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The privately owned Fadrowski Drum Disposal Site is located on approximately 20 acres in theCity of Franklin, Milwaukee County, Wisconsin. The site was operated as a landfill forconstruction debris and fill dirt from 1970 to 1982. In 1983, drums uncovered on the property werefound to contain lead, chromium, DDT, and petroleum distillates. One drum exploded when heavyconstruction equipment hit it. Because of the explosive hazard and possible contamination ofgroundwater, the Wisconsin Department of Natural Resources (DNR) proposed the site for inclusionon the National Priorities List in 1984. The Wisconsin Division of Health (DOH) published apreliminary health assessment for this site in June 1989.

The area of the site is experiencing rapid urbanization and commercialization. The City of OakCreek is across 27th Street east of the site, and 36,000 people live within three miles of the site. Theclosest private residential well is within 300 feet of the site, and nine others are within 4,000 feet ofthe site. Prior to the 1993-94 remedial action, people were concerned about the quality of theirprivate drinking water supply, and about the health of children who play on the property and swimin the site pond.

In the past, people could have been be exposed through ingestion or skin contact to low levels ofpolycyclic aromatic hydrocarbons (PAHs), considered to be probable human carcinogens, in surfacesoil and sediments on the site. Repeated contact, however, to these levels are expected to show noapparent increased risk of getting cancer.

A 1986, a DOH cancer investigation was conducted in response to citizen concern aboutenvironmental contamination from other hazardous sites in the area. The investigation showed noincrease in cancer rates for the City of Franklin, nor was there an increased rate of site-specificcancers that might be related to radium or landfill wastes. Since the study included the entire City ofFranklin, the results are relevant to this site as well. The DOH continues to address public healthconcerns through ongoing educational activities.

During the development and finalization of this health assessment, the site's public health threat hasbeen reduced from the status of a public health hazard to no apparent public health hazard. Remedial actions have eliminated current exposures, physical hazards, and the likelihood of futureexposures. Past exposures to site contaminants pose no apparent public health hazard because theexposures were not at levels which would be expected to cause adverse health effects.

The DOH in cooperation with ATSDR will reevaluate the site if new information shows the publicis exposed to contaminants at levels of concern. At that time, the DOH would solicit public healthconcerns through the Franklin City Health Department and provide continuing education asinformation was available. DOH will offer opportunities to practicing primary care physicians inthe Franklin area when this public health assessment is released. Additional health studies are notnecessary at this time since there is no evidence of exposure that would result in environmentally related illness.


Site Description and History

The Fadrowski Drum Disposal Site occupies approximately 20 acres at 6865 South 27th Street inthe City of Franklin, Milwaukee County, Wisconsin (see Appendix A, Figure one). From 1970until 1982 the site was operated as an unregulated, unlicensed landfill, accepting construction debrisand fill dirt. Sludge, rubbish, and containerized liquids were illegally discarded at the site (1, p. 2-2). In 1981, a citizen informed the Wisconsin Department of Natural Resources (DNR) that barrelsof hazardous wastes were buried on the site. The DNR performed an inspection but failed to findevidence of such waste. DNR records indicated leachate seeps on the site between 1981 and 1984(2, p. 1). In 1983, the property was sold to the Menard Corporation. While excavating for fill dirtin the field north of the dump area, barrels of hazardous wastes were exposed (4, p. 1). One of thebarrels exploded when heavy construction equipment hit it, spilling liquids onto soil (5, p. 1). TheDNR tested the contents of the drums, after which the contractors reburied the drums under at leasttwo feet of clay (15. p 5). In 1988, investigators uncovered other leaking, corroded and crusheddrums (1, p. 5-5).

The site currently is not being used for any purpose. The U. S. Environmental Protection Agency (EPA) proposed the site for placement on the National Priorities List (NPL) in 1984, and placed iton the list in 1986 (1, table 1). When the EPA places a site on this list, the site qualifies for clean-upunder the federal "Superfund" program (10).

The Wisconsin Division of Health (DOH) in cooperation with the ATSDR completed a preliminaryhealth assessment of the site in June 1989. That report was based on data that were available priorto the remedial investigation required by the Superfund program. Warzyn EngineeringIncorporated, conducted a remedial investigation of the site in 1988 and 1989 for Acme Printing InkCompany, a potentially responsible party. The EPA selected a plan for clean up of the site in June1991 that included locating buried drums, removing drums and associated characteristicallyhazardous wastes, off-site recycling or treatment and disposal of drummed wastes, treating anddisposing of contaminated soil, constructing a leachate collection trench (16, p.33), long-termmonitoring of groundwater and surface water, constructing an approved cap over the disposal area,fencing the site, and implementing deed restrictions (16, p. 2).

Site remediation is ongoing. As of March 1994, the site has been fenced, physical hazards removed,the on-site pond has been drained and backfilled, and buried drums and associated contaminationhave been excavated and contained. Removal from the site of approximately 170 drums isscheduled to begin prior to the summer of 1994. During the 1994 construction season, constructiondebris will be consolidated into a single disposal area and capped, and the leachate collection trench will be constructed.

Glaciers created this area of gently sloping moraines (1, p. 3-1). Two aquifers reside beneath thesite; a bedrock aquifer flowing east toward Lake Michigan and a shallow aquifer, whose water tableis three to ten feet below the surface of the site, flowing very slowly through clay soils downwardand toward the west (2, p. 1; 1, p. 7-3). The downward movement is stronger than the westwardmovement within the clay layer (13, p. 1).

Soil at the site is a silty, clay till (Ozaukee-Morley-Mequon). Well drillers refer to the soil as red orblue clay. The red clay layer is near the surface with blue clay extending down approximately 80feet. An undifferentiated sand, gravel, silt, and clay layer lies between the blue clay and Ordoviciandolomite bedrock. Dolomite is approximately 175 feet below the surface (1, pp. 3-2, 5-7). Mostresidential and municipal wells are screened in the bedrock aquifer; none are screened in clay.

Site Visit

A site visit was made on August 18, 1988, by staff of the DOH and DNR. At that time there wasconsiderable surface erosion of the site, both on the northern edge of the mounded landfill and in thefield between the landfill area and the north boundary. Runoff was generally westward. Some ofthe erosion channels were 2-3 feet deep. During the site visit evidence was found of recent dumpingof an unidentified sludge on the surface of the mounded landfill area. Cattails and other vegetationnear to and west of the pond appeared to be stressed (9, p. 2).

The Fadrowski disposal area, where dumping occurred, was mounded. A relatively flat field waseast and north of the mound within the property boundaries. The mound was steeply sloped towarda pond that resulted from digging operations on the west side of the property. The pond was adischarge area for the upper aquifer (1, p. 5-13). A creek flows from north to south at the far westend of the property. It eventually empties into the Root River about 2 miles southeast of the site (3,p. 6). Overflow from the pond contributed to a wet, low-lying field that eventually drains into thecreek. A storm sewer/ditch was situated in the north field, running from east to west; the outfallbeing 300 feet east of the creek. Rainwater runoff from 27th Street and a retail store parking lot emptied into the storm sewer (see figure 2).

Representatives from the DOH, DNR, and EPA visited the Fadrowski site in July 1989. Theproperty was covered with gravelly soil and tall weeds. Soil was heavily eroded in places. Thecondition of the site had not changed since the 1988 visit. There was no evidence that children playon the site. The property is accessible from all sides, but access was easiest from a parking lot to thenorth.

Representatives from DOH and DNR visited the site on January 23, 1991 and observed snowmobiletracks north of the fill area running from the north boundary down to the creek. Metal scraps, piecesof concrete, and asphalt debris were protruding from the fill area. A 55-gallon drum, whichappeared to be empty, was lying on its side in the fill area. South of the site property, activelandfilling of construction debris was taking place.

DOH staff visited the site on August 7, 1992. There were "no trespassing" signs posted at the northedge of the property. Survey markers were placed on the site. Piles of construction debris in parts ofthe disposal area looked like they were recently-dumped. Metal, concrete, and other constructionmaterials littered the disposal area, creating physical hazards. Food wrappers and other trash aroundthe pond indicated that people have trespassed on the property and perhaps used the pond forrecreational activities. Staff observed no evidence of remedial action on the property.

On August 31, 1993, DOH staff attended a meeting with the community members and sitecontractors who discussed the remedial action. Following the meeting, people visited the site anddiscussed logistics of the cleanup. One person expressed concern about air monitoring during thecleanup and was told monitoring would be done. DOH staff contacted the EPA in November 1993and again in March 1994. Remedial actions are underway as described previously.

Demographics, Land Use, and Natural Resources Use

The Fadrowski Site, located in a mixed residential and commercial suburb of Milwaukee, isexperiencing considerable growth. Rawson Avenue, one-quarter mile south, is a developedresidential and commercial area. A subdivision of more than 100 homes is approximately one-halfmile southwest of the site property. Two schools are within a mile south of the site: the closestbeing St. James school, 2,000 feet away. There are approximately fifty homes within 1,500 feet ofthe site. The closest home is within 100 feet of the property.

The population within 3 miles of the site is 32,000 (6, 1). A few children played and swam on thesite. At one time, a play fort was set up on the south side of the Fadrowski site (1, p. 8-13). Approximately 18,000 people within a three-mile radius of the site depend on groundwater fordrinking water. The other 14,000 are tied into municipal water systems that use water from LakeMichigan (6, p. 1). It is reasonable to expect continued residential development in the area of thesite and expanded municipal water service.

Health Outcome Data

Death certificates listing the cause of death, census information, and the relatively new CancerReporting System may be helpful in future surveillance activities. The Cancer Reporting Systemprovides information about newly diagnosed cases of cancer and is accessed by zip code. Data is available since 1980.


People living west of the site, beyond the creek, expressed concerns about the continued quality oftheir private well water. The EPA tested one private residential wells to the west of the site at therequest of the owner. Residential wells west of the site are drilled into the bedrock aquifer that flowstoward the east. No contamination was found in wells at the west end of the site and additionaltesting of residential wells west of the site is not needed. One person who swam with his children inthe site pond was concerned about long-term health effects resulting from possible exposure tocontamination. Citizens expressed concern about long-term health effects that could result from pastexposures to contamination at the site. People living near the site have complained of paint and solvent odors (8, p. 8).

In October, 1986 the Franklin City Health Department requested assistance in investigating apossible cancer cluster in a subdivision called Security Acres. The community was concerned that ahigher than normal rate of cancer was caused by radium in drinking water and other contaminantsfrom nearby landfills. The results of that investigation are discussed in the "Health Outcome DataEvaluation" section of this report (12).

No additional community health concerns were expressed during an August 31, 1993 meeting withsome members of the community. As of March 1994, no new community health concerns have been reported to the DOH, EPA, or local health officials.


This section of the public health assessment describes environmental sampling previously conductedat the site and identifies contaminants of concern found in specific environmental media. Theselected contaminants are evaluated in subsequent sections of the health assessment to determinewhether exposure to them has public health significance.

DOH selects contaminants for further evaluation based upon the following factors:

  1. concentrations of contaminants on and off the site;

  2. sampling locations and frequency, field data quality, and laboratory data quality;

  3. comparison of on-site and off-site concentrations with health assessment comparisonvalues for non-carcinogenic and carcinogenic endpoints; and

  4. community health concerns.

It is emphasized that identification of a contaminant of concern in this section does not mean thatexposure to it will cause adverse health effects. As mentioned above, the potential for adverse healtheffects resulting from exposure to contaminants of concern will be evaluated in subsequent sectionsof the health assessment.

Comparison values for health assessment are contaminant concentrations in specific media (soil,water, and air). When a chemical exceeds a comparison value the health assessor will focus his/herattention on that chemical as being more likely to cause health effects. The data tables may includethe following acronyms:

  • EMEG = Environmental Media Evaluation Guides

  • CREG = Cancer Risk Evaluation Guide

  • RMEG = Reference Dose Media Evaluation Guide

  • IARC = International Agency for Research on Cancer

  • MCL = Maximum Contaminant Level

  • ND = not detected

  • ppb = parts per billion

  • ppm = parts per million

EMEGs are media-specific screening values developed by ATSDR for use in selectingenvironmental contaminants of potential health concern. EMEGs are based on non-carcinogenichealth endpoints and do not consider potential carcinogenic effects. RMEGs are developed likeEMEGs but are based on EPA's reference dose when ATSDR does not have a MRL (Minimal RiskLevel). CREGs are estimated comparison concentrations for specific chemicals based on one excesscancer in a million persons exposed over a lifetime. CREGs are calculated from EPA's cancer slopefactors. MCLs represent contaminant concentrations that EPA deems protective of public health(considering the availability and economics of water treatment technology) over a lifetime (70years) at an exposure rate of 2 liters water per day. MCLs are regulatory concentrations, while theother comparison values are not.

On-site Contamination

The DNR tested the contents of drums uncovered in 1983 and found high levels of metals, DDT,and petroleum distillates (Table 1). Electromagnetic surveys detected buried metal objects in thefield north and east of the dump area and within the site property boundaries (see figure 3). Some ofthe areas may contain metal debris other than drums of waste. Twelve drums were uncovered inlocations identified by the electromagnetic survey (1, fig 6 & 10). Their contents were not sampled,but soil around the drums was. Their leaking and corroded condition was noted, and the drums werecovered over (1, p. 5-7).

Table 1.

Chemicals of Concern in Drum Wastes (July 1983)
Content Description Contaminant Level (ppm)
green sludge lead 32,700
  chromium 6,890
black sludge lead 1,200
sediment/soil lead 700
paint lead 900
paint lead 400
oily water DDT 1,450

petroleum distillates in all samples - no levels reported
ppm = parts per million
Source: 11, p.2

The remedial investigation sampled construction waste, sub-soil, surface soil, sediments around theproperty and at the pond, surface water in the pond and creek, air quality, and groundwater on andaround the site (Tables 2 & 3). Elevated levels of metals, volatile organic compounds (VOCs), andpolycyclic aromatic hydrocarbons (PAHs) were found in subsurface soils (1, table 6-3). The drumsuncovered in 1981 were not sampled for PAHs.

Nine test pits were dug in the disposal area and the contents were described as construction debrisincluding bricks, metal scrap, metal pipe, concrete, asphalt, wood, tar paper and brush (1, p. 5-5). Eight samples revealed levels of carcinogenic PAHs which would be of health concern if peoplewere exposed to disturbed subsurface-soil.

Groundwater and surface water were tested for VOCs, metals, PAHs and pesticides. One sample ofgroundwater, in the shallow clay aquifer, showed mercury at a level that slightly exceeded theWisconsin Groundwater Enforcement Standard of 2.0 micrograms per liter (g/l). Later testingindicated no mercury (13, p.2). No residents in the areas obtain their drinking water from theshallow clay aquifer.

Table 2.

Chemicals of Concern in Water(µg/l)
    Surface Water Comparison Value
  Groundwater Upstream Downstream Pond water
Contaminant   (one sample) (one sample) (one sample)
Lead ND 5 5 ND 151
Chromium 10-13 ND ND ND 1002
Toluene ND 3 ND ND 10002
Mercury ND-2.3 ND 0.2 ND NA

NA = Not Available
µg/l = micrograms per liter
Source: 1, Appendix D, Table 6-6, Appendix I
1 = EPA Action Level
2 = MCL
3 = CREG

Table 3.

Chemicals of Concern in Soils and Sediments (mg/kg)
Contaminant Surface soil (12/88) Upstream sediment (3/90) Downstream sediment (3/90) Pond sediment (12/88) Subsurface soil (12/88-1/89) Comparison value
Lead 108 34 69 37 136 NA
Chromium 18 35 21 30 29 3002
DDT ND ND ND ND 0.28 23
Toluene 140J ND ND ND 1.8 10,0004
PAHs1           NA

NA = Not Available
J = estimated
mg/kg = milligrams per kilogram
Source: 1, Appendix D
1 = see Table 4
2 = RMEG-child, Cr VI
3 = CREG
4 = RMEG-child

Surface soils on the steep slope from the west side of the dump area have elevated levels of lead,PAHs and toluene. Only two surface soil samples near the waste disposal area were taken. As such,it is difficult to generalize about the condition of surface soil elsewhere on the site. The pondsediments were not significantly affected by the disposal area. Twenty-five soil borings were done,with twenty-eight samples taken at depths from 2 to 15 feet (1, p. 5-6). PAHs were present and aredescribed in Table #4. Metals were above background in many samples but not at levels of healthconcern.

Both surface water and sediments of the stream show increases in some metals downstream from thesite, but not at levels of health concern. The contractor for the remedial investigation monitored airquality over freshly exposed fill material and found values less than or equal to 10 parts per million for volatile organic compounds (1, p. 8-13).

310-330 ND-18,000

Table 4.

Ranges of Individual Carcinogenic PAH Contamination (µg/kg)
  Sediment (1988) Surface soil (1990) Test pit (1988) Borings (1988-89) Comparison value
Benzo(a)anthracene ND-290 570-890 ND-17,000 ND-2,700 NA
Chrysene 100-350 570-840 ND-15,000 ND-2,100 31
Benzo(b)fluoranthene ND-250 1,100-1,500 ND-290 ND-1,700 NA
Benzo(k)fluoranthene 510-530 1,100-1,500 ND-21,000 ND-2,500 NA
Benzo(a)pyrene 650-880 ND-3,000 0.12
Indeno(1,2,3-cd)pyrene 97-240 290-380 ND-9,500 ND-2,200 NA
Total PAHs
450-1,000 4,280-5,990 590-65,000 450-10.420 NA
Total PAHs
330-900 2,260-3,520 690-114,000 500-14,600 NA

NA = Not Available
ND = not detected
g/kg = micrograms per kilogram
1 = IARC
2 = CREG
Source: 1, Appendix D, Table 6-3, Table 8-1

Off-site Contamination

Contaminated soil particles appear to have washed from the disposal area into the wetlands and thestream southwest of the property. The off-site area of highest contamination to the south hasrecently been covered with many feet of fill soil and is no longer accessible to the public. Fourresidential wells located in the deep aquifer to the east were sampled in April 1991 and are notaffected by site contaminants (14, p. 3). Monitoring wells at the east and west end of the propertycontain only low levels of substances associated with construction debris (15, Appendix A). For thatreason, off-site monitoring wells are not necessary at this time.

A review of the Toxic Chemical Release Inventory showed no releases for the Fadrowski site, norwere there other releases reported within one mile of the Superfund site (17).

Quality Assurance and Quality Control

In preparing this document the DOH assumes that adequate quality assurance and quality controlmeasures were followed during chain of custody activities, laboratory procedures, and data reportingduring the remedial investigation. The ability to make valid conclusions and recommendation isdependant, to some extent, on the amount and quality of data provided by the agencies andengineering firms involved. The remedial investigation followed a quality assurance project planapproved by the EPA.

Physical and Other Hazards

The site is now fenced and site hazards are being eliminated. Steep incline have been graded. Thepond has been drained and filled. Buried drums have been safely removed and packed for off-site disposal.


In general, people may be exposed to chemicals in a number of ways. The pathways analysis looksat five elements in two broad categories Environmental Pathways - the source of the chemicals,where they are found (soil, water, air), the ways the chemicals may move from the site; and HumanExposure Pathways - ways by which people could be exposed to the chemicals (touch, ingestion,inhalation), and the groups of people that might be exposed.

Exposure pathways are referred to as completed, potential, or eliminated. A completed pathway isone where there is a clear indication that people were exposed to chemicals from the site and whenthere is sufficient information to evaluate that exposure. All five of the elements must exist for acompleted pathway to exist. This includes exposures that occurred in the past and exposures that arecurrently happening.

A potential pathway exists when there is insufficient information to link a chemical to a known levelof exposure among an identified population. A potential pathway may refer to a past, present, orfuture exposure. An exposure pathway can be eliminated if one of the five elements is missing andwill never be present.

Environmental Pathways

Groundwater: Because most contaminants are buried in permeable fill, contaminants can seepreadily into groundwater. However, the flow of groundwater through the clay underlying the wasteis very slow (roughly 10-6 centimeters per second), and this clay has kept contamination from gettinginto the deeper bedrock aquifer (1, p. 4-6). The water table of the shallow clay aquifer slopes westto the pond and wetlands. Water that infiltrates contaminated fill and leaking barrels may dischargeto the pond, wetlands, and stream on the western side of the site. DNR investigators observeddiscolored seeps in the slope east of the pond. Because there are moderate downward gradients inthe shallow aquifer, groundwater could eventually carry contaminants to the underlying dolomiteaquifer. Metals in the waste will tend to adsorb to the clay particles, as will the less soluble organiccompounds making migration to the bedrock aquifer less likely. If more soluble contaminants arepresent in the buried drums in sufficient quantity, these compounds could reach underlying aquifers.

There is no confirmed indication of groundwater contamination away from the source (1, p. 7-3). One private residential well within 300 feet of the disposal area and nine other private wells within4,000 feet have been tested (see figure 4). All but one of the private wells sampled are screened intothe dolomite aquifer. The one exception is a well cased into sand and gravel 150 feet below groundsurface (1, appendix I-2).

Surface Water and Sediments: The remedial action will control possible surface water runoff thatcould have picked up contaminated surface soil or carried leachate. Leachate will be directed, as aresult of the remedial action, to a trench system. If leachate samples are within discharge limits, theliquid will be released to the municipal sewerage system.

Soil: The current remedial action will include a landfill cap to cover soil contaminated with PAHs. Drums have been removed and so the threat of additional soil and groundwater contamination fromtheir contents.

Air: Air is not expected to carry significant amounts of contaminants from the site under presentconditions. Surface soil contained very low levels of toluene (estimated at 140 g/kg) (1, AppendixD). That soil will be covered with a landfill cap in the summer of 1994. Other contaminantsidentified in the surface soil are not volatile. Because the site will be re-vegetated after the remedialaction, wind will blow relatively little dust from the soil. Air monitoring will be conducted duringthe remedial action.

Human Exposure Pathways

There are approximately 50 residences within 1,500 feet south and east of the property. Residentsof those households are the population most likely to trespass or use the site for recreationalactivities. The site is now off-limits to children who might play on the site. Workers who arecurrently engaged in remediation activities are the persons most likely to be exposed to sitecontamination. There is a school and subdivision approximately one-quarter mile away. Fromcomments at meetings, as many as 10 children were reported to have played frequently at the site(several times in one summer).

Ingestion: People who swam in the pond may have ingested low levels of contamination containedin the surface water or suspended from sediments. As noted previously, no contamination has beenfound at levels of health concern in surface water. Contaminated soil could have been ingestedthrough normal hand to mouth activities.

Dermal Contact: Dermal contact to chemical contamination in soil or surface water is no longerexpected since the site is fenced and will be capped soon. In the past, people trespassed on theproperty and could have been exposed to contaminated soil or leachate as they touched soil particles. Children are reported to have played in soil and rode dirt bikes across the field. Workers involved inthe remediation of the site could be exposed to contaminants as wastes are moved, covered, or inother ways contacted. PAHs absorb through skin, adding to the dose received through inhalationand incidental ingestion of contaminated soil particles. DOH staff were assured that site workerswill be adequately protected during remedial activities.

Inhalation: People who live near the site could inhale contaminated dust particles as the soil isdisturbed during remedial activities. Site contractors will monitor air quality throughout the remedial activities.


Toxicological Evaluation

The people who are currently most likely to receive the highest exposures to site chemicals areworkers who are remediating the site. The following PAHs were found in many soil and sedimentsamples and could be absorbed through dermal contact, accidental ingestion, or inhalation ofcontaminated dust particles: benzo(a)anthracene, chrysene, benzo(b)fluoranthene,benzo(k)fluoranthene, benzo(a)pyrene, indeno(1,2,3-cd)pyrene, and dibenz(a,h)anthracene (1,Appendix D, Table 6-3, Table 8-1). All of these compounds cause cancer in laboratory animals. The EPA considers the evidence sufficient to classify the chemicals as "probable humancarcinogens." In the past, children who frequented the site 40 times per year for 8 years could haveingested carcinogenic PAHs at an average daily lifetime dose of 10-7 mg/kg/day (Appendix B). Children who frequented the site 40 days per year for 8 years might have absorbed PAHs throughskin contact for a daily lifetime dose of 10-6 mg/kg/day (Appendix B). Because concentrations ofPAHs in surface soils were relatively low, even if children played at the site frequently there wouldbe no apparent increase in cancer risk from such exposure (maximum estimated additional lifetimecancer risk of 3 x 10-5. See Appendix B).

Lead, chromium, and toluene found in surface soil at levels that are not expected to result in adversehealth effects. DDT, a persistent pesticide and carcinogen, was found earlier in barrel contents butnot in samples of soil nor surface water.

The DOH expects to see no adverse health conditions from exposure to contaminants on the site. The risk of cancer increases with the number of contacts with soil and the amount of soil ingested. Children would be expected to ingest more soil than an adult through common hand-to-mouthactivities; and children were the most likely people to play on the site regularly in the past. Workerswho uncover high levels of contamination while digging on the site might receive doses ofsubstances that would result in adverse health effects. The data are not sufficient to anticipate thetype or severity of illness that could result from exposure to the buried contaminants. Surface soilcould become contaminated as buried drums are removed from the site and their contents seep to theground surface. Since carcinogenic chemicals were present in original samples of barrel contents,workers who touch contaminated soil could have an increased risk of cancer. The extent of that riskis difficult to determine based on the limited data that are currently available. Contractors assuredDOH staff that workers will be adequately protected.

Health Outcome Data Evaluation

"Health outcome data" is a phrase referring to records of death and disease. When there is evidencethat people near a site have been exposed to contaminants at levels that could lead to an increase inrates of death or disease, a review of health outcome data may be appropriate. A review also may beappropriate if there are reports of unusual clusters of diseases near a site. There is no evidence ofsignificant public exposure to chemicals from the landfill.

In October, 1986, the Wisconsin Division of Health investigated a report of a cancer cluster thatmight be linked to radium or landfill contamination in drinking water at the Security Acressubdivision in Franklin. This request for an investigation was not related to this Superfundinvestigation; however, the results apply to the entire community and to landfill contaminants ingeneral. The DOH conducted a disease-cluster investigation. An age-adjusted comparison wasmade to the nation, Wisconsin, and Milwaukee County for all cancer sites for three time periods: 1960-69, 1970-79, and 1980-85. The investigation concluded that there are no significantly highrates for individual cancer sites, nor rates of specific cancer with an environmental exposure etiologywithin the City of Franklin. The division recommended that the local health department monitorsentinel cancer deaths within the City of Franklin (12). If a significant route of human exposurewere identified for the Fadrowski Drum Site, additional site-specific surveillance may be appropriate.

Community Health Concerns Evaluation

The following are responses to the community health concerns gathered as part of the public healthassessment process:

Concern: People living west of the site, beyond the creek, expressed concerns about the qualityof their private well water.

Response: The EPA tested one private residential wells to the west of the site at the owner'srequest. Residential wells west of the site are drilled into the bedrock aquifer that flows toward theeast. No contamination was found in monitoring wells at the west end of the site and additionaltesting private wells farther west is not necessary at this time.

Concern: One person who swam with his children in the site pond was concerned about long-term health effects resulting from possible exposure to contamination.

Response: Past exposures to the low levels of contamination in the site pond water andsediments are expected to cause adverse health effects. The pond has been drained and filled withsoil.

Concern: Citizens expressed concern about long-term health effects that could result from pastexposures to contamination at the site.

Response: The likelihood of long-term adverse health effects depends on the number andduration of exposures, in addition to personal behavioral characteristics such as hand to mouthhabits. Based on the data reviewed and using conservative assumptions about exposure doses,adverse health effects are not expected from past exposures to site contaminants.

Concern: People living near the site have complained of paint and solvent odors (8, p.8).

Response: The contractor for the remedial investigation monitored air quality over freshlyexposed fill material and found values less than or equal to 10 parts per million for volatile organiccompounds. One sample of groundwater showed mercury levels of 2.3 micrograms per liter (g/L)which is above the Wisconsin Groundwater Enforcement Standard of 2 g/l. Later testing indicatedno mercury. As long as wastes are undisturbed, the levels of volatile organic compounds in airwould not cause adverse health effects. Air monitoring is being conducted as part of the remedialaction.

Concern: The residents in Security Acres subdivision were concerned that a higher thannormal rate of cancer was caused by radium in drinking water and other contaminants from nearbylandfills.

Response: The results of that investigation are discussed in the "Health Outcome DataEvaluation" section of this report (12). They show no increase in the number of cancers normally expected in the area.


During the development and finalization of this health assessment, the site's public health threat hasbeen reduced from the status of a public health hazard to no apparent public health hazard. Remedial actions have eliminated current exposures, physical hazards, and the likelihood of futureexposures. Past exposures to site contaminants pose no apparent public health hazard because theexposures were not at levels which would be likely to cause adverse health effects.

The people who most likely received the highest exposures to site chemicals included children whomight have regularly played on the property; people who regularly swam in the pond; and workerswho are performing the remedial action on the property. Low levels of carcinogenic PAHs werefound in many soil and sediment samples and could have been absorbed through dermal contact,accidental ingestion, or inhalation of contaminated dust particles. Because concentrations of PAHsin surface soils are relatively low, even if children played at the site frequently there would be noapparent increase in cancer risk from such exposure. Levels of lead, chromium, and toluene foundin surface soil are not expected to result in health effects. DDT was found earlier in barrel contentsbut not in samples of material that people could have been exposed to.

The threat of groundwater contamination has been eliminated through the removal of the burieddrums and associated highly contaminated soil and waste. Low level contamination andconstruction wastes is being consolidated and capped. Leachate from this capped area will becaptured by a leachate collection trench. There is no indication of current groundwatercontamination away from the source, however, groundwater will be tested in monitoring wells and anearby private well.

In October, 1986, the DOH conducted a disease-cluster investigation. The investigation concludedthat the cancer rates within the City of Franklin for individual cancer sites were not significantlyhigh. None of the cancers known to have environmental exposure etiology were significantly high.

Prior to remediation, community members expressed concern over the safety of their private wellwater, possible long-term health effects from past on-site activities, and a perceived higher thannormal cancer rate in the community of Security Acres. These concerns are addressed in the Community Health Concerns Evaluation section.


The number of recommendations have been reduced since the public comment release of this healthassessment due to the completed and ongoing remedial actions. Outstanding recommendations include:

  1. Selected private residential wells and monitoring wells should be tested at reasonable intervals to confirm that the dolomite aquifer remains uncontaminated.

    1. Regular testing of monitoring wells should be done to detect any further migration of site-related contaminants.

    2. Testing of private wells should be carried out at appropriate intervals consistent with the site characteristics to test further for possible contamination of the underlying aquifer.

  2. Workers should be adequately protected from inhalation and dermal exposure whendisturbing soil at the site. All appropriate Occupational Safety and Health Administration regulations should be observed when addressing hazardous site remediation.

  3. Surface water tests of the adjacent stream should be conducted in connection with the remediation process and thereafter as necessary to maintain safe water quality.

Health Activities Recommendations

The DOH and ATSDR's Health Activities Recommendation Panel evaluated the data available atthis site to decide if more action on health-related concerns is appropriate. Such action mightinclude providing community health education or carrying out more detailed studies on cases ofdisease near a site (10). There is no need for more health studies at the Fadrowski site. People mayhave come in contact with contaminants at the site. It is unlikely, however, that the low level ofexposure caused illnesses that could be documented now or in the future. The DOH and ATSDRwill look again at the need for more health studies if high levels of contamination are released whenthe site is cleaned up or if new information shows that public exposure is greater than expected. TheDOH will continue to provide health education as part of its regular activities at Superfund sites.


The recommendations provided in this health assessment relate to reduction of human exposure andperformance of health studies. The following actions either have been or will be performed to meetthe needs expressed by the recommendations of this health assessment.

The DOH in cooperation with ATSDR will:

  1. Look again at the need for more health activities if new information shows that public exposure is greater than expected;

  2. Provide continuing public health education as new information pertaining to public health issues becomes available;

  3. Continue to solicit health concerns of Franklin citizens through agency contacts with the Franklin City Health Department;

  4. Offer ongoing health professional education opportunities to practicing primary carephysicians in the Franklin area at the time when the public health assessment is released to the public.

The EPA through its 1991 Record of Decision calls for source control of groundwatercontamination. Groundwater is the environmental pathway of most concern at this site. Workerprotection is also addressed in the Record of Decision. The EPA is involved in oversight of remedial actions that have been or will be conducted:

  1. Excavation and sampling of previously identified drums and associated characteristically hazardous wastes;

  2. Construction of trenches to find, sample, and excavate additional drums and hazardous soils;

  3. Off-site recycling or treatment and disposal of drummed wastes;

  4. Treatment and disposal of contaminated soil;

  5. Construction of a landfill cover in compliance with landfill closure requirements;

  6. Imposing legal restrictions to limit land and groundwater use;

  7. Monitoring of groundwater and surface water to ensure effectiveness of remedial action and evaluate the need for future groundwater treatment;

  8. Fencing of the property; and (16, p. 2)

  9. Construction of a leachate collection trench. (16, p. 33)

  10. Workers will be protected from short-term risks by means of standard safety programs, such as use of protective equipment, monitoring, and dust control measures. (16, p. 34)


Mary Young
Public Health Educator
Section of Environmental Epidemiology and Prevention

Kenneth Bro, Ph.D.
Environmental Engineer
Section of Environmental Epidemiology and Prevention


Louise Fabinski
Regional Services
Office of the Assistant Administrator


William J. Greim
Division of Health Assessment and Consultation
Remedial Programs Branch


This Fadrowski Drum Disposal Site Public Health Assessment was prepared by the WisconsinDivision of Health under a cooperative agreement with the Agency for Toxic Substances andDisease Registry (ATSDR). It is in accordance with approved methodology and procedures existing at the time the public health assessment was begun.

William Greim
Technical Project Officer
Division of Health Assessment and Consultation (DHAC)

The Division of Health Assessment and Consultation, ATSDR, has reviewed this public health assessment, and concurs with its findings.

Robert C. Williams, P.E., DEE
Director, DHAC, ATSDR


  1. Warzyn Engineering, Inc. for the U.S. EPA, Agency Review Draft Remedial Investigation Report: for Fadrowski Drum Disposal Site, Madison, Wisconsin, June 1990.

  2. Gifford, Michael, U.S. EPA, Region V, Memo to the File: Franklin/Menard Drum Disposal Site, March 16, 1984.

  3. U.S. EPA, Site Inspection Report: Menards Drum Disposal, Chicago IL, January 1984.

  4. Hoyer, Bob, Wisconsin Division of Emergency Govt, Report to P. Jeff LaBudda: Drums on Menards Inc Property, June 28, 1983.

  5. Duchelle, E. & Trcka, F., Wisconsin DNR, Executive Summary: Menard's Drum Disposal Site, Madison WI, January 1984.

  6. U.S. EPA, Region V, Fact Sheet: Fadrowski Drum Disposal Site, Chicago IL, October 1987.

  7. Agency for Toxic Substances and Disease Registry (ATSDR), Draft Toxicological Profile for Polycyclic Aromatic Hydrocarbons, Atlanta GA, February 16, 1990.

  8. ATSDR, site summary: Fadrowski Drum Disposal (Menards), May 10, 1988.

  9. Anderson, Dennis, Wisconsin Division of Health, Health Assessment for Fadrowski Drum Disposal Site, Madison Wisconsin, June 6, 1989.

  10. Comprehensive Environmental Response and Liability Act as amended, 42 U.S. Code9604 (i).

  11. Degenhardt, David, WI State Laboratory of Hygiene, Memo to Frank Trcka re: Barrel waste samples from the Menard Const. Site, Milwaukee, Madison, WI, July 13, 1983.

  12. Wisconsin Division of Health, City of Franklin Cancer Investigation, Madison, Wisconsin, February 16, 1987.

  13. U.S. EPA, Region V, Memo re: Health Assessment from Terese Van Donsel to ATSDR, April 1991.

  14. U.S. EPA, Region V, Memo re: Residential Well Sampling Report, May 1991.

  15. U.S. EPA, Region V, Selected Remedial Alternatives for the Fadrowski Drum Disposal Site, June 1991.

  16. U.S. EPA, Region V, Fact Sheet: U.S. EPA recommends cleanup Plan, April 1991.

  17. U.S. EPA, National Library of Medicine, Toxic Chemical Release Inventory, July 1991.


Area Map
Figure 1. Area Map

Site Map
Figure 2. Site Map

Possible Drum Locations from Electromagnetic Survey
Figure 3. Possible Drum Locations from Electromagnetic Survey

Private Well Sampling Locations
Figure 4. Private Well Sampling Locations


Lifetime Cancer Risk From Human Exposure to Carcinogenic PAHs in Landfill Surface Soil


  1. Children ages 6 - 13 frequent the site two times per week in the summer (10 weeks) and once per week in the spring and fall (20 weeks), i.e., 40 days per year.

  2. Children consume 100 mg of site soil per day on site.

  3. Children get their arms and legs dirty in the summer but get only their hands dirty in the spring and fall.

  4. Soil adheres to skin at 20 g/m2.

  5. Of the two samples of surface soil taken, the one containing the higher concentration of carcinogenic PAHs is representative of PAH concentrations in surface soil on site.

  6. Fifty percent of carcinogenic PAHs applied to skin are absorbed. All PAHs desorb from soil completely.

  7. No other contaminants that were found in drums, in the past, are present in surface soils. If buried drum contents contaminate surface soil in the future, health risks could be greater than presented here.


Average lifetime daily dose of carcinogenic PAHs ingested

PAHs Soil Conc. x Soil Consumed x Consumption Frequency
=           Average Lifetime Body Weight

(6 mg PAHs/kg soil) x 100 mg soil x 10-6 kg/mg x 40 days/year x 8 years
=           70 kg body weight x 365 days/year x 70 years/lifetime

= 1 x 10-7 mg PAHs/kg body weight/day

Average daily lifetime dose of carcinogenic PAHs absorbed through skin

Soil PAHs x Soil Adherence x (Exposed Skin x Exposure Freq.) x Absorption
=           Average Lifetime Body Weight

(6 mg/kg) x (20 g/m2) x [(0.44m2 x20days)+(0.057m2 x20days)] x 8yrs x 0.5
=           70 kg body weight x 365 days/year x 70 years/lifetime x 103 g/kg

= 2.7 x 10-6 mg PAHs/kg body weight/day

Upper level estimate of additional lifetime cancer risk

= Intake of Carcinogenic PAHs x Cancer Slope Factor (oral)
= 2.8 x 10-6 mg/kg/day x 12 (mg/kg/day)-1
= 3.4 x 10-5


A public comment draft public health assessment was mailed on May 29, 1992 to 41 people and tworepositories on the Division mailing list for Fadrowski Drum Disposal Site. A media announcementwas mailed to 18 newspaper, radio, and TV stations in the Milwaukee area. Twenty-eight primarycare physicians were identified through physician licensing and sent informational letters about thehealth assessment. From that mailing only one set of comments were received and the commentswere editorial in nature. The suggested changes were made. The public comment period lasted through June 30, 1992.

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