We have extensive efforts underway to address PFAS from our historic actions at our Fire Training Center. PFAS is a ubiquitous challenge, and Tyco takes responsibility for our contribution to the problem. After years of thorough investigation and more than 40 reports submitted to the WDNR, we know that PFAS from our historic operations affected soil on our property, some private drinking water wells in the Town of Peshtigo (specifically 169 wells in an area known as the Potable Water Sampling Area or PWSA), and groundwater under our property and extending to the east and north.

We’ve made a lot of progress in going after this PFAS and fixing the situation. From a $25 million state-of-the-art facility to scrub PFAS out of groundwater, to excavation and removal of affected soils to an out-of-state licensed disposal facility, to working with neighbors to deliver long-term clean drinking water through new deep wells, we are actively solving the problem. Our efforts are thorough and comprehensive, and we believe represent the kind of responsible approach that we hope the many other contributors to PFAS in the environment will also step up and take.

Groundwater
In May 2021, WDNR approved our plan for a Groundwater Extraction & Treatment System (GETS) designed to focus on the area where the vast majority of PFAS is migrating from historic operations at Tyco’s Fire Technology Center (FTC). The GETS extracts groundwater containing PFAS before it upwells into Ditch B, transports the groundwater via underground pipes to a treatment system that removes PFAS from the groundwater, and delivers the treated water, significantly below DNR standards, into Ditch B. The GETS is now operating and successfully treating the groundwater for PFAS before it is discharged into Ditch B. (See GETS fact sheet).

Soil
In June 2021, Tyco began excavating and removing soil with PFAS from the FTC. All of the stored soil from the construction of the Advanced Research & Testing Facility, and the soil with aggregated PFAS from 5 locations in the FTC’s Outdoor Testing Area has been loaded into rail containers and transported out of state for disposal at a permitted facility. (See Soil fact sheet)

Long-Term Drinking Water
In 2022 and after independent engineering studies identified the options available, Tyco engaged with neighbors and offered to build them their preferred long-term drinking water option. Most wanted deep wells, and Tyco got to work.

Installation of deep wells with water treatment systems began in December 2022, and results from the completed installations demonstrate that the treated deep well water is safe to drink. Tyco plans to install about 70 deep wells in 2023 and will continue to install additional wells as requested by property owners in the PWSA.

Other neighbors preferred going through the legal requirements to pursue municipal water from the City of Marinette. Tyco supported those neighbors in that effort, but that effort did not succeed. Tyco then made clear to those neighbors that they can still choose deep wells, and many have done just that. Tyco will install wells for them, as well as treatment systems that include a 20-year maintenance contract – the same package provided to those who originally chose deep wells. (See Deep Well fact sheet)

Investigation
These remediation plans are based on over 5 years of investigating soil, groundwater, surface water and air to find out how PFAS moved from the FTC and where it went. This included the submittal of over 40 reports with thousands of supporting data, figures, and appendices. We also implemented interim solutions as quickly as possible, including providing bottled water or in-home treatment systems to residents whose drinking water was impacted, and addressing PFAS from the FTC in drinking and surface water while we identified the long-term solutions detailed above. In April 2023, we submitted our updated site investigation findings including final groundwater investigation results that clearly define the boundaries of the area impacted by PFAS from Tyco’s historic operations.

Our priority was to ensure the community’s water is safe and that residents are protected from PFAS contamination. To do so, we immediately offered bottled water and point-of-entry treatment systems (POETS) to all households in the Town of Peshtigo potentially impacted by PFAS from historic FTC operation (known as the Potable Well Sampling Area or PWSA).

We also took immediate steps to stop PFAS from traveling from the FTC, including:

• Stopped outdoor testing of firefighting foam (AFFF) in 2017
• Ceased untreated industrial wastewater discharges to the City of Marinette’s treatment plant in 2019
• Supported the City of Marinette in managing its biosolids by providing $4.3 million to pay for advanced equipment and licensed disposal of biosolids instead of land spreading that ended in 2018.
• Installed interim filtration systems at Ditches A and B in 2019 to reduce PFAS in surface water.

Longer-term actions included:

• Constructed and operating an on-site wastewater treatment system in the $11 million Advanced Research & Testing Facility. Treated water is discharged into relined wastewater lines leading from our properties to the Marinette wastewater treatment plant.

Since 2017 and in more than 40 reports submitted to WDNR, we identified the site investigation area based on extensive research and analysis to understand how PFAS traveled from the FTC and where it went.

• We examined PFAS in groundwater, soil, and surface water.
• We analyzed how PFAS from historic operations moves in the environment.
• We evaluated the geology of the area – sand aquifer, bedrock etc.
• We analyzed whether PFAS from the FTC could have moved off our site through the air.
• We installed hundreds of investigation points [Vertical Aquifer Profiling (VAPs), piezometers, soil borings and monitoring wells] to more fully delineate surface water and groundwater characteristics and flow patterns.
• In 2022, several hundred additional samples were taken from over 200 locations, over 30 new and previously untested monitoring wells and over two dozen new VAPs. This allowed us to more precisely define the boundaries of the groundwater plume, and the groundwater investigation is now complete.
• In 2022, we also compared the types of PFAS (fingerprint) present at the FTC and in the related groundwater plume with the fingerprint of PFAS in drinking water wells in the ESIA and found that they are distinctly different from each other.

Tyco contacted owners of impacted wells in the PWSA to understand their preferences about long-term water solutions and take direction from those neighbors about delivering those solutions to them. After extensive analysis by independent experts hired by Tyco or by the Town of Peshtigo and paid for by Tyco, four possible clean water options were identified. Tyco reached over 90% of the 169 well owners. Most favored deep wells, a significant percentage were open to annexation that would be needed to get water from the City of Marinette, and very few supported the possibility of securing water from the City of Peshtigo.

Efforts were made by some neighbors to go through the legally mandated process to pursue annexation to the City of Marinette and secure water. The effort failed to secure the needed demonstration of support (51% of electors and 50% of property value/acreage).

Tyco has sent deep well agreements to all the property owners in the PWSA. To date, over 100 property owners have made clear their desire for a deep well and sent back signed agreements. More than a quarter of these properties have had new deep wells installed. As part of the installation process, Tyco also connected treatment systems (water softener plus reverse osmosis system) that successfully treat naturally occurring elements (including radium) to meet applicable standards. All test results from the 25+ installations completed by Tyco demonstrate the deep well water is safe to drink. (See Deep Well fact sheet)

Yes, Tyco settled a class-action lawsuit with Peshtigo residents. Tyco issued a $15 million payment on October 22, 2021, to a court-approved administrator for the class-action lawsuit settlement agreement reached between Tyco and individuals who live(d) in the Town of Peshtigo, whose property may have been affected by the presence of PFAS from Tyco’s Fire Technology Center (FTC) or who may have drunk water that contained PFAS. The court-approved administrator is making all decisions about disbursing the funds according to certain criteria. Tyco had no role in determining the amount any individual will receive.

The settlement agreement was announced in January 2021 in response to a class-action lawsuit filed in 2018 against Tyco. Although the settlement agreement is not an admission of wrongdoing, we believe settling this case is the right thing to do to address the disruption this issue has caused our neighbors.

Further information and contact information for questions about the settlement is available at www.firefightingfoamsettlement.com.

No. The foam in area ditches is not firefighting foam. We may have contributed some of the PFAS that accumulates in the foam but “Foam is a common occurrence on Wisconsin waterways and can often be observed floating on the surfaces of lakes and rivers,” per WDNR’s website.

At DNR’s request, in April 2020, we began to monitor, collect, and remove foam in Ditches B and C, and eventually expanded to include Ditches A, D & E. We collect foam using booms starting in the spring and ending in late November when the ditches start to freeze. The foam is stored, tested, and sent off-site to a licensed facility for disposal.

Each year, Tyco reports the PFAS levels in foam collected from area ditches, primarily Ditch B. While the foam is not AFFF, some of the PFAS in the foam may be attributable to Tyco’s historic operations at the FTC and the remainder is due to PFAS that is ubiquitous in the environment. Tyco has been monitoring the surface water in area ditches since 2018 as part of the site investigation process. In instances where PFAS are present in the water, the naturally occurring foam has been found to accumulate PFAS at higher concentrations than is present in the water. Therefore, collecting and disposing of the foam also helps reduce the PFAS in the ditch.

The Groundwater Extraction and Treatment System (GETS) is reducing surface water concentrations of PFAS in Ditch B, and foam that is collected will continue to be monitored over time.

Per DNR request, Tyco posted signs with language approved by DNR advising the public not to drink, play, or swim in the water/foam at multiple locations along the ditches in the City of Marinette. More recently, Tyco also worked with local municipalities and property owners to update the sign text and increase the number of signs when requested.

Even though this is a complicated issue and there are multiple potential sources of biosolids, Tyco has taken affirmative action with respect to biosolids by providing bottled water on request to homeowners in the WDNR designated “biosolids area.” Tyco funded a dryer that has allowed the Marinette POTW to send its biosolids to a licensed landfill since 2018, therefore, the City of Marinette has not land spread any biosolids for the last 5 years. Tyco also stopped all industrial wastewater discharges from the FTC to the City of Marinette wastewater treatment plant in 2019. Tyco then invested millions in building an on-site, state-of-the-art water treatment system at the FTC that treats all industrial water before it is discharged to the City of Marinette, under a permit. Tyco has acted to make sure the environment is protected while no one else has, including the DNR.

WDNR’s actions with respect to biosolids have been concerning. The WDNR has allowed and continues to allow millions of gallons of biosolids to be land applied in the biosolids area without testing for PFAS or setting a limit for how much PFAS can be in biosolids that are spread on fields. In crop year 2022 alone, WDNR permitted 2 million gallons of biosolids to be spread in Marinette County – 87% from industrial sources (31% from paper manufacturing) and 13% from municipal sources. This undermines the scientific basis of the research the DNR wanted Tyco to conduct since it is impossible to isolate impacts of the historic land-spreading activities by the City of Marinette. Therefore, Tyco paused our investigation of the potential impact of Marinette Wastewater Utility biosolids in the WDNR-designated “biosolids area.”

Although Tyco has paused the investigation of specific fields, and the DNR has not acted to stop the multiple sources of biosolids in the area, Tyco remains focused on clean drinking water and continues to provide bottled water to the more than 100 homes in this area that requested it.

Tyco has submitted exhaustive evidence demonstrating that the PFAS found in the DNR’s Expanded Area (ESIA) did not come from our historic operations at the Fire Technology Center (FTC). The additional extensive data collected in 2022 further delineated the plume and clearly shows there is no connection between the plume and scattered spots of low-level PFAS found in the ESIA. Tyco analyzed multiple lines of evidence, including:

• Groundwater flow
• Surface water flow
• Potential aerial pathways
• Geology
• Hydrogeology
• Isoconcentration contours
• Forensics “fingerprinting” report conducted by an independent consultant and submitted as part of the Site Investigation Status Report in April 2023.

For example, groundwater elevation data from the expanded network of monitoring wells confirm that the FTC is downgradient from the potable wells DNR sampled in the west and southwest portions of the ESIA. Since these areas are hydraulically uphill of the FTC, we know that the FTC is not the source because groundwater does not flow uphill.

In the Expanded Area south and east of the plume, additional sample results from monitoring wells, piezometers and soil borings confirm the previously mapped southern plume limit is within the current PWSA boundary.

Additionally, the fingerprints of PFAS that DNR found in the ESIA are very different from the fingerprints of PFAS in the plume from Tyco’s FTC – they have different chemical signatures, which means they are from different sources. Likewise, PFAS detections in the ESIA are not contiguous to our plume. That is, there are patches of PFAS in the expanded area – like would be found across the country given that PFAS is in countless products; there is no evidence of a PFAS plume in the ESIA.

DNR itself has stated there are many other sources of PFAS and has identified several other PFAS sites near Green Bay and/or the Fox River which discharges into Green Bay. The Marinette and Peshtigo communities contain numerous industrial facilities that are likely contributing PFAS to the environment including paper manufacturers, metal fabricators, landfills, and septic systems.

Tyco has taken responsibility for and is cleaning up PFAS that came from historic operations at the FTC. The data we have shared with the WDNR, the WDNR’s own statements, and other existing documents, however, indicate that there are other sources of PFAS contamination in the community that are unrelated to Tyco. Tyco has no authority to investigate these other sources or take enforcement action against them. WDNR does have that authority but has not been acting to stop known sources with the result that PFAS continues to discharge into the environment.

In addition to many industrial sources of PFAS, due to the widespread usage of PFAS across thousands of household products and materials since the 1940s, including toilet paper, PFAS have been detected in household septic effluent at environmentally relevant concentrations (Thompson et al., 2023). Septic effluent has been identified as a potentially significant source of PFAS to groundwater and nearby drinking water wells (Schaider et al., 2014 and 2016; Subedi et al., 2015; Gao et al., 2019).

No, the data gathered indicate that air is not a significant pathway for PFAS from AFFF, as reported to WDNR in June 2020. This finding is consistent with the design and purpose of AFFF – to fall on surfaces in the worst fires to smother flames within seconds.

WDNR testing of deer in the area around the FTC did not detect PFAS in deer meat or tissue exceeding relevant standards. Because the highest PFAS reading among any deer tested was 92 parts per billion (ppb) in the liver, about 67% lower than the Michigan-set standard, the WDNR issued cautionary advice that livers from deer killed in a very limited area around the FTC should not be eaten. This advisory did not apply, however, to other deer meat or tissue. We placed ads in local papers to keep hunters informed.

In November of 2020, we concluded sampling of surface water and fish tissue from three privately owned ponds near the FTC. Of the 26 fish analyzed, none registered a PFOS level exceeding 200 ppb, which is the level a Do Not Eat advisory should be issued, per the guidelines established by the Great Lakes Consortium, which includes Wisconsin. Tyco had planned to test additional area ponds in 2022, but they were found to not contain fish. DNR advisories on fish and wildlife can be found here.

According to the Wisconsin Dept. of Health Services (WDHS), ingestion is the primary pathway for PFAS exposure and the WDHS website notes that “PFAS don’t easily enter the body through the skin.” To avoid accidental ingestion, the website recommends keeping water out of your mouth, avoiding foam, washing your hands, and rinsing pets.

If you have additional questions about potential health issues, you should contact your doctor.

The WDHS released updated guidance on this topic in January 2023, which you can find on its website (https://www.dhs.wisconsin.gov/publications/p03111.pdf). This newsletter entitled “PFAS and Backyard Gardening” recommends that gardeners use “water with PFAS levels below DHS recommended groundwater standards for watering fruit and vegetable gardens” and to practice safe gardening habits to lower exposure to PFAS and other contaminants that can be found in soil.

For pools, DHS’s website notes that “PFAS don’t easily enter the body through the skin” and it provides recommendations for avoiding swallowing PFAS by accident as a result of swimming, such as keeping water out of your mouth, avoiding foam, showering after swimming, and rinsing pets. And if you have questions about your specific situation, you can contact DHS at 1-608-266-1120 x 5. (DHS healthy swimming guidelines)

The smoke is from first responders being trained in how to use Tyco’s firefighting technologies, such as handheld dry powder extinguishers, or from our indoor test facilities. We stopped outdoor testing of firefighting foam blended with PFAS at the Fire Technology Center (FTC) in 2017, so the substances tested outside have no fluorine added.

All these activities can result in visible smoke. All our testing at the FTC is covered by and complies with a permit issued by the WDNR called a Minor Source Air Permit.

In late 2013, we detected PFAS chemicals at the center of our 380-acre property in Marinette. Our personnel studied the issue and discussed it with outside consultants. Based on the topography, the nature of the compounds and other factors, they believed the issue was confined to our property. They also believed we did not have regulatory reporting obligations based on those tests.

In 2016, further testing revealed the presence of PFAS near the property boundary, and we notified the WDNR of these results and the testing from 2013. In 2017, in conjunction with the WDNR and local officials, we conducted testing in drinking water wells in Town of Peshtigo and found that some wells contained PFAS, some at levels higher than the recommended drinking water standard for the state of Wisconsin that was in place at that time of 70 parts per trillion (ppt).

As soon as we became aware that PFAS from historic operations at the FTC migrated into private drinking water wells in Peshtigo, we took responsibility, provided bottled water and point-of-entry systems (POETS), and moved rapidly to address this issue and identify long-term solutions.

In April 2024, the U.S. EPA finalized a national drinking water standard related to PFAS, setting enforceable Maximum Contaminant Levels (MCLs). The EPA’s standard is 4.0 parts per trillion (PPT) for PFOA, 4.0 PPT for PFOS, 10 PPT for PFHxS, 10 PPT for PFNA, and 10 PPT for HFPO-DA (commonly known as GenX Chemicals, individually, as well as 1 (unitless) Hazard Index for mixtures containing two or more PFHxS, PFNA, HFPO-DA, and PFBS. The EPA’s standard requires that all public water systems have three years to complete their initial monitoring for these chemicals and they must inform the public of the level of PFAS measured in their drinking water. The EPA has said that where PFAS is found at levels that exceed these standards, systems must implement solutions to reduce PFAS in their drinking water within five years.  Tyco works closely with the Wisconsin Department of Natural Resources in the investigation and remediation of our sites in Marinette.