Wauleco Wood Waste Burning Plan

Site investigation Work Plan

Wauleco Wood Waste Burning


Wausau, Wisconsin

March 15, 2019

Prepared for Wauleco, Inc.

Prepared by TRC Environmental Corporation of Madison, Wisconsin

This letter to the editor will highlight two sections of the 140-page Site Investigation Work Plan.

Section 3 Introduction

Section 3.2 Purpose and Approach

“The Purpose of this Site Investigation Work Plan (SI Work Plan) is to respond to the request in the WDNR letter to ‘address aerial deposition of contaminants associated with the combustion of wood waste generated at the facility.’ We understand that the Department’s concern associated with the historical combustion of wood waste is that dioxins and furans may have been formed, emitted from the air discharge, and aerially deposited to the soil downwind of the boiler air emission stack. Therefore, the constituents of potential concern (COPC’s) for this site investigation are dioxins and furans.

This SI Work Plan is intended to present the proposed sampling and analysis strategy, sampling methods, and other details for the implementation of proposed Scope of Work to respond to the request.”

Section 7 Schedule

From all indications, the Site Investigation Work Plan will be completed in approximately 195 days.

“Consistent with NR716.09(2)(h)Wis. Adm. Code, based on the approach described in this SI Work Plan, the targeted schedule is as follows:

*Air dispersion model input parameters will be provided to the WDNR by April 5, 2019.

*Within 30 days of receipt of concurrence from the WDNR on the air dispersion model input parameters, the air dispersion model will be developed/run. Concurrently, the background conditions will be performed. The interpretation of modeling results, background conditions assessment and identification of proposed background soil sample locations will be provided to the WDNR.

*After off-site access permission/agreements are obtained, the background soil sample collection will begin within two weeks.

*Within 60 days of receipt of the background sample analytical results, a proposed data gap sampling technical memorandum will be prepared proposing additional soil sample locations, if any.

*Upon concurrence from the WDNR of the proposed data gap soil sampling locations, permission to access off-site properties will begin.

*After off-site access permission/agreements are obtained, the data gap soil sample collection process will begin within two weeks.

*Soil sample results will be provided to WDNR within 10 business days as required by NR716.14(2), Wis. Adm.Code

*A Site Investigation Report summarizing the activities discussed in this SI Work Plan will be provided to the WDNR within 60 days of completing all site investigation activities.”

The complete Site Investigation Work Plan can be viewed:


In light of the Purpose and Approach, the lengthy Schedule, and other relevant information contained in the 140-page Site Investigation Work Plan dated March 15, 2019 that was released to Citizens for a Clean Wausau and Wausau City officials, it is imperative that work on Thomas Street Construction Phase II and Riverside Park be halted until the SI report summarizing the activities in the Site Work Plan is completed and released to the public.

Citizens for a Clean Wausau and other organizations will continue their involvement to advocate for the health and well-being of all people in the Wausau area who value the air we breathe, the indispensable clean soil and water that provides life to all of us.

Join our cause and make your voices heard.

Thank you.