HEALTH CONSULTATION
FORMER MERIT CHEMICAL PROPERTY
VILLAGE OF SHARON, WALWORTH COUNTY, WISCONSIN
The Wisconsin Department of Health and Family Services (DHFS) was asked about the potential human health concerns related to the proposed rezoning and redevelopment of the former Merit Chemical property. Groundwater at the property has low levels of contamination, but it is not a health hazard because no one is drinking affected groundwater. Very low levels of cleaning chemicals from past commercial activities may remain in the building, but are not an apparent health hazard.
A thorough cleaning and painting of surfaces should effectively address any existing residual cleaning chemicals. Any higher concentrations that might be inside of blocked drains are probably not a health concern, but may be adversely impacting the environment. There are information gaps about the specific commercial activities prior to 1984, and DHFS recommends a more thorough review of past records, such as an ASTM Phase I investigation. Interior and exterior paint should be tested for lead. If found, lead-based paint should be removed and disposed. Other building safety issues should be addressed by complying with current building and zoning requirements.
In August 2001, a zoning and building inspection consultant for the Village of Sharon, Walworth County, contacted the Wisconsin Department of Health and Family Services (DHFS). The consultant raised human health questions related to the former Merit Chemical property (here after referred to as "the property") and the proposed rezoning and redevelopment of the property from industrial to mixed use, including residential. The property is located at 165 Park Avenue, in Sharon, Wisconsin. The property is on the outskirts of the village, and is bordered to the south by a rail line and vacant wooded lot, to the east by vacant fields, and to the west and north by a low density residential neighborhood.
Before 1959, the property was a dairy. In 1959, dairy operations ceased, and the facility was converted to a business that commercially repackaged and sold cleaning and disinfecting chemicals for use by dairies. In 1984, the business changed owners, but continued to sell the same commercial products. A recent Merit Chemical product line brochure (unspecified date) from the DNR files describes the following "sanitation chemicals" sold by the company: 1) alkaline powders, 2) alkaline liquids, 3) chlorinated alkaline powders, and 4) other cleaning materials. No other agricultural-related chemicals (e.g. pesticides, fertilizers) were included in the product list.
Groundwater at the property has slightly elevated concentrations of contaminants (Table 1). This contamination appears to be mainly from petroleum-related chemicals that originated from leaking underground storage tanks on the property. Environmental investigations indicate that groundwater contamination is very localized and no nearby drinking water wells are affected or threatened. A 1997 petroleum cleanup action at the property has been followed by a decrease in the levels of almost all contaminants in groundwater. This action removed over 700 cubic yards of affected soils and five storage tanks (four used for petroleum products and one used for alcohols). In a recent letter to DNR, an environmental consultant reported that groundwater contamination "is decreasing or stable" and recommended the case be "closed with a groundwater use restriction." (1) While this cleanup action focused on contamination from petroleum-related compounds, the prior groundwater investigations also discovered contamination in one well (MW-3) from an assortment of chlorinated hydrocarbons, including chlorinated ethanes, ethenes, and trihalogenated methanes. Groundwater and soil samples were not tested for semi-volatile organic compounds nor pesticides.
Table 1: Groundwater Contaminants
Merit Chemical Property
Village of Sharon, Walworth Co., Wisconsin, 1994
All Concentrations in micrograms per liter
|
Chemical |
Highest Level Detected |
Lowest Level Detected |
Frequency of Detection |
Wisconsin Groundwater Enforcement Standard |
| Benzene |
680.0*
|
-
|
1/3 |
5.0
|
| MTBE |
330.0*
|
-
|
1/3 |
60.0
|
| Carbon Tetrachloride |
72.0*
|
-
|
1/3 |
5.0
|
| Chloroform |
4,500.0*
|
-
|
1/3 |
6.0
|
| 1,2-Dibromomethane |
7.3*
|
-
|
1/3 |
0.05
|
| 1,1-Dichloroethane |
12.0*
|
-
|
1/3 |
7.0
|
| 1,2-Dichloroethane |
9.9*
|
12.0*
|
2/3 |
5.0
|
| 1,1,1-Trichloroethane |
17.0
|
-
|
1/3 |
200.0
|
| 1,1,2-Trichloroethane |
9.4*
|
-
|
1/3 |
0.6
|
| Trichloroethane |
390.0*
|
-
|
1/3 |
5.0
|
| Tetrachloroethene |
12.0*
|
-
|
1/3 |
5.0
|
| Vinyl Chloride |
5.8*
|
-
|
1/3 |
0.2
|
Note: * - Exceeds Wisconsin Public Health Groundwater
Quality Enforcement Std (NR140)
Source: Stiles Environmental, Inc. Site Investigation
Report and Additional Work Plan for Merit Chemical. Lake Mills, Wisconsin: SEI.
May 24, 1996.
On August 20, 2001, DHFS staff visited the property with the current owner. They conducted a cursory walk-through inside the building and did not observe any obvious conditions inside that suggested contamination from the past industrial processes that posed a health concern. They did observe peeling paint on walls and standing water in many rooms, particularly those with a leaking roof. One room had a very slight chlorine-related odor and blue plastic basins laying on the floor, which the owner reported cutting in half to catch rainwater leaking through the roof. The owner stated these drums were in the building when he purchased it, and he found them to be empty and clean. The owner reported that chemicals sold by Merit Chemical were packed in these drums, which customers returned when emptied. The owner also reported that returned drums were cleaned and refurbished for reuse by the former owner of Merit Chemical.
Groundwater contamination at the former Merit Chemical property does not pose a public health hazard. Any planned remediation of local groundwater contamination should not affect human health issues related to the proposed redevelopment of the property or to the inside of the building. An environmental contractor concluded that chlorinated hydrocarbons detected in samples from one groundwater monitoring well (MW-3) was from "a chemical reaction between free chlorine from the floor drains and petroleum hydrocarbons."(2) However, DHFS believes that only the trihalogenated methanes found in water samples from the monitoring well were created by such an interaction. The appearance of trihalogenated methanes is common in drinking water wells after chlorine bleach is used to destroy bacteria infestations. It is more likely that the chlorinated ethanes and ethenes found in this single monitoring well came from the improper disposal of waste solvents previously used at the facility.
The contractor reported that when constructing MW-3, they unintentionally drilled through a tile pipe that apparently serviced one or more drains from the former Merit Chemical facility. They suggested that these chlorinated compounds originated from the pipe. The chlorinated ethanes and ethenes found in this well are common commercial solvents that are manufactured by sophisticated industrial chemical processes. These chlorinated solvents tend to be persistent in the environment and are not likely to be created in the environment, under stable conditions, from the simple mixing of chlorine and petroleum products.
Sometimes very high levels of volatile organic compounds (VOCs) in shallow groundwater can release vapors that can migrate inside buildings and create unsafe breathing conditions. However, the VOC levels in groundwater near the property are relatively low; therefore, such indoor air conditions are extremely unlikely inside the building.
Given the wide assortment of items stored in the building, the age and varying conditions of the structure, poor lighting and room conditions, time constraints of the cursory inspection, and other issues, DHFS staff could not carefully and thoroughly inspect every portion of the building for possible chemical staining or odors. Therefore, the cursory inspection was unlikely to reveal evidence of contamination by other substances that are unrelated to the reported, past industrial processes. Given the absence of any indoor sampling data, DHFS staff were only able to evaluate the building based on visual observations and odors. The chlorine odor in one room was evidently from residues of chlorine-based cleaning chemicals that remained in the drum and dissolved in the water. Residues of such chemicals under these conditions are not a health concern. Most people notice odors of some chlorine-based chemicals at extremely low levels, much lower than concentrations that can result in adverse health effects.
Waste chemicals handled at the property may have been poured into floor drains and be found at elevated concentrations where these drains were blocked. Standing water observed in certain rooms that had floor drains suggests that these drains were blocked. The chlorinated VOCs and chlorine in one groundwater monitoring well (MW-3) were associated with drain pipe that was encountered when the well was drilled and indicates that waste chemicals were disposed into floor drains.
The property owner said that he closed floor drains in many rooms by filling them with concrete and he plans to continue this practice. Blocking these drains could reduce the likelihood that people could come in contact with such contamination, particularly if flooding were to occur. However, such blocking may not prevent the dispersal into the environment of chemicals that were previously poured down the drains. However, such contaminants in closed floor drains are unlikely to be a current human health concern. The presence of chlorinated solvents in the monitoring well suggests such residues may also remain behind in the building. The cleaning chemicals sold by Merit Chemical are easily diluted and are not persistent in the environment. However, DHFS would be concerned if people had regular, direct contact with full strength concentrations of the chemical products sold by the former Merit Chemical.
Residues of chemicals previously handled in the former Merit Chemical building may remain behind. Residual concentrations of the above listed chemicals that were distributed by the former Merit Chemical are unlikely to be a health concern. Unless more persistent chemicals exist inside of the building, such as pesticides, a thorough cleaning and then painting of all surfaces should effectively address any existing residuals that are related to past commercial products.
Assumptions by DHFS about residual contamination inside the building are based on the list of products distributed by the former Merit Chemical that was in the consultant reports and the DNR files. Furthermore, the available information is limited to commercial activities between 1984 and 1994. DHFS was unable to obtain reports, product lists, or other information of materials and chemicals used, stored, or distributed by the facility between 1959 and 1984. While DHFS has no information which suggests that chemicals other than those listed above were received or distributed, it is plausible that other chemicals of a much more persistent and toxic nature, such as pesticides, were handled by or passed through the facility. Given this information gap, DHFS recommends a more thorough review of past records such as an ASTM Phase I investigation, to verify current anecdotal information and shed further light on the handling of other chemicals at the property.
Given the age of the buildings, lead-based paint may be on the exterior and interior walls of structures at the Merit Chemical property. When DHFS staff walked through the building with the owner, they did notice peeling paint in a number of rooms. The owner reported that he had not tested walls for lead. DHFS recommended to the owner that he test all painted surfaces in each room for lead. If elevated lead is detected, then paint should be properly mitigated and disposed. Other safety issues may also exist inside the building (such as structural or electrical code issues); however, this extends beyond the expertise of DHFS staff and should be addressed by compliance with local and state building and zoning requirements.
DHFS recognizes that children are especially sensitive to exposure to some contaminants. DHFS also recognizes there are many health concerns and questions related to the residential redevelopment of a former industrial chemical facility. DHFS considered potential child exposures and health issues when assessing and inspecting this property. As a result, DHFS concluded that lead based-paint at this property can pose a significant health risk to any children who come onto the property and recommended that all painted surfaces be screened for lead. Children who are exposed to lead are at risk of having blood lead levels exceeding 10 micrograms per deciliter (µg/dL). Children who have blood lead levels greater than 10 µg/dL might have learning and behavior problems.
CONCLUSIONS AND RECOMMENDATIONS
Henry Nehls-Lowe, MPH
Epidemiologist
Bureau of Environmental Health
Division of Public Health
Wisconsin Department of Health & Family Services
This public health consultation on the Former Merit Chemical Property was prepared by the Wisconsin Department of Health and Family Services under a cooperative agreement with the Agency for Toxic Substances and Disease Registry (ATSDR). It is in accordance with approved methodology and procedures existing at the time the public health consultation was begun.
Gail D. Godfrey
Technical Project Officer, SPS, SSAB, DHAC
The Division of Health Assessment and Consultation, ATSDR, has reviewed this public health consultation and concurs with the findings.
Lisa C. Hayes
for Chief, SSAB, DHAC, ATSDR