EagleHerald/John Liesveld
In October, contractors working for Tyco Fire Products perform a scheduled change out of several large bags of Granular Activated Carbon utilized by the Ditch A filtering system. The system is designed to remove PFAS from a stream that runs through Tyco’s Fire Technology Center in Marinette. GAC is highly efficient at absorbing certain organic chemicals like PFAS making it useful for filtering PFAS from water.
EagleHerald/John Liesveld
In October, contractors working for Tyco Fire Products perform a scheduled change out of several large bags of Granular Activated Carbon utilized by the Ditch A filtering system. The system is designed to remove PFAS from a stream that runs through Tyco’s Fire Technology Center in Marinette. GAC is highly efficient at absorbing certain organic chemicals like PFAS making it useful for filtering PFAS from water.

Editor's note:  An article (Jan. 10) in the EagleHerald detailed a tour coordinated by officials from Tyco Fire Products LP. It offered municipal officials from the cities of Marinette and Peshtigo and the Town of Peshtigo an opportunity to educate themselves about the largest of two Granular Activated Carbon (GAC) filtration systems located on what is known as Ditch B. The other GAC system is located at Ditch A. The GAC systems are designed to filter PFAS (per- and polyfluoroalkyl substances) from surface water in those ditches.

MARINETTE — Ditch A and B represent two streams running though the City of Marinette that cross or parallel Tyco Fire Products LP Fire Technology Center (FTC). Ditch B runs west to east just north of the FTC and then passes through Marinette neighborhoods before emptying into the bay of Green Bay. Ditch A crosses FTC property and then runs southward toward University Drive and beyond. 

Both streams received PFAS  (per- and polyfluoroalkyl substances) contamination after years of testing firefighting foams that contained PFAS at the FTC facility (See Marinette PFAS History). 

Thursday’s tour of the Ditch B GAC system served as an act of transparency of the cleanup operations under way by Tyco and its parent company Johnson Controls Inc. in the surrounding areas. 

However, questions remain among Wisconsin Department of Natural Resources officials as well as individuals living in the contamination plume. 

DITCH A: INFLUENT VALUES

One of those questions regards Ditch A. Ditch A system operates similarly to Ditch B but at less capacity when it comes to gallons per minute (gpm) of water filtered. Ditch A handles about 150 gpm compared to 600 gpm at Ditch B. 

A very preliminary review of the almost 4,000-page semi-annual report on the operating effectiveness of the Ditch A’s filtration system raised further questions for DNR officials regarding cleanup and general operations at Tyco’s Fire Technology Center. Arcadis, a design and consultancy firm contracted by JCI/Tyco to provide environmental testing and advising, submitted the report Dec. 31. The report documents influent (surface water before PFAS filtration) and effluent (after PFAS filtration) values for Ditch A between the dates of Jan. 15 and June 26 of 2019.  

Christine Haag, WDNR Remediation and Redevelopment Program director, raised the question to the EagleHerald that asked why a report that included data collection on Ditch A that ended in June 2019, was not submitted until Dec. 31 (six months later). 

More importantly, she also pointed out that, according to the report, in March 2019 the influent values of PFOA and PFOS in the surface water of Ditch A spiked significantly. 

Between Jan. 15 and March 4, 2019, Tyco was still discharging PFAS-containing waste from their FTC  facility directly into the Marinette wastewater treatment system. During that same time, the levels of influent PFOS and PFOA in Ditch A remained relatively low.

However, after concerning high levels of PFAS were measured in Marinette’s biosolids and wastewater holding tanks, Water and Wastewater Operations Manager Warren Howard confirmed that JCI/Tyco “voluntarily” ceased discharging PFAS waste into the city’s wastewater system on March 4, 2019.  

Furthermore, after March 4, Tyco Senior Manager, Marketing Communications Jim Cox stated that the company began shipping the facility’s PFAS waste to a deep well injection facility in the state of Ohio. Deep well injection places liquid waste into geological formations deep underground where the potential for contamination of water aquifers remains extremely low.   

According to the Arcadis’ semi-annual report, a considerable jump in PFOS and PFOA occurred in samples taken March 28 at points before filtering occurred (influent) in the Ditch A. That date was just over two weeks after Tyco ceased discharging of PFAS waste into Marinette’s wastewater system. Specifically, those samples showed an increase of PFOS and PFOA surface water from 12 ppt and 19 ppt, respectively, to 350 ppt and 480 ppt, respectively. 

Then from March to June, PFAS levels continued an upward trend in Ditch A’s influent surface water. By June 26, 2019, (the last date of recorded sampling in the report) PFOS influent (pre-filtered) levels reached as high as 690 ppt while PFOA had jumped to 1,600 ppt.  

It is important to note that despite of the high influent levels in Ditch A, the effluent levels (water after PFAS is removed by the filter) contained extremely low values of PFOS and PFOA, less than 1.8 ppt for each, according to the Arcadis report. That equates to an average efficiency of over 99% for removal of both PFOS and PFOA from the influent water in Ditch A (before filtering) to the effluent water (after filtering). 

Currently, unlike the State of Michigan, no regulated standards exist in Wisconsin with regard to surface water levels of PFOS and PFOA. But according to WDNR officials, a lack of enforceable standards does not excuse the fact that a toxic substance has been detected — as recently as June — at high levels in the surface water of a stream that runs through the wooded area immediately surrounding the JCI/Tyco FTC facility. Nor does it mean the WDNR lacks any authority or other avenue of enforcement regarding toxic release of a substance by any individual or entity.

Haag pointed out the data on PFAS values in the Ditch A raise questions, as well as the potential of imposing further regulatory authority on JCI/Tyco under the Wisconsin Spill Law (state statute 292.11). 

“The data begs the question as to why the (PFAS) numbers on the influent (surface water) are increasing,” she said.

The Spill Law dictates, “a person who possesses or controls a hazardous substance or who causes the discharge of a hazardous substance” on their property or on anyone else’s property “shall notify the DNR immediately of any discharge.” 

“(Under the Spill Law) WDNR has the authority — even without set (PFAS) water quality standards — to require JCI/Tyco to take action,” Haag said. “Such action includes the investigation into the degree and extent of the contamination; taking interim actions to treat that water; and then (conducting) a response action to discontinue that discharge from the source into the ditch.”

According to WDNR hydrogeologist Dave Neste, Arcadis provided no explanation in their report as to the cause of the significant increase in influent surface water PFAS levels. Neste also serves as the remediation project manager providing oversight and guidance to Tyco and Arcadis as they continue their site investigations and cleanup efforts. 

At this point, the lack of data interpretation makes drawing any conclusions difficult for the WDNR, Neste explained.  

“(The DNR) is currently evaluating the semi-annual report to find out why (influent PFAS) concentrations increased during the six-month testing period (from January to June 2019),” Haag added. 

Wednesday, the EagleHerald further examines the Ditch B system.