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The current website can be found by visiting: https://tycomarinette.com
Question: What actions are you taking to remediate the PFAS from the FTC?
Answer: In November 2020, we announced an integrated permanent source-control approach to remediate the PFAS-impacted groundwater, as well as the affected soil at Tyco’s Fire Technology Center. We have since made tremendous progress in implementation of each of the related plans submitted to and approved by the Wisconsin Department of Natural Resources (WDNR). Tyco appreciates DNR’s efficient and effective work in reviewing and approving the lengthy, detailed documents we submitted related to these major and important remediation projects.
Groundwater
In May 2021, WDNR approved our plan for a Groundwater Extraction & Treatment System (GETS) designed to focus on the area containing 95% of the PFAS that came 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, which meets or exceeds DNR standards, into Ditch B. The GETS is under construction and is scheduled to begin start-up operations in the first half of 2022. (See GETS fact sheet)
Soil
Per our plan approved by DNR in June 2021, soil with aggregated PFAS is being excavated and removed from the FTC. 95% percent of the stored soil from the construction of the Advanced Research & Testing Facility (See ARTF fact sheet) construction has been loaded into rail containers and transported out of state for disposal at a permitted facility. Soil with aggregated PFAS at 5 locations in the FTC’s Outdoor Testing Area will be excavated starting spring 2022 and transported out of state for disposal at a permitted facility. (See Soil fact sheet)
Investigation
These plans are based on almost 4 years of investigating soil, groundwater, surface water and air to find out how PFAS moved from the FTC and where it went. This included gathering over 10,000 data points that were submitted to the WDNR in a 1,000-page report in May 2020. We also implemented interim solutions as quickly as possible to address PFAS from the FTC in drinking and surface water while we identified long-term solutions.
Question: How did you identify the site investigation area?
Answer: We identified the site investigation area based on extensive research and analysis of more than 10,000 data points to understand how PFAS traveled from the FTC and where it went:
We will also be submitting to DNR in February 2022 an Additional FTC Site Investigation Plan that will build on the 10,000 data points and include some additional testing/analysis to provide an even more granular look at the PFAS plume associated with the FTC.
Question: What are your next steps in the area northwest of the FTC where biosolids from the Marinette wastewater system were spread?
Answer: Tyco will provide bottled water and conduct a comprehensive investigation of the biosolids area even though there are clearly many other sources that contributed PFAS to the City of Marinette wastewater system and, therefore, the biosolids spread in the fields. Typically, public authorities undertake the initial scientific work needed to understand the sources of materials and their impact on the environment, as has been done with biosolids in Michigan*and will be done as part of EPA’s PFAS Roadmap. Since this has not happened in Wisconsin and Tyco believes a thorough scientific approach is warranted for this complicated and emerging biosolids issue, we are agreeing to DNR’s request and stepping up to launch an investigation that will follow industry best practices.
*Michigan’s Dept of Environment/Great Lakes and Energy (EGLE) in 2020-21
Question: Why did you help the City of Marinette buy new equipment for dealing with the biosolids from their wastewater system?
Answer: Given that Tyco was historically one of the contributors to Marinette’s wastewater treatment plant and the resulting biosolids, we decided to pay for equipment and treatment that the City of Marinette will be using to address PFAS in biosolids. It is important to note that Tyco is no longer a source of PFAS in the Marinette wastewater treatment plant because we stopped discharging untreated water in 2019.
Question: Why did you conclude that the Expanded Area was not impacted by PFAS from the FTC?
Answer: Tyco has submitted exhaustive evidence demonstrating that the PFAS found in the DNR’s Expanded Area did not come from our historic operations at the Fire Technology Center (FTC). No evidence or data has been presented to the contrary. Geologic data demonstrates, for example, that the FTC is downgradient from the potable wells DNR sampled, so the PFAS DNR found in scattered spots in the Expanded Area could not have come from the FTC since water does not flow uphill. In addition, the type of PFAS DNR found in the Expanded Area is very different from the type of PFAS in the plume from Tyco’s FTC - they have different chemical signatures, which means they are from different sources.
Question: Why should the WDNR identify other responsible parties?
Answer: 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 and other existing documents, however, indicate that there are other sources of PFAS contamination in the community. Only WDNR has the authority to investigate and address those sources; Tyco does not.
For example, the Marinette and Peshtigo communities contain numerous industrial facilities that are likely contributing PFAS to the wastewater treatment plants. In addition, PFAS has been used in thousands of common household products since the 1940s and its use results in PFAS in groundwater and, in areas where there are shallow potable wells and septic tanks, it can move into drinking water. This means that even with our remediation systems, PFAS will remain in the community unless action is taken to identify and stop these other sources.
Question: Was PFAS released into the air when AFFF was tested outdoors?
Answer: We stopped testing AFFF firefighting foam outdoors in 2017. We did a thorough review of scientific studies and analysis of our operations and, as reported to the WDNR in a June 2020 report, the data gathered indicate that air is not a significant pathway for PFAS from AFFF. This finding is consistent with the design and purpose of AFFF – to fall on surfaces to smother flames within seconds.
In response to DNR’s feedback on our air pathway work plan, we are continuing to study this pathway and data so far indicate that air is not a significant source of PFAS from AFFF in soil or groundwater on/near the FTC.
Question: Are deer and fish safe to eat?
Answer: The love of the outdoors is important to our community and way of life, and the safety of our community always comes first.
The WDNR undertook a study to look at the relationship between PFAS and deer in the area around the FTC. While the highest PFAS reading among any deer tested was 92 parts per billion (ppb) in the liver, less than one-third of the standard established by Michigan, 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 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, of which Wisconsin is a member.
Question: Is it unsafe if water leaks into the basement of homes in the City of Marinette where there is PFAS in the groundwater?
Answer: According to a June 2019 letter from the Wisc. Department of Health Services (WDHS) to the Wisconsin Dept. of Natural Resources (WDNR), touching water or foam is not considered a significant health concern.
For more details on paths of PFAS exposure, both WDHS and WDNR have issued helpful guidance that you can find on their websites. According to WDNR, on the Marinette page of their website under FAQs (https://dnr.wisconsin.gov/topic/PFAS/MarinetteFAQ.html), PFAS do not easily enter the body through the skin. Therefore, touching or having skin contact with water, products or packaging containing PFAS is not a major source of PFAS exposure.
The federal Agency for Toxic Substances and Disease Registry (ATSDR), an arm of the Centers for Disease Control, state that activities like bathing, showering, or washing dishes in water containing PFAS should not increase your exposure. https://www.atsdr.cdc.gov/pfas/health-effects/exposure.html
However, to be cautious, you should rinse off and wash your hands with soap after touching water from your basement that you suspect may contain PFAS. https://www.dhs.wisconsin.gov/chemical/pfas.htm
If you have additional questions about potential health issues, you should contact your doctor.
Question: Is it safe for City of Marinette residents where there is PFAS in the groundwater to use their irrigation wells for watering plants and filling their pools?
Answer: The WDHS released updated guidance on this topic in a letter sent out May 18, 2021, which you can find on its website. This letter from WDHS (to WDNR) indicates that “Overall, the available research indicates that most garden plants are a minor source of PFAS exposure and that drinking PFAS-contaminated water continues to be the most common source of exposure. DHS recommends that sources of water with PFAS levels below DHS’s recommended groundwater standards in Cycle 10-11 (i.e., 20 ppt for PFOA, PFOS) be used for watering fruit and vegetable gardens to avoid small amounts of exposure to PFAS.
For pools, recent DHS guidance (May 18, 2021 letter) says that “for non-potable uses such as pools, levels of PFAS above the DHS groundwater standard recommendations may be acceptable.” However, to reduce the chance of accidental ingestion of small amounts of PFAS, remind swimmers not to swallow pool water. And if you have questions about your specific situation, you can contact DHS at 1-608-266-1120 x 5.
Question: Are you responsible for foam in the ditches? Does it contain PFAS?
Answer: As stated on the WDNR’s website, “Foam is a common occurrence on Wisconsin waterways, and can often be observed floating on the surfaces of lakes and rivers. Surface water foam can form as a result of natural processes or from human-caused discharges such as runoff of contaminants into waterways.” 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 and sent off-site to a licensed facility for disposal.
In August 2021, Tyco reported the PFAS levels in foam collected from Ditch B. The cause of some PFAS in the foam is 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) will reduce surface water concentrations of PFAS in Ditch B and foam that is collected will continue to be monitored over time.
Question: Will you be updating the advisory signs about PFAS in the ditches?
Answer: 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. At the request of DNR, Tyco is currently working with local municipalities and property owners to update the sign text and possibly increase the number of signs.
Question: What causes the dark smoke I see sometimes coming from the FTC?
Answer: We stopped outdoor testing of firefighting foam blended with PFAS at the Fire Technology Center (FTC) in 2017. The only outdoor testing we conduct today is done to test Tyco products with no fluorine added, such as handheld dry powder extinguishers.
At the FTC, we test our AFFF lifesaving firefighting products inside our test facilities and in outdoor test areas to ensure that they will work properly when first responders need them. We also train first responders, primarily in the summer months, to fight fires so they can do their jobs effectively and return safely home to their families. But we do not train them outdoors using AFFF.
All of these activities can result in visible smoke. All of our testing at the FTC is covered by and complies with a permit issued by the WDNR called a Minor Source Air Permit.
Question: Was there a legal settlement with Peshtigo residents impacted by PFAS? Who is getting payments?
Answer: 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, WI whose property may have been affected by the presence of per- and polyfluoroalkyl substances (PFAS) from Tyco’s Fire Technology Center (FTC) or who may have drunk water that contained PFAS. The court-approved administrator will make all decisions about disbursing the funds according to certain criteria. Tyco has no role in determining the amount any individual receives.
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.
Question: Where are you in the process for selecting a long-term drinking water solution for the Town of Peshtigo?
Answer: On December 6, 2021, discussions facilitated by a third-party chosen by DNR began with all interested parties – Town of Peshtigo, DNR, City of Marinette, City of Peshtigo, and Tyco – to identify and select a solution for providing long-term clean drinking water to the residents of the Town of Peshtigo in the Potable Well Sampling Area. Tyco requested the participation of DNR in an effort to expedite a mutually agreeable solution. Tyco continues to fund legal and technical support for officials in Town of Peshtigo, City of Marinette, and City of Peshtigo to evaluate the long-term water solution options.
The confidential discussions are scheduled to continue in January 2022.
Question: When did Tyco become aware of PFAS in the soil and groundwater? Or contamination of any drinking water supplies?
Answer: 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 to be 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 2016 EPA health advisory level 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 and moved rapidly to address this issue and identify long-term solutions.
Question: What immediate actions did you take to address PFAS while you worked to identify long-term solutions?
Answer: Our first priority was to ensure the community’s water is safe and that residents are protected from PFAS contamination. To do so, we immediately provided bottled water and point-of-entry treatment systems (POETS) to all affected households in the Town of Peshtigo where measurable PFAS levels were detected.
We also took immediate steps to stop PFAS from traveling from the FTC, including:
Question: Does the EPA regulate PFAS?
Answer: The U.S. EPA has not included PFAS on its list of hazardous chemicals, so it does not currently regulate PFAS, but it has allowed states to do so. The EPA set a health advisory level (HAL) in 2016 for PFAS at 70 ppt for drinking water. In 2020, the EPA indicated that it has an intent to regulate PFOA and PFOS and put forward a comprehensive PFAS roadmap to analyze this complex issue across the many different dimensions.
Question: What are the latest results you’ve obtained from your private well drinking water testing?
Answer: As of April 2, 2018, 137 wells in the area have been tested and we have validated results back from all of them. 97 wells returned results of “Non-Detect,” meaning neither of these compounds were detected in that well’s drinking water. 29 wells returned a detection for PFOA and/or PFOS, but these detections were below the U.S. EPA’s Health Advisory Level (HAL) of 70 parts per trillion. 11 wells have returned results above the HAL.
Question: And what are you doing for these properties that have detections of PFOA or PFOS?
Answer: First, for every well that has been sampled, no matter what the results have been, the owners or residents of that home have been offered bottled water. Second, for the 11 wells with results over the HAL, we have offered to pay for, install, and monitor localized home carbon filtration systems that are proven to remove both of these compounds from drinking water. These are called Point of Entry Water Treatment system – or a “POET” system, and are described below.
Question: What is the current status of your work?
Answer: On March 8, 2018 we submitted two draft work plans to the Wisconsin Department of Natural Resources (DNR): a Site Investigation Work Plan and a Long Term Potable Well Monitoring Plan. The proposed Site Investigation Work Plan describes the further investigation of groundwater, soil, storm water and ditch sampling in the area. The Long Term Potable Well Monitoring Plan lays out a schedule to re-sample all potable (drinking water) wells that we’ve tested in the area. We’ve received initial feedback to these plans from the DNR and are meeting with them to address their questions and recommendations. As soon as that is completed, the plans will be updated, and the work will begin almost immediately.
The DNR has posted copies of these Work Plans to their BRRTS on the Web website here:
You can enter the following activity number which will take you to the relevant documents:
0238580694
Question: Will you wait then to retest the drinking water wells you tested before?
Answer: No, we are not waiting. In fact, re-testing began on April 2, 2018.
Question: Is it true you first saw readings for PFOS and PFOA as far back as 2013 and 2014?
Answer: Yes, testing that we were doing on our fire training property in 2013 and 2014 returned readings that indicated that PFOS and PFOA were present in the soil and groundwater. However, at the time we did not have data showing movement of the compounds offsite. It wasn’t until 2016 that we had data that showed we had concentrations of these compounds at the edge of the property, so we then began the series of tests which led us to where we are today.
Question: What about wells that have these compounds, but are below the EPAs health advisory of 70 parts per trillion – don’t other states have lower levels that require action?
We recognize that other states may have different levels, but we’re working under the direction of and closely with the Wisconsin DNR and DHS. The state of Wisconsin doesn’t have its own standard yet, and similar to several other state’s approaches, and in accordance with DNR and DHS guidance, we are following the U.S. EPA health advisory level which is set at 70 parts per trillion. If advisory levels get promulgated or changed, we will act accordingly in cooperation with the DNR and DHS.
In November 2016, the US government issued a PFOA & PFOS Drinking Water Health Advisory. See attached link for further information by the EPA. https://www.epa.gov/sites/production/files/2016-06/documents/drinkingwaterhealthadvisories_pfoa_pfos_updated_5.31.16.pdf)
Question: What about the ditch running South from your property; wouldn’t that ditch carry these chemicals much farther and faster than groundwater would?
Answer: The ditch may be a factor in the movement of these compounds, but we have more investigating to do to better understand that matter. We have found some positive readings near the ditch, but we’ve also found Non Detect readings at various points near the ditch as well. As soon as the ice melts and we can better test the soil and water moving through the ditch, we will be better able to understand the ditch as a conveyance mechanism. This work is included in the draft work plans we submitted to the DNR.
Question: Why can’t I test the water myself with an independent lab of my choosing?
Answer: If you want to test the water you certainly have that option. However, it’s important to realize that this is highly technical work. As these compounds are present in many household items and clothing, collecting the sample requires very specific methods to prevent contamination from those other sources. Additionally, 3rd party independent laboratories should be accredited and experienced in looking for these types of compounds. The consultant we are using, and the labs they are sending the samples to, have that specific experience.
Question: Are the filtrations systems you are offering the best available?
Answer: Just as qualified and accredited labs should test your drinking water, it is important that the water filtration system selected is specifically designed and proven to treat water where PFOA and PFOS are present. The filtration systems that we recommend have been shown to successfully treat water exposed to PFOS and PFOA. Again, you can shop around, but we are working with a consultant and a supplier with proven track records and technology. And to reiterate, we are paying for the installation and maintenance of these systems.
Question: How will this affect property value?
If any home in the study area has elevated levels, it is our understanding that there are really three options in cases like this. All three options have proven to be effective in resolving the presence of these compounds in a home’s water supply.
Question: How far have these substances traveled offsite?
Answer: It is still too early to know how far they may have traveled. We are still in the process of determining through delineation testing where the compounds may have traveled, and how many private wells might have levels of PFOS or PFOA.
Question: What is the percentage of shallow wells that have tested above the HAL?
Answer: All of the wells that have test results above the HAL have been shallow wells. The percentage of those meeting this threshold changes as more results come in, but the general trend lines continue to hold and the percentage is holding at or near 8% of the wells tested. Keep in mind we are testing wells only in areas where we’ve seen suggestions that groundwater movement may have carried these compounds. Only a certain part of the town of Peshtigo is in the study area.
Question: How have the resampling results compared to the initial sample results for drinking water wells?
Answer: The resampling efforts have consistently returned results that mirror or come very close to the initial round of results. None of the resampling results changed a well’s status into a different category. For example, drinking water wells that had “Non Detect” results in the initial testing all had “Non Detect” results in follow-up testing.
Question: What depth has returned the most detections?
Answer: While the well-depths at which detections have occurred has varied, by and large the majority of detections has occurred between 15 and 30 feet below ground surface, which is consistent with the theory that detections are generally found in groundwater from the shallow sand aquifer.
Question: If deeper bedrock wells are drilled within the study area, will they provide a conduit for shallow groundwater that contains PFAS to migrate into deeper aquifers that don’t contain PFAS?
Answer: There are specific ways to install bedrock wells that are done in a manner to prevent cross-contamination. These methods involve using specialized drilling equipment to seal parts of the well that are above bedrock and stop shallow groundwater from being able to flow into the well as it is being installed and after it is installed.
Question: Will Tyco pay to test wells that may be installed in the future?
Answer: Tyco Fire Products, L.P remains committed to addressing the issue, and we will continue to test wells inside of the study area.
Question: What is the definition of shallow and deep wells? How deep is a shallow vs. deep well?
Answer: The depth of wells varies greatly, depending upon where they are drilled and how deep the water table is at that location. When we talk about “deep wells” we are referring to wells that are deep enough to draw from groundwater in bedrock.
Question: How am I not being exposed by bathing in the water, or watering my garden with it? What other exposure pathways are possible?
Answer: The EPA Health Advisory states that, “These health advisories only apply to exposure scenarios involving drinking water. They are not appropriate for use in identifying risk levels for ingestion of food sources, including: fish, meat produced from livestock that consumes contaminated water, or crops irrigated with contaminated water.”
Question: When will a decision be made regarding what wells will be cleaned up that are detected below the HAL?
Answer: We are working with the DNR and DHS to determine what course of action might be taken for wells with detected levels, but below the HAL. In the meantime we continue to offer bottled water to those households and businesses that fall into this category.
