Skip directly to search Skip directly to A to Z list Skip directly to site content




The Wisconsin Department of Health and Family Services (DHFS) was asked about the potentialhuman health concerns related to the proposed rezoning and redevelopment of the former MeritChemical property. Groundwater at the property has low levels of contamination, but it is not ahealth hazard because no one is drinking affected groundwater. Very low levels of cleaningchemicals from past commercial activities may remain in the building, but are not an apparenthealth hazard.

A thorough cleaning and painting of surfaces should effectively address any existing residualcleaning chemicals. Any higher concentrations that might be inside of blocked drains are probablynot a health concern, but may be adversely impacting the environment. There are information gapsabout the specific commercial activities prior to 1984, and DHFS recommends a more thoroughreview of past records, such as an ASTM Phase I investigation. Interior and exterior paint should betested 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, WalworthCounty, contacted the Wisconsin Department of Health and Family Services (DHFS). Theconsultant raised human health questions related to the former Merit Chemical property (here afterreferred to as "the property") and the proposed rezoning and redevelopment of the property fromindustrial to mixed use, including residential. The property is located at 165 Park Avenue, inSharon, Wisconsin. The property is on the outskirts of the village, and is bordered to the south by arail line and vacant wooded lot, to the east by vacant fields, and to the west and north by a lowdensity residential neighborhood.

Before 1959, the property was a dairy. In 1959, dairy operations ceased, and the facility wasconverted to a business that commercially repackaged and sold cleaning and disinfecting chemicalsfor use by dairies. In 1984, the business changed owners, but continued to sell the same commercialproducts. A recent Merit Chemical product line brochure (unspecified date) from the DNR filesdescribes the following "sanitation chemicals" sold by the company: 1) alkaline powders, 2) alkalineliquids, 3) chlorinated alkaline powders, and 4) other cleaning materials. No otheragricultural-related chemicals (e.g. pesticides, fertilizers) were included in the product list.

Groundwater at the property has slightly elevated concentrations of contaminants (Table 1). Thiscontamination appears to be mainly from petroleum-related chemicals that originated from leakingunderground storage tanks on the property. Environmental investigations indicate that groundwatercontamination is very localized and no nearby drinking water wells are affected or threatened. A1997 petroleum cleanup action at the property has been followed by a decrease in the levels ofalmost all contaminants in groundwater. This action removed over 700 cubic yards of affected soilsand five storage tanks (four used for petroleum products and one used for alcohols). In a recentletter to DNR, an environmental consultant reported that groundwater contamination "is decreasingor stable" and recommended the case be "closed with a groundwater use restriction." (1) While thiscleanup action focused on contamination from petroleum-related compounds, the prior groundwaterinvestigations also discovered contamination in one well (MW-3) from an assortment of chlorinatedhydrocarbons, 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










Carbon Tetrachloride













































Vinyl Chloride





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 acursory walk-through inside the building and did not observe any obvious conditions inside thatsuggested contamination from the past industrial processes that posed a health concern. They didobserve peeling paint on walls and standing water in many rooms, particularly those with a leakingroof. 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 ownerstated these drums were in the building when he purchased it, and he found them to be empty andclean. 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 healthhazard. Any planned remediation of local groundwater contamination should not affect humanhealth 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 onegroundwater monitoring well (MW-3) was from "a chemical reaction between free chlorine from thefloor drains and petroleum hydrocarbons."(2) However, DHFS believes that only the trihalogenatedmethanes found in water samples from the monitoring well were created by such an interaction. Theappearance of trihalogenated methanes is common in drinking water wells after chlorine bleach isused to destroy bacteria infestations. It is more likely that the chlorinated ethanes and ethenes foundin this single monitoring well came from the improper disposal of waste solvents previously used atthe facility.

The contractor reported that when constructing MW-3, they unintentionally drilled through a tilepipe that apparently serviced one or more drains from the former Merit Chemical facility. Theysuggested that these chlorinated compounds originated from the pipe. The chlorinated ethanes andethenes found in this well are common commercial solvents that are manufactured by sophisticatedindustrial chemical processes. These chlorinated solvents tend to be persistent in the environmentand are not likely to be created in the environment, under stable conditions, from the simple mixingof chlorine and petroleum products.

Sometimes very high levels of volatile organic compounds (VOCs) in shallow groundwater canrelease 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 airconditions are extremely unlikely inside the building.

Given the wide assortment of items stored in the building, the age and varying conditions of thestructure, poor lighting and room conditions, time constraints of the cursory inspection, and otherissues, DHFS staff could not carefully and thoroughly inspect every portion of the building forpossible chemical staining or odors. Therefore, the cursory inspection was unlikely to revealevidence of contamination by other substances that are unrelated to the reported, past industrialprocesses. Given the absence of any indoor sampling data, DHFS staff were only able to evaluatethe building based on visual observations and odors. The chlorine odor in one room was evidentlyfrom residues of chlorine-based cleaning chemicals that remained in the drum and dissolved in thewater. Residues of such chemicals under these conditions are not a health concern. Most peoplenotice odors of some chlorine-based chemicals at extremely low levels, much lower thanconcentrations that can result in adverse health effects.

Waste chemicals handled at the property may have been poured into floor drains and be found atelevated concentrations where these drains were blocked. Standing water observed in certain roomsthat had floor drains suggests that these drains were blocked. The chlorinated VOCs and chlorine inone groundwater monitoring well (MW-3) were associated with drain pipe that was encounteredwhen 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 andhe plans to continue this practice. Blocking these drains could reduce the likelihood that peoplecould 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 previouslypoured down the drains. However, such contaminants in closed floor drains are unlikely to be acurrent human health concern. The presence of chlorinated solvents in the monitoring well suggestssuch residues may also remain behind in the building. The cleaning chemicals sold by MeritChemical are easily diluted and are not persistent in the environment. However, DHFS would beconcerned if people had regular, direct contact with full strength concentrations of the chemicalproducts sold by the former Merit Chemical.

Residues of chemicals previously handled in the former Merit Chemical building may remainbehind. Residual concentrations of the above listed chemicals that were distributed by the formerMerit Chemical are unlikely to be a health concern. Unless more persistent chemicals exist inside ofthe building, such as pesticides, a thorough cleaning and then painting of all surfaces shouldeffectively 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 ofproducts distributed by the former Merit Chemical that was in the consultant reports and the DNRfiles. Furthermore, the available information is limited to commercial activities between 1984 and1994. DHFS was unable to obtain reports, product lists, or other information of materials andchemicals used, stored, or distributed by the facility between 1959 and 1984. While DHFS has noinformation 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 amore thorough review of past records such as an ASTM Phase I investigation, to verify currentanecdotal 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 ofstructures at the Merit Chemical property. When DHFS staff walked through the building with theowner, they did notice peeling paint in a number of rooms. The owner reported that he had nottested walls for lead. DHFS recommended to the owner that he test all painted surfaces in eachroom 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. DHFSalso recognizes there are many health concerns and questions related to the residentialredevelopment of a former industrial chemical facility. DHFS considered potential child exposuresand health issues when assessing and inspecting this property. As a result, DHFS concluded thatlead based-paint at this property can pose a significant health risk to any children who come onto theproperty and recommended that all painted surfaces be screened for lead. Children who are exposedto 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.


  1. Groundwater contamination at the former Merit Chemical property is not a public healthhazard. Future remediation of groundwater contamination should not affect human healthissues inside the building, as well as redevelopment decisions for the property.

  2. Very low levels of chemicals may remain inside the building, but residual concentrations of the chemicals distributed by the former Merit Chemical are not an apparent public health hazard. The thorough cleaning and painting of surfaces should effectively address any existing residual, non-persistent chemicals.

  3. Elevated chemical concentrations may be found inside sealed pipes that service floor drains, but such contamination is unlikely to be a public health concern. However, suchcontamination may reach and adversely impact the environment.

  4. There are information gaps about commercial activities prior to 1984, and a more thorough review of past records, using ASTM Phase I investigation procedures, should be considered before rezoning and redeveloping the property, particularly for residential uses.

  5. Interior and exterior wall paints throughout the facility should be tested for lead. If found, lead-based paint should be properly removed and disposed. Any other building safety issues should be addressed by complying with building and zoning requirements.


  1. DHFS provided these findings to the Sharon Village Board and will provide additionalpublic health technical assistance when requested. DHFS recognizes that the Sharon VillageBoard might make future decisions on the Merit Chemical property that have public healthimplications, yet not contact or request assistance from either DHFS or the WalworthCounty Health Department. DHFS is relying on the Sharon Village Board to follow up withstate or local public health agencies when such decisions are made and technical assistance is needed.

  2. DHFS will continue to coordinate with the Walworth County Health Department on public health questions and concerns related to the former Merit Chemical property.


  1. BT2, Inc. Correspondence to W. Ebersol, DNR. Madison, WI: BT2. September 11, 2001.

  2. Stiles Environmental, Inc. Site Investigation Report and Additional Work Plan for Merit Chemical. Lake Mills, Wisconsin: SEI. May 24, 1996.


Henry Nehls-Lowe, MPH
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 theWisconsin Department of Health and Family Services under a cooperative agreement with theAgency 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

Table of Contents The U.S. Government's Official Web PortalDepartment of Health and Human Services
Agency for Toxic Substances and Disease Registry, 4770 Buford Hwy NE, Atlanta, GA 30341
Contact CDC: 800-232-4636 / TTY: 888-232-6348

A-Z Index

  1. A
  2. B
  3. C
  4. D
  5. E
  6. F
  7. G
  8. H
  9. I
  10. J
  11. K
  12. L
  13. M
  14. N
  15. O
  16. P
  17. Q
  18. R
  19. S
  20. T
  21. U
  22. V
  23. W
  24. X
  25. Y
  26. Z
  27. #