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The Wisconsin Department of Natural Resources requested that the Wisconsin Department of Health (DNR) and Family Services (DHFS) evaluate the public health implications of the environmental sampling data from the Ace Manufacturing property. These samples were collected in July 1997 as part of the Phase II site assessment of DNR's Brownfield Environmental Assessment Program. Some surface soils samples had elevated levels of metals, but these are not a health concern. Other substances detected in surface soils also are not a health concern. Metal shavings protruding from the ground may pose a physical hazard and should be removed. Groundwater beneath the property has some contamination, but there are no known nearby drinking water wells. Unknown liquids in containers stored in the basement should be identified and properly disposed.


The Ace Manufacturing property is at 204 Wisconsin Avenue, Weyauwega, Waupaca County, and is located along the Weyauwega mill pond (NW¼, Sec 4, T21N, R13E). Between 1920 and 1950, the property was used by a dental tool manufacturing business. Between 1950 and 1991, a screw machine parts manufacturing business used the facility. Currently, a furniture restoration business rents the newer, eastern portion of the building. This business not only provides the city with revenue, but their presence probably discourages unauthorized entries to the building. The western portion of the building is an older brick structure. Many manufacturing materials remain inside this older portion of the building, but heavy machinery has been removed.

During a May 8, 1997, site visit, representatives of DNR and DHFS observed discolored soil beneath the dilapidated loading dock along the western side of the building. The bricks beneath one northern-facing window were stained with a dark substance, possibly remains of an oily liquid that was disposed out the window. We saw potential physical hazards outside the building. These include the dilapidated loading dock on the western side of the building and materials on the loading dock along the north side of the building. Nearby residents store some of their belongings on what appears to be the property. In December 1994, Donald Wick , a sanitarian with the Waupaca County Department of Health and Human Services, investigated the inside of the building for asbestos. Asbestos was found only in insulation of the door panel of a small safe. Mr. Wick recommended that a licensed asbestos contractor be retained to properly remove and dispose of this material.


Surface Soils

Fifteen surface soils were tested for inorganics, volatile organic compounds (VOCs), semi-volatile organic compounds (SVOCs), pesticides, and polychlorinated biphenyls (PCBs). All VOCs, SVOCs, pesticides, and PCBs were either not detected or were at low concentrations that are safe and do not pose a health concern.

The only inorganic substances found at elevated concentrations were lead and chromium. Lead was detected at 636 mg/kg in SS11 and 436 mg/kg in SS10. A third soil sample had 217 mg/kg of lead, and the rest of the soil samples had lead levels below 61 mg/kg. While the two highest concentrations are above EPA's soil screening guidance level of 400 mg/kg, since young children do not apparently come in regular contact with these soils and the concentrations are not representative of overall lead soil concentrations at the site, these soils do not pose a health concern.

Only the surface soil sample from SS11 showed an elevated total chromium concentration, at 24,915 mg/kg (all other chromium concentrations were less than 11 mg/kg). Assuming that most or all of the chromium present in this discrete sample was in a trivalent state, this would not pose a health concern. A portion of this chromium is plausibly present in a hexavalent form. Hexavalent chromium is more toxic than its trivalent state. However, hexavalent chromium is also less stable and tends to be reduced, over time, to a trivalent state. Therefore, an appreciable portion of this total chromium is not likely in a hexavalent form and, consequently, does not represent a health concern. Despite this, given the widespread metal shavings that we observed on the bank near where sample SS11 was collected, DHFS recommends removing this waste material because these shavings might pose a physical hazard to someone walking or climbing in this area.

Tentatively Identified Compounds (TICs)

A number of semi-volatile TICs were found in several soil samples. The highest TIC concentrations were saturated fatty acids and included: hexadecanoic acid, octadecanoic acid, tetradecanoic acid, and other unspecified organic acids. These fatty acids have a number of commercial uses, including cutting and lubicating oils, as well as additives for comestics and foods. For some soil samples, several fatty acids TICs were previously mis-identified by EPA chemists as nitro-polyaromatic compounds, but this was recently corrected. Fatty acids in these surface soils are not a health concern.

A number of unspecified PAHs (polycyclic aromatic hydrocarbons) were also identified among the TICs at concentrations as estimated to be as high as 18 mg/kg. These unspecified PAHs probably do not pose a health concern. The unspecified PAHs are not included in the targeted analysis because they are not known to be particularly toxic or harmful to human health. The most potent PAH is benzo(a)pyrene, which is a probable human carcinogen. Six other PAHs are also designated as probable human carcinogens, but their toxicities are one to three orders-of-magnitude lower than benzo(a)pyrene. Assuming that the toxicities of the unspecified PAHs are also similarly lower than that of benzo(a)pyrene, DHFS does not believe it is likely that these are a health concern.


In 1997, groundwater samples from the five monitoring wells were also tested for inorganics, VOCs, SVOCs, PAHs, pesticides, and PCBs. Concentrations of methylene chloride was found in two water samples from MW-2 and MW-4 (at 5 and 155 µg/L, respectively). Those levels matched or exceeded its Wisconsin Groundwater Quality Enforcement Standard of 5 µg/L. Chloromethane was detected in MW-4 at 5 µg/L, which is above its Enforcement Standard of 3 µg/L. All other substances detected in this round of sampling were well below their respective Enforcement Standards. Groundwater samples collected in 1995 contained concentrations of benzene and trichloroethylene from one location above their respective Enforcement Standards. The 1997 round of groundwater sampling did not find benzene and trichloroethylene above an Enforcement Standard. The 1997 and 1995 groundwater sampling results suggests this groundwater contamination may be localized. There are no known private drinking water wells near the property.

Other Issues

When EPA visited the site in December 1997, they used a photo ionization detector (PID), which reported elevated VOCs in the basement of the building. Keith Lesniak, EPA Region-V, informed DHFS that when this measurement was taken, they also noticed a "sewer gas" like odor. Mr. Lesniak observed that the floor in the basement was dry (as opposed to the standing water throughout the basement during our May 8, 1997, visit). The DHFS representative conferred on this issue with Don Wick, of the Waupaca County Health Department, and jointly speculated that sewer gas entered the basement through an unused, dry "P-trap" and was the source of the odor. Sewer gas can provide a false VOC reading on a PID.

During the May 8, 1997, site visit, the DHFS representative saw a number of unmarked cans and small drums in the basement. The labeled containers with liquids were removed but some unlabeled containers with liquids remain. The contents of these containers should be identified and properly disposed.


  1. Surface soils in certain locations were found to have elevated levels of metals. However, metals in surface soils at the Ace Manufacturing property were not at concentrations that pose a health hazard. Despite this, metal shavings from these locations might pose a physical hazard.

  2. VOCs, SVOCs, PAHs, pesticides, and PCBs detected in surface soils do not pose a health concern. Laboratory analysis of surface soils found a number of tentatively identified compounds, but none pose a health concern.

  3. Groundwater beneath certain portions of the property is contaminated, but there are no known nearby drinking water wells.

  4. There are unknown liquids in unmarked containers stored in the basement.


  1. Metal shavings protruding from the ground should be removed.

  2. Test the unknown liquids in the unmarked containers and dispose of them properly.


  1. Mid-State Associates, Inc. Phase I Environmental Site Assessment for Ace Manufacturing Company, 204 W. Wisconsin Avenue, Weyauwega, Wisconsin. Prepared for Waupaca County, Waupaca, Wisconsin. Project 212194, ESA. Baraboo, WI: Mid-State Associates. October 1994.

  2. Waupaca County Department of Health and Human Services. Memorandum from D. Wick to J. Goeser, Waupaca County Treasurer. Environmental Site Assessment: Ace Manufacturing, Weyauwega, Wisconsin. December 8, 1994.

  3. Mid-State Associates, Inc. Phase II Environmental Site Assessment for Ace Manufacturing Company, 204 W. Wisconsin Avenue, Weyauwega, Wisconsin. Prepared for Waupaca County, Waupaca, Wisconsin. Project 212312,ESA. Baraboo, WI: Mid-State Associates. November 1995.

  4. Wisconsin Department of Health and Family Services. Memorandum to Department of Natural Resources, from H. Nehls-Lowe to T. Sturm. "Public Health Issues for the Ace Manufacturing Property, Weyauwega, Waupaca County." May 22, 1997.

  5. Wisconsin Department of Natural Resources. Scope of Work for Additional Site Soil Sampling: Ace Manufacturing. August 1, 1997.

  6. Wisconsin Department of Natural Resources. Internal memorandum to T. Sturm from C. Khazae. "Former Ace Manufacturing Data Summary". December 10, 1997.

  7. Ecology and Environment, Inc. Site Assessment Report for Ace Manufacturing Site, Weyauwega, Waupaca County, Wisconsin. TDD: S05-9712-015. Prepared for the U.S. Environmental Protection Agency Region V Office, Emergency Response Branch. Chicago, IL: E and E. March 16, 1998.


Henry Nehls-Lowe, MPH
Health Hazard Evaluation Unit
Bureau of Public Health
Division of Health
Wisconsin Department of Health & Family Services

ATSDR Senior Regional Representative

Louise Fabinski
Regional Services
Region V
Office of the Assistant Administrator


This Ace Manufacturing public health consultation 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 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.

Richard Gillig

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

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