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DNR Correspondence
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DNR Correspondence
Neighborhhod Response to Caldwell's Letter
Neighborhoods for a Healthy Environment
August 14, 1999
RE: Response to a letter sent to George Meyer by Thomas Caldwell, President
and CEO of Madison-Kipp
Dear Neighbors:
We learned last week of the attached letter, dated July 13, 1999, from
Madison-Kipp
Corp.'s President and CEO Thomas Caldwell to Wisconsin DNR Secretary George
Meyer. The letter depicts Kipp as a victim of its neighbors and seeks Secretary
Meyer's assistance in preventing DNR's regional staff from conducting an
odor survey in this neighborhood at this time. (DNR regional staff, in response
to a recent petition by 22 neighborhood residents to Alder Judy Olson regarding
Kipp's fumes and their health effects, has proposed such a survey.)
DNR plans to hold a public hearing soon on whether the Kipp Corp., which
has been operating under an "application shield" since 1995, should be granted
an operating permit. As his letter makes plain, Mr. Caldwell wants no odor
survey conducted until after that public hearing, if at all. His letter is
somewhat astonishing in its assumptions, tone, request, and even accusations;
but if Kipp is the good neighbor its recent communications with its neighbors
state it is, it should have nothing to fear from neighbors' responses to
an odor/health survey. It might be asked, too, whether it is appropriate
for a regulated entity to try to influence its regulator.
Citizens' complaint files regarding Kipp's air pollution (obtainable at DNR's
Air
Management Bureau, Southern District, Fish Hatchery Road facility) contain
hundreds of health complaints over the past decade. We have copied many of
them. Although Kipp's executives have portrayed complaints as coming from
only one person, or a very small group, DNR files show that many neighbors
have complained about problems experienced near Kipp's operations, including
strong and unpleasant smells, nausea and vomiting, shortness of breath, chest
constriction and chest pain, headache, sore throat, runny nose and eyes,
stinging and irritation of mucous membranes and skin, speeding, pounding,
and irregular heartbeat, dizziness and difficulty in concentrating, deep
coughing, repetitive sneezing, liver and kidney problems, cramps, diarrhea,
asthma, and miscarriage. A disturbing amount of disease including cancer,
birth defect, disabling arthritis, and liver and kidney failure (eventually
resulting in death) has occurred in the area adjacent to Kipp in recent years.
(A small-sample Madison Health Department survey in 1994 reported that short-term
problems tended to disappear away from the Kipp area.)
Kipp emits many kinds of chemicals, compounds, and metallic particulate,
and it is hard for neighbors to distinguish each one in this toxic melange.
Some very noxious emissions have little or no "odor" but are nevertheless
toxic or hazardous. High levels of particulate of any kind make breathing
difficult and damage the lungs. Once an industrial fume can be smelled, it
is generally capable of harming health; if these fumes continue over months
or years, chronic health damage can result. We believe that it is vital for
the State (perhaps including the State Health Department) to conduct a
comprehensive health and odor survey among all neighbors near Kipp as soon
as possible, using state-of-the-art methods accepted nationwide. We would
be most disappointed if DNR were to yield to pressure from Kipp executives
to postpone the planned survey until after Kipp's permit hearingor
to decline to conduct it at all.
An epidemiological study of the neighborhood surrounding Kipp was considered
b the Madison Health Department (with input from DNR and the State Health
Department) in November 1996, but was decided against, in part because Kipp
was making "changes." (We have copied the memo detailing the decision.) This
decision was somewhat surprising, considering the number of neighbors of
Kipp who had made health complaints between late 1994 and the date of that
decision. Kipp again plans to make "changes"this time to install a
taller stack "within early calendar year 2000," with additional exhaust fans.
Mr. Caldwell makes no mention of any filtering, scrubbing, or electrostatic
precipitation in this proposed stack, just as there is none in present Kipp
stacks and roof ejection units. How will merely ejecting uncontrolled polluted
air into the neighborhood from a higher stack with more powerful fans improve
neighborhood air qualityespecially if the much lower, unfiltered roof
ejection units continue to exhaust Kipp's foundry air near our houses? One
must use one's common sense!
Mr. Caldwell makes several unusual statements in the second full paragraph
of page 3 of his letter, one of them "According to DNR's own models, the
levels of chlorine and HCl [hydrogen chloride] resulting from the plant are
below odor detection levels for the time period modeled." If that is so,
why are there so many complaints of strong chlorine smells in the complaint
files and on petitions? Common senseagain!would lead one to question
whether the model used gives an accurate picture of Kipp's operations. Mr.
Caldwell continues, "At detectable levels they are no worse than odors from
swimming pool chemicals experienced by visitors to a pool or water park."
Unfortunately, "odors" are not the chief problem in the chlorine emissions
from Kipp; chlorine, combined with the intense heat of a Kipp aluminum furnace
and the volatile organic compounds (VOCs) on some metal Kipp melts in it,
could potentially combine to produce dioxin, one of the most toxic chemicals
produced by man. (See toxins fact sheet.) The comparison of Kipp's chlorine
operation to a chlorinated swimming pool or "water park" is a bit strained.
Chlorine is on the EPA Extremely Hazardous Substances List (see health risks
on attached fact sheet). Since 1990, Kipp has almost continuously injected
chlorine gas into its large RCI aluminum-melting furnace very close to houses.
A required sign posted on the nearby chlorine storage area states that inhalation
of chlorine will cause nausea and shortness of breath, yet Kipp recently
suggested increasing its chlorine rate from the 35lb/hour maximum rate to
80 Ibs/hour! Chlorine has a distinctive odor, as does another heavy Kipp
emissionits "die-lube" lubricant, used to prevent parts from sticking
to die-cast molds. This paraffin-based compound has a suffocating, sickening,
permeating waxy odor. Mr. Caldwell describes it as "not unpleasant"perhaps
because he has never lived in this neighborhood, which may reek of it all
day and all nightdepending on the wind direction, which constantly
changes. Kipp claims that it cannot afford to control this emission except
by dilution with waterwhich it has repeatedly put forth as its
"LACT"Latest Available Control Technologyto comply with state
law. DNR and EPA investigative documents list Kipp's emissions as "uncontrolled."
Kipp's claim that effective pollution controls are "too costly" contrasts
vividly with its listing of many large buyers of its productsincluding
General Motors, Chrysler, Harley-Davidson, Volkswagen, etc. We believe that
it can easily affordand must be requiredto control its emissions,
for the sake of the health and well-being of everyone in this long-established
(since before 1900), formerly very pleasant residential area.
Others of Mr. Caldwell's statements may also strike the reader, such as (page
3, third-to last paragraph), "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." (Emphasis added) This comment
needs no interpretation.
Under current law, polluting industries test their own pollution (through
consultants). The Wisconsin DNR does not conduct independent stack testing,
and during this decade it has generally accepted the results of Kipp's
consultants, no matter how many health complaints it has received from the
public. DNR cited Kipp in 1994 and 1995 for noncompliance and serious violations
for such practices as letting its emissions escape uncontrolled through open
windows and doors, but it claimed in 1997two to three years after initial
citationthat Kipp was in compliance for all cited irregularities (although
neighbors at a public meeting in mid-1997 detailed continuing serious problems
with Kipp's pollution). Although DNR can legally fine industries at least
$25,000 a day for not complying with its regulations, it has never fined
Kipp.
Unfortunately, air pollution has not been the only neighborhood problem traceable
to Kipp. In 1994, in a DNR-required investigation, Kipp soil was found to
contain levels of the carcinogenic solvent tetrachloroethene (PCE) of up
to 6.4 million micrograms per kilogram (ug/kg); PCE contamination found in
a well at Madison Brass Works, about 35 feet from Kipp across Waubesa Street,
was traced to Kipp. In the ensuing 4-year investigation, groundwater on Kipp's
property was found to contain up to 2,600 ug/liter of tetrachloroethene;
levels of 5 ug/liter trigger investigation. These levels are hazardously
high. Neighbors were not notified of this contamination by Kipp, DNR, or
the City between 1994 and early 1999. Our repeated efforts to learn whether
contamination had occurred were thwarted by DNR until we recently cited the
public right to know law; we then were shown DNR files detailing this
contamination by numerous chlorinated and other toxic compounds. (The documents
detailing this contamination are kept at DNR's Remediation and Redevelopment
division, at the Fish Hatchery Road facility)
Although our initial efforts to find out whether Kipp remediation had begun
were unsuccessful, Kippin spring 1999finally publicly admitted
contaminating both soil and groundwater, and a report from its consultant
on initial soil remediation was finally made available. There is question
as to whether the direction of groundwater movement and extent of contamination
have been adequately defined and what level of chlorinated solvents will
remain in area soil after remediation. Once contamination of groundwater
has occurred, it is difficult to remediate. All Madison drinking water comes
from groundwater. Soil and groundwater contamination were found under Kipp's
industrial yard; a drainage ditch parallel to and between the bicycle path
behind Kipp and Kipp's paved industrial yard (and about ten feet from both)
empties into nearby Starkweather Creek, which flows into Lake Monona.
Many neighbors have worked on these problems for many years; many have been
driven out of the neighborhood by health problems experienced only when they
lived near Kipp. We continue to work on them and would welcome any ideas
you may have. We applaud the recent petition to Alder Olson and believe that
if enough neighbors speak up about the way in which Kipp's operations affect
them, Kipp will begin to take the action required to protect this neighborhood.
As the mayor of Madison, Sue Bauman should also be held accountable for the
environmental assault this neighborhood has endured for almost a decade;
Section 28.04(17) of the Madison General Ordinance protects all residents
against activities which may be potential hazards or nuisances.
Kipp is presently operating under an application field. EPA guidelines require
that all of Kipp's emissions be considered before receiving an operating
permit. A public hearing is also required.
It would also be useful for DNR and the City to hear the public's views on
Kipp's pollution at the time of the public hearing on Kipp's permit.
Please call DNR's Southern District, Air Management office, for information
or email us at
[email protected]
NEIGHBORHOODS FOR A HEALTHY ENVIRONMENT
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