April 1997, Dames & Moore returned to the site to collect additional Geoprobe soil samples to define the full horizontal and vertical extent of impacted soil at these two locations for purposes of remedial excavation. Sample locations are shown on Figure 2. At each of the two locations, one boring was advanced to the water table (GP-9 at the north location, GP-13 at the south). The remaining borings were advanced to the maximum contaminant depth, based upon head space monitoring. Boring logs are included as Attachment A.
Samples were selected for volatile organic compound analyses based upon head
space analyses. The results of these analyses are presented in Table 1.
Samples yielded PCE concentrations ranging from non-detect to 6.4 million
ug/kg. Trichloroethene concentrations ranged from non-detect to 126,000
ug/kg. Laboratory reports are included as Attachment B.
Attachments include the TABLE 1 RESULTS OF SOIL ANALYSES-GEOPROBE SAMPLES
[Page 1 of a 6 page letter. Emphasis added. Entire document can be obtained
at Fish Hatchery DNR, soil and water remediation department. Please note
the high concentrations of PCE and Trichlorethene found.]
[FROM: DNR ADMINISTRATION FILE]
Mr. George E. Meyer
RE: Madison Kipp Air Permit Issues - Odor Survey
Dear Secretary Meyer:
Madison Kipp Corporation (KMC) appears to be the victim of an unfortunate combination of circumstances which cry out for a common sense resolution involving intervention, on your part.
As an existing source, KMC is now required by the state air laws to obtain an operating permit for its plant. This permit application was submitted on 10/25/95 and we have been operating under an application shield since then. In December 1998, DNR staff raised questions about particulate emissions, and MKC and our consultants have been working with DNR staff to address these questions. As a result of those consultations DNR staff has confirmed that the construction of a single tall stack at the Atwood Avenue plant coupled with additional exhaust fans will allow the company to collect and emit manufacturing by products which will meet the DNR's ambient air quality standards. A hearing on the proposed permit is expected to be scheduled for mid-August.
As I'm sure you know, this process has been underway for a significant period of time. We note that from our contacts in the industry (there are a number of die casters in the State of Wisconsin, principally in the Southeast region), that MKC appears to be the first diecast facility which will obtain a permit conditioned upon the installation of control technology agreed to with your Department.
The Current Odor Issue
Very recently, and without warning a petition signed by 22 residents was received by Alderperson Judy Olson of the City of Madison. Alderperson Olson passed this petition on to the City Health Department, which in turn has forwarded it to our department. We understand from our consultant's meetings with DNR staff that based on this petition DNR regional staff intend to conduct an odor survey and to attempt to complete the odor survey in advance of the permit hearing in August.
We believe the conduct of an odor survey is ill-advised for several reasons and hope that your department will reconsider the current plan to conduct one on the basis of prevailing wind patterns for Madison. Almost all of the citizens signing the petition are upwind from Madison Kipp but downwind of other manufacturing facilities in the vicinity. We suspect that these complaints may emanate from another source. Despite the locus of complaints, Madison Kipp has become the focus of the petition and of your staffs consideration of an odor survey Rather than choose the location of the complainants as the center point of the survey the staff is proposing Madison Kipp as the center point.
Second, there has been a concerted effort in the neighborhood to distribute and post flyers focused on Madison Kipp. This effort has, in our view, created a climate of suspicion and misinformation and will contribute to significant bias in the results of any odor survey which might be conducted. We question the value of any survey results obtained in such an infected situation. Copies of the flyers are attached.
Third, the tall stack will solve not only the particulate issue, but should minimize any odor complaints. Based on modeling done by your staff the residual levels of chlorine, HCL (and die lube) certainly cause no human health hazard and in fact are less than threshold odor detection levels. Nevertheless, because of ambient air quality standards, a tall stack will be installed. It is anticipated that this stack will cut the emissions detectable at ground level to 1/100th of current levels. Logically, this stack should eliminate odor perceptions as well as particulate issues.
We have consulted with John Hausbeck of the City Health Department. The petition they received focuses on chlorine emissions. Hausbeck, who lives in the neighborhood, states that he has not detected any chlorine odors. However, he has smelled die lube (a waxy and not unpleasant smell). He is not concerned about chlorine or HCL emissions and appears to recognize that a stack will have a moderating effect on plant emissions.
We respectfully request that any proposed odor survey in the area of Madison Kipp not take place at the current time. First the boundary of the survey ignores the location of the complaints and focuses (improperly in our view) on Madison Kipp. Second, an odor survey now would be meaningless in light of the planned construction of a large stack within early calendar year 2000. Surveying existing conditions will provide no useful data. Third, the current effort by some neighbors to inflame neighborhood concerns undercuts the legitimacy of any survey.
Separating odor issues from the health-based air permit process will allow prompt construction of a source control which should have a material and beneficial effect on any emissions. In short, an unnecessary, and flawed survey process can be avoided with no impact on the public health or safety
We would be remiss if we did not comment that there are significant problems with the Department's odor rules as applied in these circumstances. According to DNR's own models, the levels of chlorine and HCL resulting from the plant are below odor detection levels for the time period modeled. At detectable levels they are no worse than odors from swimming Pool chemicals experienced by visitors to a pool or water park. To say that emissions at this level are malodorous suggests a loss of common sense. Even if 80% of the individuals in the neighborhood believed chlorine emissions were excessive, your Department could not, in good conscience and after an exercise of common sense, conclude that this normal constituent in many manufacturing processes, including water treatment, constitutes a malodorous emission.
The die tube is a similar circumstance like many die casters, Madison Kipp has moved away from hydrocarbon based die lubes to water based die lubes. All these products do cause particulate emissions (small droplets of die tube). The most common description of die lube odor is the smell of a candle burning. Die lube is a waxy lubricant and small amounts of perfume are added to deal with any possible real odor issues. Again, to conclude that if some percentage of neighbors found this emission excessive, they could have the effect of declaring this a malodorous emission subject to control flies in the face of common sense.
We can avoid these disputes by getting on with the permit process. Our expectation is that even the most remote reason for complaint will be reduced dramatically as a result of the tall stack which will be constructed. This obviates the need for any present dispute between us over the rule itself, the survey techniques or other issues which I'm sure you have had opportunity to consider the context.
Finally, a brief history. Madison Kipp Corporation has been operating on the near East side of Madison for 100 Years. Indeed, this is Madison Kipp Corporation's 101st anniversary. The plant was here long before the residential neighborhood grew up around it. MKC considers itself a law abiding citizen complying with the regulations of the State of Wisconsin and the Federal Government We provide over 600 blue collar jobs in the Madison workplace and are a major employer in the region. Manufacturing plants in residential districts can lead to misunderstandings.
We hope that the unfortunate juxtaposition of events evokes a logical response. We ask that you decide not to conduct a survey, but rather to complete the permit process and allow construction of the stack. If after the stack is up, there are valid neighborhood complaints about odor you department can evaluate them at that time.
Very truly yours,