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The federal "Superfund" law requires the U. S. Agency for Toxic Substances and Disease Registry (ATSDR) to conduct a public health assessment of all toxic waste sites that the U. S. Environmental Protection Agency (EPA) proposes for inclusion on the list of the nation's most hazardous waste sites. This list formally is called the National Priorities List. The Wisconsin Division of Health (WDOH) works with ATSDR to prepare assessments. The purposes of public health assessments are:

1. To evaluate whether contaminants at the site pose a current or future threat to public health;

2. To recommend any steps needed to protect the public from exposure to toxic substances, and

3. To recommend long-term health studies, when appropriate.

For each assessment health professionals look at the types of contamination present, including each chemical's toxicity; ability to move through soil, water or air; persistence in the environment; and ability to accumulate in the food chain. They look at ways that people could be exposed to contaminants such as eating, breathing, or touching the chemicals. Investigators check relevant health records when appropriate to see if there may be increases in health effects related to public exposure to contaminants from the site. Finally, an assessment identifies the health hazards that a site may pose and recommends action to protect public health now and in the future.

The WDOH and ATSDR conduct a "preliminary" health assessment after EPA proposes to include a site on the National Priorities List. The preliminary assessment relies on whatever data are available at the time. It also identifies sampling to be addressed by the remedial investigation conducted as part of the Superfund clean-up of the site. The WDOH, in cooperation with ATSDR, completed the Preliminary Health Assessment of the Kohler Company Landfill in 1989. Now that the remedial investigation of this site is completed, WDOH conducted a "full" health assessment using the more complete set of data that the investigation provided. Local, state and federal agencies and the local community commented on this assessment in the summer of 1993. This final edition of the assessment incorporates those comments. A list of the comments and our response is included at the end of this document (Appendix C).


The Kohler Company Landfill is a 40-acre disposal site for the Kohler Company, a manufacturer of bathroom fixtures and small engines. The site lies adjacent to the floodplain of the Sheboygan River. Past disposal practices included pouring liquid slurries containing solvents, hydraulic oils, and metals into pits on the site and filling the remainder with foundry sand and other solid and hazardous wastes. Waste and groundwater in and under the site contain polychlorinated biphenyls (PCBs) and high levels of various volatile organic compounds and metals. Sediments in the Sheboygan River and the adjacent floodplain contain PCBs for which there is a known upstream source associated with the Sheboygan River and Harbor Superfund site. PCBs in the river have entered the food chain and are present in fish which may be caught and consumed. PCBs in the adjacent Sheboygan River and Harbor Superfund site present a public health hazard to those who consume fish caught from the Sheboygan River. A separate health assessment for the river and harbor site is available. Exposure to site-related compounds in groundwater at the Kohler Company Landfill poses an indeterminate future public health hazard. Contaminants in groundwater at the site exist at levels of health concern, but it is not clear whether people are likely to be exposed to contaminants in groundwater. Private water supply wells could be affected if contaminants in groundwater flow beneath the Sheboygan River to nearby wells. Contaminants in landfill waste, leachate, and groundwater currently pose no apparent public health hazard because volatile organic compounds discharging in groundwater to the Sheboygan River are not expected to be at levels likely to affect the health of people who swim or fish in the river.

Efforts to find any frequent consumers of Sheboygan River fish should be continued. If frequent consumers are found, they should be evaluated for a program to relate fish consumption levels with body burdens of fish-borne contaminants. Efforts to extend awareness of fish consumption advisories should be extended, especially to sport fish consumers who can not read English. Groundwater on the side of the Sheboygan River opposite from the landfill should continue to be monitored for chemicals of concern at detection limits as close as possible to Wisconsin groundwater standards.


A. Site Description and History

The Kohler Company Landfill, Sheboygan County, Wisconsin, is an active landfill used by the Kohler Company, a manufacturer of bathroom fixtures and small engines, for waste disposal. The landfill is constructed on approximately 40 acres adjacent to the floodplain of the Sheboygan River. The site borders the Sheboygan River floodplain on the east, County Highway A on the south and west, and County Highway PP on the north (see maps in Appendix A). Kohler Company began using the landfill in the early 1950s primarily for disposal of foundry wastes including sand, dust collector waste, slag, clay, and other wastes not considered hazardous under the Resource Conservation and Recovery Act (RCRA). The landfill continues to accept RCRA non-hazardous wastes for disposal.

The landfill consists of a series of cells constructed between the mid-1950s and the mid-1970s (Appendix A-2). Some of these cells were filled with hydraulic oils, solvents, paint wastes, enamel powder (containing lead and cadmium), lint from brass polishing, chrome plating sludges, and other wastes characterized as hazardous under RCRA. Other cells were used as settling ponds for waste slurries. Beginning in 1975, hazardous liquid wastes were no longer accepted at the site. Since 1980, hazardous solid wastes have not been accepted at the landfill. Other areas of the landfill (outside the cells) were used for disposal of foundry sand and related wastes.

In the mid-1970s, the Wisconsin Department of Natural Resources began the "Sheboygan River Basin Assessment" which included analysis of potential sources of surface and groundwater contamination in the area. In 1979, as part of this assessment, surface water runoff from the Kohler Company Landfill was analyzed for heavy metals, nutrients and biological and chemical oxygen demand (1). Copper and zinc concentrations were found to exceed their respective EPA surface water quality criteria values.

After the EPA placed the Kohler site on the federal "Superfund" list (the National Priorities List) in 1984, the Kohler Company performed a "Remedial Investigation/Feasibility Study" (RI/FS), conducted in three phases from 1986 through 1991. The objectives of the RI were to determine the extent of hazardous contaminant release from the landfill and, if necessary, to identify potential action that could be taken at the site to mitigate any hazards. The RI was completed in September 1991 (2). The Wisconsin Division of Health (WDOH) completed the preliminary health assessment on the Kohler site in April, 1989 (3).

On March 30, 1992, the U.S. Environmental Protection Agency (EPA) signed a Record of Decision for controlling sources of contamination at the site. The initial cleanup plan calls for installation of a final cover system, altered slopes and fill volumes, revised operations plans, a limited leachate collection system, zoning and deed restrictions, and access restrictions. Operations at the landfill tentatively are planned to cease sometime in 1995 or 1996. Groundwater cleanup plans will be addressed in a second operable unit (4). In November and December 1992, the Kohler Company prepared two additional documents incorporating the results of the RI, an environmental contamination assessment (5) and a plan of operation modification (6).

The area in the vicinity of the site is generally flat, except near the river where slopes extend down to the river. The Sheboygan River, which empties into Lake Michigan 4.2 miles downstream of the site, borders the site on the south and east. Surface runoff from the site drains directly into the Sheboygan River. The east half of landfill was constructed in the historical floodplain of the Sheboygan River. The land surface was approximately 40 feet below that of the surrounding upland area. Material was disposed of such that much of the floodplain was filled up to 40 feet above its original elevation. The current 100-year floodplain is at the eastern edge of the waste-filled area.

Three aquifers underlie the Kohler Landfill site: an unconsolidated glacial till aquifer with a depth of 20-100 feet; a Silurian-age dolomite aquifer extending from 100 to 790 feet below the surface; and a deep sandstone aquifer 1160 feet below the surface. Separating the Silurian-age dolomite and the sandstone are 165 feet of shale and 200 feet of Galena-Platteville dolomite. A 20 foot silty clay layer within the unconsolidated material separates the upper till and lower till units. Near the Sheboygan River, the clay layer is eroded. The water table lies a few feet below ground surface at the top of the site in a few locations. In general, the water table is 10 to 35 below ground surface and slopes down to the river. All of the geological units including the fill material are at least partially saturated (2, p.10).

B. Site Visit

On October 15, 1991, Kenneth Bro and Mary Young from the WDOH visited the Kohler Company Landfill along with representatives of the Wisconsin Department of Natural Resources (WDNR), the EPA, and the Kohler Company. The central portion of the landfill was being used for disposal of cracked ceramic material and foundry sand. Sludge consisting of wet foundry sand and ceramic dust was being poured into trenches on the east side of the landfill. The sides of the landfill are well vegetated and steeply sloped to the Sheboygan River on the east and to County Highway A to the west.

Site visitors observed leachate seeps on the east side of the landfill at the bottom of the steep slope. Leachate was flowing across the access road and toward the Sheboygan River. The Kohler Company representative showed the site visit team the area where solvents were thought to have been disposed of in the past. Grasses are now growing in the area and no trenches or pits remain. A fence is present along County Highways PP and A. However, access to the site from the river is unrestricted. A Kohler Company representative noted that the site is posted and patrolled regularly by Kohler Company security guards.

Kenneth Bro and two WDNR representatives viewed the site from the perimeter on May 19, 1994. Red soil from a nearby construction site was being stockpiled at the top of the site. Otherwise, the site appeared the same as it did in 1991.

C. Demographics, Land Use, and Natural Resource Use

The Kohler Company Landfill is within the corporate limits of the Village of Kohler (population: 1,817) approximately 3/4 mile east of the nearest home within the village (see map in Appendix A). Land adjacent to the site on the east, south and west is part of the undeveloped 800-acre Kohler Wildlife Reserve. The northern border of the site is marked by County Highway PP. The site is approximately 2000 feet east of the Kohler Company, which employs 6,400 people. The site is within four miles of the cities of Sheboygan and Sheboygan Falls (pop. 49,676 and 5,823, respectively). Two homes are located within one-half mile south of the site, across the Sheboygan River. In 1980, 1,518 individuals lived in the Kohler ZIP code, 99.5% of whom were Caucasian (7). The mean household income is well above the national average.

Thirty-eight wells are located within one mile of the site. No site-related contaminants have been detected in these wells to date. Three wells that formerly supplied drinking water for the Village of Kohler are approximately 2,000 feet southwest of the site across a bend in the Sheboygan River (see map in Appendix A). These wells are 413-450 feet deep. One well supplying a private residence is approximately 1,500 feet south of the site across the river and is 177 feet deep. Another well supplying non-potable water for the Kohler Company is approximately 1000 feet west of the site and is 1,177 feet deep. Eleven wells supplying private residences along Taylor Drive and Union Avenue are across the river 2,000 feet southeast of the site. Twenty-two wells supplying the Kohler Company and private residences are between one-half and one mile of the site. At least eight of these twenty-two wells are used for non-potable water (2, pp.58-59, 126, Fig.35, Table 7). Drinking water for the Village of Kohler now comes from Lake Michigan.

The Sheboygan River and harbor are used for fishing. In addition, some individuals may consume waterfowl obtained in the area (8).

D. Health Outcome Data

State data available to study the health effects of this site include the Cancer Reporting System (CRS), the Hospital Discharge Database and birth certificates. The CRS lists the name and address of everyone in the state who has contracted cancer since 1978. The Hospital Discharge Database lists the zip code of the patient's residence and an encrypted case identifier for all hospital discharges since 1989. Birth certificates are also available for studies of congenital anomolies, a potential health effect resulting from exposure to polychlorinated biphenyls (PCBs). No birth defects monitoring program is currently available in Wisconsin.


A number of local citizen groups have been formed to address general environmental concerns in the Sheboygan River watershed, including the Izaak Walton League (9). Recent meetings of this group have focused attention on WDOH and WDNR warnings not to consume certain species of fish from the Sheboygan River due to unhealthy PCB concentrations. Other groups involved with general Sheboygan River issues include the Citizens Advisory Committee for the Sheboygan Area of Concern (involved in remedial action under the Great Lakes Water Quality Agreement of the United States and Canada), the Sheboygan Water Quality Task Force, and the Sheboygan County Interfaith Organization's Environmental Concerns Committee.

There has been active community concern about the environmental quality of the Sheboygan River and Harbor for a number of years. A major part of this concern relates to PCBs and heavy metals in river sediments and their impact on the river ecosystem. Many groups would like to see the river system cleaned up sufficiently to reduce the levels of PCBs in river fish and wildlife, not only so that game species can be eaten, but also so that contamination will not harm the ecosystem itself. When the remedial investigation showed that volatile organic compounds (VOCs) in groundwater under the landfill are likely discharging to the river, community members expressed concern about the effect of the VOCs on aquatic life. There is some concern about the potential health effects the VOCs may have on people who wade or fish from the river downstream of the landfill.

A public meeting held on October 16, 1991, at which EPA representatives described proposed remedial action options being considered, was attended by sixteen community members and representatives from WDOH and WDNR. The main questions asked by community members at the meeting concerned how the remedial action will control further contaminants into the Sheboygan River.

In April and May 1992 the Division of Health, in cooperation with local health departments and several other agencies, held six meetings with Southeast Asian residents of the Sheboygan and Manitowoc areas. The meetings were dedicated to providing non-English speaking residents with health information about contamination in area fish. Two hundred forty residents attended. These residents expressed health concerns similar to those expressed by other citizens but also expressed concerns reflecting the language barrier to their comprehension of the health advisories. While significant effort has gone to promoting awareness of the health advisory among English and Spanish speaking people, few efforts have been made to inform Southeast Asian people. Several participants at the meetings said that they were unaware of the advisories.

The public comment release of the health assessment for the Kohler Company Landfill was distributed to the community for public comment from May 28 through July 30, 1993. The findings of the assessment and its availability for comment were announced in a local newspaper at the beginning of the comment period. A summary of the public comments and of how they were addressed in this health assessment appears in Appendix C.

The Sheboygan Water Quality Task Force held a meeting on July 20, 1993 was attended by about thirty people, including representatives from WDOH and WDNR. Members of the task force expressed concern that the public comment release assessment understated the level of community concern about the site. At the meeting the WDOH agreed to revise the discussion of community concerns and to extend the comment period so that community members could submit any futher concerns. In general citizens expressed frustration that cleanup of the landfill is occurring too slowly and that too much contamination is continuing to flow into the river. At another meeting on May 19, 1994 concerning the remedial action plan for the Sheboygan River, community members again expressed concern about contamination leaching from the landfill to the river and about the adequacy of the EPA's plan for source control.

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