MARINETTE — An updated work plan submitted by JCI/Tyco to the Wisconsin Department of Natural Resources (WDNR) on Monday: “Private well sampling work plan – land-applied biosolids,” details the testing of private drinking water wells potentially contaminated by PFAS (per- and polyfluoroalkyl substances) due to the wells’ proximity to fields that received contaminated biosolids as fertilizer. The wells designated for testing reside within a radius of 1,200 feet of 61 fields distributed throughout Marinette County and parts of Oconto County.

In November, JCI/Tyco submitted an initial plan titled, “Biosolids Landspreading – Phase I Investigation Work Plan” to the WDNR, which outlined JCI/Tyco’s investigation of only 16 fields that had received historic land application of biosolids from the City of Marinette Wastewater Treatment Plant (WWTP). However, after reviewing the plan, and based on historical records and maps of biosolids land application, officials with the WDNR informed JCI/Tyco to expand their investigation and well sampling.

The initial plan submitted in November served as a kind of survey of the original 16 fields and wells located near fields that had received biosolids, according to Dave Neste, a WDNR hydrologist and the project manager who oversees JCI/Tyco site investigations.

“(The original plan) was just to try and determine which ones had the highest probability of being impacted,” Neste said. “But the (WDNR) said ‘no,’ to that plan and said that all the wells within 1,200 feet of all 61 (not 16) fields must be sampled.”

After discussion and agreement with the WDNR, JCI/Tyco drew up the new plan and submitted it in March.

“The plan we submitted to (WDNR) for the testing of the (61) fields supersedes the November plan,” said Fraser Engerman, Director of Global Media Relations. “Although we believe it is critical to identify all potential contributors of PFAS to the biosolids, both Tyco and the WDNR agreed that understanding potential impacts to the drinking water wells in these fields is the right first step in this process.”

Documentation, maps and other information compiled by the Marinette Department of Water & Wastewater show that the city conducted a WDNR approved land-spreading of biosolids on the designated fields from 1996-2017. According to the U.S. Environmental Protection Agency (EPA), a city’s biosolids can be “used beneficially” when applied on agricultural, forest, and reclamation land. According to the JCI/Tyco work plan, land-application of biosolids can also help reduce the need for chemical fertilizers.

The work plan also states that fields located in Marinette and Oconto Counties received biosolids that originated from the holding tanks at both the Marinette and City of Peshtigo WWTPs, both of which discovered elevated amounts of PFAS between 2017 and 2018.

Historically, Tyco’s fire technology center in Marinette, a facility used for the live testing of PFAS-containing firefighting foams, legally discharged the waste runoff accumulated from those tests into the city’s wastewater system. In addition, some of that waste also leached into groundwater surrounding the facility. It resulted in contamination of the city’s biosolids, and in an ensuing plume of contaminated groundwater that seeped into several wells located in the parts of Marinette and throughout the Town of Peshtigo.

Additionally, the work plan also references other potential sources of PFAS contamination to the biosolids. It states that several different industrial sites in the Marinette and Peshtigo areas “are likely contributing sources of PFAS to the WWTPs” in both cities. Thus the work plan claims that it results in the possibility for the existence of multiple PFAS sources for that historic biosolids contamination. However, no industry was identified by name.

Staff working for Arcadis, a design and consultancy firm contracted by JCI/Tyco to provide environmental testing and advising for PFAS investigation and cleanup, will conduct the sampling. According to the plan, the collection of well water samples occurs directly from internal home water outlets such as a kitchen sink tap.

Following collection, Arcadis sends the samples to TestAmerica Sacramento in California via over-night delivery, where sample analysis occurs. Once at TestAmerica, each sample is analyzed for 36 PFAS compounds. PFAS comprise a family of over 4,700 substances, of which PFOA and PFOS have received the most scrutiny and study over the years, ever since scientists discovered in the early 2000s that the chemicals were potential human health — including carcinogenic — risks. However, according to some internal research records compiled by E.I. DuPont de Nemours & Co., the maker of Teflon (a significant source of PFAS), those health risks were known decades prior.

Within ten days after the return of sample analysis, a “results letter” will be delivered to respective well owners. However, as the timeline for the collection and sample analysis relies upon the unfolding COVID-19 crisis, the EagleHerald will monitor and update as new information arrives.

For more immediate news, residents and concerned citizens can access the WDNRs webpage pertaining to the Marinette and Town of Peshtigo contamination at:

Additionally, for updates directly from JCI/Tyco, residents can visit