472 24 26018 https://digitalcollections.library.gvsu.edu/files/original/742ade047db221ec0c5326d3efa42bb9.mp4 3286ed4dd1ef2ff8abd488b18cef7535 https://digitalcollections.library.gvsu.edu/files/original/08f90ed333dada156955a3c9c3d143f0.pdf e7ec639ee85c9a76aea5b866172ce8e6 PDF Text Text Grand Valley State University Veterans’ History Project Interview Vietnam War Jim McCloughan 1 hour 44 minutes (1:03) – Background -Born May 30, 1946 in the hospital in South Haven, Michigan -Parents took over grandparents’ farm in rural Bangor, Michigan -Grew up in Bangor, MI -Attended one room school house “about a mile down the road” until 6th grade -Junior High School and High School in Bangor -Graduated in 1964 -Went to Olivet College -Bachelor’s Degree in Sociology as well as a teaching degree -Played 4 years of football, wrestled for 4 years, and played 2 years of baseball -Graduated in June 1968 -Told to report for a physical -Had signed up for draft when he was 18 -Was told he would be drafted that July (1968) -Had already signed contract with South Haven Schools in May to teach, desperately needed teachers -School board appealed to draft board, but the draft board said he had already had his deferment (4:17) – Basic Training (Fort Knox portion) -Sent to Fort Knox, Kentucky for basic training -1st week housed with 30-35 men -E5 Spec. 5 Medic was in charge -Medic finds out he has medical knowledge, most likely requested for him to be sent to Ft. Sam Houston for medic training after basic -Only one to go to Ft. Sam Houston -Most medics were not draftees -Training wasn’t very difficult (physically) -Had to emotionally adjust to not being in a small community -Mentally disciplined from sports, prepared him for distractions and drilling -Appointed squad leader because he was older -Sense of maturity, majority of draftees were high school graduates -8 weeks of basic training ends (10:35) Fort Sam Houston portion -Rode on bus to Ft. Sam Houston in San Antonio Texas �-Met Marty Romine -Arrived 2 weeks early, attached to transportation unit in the country -Had barracks to themselves -Drove every kind of vehicle they had, said it reminded him of home -10 weeks of medic training -Lots of classwork -Marty was training partner -Learned how to give shots and apply bandages knew other basic medicine from being in sports -Interviewed to get a trainer position, thought he would get it and stay out of Vietnam (13:00) Last Day of Training -Deployment orders: Southeast Asia, Vietnam -Thought it was mistake, asked command, not a mistake, Army regular (enlistee) got the training job -Offered to “re up” by joining Airborne, Special Forces, or OCS (Officer Candidate School), but declined because it would mean an additional year of service (15:15) More Talk about Training - Prepared for hospital work as well -Was assigned as a combat medic because the Army needed them -Went to Ft. Sam Houston in November -Got 2 weeks of leave for Christmas -Graduated from medic training in February -2 weeks leave in February -Worked with wrestling team in South Haven for the championships -Visited wife (16:35) Deployment -Sent to Oakland California -Gates in sorting area locked to keep soldiers in (17:35) More Talk about Training -Had only one conscientious objector -Some men claimed they were but in Vietnam that changed -First time medics were allowed to be combatants (19:10) More about Deployment - Layover in Oakland for a few days -Flew up to Alaska -Brother lived in Alaska with wife and child, wanted to visit them, but the plane was only there for 20 minutes -Flew in military transport (very uncomfortable) -First thing he noticed about Vietnam is that it stunk because it was humid mixed with the smell of human feces (21:20) (Added Step) Went from Alaska to Guam, and from Guam boarded military transport and flew to Cam Ranh Bay in Vietnam) �(21:55) Arrival in Vietnam -Orientation for 2 days -Booby traps -Snakes -Division headquarters was in Chu Lai -Part of 3rd Battalion, 21st Regiment, 196th Light Infantry Brigade, 23rd (Americal) Division -Introduced to Captain Jim Foster who was in charge of medics -Taught him how to create a practical medical kit for the field -Was attached to Charlie (“C”) Company just outside of LZ Center -Flew out in helicopter -Met the soldier he was replacing, one Pat Rocco -First person he met in Charlie Company was Sergeant Doug Hatton who “talked real slow,” “was missing a front tooth,” and “had his helmet on crooked.” -Grew to like him -“I was a kindergartener in fighting war, but he (Sgt. Hatton) had a master’s degree.” -Became best friends -Company was stationed in a thick tree area, but not dense enough to be considered a jungle (27:50) First Contact -Arrived in LZ Center on the 7th of March and the company was ambushed on the 10th -In the ambush lost two men, but not from his platoon (2nd platoon) -Immediately got used to hearing, and reacting to, people calling for a medic (30:00) Basic Duties -Was in charge of making sure that men took daily and weekly anti-malarial pills -Tended to still healing wounds -Impetigo was rampant (bacterial skin infection) -Hydrogen peroxide and nitrous ointment used to treat it -Took about 5 to 6 days to heal -Also took care of sprains, strains, boils, and rashes (31:19) Daily Routine -Got up before dawn and started moving -At sunrise stop and eat -He (Jim) would go around and check on soldiers -Get to destination and establish perimeter before dark -More patrols meant less contact -Normally moved as a company (35:10) Conditions -Rice paddies -Jungle in the mountains -Not a lot of civilians -“Not a good country for a democracy” -Very rural, very primitive -In the beginning thought the people were friendly, over time sensed bitterness -Booby traps in the rice paddies �-OED’s (“other explosive devices”), not IED’s like in Iraq or Afghanistan -Caused gruesome injuries -Hated being in the rice paddies because of vulnerability and booby traps -Occasionally fought alongside Army of the Republic of Vietnam (ARVN’s) -Inept and unhelpful soldiers (43:40) Jungle Conditions -Humid in the jungle, lots of leeches, lots of spiders -Never saw snakes or tigers (45:10) Return to LZ Center -Return to LZ Center for a week -Resupply -Shower (only allowed 5 gallons of cold water) -New set of clothes -Get more rations -Access to warm meals -Got to sleep on a cot instead of on the ground (46:40) Battle of Tam Ky (Prologue) -4th Day of 7 Day rotation at LZ Center they were attacked -May 12th at 1:30 AM the north end of LZ Center was attacked by North Vietnamese sappers -2 U.S. troops killed -Evening of May 12th Lt. Carrier (company commander) was called into TOC (tactical operations center) -Being sent to Tam Ky (large town that was being attacked) -No idea on enemy troop strength -Lt. Carrier argued that the mission was flawed, but was threatened with court martial if refused to go (49:30) Battle of Tam Ky – Securing the Landing Zone -Left for Tam Ky at 10:10 AM on May 13th via helicopter -Landing Zone was “hot” (under fire) -Had to jump from helicopters -2 helicopters were shot down -Established perimeter to help with extraction of wounded -Helped one man who had managed to hurt himself in the jump -Secured landing zone and regrouped (52:30) Battle of Tam Ky – Nui Yon Hill Pt. 1 -At 4 PM command wanted scouting platoon to go to Nui Yon Hill -Massive fortification south of Tam Ky -About 1500 North Vietnamese -Scouting platoon was made up of 19 U.S. soldiers and 1 South Vietnamese interpreter -Entered trench surrounding Nui Yon Hill -Noticed two contacts stringing wire in the distance -Opened fire on them with Sgt. Hatton -Immediate NVA retaliation, point man killed -2 soldiers wounded in the open �-Went to help them, realized they were shell-shocked, not wounded -One wound up getting killed, the other captured -Left trench four or five times to retrieve wounded troops -Airstrike was imminent, tons of crossfire -Helped load wounded onto medevac -Lt. Carrier suggests that he (Jim) goes as well since he was wounded -Refuses, wants to stay behind and continue to help (1:06:58) Battle of Tam Ki – Nui Yon Hill Pt. 2 -Next day was uneventful -Hungry, tired, and wounded -By evening the company was told to move, 1st Platoon would lead instead of 2nd -Engaged again -Goes back into crossfire again to retrieve wounded soldiers -Spooky (AC 130 gunship) provided flares for light, and heavy covering fire -NVA failed to win because they didn’t totally surround the U.S. forces -169 NVA killed, minimal U.S. losses -Extracted by helicopter (1:12:15) Stand Down in June -Returned to LZ Center for a break from the field -Patrols and search and clear missions continued though -Did not reach full company strength again until July -Tried to welcome replacements, make them feel included (1:15:10) Battle of LZ East -LZ East was getting probed by NVA -June 10th volunteers were asked to go assist LZ East in establishing a perimeter -2:35 AM NVA sappers attacked -Bunker hit, saved 2 men -NVA began to bombard position with mortars -Sappers effectively overran base -Destroyed key positions -Artillery -Medical bunker -High ranking officers killed -Lost 17 U.S. soldiers -Treated wounded NVA as well -Fighting lasted 30 minutes -Returned to LZ Center (1:22:10) Deployment to Chu Lai -Had to provide positive ID for rescued POW at the hospital in Chu Lai -While at the hospital was offered position at the hospital in Chu Lai -Asked Lt. Carrier for permission, response, “What the hell are you still doing here?” -Emotional, bittersweet moment -Attached to 91st Evacuation Hospital in Chu Lai -Got own bunker and locker �-Helped in the hospital -Emergency room work -Paperwork -Interviewed patients -December 1969 Bob Hope performed in Chu Lai, opted out of seeing him -Occasional rocket strikes happened, but Chu Lai was relatively safe -Extremely competent medical personnel (1:31:25) Morale and Relations -Morale constantly fluctuated between good and bad -Troops nearing the end of their tour had high anxiety -Competent officers improved morale -No problems with insubordination -Fairly high drug use -Pills -Marijuana -No heroin yet -African Americans kept to themselves out of choice -Race relations were good though (1:38:40) Coming Home -Came into Chicago -No welcome committee -Father and wife were sent to the wrong gate -Wanted to tell family and friends “goodbye” and “I love you” from then on -Was not hassled, but not welcomed either -People didn’t want to talk about Vietnam with veterans -Rehired by South Haven Schools -Head coach there for 38 years as well -Coached 35 summers with the American Legion Baseball -Worked a lot -Loved his various jobs -Staying busy kept his mind off memories -Retirement allowed for the memories to start to come back -Proud to have served alongside who he did -Highest respect for those he served with � Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Veterans History Project Creator An entity primarily responsible for making the resource Grand Valley State University. History Department Description An account of the resource The Library of Congress established the Veterans History Project in 2001 to collect memories, accounts, and documents of U.S. war veterans from World War II and the Korean War, Vietnam War, and conflicts in the Middle East and elsewhere, and to preserve these stories for future generations. The GVSU History Department interviews are part of this work-in-progress, and may contain videos and audio recordings, transcripts and interview outlines, and related documents and photographs. Coverage The spatial or temporal topic of the resource, the spatial applicability of the resource, or the jurisdiction under which the resource is relevant 1914- Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/page/InC/1.0/?language=en">In Copyright</a> Subject The topic of the resource Afghan War, 2001--Personal narratives, American Iran Hostage Crisis, 1979-1981--Personal narratives, American Korean War, 1950-1953--Personal narratives, American Michigan--History, Military Oral history Persian Gulf War, 1991--Personal narratives, American United States--History, Military United States. Air Force United States. Army United States. Navy Veterans Video recordings Vietnam War, 1961-1975--Personal narratives, American World War, 1939-1945--Personal narratives, American Publisher An entity responsible for making the resource available Grand Valley State University. University Libraries. Special Collections & University Archives Contributor An entity responsible for making contributions to the resource Smither, James Boring, Frank Relation A related resource Veterans History Project (U.S.) Identifier An unambiguous reference to the resource within a given context RHC-27 Language A language of the resource eng Source A related resource from which the described resource is derived <a href="https://gvsu.lyrasistechnology.org/repositories/2/resources/455">Veterans History Project interviews (RHC-27)</a> Oral History A resource containing historical information obtained in interviews with persons having firsthand knowledge. Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Identifier An unambiguous reference to the resource within a given context McCloughanJ1554V Title A name given to the resource McCloughan, James (Interview outline and video), 2013 Creator An entity primarily responsible for making the resource McCloughan, James Description An account of the resource Jim McCloughan is a Vietnam War veteran who was born in South Haven, MI in 1946 and was drafted after college in 1968. He served with the 3/21st Infantry in the 196th Light Infantry Brigade, 23rd (Americal) Division as a combat medic. He fought in several major battles, including Tam Ky, and received two purple hearts during his tour. Contributor An entity responsible for making contributions to the resource Smither, James (Interviewer) Kentwood Historic Preservation Commission (Kentwood, Mich.) WKTV WKTV (Wyoming, Mich.) Subject The topic of the resource Oral history Veterans History Project (U.S.) United States--History, Military Michigan--History, Military Veterans Video recordings United States. Army Vietnam War, 1961-1975--Personal narratives, American Language A language of the resource eng Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/page/InC/1.0/?language=en">In Copyright</a> Type The nature or genre of the resource Moving Image Text Relation A related resource Veterans History Project (U.S.) Date A point or period of time associated with an event in the lifecycle of the resource 2013-10-24 Source A related resource from which the described resource is derived <a href="https://gvsu.lyrasistechnology.org/repositories/2/resources/455">Veterans History Project Collection, (RHC-27)</a> Format The file format, physical medium, or dimensions of the resource application/pdf video/mp4 Publisher An entity responsible for making the resource available Grand Valley State University. University Libraries. Lemmen Library and Archives https://digitalcollections.library.gvsu.edu/files/original/a0d0bffb364664fda00bdcdefd1d48a1.m4v 47d4d1cc31fc5006de4b50082a71f166 https://digitalcollections.library.gvsu.edu/files/original/08dbc3c3bbf0e20bff5b8528295dc09c.pdf 4952d3f007fec17676d2434f645c3db0 PDF Text Text Grand Valley State University Veterans History Project Interview James McConnon Length: 36:08 (00:25) Training    James was drafted into the Army in October of 1971; he had been living in Caledonia, Michigan He went through many physicals in Detroit and then was sent to Fort Knox, Kentucky for basic training for 8 weeks James went through secondary advanced individual training at Fort Bliss, Texas where he worked on an Air Defense Missile System (3:50) South Korea  James was sent to South Korea to work as an Air Defense Artilleryman in April of 1972  He became squad leader and was working with vehicles that carried the missile launching system  Most of the time in Korea James just spent field training at Camp Casey in the North  He worked on the Air Defense System near the DMZ for 14 months  James felt it was nice to live in a different country and learn about another culture  Plus his father had fought in the Korean War and James was able to learn more about some of the things his father had experienced (9:20) Average Days  The men used an HAM Radio to call home and James also wrote his friends and family often  They had cafeteria style food, which wasn’t terrible, but they got sick of it pretty quickly  They were told not to eat the local food because they could easily get sick from it and have serious health issues  James was able to see a few USO shows with Bob Hope  They men often played softball and other games on the base (13:22) After Korea  After serving his time in South Korea James was shipped to Fort Hood, Texas and he worked there for a short time before he was discharged  He did not enjoy working on the base in Texas because he had grown accustomed to such a different environment  James then went to college and earned his Associates Degree and also became a member of the American Legion �  Being in the service helped him to become a more open-minded person and he was able to work with many different types of people James made many good friends in the Army and overall had a very positive experience � Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Veterans History Project Creator An entity primarily responsible for making the resource Grand Valley State University. History Department Description An account of the resource The Library of Congress established the Veterans History Project in 2001 to collect memories, accounts, and documents of U.S. war veterans from World War II and the Korean War, Vietnam War, and conflicts in the Middle East and elsewhere, and to preserve these stories for future generations. The GVSU History Department interviews are part of this work-in-progress, and may contain videos and audio recordings, transcripts and interview outlines, and related documents and photographs. Coverage The spatial or temporal topic of the resource, the spatial applicability of the resource, or the jurisdiction under which the resource is relevant 1914- Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/page/InC/1.0/?language=en">In Copyright</a> Subject The topic of the resource Afghan War, 2001--Personal narratives, American Iran Hostage Crisis, 1979-1981--Personal narratives, American Korean War, 1950-1953--Personal narratives, American Michigan--History, Military Oral history Persian Gulf War, 1991--Personal narratives, American United States--History, Military United States. Air Force United States. Army United States. Navy Veterans Video recordings Vietnam War, 1961-1975--Personal narratives, American World War, 1939-1945--Personal narratives, American Publisher An entity responsible for making the resource available Grand Valley State University. University Libraries. Special Collections & University Archives Contributor An entity responsible for making contributions to the resource Smither, James Boring, Frank Relation A related resource Veterans History Project (U.S.) Identifier An unambiguous reference to the resource within a given context RHC-27 Language A language of the resource eng Source A related resource from which the described resource is derived <a href="https://gvsu.lyrasistechnology.org/repositories/2/resources/455">Veterans History Project interviews (RHC-27)</a> Oral History A resource containing historical information obtained in interviews with persons having firsthand knowledge. Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Identifier An unambiguous reference to the resource within a given context McConnonJ Title A name given to the resource McConnon, James (Interview outline and video), 2009 Creator An entity primarily responsible for making the resource McConnon, James Description An account of the resource James McConnon was drafted into the Army in October of 1971 and went through basic training at Fort Knox, Kentucky for 8 weeks. He then went through secondary advanced individual training at Fort Bliss, Texas where he worked with the Air Defense Missile System. After training James was sent to South Korea in April of 1972 to work with Air Defense Artillery. James spent 14 months in the Northern area of South Korea working on air defense where he spent most of his time in field training. Contributor An entity responsible for making contributions to the resource Farhadi, Matthew (Interviewer) Caledonia High School (Caledonia, Mich.) Subject The topic of the resource Oral history Veterans History Project (U.S.) United States--History, Military Michigan--History, Military Veterans Video recordings Vietnam War, 1961-1975--Personal narratives, American United States. Army Language A language of the resource eng Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/page/InC/1.0/?language=en">In Copyright</a> Type The nature or genre of the resource Moving Image Text Relation A related resource Veterans History Project (U.S.) Date A point or period of time associated with an event in the lifecycle of the resource 2009-05-29 Source A related resource from which the described resource is derived <a href="https://gvsu.lyrasistechnology.org/repositories/2/resources/455">Veterans History Project Collection, (RHC-27)</a> Format The file format, physical medium, or dimensions of the resource application/pdf video/mp4 Publisher An entity responsible for making the resource available Grand Valley State University. University Libraries. Lemmen Library and Archives https://digitalcollections.library.gvsu.edu/files/original/83ca9c502c623b8c503a114ca222a489.mp4 9d6e6748865e5685316aaba4824567da https://digitalcollections.library.gvsu.edu/files/original/2212eb8aa430a7c9fb8619da7aa9aeae.pdf 72938683581d790aacac15d9a2cc1647 PDF Text Text Grand Valley State University Veterans History Project Interview Vietnam Ted McCormick Total Time – (01:34:22) Background • • • • • • • • • He was born in Standish, Michigan (00:31) o He was born when there was not a hospital in town He grew up in Flint, Michigan (01:06) Went to Flint Public Schools His father was in the automotive industry (01:15) There were 4 children in the family o He was the second oldest (01:32) He finished high school in 1968 He worked at Buick in 1968 (02:11) At this point, he was indifferent to Vietnam o He believed it would be over by the time he would be at the drafting age (02:32) He knew others that had been to Vietnam o They did not talk about the war too much Enlistment/Training – (03:39) • • • • • • • • • • He received his draft notice in 1969 (03:47) He went to Detroit, Michigan for his physical (05:11) o The majority of the men getting their physical were looking for a way out of going to the war  Not very many of them got out of it After Detroit, he was bused to Fort Knox (06:54) They arrived at Fort Knox in June, 1969 When they arrived, they got the typical rude welcome He had no idea of what to expect when he got there (07:35) They had to take aptitude tests, but they did not necessarily dictate where soldiers went Basic training was not very difficult for him (08:38) He was familiar with weapons before he entered camp o There were some men who found training extremely difficult (09:05) The majority of the men in his training company were primarily from Michigan o There were some blacks in his company (09:55) �• • • • • • • • • • • •  They made it a similar percentage to the population as a whole Basic Training lasted 3 months (10:23) After basic training, you receive your orders – advance individual training He was then flown to Fort Polk, Louisiana (11:04) Fort Polk was very similar to For Knox o It was maybe more advanced in some areas Fort Polk had mock Vietnam villages and mock scenarios for training (12:04) The instructors were soldiers that previously served in Vietnam o The instructors had a lot of apathy while training (13:34) He was offered the option of becoming a helicopter pilot but he declined it because he did not want to extend his two years (14:34) He trained on the M16, M14, M60 machine gun, 45, grenade launchers, etc. (15:20) He spent 3 months in Advanced Individual Training (AIT) (15:39) He was able to go home for Thanksgiving in November, 1969 After his leave, he was sent to Fort Lewis, Washington (16:12) They were in Washington waiting to replace others in Vietnam o It was extremely depressing – they were at the end of the war and many of the soldiers knew what was going on o They were waiting around for three days Active Duty – (17:18) • • • • • • • • • • • • He is then sent to Vietnam via charter plane (17:25) o They went through Alaska, Japan, and Cam Ranh Bay (17:37) o The ride was extremely depressing o There were stewardesses on the flight – they tried to cheer the soldiers up (18:11) They landed at Cam Ranh Bay during the day (18:29) It was extremely hot After he gets off the plane, they went to their replacement company (19:15) They were taken on cattle trucks up the coastline of South Vietnam o He was able to see how poor the people were and experience the culture They had armed escorts in a convoy (20:29) The drive took 3-4 hours (21:32) He found out when he was in Cam Ranh that he was assigned to the 101st Infantry He was first assigned to Bravo company 1st Battalion, 327th Infantry Regiment (22:37) There were men who took pills that they thought would give them symptoms of malaria when they were out on the field o All three of the men died soon after taking the pills (23:29) The unit stayed for 5-6 days in the camp before heading out (25:06) The new soldiers are shunned when they first arrived (25:28) o You are considered an idiot until you have proved yourself �• • • • • • • • • • • • • • • • • • • • • • • • • The first mission he went on, he saw a woman hit with an M79 grenade round (27:00) o The round did not go off (27:06) o The decision was made to not report the incident – the woman and her child were both murdered o This was part of an ambush outfit (27:50)  They were on high alert and the observation post shot He initially operated in the Triple Canopy jungle (30:16) When he is sent up to the triple canopy jungle, they were trying to locate movement at night and locate positions or activity (31:12) o They were the average recon unit o The platoon was 30 men On their reinforce recon missions, they were locating the enemy (32:33) He remembers seeing a young soldier cut in half by an M60 The first time he was in regular combat situation was in April, 1970 There had been a previous company that had gone into an area and had been cut up (35:42) On April 14, 1970, his unit was being hit with mortars all day The wounded could not be extracted from this fight because everything was socked in (38:29) His platoon went in to locate the base (38:41) They could not find it for four days, so they sent out a dog ahead of them The Vietnamese waited until his platoon walked into their position (39:58) They were hit with napalm There were 200 mortars electrically wired together to wipe out his platoon, but because they moved in so fast, they did not have the time to set it up (41:13) The order to attack quickly, though it sounded crazy, actually worked o The Vietnamese did not have time to get ready Just before the battle they were being resupplied (42:11) When they went in, they were short on supplies (42:33) The majority of his tour was spent doing many of these kinds of missions They always seemed to use the same tactics (43:12) o Move at night, reinforce recon, etc. They were still operating in the triple canopy jungle o He was primarily on the eastern side – Elephant Valley Missions were meant to find any kind of contact activity (44:18) He rarely saw the NVA (North Vietnamese Army) – they were extremely disciplined The NVA used bunkers and caves He would spend 7-30 days on different missions (47:02) o Depending on the commander, but they would often get a break after 30 days When on patrol, the men in the platoon were generally extremely disciplined and focused on the job (48:06) �• • • • • • • • • • • • • • • • • In order to stay safe while marching at night, you have to maintain contact with the person in front of you (48:44) o They would move on trails at night o There were many problems with booby-traps and ambushes (49:15)  The point man would have to look for them They seldom cut directly through the jungle He remembers seeing rock apes and getting rocks thrown at them (50:42) o There were tigers that caused troubles for troops o There were extremely poisonous snakes o It was like fighting in the Garden of Eden (52:14) o There were fox bats that would turn the sky black (52:25) It was extremely common for men to get diseases from being in the jungle He developed cellulitis (53:25) When men would return to camp, they would typically get drunk or smoke pot (55:22) o This was before heroin became available o After heroin arrived, there were racial problems as well as many other problems o He noticed the heroin problem in August, 1970 (55:56) o After returning from R&R, he noticed the heroin abuse Before heroin there was some racial tension, but it was isolated – it was profound once heroine addictions began o The heroin did not follow the soldiers into the field (56:49) There was a lot of marijuana abuse (57:11) He got the cellulitis in February, 1970 (58:03) Once he got sick, he was sent back to Camp Eagle When he was on R&R he went to Sydney, Australia (58:55) o He was able to pick his destination o It was culture shock to experience Australia after spending nearly half a year in Vietnam o The Australians were extremely nice to American soldiers o It was incredibly difficult to get back on the plane to go back to Vietnam (59:40) He did not have any idea what was going on with the war at large (01:01:19) The last mission he remembers was in October, 1970 (01:03:09) His unit was close to the Laotian border o They were protecting the artillery units that were firing into Laos One of the most dramatic parts of his service was the battle of Hill 882 along with the 502nd infantry – the battle lasted from April until June (01:04:30) o The 502nd infantry never had historical explanations as to what happened to their unit He believes the 101st underestimated the commitment of the NVA (01:06:20) o The military changed from an offensive position to a defensive posture He never lost respect for the NVA �• • • • • o Remembers seeing them standing up and trying to shoot down jets with their AK-47s (01:09:42) When he was out on the field, he typically carried a machine gun or an M16 The air support that the Americans would call in was superb o The NVA would try to get as close to the Americans as possible in order to negate the air power (01:10:58) o They would sometimes have to call in air support on themselves o They support was generally quick and accurate After R&R, he went through a period of depression and remorse (01:12:34) He was able to get close with some of the men in his unit (01:13:36) Some of the sergeants he served under were “shake ‘n bake”, but they did the job (01:15:45) o The sergeants and lieutenants usually provided great leadership (01:16:17) After the Service – (01:17:05) • • • • • • • • • • • • He was able to go home a little bit early from his tour – October, 1970 (01:17:13) He spent a week in Phu Bai, Vietnam before he got on a plane to return to America o When waiting to find out when he would leave he just hung out (01:18:19) o The atmosphere on the plane was extremely depressing (01:18:50) His first landing was at Fort Lewis, Washington He had changed out of his military clothing into civilian clothing On his leave home, he spent time getting drunk (01:20:42) After his leave back home he was sent back to Fort Knox He was encouraged to re-enlist after he was discharged (01:22:46) o They offered to make him a sergeant In general, he had not had much contact with civilians in Vietnam (01:24:31) There were Vietnamese spies within his units (01:25:20) o There was an old man o Some of the men were useful but some were not  He saw one of them selling heroin When he came home, he went crazy for a couple of years doing crazy things (01:26:34) o He suffers from PTSD – it was dormant until it was triggered in 1976  It was triggered when he knew and saw someone that was hit by a car  He was compensated for PTSD He believes the Army made him have a deeper feeling for religion (01:32:37) o He is not necessarily religious, but he understands it better now o It has been one of the largest influences on his life He does not like to dwell on the negative things in the war (01:33:13) o He did certain things for his fellow soldiers not because he wanted to � Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Veterans History Project Creator An entity primarily responsible for making the resource Grand Valley State University. History Department Description An account of the resource The Library of Congress established the Veterans History Project in 2001 to collect memories, accounts, and documents of U.S. war veterans from World War II and the Korean War, Vietnam War, and conflicts in the Middle East and elsewhere, and to preserve these stories for future generations. The GVSU History Department interviews are part of this work-in-progress, and may contain videos and audio recordings, transcripts and interview outlines, and related documents and photographs. Coverage The spatial or temporal topic of the resource, the spatial applicability of the resource, or the jurisdiction under which the resource is relevant 1914- Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/page/InC/1.0/?language=en">In Copyright</a> Subject The topic of the resource Afghan War, 2001--Personal narratives, American Iran Hostage Crisis, 1979-1981--Personal narratives, American Korean War, 1950-1953--Personal narratives, American Michigan--History, Military Oral history Persian Gulf War, 1991--Personal narratives, American United States--History, Military United States. Air Force United States. Army United States. Navy Veterans Video recordings Vietnam War, 1961-1975--Personal narratives, American World War, 1939-1945--Personal narratives, American Publisher An entity responsible for making the resource available Grand Valley State University. University Libraries. Special Collections & University Archives Contributor An entity responsible for making contributions to the resource Smither, James Boring, Frank Relation A related resource Veterans History Project (U.S.) Identifier An unambiguous reference to the resource within a given context RHC-27 Language A language of the resource eng Source A related resource from which the described resource is derived <a href="https://gvsu.lyrasistechnology.org/repositories/2/resources/455">Veterans History Project interviews (RHC-27)</a> Oral History A resource containing historical information obtained in interviews with persons having firsthand knowledge. Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Identifier An unambiguous reference to the resource within a given context McCormickTNoId Title A name given to the resource McCormick, Theodore (Interview outline and video), 2012 Creator An entity primarily responsible for making the resource McCormick, Theodore Description An account of the resource Ted McCormick was born in Standish, Michigan and grew up in Flint, Michigan. He graduated from high school in 1968 and received his draft notice in 1969. He took basic training at Fort Knox, Kentucky, and infantry training at Fort Polk, Louisiana. Sent to Vietnam, he was assigned to an infantry company in the 101st Airborne Division. His unit went on patrols in the jungles of northern South Vietnam and encountered its share of firefights, ambushes and booby traps. In the last few months of his tour, which ended in October, 1970, he observed the effects of readily available heroin in the rear areas, and an escalation of racial tensions. Contributor An entity responsible for making contributions to the resource Smither, James (Interviewer) Subject The topic of the resource Oral history Veterans History Project (U.S.) United States--History, Military Michigan--History, Military Veterans Video recordings Vietnam War, 1961-1975--Personal narratives, American United States. Army Language A language of the resource eng Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/page/InC/1.0/?language=en">In Copyright</a> Type The nature or genre of the resource Moving Image Text Relation A related resource Veterans History Project (U.S.) Date A point or period of time associated with an event in the lifecycle of the resource 2012-04 Source A related resource from which the described resource is derived <a href="https://gvsu.lyrasistechnology.org/repositories/2/resources/455">Veterans History Project Collection, (RHC-27)</a> Format The file format, physical medium, or dimensions of the resource application/pdf video/mp4 Publisher An entity responsible for making the resource available Grand Valley State University. University Libraries. Lemmen Library and Archives https://digitalcollections.library.gvsu.edu/files/original/c40be73e065f80db25aa63db2079b377.mp4 cbd4d77be6efeaf4ef56f8c4bf17ca94 https://digitalcollections.library.gvsu.edu/files/original/ba4b0193b69cc987cf5531f43dd34a78.pdf dd0616e88f18a1769f8045196f494507 PDF Text Text Grand Valley State University Veterans History Project Interview Vietnam War Jim McCoy 1:31:51 Introduction (00:19)           Jim was born on August 29, 1951 in Santee, California, which is about twenty miles east of San Diego. He grew up in Santee and graduated from high school there in 1969. In high school, everyone was aware of the war, and most of the guys in his class all had plans of joining one of the branches of armed forces after graduation. College was not an option for Jim, but he later attended junior college. Growing up, his dad was a machinist at Ryan Aeronautical which is famous for their part in developing Lindbergh‟s airplane. He worked there until the day he died. Looking back on his childhood, they were lower middle class like many other families in that day. During high school, he saw the movie “The Green Berets” starring John Wayne and thought it would be fun, so in order to beat the draft, he and another guy went down and enlisted in the United States Army. (02:39) Jim enlisted for three years thinking that he was going into Special Forces. Prior to his enlistment, he did not participate in the anti-war movement nor did anyone in his town. The two biggest employers in the area were all defense companies. Jim enlisted in December 1969. Military Training (03:55)          Jim was sent to Fort Ord, California for his basic training. He was sent to Los Angeles for his induction and physical. This was where all inductees from all the branches were sent including draftees. For the most part, not many people were trying to scam the system to get out of service, but Jim does remember standing in line and someone calling ten names and saying “Congratulations, you‟re going in the Marine Corps”. (04:46) Jim‟s parents were extremely disappointed that he joined the Army instead of the Navy because San Diego was a Navy town. They were bussed all the way north to Fort Ord, which is in the Monterey area. When they got there, the drill sergeants got on the bus and started yelling at everyone. He was there for two weeks and then everyone was sent home for two weeks for Christmas. His company in basic training was comprised mostly of draftees with a few other enlistees like himself. (06:53) The draftees had bad attitudes, with one of them jumping out of a third story window and breaking his leg to get out of military service. Basic training was about learning how to be a soldier, marching and getting along. �            Physical aspects of basic training were relatively easy for Jim because he was 18 years old and in good shape, he also did not have much problem learning the discipline; since he volunteered for it he knew what he was getting himself into. For the people that caused trouble, the drill sergeant will single them out and give them extra duties and yell at them. (08:44) The drill sergeants were fair to everyone and treated everyone equally. Jim was chewed out a few times himself, whether he deserved it or not. Basic training lasted for eight weeks. Once that was completed he was sent to Fort Jackson, South Carolina to attend AIT (Advanced Infantry Training). AIT was not very pleasant, since they were treated very poorly by the sergeants who were all southern boys that were shake and bake‟s. Jim and the other guys from California were given all the KP duty and other jobs that nobody else wanted to do. Because he planned on joining Special Forces, Jim had signed up for jump school. He later learned that to be in SF you had to be at least nineteen and a half years old. Jim was still only eighteen and he also became fed up with the treatment that he was given at AIT so he signed a waiver saying that he did not want to go to jump school. (10:45) Only a few of the instructors there were Vietnam veterans. It was the assumption during training that they were all going to Vietnam. Most of the training was also geared in that direction teaching them some of the basics that they would need to know in country. AIT lasted another eight weeks. After that, 24 of the men were sent to Panama at Fort Sherman to go through jungle school, which lasted two weeks and was conducted in the Panama Canal Zone. This training was fun, and Jim really enjoyed it. Once they got there they were split into squads, each man had their rank taken away and everyone was put in the jungle and learned how to cut trails, eat food found in the jungle, ride on a slide for life over a river, make rafts for river crossing and rappelling. None of which actually helped in Vietnam except for getting a head start for SERTS (Screaming Eagle Replacement Training School) in Vietnam. Some of the physical conditioning helped though, because it was hot and humid in Panama like Vietnam and it rained a lot. (14:33) After he finished this training, he was given a three day leave. On that leave period, Jim told his parents that he was going to Vietnam. Vietnam (15:34)      Jim went to Travis Air Force Base in California and was issued some clothing and received some shots before being put on an airline and flown to Hawaii where he bought a pack of cigarettes for sixty cents (which was a lot back then for smokes). From Hawaii they were flown to Thompson Airport in Saigon. The plane ride over was quiet and not upbeat at all. It was a chartered commercial airline that they were flown over on. (16:53) They landed in Vietnam in the afternoon, and he remembers when they first opened the door of the plane they could feel the heat rush in. Jim was sent to Bien Hoa, which was the main processing center for people coming into country. While there, they asked for volunteers to pull guard duty and they were promised a good assignment, and that they wouldn‟t be sent to the 101st. He volunteered and stayed there for three weeks standing this duty. �   Jim arrived in Vietnam in May 1970. (18:10) Other operations were going on in Vietnam, but Jim did not pay much attention to them and he did not bother with the news. He just focused on doing his job. He heard rumors about what was going on up north. While in Bien Hoa he never left the base and he doesn‟t remember any attacks or incomings there. Ripcord (20:20)               Jim was reassigned to Phu Bai which was to the north and was in the AO (Area of Operations) for the 101st Airborne. They were flown in on C-130‟s and they were processed into the 101st. He did not have a weapon at that point but was given one once he started SERTS. SERTS consisted of classes on booby traps, cultural issues in Vietnam and dealing with the locals. After the training, Jim was assigned to Delta Company, 1/506th. When he met up with his unit, they were on a stand down having a party. (22:47) The first thing that he did was throw away all the gear that he didn‟t need like mosquito netting. He fell right in with 1st platoon and was sent out on his first mission. Since he was a new guy called a „cherry‟ he was assigned to be an ammo bearer for a machine gun team. His machine gunner, Brian Redfern, took Jim under his wing and taught him what he needed to know. (24:37) After the company party, they left the next morning on their first mission. Jim got his rucksack on and they all moved out to the LZ for the helicopters at Camp Evans. They were given their flight assignments and some of the guys gave him some last minute advice while in the air. Jim was scared because he was sitting on the edge of the door with his feet dangling out with his rifle pointed outwards. The heavy rucksack on his back helped keep him balanced in the chopper. (26:56) They landed on Triple Hill, and they got out and looked around. The jungle was all chewed up from all of the incomings and shooting. Immediately after landing, they started sending out patrols. This was his first day in the field. During that patrol, they found underground bunkers that included hospitals and artillery positions. They did not take any fire at that time and did not see the enemy. Once they finish their patrol they set up a NDP (Nighttime Defensive Position). The company had about 86 men. Each platoon had about 20-25 men in them. (29:54) That first night, Jim was on fire watch and he heard something that sounded like “Fuck You”, which turned out to be the call of a gecko lizard. They found lots of new bunkers and fortifications but still had not found any NVA or Viet Cong. Four days into the field mission, they were picked up by helicopter and taken just outside Firebase Ripcord, which was under bombardment from the enemy. Jim remembers flying around it and seeing that it had such steep edges going around it. (32:56) �                While flying around the LZ, they saw red smoke, which means that it was a hot LZ. Jim jumped out of the bird as soon as it landed and ran to the side of a hill. He could hear the AK-47 fire, and Jim was still carrying the ammo for the machine gunner. Captain Workman was his company commander, and he reported to higher that all his cherries survived the landing. Jim and his machine gunner set up a position covering a trail leading up the hill. Jim saw the top of a boonie hat coming down towards them and asked if they had any friendlies up there, which they did not. His machine gunner then opened up on the trail. (37:35) Jim looked over to another soldier, Tommy Smith, and he wondered why he wasn‟t firing so he threw him some ammo. Jim looked over to him and asked if he was ok, and he said his gun jammed. He told Jim that a NVA soldier was so close to him he could have reached out and shook his hand. Things got worse as the day went on. They formed up a patrol and began going up the hill. Once they got to the top, they found a trench with trails going to and from it into the jungle. (39:30) Jim was sitting on a trail watching below when he saw an enemy soldier crawling up the trail on his belly. Jim raised his rifle and the NVA saw him and sat up on all fours, then Jim switched his M-16 to fully automatic and began firing. He doesn‟t know if he killed him or not, but it was very weird firing at another human being for the first time, it was a life changing experience. (41:58) That afternoon, a patrol was ambushed and several were killed along that same trail that Jim had shot down. Another patrol was sent down to gather the wounded and the dead. The worst memories that Jim has of Vietnam were hearing the moans of the wounded men before the NVA finished them off. (44:35) They came back down the hill to the LZ and gathered their wounded and brought them down to be flown back. Ripcord was firing illumination rounds to aid in the extraction. They did not take any fire while they were getting the wounded out. (46:35) That night was quiet, with the only activity that could be heard was far off in the distance. In the morning, they began taking incoming mortar rounds. Nobody was dug in and it was chaos when the NVA realized that they were zeroed in on Delta Companies position. They began firing mortar round after mortar round. It was during this barrage that most of the men they lost in the battle were killed. (48:49) During the attack, Jim was huddled under his rucksack waiting it out. The man next to him was hit and Jim took out one of his bandages and helped the man. One man stood up and yelled “Let‟s get out of here!” so they began to grab gear and bodies and started heading down the hill. Jim was one of the few guys that was not wounded at that time, so he helped get some of the wounded down to the waiting helicopters. Helicopter pilots were radioing them and telling them that they had 500 NVA moving towards their position. (52:52) They had airstrikes coming in and dropping bombs all day long. Jim was on the perimeter protecting the group of survivors during this battle. At one point, their company was down to 14 men. Jim was extracted later that day; Captain Workman made him run out to the LZ to get on the bird. When he got in the bird everyone was cheering �     and happy that they made it out. The door gunner told them that the bird just behind them did not make it out, and Jim later found out that Captain Workman was killed by the rotors of one of the choppers as he was trying to bring in the last bird. (57:37) Once they returned to Camp Evans, Jim felt numb and in shock. His first sergeant came up to him and told Jim that he wasn‟t a cherry anymore. One soldier took off his rucksack and realized that he had a piece of shrapnel sticking out of his back and he didn‟t even know it. A couple of days after getting back to base, they had a memorial service for Captain Workman. (59:44) At that point, the company size was 33 men, and that was after they got their replacements. They spent the next three months trying to build up their unit again and conducted firebase duty. After that they were tasked with blowing out landing zones for helicopters. Eventually, they were up to strength to where they could go back out on missions. During this buildup period, they did not have any engagements with the enemy and things were relatively quiet. (1:02:16) After Ripcord, they didn‟t find much on their patrols and most of the enemy contact was in the form of booby traps. After Ripcord (1:04:20)            They spent up to two months at a time in the field. Jungle rot was a big problem with most guys, and some also got dysentery and cellulitis. At that point, they were still operating with Vietnamese scouts, which Jim found to be worthless. He had one assigned to him once he was promoted to sergeant. (1:06:55) When Jim was recommended for the promotion, he was taken back to the rear, cleaned up, took some tests and then sent him back out. He received his orders in December saying that he had been promoted. (1:08:32) They got letters from home whenever they could get the mail out to them. When the choppers could not land, they would sometimes hover over the men and just kick out the mail and go. Almost all of Jim‟s time in country was done in the field. He was told that he could go home for R&R, so he did. Although he wishes that he would have gone to Bangkok or some other place instead of going home. (1:10:25) Going from the jungle to the civilian world was weird for him and he did not talk about it much with anybody. While home, he saw all the protesting that was happening back in the states. After he got back to Vietnam, he had a couple more months to go before his tour was up. Jim did not spend much time with the civilian population. He once spent two weeks guarding a village that was about to hold a democratic election. On that mission he went out on a sniper mission with two other guys. (1:13:39) Racial tensions were very high, especially in the rear. It was always blacks against whites on base, but in the field it was all gone. Most of the men in the rear were black men that found ways to stay out of the field or were drug addicts. There were no drugs or drinking in the field and no smoking in the field after dark. �     Some fights would break out between whites and blacks. On one occasion a white soldier shot and killed a black soldier over drugs. (1:15:44) They also had men that would shoot themselves in the foot to stay out of the jungle. Each man was given a leave home, which he already took and they were also given an R&R. Jim signed up to go to Sydney, Australia without a dime to his name. (1:17:57) When he was getting ready to get on the bird to go, his friend came out and told him that he only had ten days left in country. He was processed out in Phu Bai and then he flew home. The mood on the plane was great, people were yelling and screaming and jumping for joy. Back in the States (1:19:41)        They first landed in Tokyo, and then they flew straight in to Fort Lewis, Washington. When they got there they were all given a steak dinner. Each man was given a class A green uniform with all their ribbons and stripes ready for them. (1:20:20) Jim flew home to San Diego in uniform, but he did not have any troubles with protestors. He was given a thirty day leave once he got home, before he had to report back in. After living in the environment of Vietnam, it took some time to readjust. Jim was originally slated to go to Fort Benning, Georgia to be an instructor at the infantry school, however, at the last minute he was sent to Fort Riley with the 1st Infantry Division. They went to Germany for a month and conducted war games with several other nations. (1:22:50) While in Germany, they were convoyed with their tanks and they did have some opportunities to visit local villages and try the beer and the food. They were able to spend one night in Nuremburg for R&R. Jim was later offered a chance to get out of the army early if he was willing to spend a year in the active reserves. When he got out, he had spent a little more than two years active duty. (1:24:20) Civilian Life (1:24:24)      When he got home to San Diego, he got a job working as a custodian at a recreational club. He started attending junior college and became interested in law enforcement. Eventually he wound up joining the California Highway Patrol and was stationed in Central Los Angeles. Jim stayed with the CHP for twenty eight years. He retired after that and spent one year in Iraq and one year in Afghanistan as a police advisor. (1:26:14) His first tour was in Afghanistan and his second was to Iraq. He went in to villages and worked with local police officers and taught them how to do different things. Jim would also talk with them about their criminal justice system and went on patrol with them on the streets. (1:28:41) When he was in Iraq, his first sergeant found out about his Vietnam experience and presented him with a 101st Airborne patch. Both of his tours were horrible and he would not recommend people to do that, but he did learn about those cultures and a little bit of the language. � Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Veterans History Project Creator An entity primarily responsible for making the resource Grand Valley State University. History Department Description An account of the resource The Library of Congress established the Veterans History Project in 2001 to collect memories, accounts, and documents of U.S. war veterans from World War II and the Korean War, Vietnam War, and conflicts in the Middle East and elsewhere, and to preserve these stories for future generations. The GVSU History Department interviews are part of this work-in-progress, and may contain videos and audio recordings, transcripts and interview outlines, and related documents and photographs. Coverage The spatial or temporal topic of the resource, the spatial applicability of the resource, or the jurisdiction under which the resource is relevant 1914- Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/page/InC/1.0/?language=en">In Copyright</a> Subject The topic of the resource Afghan War, 2001--Personal narratives, American Iran Hostage Crisis, 1979-1981--Personal narratives, American Korean War, 1950-1953--Personal narratives, American Michigan--History, Military Oral history Persian Gulf War, 1991--Personal narratives, American United States--History, Military United States. Air Force United States. Army United States. Navy Veterans Video recordings Vietnam War, 1961-1975--Personal narratives, American World War, 1939-1945--Personal narratives, American Publisher An entity responsible for making the resource available Grand Valley State University. University Libraries. Special Collections & University Archives Contributor An entity responsible for making contributions to the resource Smither, James Boring, Frank Relation A related resource Veterans History Project (U.S.) Identifier An unambiguous reference to the resource within a given context RHC-27 Language A language of the resource eng Source A related resource from which the described resource is derived <a href="https://gvsu.lyrasistechnology.org/repositories/2/resources/455">Veterans History Project interviews (RHC-27)</a> Oral History A resource containing historical information obtained in interviews with persons having firsthand knowledge. Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Identifier An unambiguous reference to the resource within a given context MCCoyJ1551V Title A name given to the resource McCoy, James (Interview outline and video), 2013 Creator An entity primarily responsible for making the resource McCoy, James Description An account of the resource Jim was born in Santee, California on August 29, 1951. After Jim graduated from high school in 1969, he decided to beat the draft and enlist in the United States Army. He was sent to Vietnam in May 1970 and worked as a base guard at Bien Hoa. After some time, he was reassigned to 1st Platoon, Delta Company, 1/506th, 101st Airborne out of Camp Evans. Jim took part in the attack at Firebase Ripcord. After getting out of the army, Jim joined the California Highway Patrol and served for twenty eight years. After retirement from the CHP, Jim went to Iraq and Afghanistan and worked as a police advisor to local police departments. Contributor An entity responsible for making contributions to the resource Smither, James (Interviewer) Subject The topic of the resource Oral history Veterans History Project (U.S.) United States--History, Military Michigan--History, Military Veterans Video recordings United States. Army Vietnam War, 1961-1975--Personal narratives, American Language A language of the resource eng Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/page/InC/1.0/?language=en">In Copyright</a> Type The nature or genre of the resource Moving Image Text Relation A related resource Veterans History Project (U.S.) Date A point or period of time associated with an event in the lifecycle of the resource 2013-10-10 Source A related resource from which the described resource is derived <a href="https://gvsu.lyrasistechnology.org/repositories/2/resources/455">Veterans History Project collection, (RHC-27)</a> Format The file format, physical medium, or dimensions of the resource application/pdf video/mp4 Publisher An entity responsible for making the resource available Grand Valley State University. University Libraries. Lemmen Library and Archives https://digitalcollections.library.gvsu.edu/files/original/17114e18c67f0d9cecc0d8807b0e65e9.mp4 f431b2f42b08a727037ee572400ac60d https://digitalcollections.library.gvsu.edu/files/original/92c8cf0a53f5a8d748c2e575d0bfbaaa.pdf 53619c66253afeef71e5004a43ba3880 PDF Text Text ORAL HISTORY INTERVIEW JOYCE BARNES McCOY A player in the first year of the league 1943 Women in Baseball Born: 1925 Hutchinson, Kansas Resides: Interviewed by: Gordon Olson, GVSU Veterans History Project, September 27, 2009, Milwaukee, WI at the All American Girls Professional Baseball League reunion. Transcribed by: Joan Raymer, September 16, 2010 Interviewer: “Now Joyce, before we get into talking about that first year of the league let‟s put some background information on the table. Tell me, if you will, when and where you were born and a little bit about your family, your parents, and that sort of thing.” I was born on a farm south of Hutchinson, Kansas. My father was a farmer and my mother had an uncle that had been in the oil business down in Louisiana and he became ill and couldn‘t work any longer, so he bought this farm and he needed somebody to run his farm, so that‘s where I was born, was on this farm. Interviewer: “And what year was that?” 1925 Interviewer: “October?” October 18th Interviewer: “October 18th 1925. Your parents‟ names?” Edward J. Barnes and Ethyl Amy Chase. 2:06 Interviewer: “All right now, we‟ll jump right into your youth. At some point you start playing ball. You obviously enjoyed playing ball and how did it come about— because it wasn‟t always what young girls did at that time, out playing ball.” 1 �I had two older brothers, a younger sister and a younger brother and those days were kind of hard times. You didn‘t have a lot of money, but we were happy and we played and we played ball. Interviewer: “What kind of equipment did you have to play?” Not very fancy and I didn‘t even have a ball glove until I was in grade school and got on a ball team. Interviewer: “The ball got batted around and you would stick it back together?” Yes, we played with whatever we could find. Interviewer: “If the bat broke you tapped it back together. You developed some skill at the game though?” 3:06 Well, when I was in sixth grade we moved to—we had lived in a little settlement close to the city of Hutchinson and then we moved farther out into the country and I went to a little country school and I guess I was the biggest girl in the sixth grade, so the teacher just decided I was to be the pitcher and that‘s when I really got started. Interviewer: “Kept playing—did you play in any kind of organized teams or leagues during that period of your life?” No, we played against the other grade schools, all the other little country grade schools. Interviewer: “And they would bus you I guess, or take from one school to another.” By car Interviewer: “By car from one school to another?” Yes Interviewer: “that can get to be some pretty intense rivalry once and a while?” 2 �Yes it was, I had some cousins in another grade school and they were pretty competitive. One of the girls was older than me and she was a little better. 4:16 Interviewer: „You had to establish who was in charge there. Ok now, you play ball and you‟re getting pretty good at it. At what point did it go--?” When I went to high school the girls couldn‘t compete, they were not allow, they thought it was too strenuous for girls to play ball and I know, I was a freshman in high school and my oldest brother was a senior and the basketball coach told him that he sure wished I was a boy. Interviewer: “What was permitted for the girls?” Well, we played tennis, we could play some tennis and we had one year of physical education and that was all and we had intramural, but we couldn‘t compete with other schools. 5:05 Interviewer: “Did you play any version of basketball?” Yes, when I played there I had to play the girls rules, but when I was out in a—I was in a country school where they had—the goals were outside and we played in the dirt and we played boys rules then. Interviewer: “I think for some of the people that will look at this interview, we may have to explain just a little bit what girls rules were. Can you do that?” The forwards played—they had a line at the half court and the forwards played on the front and the guards played on the back part and guarded the forwards of the other team. 5:52 Interviewer: “So the guards could only come up to half court and had to pass the ball into the offensive zone really.” 3 �When I was a freshman in high school they had a tournament in a little grade school called Willis, which was east of my high school and the teacher, one of the teachers wanted me to come and referee the game, so they let me out of school and I went over and refereed the grade school game and if a person, a girl, had a hold of the ball and the other one came up and put their hand on it, that was a foul. Interviewer: “Didn‟t have to touch the person, just touch the ball?” Just touch the ball, that was a foul. They didn‘t have any-Interviewer: “Certainly no type guarding or anything of that sort.” No, no Interviewer: “And that form of basketball persisted for quite a while actually in some states I know. Before they finally decided girls could stand a little more strenuous activity.” 6:57 When I was out of high school I went to work at the American Optical Company as an optician and there were several women about my age and we rented a junior high gym and we played boys rules and one night a Catholic Priest came in and he said, ―can I bring my young boys over to play a game with you?‖ We said, ―sure, come ahead‖, so they came over a few times. The first night they came we were there practicing and I said, ―they probably want a basketball‘, so I dribbled to the halfway mark and threw the ball and it went through the hoop. Interviewer: “That‟s known as intimidation, that‟s what that is.” Well, they came a few times and one night we went to play them and here came the priest by himself and he said the nuns found out they were playing against the girls, so that was 4 �a no, no, but I did join a—we had a group of girls that—I think the Adla Hale Business College kind of sponsored a team and I played against them some. 8:12 Interviewer: “You continued—were jumping ahead, but we‟ll finish this thought. You continued in sports after you had played as a professional baseball player for a year?” I wasn‘t there a year; I was just there a short time. I read an article in the Hutchinson News, I was still in high school and Fred Mendel was a sports writer and he said that Phillip Wrigley was starting this professional women‘s softball team, so I wrote him a letter and he answered me, Ken Sells was—and said they wouldn‘t have any coaches or scouts in my area, but they would pay my transportation and that was during the war and my mother didn‘t want me to ride on the train by myself. 9:09 I wrote him another letter and they said your mother is welcome to come, but we won‘t pay her expenses, so we got on the train and went up there and-Interviewer: “Up there being Chicago?” Yes, to Chicago and we went to the Wrigley Building and Ken Sells interviewed me and he said, ―well, we‘re going to put you with the Kenosha team and they‘re in Rockford right now. He said, ―I‘ll be off work at five o‘clock‖, and he took us up to a room that had a lot of beds and he said, ―you better go to bed and rest‖, and I thought my mother needed it worse than I did and he said, ―I‘ll come and get you and put you on the train to Rockford‖, so then we went to Rockford and she met—there was some older man that was kind of a scout and then she met the coach and the chaperone and she decided that I was safe, so she went home. 10:10 5 �Interviewer: “I wonder if that older man was Johnny Gottselig, he did a lot and represented Wrigley in a—it wasn‟t a tight well run organization at first. They were just putting it together.” It could have been him and that team coach, manager, was--he said he had been in Topeka, Kansas and I can‘t—I‘m having a senior moment and I can‘t think of his name right now, but he didn‘t stay any longer than I did. Interviewer: “he decided his future wasn‟t managing a women‟s baseball team?” Well I don‘t think they gave me took much of a tryout. They let me pitch. I went to the field and they gave me an outfit and shoes and their little dresses and things and I practiced with them and we went to South Bend, Indiana and played and see, there were just four teams, and we went to Racine and I think I pitched at Racine, but then I was there three weeks and they paid me forty dollars while I was there and then they finally— some young woman, she was older than I, came and they decided they wanted her instead of me, so they-- 11:42 Interviewer: “You got your release.” Yes Interviewer: “How old were you at this point?” Seventeen Interviewer: “Seventeen years old.” I was a roommate of Audrey Wagner. She and I were—she was just a little bit younger than I, maybe not quite a year. Interviewer: “When you say roommates, where did you stay?” 6 �We roomed with the Hill family. Mr. Hill had been a circus performer and he had been in an accident and both of his legs were broken, so they had a house and they rented out rooms. There was a lady, a corset sales lady, and she took Audrey and I to the picture show one night and they also took me to a beer joint. It wasn‘t a very good place and I wasn‘t use to that sort of thing. Interviewer: “That‟s all part of growing up.” I got kind of sick, of course Audrey, she was a German and used to drinking beer and it didn‘t bother her. 12:46 Interviewer: “So that was one of your first introductions to drinking beer?” Right Interviewer: “The league is responsible for so many things.” We sure had a good time. There was a lady from Canada, she was twenty-four years old, Kay Bennett, and she roomed in the same house and she looked after Audrey and I and kept us out of trouble. Interviewer: “Now you said you pitched, had you been playing, like in high school, on summer teams or anything like that?” Well, just on summers teams, pitching. Interviewer: “So you had experience as a pitcher?” Yes, when I was thirteen years old, I take that back, when I was thirteen years old , still in grade school, I could run so fast—they had ten players on the softball team at that time and they had a roving short which played in-between the outfield and the infield and I covered that whole area. 13:39 Interviewer: “You were what they call the short fielder.” 7 �Yeah, and I covered that whole area because I could run fast. Interviewer: “That also means you probably could throw pretty well because that‟s the other job of the short fielder. Cover the ground, get to the ball and in some cases even throw people out at first if they‟re not hurrying down to the base.” Correct, and I played every position but catcher. Interviewer: “Let‟s talk about the game that you got introduced to during that time that you were part of the All American Girls because it‟s not quite softball. They were starting to move away a little bit weren‟t they in terms of the length of the bases?” I don‘t think so, not when I was there. I think it was what I was used to playing on. Interviewer: “Ok, ok.” And the ball was about the same. Interviewer: “The leadership of league, Wrigley and those around him, grappling with just what they wanted to present as entertainment and trying to sort out if it was going to be baseball or softball or how it was going to be distinctive.” 14:58 They were still doing softball. Ms. Harney, she pitched more like I did—they didn‘t do the ―windmill‖. Interviewer: “So how did they—if they didn‟t do the “windmill” how did they?” You just threw it. There at home, my catcher, she‘d take her glove off and she had a pretty sore hand. Interviewer: “So even though it was underhand, you weren‟t allowed to come up and throw sidearm, strictly underhand?” Well, in the league there they let them throw sidearm I think. 8 �Interviewer: “So can you throw a breaking pitch just drawing back and throwing like that?” Well, I had a little bit of stuff on it. Interviewer: “Ok, ok.” I know some of them couldn‘t hit it. Interviewer: “That‟s what matters. 15:50 Well, another way—one more question, a little bit more about that, is that the best quality softball you ever encountered at that point, hitting better?” Yes, they were all good players. Let‘s see, Mary Lou Lester was the short stop, Shirley Jamison played, Janice O‘Hara was the first baseman, Peewee Westerman was the catcher, she was younger than I was and he let her—and Helen Nicole from Canada, I think they pitched her so much that she had a sore arm. Interviewer: “Which is not a good thing. A sixteen year old catcher, she had to know what she was doing back there.” She was good. She‘s no longer living. Interviewer: “Catchers pretty much run the show when they‟re out there.” That‘s right. Interviewer: “That‟s a lot of responsibility for someone that young.” 16:44 Audrey Wagner was a catcher, but they had her in center field. She didn‘t ever pitch when I was there. Interviewer: “So you had to be able to play more than one position?” Yes Interviewer: “Did you play other positions?” 9 �No, they just had me pitch, that‘s about it. Interviewer: “Ok, how about the field itself, was it a pretty good place to play?” Yes, it was a nice field. Interviewer: “Well groomed?” Right there in Kenosha, the Hills lived right on the lake, but after I was married we drove up there and it had all changed. The field that I played on in Kenosha is not there. Interviewer: “That happens unfortunately.” Right Interviewer: “I went back to a field that I once played on and there were forty foot trees and it wasn‟t that long ago.” I think they built houses in there now and the parks all gone. We would go down to the lake and Mr. Hill, he got his lawn chair; he had to watch after us. He said, ―you have to be careful there‘s maybe glass out there, so watch where you –you know people were careless. Pauline, what was her name? She was from Chicago, she‘s go out there and get on that pier and just dive in that cold water. I‘d step in there and my legs would hurt it was so cold. 18:05 Interviewer: “She was more used to it. How about the fans, did you have good crowds come out to watch the games?” Yes Interviewer: “Did they heckle or people questioning whether it was appropriate activity for women?” 10 �Yeah, we had a lot. I think we felt, I did anyway, more patriotic at that time, so when we went out on the field, the first thing we did was march out in a V for victory for the armed forces, that was more my idea. Interviewer: “That‟s how you started every game? With the national anthem?” Yes Interviewer: “That‟s a good point. You‟re seventeen; to what extent were you aware that in a way you were part of the war effort. Did you think about that or did they talk to you about that idea.” Not so much that, I thought about it, I thought our purpose was to entertain the troops and the defense workers, that‘s my idea. 19:15 Interviewer: “Did you have any perception at that point that Mr. Wrigley was also concerned that they were going to cancel regular, not regular, men‟s professional baseball?” Oh no, no, no, we were—not to do that. Interviewer: “That‟s not something he chose to share with all of you.” No, that wasn‘t my idea. I‘m not a women‘s libber, if that‘s what you want to know. Interviewer: “Well, that‟s a part of it—yeah, that‟s an interesting question because those who choose to look back now, see you in that role, those of you who played professional baseball.” That wasn‘t my idea. Interviewer: “Ok, it was just a chance to play ball?” Yes 20:05 11 �Interviewer: “It takes a certain amount of gumption for a girl in Kansas to just sit down and write a letter to Mr. Wrigley and say, “I want to come and play baseball or softball for you”. Did you tell your mother you were sending the letter?” She knew it. Interviewer: “Your mother supported you in all of this?” Yes, my dad, he was a fan of baseball. When we were in grade school the Phillies and the Athletics came, Connie Mack was there. Vince DiMaggio was in the outfield for one of the teams and daddy took us to the game and we saw all that. Interviewer: “After the seasons were over they would often do that and if you lived in Hutchinson, Kansas that was your chance to see major leaguers.” Mickey Mantle was from Oklahoma and he played on a Joplin minor farm team and we had a farm team and I quite often saw him play. He played shortstop. 20:58 Interviewer: “At that point. Did you have an inkling that this was a pretty good ball player even then, in the case of Mantle?” Yes, yes we did. 21:06 Bob Swanson was the pitcher for the Hutchinson team and he said he struck him out. Interviewer: “Well, he did strike out once in a while.” A friend of mine, Lauren Arnold, he said he played on the—and he said, ‗I made up my mind I wasn‘t going to let him get a hit off of me‖, but he said, ―I walked him‖. Interviewer: “One way to do it. So you‟re time on the team was how long?” Three weeks Interviewer: “Three weeks and then they decided they wanted a different pitcher, what did you do?” 12 �Well, I went into Chicago and I went to a game there, women played, and then I didn‘t tell my mother I was doing this, I left Chicago and I had an aunt in Jefferson City and I got on the train and went to Jefferson City. If my daughter would do that I‘d be frantic. My brother was there, my aunt worked in a bakery there and I didn‘t even know my aunt‘s address, but I knew the bakery‘s address, so I went there and they happened to be working. I‘m very adventuresome. 22:21 Interviewer: “so you stayed there for—“ A couple of weeks and then my brother and I got on the train to got home. He had to go into the service. He was going into the V12 training and so, what‘s this drummer, Gene Krupa, he was going to put on a show in a Kansas City theater, so we got off the train in Kansas City and went to that show and it was really fun. Interviewer: “A little hard to go back to the farm after those experiences?” Yes Interviewer: “But you did and---“ We didn‘t live on a farm, we had four acres and we had a milk cow and chickens etc. My dad helped—it was hard to find jobs and he helped build the first nine holes of Prairie Dunes golf course. He said he needed a job and they said they were building this golf course, so he went over there and Claude Morris was the foreman and he said, ―well, you‘ll have to get you a Social Security Card‖, and it was in 1937 and he said, ―I can do that‖, and he went to work. 23:35 I was trying to think who the fella that laid out that course—the Carey family, the Emerson Carey family was big in Hutchinson and they started Prairie Dunes. You probably heard of it haven‘t you? Interviewer: “Yes, it‟s a well known course.” 13 �This fellow would come and he‘d drive out there and his big Pontiac car and he‘d say, ―Claude, I‘d like to have one of your men ride around with me, we want to look the sand hills over‖, and he said, ―ok‖ and he said, ―I‘ll take Ed Barnes‖, and my dad was really thrilled about that. He got to drive all over. Interviewer: “Get to consultant on the layout of the course a bit.” He was the waterman and they watered at night. He worked at night and he‘d walk the course and the pro lived there above the clubhouse and his wife would come down, she knew about what time my father would pass the clubhouse, and she would usually meet him with a cup of coffee and a piece of pie or something. 24:33 Interviewer: “Nice to be appreciated a little bit. Ultimately within a relatively short period of time, you‟ve gone to Chicago, tried out, very short tryout, been in the league, you‟re out of the league, you‟re back home. Tell me what came next?” Well, I had to finish high school. Interviewer: “It‟s remarkable to me that you young women were doing all that, so you went back and finished high school?” Yes Interviewer: “Did you continue in sports thereafter?” Just sandlot stuff and I played a lot of basketball. Interviewer: “Softball?” Yes, a lot of softball. 25:28 My class, we had intramural sports in high school, and when I was a freshman we won the basketball and we beat all of them even the seniors and we won the softball too. I have a little—it has Pepsi-Cola on there and a little softball and the year and I‘ve kept that. 14 �Interviewer: ―That was your trophy. How about other aspects of your life, you married at some point?” Well, after high school, my parents weren‘t wealthy and you had to pay tuition to go to college, so I went to work at the American Optical Company and we made army glasses. We put out a hundred pair a day. 26:30 Interviewer: “The army would outfit the soldiers.” And the families and we would get orders from Fort Sill; see it was in Hutchinson, American Optical Company. Fort Sill and different ones, Fort Leonard [Wood], I think, was in Missouri. I worked in the finishing lab and I enjoyed that work. Interviewer: “You stayed with them?” I worked until, even for a short time after I was married. Interviewer. “You married in?” 1947 Interviewer: “1947 and your husband had been in the service? Was he in the service?” He went into the service before the war started. He was six years older than me. I didn‘t know him until after he had come home from the service and that was in 1945. Interviewer: “Where did he serve?” He was a fourth class—see they started training pilots in Corpus Christi and he was the fourth class to go through Corpus Christi and they could choose if they wanted to go into the navy or the marines and he chose the navy because he thought he‘d have a good bed and good food. 27:33 They sent him to Alaska and on his way to Alaska, he was to fly sub patrol-- 15 �Interviewer: “They were concerned about submarines.” The Japs had sent some torpedoes in you know. When he got to the state of Washington they sent him out on a Coast Guard station and they had two fellas get in a plane and one fella tied a rope around his waist and he had a bomb here, we weren‘t prepared for war, and they flew out along the coast and if they saw a sub he was supposed to open that door and kick the bomb out. Interviewer: “Bombs away!” He said it was—those fellas really—it was frightening, it was frightening, but young fellas don‘t have the fear that the older ones do. 28:33 Interviewer: “Young women obviously don‟t either.” He said that was really a dangerous duty he had up there because there was so much fog. You had to fly by instruments because of the fog and also the mountains. You had to know so you didn‘t crash into a mountain. Interviewer: “You didn‟t have all of the devices they have on planes now.” They had seaplanes and he told one story about a pilot and his co-pilot, they went down and the pilot got—hypothermia sets in and he was gone, but the co-pilot, they were able to rescue him, so it was dangerous. Interviewer: “Yes, and all part of the war effort and all contributions in all different ways. Did he stay in the military then?” No, after he served eighteen months up there they sent him to—taught him to fly off a carrier, it was a Jeep Carrier, I don‘t know if you know what that is or not, it was a smaller carrier and they took tankers and destroyers, they took care of them. 29:55 Interviewer: “Now, they sailed as part of the—“ 16 �They went in the south Pacific and he flew a Wildcat, which is a F4 fighter plane, and he strafed the islands, Guam, Tinian, and I‘ve got his log book, the first flight he ever took, and strafed those islands before the landing crews went in. They also had torpedo bombers and there were two on that plane, he was alone. One reunion we went to they were talking and he said he was chasing this Jap Zero plane and all of a sudden he lost it and pretty soon the shells began exploding around him and he said, ―I knew that plane was around there somewhere‖, and he was looking for it and this other fighter pilot said, ―our own ships were shooting at McCoy‖. 30:54 Interviewer: “That‟s kind of discouraging.” He was in that terrible typhoon and it bent the flight deck down over the bow of the ship, the weight of the ocean came over, so they had to go into Hawaii. He served nine months there and they sent him to the south part of—in the desert of California and he was an instructor and then he flew a Hellcat, which is a F6, it was a little faster plane and he was an instructor there. He was just lucky to get home, he didn‘t get his discharge though until 1956. Interviewer: “He had a long commitment to the military.” He didn‘t serve any. Interviewer: The reserve? Some of the reserve?” Well, he didn‘t—he thought he would get into a—the first year we were married he went to Kansas City and took a physical, we had a Naval Air Station there in Hutchinson and they thought they could form a group there and fly. 31:57 They wouldn‘t pay him, so he said he wasn‘t flying. 17 �Interviewer: “Ok, that makes some sense. Did you continue to live in Hutchinson, Kansas?” No, we lived in Partridge; it‘s a little town southwest of Hutchinson. Interviewer: “Same area though?” Yes, the same area. Interviewer: “And it‟s still there?” Still there and we lived—our road was named McCoy, it was a mile long and on the north side of the town. We had a quarter section we lived on. Interviewer: “Did anyone in that area know that you played professional baseball?” Yeah, they found out. Interviewer: “How did they find out?” Well, I guess I told them and they had a museum there in Hutchinson. 32:45 The way they found me—the curator of the museum in Hutchinson knew that I had played and Dottie Key and her husband came to Hutchinson for a big –we had a big showing at the mall. Jack Banna, he had played, he was a Hutchinson man and he played for the Dodgers and he won a game in the World Series for the Dodgers and we took our memorabilia into the mall, so he introduced me to Dottie. Interviewer: “Now, was this before or after the movie?” This was after. 1996. Interviewer: “There was a period of time in there before the movie where not too many folks knew about the league and the women who had played and you just kind of went on with the rest of your life, right?” 18 �Right, my nephew lives here in Milwaukee and he read an article in the newspaper in Milwaukee and he sent me the paper and said, ―Aunt Joyce, those girls you played with, they‘ve got an association‖, and then I met Dottie Key after that. 34:02 She came from, they have a big complex out on the west side of Hutchinson where they have tournaments and teams from all over the country and she came and was a guest there. Interviewer: “Ok, you saw the movie then and do you have an opinion of the movie?” Yes, I saw the movie and it was a movie. Interviewer: ―Parts of it you like and parts of it you don‘t like?‖ Those girls, they were supposed to be sisters, and they lived on a farm. Interviewer: “The Weavers?” I don‘t know who they were, but they had never been on a farm, they didn‘t even know what a cow looked like. They didn‘t tell that in the movie, but that‘s right. Interviewer: “A farm girl would know.” Yes, and we didn‘t have a drunk coach either in our dressing room. 35:02 Interviewer: ―You know, that‟s one aspect of the movie that an awful lot of you commented on. That was too Hollywood. How about since the movie, people are aware again of it, how has that affected you?” Oh, they think I‘m an icon I guess. Interviewer: “Do you enjoy that?” Some of it and they asked me to come and throw out a pitch at this complex there and I never experienced anything like that. The officials, officials of Hutchinson, the Mayor and some of those were there, so they introduced us and when they introduced me I stood 19 �up and the whole grandstand was alive and yelling and hollering, so I took my hat and waved at them and then they started in again. All the umpires and things, they took their hats off and I had to autograph everything. I had my picture taken. 36:10 Interviewer: “Well, overdue recognition I think.” It was a little bit overdone. Interviewer: “Well, but it was time to recognize that very unique experience that you women had during and after WWII. I think that‟s what people were doing, saying, “we almost forgot and now we‟re glad we didn‟t”.” Well, I didn‘t really think I was that great. Interviewer: “Since then have you done other kinds of activities? Speak to groups, talk to young women who want to be in athletics, any of that sort of thing?” Well, a young girl in Haven, Kansas was doing a history project on women in baseball and she got in contact with the league and they said, ―well, the only one we have in Kansas is Joyce McCoy‖. 37:03 She lived in the little town of Haven, which is about fifteen miles from me, so she came to see me and we had a good time and she did a good job and she went to the University of Maryland and then finally she went to the Smithsonian Institute with her--she just graduated from high school and she‘s in college this year and she‘s quite a baseball player. My goodness, she can pitch. She can throw the softball sixty miles an hour and they say that‘s equivalent to ninety miles and hour with a baseball. Interviewer: “She‟s pretty close.” But she does that windmill. 20 �Interviewer: “You do get a little more speed on the ball that way. Do you see yourself as a roll model?” No, not really, I play golf and I bowl, I‘m too old to play baseball now. 38:02 Interviewer: “you still stay active in sports? It sounds to me like sports have always been an important part of your life?” My granddaughter and grandson were swimmers. My granddaughter was pretty good in swimming and her times are still in the high school there in Wichita. Interviewer: “It‟s in the family.” And then her children—my great grandson is thirteen years old and he‘s a wrestler and a football player, baseball player and in wrestling he went to the University of Missouri in Columbia, he lives in Parkville, and he got third in the state and he‘s thirteen years old. Interviewer: “Now, do they all know that grandma was a ball player too?” Yes Interviewer: “Do they like that?” Christopher, the next little boy, he was only two years old and I was the only one who could pitch to him right so he could hit the ball. You know they thought he was little and they would throw the ball and it would go down like this. 39:02 You have to throw it straight so they can hit it and he‘d hit the ball when he was two years old. Interviewer: “Grandma‟s still teaching?” Yes Interviewer: “Great and thanks for taking time to talk to me. I really appreciate it and gentlemen you‟ve been sitting here, anything occur to you that we didn‟t cover that we should cover? 21 �Thank you Interviewer: “Thank you very much.” 22 �23 � Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource All-American Girls Professional Baseball League Interviews Creator An entity primarily responsible for making the resource Grand Valley State University. History Department Description An account of the resource The All-American Girls Professional Baseball League was started by Philip Wrigley, owner of the Chicago Cubs, during World War II to fill the void left by the departure of most of the best male baseball players for military service. Players were recruited from across the country, and the league was successful enough to be able to continue on after the war. The league had teams based in Wisconsin, Illinois, Indiana and Michigan, and operated between 1943 and 1954. The 1954 season ended with only the Fort Wayne, South Bend, Grand Rapids, Kalamazoo, and Rockford teams remaining. The League gave over 600 women athletes the opportunity to play professional baseball. Many of the players went on to successful careers, and the league itself provided an important precedent for later efforts to promote women's sports. Source A related resource from which the described resource is derived <a href="https://gvsu.lyrasistechnology.org/repositories/2/resources/484">All-American Girls Professional Baseball League Collection, (RHC-58)</a> Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/page/InC/1.0/?language=en">In Copyright</a> Subject The topic of the resource Sports for women World War, 1939-1945--Personal narratives, American All-American Girls Professional Baseball League--Personal narratives Oral history Baseball players--Minnesota Baseball players--Indiana Baseball players--Wisconsin Baseball players--Michigan Baseball players--Illinois Baseball for women--United States Publisher An entity responsible for making the resource available Grand Valley State University Libraries, Special Collections and University Archives, 1 Campus Drive, Allendale, MI, 49401 Identifier An unambiguous reference to the resource within a given context RHC-58 Format The file format, physical medium, or dimensions of the resource video/mp4 application/pdf Type The nature or genre of the resource Moving Image Text Language A language of the resource eng Date A point or period of time associated with an event in the lifecycle of the resource 2017-10-02 Contributor An entity responsible for making contributions to the resource Smither, James Boring, Frank Relation A related resource Veterans History Project (U.S.) Oral History A resource containing historical information obtained in interviews with persons having firsthand knowledge. Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Identifier An unambiguous reference to the resource within a given context RHC-58_JBarnes Title A name given to the resource McCoy, Joyce Barnes (Interview transcript and video), 2009 Creator An entity primarily responsible for making the resource McCoy, Joyce Barnes Description An account of the resource Joyce Barnes McCoy was born in on a farm south of Hutchinson, Kansas on October 18, 1925. She played softball with her siblings and then played various sports throughout grade and high schools. One day while still in high school she was reading a Hutchinson News article in which read that Phillip Wrigley was looking for girls to try-out for women's softball teams up in Chicago. After one correspondence—Mr. Wrigley paid Barnes' way to the tryout in Chicago. She started and ended her professional career by playing with the Kenosha Comets in 1943. She played as a pitcher while there. Contributor An entity responsible for making contributions to the resource Olson, Gordon (Interviewer) Subject The topic of the resource Oral history Veterans History Project (U.S.) Video recordings All-American Girls Professional Baseball League--Personal narratives Baseball for women--United States Baseball Sports for women World War, 1939-1945--Personal narratives, American Baseball players--Wisconsin Language A language of the resource eng Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/page/InC/1.0/?language=en">In Copyright</a> Type The nature or genre of the resource Moving Image Text Relation A related resource Veterans History Project (U.S.) Date A point or period of time associated with an event in the lifecycle of the resource 2009-09-27 Source A related resource from which the described resource is derived <a href="https://gvsu.lyrasistechnology.org/repositories/2/resources/484">All-American Girls Professional Baseball League Collection, (RHC-55)</a> Format The file format, physical medium, or dimensions of the resource application/pdf video/mp4 Publisher An entity responsible for making the resource available Grand Valley State University. University Libraries. Lemmen Library and Archives https://digitalcollections.library.gvsu.edu/files/original/8a65df60409efd3c6f27dc37232cd754.mp4 ae2b3434d15e7649ac780e5afdc2e715 https://digitalcollections.library.gvsu.edu/files/original/7322a2dee99a90cb635f982dbe893719.pdf 7f0fb1ce689bfa8e0f2b2728386aec30 PDF Text Text Grand Valley State University Veterans History Project Todd McCrumb (22:20) (00:17) Background Information • Todd was born in Lansing, Michigan in 1965 • His father was a state policeman and was often transferred all over Michigan • Todd graduated from high school in 1984 • He had not been interested in going to college right away and the unemployment rate was at 16%, so he joined the Air Force in August of 1984 (2:45) First Days in the Air Force • There were many angry people in the Air Force that he had to train with • Training was intense and the drill sergeants were mostly left over from Vietnam; they were all very mean • Todd was sent to South Korea near the DMZ where he worked with the security police guarding F-16s with nuclear weapons and U2 spy planes • They also worked with the South Koreans • There was one South Korean guard for every American that was there • Every young man in South Korea has to join the military for two years after graduating • Much was lost in translation and problems were caused by miscommunication (6:50) Every Day Activities • Long distance cost about $3/minute so Todd preferred to write letters • He made only $600/month and could not afford the phone calls • They always got free rides on planes and had great food • Todd said that it was “like eating at Big Boy every day,” and that he gained a lot of weight • There were many activities at the recreational centers, they received many free concert tickets, and free hunting/fishing licenses (11:15) The End of His Time in the Service • A bill had recently been passed that sought to cut military costs and decrease the size of the military • Todd had though about re-enlisting, but wanted to be stationed somewhere other than Montana because it was very boring • He had even offered to go back to the DMZ in South Korea • They told him that if he re-enlisted he would be in Montana for another 6 years • Todd was off the base in Montana in 4 days and back in Michigan • He was unsure of what he wanted to do for his future and had thought about becoming a state policeman • He later decided to take classes at Grand Valley State University, where he received his Bachelor’s and Master’s Degree and is now a teacher �(15:15) Effects of His Military Experience • Todd is now much more involved in international news, but feels that much is spinned to promote special interests • There are some in the military that are just war-mongers and looking to kill • Todd was trained more in helping people than in hurting people • In the reserve he spent a lot of time working with first-aid and providing help during disasters • Todd feels that peace is not the absence of war, but the result of war because there are a lot of bad people out there � Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Veterans History Project Creator An entity primarily responsible for making the resource Grand Valley State University. History Department Description An account of the resource The Library of Congress established the Veterans History Project in 2001 to collect memories, accounts, and documents of U.S. war veterans from World War II and the Korean War, Vietnam War, and conflicts in the Middle East and elsewhere, and to preserve these stories for future generations. The GVSU History Department interviews are part of this work-in-progress, and may contain videos and audio recordings, transcripts and interview outlines, and related documents and photographs. Coverage The spatial or temporal topic of the resource, the spatial applicability of the resource, or the jurisdiction under which the resource is relevant 1914- Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/page/InC/1.0/?language=en">In Copyright</a> Subject The topic of the resource Afghan War, 2001--Personal narratives, American Iran Hostage Crisis, 1979-1981--Personal narratives, American Korean War, 1950-1953--Personal narratives, American Michigan--History, Military Oral history Persian Gulf War, 1991--Personal narratives, American United States--History, Military United States. Air Force United States. Army United States. Navy Veterans Video recordings Vietnam War, 1961-1975--Personal narratives, American World War, 1939-1945--Personal narratives, American Publisher An entity responsible for making the resource available Grand Valley State University. University Libraries. Special Collections & University Archives Contributor An entity responsible for making contributions to the resource Smither, James Boring, Frank Relation A related resource Veterans History Project (U.S.) Identifier An unambiguous reference to the resource within a given context RHC-27 Language A language of the resource eng Source A related resource from which the described resource is derived <a href="https://gvsu.lyrasistechnology.org/repositories/2/resources/455">Veterans History Project interviews (RHC-27)</a> Oral History A resource containing historical information obtained in interviews with persons having firsthand knowledge. Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Identifier An unambiguous reference to the resource within a given context McCrumbT Title A name given to the resource McCrumb, Todd (Interview outline and video), 2008 Creator An entity primarily responsible for making the resource McCrumb, Todd Description An account of the resource Todd McCrumb was born in Lansing, Michigan in 1965 and enlisted in the Air Force in 1984 shortly after graduating from high school. He had been unsure of what he wanted to do in his life, not ready for college, and unemployment in the area was at 16%. Todd spent time working with the security police near the DMZ in South Korea. He was later stationed in Montana. Todd did not re-enlist because he was told he would have to spend another 6 years in Montana. He later graduated from Grand Valley State University and is now a teacher. Contributor An entity responsible for making contributions to the resource Davidson, Matt (Interviewer) Nosanvo, Catlin (Interviewer) Subject The topic of the resource Oral history Veterans History Project (U.S.) Video recordings United States--History, Military Michigan--History, Military Veterans United States. Air Force Other veterans & civilians--Personal narratives, American Language A language of the resource eng Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/page/InC/1.0/?language=en">In Copyright</a> Type The nature or genre of the resource Moving Image Text Relation A related resource Veterans History Project (U.S.) Date A point or period of time associated with an event in the lifecycle of the resource 2008-06-02 Source A related resource from which the described resource is derived <a href="https://gvsu.lyrasistechnology.org/repositories/2/resources/455">Veterans History Project Collection, (RHC-27)</a> Format The file format, physical medium, or dimensions of the resource application/pdf video/mp4 Publisher An entity responsible for making the resource available Grand Valley State University. University Libraries. Lemmen Library and Archives https://digitalcollections.library.gvsu.edu/files/original/0efb98cd5a83529f3e028bae2133d597.mp4 e27303ddcc77ce6c2bba0316dfac7a65 https://digitalcollections.library.gvsu.edu/files/original/06bbb527653f0b5f4cae0d9640d57e95.pdf 3a0fff934b9f584eeb557609c2589f2c PDF Text Text Grand Valley State University Veterans History Project Interview World War II Lewis McDonald Length of Interview (0:00:00- 1:23:17) (0:00:00 – 0:03:10) Background     Born in Grand Rapids, Michigan, in December 1922 (0:00:16) Went to St. Francis parochial school for 10 grades, and then South High School. Graduated in 1940 (0:00:36) Father was a streetcar operator, and after streetcars were taken off worked for the new bus company in the shop (0:01:06) After high school worked for the A&P grocery store (0:03:10) (0:03:15 – 0:05:20) Enlistment Motivation for enlistment (0:03:15- 0:05:50)     Decided to go into the service as sister was serving as a nurse, and brother was a gunner (0:03:25) Had heard about Pearl Harbor while at a bar, but didn’t initially think about going into the service (0:04:15) He and a friend chose to enlist so that they could possibly choose their branch of service (0:05:00) He enlisted in December 1942 (0:05:20) Basic Training (0:05:20 – 0:10:20)      Went to Fort Custer in Battle Creek, Michigan, and completed basic training at Fort Sill, Oklahoma (0:05:50) Enjoyed the train trip to Oklahoma, states that war was not on anyone’s mind (0:06:20) Once at the camp the shorter men were separated from taller boys for work placement, he was placed with the taller group (0:6:50) Had flat feet, but didn’t tell the doctor(0:07:25) Was assigned to the mule pack during basic training for 4 months, spent a lot of time outdoors, walking and traveling (0:08:30) Air Corps Training (0:10:20 – 0:21;50)     Recruited for the Air Corps (0:10:20) Trained for Air Corps at Wichita Falls, Texas (0:11:00) From there went to Santa Ana, California (0:11:15) Took a college course while waiting for cadet program to start (0:11:35) �              Went to Santa Ana and started the cadet program, stayed in wooden barracks (0:12:08) Went to school all the time, and then spent time flying PT-22 tandem front and back open cock pit, over 100 horsepower engine monoplane (0:12:24) The planes had no radios, so the radioman sat in the back and relayed messages through a tube (0:13:05) He and others experienced constant worry about getting “washed out” if you didn’t meet qualifications (0:13:58) Stayed for 8 months which included three training stages, primary, secondary, and advanced (0:14:30) In the classes learned about aviation, navigation, mechanics, and Morse code (0:15:00) Advanced training was in Pecos, Texas (0:16:20) Had the choice to fly fighters or bombers, he chose bombers (0:16:45) Graduated as Class 44F (44 is 1944, the year he graduated, F was the number of the class) (0:16:50) From there he went to Roswell, Mexico for training in a B-17 (0:17:05) Most flight instructors were civilians (0:18:20) For entertainment, they went to bars and to dances (0:20:00) At times there were USO shows (0:20:35) First impression of flying a B-17 which had a 100 ft. wingspan, was it felt like flying the house around (0:21:50) (0:23:00 – Active Duty Deployment to Europe (0:23:00 – 0:31:50)            Went to Tampa, Florida, as a flight officer, which is equivalent to a warrant officer. They were not considered commissioned officers, but they were officers (0:23:00) Once they got a crew together, went over on the ship Queen Elizabeth (1994) (0:24:25) While on the ship the four officers were treated like kings while the enlisted men were not, who packed five decks below (0:24:40) Landed in Scotland and took a train to the base, 50 miles north of London in Ridgewell(0:25:05) During training practiced a lot of formation flying (0:25:25) Bombing focused on German airfields and train tracks to cut out all methods of transportation (0:25:50) Never saw a German air fighter the entire time he was there (0:26:14) Missions were often 10 hours long in duration (0:28:30) His main base was at Ridgewell The base had an officer’s club, a mess hall, a PX, and hospital, and Quonset huts for housing(0:28:40) Explains the importance of flying in formation, formation was a defense mechanism to prevent fighter planes from attacking (0:31:52) First combat mission (0:31:50 – 0:50:18) �       For the first mission he flied Tail End Charlie, where you fly low below and behind everyone in the squadron (0:32:40) Describes missions as exciting, your adrenaline pumping (0:32:55) Describes it as fun and thrilling, dangerous but still a thrill (0:33:40) Describes shock at being able to fly a bomber while in his early twenties (0:34:22) Did not lose many aircraft at this time in the war (0:35:00) Lieutenant Bob Jankovic was the only one that the troop lost during this mission. His plane was shot down, and he did not know it was Jankovic’s plane until 30 years later when he read a history book on the Eighth Air Force, which was his combat unit (0:36:39) Jankovic’s parachute opened too soon after he bailed from the plane, and caught on the tail of the plane, though Jankovic landed alive, his leg was broken, and he was captured by Germans and spent the rest of the war in a POW camp (0:38:12) Mission to Pilsen, Czechoslovakia (0:38:50 – 0:45:00)       Pilsen, Czechoslovakia was a very dangerous place to fly because they had a big munitions factory, The Skoda industrial plant (0:40:35) He underwent training to be a squadron lead pilot (0:41:00) While flying to Pilsen, the radio announced that the Eighth Air Force was coming in to bomb the Skoda Works in Pilsen (0:41:20) When the unit got there everyone at the works was prepared and on guns (0:41:45) They dropped bombs on the secondary target (0:42:32) As a bomber, he had no idea if he hit his target or not, so they would send planes overhead before and after to take photographs (0:43:22) Post European Tour (0:50:18 – 1:06:00)        His crew had been a replacement crew and the last one over, so they were to be the first to leave and return to the United States to retrain with B-29s (0:51:25) Went back to the States three weeks after the war was over in June (0:51:50) Went to Tampa, Florida at MacDill Air Force Base where he started flying 29s (0:52:00) The war ended before he ever was deployed again (0:52:40) To get his 3 hours a month of flight time to get fly pay, he would fly an L-5, a field artillery spotter plane around (0:52:00) It took 200 gallons of gas to get off the ground, and was expensive (0:53:00) Had a lot of fun flying, would go out Sunday morning to get flying time in (0:54:10) Photo Reconnaissance Unit (0:56:00 – 1:00:00)    He ended up in Greenland as a crew pilot (0:56:30) Any state that wanted mapping would contract the Army to get aerial photos (0:57:05) Spent time in Little Rock, Arkansas doing mapping for a summer (0:57:10) �Pause in tape at (0:58:10)        Joined a Photo Reconnaissance Unit to Greenland to make new maps of Greenland, building a new base in Thule (0:58:15) Took two B-17s to Greenland, spent a whole summer there (0:59:00) The plan was to send all the photos back to the United States and make new maps from them (0:59:40) The base at Thule is now fully operating today, and the Strategic Air Command has a big base there (0:59:40) The base is built on refrigerated bases to keep the structure solid so it wouldn’t sink in the spring and summertime (1:00:45) Describes his and other reservists' relationship with West Point graduates as being somewhat unfriendly (1:05:15) Was offered three options after the war: stay in at his current rank and continue to serve indefinitely, get out, or take the rank of a Master Sergeant and stay in the regular Army (1:05:45) Life after the military (1:05:50- 1:23:17)       He got out in January 1947, and began looking for a job (1:06:15) Gave up hopes of being a commercial pilot because the job market was nonexistent and the pay was low (1:09:15) Became a plumber and began the apprenticeship program, and then joined his friend’s company (1:09:30) Stayed with his friend’s company for three years, then joined the union as a commercial plumber, hoping to work on larger projects (1:11:00) Was laid off after a year, and went to work for himself, working mostly remodeling and houses for 35 years (1:12:11) Describes of his time in the service: “You got to know people a little bit better,” says “it was a great experience.” (1:16:45) Ends at 1:23:17 � Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Veterans History Project Creator An entity primarily responsible for making the resource Grand Valley State University. History Department Description An account of the resource The Library of Congress established the Veterans History Project in 2001 to collect memories, accounts, and documents of U.S. war veterans from World War II and the Korean War, Vietnam War, and conflicts in the Middle East and elsewhere, and to preserve these stories for future generations. The GVSU History Department interviews are part of this work-in-progress, and may contain videos and audio recordings, transcripts and interview outlines, and related documents and photographs. Coverage The spatial or temporal topic of the resource, the spatial applicability of the resource, or the jurisdiction under which the resource is relevant 1914- Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/page/InC/1.0/?language=en">In Copyright</a> Subject The topic of the resource Afghan War, 2001--Personal narratives, American Iran Hostage Crisis, 1979-1981--Personal narratives, American Korean War, 1950-1953--Personal narratives, American Michigan--History, Military Oral history Persian Gulf War, 1991--Personal narratives, American United States--History, Military United States. Air Force United States. Army United States. Navy Veterans Video recordings Vietnam War, 1961-1975--Personal narratives, American World War, 1939-1945--Personal narratives, American Publisher An entity responsible for making the resource available Grand Valley State University. University Libraries. Special Collections & University Archives Contributor An entity responsible for making contributions to the resource Smither, James Boring, Frank Relation A related resource Veterans History Project (U.S.) Identifier An unambiguous reference to the resource within a given context RHC-27 Language A language of the resource eng Source A related resource from which the described resource is derived <a href="https://gvsu.lyrasistechnology.org/repositories/2/resources/455">Veterans History Project interviews (RHC-27)</a> Oral History A resource containing historical information obtained in interviews with persons having firsthand knowledge. Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Identifier An unambiguous reference to the resource within a given context McDonaldL0568V Title A name given to the resource McDonald, Lewis (Interview outline and video), 2007 Creator An entity primarily responsible for making the resource McDonald, Lewis Description An account of the resource Lewis McDonald of Grand Rapids, Michigan, is a World War II veteran who served as a pilot with the Eighth Air Force. Lewis was drafted in 1943 and went to Fort Sill, Oklahoma for basic training. While there, he was recruited into a pilot training program, and was sent to England in late 1944 to be a B-17 pilot. He flew regular missions over Central Europe until the German surrender, at which point he was sent back home to train as a B-29 pilot, but the war ended before he was to deploy to the Pacific. After the war, he remained in the Army Air Corps for a year and a half, mostly flying B-17 on aerial photography missions, and spent the summer of 1946 doing this at Thule, Greenland. Contributor An entity responsible for making contributions to the resource Smither, James (Interviewer) Subject The topic of the resource Oral history Veterans History Project (U.S.) United States--History, Military Michigan--History, Military Veterans Video recordings World War, 1939-1945--Personal narratives, American United States. Army Air Corps Language A language of the resource eng Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/page/InC/1.0/?language=en">In Copyright</a> Type The nature or genre of the resource Moving Image Text Relation A related resource Veterans History Project (U.S.) Date A point or period of time associated with an event in the lifecycle of the resource 2007-12-01 Source A related resource from which the described resource is derived <a href="https://gvsu.lyrasistechnology.org/repositories/2/resources/455">Veterans History Project Collection, (RHC-27)</a> Format The file format, physical medium, or dimensions of the resource application/pdf video/mp4 Publisher An entity responsible for making the resource available Grand Valley State University. University Libraries. Lemmen Library and Archives https://digitalcollections.library.gvsu.edu/files/original/738c229cd7fe58605a44c020a60a18b7.pdf 94b51d5bdaa6bce0360e7a27754c9c44 PDF Text Text Speaking Out Western Michigan’s Civil Rights Histories Grand Valley State University Special Collections Interviewee: Mirta McGee Interviewers: Christina McGee Supervising Faculty: Melanie Shell-Weiss Location: Grand Valley State University Special Collections Date: 10/22/2011 Biography and Description Mirta McGee was born in Cuba and raised in the United States. She is currently an elementary school Spanish teacher. She discusses balancing Cuban culture with American culture, discrimination based on language barriers, and the differences between when she was growing up and her students now. Transcript CHRISTINA: Could you please introduce yourself and tell me a little about yourself? MIRTA: My name is Mirta Maria McGee. I was born on February 9th, 1960 in Cienfuegos, Cuba. My parents were Eduardo and Mirta Irueta and I have one sister, Concepcion Irueta and goes by the name of Connie. I am married and have three children. My oldest is Christina at nineteen years old, Nicholas at seventeen years old, and Caitlin who is fourteen years old. CHRISTINA: And where did you do all your schooling? MIRTA: I graduated from the University of Michigan with a BA in education and then I went back to get my Masters in Education at U of M. I also vent to the University of New Rochelle in New York to get my Montessori training for six to nine year olds, and that’s kind of like first, second and third grade, you teach all three grades in the same classroom. And currently I’m getting my Spanish endorsement from Wayne State for grades 12 through... I mean I’m sorry kindergarten through 8th grade CHRISTINA: And what are you doing now? MIRTA: Right now i’m teaching Spanish to grades third, fourth and fifth. CHRISTINA: Explain coming from Cuba to America. Or if you don’t really remember that how was it from living in Florida to Detroit, how was the transitions? MIRTA: Well I left Cuba when I was 2, and we lived in Florida for about nine months so I turned three in Miami and then we moved to Detroit. So I don’t really remember anything from Miami or Cuba because I was too young. But 1 do remember the different houses we lived in when we moved to Detroit. We lived in one neighborhood that was near All Saints. My sister who is seven years older than me went to Page 1 �AU Saints. And then we moved to another neighborhood where we were closer to Saint Gabes and that’s where I went to school. All my schooling from first through to high school was catholic schools, they were private. So one school was first through eighth and then 1 went to Holy Redeemer for ninth, tenth, eleventh and twelfth grade. CHRISTINA: And how were the Catholic schools, how was that compared to what you see now in the public schools? MIRTA: Well it was more disciplined, they were stricter. We... I loved the uniform. I wish more schools had uniform. But it was more restrictive, you had certain things you had to do or you couldn’t do. We had religion every day. There was more of a sense I think sometimes of family than there is now. There were the priests involved in your training. All the Nuns that we had, because being a parochial school a lot of nuns did the teaching, now a day you hardly see nuns. There are so few of them around. My neighborhood was very diverse so we had lots of nationalities living together, learning about each other’s nationalities. CHRISTINA: Were they mostly catholic or was it all different types of religions? MIRTA: No all different types of religions. A lot of the kids I hung out with where Catholic only because we all went to the same school so you usually stick to the friends you go to school with but when we were in middle school and high school and a lot of us worked in the neighborhood tasty freeze. And there, there were all kinds of people. Kids who went to the public school, as well as kids who went to the parochial schools so there were a lot of different religions we were hanging out with at the time. CHRISTINA: So I know you described what it was like growing up but do you have any distinct memories? How was it growing up in the sense that you weren’t necessarily born in this country? And of course people would hear about that and... MIRTA: Well. . we... My parents still followed all the Cuban traditions but then we tried to follow along some of the newer American traditions. We as Cubans don’t celebrate Christmas Day we celebrate Christmas Eve. We still stuck to the Christmas Eve going to church on Christmas Eve and celebrating it after that. Then St. Valentine’s day that wasn’t really a big holiday for us. Halloween wasn’t a really big holiday but because all my friends were doing the Halloween and the trick or treating but so it was a meshing of cultures. Of our culture that we didn’t want to lose sight of and the new host culture of the country we were now living in. CHRISTINA: So did your parents feel that because you were in a new country but obviously you guys stuck to what your customs were but did they change it more because of you or just to fit in? MIRTA: I think it was a little bit of both, to fit in and to make me feel like I was a part of it. And more comfortable if all my friends were doing something and I won’t have been doing it then maybe I would’ve been more left out. More than anything it was more in stuff like holidays or stuff like that. There were still stuff that they... I wasn’t allowed to say like sleepover at friend’s house because my parents didn’t know; they basically didn’t know other parents. And since they didn’t know them, they didn’t feel comfortable with me spending the night over there. I mean I could still go over to friend’s Page 2 �houses, they could come to my house but we didn’t do that whole sleeping over routine and things like that. CHRISTINA: I see, and can you ever remember when you were in school or a time when you had difficulty or you were made fun of or you personally or your sister personally discriminated against? How did you respond to that? MIRTA: Well there were kids that would tease you and call you... . all they knew about Cuba was Castro so they would call you mini Castro or stuff like that. We would get the, since our culture we kinda as babies get our ear pierced. So we had our ear’s pierced and our earrings, and we would kinda get... it was kind of a new thing that Americans were not used to seeing. So we were made fun of for that saying we were barbarians because we had holes in our ears. And being a prochial school we always had a uniform but once a month we had a free day let’s say that you could wear whatever you wanted like a causal day. So naturally all the kids would wear jeans but Cubans don’t wear jeans because Cuba’s a hot tropical island and jeans would only make you hotter. So we wore cotton dresses, cotton skirts, linen, and things like that. So if we wore something like that for casual day then that was also another way for us to be standing out and being made fun of saying that we were freakish because we weren’t dressing like the norm. MIRTA: So how did that make you guys feel? Did it make you guys feel like you weren’t fitting in or was it just like kids will be kids. Or was it different because you were not... CHRISTINA: Well I guess it was a little bit of both. I’m sure there was sometimes when you thought about kids just being kids but other times it kind of upset us because... I guess we felt like we weren’t, our feelings weren’t being taken into consideration, because it was almost like as long as there was something different about you then its ok to make fun of. I guess we were used to other cultures, it wasn’t,.. I mean we didn’t feelthe same way. And our high school there was a huge melting pot of different nationalities. We had the Muslims, we had a big group of Hispanics because there were Mexicans and the Puerto Ricans so there was that big community. And Holy Redeemer is in a Hispanic neighborhood so there was that group and we had a huge group of Arabic people. So they were all doing their thing but I think that on the whole that everyone got along. Everyone kinda realized there were different religions and then at our high school we also had to take religion courses which were world religion that kind of gave you the, taught you all different kind of religions. We looked into the Muslims, the Jewish andwe had field trips where we visited the synagogue and different churches. So I think that also gave us an awareness of other people, their beliefs and their customs so I didn’t feel that, at least during my high school years that people kinda made fun of you. I think by the time we go there, there was so many different cultures all trying to get along that it was a lot easier. I think that in elementary school we kind of stuck out as being different. So it was a little more difficult plus we were new to this country so it was getting used to all that and being made fun of But as we got older and you’re kind of thrown in with a lot more different groups that then you kind of learn to get along better. CHRISTINA: So you feel like once you guys all grew up and you went to school generally with the same people? Page 3 �MIRTA: Yes for like 12 years. CHRISTINA: You all got to know each other and it was bad at first but then it slowly just everyone understood each other got along. And you were more open to cause usually the grades are smaller when you are in elementary and middle school and once you get into high school everything opens up and everything opens up and they realize that its different MIRTA: Yeah and I guess that would probably be, in my case that it probably helped a lot that Holy Redeen er is in or close to Mexican town. So there was a lot of Spanish speaking people, there were a lot of Spanish speaking shops around, bakeries so it kinda it made it easier I would say. Holy Redeemer had a Spanish mass; it had a huge group of Spanish speaking members so… CHRISTINA: It made it easier MIRTA: It made it a lot easier, but even so with any fights that ever broke out in our high school was never between different racial groups. it was always like you know just over silly dumb things but between friends and between groups but it was never raciall motivated. CHRISTINA: Ok, so was there ever like family, how did your parents respond? Because they had been living in Cuba obviously for a long period of time, so the transition would’ve been probably a culture shock, a lot different coming from Cuba to America. MIRTA: Yes I will have to say I always felt that I had to give my parents a lot of credit that leaving when they were... My dad was in his 40’s when he left Cuba to start in a new country, a new job, basically a new language because they took English in Cuba but as anything when you learn the language and then you are immersed in it, to speak it it’s a bit different. When they first came here they had to get used to the language because everybody, in any language they speak faster than when you learn it. When you learn a language everything is ‘how are you”, and no one speaks like that. So a lot of the slang and stuff they had, they didn’t know, and they had to pick up and so it was difficult for them. Beside that, also picking up and starting in a country whose culture is completely different, The climate is completely different. Michigan with its cold and its snow is a drastic change from Cuba which is tropical and warm all year round. And so that was a big transition for them. They left all their family, their friends and all heir possessions. All their keepsakes and pictures and photo albums, everything, to start all over and try to make a better live for themselves. So I think they would’ve had a harder time because my mom had been a teacher in Cuba but her degree was recognized to a point but she had to go back to school to get an endorsement so she could teach Spanish and she almost had to get another degree so she could be able to teach here. So that was also an adjustment, having to go back to school and start all over as well as learn every CHRISTINA: Everything that about America MIRTA: Right CHRISTINA: Where they discriminated against? Did they ever get the rude comments and the... Page 4 �MIRTA: I do remember every once and a while. I remember one day we had just come back from church and we were on our way back home and we stopped at one of those corner mom and pop type stores to get some milk and bread or something like that, to pick up something. We were leaving the store talking amongst ourselves in Spanish and a little old lady stopped us and started yelling at my dad, saying that now that we were in America we should speak English and not any other language. And I remember my dad getting mad and it was a little polish lady. I remember my dad telling her “I’m sure when you go home you speak in polish and nobody is telling you what to do.” My dad felt strongly that just because we were here didn’t mean that we didn’t have to our culture and our language. And the only way we would kept that is if we kept speaking it, and he didn’t want my sister and I to forget the language to forget our nationality and all our traditions. So we still spoke in Spanish, that’s not to say that we didn’t speak in English too but he didn’t want us to forget that. So we did that at home, and that’s how he would make sure I spoke in Spanish so I won’t lose it. So that kinda upset me because I guess, I would hear Arabic being spoken by this family, I would hear Italian by this one, Polish by this one. And to me that never really bothered me, I always thought that it was neat that other people and their language and their customs and their traditions. So I guess I never really understood why somebody would be offended by that but I guess it’s their own I think that when people hear you speak in another language it’s that narcissistic tendency to think that they think you are talking about them. The whole world revolves around them, no we are not always talking about you. It isn’t about them. We are talking about whatever we want to talk about but since they don’t know what you’re saying they assume that you are saying something about them. CHRISTINA: So they didn’t have as much as a problem you would say because you were immersed in the schooling and you were... MIRTA: We still had, I do recall my mom maybe because she spoke more English because she was teaching and she still had an accent, but my dad’s accent was stronger than my moms, and basically it’s because if he didn’t always have to speak it he spoke more of the Spanish. My, not that he didn’t understand you, he understood the English and he spoke it but he didn’t speak it as often as my mom. So I remember going into Sears, and we were buying some kind of appliance, I don’t remember what, but I remember my dad going in there and right off the bat saying excuse me, something about a strong accent or his English was not as good. 1 remember the salesman gushing all over ahhh no you speak perfect English. Which you kinda knew it was a big lie because it wasn’t perfect English you know it wasn’t bad English but it wasn’t perfect English. So he was just buttering him up so he could get his commission and his sale, And he would just go on and ooze about how wonderful my dad’s English was and blah b!ah blah. And then I remember we purchased something and it was a big ticket item and we brought it home. Something happened and it wasn’t working and we had to have a repair or something. I remember going back with my dad and the salesman going “what? I don’t understand you. What do you want? I don’t understand a thing you are saying.” I remember my dad looking at him saying “funny when I came in here to purchase it my English couldn’t have been better but now that there is a problem with something you claim to not understand me.” So I did notice the instances like that, where there would be, their nationality or their English would come into play and then they were treated differently. Also because my dad had the thicker accent people would always assume, because you had the have an accent for some reason you are lacking in intelligence. Or that you’re deaf, so they scream Page 5 �when they talk to you. I’m not deaf I have an accent. I always look at it as no I would think that if you know two or three languages you are a heck of a lot more intelligent than one who only speaks one. So instead of talking down you should try to listen to what they are saying and not treat them like they are ignorant. That I always found to be pretty annoying hut then I think I when I.,. The first job I ever had was working at the Tasty Freeze and the couple who ran it were German. So I was always exposed to them talking to each other in German and I got used to listening to accents. Like my parents had their accent, they had their accent, my best friend was Maltese and I always went over there and I would always like to listen to her mom and dad talking Maltese and so there was all different languages that I was exposed too growing up. CHRISTINA: I see. Now you live in a predominantly white community, would you say that it’s been different than where you grew up, where you were surrounded by so many Hispanics? I mean now you are older and it’s different and times have changed do you think there is a difference? MIRTA: Yes I would, because I think this community (as wonderful as I like where I live) I see where, umm, people are not used to anyone who is different than them. I see how they look kind of differently on the Asians, Indians, Hispanic, and I don’t think they quite know how to deal with them because they haven’t had to. This is a really small community with one high school, two elementary schools, and one middle school, and they really haven’t had to deal with a lot of diversity and I don’t think they know how to deal with it. You hear the adults, you hear the kids becauseobviously they’ve been exposed to it with there parents how they don’t go into the city, because of the crime, they’re afraid to go into the museum, and its really kind of sad because they separate themselves like that. It’s like they’re only comfortablebeing with there “own kind” and frankly I kind of think my childhood was better being exposed to all kinds of people, because there you learn from each other, you learn from their traditions and culture. You learn how to get along as opposed to being strictly with all, lets say white Anglo Saxons and then its like there not used to dealing with anybody else, and if anyone’s just a little bit different they don’t know what to make of it CHRISTINA: Right and I know going to school in the community, if there was one black kid everyone knew who he was and everyone know everything about him just because he was the only one. I mean I never really experienced anyone being discriminated against or racially profiled. You have your Middle Eastern kids that would make jokes about themselves. They would call themselves “the brown kids.” They would joke and talk about themselves. You being a teacher have you seen any bullying or comments being made or anything in the younger grades? MIRTA: No. I would have to think about that but I haven’t really umm what I do whenteach, I mean I, I not only teach them the language, I try to teach them about the culture, because unfortunately when they hear, ok where going to learn Spanish and we talk about Spanish, they unfortunately think the only other country that speaks Spanish is Mexico and they don’t have a clue that there are tons, there is Puerto Rico, South America, Central America, there is the Caribbean, and so I try to open their eyes so they are more culturally aware. So maybe each month we do a country. One month we do Spain, and we learn about what life is like in Spain. What is there music like, what is there dance like? So I show them the flamingo, and what that music is and how it came about and the dancing and how it’s similar. And we do Mexico, and we learn about the mariachi and how it came about. Then we can go and learn about Page 6 �Argentina and the tango, and their culture because you want them to be culturally aware and know that there is a whole world out there and there are different traditions. You know we talk about the DIa de los Muertos and how did that came about. And typically, a lot of our traditions, are Hispanic traditions, come from Roman Catholic faith, because the majority are catholic. I’m not saying every Hispanic is, but the major religion in Spain is Catholicism, the major religion in Cuba is Catholicism and in Mexico. So a lot of these traditions where based on the church. So El DIa de los Muertos was to honor the dead, we didn’t do Halloween, we did that. So during Christmas we do the Posadas, which is the re-enactment of Christ going from inn to inn, not Christ, I should say Mary and Joseph looking for a place to stay and finally finding it at the stable. So all of these are religious holidays. So I try to tell them, this is how this culture celebrates these things because they are all religion based. CHRISTINA: So you’re saying kids now a day are more sheltered than they were in the past. How you were raised and everything, you are culturally aware. You had all the different ethnicities and languages around you. I know you had some white friends, and obviously they were more culturally aware. You see kids now a day and they’re telling you they only think Spanish comes from Mexico, would you say kids are more sheltered now than they were before and they don’t know what’s going on and they are more ignorant if you will, and the parents are to blame because they don’t want their kids to be? MIRTA: I don’t know if they don’t want or if they don’t feel comfortable with or they don’t know enough about. Which is surprising when you think about all the technology out there; you’ve got YouTube and all the different things in the computer, you would think the world opens up more for you now because of all that. I guess to a degree, with the music, they can be more aware. You have your different Hispanic groups and they are opening up and crossing over to the American scene and are more pop. So that kind of teaches them. We had Gloria Estefan and theMiami Sound Machine, which really opened up the Cuban music and brought it to the American scene, and now we have Pitbull doing his rap and that kind of also makes them more aware. So I guess in a way that helps a little bit but otherwise people kind of didn’t know what was going on, so I guess it depends. If you haveparents that are making these kids more aware and are teaching them about thisand are taking them places, if they only stay in their little community and only go to the same kind of places then they aren’t going to know any better. We have a family in my school, they go to Coasta Rica every year for spring break. And so now the kids just love it and they say “we can practice our Spanish there” and they have come back with so many souvenirs that I told the mom who is always bringing me stuff, and I said great because one of my months we are doing a unit on Coasta Rica. And so that also gives them another sense of what’s out there, how people live and what they do. CHRISTINA: And do you think that class has anything do with it? Like social class and the income that people make. Is higher class or lower class more or less aware? MIRTA: Well I suppose class will have something to do with it. If you are better off and you have the funds to be able to travel and you do travel. I mean you may have the money to travel but you never leave and never go anywhere and then of course that doesn’t help. But these people that are traveling and seeing the world that opens up their horizons and opens up their ideas so that they are able to communicate with people and see the differences and if you never leave your back yard then you don’t know what’s out there and you can’t really relate to people because it only what you know and a lot of Page 7 �times what you don’t know and what people don’t know scares them and therefore they shy away from it or sometimes people make fun of what they don’t understand or don’t know. CHRISTINA: Do you see any changes being made in your community in regards to the minority groups that are here? Or are they accommodating them better? MIRTA: Well I think, you made that reference to them calling themselves “the brown group”. I think as the kids have become more outspoken, which is a good thing, they feel more comfortable about themselves that they can be outspoken. That kind of brings the attention to themselves but in a humorous way. They are talking about themselves... CHRISTINA: But not taking themselves to seriously? MIRTA: Yeah, and so that other people can see them. Instead of them fading into the wood work because they don’t want any attention brought to them because they don’t want to be made fun off or they don’t want to be whatever the reason may be. By them pushing themselves in the fore front, they’re trying to make a stand that, “Yeah we are different in these ways, but in other ways we are the same as you”. I do think though that sometimes people mistake when you say something, I don’t want to say criticism, but people get offended if you say something that you do not like about this country or something in that f... as soon as they know that your not from this country they take offense. When really every body has their opinion. I mean, no country, no place that you live can be totally perfect. So there is always something, o this is great but you if you could improve this it would be even better. Its healthy criticism. And I think sometimes people take offense when you say something like that, because right away they want to say “well you don’t have a right to criticize, you shouldn’t say anything.” They might have thought the same thing but they don’t want to hear you say it. I remember when I was in school my sister was in high school and they had a civic project. The class project was that they had to write about/find something that they did not like about Detroit. What problem Detroit had and what they could do to fix it, and Connie wrote about the pollution in Detroit, meaning pollution of the garbage and how the streets were littered and what they should do and how they should clean them up etc. I remember it was an evening andthe principal and the pastor of our school knocked on the door and the principal basically told my sister if she was so unhappy with Detroit and if she thought it was so dirty or had so many problems then maybe we should go back to where we came from. Because if we were criticizing it, then clearly that meant we weren’t happy here and we shouldn’t be here. And first of all I found that to be really rude andoffensive because my dad said to the principal “and are you going to everyone’s house that wrote that paper because that was the class assignment, to find a problem and talk about it and how you would correct it.” And surely they didn’t go to everyone’s house they only went to our house because we were Cuban and not America so we had no right, according to them, to criticize this country. And I just found that to be first of all, in bad taste. You were supposed to be religious people, and that was intolerant and it showed their intolerance. And second of all, if you didn’t want anyone criticizing you country, you shouldn’t have made that assignment, that what the assignment was, so in that case I thought that was a definite case of discrimination, they didn’t like what we had said so they came. CHRISTINA: And they personally picked you out? Page 8 �MIRTA: Yeah CHRISTINA: Is America what you would expect it to be? I know you don’t remember when you came here, but is the image of America, you know, you’re told the melting pot, everyone is mixed together, it is the land of the free, home of the brave, there is opportunity and jobs. Is that what you see it to be? What they tell foreigners is the image of America that what you see it to be? MIRTA: Yes. I believe that you can come to this country and make something of yourself. There is people that leave for religious persecution, people that leave because of the government, which was the case for us. We left a year after Castro took over, because my dad had already been following closely enough to know that he was steering toward communism and he knew it would only get worse. It was bad when we left but it only went down hill from there and he didn’t want his children raised in that environment so he chose to leave and try to make a better home and a better life in a new country and that’s what he in turn did. I do think that other nationalities and other groups of people can be very successful. For instance, there’s different kinds of communities that have come up and have become very successful. If I talk about the Cuban community, the Cubans made Miami what it is today. Miami was a little city no one knew anything about. Older people went there to retire and that was the extent of that. Cubans are the third highest minority in education and social economic status. Turning Miami into a Little Havana and opening up all of their little shops and businesses. They have a Cuban mayor and a Cuban governor. That pushed the city to become famous in all the things that it did. You had Miami Beach that was just strictly a beach that people went to and then what did they do? They turned it into a little jazz area, with little shops, and different Cuban establishments, so yeah, they became very successful and to them that was the American dream. They became successful and they still had part of their culture and they also became Americanized and used part of the American culture but they made that successful and made it there own and they started that whole Calle Ocho, which is 8th street, their little festival. And it started out as a little festival, and as it got bigger and bigger the recruited big names in the jazz community, in the rock and roll community. The Cuban stars as well as other stars and made a name for themselves and kind of opened it up to the world to say “hey, this is who we are and this is what we are about, to learn about it.” It’s a free concert, yeah people go around and buy food and souvenirs, but you got all these big time musicians that they would bring in that were, whether they were jazz or singers, whatever they were that were big names kind of taught a little bit about there culture to the rest of the world. CHRISTINA: So you would say that the American dream is obtainable to those that are not American. It is a possibility; it’s not just something that the Americans just throw out there to get you to come over? MIRTA: No it takes a lot of hard work and it takes dedication and you can’t have the mentality of “you owe me this” and getting free handouts. You know a lot of these people started out small with low paying jobs and they just kept working and earning trying to get to the next best job and just kept working at it until they made it a success. I’m sure it was a lot of hard work, but it was like anything a lot of them went to school and just new that the more education they got the better it would be for them. Page 9 �CHRISTINA: Would you say that when immigrants come to America they take on a new identity, new cultural beliefs, just the way they do things? I know you mixed you Cuban tradition with the American tradition, but do you think that they try to change or do they want to preserve their culture? MIRTA: I guess it depends when they came over and what their feelings are. Depending on the generation, there was the generation of the Italians who came here and were given a lot of problems and so they didn’t speak Italian. I had a lot of friends, depending on when they came; their parents wouldn’t speak to them in Italian so therefore they never learned the language. The parents spoke the Italian but they didn’t want there kids to learn it because now they were in America they had to learn English and they wanted to blend in and didn’t want to stand out because they were made fun of and given a lot of grief because they were a different nationality. And while I understand that and sympathize with that, I think that is really sad because then you are losing a vital part of who you are and those traditions and those beliefs and that language is what your made of. It forms your basis, and to deny that and to forget about that your kind of inhibiting your future, and your children because their losing that richness. They’re not being exposed to the language. They’re not being exposed to that wealth of tradition and culture that there parents where, and it’s wonderful to have these traditions to be passed down form the grandparent, and great grandparent, and this is what we do and believe. Kids love that kind of stuff. Kids love to know the kind of things you did when you were a kid. I think your short changing you children if you just think that because you’re here, you have to be so Americanized. When you think about it, there really is no true American. The only true American is the Native American Indian because everyone from this country came from a different country, like Ireland and Germany. So there are all these different cultures and nationalities here that are blending and I think it makes it richer when you can learn about all these different cultures. “0 wow this is what we did when we were growing up. What did you do?” I just think it makes you a more well-rounded person. CHRISTINA: Would you say minority groups are becoming more outspoken, and they are not just going to conform to what everyone’s doing? They aren’t going to be forcing it down people’s throats but in general, they want to preserve their culture. MIRTA: I would say so because I think now we have so many and there are so many cultures and so many different churches and have festivals, and downtown they still have festivals, like in Hart Plaza they would have different festivals. People go down there and see the Polish festival and Arabic festivals, and I think you learn about their food you learn about their beliefs. I think that opens up a whole new world and I think therefore because of that, I do believe people are more outspoken. Of course we have our times that there were some difficulties like after the terrorist attacks. I felt bad because Arabic people were being singled out because they were suspicious because they could be a terrorist which is not fair for them as a whole because you have a few bad apples that are ruining it for the rest and so anytime there was anybody that looked Arabic then “oh my god lets look at them closely because they might be a terrorist.” And it’s a shame that its come to that, but as well as I understand it, sometimes that’s when people are scared, and we had the same things when there was the bombing of Hiroshima and all of that. We were leery of the Japanese, depending on what happens we have those times that I guess a certain minority group does gets singled out for being untrustworthy and suspicious and I guess to an extent that will always happen I guess, depending on the circumstances. Page 10 �CHRISTINA: So if there is one thing that you could change about how people view you or just minority groups in general, what would you like to see happen? MIRTA: I guess people should be more open minded, be willing to learn new things, be exposed top new ideas. I remember when I was in 8th grade, and we were learning the metric system, one of the 8tI grade students, was complaining, “why do we have to learn the metric system why don’t they learn our system”, and I remember telling him “the majority of the world knows the metric system, we are one of the only countries that doesn’t” and why do we have to learn a new language why don’t they just learn English. When you think about it, most countries, besides aside from the United States, they know their language and they know sometimes two and 3 others. They learn English and sometimes a third and fourth language. I found that to be a really close minded mentality, that the world revolves around me. We are super power therefore why should we have to do that? But as a super power, then we should be able to know more languages, be more tolerant, and sometimes I think we are less tolerant. So I think that if they could learn from that that then it would make them stronger and better, and because of that they would be more well rounded and more tolerant and they would be able to get along better with others. END OF INTERVIEW Page 11 � https://digitalcollections.library.gvsu.edu/files/original/99419e270d9df04fa39e80fa539e2b85.mp3 3ab50447ba16bfb65313ee95303a4f16 Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Speaking Out: Western Michigan Civil Rights Oral Histories Subject The topic of the resource Civil rights--Michigan--History Personal narratives Oral histories African Americans--Personal narratives Gays--Personal narratives Lesbians--Personal narratives Bisexual people--Personal narratives Transgender people--Personal narratives Veterans--Personal narratives Women--Personal narratives People with disabilities--Personal narratives Muslims--United States--Personal narratives Hispanic Americans--Personal narratives Homophobia Discrimination Islamophobia Stereotypes (Social psychology)--Upper Penninsula (Mich.) Description An account of the resource Collection of oral history recordings documenting the history of civil rights and social justice advocacy in Western Michigan. The collection was created by faculty and students as a project of the LIB 201 (formerly US 201): "Diversity in the U.S." course from 2011-2012. Creator An entity primarily responsible for making the resource Grand Valley State University. Brooks College of Interdisciplinary Studies Source A related resource from which the described resource is derived Speaking Out: Western Michigan Civil Rights Oral History Project (GV248-01) Publisher An entity responsible for making the resource available Grand Valley State University. University Libraries. Special Collections & University Archives Date A point or period of time associated with an event in the lifecycle of the resource 2017-05-02 Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/vocab/InC/1.0/">In Copyright</a> Format The file format, physical medium, or dimensions of the resource audio/mp3 application/pdf Language A language of the resource eng Type The nature or genre of the resource Sound Text Identifier An unambiguous reference to the resource within a given context GV248-01 Coverage The spatial or temporal topic of the resource, the spatial applicability of the resource, or the jurisdiction under which the resource is relevant 1930-2011 Oral History A resource containing historical information obtained in interviews with persons having firsthand knowledge. Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Identifier An unambiguous reference to the resource within a given context GV248-01_McGee_Mirta Title A name given to the resource Mirta McGee audio interview and Transcript Creator An entity primarily responsible for making the resource McGee, Mirta Contributor An entity responsible for making contributions to the resource McGee, Christina Description An account of the resource Mirta McGee was born in Cuba and raised in the United States. She is currently an elementary school Spanish teacher. She discusses balancing Cuban culture with American culture, discrimination based on language barriers, and the differences between when she was growing up and her students now. Subject The topic of the resource Civil rights--Michigan--History Hispanic Americans--Personal narratives Women--Personal narratives Discrimination Language A language of the resource eng Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/vocab/InC/1.0/">In Copyright</a> Type The nature or genre of the resource Sound Text Format The file format, physical medium, or dimensions of the resource audio/mp3 application/pdf Relation A related resource Speaking Out: Western Michigan Civil Rights Oral History Project Date A point or period of time associated with an event in the lifecycle of the resource 2011-11-22 Publisher An entity responsible for making the resource available Grand Valley State University. University Libraries. Lemmen Library and Archives https://digitalcollections.library.gvsu.edu/files/original/b7cd56396d8d29a14ebb35e676557401.mp4 07df1d3520e6d4200fd06ffd65b45e28 https://digitalcollections.library.gvsu.edu/files/original/fefdc7d84a7e416e4dfa4e5388cb54f2.pdf 31c736c2c6d8d77011d67c6b8d700a22 PDF Text Text Grand Valley State University Veterans History Project Vietnam War Madelaine McGregor Length: 38 Minutes Pre War She was born in South Bend, Indiana (0:30) Her maiden name is Schrader and she has one older brother (0:38) She went to high school in South Bend (0:44) She meet her husband [Michael McGregor, whose interview is also in our archive] when she was 15 in high school in blind date on Halloween, she married him at the age 19 )1:29) She was working for an insurance company, she had been in co-op in high school where she worked half a day and went school for the other half (1:48) She thought about going to college but her family did not have enough money (2:01) She would have gone into nursing had she gone to college and she had volunteered at hospital in middle and high school (2:32) She got married in 1965 her husband had graduated from the university of Indiana and had accepted a job in Columbus, Ohio (2:44) The wedding was moved up by two weeks so that her husband could be exempted from the draft that had just been announced (3:28) They had their honeymoon in Saint Joseph, Michigan and then they moved Ohio where her husband started his job as a syphilis epidemiologist (4:44) �She was going to find a job, but her husband Mike did not want her to work so she did not, after a few months they moved back Indiana where her husband got a job with the Bendix Corporation (5:23) The Draft Her husband was drafted in the fall, because by that point they had started to draft married men with no children (6:02) She moved in with her parents, and soon found out that she was pregnant (6:35) She was in shocked that she was pregnant (6:48) On her husband's side of the family this was the first baby born in 22 years (7:20) She told her husband after basic (7:56) Working and Pregnancy She started working in an office in order to pay for the car and because her allotment from the military was very small ( 8:37) They sold typewriters and office machines, and hid her pregnancy as long as possible but she had to tell her boss eventually, which led to her having to sit in the back of the room and she could not work with customers (9:43) She felt that it was unfair, but they did help her as much as possible, but the day after she left the job she had the baby (11:47) She needed the money to help pay for the baby (12:07) �After the bay was born she got more money from the military and she saw her husband during the third trimester, She was later able to take the bus to see him (12:21) Communication Her husband Mike was originally be sent to Germany but he wanted to be stateside to see his son be born, after Mike Jr. was born, he got papers to be sent to Vietnam (12:54) Mike’s father had died during D-Day and he was raised by his Mother and Aunt. His brother served in the Marines and got out just before Mike was drafted (13:38) She did not see Mike until next June when Mike came on leave, by that time Mike Jr. was 1 (14:43) They kept in touch by sending letters and tape recordings (15L36) It was difficult to write the letters because she was not sure what to tell him about because how normal her day to day was compared to what was happening in Vietnam (15 48) Mike’s letters were largely positive and did not mention the fighting, his only compliant was about the food and she sent him care packages every month 16:15) She was able to see him for 10 days in Hawaii and the people treated them very well, and Mike was able to do many things that he had missed (17:03) Mike had changed a lot. He was he was much quiteer and did not like crowds because the effect of the war he was even suspicion of children and had difficultly interacting with other people (18:17) He very observant of any room they were in (18:34) �She went home, and was receiving enough money not need to work, because she got a larger allotment after the birth of Mike Jr. Mike was able to leave the service several months early, with no explanation (21:01) After the War She and the baby went to go meet Mike, there was sense that people looked down on them (22”31) Early when they had dinner near the base people treated them very poorly and were did not want serve them at all.(23:38) They were treated well in South Bend, but Mike continued to have nightmares and other problem for a couple of months (24”23) They decide to take a vacation to reconnect and they went to Niagara Falls, and they felt much better (25:52) Mike got a job and they moved to Niles, Michigan (25:48) Mike became a Human Resources director which was something that he liked more than being an epidemiologist (26:14) They had another child named Melissa, and Madeline was a stay home mother because that was what they though was best for the family (27:34) She disagreed with the anti-war protestors and would argue with them (29:24) They children kind of knew that their father was in Vietnam nut they were very young at the time (29:45) �She was very removed from the women women’s movement, was more effect by the civil rights movement that they supported because they grew up in desegregated community (31:34) One of the Mikes friends from the war was an African American man who in an interracial marriage, was disliked by the McGregors’s neighbors when the couple came to visit (32:02) She also noticed segregation when they went to Kentucky to meet her husband and that affected her greatly(33:23) She happy that troops were treated better now, but she is unhappy that her husband was treated poorly at the time (35:03) She was not sure why they were in Vietnam and disliked the war but did not talk to Mike about that (35:57) Her husband as still effected by the aftereffects of the war such as bouts of fear and alertness but it was lessened over time (36:45) She talked to a friend about it a little bit but there was not support groups or consular to go to so she dealt with it as best as they could (37:43) � Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Veterans History Project Creator An entity primarily responsible for making the resource Grand Valley State University. History Department Description An account of the resource The Library of Congress established the Veterans History Project in 2001 to collect memories, accounts, and documents of U.S. war veterans from World War II and the Korean War, Vietnam War, and conflicts in the Middle East and elsewhere, and to preserve these stories for future generations. The GVSU History Department interviews are part of this work-in-progress, and may contain videos and audio recordings, transcripts and interview outlines, and related documents and photographs. Coverage The spatial or temporal topic of the resource, the spatial applicability of the resource, or the jurisdiction under which the resource is relevant 1914- Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/page/InC/1.0/?language=en">In Copyright</a> Subject The topic of the resource Afghan War, 2001--Personal narratives, American Iran Hostage Crisis, 1979-1981--Personal narratives, American Korean War, 1950-1953--Personal narratives, American Michigan--History, Military Oral history Persian Gulf War, 1991--Personal narratives, American United States--History, Military United States. Air Force United States. Army United States. Navy Veterans Video recordings Vietnam War, 1961-1975--Personal narratives, American World War, 1939-1945--Personal narratives, American Publisher An entity responsible for making the resource available Grand Valley State University. University Libraries. Special Collections & University Archives Contributor An entity responsible for making contributions to the resource Smither, James Boring, Frank Relation A related resource Veterans History Project (U.S.) Identifier An unambiguous reference to the resource within a given context RHC-27 Language A language of the resource eng Source A related resource from which the described resource is derived <a href="https://gvsu.lyrasistechnology.org/repositories/2/resources/455">Veterans History Project interviews (RHC-27)</a> Oral History A resource containing historical information obtained in interviews with persons having firsthand knowledge. Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Identifier An unambiguous reference to the resource within a given context RHC-27_McGregorM1680V Title A name given to the resource McGregor, Madelaine (Interview outline and video), 2014 Date A point or period of time associated with an event in the lifecycle of the resource 2014-10-09 Description An account of the resource Madeline McGregor was born in 1946 in South Bend Indiana. She married her husband Mike McGregor in 1965, at age 19, and her husband was drafted the next year. Around the same time she became pregnant, and had her son Mike Jr shortly before her husband left for Vietnam. While her husband was training but before her son was born Madeline sold typewriters at a store. After he served his two years Mike returned and they had another child named Melissa. Creator An entity primarily responsible for making the resource McGregor, Madelaine Contributor An entity responsible for making contributions to the resource Coryell, Janet (Interviewer) Subject The topic of the resource Oral history Veterans History Project (U.S.) United States--History, Military Michigan--History, Military Other veterans & civilians--Personal narratives, American Vietnam War, 1961-1975--Personal narratives, American United States. Army Language A language of the resource eng Type The nature or genre of the resource Text Moving Image Source A related resource from which the described resource is derived <a href="https://gvsu.lyrasistechnology.org/repositories/2/resources/455">Veterans History Project collection, (RHC-27)</a> Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/vocab/InC/1.0/">In Copyright</a> Publisher An entity responsible for making the resource available Grand Valley State University Libraries. Allendale, Michigan Relation A related resource Veterans History Project (U.S.) Format The file format, physical medium, or dimensions of the resource application/pdf video/mp4 https://digitalcollections.library.gvsu.edu/files/original/3082209a6ff62d35615fe995891c6412.mp4 3318ec7b3bd84c492b20c50537e02575 https://digitalcollections.library.gvsu.edu/files/original/a134ad2c3d22329c381aae4e0ff04dea.pdf de465c30b65fc7bd67882f79a8b4ac7a PDF Text Text Grand Valley State University Veterans History Project Michael McGregor (2:23:37) Background Information (00:03)             Born in Indiana on February 5th 1943. (00:04) His father was a career soldier in the Army. He died in World War II. (00:10) His parents met at a Military Academy were Michael’s father was running the ROTC. (1:25) His brother was born in 1941 while his father worked at Fort Hayes, Ohio. (2:41) He graduated from South Bend Central High School. (3:06) He attended college with VA assistance and graduated in 1965. (3:15) Michael majored in history and had the intention of becoming a teacher. (3:40) He later began working for the U.S. public health service where he interviewed people diagnosed with syphilis to help control its spread. (4:06) He married his wife early to avoid the draft. (5:03) He then began making fuel controls for the F111 at Bendix Aerospace. (6:25) In September of 1966 Michael received his draft notice. (6:40) In November of 1966 he reported at the Chicago induction center where he was processed. (6:55) Basic Training (7:20)          He began his basic at Fort Campbell, Kentucky (7:26) The men stayed in World War II barracks. (7:55) Basic lasted 8 weeks. The training consisted of close order drills, hand to hand combat, physical training, and an emphasis on decline. (8:12) If detractions were no followed, men were often “volunteered” for hand to hand combat demonstrations. (9:14) Michael’s company consisted mainly of National Guard and Reserve men. (9:55) Being at almost 23 years of age, Michael was older than most of his fellow soldiers. (10:43) While in basic, Michael was given a pay of 90 dollars a month, of which 50 dollars when home to his wife. (11:37) He was OCS (Officer Candidate School) qualified and opted for it. (12:25) He was then sent to Advanced Individual Training for artillery at Fort Sill Oklahoma. He later dropped this OCS training due to his wife’s unexpected pregnancy. As a result of dropping OCS, Michael was placed in an artillery unit. (13:30) Service at Fort Sill (14:00)     He trained in a brand new area with brand new barracks and squad bays. (14:01) The training at Fort Sill was not as rigorous as his basic. (14:27) He was placed in field artillery operations and intelligence. This trained Michael to locate targets, and calculate quadrant and deflection for the gun. (14:41) He was very good at this job, due primarily to his background in math and map reading. (16:14) �       The training process at Fort Sill took 4 months. (18:04) He was assigned to go to Germany. However, he preferred to stay stateside until the birth of his child. Due to this, he was placed in a holding company. He was used primarily in training exercises. (18:19) On July 29th 1967 Michael’s son was born and he was given leave. After returning he assigned to go to Vietnam. (20:14) At the time of his deployment, Michael knew that Vietnam War was going on but he could not fathom the reality of being sent there. (20:52) At the time, he men that Michael knew from training who went to Vietnam went because they volunteered to go. (22:37) There were no newspapers readily available that the soldiers could easily access. (22:54) He did not want to travel to Vietnam, but he was not willing to abandon his family to avoid being sent. (25:34) Voyage to Vietnam (26:01)         He was first sent to RVN (Republic of Vietnam) training at Ft. Sill for 3 weeks before being sent overseas. This consisted of class room training were the men were instructed on cultures, practices, and environment of Vietnam. (26:05) In basic Michael was trained on the M14. In RVN he had to qualify with the M16. (27:04) Anti-ambush training was also taught. (27:12) After finishing RVN, the men were sent home on leave. (27:35) While reporting in Oakland, California, Michael did encounter some protesters. (28:06) He was sent out of Travis Air Force Base by plane to Vietnam. He left at 10:00 at night. (28:57) At approx. 2 AM the plane landed in Honolulu, Hawaii. The plane then landed in Japan and then Cam Ranh Bay. (29:39) The heat and the humidity were the first things that the soldiers noticed. Michael was also very scared. (30:10) Arrival in Vietnam (31:30)         The base was much like any other army base. However, the building did look very fragile. (31:34) Upon his arrival, Cam Ranh Bay did not seem to look much like a war setting; it was surprisingly calm. (32:50) It took 2-3 days to be processed. After being assigned Michael was sent to Camp Ratcliff where he was assigned to the 1st Cavalry Division. (33:06) Every man joining the division had to go through a 1 week jungle school. (34:30) The men were made to go through booby trap courses. (35:28) While on perimeter duty at night, Michael heard what he thought was an enemy in the bush and opened fire, only to be stopped by a sergeant. What he had heard was something known as the “Fuck you Lizard.”(36:00) The men repelled out of towers and then practice repelling out of helicopters. (37:53) Michael was then taken by plane to the 1st Battalion of the 21st Artillery. (39:03) Service in the 1st Cavalry (39:56) �   The cavalry battalions had did not have any heavy weapons companies at the time but only 4 rifle companies. They were then given 4 howitzers. [McGregor's battery of 1/21 artillery was thus attached to the 2/7 Cavalry] (40:25) The Air cavalry had 3 practice maneuvers a day. One in the morning, one in the afternoon, one at night. (41:58) He stayed in FDC (the battery's fire direction control) for about 10 days. (43:50) Early Action in Vietnam : Operation Byrd (44:03)                   During this operation the men went on “raids” or a “hip shoots.” This is when one or more of the battery's guns were flown to temporary positions to support the infantry when they went beyond the range of the guns in the more permanent position. A raid was completed in a day, but on a hip shoot they would stay for one or more nights in the new position. After 10 days in his unit, Michael was sent on a “hip shoot” here he was shot at. (44:20) Often times the men went in with a senior NCO. The men would then assault the area and set up a perimeter. (46:00) There was often an artillery preparation before the men landed. (46:48) The men often only had a matter of seconds to get off the helicopter before it would lift off again. (48:26) His first night on his first “hipsho0t” Michael fell asleep. He awoke to a trip flare. (49:29) Michael and his unit were working to break the influence of the Vietcong in the area and protect the rice harvest. (51:14) There was a city near where Michael was stationed. This meant there was a large amount of people who needed a large rice harvest. (53:26) Because there was a town nearby, the men were able to get leave if they were good soldiers. In town the men often drank. (54:29) When he arrived in Vietnam, Michael had the intention of keeping a diary. (57:43) He was in Phan Thiet form October 1st 1967- January of 1968. (58:55) The native people didn’t pay much attention to the soldiers unless they were spending money. (59:10) There were only 2 rough incidents while in this area of Vietnam. (1:00:50) There was some friendly fire. Several U.S. soldiers were killed by a napalm strike. (1:02:54) Most of the heavy fighting was done with by the time Michael arrived. There were still some snipers in the area. (1:04:58) His unit was moved out of Phan Thiet in October of 1967 before the Tet Offensive stated. He was moved near Bong Son in LZ Mustang. (1:06:41) While at LZ Mustang the men were attacked almost every night. (1:09:11) A U.S. trap set around the perimeter consisted of wire connected to claymore mines. (1:10:45) Michael felt sympathy for a North Vietnamese soldier who was killed by a detonated claymore booby-trap. He admired his courage to go and fulfill an objective that would most certainly get him killed. (1:12:03) The Tet Offensive (1:13:04)  The Tet offensive began while Michael was at LZ Mustang. He was later moved to the Northern part of Vietnam to take part in the counter attack. (1:13:07) �   His unit was given the task of blocking to the North. There was a bridge and a river that was to be secured just north of Hue. Once secured, they were also to provide fire support. (1:15:10) Michael was fortunate to miss the bulk of the fighting during the securing of the bridge. The men did, however, come under fire on multiple occasions. (1:16:20) The men spent approx. 1 week securing and protecting the bridge at Hue. (1:18:47) Operation Pegasus (1:20:04)        Michael missed the initial deployment by one day due to his R&R in Da Nang. (1:20:15) The North Vietnamese set up several strong points on hill tops anticipating the men to travel in on the road. Instead they air assaulted in. (1:20:16) He rejoined his unit at LZ Thor. (1:22:27) Marines were sent in initially to clear the area. After hitting intense resistance they fell back. (1:22:47) When he arrived in Khe Sanh, it looked as though there had been some fighting a bombardment, but most of its appearance was typical to any other LZ. (1:24:43) The men were them moved to LZ Stud. While here several men hijacked the mess truck of another company. (1:26:11) Often, long delay fuses were placed on buried supplies such as nails from ammo boxes when the men left an area. This was to stop the North Vietnamese form digging up the supplies and using them in booby-traps. (1:27:05) Operation Delaware (1:29:09)          After the completion of Operation Pegasus the men were sent back to Camp Evans. (1:28:09) The one thing that Michael had heard about Vietnam was of a rescue attempt made in the A Shau Valley. This was the location that Michael was sent next. (1:28:25) He was first sent to LZ Pepper. While being dropped, the helicopter took fire and crashed. No men were injured. (1:30:34) Because the Vietnamese were caught of guard during operation Delaware, often times Michael encountered enemy soldiers and had to fire upon them. (1:33:50) For approx. 1 week, Michael and his unit still saw Vietnamese soldiers wander toward their unit, ignorant to the fact they were there. (1:35:55) Michael worked with 3 howitzers during this operation. (1:36:45) His unit was in the A Shau Valley for approx. 2 weeks. Then he was moved to an area east of Camp Evans. There the men simple secured the area. Often the men had to force North Vietnamese out of tunnels. (1:38:00) He stayed near the China Sea till he came back to the U.S. in September of 1968. (1:40:46) While in Vietnam Michael had his hands cut up by barbed wire and took some shrapnel. Aside from that, he was left relatively unharmed. (1:41:20) Life in Vietnam (1:41:58)   His wife attempted to write him every day. His mom also wrote often. Michael had trouble receiving mail only if he was being moved to another location. (1:42:01) He worried that if his family knew where he was then they would be very worried about him, more so then they already were. (1:43:15) �   During some R&R in Hawaii in June of 1968 (after 9 months in Vietnam), Michael was able to meet with his wife. (1:43:47) The people in Hawaii were very gracious of Michael’s service. He was often offered discounts at hotels and free drinks. (1:44:52) Michael received a tape from his wife while in Vietnam. The reality of having a piece of his life that was not in the Army was difficult to grasp. (1:46:53) Discharge (1:48:50)   He landed in U.S. at Fort Lewis Washington at 9AM. At then PM of the same day he was discharge. (1:49:32) There were offers made to Michael to reenlist. He had no interest in doing so. (1:51:18) Life in Vietnam (cont.) (1:53:00)        Because he went in to a unit of soldiers who have been in the field for a while, he joined a unit of strangers. (1:53:01) Michael did have some mentors which helped him get assimilated with the other soldiers. (1:54:30) The rotation of high command men was often viewed as ridiculous. The reason was that this often resulted in the change of company structure every 6 months. (1:55:38) There was a lot of resentment over what the higher command soldiers had verses the average soldiers and the pay that different solders had. (1:58:44) While napping before a flight in Cam Ranh Bay, Michael and one of his fellow soldiers was yelled at by a Sergeant Major for napping and wearing dirty uniforms. The Sergeant Major was dressed well and wore a flak jacket with shined shoes while Michael whore tattered clothes. The conversation was then interrupted by a pair of pilots, who outranked the Sergeant Major, and informed him that “where those men are going they shoot pricks like you.” (2:00:05) The pilots then bought the two soldiers drinks and asked them about how well they thought the air units helped them in the field, since they didn't get much feedback from the troops. He felt that the inequality that existed in the military had the solders on the ground taken advantage of. (2:04:57) Life after Service (2:05:03)     When he arrived home he was greeted by his wife, some, brother, and sister in law. (2:05:26) He began working in humans recourses. (2:07:24) He was hired at a plant to instill a sense of discipline. He was hired due to his military background and height being 6’4”.(2:08:01) Michael was unable to take advantage of the G.I. bill after he returned to the U.S. a bill was later passed that allowed him to take it. (2:09:36) Thoughts on Service (2:11:20)]   He met a lot of good people and had a lot of good times, but he also had some of his worst times while in the service. (2:11:24) He wished he had gotten more contact information. When he left the military he recognized some men only by their call sign. (2:12:12) �     One man he did meet while in the Army he did keep in contact with later became an air line Pilot. (2:14:00) Michael was not exposed to much of the protests in the late 1960s. He did follow the war after he was discharged. (2:16:39) He did not know why the men were fighting in Vietnam. He came to the conclusion that it was a colossal waste. (2:17:15) He didn’t like how the protests vilified the soldiers. (2:18:54) There was a lot of pride within the 1st Cavalry. (2:20:47) � Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Veterans History Project Creator An entity primarily responsible for making the resource Grand Valley State University. History Department Description An account of the resource The Library of Congress established the Veterans History Project in 2001 to collect memories, accounts, and documents of U.S. war veterans from World War II and the Korean War, Vietnam War, and conflicts in the Middle East and elsewhere, and to preserve these stories for future generations. The GVSU History Department interviews are part of this work-in-progress, and may contain videos and audio recordings, transcripts and interview outlines, and related documents and photographs. Coverage The spatial or temporal topic of the resource, the spatial applicability of the resource, or the jurisdiction under which the resource is relevant 1914- Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/page/InC/1.0/?language=en">In Copyright</a> Subject The topic of the resource Afghan War, 2001--Personal narratives, American Iran Hostage Crisis, 1979-1981--Personal narratives, American Korean War, 1950-1953--Personal narratives, American Michigan--History, Military Oral history Persian Gulf War, 1991--Personal narratives, American United States--History, Military United States. Air Force United States. Army United States. Navy Veterans Video recordings Vietnam War, 1961-1975--Personal narratives, American World War, 1939-1945--Personal narratives, American Publisher An entity responsible for making the resource available Grand Valley State University. University Libraries. Special Collections & University Archives Contributor An entity responsible for making contributions to the resource Smither, James Boring, Frank Relation A related resource Veterans History Project (U.S.) Identifier An unambiguous reference to the resource within a given context RHC-27 Language A language of the resource eng Source A related resource from which the described resource is derived <a href="https://gvsu.lyrasistechnology.org/repositories/2/resources/455">Veterans History Project interviews (RHC-27)</a> Oral History A resource containing historical information obtained in interviews with persons having firsthand knowledge. Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Identifier An unambiguous reference to the resource within a given context McGregorM0561V Title A name given to the resource McGregor, Michael (Interview outline and video), 2010 Creator An entity primarily responsible for making the resource McGregor, Michael Description An account of the resource Michael McGregor, born in Indiana in 1943, served in the U.S. Army from November of 1966 through late 1968 in the 1st Cavalry Division in the Vietnam War. After receiving his draft notice, Michael trained at Fort Campbell, Kentucky. He was then sent to Fort Sill, Oklahoma, where he began his work in field artillery. In the fall of 1967 Michael was sent to Vietnam and was placed in the 1st Cavalry. He served in the Phan Thiet area at the end of Operation Byrd, and moved up to the Hue area after the start of the Tet Offensive, and later in the Khe Sanh area and the A Shau Valley. Contributor An entity responsible for making contributions to the resource Smither, James (Interviewer) Kentwood Historic Preservation Commission (Kentwood, Mich.) WKTV WKTV (Wyoming, Mich.) Subject The topic of the resource Oral history Veterans History Project (U.S.) United States--History, Military Michigan--History, Military Veterans Video recordings United States. Army Vietnam War, 1961-1975--Personal narratives, American Language A language of the resource eng Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/page/InC/1.0/?language=en">In Copyright</a> Type The nature or genre of the resource Moving Image Text Relation A related resource Veterans History Project (U.S.) Date A point or period of time associated with an event in the lifecycle of the resource 2010-05-06 Source A related resource from which the described resource is derived <a href="https://gvsu.lyrasistechnology.org/repositories/2/resources/455">Veterans History Project Collection, (RHC-27)</a> Format The file format, physical medium, or dimensions of the resource application/pdf video/mp4 Publisher An entity responsible for making the resource available Grand Valley State University. University Libraries. Lemmen Library and Archives https://digitalcollections.library.gvsu.edu/files/original/a42cf776085ca4f2471548e75f643f12.mp4 316a3c4d6b080cc13b2e6fb5271cb0ba https://digitalcollections.library.gvsu.edu/files/original/ea26423f111872525bd82ab4384adea3.pdf 4454970f31735606fda33697736d32d4 PDF Text Text Living with PFAS Interviewer: Dani | Interviewee: Lynn | Date of Interview: 7/29/2021 5:00:00 AM Danielle DeVasto: All right. So, I'm Dani DeVasto, and today, July 29, 2021, I have the pleasure of talking with Lynn McIntosh. Hi, Lynn. Thanks for being here today. Well, thanks for having me here with you, really. Lynn Macintosh: Yeah. Thank you for coming all this way. Danielle DeVasto: Lynn, can you tell us where you are from and where you currently live? Lynn Macintosh: Well, I'm actually from the east coast. I lived most of my life growing up on the east coast, Pennsylvania, New York, and I live now here in Rockford, where I've lived for, oh, 30 years. Thirty years. Danielle DeVasto: Wonderful. Wonderful. Lynn, can you please tell me a story about your experience living with PFAS? Lynn Macintosh: Thank you. Uh, my experience with PFAS is really on the discovery of it and the living in a town [CLICK SOUND] that spewed this into the river for years, for decades, and no one really say much about it, I think, because it's white and it's foamy, and when water goes thrashing over a dam and bubbles up, because although some of the __________ 00:01:26, it's like they were years ago, it's white, it's not an oil spill __________ 00:01:32. It's sudsy, suds make you think of clean, it's white, and, um, [CLICK SOUND] I didn't even notice it when I first moved here, but I started to notice it in the summer of 2009 and 2010, when I heard that this tannery, that's right behind me, location, location, location, I happened to move, uh, just east of a tannery, coming here from the east coast and not understanding that, and about that time when I was really concerned about this tanuh, this- [LIP SMACK] this, uh, approaching demolition, I started noticing it a little bit more than I had before, and they started taking pictures of the river, and I started noticing foam, and I collected them. I have a lot of them in a book here, and I sent them all over the place, uh, of these pictures of this awful, not even so much of just the foam, but this filmy, weird, um, substance that appeared frequently. I suppose this- this picture really shows what it was like because it was almost a pre-foam stage and it would just sort of sit on the river and if you threw something into it, it would make a hole and then close up, and it was really odd to me, and I started going on the river and kayaking, and I got pictures sometimes of the foam looking like this, piled up. This is a close up of that other picture that I had before. It's much better. I would see puddles like this when the ice melted. I'd see big spots of it. So, anyway, I started noticing the river, and one day, many years later, if I could have that picture again, I saw this picture from Wurtsmith in a photo, and I looked at that picture seven years later and I thought, why did they have a picture of Wolverine's foam in this article about Wurtsmith? 'Cause up til now all I could conclude was that it was a surfactant. As a citizen, I worked with Dr. Rediske, who told me how to do some basic sampling on the river, and when I would go and do my little samples, I decided to always add in checking for the surfactant level, and I had done some research about natural foams and these kinds of foams, and I knew that this foam wasn't good for the river, but I Page 1 �didn't know it was PFAS. [BANG SOUND] But I did start observing it. It's like my eyes were open to the river. I thought this is really weird, and when my- my eyes were on the river and- and my concern was for this coming demolition, so I started training myself, taking walks and observing things, uh, in that summer, and it started this avalanche of questions and deepened my concern about this approaching demolition on the tannery. I had seen that we live in a town and you're busy with young kids, you assume that your town's taking care of you and your water's safe and all that. Everyone cares and is doing their job, and after having witnessed a demolition gone awry in my own backyard with asbestos clouds flying in the air right behind me the year before and having to report that to the DEQ and going through the whole coverage of it, this lovely little home here was riddled with asbestos, as pretty as it is, and they took it all down without removing any of it. So, living in Rockford, now, in 2009 and 2010, after my two older children had graduated and one- one other daughter who, uh, was here until 2012, I said to myself, this is a tannery, this is 15 acres. It's obvious that my city doesn't care if they're actually in, they were in kind of cahoots with all. They got fined, everybody involved in that asbestos, they also got fined. Um, they had to haul it to maul it to licensed, haul it to a licenced landfill, and, um, and it was a dangerous thing to do. It was so irresponsible, and all the city did was do what happens a lot in politics, put a spin on it, downplay it, and make it out to be my fault or other people's fault, __________ 00:07:05, and that, too, was very clear. So, I got involved in researching this demolition, and I became what I like to talk about in my way of doing it, I hired myself [LAUGHTER] one day without an interview [LAUGHTER] to investigate this, and I called myself a ragtag. I was part of the ragtags. I was- I was a hub of the ragtags, and I found other citizens, friends, people I knew, who cared, people who were recently retired, [CHUCKLE] who were home during the day to come down and help me, first of all and do field investigations. I found a fisherman, who knew we called on the Islands of the Lost Soles up there. It's a shoe company and that [CHUCKLE] was the mystic. This fisherman said, "Oh, yeah, have you been north to see the Islands of the Lost Soles?" It's pretty- pretty gruesome up there, the foam and the stench and, so I went up there and, so I had one- one particular fisherman who went out with me- with me that day, and we also noticed the foamy, filmy stuff. Uh, I had a friend who I would call in the middle of the day, who was recently retired. [CHUCKLE] Sometimes I'd send him down to city hall with my camera to get photos of aerial views 'cause they didn't want to see me too much at city hall, and I didn't want to see them. So, [CHUCKLE] and he would playfully, and actually I think he meant it, try to get out of some of these things, but, um, [LAUGHTER] I was persistent, and he was a friend, so I was llike, he would say things like, "Well, I- I can't go down, I don't have a good camera." Here, take mine. "Oh." [LAUGHTER] Or, in the middle of the day, Andrew, I need you to get down to the river right now. "What's going on?" I said, there's 14 dead fish in the river right near the tannery. "So, uh, it's a little late for them." [LAUGHTER] And I said, no, no, you don't get it. This is a fish kill. I learned this phrase from the Department of Environmental Quality, have there been any fish kills? He's like, "Oh, this is a fish kill." So, I knew Andrew, I knew he was home, and I used my little flip phone, which I used in all my escapades up to 2018, actually. I had his number memorized, I called him up, and convinced him to come down with a bucket and a butterfly net Page 2 �and to reach through this grated bridge over the river using his length of arm, and he was six feet tall, so he's, like, really spread across the trail and he's scooping out dead fish for me and we're putting them in a bucket, and I'm bringing them down to the DEQ. This is forensic evidence. [CHUCKLE] I had people taking photos for me, walking around the tannery while it was going on, getting photos of dust. [LIP SMACK] I had people who would come meet me and get samples of the- of the river. I finally met someone who was troubled by it, too, and I said, yeah, I'd really like to get some sediment samples of this river and at that point, my husband had lost a lot of enthusiasm for helping me out on these ventures, especially after I lost his- his, uh, boots, his, uh, fisherman's boots, that I left in a thicket by the river, and he said, "Well, I'll go out with you," and so it was pretty much anybody who was tall and willing and able. I would they became, they joined the ragtags. Yeah, they helped me, uh, collect a lot of good evidence. So, we ended up getting sediment samples by taking PVC pipes and jamming it down in and water out. It was really exciting. Um, so, anyway, for about two years, I was running on kind of this startled, urgent energy that there's something wrong here. This demolition is not going to be safe. I was right, it wasn't, but the more I asked, the more I realized I needed to stay involved because outside my little city and my city government and my county and the Department of Environmental Quality in Grand Rapids, and my legislators, who didn't really want to be involved outside of that, when I would get to top people at the EPA or top people in other states or research by phone, they were like, "Really? Tell me that again. Well, who's the project, who's the project leader?" There isn't one. "No, there has to be one." No, there's no project leader. "Hmm, well what about the water department? Aren't they getting samples of the sediment? They can at least do that. They don't have to get on site to do that." Nope, they're declining. "Well, what about is- aren't there any incentives they can get to get compensated?" Yeah, they tried to get them to do a testing on baseline __________ 00:12:22, phase one, phase two, and they were given this amount of money, and Wolverine said, “No, thank you." Um, we knew that the people, some of the good people in DEQ were actually concerned, but nobody felt like they had the authority or wanted to step out and risk the ire of the company or even the governor at that time or any of that. So, [LIP SMACK] when our facts and our findings raised eyebrows everywhere else, we knew that we were right and then started to connect the ragtags to what I call the credibles [CHUCKLE] and A. J. Birkbeck, the environmental attorney, who represented our little group in 2010. He was a credible. He was an environmental attorney. Dr. __________ 00:13:15, who came in probably around the second half of 2012, and then full in, in 2015, 2016, was a credible, and someone from the DEQ, who was retired, which we loved people- good people who are retired, because they were now neu-, neutral and they could get involved, and Janice Tompkins heard me make a presentation at the river watershed council and I showed her a note that she was concerned, so she joined in and so, A. J. and Rick and Janice were thither were the hub of the credibles, and people respected them, so they could be the face, and Janice brought in other environmental groups, so that I could take what we found here, as the ragtags and then I would, um, I would say I was like second string on the credibles, but, you know, I was allowed into the room. We would go to Grand Valley, and meet [CHUCKLE] in- in, uh, one of the conference rooms there, and I would try to Page 3 �contain some of my angst and passion and- and enter into the rational looking over of evidence and making a plan and an agenda and carefully working through in strategic ways to make the most of what we got and never going to the media because A. J. forbid that, and he was right. We didn't go to the- the, uh, media until, I didn't go to the media until the summer of 2017. That was incredibly important to be the one living here, because I knew- I knew the lay of the land. I learned quickly to get permission to be on any property that I needed to be on to get good photographs and I knew a lot of people anyway who cared. So, I made sure I had lots of places where I could go and get photos. [CHUCKLE] And across the river, they put in this boardwalk high up, and I remember someone saying to me one day, "Oh, look at that over there. You could probably get some great photos from across the river." I'm like, oh, yeah, why didn't I see that? Uh, I found the ladder on the side of the post office and it was a ladder on the side of the shoe- shoe store. [CHUCKLE] I found all my crutches. There was a ladder I used to climb up onto my neighbor's roof of her porch right behind me, because part way during the demolition of this tannery, there's a __________ 00:16:09 and some people __________ 00:16:10 looking at birds. Um, [CHUCKLE] they- they hated that I was taking photos. So, I would- I would go right up to the fence. That didn't matter to me what this group thought of me. I wanted- I wanted photos, [CLICK SOUND] and after a while, they realized they didn't want these photos, so, they would circle at- at the start of the day, wherever they were working, they would take trucks and sort of circle the wagon, I think that's a phrase people used. Maybe it comes from the days of pioneers where you, to protect, yeah. So, they would take any truck they had, except the one that was being used and they would Lynne them up around where they were working. So, I couldn't get photos, and so then I found out [NOISE] that I could, it was higher up over here and I was, and I was up on that neighbor's roof with a good zoom camera. I could see what they were doing. And, uh, I- I taught piano lessons during that time, actually. I- I taught until my mom came out in 2013, so I do remember one day when I'm sitting here, and I'm teaching a piano lesson, and I'm very concerned in November, because I know they're getting right near an area of the tannery that I knew was bad and I'm concerned about dust clouds, and we had- we had at least made some progress with insisting on dust control, even though we didn't have site testing. Again, it was imperfect, but I knew the only way I could get, make sure that they kept up with it was to report big fugitive, fugitive dust clouds is what they called them. So, if there was a big ka-bang, and it was in this really bad part, and I was having a piano lesson, the only thing I could do was what I ended up doing. Uh, I remember the- my student's name was Casey and I- I said, Casey, I said, well, first of all, I'm sitting there in the lesson, I'm listening to her play, and I'm also half listening. You can see the window right there and like we got our ears kinda cranked out the window just waiting and I hear this huge ka-boom and I'm like, oh, my gosh. There's gonna be dust. Casey, I said, do your Mini Latin Jig three more times [CHUCKLE], practice scales, C major, G major, I'll be back in five minutes, and I ran out the back door, through my yard, into my neighbor's yard. I had thethe ladder already there, climbed up, had my camera set, ready to go and got these great photos from the November dust. I came back down, brought my camera, came back through here, as she was doing the last- the last time through in G. Oh, okay, well, let's go back to that one section and then I would just go Page 4 �on with my life. I, uh, I've used this phrase, and I think it was very true for me. They always talk about buy local so, mine was, like, buy local, spy local, it's just part of your life. If you don't have time to do this full time, [NOISE] well, just incorporate it into your life. I still get water samples and make my errands for the day, okay go shopping, drop off water samples, um, and then I would decide, let's see, I have enough money today to buy eggs and frozen vegetables and dah-dah-dah and I have enough money to buy samples to get, uh, let's see, I don't know the Michigan 10, which is the, um, metals, and that's a good deal, but it's-still don't have your $10. [LAUGHTER] So maybe today I'll just do, hmm, chromium [LAUGHTER] __________ 00:00:07. Should I add in mercury for an extra 25? Hexachrome means I have to get it there within 24 hours. No, I don't have time to do the hexa chrome today. [LAUGHTER] And so I would make these little judgment calls about what I could afford, because we actually did have to put money on the table. I have found the ragtags, uh, our group, our loosely formed group CCRR, we decided to pay the money to help us guide us and to be strategic, and that was money enormously well spent. We wouldn't have gotten where we needed to be without that. We needed A.J. Uh, Rick being a professor and a citizen. And of course we didn't pay him, but we did pay for our own samples. And we did pay, um, thousands of dollars, actually over time. And I never regret it, because you never have that moment in time again. Money is this odd thing. You go to, uh, nonprofit groups, and they're always talking about the budget and how to raise money. And, "If we had money, or if we got this grant dut dut dut dut dut dut da, then we could do this." And by the time you really need the money or you could have gotten the information, it's three years later, and it'sit's not even helpful at that point. So my dad, rascal that he was, [LAUGHTER] taught me to love the environment, taught me to not just accept no for an answer, ifif it was a no that was preventing good. And I had inherited some money. I never planned on it, never really even thought about it. And part of it I decided in honor of him I would use that money in a meaningful way to do that. It had a purpose. And my dad, before he passed away in 2011, was curious about what was happening. And it was my dad who had gotten me out into the wilds, into the rivers, swimming, and looking, loving. And it was my dad who taught me to roam, and wander, and figure it out as you go along. So I was comfortable with that. So it was meaningful and necessary. And it wasn't anything that I've everever thought back on. But I do say this to other people who want to get involved. Sometimes you do have to take your own money and put it out there. Because if you wait, you won't have that chance. And companies don't talk about it. They try to run up your bill if you get a lawyer. They try to discourage you in any way. And they have thousands and hundreds of thousands of dollars to spend. And it took them totally aback when we hired A.J., and when Rick and Janice started joining us. And when Westshore Environmental Consulting wrote up our samples into an actual report, which we handed to the EPA. And they were like, because they did not want there to be evidence. They didn't want facts. They didn't want that, and we knew that was the only safe way we could get anywhere. Pe--people, a news story is up and over in a day. They manage bad news, but they can't [LAUGHTER] samples for chromium, uh, mercury at screening levels with the sediment there, which weyou can't expect that. They try, but ultimately can't. Soso my story of being here with the ragtags, and reaching out to organizations beyond finding the Page 5 �credibles, um, being loosely organized, which was great because I compared that to being like a mountaineering group. Uh, back in the old days with mountaineering they used to have the Sherpas who would carry all your stuff. And you set up camp, and then you wait, and wait, and wait. Then you go to the next level. Then finally someone figured out light mountaineering. I don't know if that's a term they use, but just carry it yourself and keep moving. That's kind of how we moved, [CLEARS THROAT] by not being this official, organized group. We had no website. We didn't accept donations. We didn't have to account for anything. We were just sort of had this mutual agreement to stick together. And A.J. was our attorney, and Rick was our adviser, and Janice was our adviser, and they all worked with us. And that collaboration and the energy that comes from that, the mutual respect without having to like write it into a mission statement was there. And for me, I came to just simply enjoy them as characters. And yes, there wereit wasn't perfect. There were certain members who didn't really get the other ones. [LAUGHTER] And I was sort of the translator LAUGHTER] between different members. What I'd say is what I would sort of like explain this and that. "Really?" Yeah. Yeah. I think that's what you're-- "Oh, okay." [LAUGHTER] Because people are really quick to label each other and not move past that. And I guess being a writer and loving stories, I see the complexity, and the humor, and the, uh, human quality of all of us, [LAUGHTER] So I could see theI could be somewhat removed from it, not get entrapped in it, which was very helpful. Danielle Devasto: I bet. [LAUGHTER] Lynn Macintosh: There are a few people that I encountered that I think had I not had that attitude, people would have just decided not to work with that person, or not see the value. And somehow maybe it's just being who I am. Maybe it's being the age I was. I was able to find creative ways to soften things and bridge things, which was really, uh, which was really good because we've all come through on the other side and continued to work together afterwards. And these colleagues have only become more and more friends as we've spent more time together. Danielle Devasto: Well, and it sounds like this collaboration has been really critical in moving forward anything related to the tannery site it seems. Lynn Macintosh: Uhuh yeah, yeah, it was. And then the connections that Janice made, or ideas that others had. And finally myself bumping into or finding people from the DEQ who became interested, even though it wasn't theirnecessarily their project. There was one at the EPA who opened the door for us basically when he heard about early on this disaster. And he confirmed it. Hehe had the authority to call in to the DEQ. He called the city, and he called me back. He said, "My gosh, you're right, there's a total disconnect here. Nobody knows what's going on." And he was the one who said, "Well, if all else fails, get hundreds of photos. Talk to the tannery workers. Get it all done, and send us a petition __________ 00:08:16 , which is what we did a year later. Soso the way this story works is we all worked very effectively. We got the EPA out. After the disastrous, very unsafe demolition they came out and, um, basically, II think [LAUGHTER] I had showed you somewhere over here, you know, in the Rockford Independent, um, you know, there's this big article that came out in September. They accepted our Page 6 �invitation, or our petition. The EPA launches probe at tannery site. And, uh, there's all these nasty things already said about us in that article by the city manager and others. I don't want to go into all those. And it was, uh, it we got some sampling done. And then the city, and the legislators, and all of the players who had prevented things from happening as they should have, they, uh, convinced the EPA to give them oversight. So [LAUGHTER] then later it's kind of like __________ 00:09:28. It's almost like, The war is over! [LAUGHTER] EPA is going away! That's kind of how we felt like, Go away, EPA. We'll take care of it. We'll keep hiding this. [LAUGHTER] You know? Um, and so in 2012, after all our efforts, we worked so hard, everything went back to the status quo. It went back to exactly how it was before it happened. And Lynn Macintosh: I think anybody at that point, except for Janice and me, and Rick and A.J., would have just called it at that point. It's like, "Okay, we tried." Um, we did everything we could and here we are. We know that it rates high enough to be a Superfund site. We know that it's migrating in at least four areas into the river. We have data. We were right, but now nothing's gonna get done, and nothing did for- for five years. The only progress they made, I showed you the spreadsheet, the only progress they made in five years was to dig five soil samples in the wrong location. Danielle DeVasto: And at this point, did they know that there was PFAS involved, or were they just looking for like the chromium and the mercury? Lynn Macintosh: Well, that's what's really interesting. I'm glad you asked the question because in 2010, at the very beginning of 2011, Janice had connected with Bob Delaney, up at Portsmouth, who broke the whole PFAS story and had, was writing a paper about its dangers. And he had been writing his paper about what he foresaw as a catastrophe, really. A looming catastrophe, um, from 2010 to 2012. The same time we were watchdogging this demolition, he was up there writing a white paper. And almost to the month when the, when the EPA handed this back over to the DEQ, our DEQ took his white paper and shelved it. But he had asked Janice one day, "Janice, do you, do you know if they use Scotchgard in the tannery?" So she calls me up, and she says, "Lynn, do you know if they use Scotchgard at the tannery?" My very first interview in July of 2010, was Ralph Gould, whose nickname was Sydney because I gave them all code names to protect them, and in that very first interview within the first 10 minutes he was telling me all about Scotchgard. And I have that interview. I'm not going to get up and go, get it for you, [LAUGHTER] but it's scrawled about the Scotchgard. And I said, oh my gosh, they used it everywhere on everything. Tons of it. So, interestingly enough in 2012, partway through the EP's- EPA's investigation, we followed up our big petition with a second one, uh, Summary of Concerns Part Two, Connecting the Dots. And in that we updated our chemical list concern, and we included PFAS. So, they ought to have seen it, the EPA and the DEQ, it was, it was made known to them, and by 2011, I knew about it and I was concerned about it by that time. But they didn't test for it. This was a really odd thing. This was right- right before Flint, too, and the same director who shelved this report was the same director, Dan Lyon, who was also there during the Flint crisis. Uh, I don't know all the reasons why it got shelved, but if you ever talked to Bob Delaney, he was not to bring it up. He was, you know, hi- his job was on the line. They did Page 7 �not want this. So, he came forward and 2017, after this all blew up over here, and he finally came out and told about that paper. And then after this big explosion with Wolverine, and there was site after site after site after site, there were more sites than I even knew of. We knew of some of them, but there were others we hadn't known about. We knew about House Street. I had been there and walked around its perimeter a number of times, and I'd gotten all my facts that I needed to know about it to make me really concerned. But, um, but I'm glad you asked that because if you go back to 2012, here's Bob, all his work seems for naught, here were are, all our work seems for naught, so- so anybody after spending that amount of time and energy and putting, and getting so much grief without getting into all the grief that I had and all the intimidation that I experienced, and I did have some, a couple things that were, um, quite alarming happen, that would've been the time to thrown in the towel. Except that the tannery site and the interviews had led us to House Street and areas of outside __________ 00:05:08. All those interviews told about dumping, and we started to get more and more information about where specifically. And I kept meeting people and getting more clues. And Janice and I, and Rick, and A.J., because they don't give up, they just wanted to wait it out and keep meeting 'cause the last thing you do is stop meeting because that's Wolverine and everybody's thinking that you are gonna do, so you just keep meeting and hope. You don't know. So, we kept meeting every six months, and for Janice and I it was this burden, this heaviness inside that there could be people who live near these dumpsites, because she worked for the DEQ she understood groundwater contamination, that it could be affecting people's drinking water. So, like, I- I showed, I've showed this picture before. These are some of the children who live out on House Street and Chandler. They're- they're older now. This was in 2018. The best way I can describe it, it was like deep down somewhere you knew that there were people in trouble. It was like voices in a mine shaft. It's like so faint, but you still think you hear something. And it was like it was fate. Didn't have proof. Anything. But it was palpable. That this- this could be a very real danger to people, and we couldn't give up because I was a mother, you know. I'd- I'd raised two children, and that mother bear [LAUGHTER] clicked in, would not let me give up. Um, I just couldn't. It's like nothing told me to stop. Everything told me to keep going. I wished it hadn't some days. I wished that voice would go away some days, but I couldn't. I even would go, uh, one day after I, um, had interviewed Earl, the truck driver, who gave me the most important interview of all, someone who had actually driven stuff there to the House Street dumpsite, and after all these years, and hearing about people who gotten sick in that area, sought me out because I had talked to his son. And he sought me out because he wanted to tell me what he did. He wanted this to be known, and ultimately was wilLynng to have it notarized, and signed and sealed to stand up in court, which it did. And after realizing that what, hearing from his own lips what he did, how it was disposed of, in deep unLynned trenches, raw sludge just hauled out day after day, and poured in and left, he told me about two other locations as well. I'm like, oh my gosh, it's and nobody's listening. Now, I went to House Street one day, and I knocked on the door of five homes, including Sandy Wynn-Stelt's. I looked at there where the dump was, and I saw those five homes, and I thought I don't have a shred of evidence, I have an interview, I have what the tannery worker said, I'm not allowed on that property, I can't test that, but, if Page 8 �there were five homes I'd be concerned about, it would be these five right here. South of it, top grading of it, and just as one citizen to another, I'm gonna at least let them know that I know that this site was highly contaminated, and they took sludge from this site and dumped it there. I knew that. I didn't have any test results. But that if I lived there, I- I would be concerned about having my groundwater tested for safety. And so I did. I systematically knocked on all five doors. But what are you gonna do when someone knocks on your door. Right? I still felt I needed to do it, and what was really hard for me, Dani, was that when I went to Sandy's house, her husband answered the door, and then he died in 2016. So, when this all came out in 2017, then I had learned about that he, that he had died. And I remember meeting this one father with two young kids, and he listened. He was, but I couldn't offer any- any, uh, any proof. So, what we did is we decided, Janice and I decided to get the river tested using a program for Michigan, a Surface Water Monitoring Request, that any river that's not been checked in five years you can request that it gets tested. And, uh, some fisherman had already requested that the river be tested af- down in Plainwell 'cause they heard about the demolition. And the same guy at the DEQ who just took none of this seriously just wrote back and said, "Oh, it's all been tested by," you know, da-da-da-da-da, "no- no need to do this." [LAUGHTER] And then we found out that he had said that, and I'm like, are you kidding, they didn't test any of the river during that time, and you're the project manager. So, then we waited another year, and then we put together our own request, and they accepted it. And, Bob Delaney knew Janice, and Janice had found documents in Grand Rapids that proved that they used Scotchgard, showed where they stored it. Documents that the EPA had requested, and were too burdensome and cumbersome for the company to produce. She went through and found them all, and sent them to Chris Bush at the DHHS. And she worked with Bob, she looked 'em over and she said, "Bob, why don't you work, I- I think that we should bring Joe Bohr in, he works with fisheries there, I mean fish- fish toxicologist, and, uh, when you do the surface water monitoring request include testing for PFAS." So, we waited two years. It's normally a year process, but we waited two years, and in 2015, there was a, uh, fish advisory for PFAS in the fish in the river, and that's what we needed. So we had that, we had Janice's records of Scotchgard, and we had the interviews, and, uh, Rick, doc- Dr. Rediske, Rick Rediske [LAUGHTER] met with Rose & Westra, Mark Westra and Mike Robinson, from the environmental attorney at WMEAC, in an office and they told him that, "Well, no, we- we didn't use PFAS." They- they, like, eh, I have the copy of his memo. They feigned ignorance, and then I think reali-, they think realized they weren't going to be able to get very far with that, but that was their immediate response that we didn't use it. And by then Garret Ellison had started reporting on Wurtsmith, and he had proved his worth as a req-, as a res-, in- in terms of research, and credibility, and in-depth reporting, and I was reading his articles. I heard there was PFAS in Plainfield Township's water and they couldn't figure out where it was coming from, and I was the one based on my interviews, called 'em up and said, I think I know where, and I said, and I gave them documents that the DEQ had in their office there showing that there had been dumping at this Boulder Creek Golf Course, and over here, and, you know, this is the tannery, and __________ 00:14:13. So, in 2017 we took every, we had indisputable proof of their use of it, of their dumping of it, of that people lived in wells around these Page 9 �places, and that Plainfield Township talked about it in their own parks and recreation plan as a former dumpsite for- for the Wolverine Boot Company, or whatever, and that yes, chemicals used at tanneries are known to be hazardous, but as yet there have been no reported problems. Yeah. And then we found out that in 1966, that Plainfield Township had decided to not let Wolverine dump there anymore because everyone was complaining about the smell, and stench, and fires, and everything, and, uh, Wolverine sued Plainfield Township for not letting them dump there. And so the township settled under the condition that, and it's all in that timeline I showed you, they settled with Wolverine and allowed them to use the dumpsite as long as they didn't contaminate the water supply. They contaminated 25 square miles. There are 25 square miles contaminated __________ 00:15:33, and they contaminated the lakes nearby and streams. The plume, um, goes off in, like, the rays of a, like a daisy, like a flower, and the puddles are actually the rays. The- the flowers are the center part of the daisy. But, the- the plume goes this way, this way, this way, this way. It's just, there couldn't have been a worse place to have dumped it, and they dumped it deeply and in great quantity there, and in another place on Logan Street that I didn't know about. So, so we kept going because we kept getting clues, and 'cause we were concerned about the groundwater, about people drinking contaminated groundwater. I- I- I, that's what I'm concerned with. I mean, if the tannery got cleaned up, I knew it needed to be cleaned up, but it was outside here now 'cause we were on city water. And we had just contacted Garret, I did on July 19, 2017, when I realized that the DEQ was sitting on all the information we gave them, just biding their time, and playing around with sampling. Um, the geologist, I don't know if I have it over here, I think I probably do but if I don't I'm not gonna worry about it. [LAUGHTER] I use binders, lots of them. It- it kept me fit, in shape. [LAUGHTER] But there is a, yeah, there's an e-mail that Garret found. Somewhere in my vast array of- of, uh, 3-ring binders there's one that Garret found where the geologist Mark Bohr, the day after- the day after we talked to him in Ja-, uh, on January 24, 2017, the day after he was already concerned and mapping out plumes, and was already concerned about if there was a plume where it might go, and when he realized that they were just playin' around in April, after they finally did some testing to the east, not south which is where all indications were to go south, he wrote an e-mail to his, um, to David Donald and said, "I have a list of 150 addresses here and all my calculations say the plume is gonna go south, and it could go as far as Chandler Street. We need to get testing south of the site." And this was ignored. It was ignored. So, what happened was I finally July is my feisty month of the year [LAUGHTER] when I realized after we were trying to get updates about what the DEQ was doing, and they were just still playing games, this one person in particular, [LAUGHTER] I finally, was upstairs, it was a hot day, humidhumidity, and I said, that's it, that's it, I'm gonna call up that- that MLive reporter, that Garret Ellison. I still have that in my journal entry. It's like ENOUGH, and it's all in caps. It's like it's Garret or no one. [LAUGHTER] That's what I wrote and I called him up, and he first did the fish story, and he was all set to print that when everything came out about House Street. Now, here's something that's really interesting. We found out about House Street getting bottled water through a back door, so to speak. Happenstance, you might call it. I'll- I'll call it Providence because that was hush-hush. They weren't even telLynng the Page 10 �people on House Street that it was Wolverine. They were just calling it a potential responsible party, a PRP. Well, there's a PRP, and then we'll- we'll try to figure this out, you know, where it's coming from. You know, meanwhile, we said, "Wolverine dumped here," [LAUGHTER] you know, and they're, and they're not even telling them where it came from or why. And because I spoke up all these years, a colleague of my husband's, the colleague's wife had a cousin who lived on House Street, and my, andand the colleague's wife was an attorney. And the cousin called her cousin, who was an attorney who would, got up and read all about PFAS, and was so upset and realized how serious it was. And then did the whole Google thing, you know, and then found this and that, and was reminded that, from the Rockford Squire, that we'd been involved. So she calls me one Saturday morning in August and wants to talk to me about bottled water that's being delivered and do I know anything about it. I'm like, what? Where? "Well, I can't really tell you the location, but it's, you know." And so through her, and she was pretty clever, too, she would go and meet with her cousin, and when they were going around, they had this like in-house map that showed the houses with high readings, and this and that, and, uh, she got a couple of phone shots of this map, and got a lot of the back- back story about what was happening and why. And she shared it with me, and she finally told me where it was. And I called up Garret asking him, well, what do you think we should do about this? I just found out they're delivering bottled water on House Street. This is one of the sites that we had been so concerned about. It's bad enough that they're, you know, not taking any chances, you know. [LAUGHTER] And Garret was like, "What do we do about it?" He said, "This is a public health crisis. We report on it and, like, what do you have?" And so I sent him that little map. And it was fascinating because, and I'm gonna use the name David O'Donnell, because this is the person who he interacted with and this is the person who delayed our efforts from 2011 all the way till then, um. When Garret was doing the fish story and was trying to get documents and FOIA them, David O'Donnell, as a courtesy, took Garret's FOIA and first gave it to Wolverine. And Garret found out about it, and Garret was really mad about it. And David O'Donnell knew that. So, Garret goes down I'd love it if he would tell this part, I wasn't there but he goes down to the DEQ, walks into David O'Donnell's office, and says, "So, David, I hear there's a- there's a map for people out on House Street. People are getting water delivered to their homes. Do you have anything you can tell me about that?" And that's how it got out. It wasn't supposed to get out. The right information got to the right person at the right time. I always teased Garret, it was like this baton pass. Like CCRR, our core group, it's like we're running a relay, and you're like doing this third lap that goes forever, [LAUGHTER] five years we're running this third lap, and then there's Garret, who we identify who we need, and like we're exhausted, and we like give him all this information, and he knew exactly what to do and how to do it. And he ran that fourth lap, and then he just kept going, started his own investigation. But he got the story out, and everybody was taken by surprise. That is why it was so effective because they thought we'd gone away. They thought we were just little play things, and just pat us, hush puppies all will be well, right. Just pat us on the head. Well, you know, it didn't work. They tried to get the EPA out, you know. We won, the war's over, and no one is gonna make us do anything. [LAUGHTER] And then they got completely caught off guard, and so did the Page 11 �DEQ, and so did the city, and so did Plainfield. Everybody was completely caught off guard, and it was one wave of news after another. It was House Street, it was this, it was this, and it was such a big, like, almost like a tidal wave effect or a tsunami effect. I don't know the best way, I still struggle for words for that. But it- it couldn't be put back in. That's the thing. For all these years, the city and the company had been trying to keep it all in and covered. And going back to my image of the mine shaft, you know, it's like we had finally reached the people. That's what it was like in 2017. Yes, there were real people, and oh my gosh, I'm so glad we found them. Oh my gosh, what could we do to help? Like, when people were pulled up from a mineshaft, you know, they need triage, they need care. It's like it's still not a pretty picture at all, but at least we reached them before too much more time went by. And that's what's interesting about the outcome is that it was so quiet. We were so quiet all those years. And then just there's this huge knockout punch. They didn't have time to plan for it. Danielle DeVasto: Garret knew just what to do. Lynn Macintosh: I still- I still just shake my head thinking about it. I and I, none of us expected it to be that big. And now it's statewide, nationwide, worldwide. I told, I told Garret I think the story is Wurtsmith, Wolverine Worldwide. And that's how MPART got formed, because good, this is right on the heels of Flint. I asked myself, would Flint, would this have happened without Flint? I'm not sure it would have. I think Flint showed that you can't necessarily trust the people that you think ought to be looking out for you. So that, unfortunately, is a sad way to prepare the soils for the fact that, yeah, and this does happen, you know. Danielle DeVasto: Um, so what concerns do you have about PFAS contamination moving forward at this point? Lynn Macintosh: Oh, it's so hard for me. I- I have a hard time even riding my bike on the trail because I see it, and I know how long it's gonna take for things to get done, you know. And I've seen how litigation works and how that takes so long. And they've been talking about putting in some kind of pump-and-treat system over here. It's four years now. And whenever we have these rain events, I don't know why I do it, but I have video after video where I go down to the river, and I stand there, and I take photos and video. And I do it on days when the foam level is low, and I do it on days when the foam level is high. And I always say, look at this, 365 days a year, 24/7, these foamy trails of water, these paths, them form like little paths so it's like these stripes 'cause they stick to each other, these striped paths flow down the river, into the- the Grand River, and they do leave a trail. And it's still not being treated, and the company's still playing games about it. Just do the work. Just do the work. Get it done. Pump and treat here, pump and treat where it's entering the river. Just do it. Do it now. You're gonna have to do it eventually. Why- why cause that much more harm? Stop paying so much to your lawyers. Just get the work done. What would it be like to actually be the company that did the right thing? That owned up to it? That exceeded our expectations? Imagine what that would be like. You could be that company. No one's stopping you. All that grief, and I see it. I see it in creeks, I see itm and I report it, and now the DEQ doesn't have time to follow-up on these foam reports. But I still track it. I'm still trying to find some sources in Cannon Page 12 �Township, 'cause I- I- I do, I track the creeks, I track it to the ponds, I track it to vacant land, and I research the history of the land. I've learned pretty much what to look for, what- what signals, I can judge vegetation Danielle DeVasto Tid: 579-2 Lynn Macintosh: I- I can judge vegetation that's distressed. I use my nose, and my eyes to judge, um, and I have to figure out which ones to report, which is what they have to do. Which are the worst? But there's 5000 of these chemicals, and we're still, we're still letting them be manufactured. It's actually, it's that there's an- an- an inanity to it and an insanity to it, both. Why are we doing this? Because it doesn't go away. I remember, um, Dani, I would be swimming in Lake Michigan a few years ago, and I was thinking, oh my gosh, I'm thinking about this too much. Like I'm imagining, like, these PFAS bubbles are following me because I'm swimming and I'm seeing this trail of bubbles. I'm like those are just air bubbles. No, they don't seem to be just air bubbles. Oh, you're just thinking about it too much. Well, each year there's more of 'em. Well, yeah, now I get it. It's confirmed. There's PFAS in Lake Michigan. People from Grand Rapids are taking their water from Lake Michigan. Okay. Also, __________ 00:01:29 may need to filter their water like __________ 00:01:35 Township's doing. I don't know. Kids on the beaches are- are near foam. They take foam, they pick it up, they put it on their faces. This is dangerous stuff. And I see it, and I see it, and I've always seen it before everybody else. And in these weird times where I thought I'm just imagining it, like, oh come one, you're just seeing it everywhere because you're thinking about it. Clearly no. It's there. I know it's there. I know what it is now. I just like, in my, I didn't get this out for you today, but in my bottom drawer there,may- maybe I will because I wasn't planning amongst all this other stuff that I have here, um, which is a narrow pass, [SIGH] I keep finding things, and in here I have my journals from seventh grade. And I- I go back and I look at these and I see myself sort of as like a young sapling. And I go back and I'm reading some of these entries, and I start, I- I write about pollution in here, and how upset I am about it. Pollution. "The USA has many problems right now, but I feel pollution should be our largest concern. [LAUGHTER] Fighting wars and sending men to the moon is what is on everyone's mind. But, if you don't start realizing how pollution is affecting your lives, we will all be in danger." And I, and I go on about it. I'm talking about DDT, and- and the birds. Like it must have been shortly after Rachel Carson had come out, and- and how troubled I was. And then I'm, like, hear myself at the end as a seventh grader, "Now I feel I want to help stop pollution for we were given this world, so why should we wipe it out? [LAUGHTER] With further study of pollution, I will even understand it more, and I might be able to think up a way to help stop it." Danielle DeVasto: Wow, wow. Lynn Macintosh: Isn't that something? Danielle DeVasto: Yeah. Page 13 �Lynn Macintosh: And I just came upon this 'cause I'm going through things now, and I thought, oh my gosh, I've cared about, I've cared about contaminated air, or smokestacks and air, and water, since I was in elementary school. I did. I- I- I noticed it then, and I- I couldn't understand why we would let, we would put all this- this stuff up into the air. I think, well, it was before the Clean Water Act and the Clean Air Act. So, I grew up before that. And I would, as a kid, I would just shake my head. And I remember one time I took, um, white water canoeing lessons in the Schuylkill River in, near, outside Pennsylvania, and the river was warm, and I could, it, I mean just being in that river, too, I could tell it wasn't clean, and I didn't like being in. But the thing that hit me was that it was warm. Why is this river warm? It's pretty, so I and I moved out here, ba-, we came back here. One of the reasons we came back here, Dani, from the East Coast was because of Lake Michigan. And I love swimming in that lake. I love it. And I can't swim south of Muskegon anymore. I can't swim especially south of where the Grand River goes in because the water's different from 40 years ago. I've seen it. I've seen the water quality diminish, and it's- it's disheartening to think that this big, beautiful lake, I feel like after I swimming, I need this shower afterwards right about, right afterwards. So, I really, I- I want to do what I can to protect people's drinking water, but I- I want to continue to do things to help shake people awake a little bit. And I think that might come more through the arts and writing, and these stories like this getting out. I- I don't know how. I don't know how, but sometimes you wish you didn't know all that you did. Danielle DeVasto: Yeah. Before we wrap up, is there anything else that you'd like to either go back to or emphasize? Any last points that you wanna make? Lynn Macintosh: Yes, I do, and there are two things, that- that happen quite a bit. Um, a story like this has a lot of dark underbellies, and there's a lot of things I found out about people and about organizations I wish I didn't know. And there was one point where I- I really felt like giving up. I was so tired and I had a friend tell me, to say to me, "Well, you know, you love to tell stories." 'Cause I do, I'm Irish. [LAUGHTER] Comes with the territory and the curly hair. She said, "You should write about some of this place." And I says, I don't even, I don't want to write about it. I said, I'm just so sick of it. It's just, it's just, it's awful. I was really worn down by it. And she said to me, "Well, you don't even have to, like, you don't even have to even write it in a book. You could just record yourself while you're doing things. Kinda have fun with it, and pretend you're this person or, you know, as you're doing it." So. I thought about it and I bought myself a little handheld recorder, I have one in the other room. But, [LAUGHTER] I-I invented a character based on Lake Wobegon, Garrison Keillor. He had Guy Noir who, late at night on the 10th floor of the ACME building, was finding the answers to life's perplexing problems. [LAUGHTER] And I thought, I'll be Gal Noir, and my Gmail was already 003, I don't know why. Lmarie003, and I was just like, Gal Noir, eco spy, sleuth for truth [LAUGHTER], and I started writing about all of it in the third person. And, uh, th- this is my first journal, you know, and I- I would decorate each one. The secret life of Gal Noir 003 eco spy . [LAUGHTER] And I started writing and filLynng these journals. And here's a picture of me on my friend's roof. This is not a good picture, but it happens to be in my journal. Um, but I might try to retell my story through this character or parts of it. But I- I took it to heart and I have recordings. I have recordings from Page 14 �2011 on tapes, and I have journals that span every year, you know, and here's 2013. This is, uh, part two. This is part five the storyteller is born. Um, this is another part here. Every journal is different, you know. It was, interesting to me at the time. This was a sketch book. So I thought I was really funny on this one. I took and I added a lie. Sketchy, you know. [LAUGHTER] And my poem here, Gal Noir, Part Three, The Story Continues. [LAUGHTER] And this was my little quote that I- I had to find some humor, and it was very difficult speaking to my city council when they, you know, they sit there, you know, if they're awake, [LAUGHTER] and, um, they're- they don't like you to go on and on and on either, so I- I said Gal Noir has her own poetry, Gal Noir, la poetess, you know, like I collected all the poems she wrote. Um, [CLEARS THROAT], "Upon addressing one's city council, ration passion, keep it brief, spare yourself and others grief." [LAUGHTER] I learned that the hard way. But when I put it in those that little format, you know, it's like, okay, I get it now. [LAUGHTER] I've gotta ration some of that passion. You know, I can't, I can't, uh, be spoutin' it all the time. Sometimes I felt like when I was going into the city council meetings, like I was like getting off, like I was actually riding a real horse, like getting off my high horse and walking into the city council. The doors were like saloon doors, you know what I mean, and I would walk in and everybody would look, "Oh no, it's Lynn Macintosh." [LAUGHTER] Danielle DeVasto: Sounds like your imagination was Lynn Macintosh: It was. Danielle DeVasto: a useful tool for you. Lynn Macintosh: It was very helpful. Yeah, I- I- I pretend, I- I told people it felt like I wore the scarlet A for activism. I'm like other, but no, I- I befriended my imagination, and I had fun bringing certain people into it. Some people can't go there with you. But like another friend, Gail Mancewicz, who I hope you talk to, she was so upset that I had a, this little code 003. [LAUGHTER] And she says, "Well, who am I gonna be?" And I said, well, you could be 004. She goes, "Well, why 004?" I said, because then together we're 007. [LAUGHTER] You know? So, it was fun to carry certain people into that with you. Other people couldn't really be interested, and that's fine, too. It's who I am. The other thing I wanted to say was I was myself. I used what I was comfortable with. I used my simple cell phone. I used my bicycle. I used the real phone. I talked to people face-to-face. And I don- not, I do not think I ever would have gotten to the bottom of it if I had relied on Google and e-mail. I had to bump into the information. I had to bump into real people because then that connects you and people start to trust you and share and then they bring other people to you. That was absolutely, there- there's nothing, that's one reason I didn't want to do a Zoom call. Face-to-face, real life is so important. Conversation. And then lastly, from 2017 to 2018, for almost an entire year, I couldn't talk about the story with anybody because I was grieving that my worst fears were true that had been harmed. And I didn't want to bother the people on House Street. I didn't want my name to be out there because they were, they were deaLynng with this tragedy. And I kept a lot of it inside, and I was burdened by it. And I was out there on the front porch talking to Garrett and I was feeLynng very heavy-hearted, and he said to me, "You know, you should call up, you should call up Jen Carney." And I said, well- well why is that? He said, "Well, she said she'd like to talk to you sometime. She's really proud Page 15 �for what you've done. 'Cause I didn't want to be looking for that. And I said, "Really?" He said, yeah, yeah, no, I, she's, you know, they And he said, "Listen, I'll give you her number. Call her if you want." So, I called her, and it was lovely because her name is Jennifer Lynn, my first daughter is Jennifer Lynn. She has a lovely personality. We enjoyed talking. And then she told me, what she said made all the difference to me. She told me how sick she was. She told me how she thought she was going to have to get into a wheelchair. That family was gonna have to move in. No one could figure out what was going on. She was that sick. It was a total mystery. And it was that bad. And then I asked her, so how is it now? And she said, "I've gotten better every single day since I stopped drinking that water." She says, "I'm not having these symptoms anymore. I'm not having these symptoms anymore." She says, "Every day for a year, it's not been all at once." But she says, "But I've gotten better." And I just, I was on the other end of the phone Lynne and I just started crying. To hear that from her own heart and from her own mouth, that all this work, because it was a lot of work, it was really hard work. I look back, I- I say, who was it that did all this? That was me? You know, 'cause in the middle of it you don't think that. But seeing, like, a real or talking to a real person that you just have a sense that there's something wrong and actually hearing and hearing that they're getting better, that- that broke a log jam for me, but I couldn't talk about it much till then. And I'll never forget that day. In fact I probably could've started with that story because, yes, your imagination helps you, yes, working with other people help you. All these things, but it's like the fire trucks finally showed up. We've been talking about it for all this time. No one believes you and they tell you, "No, it's not fire," or "No, that's not smoke, that's mist." "Oh, no, it's where you're standing," and just, "It's a mirage." And finally, the fire trucks showed up in 2017, and things are changed and will continue to change, and, um, that makes all the difference. That's really what it's been about. And that's what it was about for me, and for- for AJ, and for Rick, and for Gail, and Janice. There wa- there was nothing that we wanted for ourselves. We just had a burden that we carried together. So, yeah, I think that's probably a good place to leave it. Danielle DeVasto: Yeah. Lynn Macintosh: Because we need to care for each other. We do. We- we can't just like it someone else's problem, right? So, anyway, and I'm so glad I've gotten to know some of those people out there. I've gotten to know Tobin and Sandy and Jen some, so yeah, completing that. Danielle DeVasto: Thank you, Lynn Lynn Macintosh: Yeah. Danielle DeVasto: for having the time to tell your story today, or at least Lynn Macintosh: Yeah. Danielle DeVasto: part of it. [LAUGHTER] Lynn Macintosh: Part of it. Danielle DeVasto: Yeah. Lynn Macintosh: Yeah. Danielle DeVasto: Okay, thank you. Page 16 � Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Living with PFAS Interviews Creator An entity primarily responsible for making the resource Devasto, Danielle Description An account of the resource Beginning in 2021, the Living with PFAS interviews were recorded to gather the personal stories of individuals impacted by PFAS contamination. PFAS, or per- and polyflourinated substances, are a large group of human-made chemicals used widely since the 1940s to make coatings and products resistant to heat, oil, stains, grease, and water. They can be found in countless household items, including food packaging, non-stick cookware, stain-resistant furniture, and water-resistant clothing. These chemicals are often called “forever chemicals” because they do not break down easily, can move through soils and contaminate drinking water sources, and build up in animals, plants, and people. PFAS have been linked to increased incidences of various cancers, increased cholesterol, decreased fertility, birth defects, kidney and liver disease, and immune system suppression, and thyroid dysfunction. It is estimated that PFAS are in the drinking water of more than 200 million Americans (Andrews & Naidenko, 2020). In Michigan alone, over 280 sites have PFAS contamination exceeding maximum contamination levels for groundwater (MPART, 2024). Date A point or period of time associated with an event in the lifecycle of the resource 2021 Source A related resource from which the described resource is derived Living with PFAS (project) Rights Information about rights held in and over the resource In copyright Subject The topic of the resource Oral history Personal narrative PFAs (Perfluorinated chemicals) Groundwater--Pollution Publisher An entity responsible for making the resource available Grand Valley State University. University Libraries. Special Collections & University Archives Identifier An unambiguous reference to the resource within a given context DC-11 Format The file format, physical medium, or dimensions of the resource video/mp4 application/pdf audio/mp3 Type The nature or genre of the resource Motion Picture Text Sound Language A language of the resource eng Oral History A resource containing historical information obtained in interviews with persons having firsthand knowledge. Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Identifier An unambiguous reference to the resource within a given context PFAS0024 Creator An entity primarily responsible for making the resource McIntosh, Lynn Date A point or period of time associated with an event in the lifecycle of the resource 2021-07-29 Title A name given to the resource Lynn McIntosh, 2021 (Interview video and transcript) Description An account of the resource Lynn McIntosh grew up on the east coast but has lived in Rockford, Michigan for about 30 years. Lynn noticed foam and filmy substance in the river in about 2010, and began taking photos of the contamination. In this interview, McIntosh discusses her work to bring public awarenss to PFAS contamination. Contributor An entity responsible for making contributions to the resource DeVasto, Danielle (interviewer) Subject The topic of the resource Oral history Personal narrative PFAs (Perfluorinated chemicals) Groundwater--Pollution Source A related resource from which the described resource is derived Living with PFAS (project) Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/page/InC/1.0/?language=en">In copyright</a> Type The nature or genre of the resource Moving Image Text Format The file format, physical medium, or dimensions of the resource video/mp4 application/pdf Language A language of the resource eng Publisher An entity responsible for making the resource available Grand Valley State University. University Libraries. Lemmen Library and Archives https://digitalcollections.library.gvsu.edu/files/original/80d67353bf054dbb2a4c497966ad0e45.pdf a4530af29cdf0152c99095b80d18a6f1 PDF Text Text Living with PFAS Interviewer: Danielle DeVasto Interviewee: Lynn McIntosh Date of Interview: 8/11/2021 Lynn McIntosh: Okay, today is August- August 11 or 12, 2021, and it's an interesting year, and an interesting time to talk about the story of CCRR and how our work together brought breakthroughs in regards to PFAS contamination. More than we ever would've thought or imagined. But it all started with a tannery, a tannery located in Rockford, Michigan. Um, this is a view of the tannery site prior to demolition [see Artifact 1]. It's a map that we'd found that had nicely labeled the buildings for us, and anything that we found like that we used and then we also enlarged it. And so this map helped us to understand some of the stories about why we should be so concerned about the demolition of all these buildings without any, with so few environmental controls that it was an incredibly unsafe demolition. What happened was the tannery closed down in 2009 on January 8. It took some time to think about it, about what they were going to do. And this paragraph at the front of this one booklet summarizes the heart of it [see Artifact 2]. "During that summer of 2010, when Wolverine was preparing to demolish their 100-year-old tannery site with little to no environmental testing and claimed on an application for Brownfield Funds that there is no known contamination on the property, I knew it was hogwash. Legalese laced with hogwash. And the city of Rockford was drinking it down because Wolverine had promised them a state-of-the-art brand new shoe store to spiff up their commercial district. Everyone knows that tanneries are contaminated and that demolitions of such sites are risky business. But no one was addressing it. It was off everyone's radar." And as I read this, I realize that it's fun to read it, because that's written with a little bit more of a flavor of a writer. I would have to have removed any inflammatory, uh, language from that document if I wanted to send it anywhere [LAUGHTER], which I spent a lot of time doing actually. But what happened was, is that—and it can be read later—the summary album talks about what happened as a result of finding that out. We—uh, a short PowerPoint was put together talking about the site, and why it was concerning [see Artifact 3]. Tannery sites and paper mills are notorious for being rife with contamination. We knew that it would likely have some areas of contamination and so did the DEQ, and they partnered with the MEDC (Michigan Economic Development Corporation) in desperation after we contacted them to put out a carrot to Wolverine and said, "Hey, listen, if you at least test the soil and the sediment, the soil and the building materials, and do a” – they call it a phase 1, phase 2 site characterization. Here it's called an ESA –“we'll give you money to help with your costs." Because you see, there weren't any files that they could find because the company had cleverly, it was very careful about what they ever gave, and a lot of things had been, had expired their retention policy of 10 years. There was so little information to be had, so they didn't want it known. But they withdrew their application without any public knowledge of environmental conditions. They weren't required to do a site assessment, so they didn't do it. And if you read through this, you'll see that it was a dusty, dirty demolition, and now that we know how bad things were and how little there were in terms of air control, they never closed down the public sidewalk, dust was in the air, the river turned brown on one side many, many times. We've got photos of all of this. Storm water was a real problem. People were still using the river. Areas Page 1 �that we had found out were going to be problem spots, this is one called The Pit. These soils were later removed, were problems. [LAUGHTER] Uh, dredging occurred in the river and places where it shouldn't have happened. Kayakers came through the river that very night. Kids played nearby, on and on and on. Hides, everything. These are not high quality photos, but high quality photos ought to be available at some point. But that was very, very concerning. And in order to figure out and put together what was going on and what was wrong, we called the DEQ and got whatever we could. We did a Freedom of Information Act request, which gave us some information. But it was meeting tannery workers that really, that really gave us a sense of what the site was about and what the problems were. We found them in various ways, but one of them was particularly helpful. And we used materials that were already printed and available, like this map, which was really something that was used in some documents that we found by FOIA request. FOIA got to be a household word. [LAUGHTER] But these were maps that we found from FTC&H for storm water pollution prevention plans [see Artifact 4]. So then we took these documents and we would talk to the different tannery workers. And this is one of the very first interviews I did with someone named Harvey White. And he went about and told me what the problems were. And he was talking quickly, and I was writing it on the paper, and I was also writing it along the side. I still have all my little notes. These are all in pencil. They've since been recopied. But the long and short of it is after that first interview, it was very, very clear that this was the heart of the concern, all along the creek, this part where the river is over here. And from the very beginning, we got the sense that number—this area here, the tannery, the hide house and the wastewater treatment plant—and this was area of concern number one, two, three, and later over here area four. Danielle DeVasto: What is this? Lynn McIntosh: This is called the power house and the laboratory, and a lot of, uh, lead and soil, very highly contaminated with lead and other, uh, VOCs, volatile organic chemicals, and everything were, um. [PAUSE] Well, what's interesting is you can see it on this map here [see Artifact 5]. This is the pit where they cleared out part of it. And then these are the soils that from a distance, even from here, you could see that they were contaminated. And in tracing back documents way back to 1994, we found a document that is in existence somewhere here. It was the 1994 ESA of the site, which nobody bothered to find. I know where it is 'cause I've seen it today three times, [LAUGHTER] and so I think I might just get up from my chair for a minute and go hunt it down because it's part of the story. This is a backyard. Danielle DeVasto: Okay. Lynn McIntosh: In 1994, they had already found, by the—okay, yeah, well these are great pictures of The Pit, I didn't mean to get those, but anyway, here's a great picture to show what we were just talking about [see Artifact 6]. Um, the soils by the power house, the dark soils—which later had to be removed when the EPA came in—were all here, and then further back. And so we saw all this as demolition was occurring, and this was the notorious pit right in here. So, the pictures correlated with what was later found. And here's another example. So it's fortuitous that we have this book the workers were talking Page 2 �many, many times about. And you can't see it very well on this document, so we later went and put this together based on the interview [see Artifact 7]. The nice thing about it is it’s taped, but it's not permanent. Here we go. We had to fine tune [see Artifact 8]. We had to figure out what the hot spots were and this was our first map based on the interviews. There's the buried USTs near the Power House. Remember you asked about that. Which we just saw, uh, yeah. Things are going to fall, and that's kind of what happens when you have your materials all scattered out in front. That's all right. It's a story. The four hot spots that the workers told us about from that very first interview, didn't include the later five, six and seven that we added. But, Harvey told me about two tanks here and here. One was filled with pure chrome and the other one was full of sulfides or sulfites, and another tank here, and they were never emptied when they redesigned the tannery. They couldn't figure out how to empty 'em. So they decided, oh, well, let's just build around them. We'll just forget about it. They wanted to recoup the cost, but couldn't figure out how to do it. So they were built into the structure of the building, and yet the question remained what happened to all those chemicals and are they still there? When they demolish it are they gonna come gushing out or have they already leached out? Nobody knew. But he told me about them and four other workers did, so I knew they were there. And he told us about this pit area, which I showed photos of, where they removed half of it during demo because no one tipped them off that it was such a bad area. And there was a cement floor on top of this area under the maintenance building, and it had been there for as long as the tannery had existed. And all waste products from this side of the tannery to this side of the tannery, all waste products eventually pooled in the bottom of this waste area, which was had a dirt floor, and then there were pipes that would bring it to the wastewater treatment plant. And then they would always back up because of hides and other debris, and then they would spill up onto the floors and the men would walk around up until 2008, when it closed. They would walk around in this, as, um, our colleague, A.J. Birkbeck called it, "This toxic soup of chemicals." Which it was. So, he tells us about these tanks. He tells us about the pit. So we make the tannery the number one hot spot. The wastewater treatment plant was the worst because of all the pipes in here that were always breaking and cracking up. And Harvey tells me the story and showed me one day when we visited the site in 2020 where his friend died. He and another worker died, standing probably in that area where my big arrow is, because they had to go down and clean out these big, broken, cracked pipes and they got overcome by toxic fumes. Two men died that day. And I heard that story from all the workers. And one woman was a young widow in her early thirties with children, and, uh, one died trying to save the other. So we knew this was a horrible area, and this was really horrible, too, because also the river didn't used to go like this. This big rounded peninsula didn't exist. The river was straight acrost here. They built it. They filled it in first with all sorts of things, and built this huge wastewater treatment plant on top of very soft soils. So, we took that first map and then we fine-tuned it. And again, Dr. Rick Rediske, from Grand Valley, was the kind of person that it just didn't have to be on a computer screen. He really enjoyed the fact that I use colored pencils, and markers, and sticky little label things, and this was good enough. It Page 3 �worked. It showed- showed everything. But it needed to be fine-tuned so then we got close in, and we learned the best thing to do is make things big so that people can describe things to you and, uh, you can understand it, and everybody can see what's going on. But we highlighted the two tanks which were here and here, and upon other interviews, we then found out that actually in between the tanks were thesethese pillars which, I mean, these—I'm sorry, let me get this right. There were tanning drums and the tanks held up the tanning drums. So actually, these tanks had a dual purpose and these were the, were the drums. And you know what's really interesting? The tanks looked more like this. So, [LAUGHTER] now that I look back at it, I'm not mechanically-minded, which is really funny, those are the tanning drums, and these are the what they would call, um, above ground reclamation, chemical reclamation tanks that had a dual purpose. They also held up the tannery drums. Which was interesting because during demolition that was something we were looking for. And we knew about all these spills here, and we knew the, about the chrome tank and the sulfide tank, we knew about the maintenance building, that there was a cement floor on top, too, because when they found all that awful stuff in there back at the same time, they, uh, didn't empty these tanks. They decided not to clean it out. They just put a cement floor on top and called it good. So, what was interesting to watch unfold based on our map, that is now attached to this earlier, which is fine—love scotch tape—um, we took it and we fine-tuned it after we got more detailed information. And then one day, lo and behold, we saw the tanning drum up here because this building had all been completely covered over. There was no way anyone could have cleaned them or gotten to them unless they broke through that outside wall. And there was the drum. There was the- the tanning drum and there was the above-ground storage tank. Just like they said. [see Artifact 9]. Um, and then here's the technical word. They used these as pillars to hold up the tanning drums. They were built into the structure of the tannery during, you know, a reconstruction process. And it was just like they said. Just like they said it was gonna happen. And so there are more photos probably in other places that show that in greater detail. But here again, is another view of it. And here's the, here's the quote from George. He said, "Here's something else that you should know. When Wolverine was redoing parts of the tannery, there were these two huge cement tanks about 20 feet by 25 feet and 18 feet high. They were pillars that were used to hold up the tanning drums, but they were also storage tanks. One tank was filled with chromium and the other tank was filled with sulfides. Wolverine wanted to be able to reuse these chemicals and not waste them. That was pure chrome in one of them. But the engineering project turned out to be a nightmare. Yes, it was very poor engineering. And as a result, Wolverine decided to just build the new area around those tanks. Yep, they just kept them there. No, they were never emptied out at that time. Yes, they are above ground. Yes, the tanks just became part of the building structure.” And then we had found out in Whitehall and their demolition, that the building materials at the Whitehall Leather tanneries were impacted. That the concrete was really contaminated. There was a lot of toxic buildup in the materials themselves. So these tanks were, indeed, the building material, the concrete itself was contaminated. Another photo shows they were mostly blue, which later when they Page 4 �removed the soils from under them, they were bright, bright blue, and they went down very, very deep [see Artifact 10]. And all of this happened in broad daylight, and there was dust going this time, and Wolverine in an official document from their environmental consultant, made the case, they said that they had cleaned them before. That they power washed them. They called the former chromium and sulfide reclamation tanks, which we're looking at and inside after removing these materials, they power washed the walls and the floors. And that was just absolutely an impossible thing to do because they didn't appear [LAUGHTER] until the wall got crashed into. There's no way. So you find things like this in official documents and you go, how do they get away with that? Uh, but they did it over and over and over again. It was impossible. This shows more of the blue cast to the color. And they were left. They should have been covered every night. So, chrome and other things could go into the air. And here's a long view of that same area, which is interesting because this shows them here and here [see Artifact 11]. So we would watch and it's like, oh my gosh, look, there's the tanks, there's the drum. There was another drum over there, just like they said. Better view. This just is dust all weekend that just kind of came off. So, to fit, to go further with that theme, what's interesting is that eight years later, when the EPA finally put in a unilateral order to actually go back and really test this area—again, I always feature that photo—we, uh, we went back to see where hex chrome was a problem, and, uh, they found hex chrome in the groundwater [see Artifact 12]. And it shows in this area where they had to excavate this all last year and the year before, all these soils, and they had to go deeper and deeper and deeper. And there was this picture in the paper and everyone talks about the- the- the, uh, [LAUGHTER] the blue chrome. "Did you see that bright blue soil? Man, they really cleaned that up." I'm thinking, yeah, I knew about it in 2010, actually, after my first interview with Harvey. Wouldn't you know. And then here, this was sulfates [see Artifact 13]. And here- here's the, right where they said, there's the drum with the sulfates. Rick Rediske, who was so kind to appreciate my hand-drawn maps, once we had these nice professional ones, he just was delighted that my simple little maps, which came from the help of the tannery workers, were spot on. Here again, two, these were the two tanks, this is vanadium, another chemical [see Artifact 14]. Just while we're in these maps, Chester talked about PFAS and PFOS everywhere, and how it would spill up out of these tanks there [see Artifacts 15, 16]. Harvey also said there would be like boats of foam and film. And another worker talked about this area, sometimes it looked like it had just snowed in July because there so much PFAS that spilled here. And then, yeah, here we go some of the heaviest spills right here. That was from Chester's interview, just like he said. And of course, this makes sense too, because this area is where the original factory was. So this was a really bad area because they originally contaminated all this, and then hopped over and continued to contaminate that side. But, uh, same thing with PFAS, again, just like Chester said. And, uh, hex chrome again where the chrome tank was. So without getting into all the maps, there's a lot of them, we went back and we took a couple of the worker interviews, and particularly with chromium and sulfites, and PFAS, we matched up the areas that they talked about. So these pictures, again, which we made large [LAUGHTER] we would show them, tell everything. And it was because of a camera, people willing to talk about it, photos during the demolition, photos of the soil, you Page 5 �know, it wasn't hard not, like, to notice these things. And also we noticed things like the awful hides and the foamy water on the river [see Artifact 17]. It's like, it was almost embarrassing how obvious it was that there was a problem and that no one had asked questions. You know, other people had seen these hides. Look at them. Just these ones look like snakes coming in [see Artifact 18]. These ones are actually, like, just they're part of the bank, the creek bank itself wrapped around them [see Artifact 19]. They just got rid of them. If you went up off season, you could just see them, they were piled. When they finally removed them, they were like six or eight feet deep in there. They had to tear down the whole riverbank because these hides contain chemicals. They were treated hides. So, talking to the workers, and climbing and clamoring along the creek bank, getting out of the kayaks to get photos like that. [LAUGHTER] Get photos of active demolition [see Artifact 20]. Yeah. And here's the and- and- and trying to prove that, yeah, I mean, when there's demolition going all on this, there should be a tent around this. And there's people on the sidewalk. And this demolition area is 10 feet away. It was so incredibly unsafe. We couldn't stop the demolition, so we got photos, got interviews and then went back to the EPA to get them to come out and test. So, these maps apply to- to later, but they're also important. Danielle DeVasto: Do you want to pause? Are you transitioning? [LAUGHTER] Lynn McIntosh: Good question. Um, [DRUMMING NAILS] Yes. Danielle DeVasto: Okay. Lynn McIntosh: It was a very unsafe demolition, and what the tannery workers had showed us, all these hot spots, at the there was just the four. The wastewater treatment plant was horrendous. We got tons of photos of that. We were advised by someone in a different department from EPA who kind of came along beside us and validated our concerns. He said, "Listen, if, uh, this is what I know." he says, "I've checked out everything you said and you're right. There's a disconnect here between your local Department of Environmental Quality and your city and the company, and I don't understand how this has happened without a project leader with no environmental consultant for your city." He says, "We won't be able to stop the demo, but you can keep it safe," and AJ concurred, "by at least screaming about dust, and making sure you get photos of dust that goes into the air or any sediment that goes into the river. Get the worker interviews. Get background. Use this time. Babysit the demo. And when you're done, take all that and send a preliminary assessment petition to the EPA." Now, I didn't know what a preliminary assessment petition was, but it's basically a petition citizens can send. It's rarely accepted. It's not the usual way that sites get discovered. But if your local entities and your legislators, no one's listening. Sort of the opposite of what is happening out in House Street right now, where there's a lot of legislators listening and a lot of media paying attention. It was total opposite here. No legislator. Everybody was in on keeping this, uh, quiet, this environmental disaster. And they were spinning tales about how the company went above and beyond, and on and on. But he said simply, "What you do, you live near the site, and you explain how your concerns haven't been addressed, include some documentation, and send it to the EPA." He says, "And I know someone who's a good man in that office, and I will give you his contact information and make sure it's on his desk." Because he wasn't directly involved, he was able to Page 6 �do little hints along the side, as did someone from the DEQ in another office up north. So, we put it together, we wrote a letter, um, we gave an overview of our concerns. There were three of us who spearheaded that effort and, um, we put together an 80-page document with seven tannery worker interviews, uh, photos [see Artifact 21]. It was a binder like this. It was chock full and it was well-written. It was thorough. We tried very hard not to make it inflammatory. To keep it very scientific and, uh, followed the instructions, and AJ helped us with it. Our attorney. And we got it to a quality that we thought might help make a difference, and within a month they decided to take the site. Hence, the headline. [LAUGHTER] Now, the other newspaper in town, The Rockford Squire, was covering nothing about this. But this particular editor, Danielle Arndt, always liked to report on two sides of things, and so she looked in both directions, asked questions all around, and, um, we had been handing her things here and there, and then when we added it all together and we had something to report, she came and she wrote an article about it [see Artifact 22]. And had we not done this—this is where it talks about citizens- citizendriven efforts are rare, um, and there's no guarantee, but they'll, if they think it registers, uh, to be of a high concern, then you, uh, might be considered. It's fascinating to go back in time and read some of it. Um, [LAUGHTER] the comment from our city manager, um, "This group has not shared anything with the city about its end goal." I mean, we attended four months of meetings trying to get their help. But our biggest fault was this. "Although we had filed more FOIA requests than I've seen in all my previous years [LAUGHTER] as city manager, if Wolverine is willing to voluntarily do testing," which they did not, "and to share the results of that testing with the public and how that will play into anything the EPA might do, I don't know. But I don't think we can ask for much more from them." And it was, that was, that was like a, that was like getting a smiling face to have him say that little for the city compared to some of the things that were said and done. But nevertheless, they didn't like us trying to get to the bottom of things, and the long and short is the EPA came out, and they did find problems, and one thing that we reported to them—and I'll get back to that, it's not really the time for that—they found substantive problems, and they produced a report which was very lengthy, called the CERCLA report, after they did a site investigation [see Artifact 23]. Joe Walczak did this report, and, um, they found four potential sources of contamination. [LAUGHTER] In the tannery [LAUGHTER] and, um, waste water treatment plant area, and near the powerhouse. However, they managed to not do any testing in area number three, the hide house, which has always been interesting because they never have. Okay. They considered this bank of the river as an area where, like, contamination was migrating, and then it was, big time. So, they had their four source areas. They, uh, one of them was the pit and, um, in the wastewater treatment plant area they noticed, and that the extent of the contamination was not fully delineated. And so they, there was a, uh, 16-page written report, and then it probably had 200 pages of tables and this and that. It confirmed everything that we had been concerned about, and it scored high enough to be listed on the national priority list, and they printed the information. And then when all was said and done, there was a lot of political play and play on the city, tons of letters going back and forth, letters to the DEQ from Rockford's Economic Development Page 7 �Corporation, letters from—oh, here's the original petition that we sent with our signatures and 25 others. They redact all that information later. That was the official page of it. US EPA, they have my original. Uh, that's the original letter. But when they were all said and done, there was so much [SIGH] upset on the part of the city, and the business district, and the company, and even the local DEQ wasn't coming out looking very good because they hadn't caught all this stuff. And everybody made a lot of noise. And what was decided was that if Wolverine would agree to something very unusual, according to Michigan law, which is if they commit to working with the MDEQ under Section 14b of Part 201, which requires MDEQ approval of your work being conducted, then we will waive our authority under CERCLA, and we will hand it back to the state of Michigan, to the city of Rockford, to Wolverine Worldwide, and to, um, the relief of all the business people and all the legislators. And they said, "We will periodically review the work being performed at the site, retain our enforcement authority," which is the absolute most important thing, they said, "and reserve the ability to resume the status of lead agency, if necessary” [see Artifact 24]. Now, what's interesting is Wolverine based their whole premise for an unsafe demolition on a statement in a document that says there is no known contamination on the property. Period. I'm not going to get that document out at the moment, but no known on the property. That little preposition, on the property, I thought about that a lot, and I used to play with it. How our health and safety all depended on that little vague little preposition on. Well, they didn't say anything about under the property. They didn't say in the property. [LAUGHTER] When they mean on the property, do they—so, it was interesting how that one word, that two-letter word was so pivotal to them getting away with everything. This if also changed everything because when all of us went back to the same players, the same DEQ, that same director, the same city, the same legislators, the same company who had done nothing to protect us. And it went back to the same old thing under a program called OCA, which means “other cleanup authority,” which is funny. What does the other clean up authority mean? Means nothing. It means like, we couldn't come up with something better, and we'll just call it OCA. It's like, okay, well, that sounds really strong. Basically, it means like, who is, who is this other, this big, amorphous other? And that's exactly what happens. Nothing gets done. That is why we latched on to the if, and we made sure that reports came twice a year. Usually it's once a year. Now they were uneasy somewhat, giving it back, because they knew it scored high enough to potentially be a Superfund site. But by Wolverine's attorney finally agreeing to require the DEQ's approval, which evidently took quite a bit, which again, meant nothing because there were two places where they, they ignored the approval anyway, this gave some hope for it to come back to the EPA. But it was really a long shot, and we knew it. So it's like, the whole house of cards fell down. It's like playing Candyland, and you go all the way back to the beginning. I spent two years spending hundreds of hours, plus you know, documenting and talking and assembling all together, and one of the best preliminary assessment petitions that the Superfund-appointed person had ever seen, and it all went back to where it was. And at that point, it was like we lost. They won. And they were like, I mean, you could feel the glee in the air. It, it's like you know the war's over. It's like, we did it. Phew. We got out of that. So the newspapers were full of, I don't know if Page 8 �I have another copy, probably hiding in a document. But it was announced, “EPA knows”—this is not the Rockford Independent. “EPA turns tannery site back to Wolverine and DEQ” [see Artifact 25]. Phew. We got out of that. So here's Harvey, the tannery worker who came. He came to that meeting. There’s A.J. Here's another person, Gail, who helped us. I'm back in here somewhere. It was a meeting that they, they had had with, they were. So, yeah, that's the meeting, and after that, it was decided to hand it back. So anybody who was sane and who wanted to go on with a normal life would have given up, and I tell you we would have given up. But this is the interesting thing. Because we explore the tannery site, we understood that Wolverine was hugely irresponsible about how they handled their waste. We learned about dumping sites near homes where they had poured raw sludge onto raw soils. And we learned about numerous places that the workers told us where there had been offsite dumping, and homes were now being built on those farms or near those gravel pits or wells that were near a ravine where stuff had been just thrown into. And I myself witnessed, in broad daylight, in August of 2011, the company started hauling. We don't know if they know, but they're, they're, um, they employed Pitsch to handle the demolition and the carting off of waste, which was supposed to have gone to a licensed landfill where, upon receipt of the waste, it would then also be tested to make sure it wasn't too hazardous to be deposited here, stored here. And one day in August, when the trucks were coming back and forth fast and furiously, I had a sense that they weren't going to a proper disposal place, and they weren't. They went up the road four miles away to a pit, which was a sand and gravel pit for simply removing sand and gravel. It wasn't an area to receive industrial contaminated waste. Yet that's where these trucks were going, and I, I chased them through Rockford and up north with my camera. It was quite, quite interesting. And I made sure I got shots [see Artifact 26]. I got shots showing that soil went in there. I made sure that I did a time sequence from start to finish [see Artifact 27]. From when they left the site to when they entered the building, and I had it all timed, I followed them, you know. And I got it. It's not in order right at the moment, but it, it goes from when they were actually loading the stuff in to when they pulled out of the site and traveled up the road and brought it. And I was outraged. I couldn't believe it, because they were taking it from the number one area of concern, and they were digging up soil, which they weren't supposed to do at all. And they were digging up contaminated concrete also from that soil. It was blue. It was all sorts of colors, and they were throwing it into these trucks and carting it away in the light of day. And when I realized that they were getting away with it even now, when they should know better and should be keeping watch on this; and I realized there were people who lived around the out perimeter of that area; and when I realized all the things that had gone on and all the areas in my county that were recipients of this, Janice and I couldn't give up. And Rick and A.J. didn't want to give up either, because they're the ones that know it's important to stick something out. But for me and Janice, it was like, we got the tannery here. We're worried about the groundwater here and what's going into the river and on the site, but we're even more worried about the people who live outside our tannery. I mean, not outside the tannery, but outside this one particular Page 9 �site. All the other areas, I may have said this before, but they basically used North Kent County as their litter box for years, and we couldn't give up. So for five years, we went underground and dug around and tried to get more and more information to try to fill in the gaps and find out more about what was going on. And we started to put together a report card, so to speak [see Artifact 28]. We took the seven areas up here, and we tracked what had been accomplished in terms of either studying it further or cleaning it out if it was bad. So during the demo, they removed soil from the pit. Nobody knows what happened to it, but they removed it. And then they removed 10 cubic yards of contaminated soil from the wastewater treatment plant over here. That we know. We have a waste record for that. No waste record for this. They saw all those stained soils over here that later, in 2019, were removed, but they covered them over. They didn't do anything. They were observed, not removed. And then again, it stated that there was no testing of soils, sediment, or water pre-demo or during demo by Wolverine or the DEQ. Nothing happened in 2011. In 2012 when the EPA came out, we got some samples. We got about eight to 12 samples because some of them failed. They took one in the wrong location. Here they did some XRF screening, but no soil sampling. Here they did the same thing. Number six. No sampling, no soil sampling in this really bad area which later, now, has all been removed. And they got four soil samples here, three here, and one here, and one here. I mean, we used to talk about eight holes in the ground. They came in and made eight holes in the ground. And they found enough in those eight holes in the ground that it rated high enough to be on a Superfund list. It goes back to everybody. It goes back to the city. And then here we go, 2013, they took five more samples near the powerhouse, but they hit the wrong location, and we were able to prove that. So what good did that do? And they removed nothing. And that's it. They did nothing in 2014. They had a plan where they wanted to do some work on this side of the creek, but that wasn't even an area that was pointed out. They hopped the creek, and instead of sampling areas one, two and three and four, they went over and created this new area. And the DEQ did not approve it, and they, they did it anyway. So they just bided, they just bided their time, bided their time. Five years, went by. Five long years. And we waited and waited and waited. We tracked these work plans, where like, 100, 100 or more pages long, each one, that went nowhere, just kind of going, getting lost in labyrinths of, of documentation that was meaningless. And Rick was excellent at helping to find the holes, and we helped. We all did that. I'm not going to go into all the detail there. But in that time, some things came together. And by the way, these are all the reports that we had to go through and disprove, all the Rose & Westra reports that continue to put out information that just needed to be disputed over and over and over and over again. But what happened in that time was that we started to track down the PFAS because we had seen PFAS in the river, not knowing it was PFAS. And we were concerned about, I showed a picture earlier about that sudsy, filmy, really weird it was almost like having Saran wrap on the river and that it would chug into foam when it was agitated. We were trying to track down the waste areas, but what helped us was in 2013, while nothing was happening at the site, one of the truck drivers who used to pick things up here at the Wolverine Worldwide site right near this wastewater treatment plant area, he would Page 10 �fill up the back of a, just a regular old trash truck that had a bucket that would hold a large vat, I guess, opened at the top. And they'd fill it up, the sludge buckets, and they'd put it on the truck. And he told us how he would drive it out to the farm on House Street, and he would line trenches that were pre-dug; six to eight foot deep, eight feet wide trenches. It was, it was a waste disposal site. It was actually known as Wolverine's waste disposal site. And Wolverine, which was required by the EPA to tell them that, and every other place they disposed of and every chemical they used, didn't do that because it was too burdensome and cumbersome. And EPA didn't follow up because that's already been decided. It's not our authority. So we found this interview with Earl, and he allowed us to do a transcript of it, Earl Arlo Tefft [see Artifact 29]. And in detail, with an incredibly detailed memory, he gave us an interview that he was willing to have notarized and that would stand up in court. So we found this in 2013. Then one of the good people in Lansing, who had helped lead this effective, at least effective at night, not despite all the pushback from the company about sampling, he mentioned that there's something, just like with the preliminary assessment petition, there's something citizens can do, that they can do a surface water quality monitoring request [see Artifact 30]. If there's an area of the river that hasn't been tested within the past five years and they have reasons for concern or would like to know about the health of their river, they can submit a request for it to be studied. So we did. [LAUGHTER[ We spent a long time. I don't know if I have a copy of the actual request form in here. I've pulled this thing apart so many times, but all the emails, everything tracing it about what we needed to do. We sent this request. That would be logical. Yes. This is the results [see Artifact 31]. Came back in 2000--we sent it in August 2013, just before we met Earl. And the results of that didn't show much but did show that the Rum Creek area near the tannery was poor in macroinvertebrate community, which is right in that area near the tannery, which later in photos, you can see how contaminated everything is in there. And in its actual report, it didn't necessarily yield much more than that little fact, except the other thing that happened in 2013 was that Janice continued to dig around. And while we were waiting for the results of that request, which I actually have in that, Janice went digging around in Grand Rapids. Someone tipped her off that some of the documents that Wolverine ought to have submitted to the EPA back when the study was going on, there might be records of them in the Departments of Public Works down in Grand Rapids. So she went digging around, and Janice found something amazing. She found documents there that shows that they had used Scotchgard [see Artifact 32]. Wolverine had denied they used it, or never told anyone they used it, but she found this document. And then she found some other areas that showed Scotchgard-specific types of chemicals and these specific chemicals. And then she found a document that had been sent to the company, “Dear Scotchgard Customer,” which they were very careful, 3M, not to…[see Artifact 33]. She found hazardous waste manifests and then all these documents: MSDS sheets, that showed, or material safety data sheets that shows Scotchgard [see Artifact 34]. And the biggest find for Janice was that she found a report called a PIPP, which is a pollution incident prevention plan [see Artifact 35]. She used to call it, [LAUGHTER] I guess the term is a SWPP, a storm water pollution Page 11 �prevention plan, a SWPP. And she found out not only that they used Scotchgard, but exactly where they stored it, and got a map to us [see Artifact 36]. Had a map. And not only just any map, she got a copy of the actual large map that they used to use back before everything was on computers. And that showed not only that they had used it, but they had stored it outside, [LAUGHTER] and you'd have to take her documents—I'd never wrote on this out of respect for her—but this was from, this was the first incident prevention plan, and it was from October 21, 1981. And interestingly enough, Wolverine sent one from 1999 or even 1990, but they never bothered to send this one, which shows that they used Scotchgard, and that they had stored it outside. And then later, letters were found that where the, where the DEQ was on their case and saying, "You can't store these chemicals outside." And then it took ten years of the DEQ pleading with them to store it inside when they finally redesigned their site and stored it inside. But they stored it near the river. And with all that research, Janice and I went back in and pulled apart this 104(e) Information Request when they finally broke this story and, um, where it also attests to the fact that in this area, in the soils over here, which we were so concerned about, no sediment and soils were sampled there [see Artifact 37]. But right outside the- the warehouse building is where they, a- a large area where they had stored chemicals outside, and they stored chemicals outside here. And there's also another area back here. It doesn't show in this photo. [LAUGHTER] Now, we know that the soil and groundwater under the demolished complex, that and the adjacent river are highly polluted with PFAS, a class of chemicals which gave Scotchgard its waterproofing abilities. Human studies have shown probable links between PFAS exposures and kidney cancer, and on and on. So, they finally tested the sediment and they found all this- this PFAS, even in the foam in the river. So, what happened with the fish study is that Janice took her documents that I just showed you and she sent them to the MDHHS, um, which for Chris- Chris Bush, that's the health, uh, and Michigan Department of Human Health Services. Danielle DeVasto: Health and, Health and Human Services. Lynn McIntosh: There we go. [LAUGHTER] And when she saw the outdoor storage, and she knew about PFAS because of what had been happening up at Wurtsmith, she told the person who tests fish, she gave him the go ahead that said, when you test fish in that section of the river—because they accepted our monitoring request—test the fish for PFAS. We waited two years for that report [see Artifact 38, 39]. Usually it takes a year. We waited two years for that report to come back. And in this file that I have that tracks some of the things we tried, lo and behold, PFAS to enough of a range of concern that there were fish warnings due to PFAS. [LAUGHTER] And when Rick Rediske saw this in 2015— again, they're not doing anything. We've got a fish report going. We've got Earl's tannery interview now, I mean, his, uh, his interview about where he disposed of the wastes, and other behind-the-scenes things going on here, we get the results of the fish report in 2015, but it's not relevant yet because the EPA has not listed a limit for PFAS until 2016. It's finally in 2016, that that summer where the EPA finally gives a 70 parts per trillion limit about what is safe in drinking water. And also, Michigan puts in a rule—I don't know the exact date—that 12 parts per trillion is it for surface water in the river for PFAS. Any river, any water body. So now this becomes even Page 12 �more relevant and things start to move really fast because we've collected now the fish report, PFAS could be traced to Scotchgard—there's ways to test it. This thing has been issued, not this thing but this limit now has been listed from the EPA finally setting it on 70 parts per trillion. By the way, here's the letter from Joe Boer that talks about the fish and also. So we've got all that and we've got the fish, we've got the interview. We don't have Bob Delaney's report, which got shelved for the same five years that our efforts were shelved, but it comes to be useful certainly shortly after that [see Artifacts 40, 41]. We have all this documentation. We have enough. Rick decides and AJ, to go to the DEQ, which we do in January of 2017, January 24. And one of the most provocative documents amongst everything else that we give them is this two-pager that Rick put together, in which he refers to the fish report [see Artifact 42]. Um, he talks about historical records. He sums it up so nicely in this one document. [LAUGHTER] And he writes this very important paragraph. He says, "Based on this information, it is likely that the Wolverine World Wide Tannery, in Rockford, Michigan, manufactured Hush Puppy shoes using PFAS containing Scotchgard from 1958 until it was banned in 2002." And he talks about industrial waste, scrap leather, wastewater and process streams produced in Rockford during this time, all may have contained PFAS residuals for at least 44 years. Waste disposed on site, residuals from spills, production waste disposed of off-site in landfills, local groundwater and scrap leather buried on site—all have the potential to contain PFAS. Because we now had this information, he met at WMEAC with Elaine Isley and Nick Occhipinti, from the West Michigan Environmental Action Council, Michael Robinson, who was the attorney for Wolverine, and Mark Westra, from the Rose & Westra—the ones who wrote so many reports that we spent hours and hours having to dispute. [LAUGHTER] At that meeting, where Rick and Elaine and Nick were witnesses, Wolverine stated that there was no evidence that PFAS was ever used at the Rockford tannery site. This statement contradicts all the above information. That's where a scientist can just tip everything over. [LAUGHTER] It's just simple language. It's like, what in the world were they doing denying that they used Scotchgard at that point? But they did. Then in 2017, five people from CCRR— Rick Rediske, AJ Birkbeck, Janice Thompkins, myself and Gail Mancewicz—went and we talked to David O'Donnell, and we gave him everything [see Artifact 43]. And we showed him a map about all the homes around the sites—which maybe that's another part. I don't [LAUGHTER], I don't know where necessarily—that's probably a new section to go to. But had we not had all these things, even without Bob Delaney's report, which I guess comes more in part three, 2017 on, we had enough indisputable evidence that the DEQ and David O'Donnell, who said he would be going to the health department and following up on this, we had everything we needed. We had indisputable evidence that we laid on that table. And I guess the next segment would be about how the three representatives of the DEQ handled that information, and how that turned this whole thing around yet again. The initial exploration and the dicking around and, uh, and, uh, looking for written information, and anecdotal information, and talking to people, and just agreeing not to throw in the towel, and being concerned now, and all the little pieces like the puzzle just started to just fall together. In ways I never could have imagined. He [Robert Kaplan, Head Page 13 �of EPA Region 5] said, "That's a load of mulch, 10 cubic yards." And I said that is the only document, that is the only document that was produced by Wolverine for waste [see Artifact 44]. So what about the 250 yards of contaminated soil being removed? Danielle DeVasto: Is that this one? Lynn McIntosh: Yeah, there's no waste records. This is, that's this one. We don't know where that went. We don't know, we know some stuff went to Rusche pit, which was illegal. We showed 'em that document. We showed them the DEQ did nothing about that. He [Robert Kaplan] was shocked. And AJ played that. I have a recording of us talking about it. He's [AJ] like, he knew that that was a big deal. Danielle DeVasto: Yeah. Lynn McIntosh: He [AJ] said, "So," and he's like, "So the EPA doesn't really care that much now anymore about where waste goes and checking in on it?" And like, they were like, we've been had. Because you see, what I didn't cover is they issued a 104(e) Information Request, which is like an environmental subpoena. And that was the basis of Janice's huge document— is that they didn't tell them. They were supposed to tell them where all the documents, where every place where they had carted waste, they were supposed to have told them. Every chemical that they used, they were supposed to tell them. And they didn't give them anything. They said, "It's just too burdensome and cumbersome." And I kinda wrote that on that little sheet I was using this morning. Danielle DeVasto: The spiral? Lynn McIntosh: Yeah, that little— Danielle DeVasto: It's right here. Lynn McIntosh: See, I need you. Here's my whole thing here. I could've just followed that. Why do I do that? I make these things up and then I just—is this interesting? Danielle DeVasto: Tell me about it. Lynn McIntosh: So here's, okay, so here's like I did this morning. It's the only way I can think about things. We talk about, this is just about PFAS, the connections, and the first interview in July, Ralph Gould tells us about PFAS. Bob Delaney's up at Wurtsmith studying PFAS. And then in November of 2011, Bob asks Janice, "Do you know if they used PFAS?" And I'm like, "Of course they did. I have the interview from Ralph." [LAUGHTER] And then 2012, um, we get the, you know, we send the petition, and then we get, um, this is sort of part two, it all comes back for nothing. It's like, go back to square one. All that work, that 75-page document, followed by another 80-page document, which I didn't show you, which included this document I didn't... We sent back another one on March 3, 2012, updating the chemicals of concern. And we included PFAS. I defend that. I didn't quite get it right, I guess, but it's found in Scotchgard. Bioaccumulates and biomagnifies. Bob Delaney, 2010. So, this is where it'd be good to talk to Bob Delaney because then it was like, um, we hit this wall, this shelf. We just, we just, the truth just all got boxed in. You know? And it was like, um, I don't, I couldn't think of an image, but in one way you deal with, um, TB, I guess if you have it is they freeze something around it, like a shell around it. And that's like kinda what they were trying to do with the truth. They were just trying to wall everything off from getting Page 14 �any further now, you know. Take Bob's report, shove it, take all our information, shove it. And, um, and then we just carried on. And we went to the envi-, we went, I didn't even say this, we went to the environmental police since DEQ wasn't doing anything. We reported violations to them and they tracked it for a while. They hit walls. The OCA was a bunch of nonsense. It's just work plans that didn't go anywhere. Remember? Danielle DeVasto: Uh-huh. Lynn McIntosh: And then, um, those efforts fizzled. The Mounties couldn't do anything. They couldn't do a criminal case. Blah-blah-blah-blah-blah-blah. The water request was in the works, but it wasn't going well. And then there was this long wait in 2014. My personal life was in upheaval. I was doing battles with another condo project here and the city, and my mom moved in to the area from Pennsylvania. So I—and then 2016 hit. The EPA analysis, the 70. Garrett's article comes out about that. The fish report sinks in finally, Rediske goes to the, you know, WMEAC. And that's when we go back in 2017 to the DEQ in January, and we bring our five documents to the EPA in October. Danielle DeVasto: And those are the ones that were listed on the cover of I don't know where the binder went. [LAUGHTER] Lynn McIntosh: Yes, yes, I do. Yes, I have it and I have, I tried to— Danielle DeVasto: That's these right, like the PIPP, the report card. Are those the five? Lynn McIntosh: Um, well, when we went back to the EPA in October 2017, see I actually can do it on paper. [LAUGHTER] Danielle DeVasto: You got it. You got it. [LAUGHTER] Lynn McIntosh: I actually wrote this so I mean. That huge binder, that heavy break-your-back binder that Janice did was a rebuttal to Wolverine's response to the 104(e) Information Request [see Artifact 45], which said, "You need to tell us this, this, this, this, this, this." And, um, and then we like, no, they used it. They never told you about it. They never told you about the House Street landfill, but we found it. We found the records. They didn't, and the report card, we gave them that. We showed them how after five years, nothing had happened. We showed them violations where they actually did work that wasn't approved, and how they avoided all the mandated hot spots. For five years they avoided everything they were told... It's like a kid with his homework. Well, and then we had the outdoor storage of Scotchgard, waste manifest, and then we found the 1994 ESA [see Artifact 46]. Which, if the DEQ had bothered to read it, they could have stopped the demolition, which I didn't really talk about at length, but there was enough information here that the entire demolition, they would have been forced to test and clean the site before deadline. But they just sent around this little conclusion paper, and no one got the report. We have people talking about getting the report. People know the report exists. We have emails saying they ran out of time, there were vacations, and, well, we don't want to stop the tannery. So, when they find stuff, __________ the tannery, I guess we'll deal with it then. I have emails that say, no, there isn't anybody assigned to the site. I mean, we have emails amongst them that says they were concerned, but it was like no one was leading the charge. Well, and then we brought the one waste manifest for the entire Page 15 �demolition, and then we brought some MLive articles about David O'Donnell. And also, again, I should add this to… Don't worry about that; it's just water. Danielle DeVasto: Okay. I didn't want it to get on your papers. Lynn McIntosh: Well thank you. I do this all the time. We gave them this article that shows that Wolverine knew about this back in 1999 [see Artifact 47]. There were letter, a letter was found [see Artifact 48]. So they lied to Dr. Rediske in 2016. And they knew about the, um, I don't know if I'd call it a lie. Let's see. There's a nice legal term for that. Avoiding the truth for purposes that lack complete integrity. And then we show them this. Sure, Wolverine know they've got a letter from 3M. 3M came out to visit them. Danielle DeVasto: So you took these five documents back to the EPA? Lynn McIntosh: Uh-huh. And we showed 'em additional things, different ways that, uh, and they were incensed. And it was when Trump was in office. Danielle DeVasto: Hmm. Lynn McIntosh: And they weren't sure how, what they were going to be able to do because it was don't enforce things. Danielle DeVasto: Uh-huh. Lynn McIntosh: But what they did instead was they met with us. They took seriously what we did. They were incensed about the 140e. Janice's document, okay. Just look at those in a minute. Um. This. I'm sorry, I just. It's really hard to, when documents kind of, um, crossover in importance in different ways. Danielle DeVasto: Yeah. Lynn McIntosh: They could go in different categories. you know what I'm talking about? Danielle DeVasto: Absolutely. Lynn McIntosh: So you don't like, you make a copy and put it everywhere, in each one; that's probably the best thing to do. But sometimes it's just not __________ 00:04:33; no one's, I don't have an assistant [LAUGH]. I'm not getting paid to do it, right? Um, you just do the best you can and, and I just like to be able to see, see things. But it does land on this, then. So this was their [EPA’s] original request for information [see Artifact 49]. And they were supposed to provide all environmental data, any and all information relating to historic solid waste handling, disposal practices, including waste liquids, semi-liquids, and sludges. Any and all information related to the removal of waste including quantities, which chemicals, you know, everything [LAUGH]. “Did you ever use, generate, store, treat, dispose of or otherwise handle, at the site, any hazardous substances, waste, or other materials? If the answer to the preceding question is anything but an unqualified no, for each such hazardous substance, waste, or other material describe in detail.” They didn't do any of that. “What were your waste management practices? Identify the location of any drum storage or any waste that were stored in there,” and they didn't tell them about the Scotchgard. It Page 16 �was like, this is like an environmental subpoena, and the EPA does reserve the right to issue fines or even criminal charges if they so choose. Pretty strict, pretty straightforward. And Wolverine, of course, didn't respond in that way [see Artifact 50], which is why Janice refuted the response. But after that meeting in October of 2017, by December they [EPA] issued a second look, which was a huge, huge step [see Artifact 51]. They had to go back and complete everything from the first one, and then they added to it. And they gave them no time, um, “give your immediate attention and request that you provide a complete and truthful response within 20 days.” They reserved their authority to study the effects of, you know, on and on. They, they just hit him hard. I mean, they would be fined. They just told them in no uncertain terms, um, well they “seek your cooperation. Compliance with the information is required by law.” So they just pulled out, after that they pulled out all the, you know? And then they went back and referred to “your responses to the March 2012 information request require follow up. In issuing this information request, we reserve the authority to seek complete and accurate responses to the March request, and to exercise authority to correct civil penalties, civil penalties, as appropriate. You may not withhold the information upon this basis that is confidential” __________ 00:08:30 . They just didn't play any games this time. And then, after all that homework, the United States Environmental Project Agency issued a unilateral administrative order for removal action [see Artifact 52]. That was the other result of our going out in 2017. And it is amazing. Where we had nine soil samples taken here, there and everywhere. I'm missing places. Like, you know, instead of testing the soil in the, in the pit, in the area that, where it was still hadn’t been emptied, they tested the fill in the area where it had been removed. Those were the kinds of games they played. And then with, where the chrome tanks were way back in 2012, the instrument broke because it was so cold. And then they went back and, you know, so they, it was like eight holes in the ground. We got some information. Even with that, it rated high enough. Okay? This time they had to go back and do grid sampling. A hundred samples across the whole site, because of this. And this also applied, thankfully, to the House Street site because they owned that property. They had registered it as a landfill for waste disposal. They were the generator of everything that got put there. And so they were able, by doing this, for removal action emergency, they were able to, with authority, say you have to do this, you have to do this. The time's clicking. You don't do this, you don't do that. OK, ten grand a day. You get it done. There's no…and they had to do it. I can't believe it when they finally removed everything from here, for those containers. Danielle DeVasto: Uh-huh. Lynn McIntosh: Every night, they covered things. Every time they, you know, cleaned up. They did all these precautions for soil removal. When I think about those chrome tanks and all that stuff, that it's just, it's sitting there and the wind is blowing dust around, you know, but this is what happened because of the report card. Because of the proof of Scotchgard, showing that everyday citizens could find the documents that were too burdensome for them to find [LAUGH]. Showing how the DEQ hadn't done her job. Nothing had been accomplished. And now people were drinking contaminated water, and Wolverine knew about this in 1999. It's like it just hit everything. But, had it not been for good people there, people at the top of Page 17 �their game in terms of having authority and power, and, and if it hadn't been for people who had, I would say all of them, integrity. And they also knew they were limited because Bob Kaplan, who signed the order, was the one who was the Regional Administrator for Region Five. And he knew that he was going to be demoted because of Trump's new pick. He had three weeks. In his last two or three weeks, he made sure this happened. [LAUGH] He could have just said, oh well, I'm out of here anyway, why should I? He didn't do that because of the person he is. Danielle DeVasto: Uh-huh. Lynn McIntosh: And that's why I like Earl Teffte, the truck driver, and Bob Kaplan. Maybe I said this last time, and when we talked, I just felt like both men, different positions. They both went out of their way, they took risks to do the right thing. And I felt as comfortable talking to Earl Teffte as I did to the head of EPA Region Five. There was no sense of “I have a title.” Danielle DeVasto: Uh-huh. Lynn McIntosh: None of that. It's like, oh my gosh, what can we do? Let's see what we can do to get something done here. That's pretty incredible. It really is. Those are the really good parts of that, of the story. Page 18 � https://digitalcollections.library.gvsu.edu/files/original/3d897166cbceaec5a8976b0250a39506.mp3 03c701ccb0476e3e03c726281a6bd148 https://digitalcollections.library.gvsu.edu/files/original/eb3b4c8f1cd655cfa024c05ade57016c.pdf 1cb6bc563842cbd8296c055bd54073da PDF Text Text Artifact 1 �Figure 2 Historical/Current Site Features Legend . = = , ~lte .. Plne T(all Siie ll<>unda1 y w♦eo••:::'=5•1•50:::====300•••••sieet Coflt(IBftoby• LMStai'ler-Zoboodct .A.1119 :2012 Sa-.wce: A&H,g.n,, G eoer51Jlfllc oato Ubt'aty rogue keepers �Artifact 2 �During the summer of 2010, when Wolverine Worldwide was was preparing to demolish their 100-year old tannery site with little to no environmental testing and claimed on an application for Brownfield funds that "There is no known contamination on the property." I knew it was hogwash. Legalese laced with hogwash and the city of Rockford was drinking it down because Wolverine had promised them a state-of-the art brand new shoe store to spiff up their commercial district. Everyone knows that tanneries are contaminated and that demolitions of such sites are risky busy. But no one was addressing it. It was off everyone's radar. �Artifact 3 �The Impact of the WWW Tannery demolition on the Rogue River, Rockford, MI �Overview Album regarding the recent demolition of the 15acre WWW Tannery site in Rockford, Michigan, and its possible long-term effects on the Rogue River Watershed, particularly in the area of the Rockford lmpoundment, north of the dam and west of the site. From North Main St. camera facing west. �WWW was not required to complete an Environmental Site Assessment, Level 1 and 2, before they demolished their 15acre tannery site on the eastern banks of the Rogue River. WOLVERINE ~~~WORLDWIDE Main Street Office 123 North Main Street �In July of 2010, MEDC partnered with the DEQ to offer tax increment funding if WWW met certain environmental conditions, including a Phase I ESA and a Phase II ESA, as warranted, and comply with Part 201 clean up criteria. WWW withdrew their application for these funds and demolition activities proceeded without any public knowledge of environmental conditions. �Historically, any tannery site that has been in operation for over 100 years, will likely have some areas of soil contamination. �This document on file in the GR District Office of the DEQ cites some of the contaminants of concern. Tannery sludge was sampled in 1993, showing evidence of the below listed contaminants of concern. • ,. • s e n , : •· t an Iud e,, n Pllievi sped ··• in , • S. i:Hih ip:~:ung the.lr u ·· .- th Is. ftij was 1 en h _ • '- sm..: 11 q ua ·,a • e 1Cen~r ' . no e fo ' a. I IOVi a • z - :_ L . Toi rie , ~bl ·, r · · -a, . ous . _ _ e o 1-,e, las 0: t .. " ·_ s, a _tew,a ,er slludg, _nefaLr s , • -• 1f isrson . • osing o: · I b I . Th' s orth ' ·- , X. Cnro ~,e n e in �The demolition itself was a dusty, dirty operation, even with a Fugitive Dust Plan in place. Front of tannery building, November 2010. �Demolition of Rockford Tannery tober 20, 2011 �Demolition activities at the WWW Tannery site continued into late August of 2011. Hard surfaces were crushed and removed both above and below the soils. This removal of so much concrete/hard surface material exceeded amounts originally detailed in the Pitsch Demolition Work Plan. �Additionally, soils were excavated at levels much deeper than the 18 inches originally set forth in the work plan. �All the concrete ( a cap of sorts ) was removed from areas like these that were once hard surface. According to tannery workers, there are buried leather hides beneath this large site pond located just north of Rum Creek. Rum Creek is just beyond the steel bar in the top left hand corner of the photo. Goodbye CAP, Hello leaching. Day after day, during the summer of 2011, workers pounded away and broke up concrete below the soil. �Proper wetting of buildings to control dust did not always occur. Fugitive dust escapes from tannery building on a windy day in October. October 20, 2011 �Dust monitors were not always placed strategically. On some days the monitors were not moved to accommodate changing wind directions. Also, monitors did not test for hexavalent chromium or asbestos, as recommended . September 2010 �November 12, 2010. Dust control was not maintained while loading demolition debris. �City sidewalks remained open to the public during demolition. Pedestrians look on as a chemical tank is demolished in the Tannery building just West of North Main Street. November 5, 2010. �In addition to Air Quality concerns and waste management control, construction storm water discharged into the Rogue River on numerous occasion. At times the turbid storm water formed a very clear silt line and/or plume into the river. Water is clear and blue on the west side of the river, in contrast to the brown silty water along the east side of the river, near the tannery. �Site puddles such as this, photographed on April 26, 2011, could have been part of such storm water as it discharged into the river. Colors were not enhanced in this photo. Site puddles such as this, on the WWTP area of the site, could also have been part of such discharges of storm water. June 29, 2011. �This photo is a great puzzle. During one of the largest storm events in the fall of 2010, a water truck drove around the site adding more water to the mix even while it poured. November 22, 2011 �During major rain events, large ponds of storm water pooled on the demolition site. Some of the excess water was pumped into the last remaining storage tank of the WWTP. Significant amounts of storm water, however, exited the site and discharged to the Rogue River. May 19, 2011 November 22, 2010 .. Rum Creek bridge connecting to Tannery to Hide House. Camerafaces south towards downtown Rodeford. �into the Rogue River at Discharge point number three: Wetlands Bridge Silty storm water exits the site crosses over White Pine Trail, and streams down the trail before discharging into Swan Point. April 27, 2011 Plume travels West towards the other side of the river. �Here are close of views of storm water exiting the site and crossing over Wetlands Bridge location point. August 20, 2011 �This photo taken from the west side of the river facing east, shows the actual silt plume formed by the discharging sediment. WWTP can be seen just beyond the green perimeter fence. August 20, 2011 �Another area of concern has been the "Pit" from which contaminated soils were removed during the demolition. �A close up view of Pit. Removed soils were not tested, simply removed. Details are pending. �The demolition of the Pump House on July 11, 2011, created a lot of disturbance of river sediments below the high water mark of the Rogue River. The following photos document final demolition activities of this small structure. �Soils were not tested prior to the removal of this river bank. Sediments in the river bottom were not tested prior to their disturbance. Operating below the high water mark of the Rogue River was not a permitted activity. �Hours after this demolition activity, thick turbid water formed a plume of silt that entered the Rogue River just north of Garden Park in downtown Rockford. Young kayakers come through the water on their way to the public boat loading area. �Surface water in that area near the Pump House demolition, where so much river sediment was disturbed, continued to show unusual appearances, even three weeks later as in this photo taken on August 8, 2011. Children play in the boat launch area just south of the Pump House. �Other major concerns still remain: Where are the waste records that verify safe disposal of contaminated soils, impacted building materials and solid/hazardous waste generated by this major industrial demolition? The United States Environmental Protection Agency finally issued a 104-E request demanding release of these documents. As of July 24, 2012 documents have been received. So where did 15 acres of demolition waste go? �Was it properly characterized? Here on August 23, 2011, demolition trucks carry debris and waste materials from the WWTP areas of the tannery site to a nonlicensed gravel pit. �The stained concrete in the chemical tank below was once filled with pure chrome according to several tannery worker statements. Where was this rubble disposed? �Other solid waste related to the tannery site has been present-for a long period of time. Along the east bank of the Rogue River just west of the tannery site, the river banks are littered with hides, leather scraps, shreds of rubber and other industrial debris. �This photo is taken from a kayak, looking straight toward the riverbank. Hides are all wrapped around the rock. Scrap s and leather debris wrap around and under trees near the river. �This leather scrap was found floating in the cattails off the White Pine Trail, just north of the site. Many questions still remain, but citizens seek continued investigation and remediation of the former WWW Tannery site and documentation ofits impact on the Rogue River Watershed. Maintaining the health, vitality, and beauty of this lovely river is certainly the best interest ofall. �Artifact 4 �While Interviewing ~ T~~nery worker Harvey White?) 1 c1t1zens made use of one _j" WWW's maps located dudng~ the FOIA process. A huge ¥elp ~ J oi" • ....... -- SCAl£:: 1• • 100" i; /~,.c I ... .. ·• •• • I • \ -------~---, , ,' ' '' ·--- C • • ..... · i . �Artifact 5 �Vt'~ - ~ IOWf'I of Roe~, t¼kltjn P~~ - dew-ol,'t, """' �'t . "' -l Oo ,... ro (/)' ro <I>< J :J ro Cm_ (/1 - �Artifact 6 �..., • - View of north erid of the "Pit" showing excavation ai:ecrof 250 c.ubicyardS-of oontaminated soil. ,y...... ._,. •• J,. -:'till: -- - -... ~.,..::....... - : · '"J _-....;: �Artifact 7 �I• i I i t-'"1~ . l c:::;:::i~ =~ 1 R~~,,~& Wo'-illc W~ Wlllt H)'lrHlic OU "" Dc«mbtr • ..., , . Im Dolt: lltctlDbu IS, 1'99 J.. ~~. I ~. Sor+ s.,;ls/hr"Ku, ~tt.lJl~r- f''fes 5plfls '" -·-·-----.._ . TI1111~: G'pil l;;J.;;cnc~ J:l«J 0 C ,,v -n,,.J( ~7'°,~ r ~ --........... I SITE DIAGRAM E f3,.,K~ I •cw-... • .Svtfi-hi-- ••J Il1,✓-~ /A.6-r's , ,... o w t.r a~ ar~..l,J. f>tf41u $I P(,l.mp J-k<.•~ A1'1a- ;5ou1'--~" Ct:.,v~ Jahr T m&1~+- 7>1;;/-- / w~ wt+-or& B,,., ·1r- �I. 3. (§:_ 1-/0T= Ct'PCIA:.loJ1,1.;1 ,Jlo.s,,,·l�.s <W,..-t,/(.,,,. f,1,.1,,.,,,.,.,,,.,..1,1, • •,.• o«� ( ::::..$;:; -.: .:;;:-::1 "';':t..:,..,, .,...,....ck,,,,,,..J-t-,Jt:# "- �!:.."':,,. Citizen map based on tannery worker interviews and 2012 CERCLA Report. WWTP �Artifact 8 �lR\JO( r=="""""""'i DOCK £iiiiiiiiiil ~ TOGGI..ER 0 0 WOLVERINE WORLD WIDE TANNERY BUILDING ROCKFORD, MICHIGAN TANNERY FIRST FLOOR ( ' �/ T'dnner"-1 ~· Hide Hou..se ~ }\t>, spo,s flt5HDI - = - = - - - =~ - ::c o~r..a; ""' m ~ m IIATtJI OIIUD$ 0 HIDE STORAGE COOLER en (3 1111.!JCN U!S. SffllA~ CAPAOr,) ---f 0 ~ TOGGUR 0 G> 0 m WOLVERINE WORLD WIDE TANNERY BUILDING .., 0 cc ROCKFORD, MICHIGAN TANNERY FIRST FLOOR C: d) ~ CD CD "'C 0)I O O - 0 �Artifact 9 �U:. _____, Also a.s-... (A.Sul. F.. IIars +-o hold up f;,nn,t'Kf drums �Artifact 10 �~r -h,.,c WdrJ(er.s s~1 -n,nK$ wer, '' Wttl/~,.,~" '/IDll4'" -,",- ~f;,i ~'':!] /ant)#r'f wh~ ~ny,ry . of ~d'~ c.1--.tn"cal -t;,,a,aery was r~-1()""4/~J. � https://digitalcollections.library.gvsu.edu/files/original/8540daa16dff7c4bcc990c973da25d70.pdf 1d04aa8090d2a92aef67b81633a40c5c PDF Text Text Artifact 11 �.. ; -~ r. · ;rr:-:-.,. ::t~~ �Artifact 12 �( ( -- . "' , a' ~ \ ! ~\ ;~-\ i ~· \ .------ . ------ !, • •• ! ~ I, IJ~L_e_g_e_n_d,...._---'--""---------~ I ; J I Groundwater Sample Location Approximate Hexavalent Chromium Extent C3 l w l C3 ~ C3 NOTES: 1. LOCATIONS AND SITE FEATURES ARE APPROXIMATE. Rose & Westra , a Division of GZA 601 Fifth Street NW , Suite 102 Grand Rapids , Michigan 49504 2. CONCENTRATION ISOPLETHS WERE DEVELOPED USING NATURAL NEIGHBOR INTERPOLATION IN ARCGIS . CONCENTRATIONS WERE NOT EXTRAPOLATED OUTSIDE OF THE AREA OF KNOWN CONCENTRATIONS. < 3.5 µgll (RML) 3. ABBREVIATIONS FOR MDEO PART 201 GEN ERIC CLEANUP CRITER IA FOR RESIDENTIAL USES: 3.5 - 11 µg/L (GSI) GSI = GROUNDWATER-SURFACE WATER INTERFACE CRITERIA. HEXAVALEHT CHROMIUM IN GROUNDWATER ISOCONCEHTRATION (PPII) TANNERY BITE GZA GeoEn'lironmflltal, lllC. 12 - 20 µg/L 4. RML • EPA REGIONAL REMOVAL MANAGEMENT LEVEL FOR TAP WATER. 21 - 40 µgll (MAX) 5. MAX= MAXIMUM DETECTED CONCENTRATION IN THE SAMPLES. Engln ■ ers;andScl•ntlsts C,Z\ PREPARED FOR: WO. VE RIN E WORLD WIDE. INC. www.g1,11.com 1-,,.-,-,.,,.-,-o,-,.- -+-:-::-:-:,-0~_._ ~-<1-;-.;, "'-'.'-o-,:-: -..~1L ~-',~- -;FI GURE C DATE: 1 /10/2019 PROJECT NO 16.0062355,02 REVISION NO 11 �Artifact 13 �( ------------ -" " • • • • • • • I ~ ~ • ~ • • • • ~ ! ~ ~ ~ i~ ,-----"'--'----"""~----""---""---=--~ ! Legend j j • Soil Sample Location Approximate Sulfate Extent C3 C3 C3 w < 5,000,000 µg/kg (DWP) 5,000,000 - 8,000,000 µg/kg 8,000,001 - 12,000,000 µg/kg 12,000,001 - 16,000,000 µg/kg (M AX) NOTES: 1. LOCATIONS AND SITE FEATURES ARE APPROXIMATE. Rose & Westra , a Division of GZA 601 Fifth Street NW, Suite 102 Grand Rapids , Michigan 49504 2. CONCENTRATION ISOPLETHS WERE DEVELOPED USING NATURAL NEIGHBOR INTERPOLATION IN ARCGIS. CONCENTRATIONS WERE NOT EXTRAPOLATED OUTSIDE OF THE AREA OF KNOWN CONCENTRATIONS. S lit.FAT E IN S OI L IS OCONCE NTilATION {PP B) T ANNERY SITE 3. ABBREVIATIONS FOR MDEQ PART 201 GENERIC CLEANUP CRITERIA FDR RESIDENTIAL USES: G2A G ■aEnvlronmenlal , lrM;:. Englflnn and Scl,1111,11 .gu.com DWP = DRINKING WATER PROTECTION CR ITERIA. 4. MAX = MAXIMUM DETECTED CONCENTRAT ION IN THE SAMPLES. PREPARED FOR: Y'IOLVERI NE WORLO WIDE , INC. .,-,,.--1,;;'-,::-:.:-•;,.,·~-"-·-c:c"': -+:"' :c.._. :-·::-"'-·~.,.:.,. , "",,-, c1 • ,c: L: c, ,_-:-iFIGU R E Q l~oc :-c "'~ : ~:-",-,;:.,,sv.,-· DATE: 1 111 12019 PROJECT NO 16.0062355-0 2 l~EVISION NO 10 �Artifact 14 �( . -- -----------------------! " - --- -------· /~ ' --- I ,,~---- • I - - - - -- - . ..- · -- - - - --- -- ~ ' a l ~:-_-;,,,-.,-,.,-,,.-,,,-,;~ • • !.\~ '.,_ _________________:_ ________,.------- --------"·-·- -··: • . __...• .- ---- ---- -~ _______ _____._ ____ -------~-----·;.: ~• • • • • • ! • • • ---------- !~ ~ . • • • i i _._.i L----- -. -------------- ., I • . . -,v)O -,'11'1(.S ! •\"'" \----. . • ( . . .• ! / 1 ) I I : 1)~ • ,,_\_ , ;). \, i i Extent 1 I C3 C3 < 20,000 • - ~-------------- ~ -- ~ r ' - -~ -- J Approximate Vanadium ! • - ! .----'-~L-- --"""=-1 Legend ! • Soil Sample Location • \ µg/kg 20,000 - 40,000 µg/kg NOTES· 1. LOCATIONS ANO SITE FEATURES ARE APPROXIMATE . 2. CONCENTRATION ISOPLETHS WERE DEVELOPED USING NATURAL NEIGHBOR INTERPOLATION IN ARCGIS. CONCENTRATIONS WERE NOT EXTRAPOLATED OUTSIDE OF THE AREA OF KNOWN CONCENTRATI ONS. VANADIUM IN SOIL IS OCONCENTllATIOM IPPIII T AN NERY BITE 3. ABBREVIATIONS FOR MDEQ PART 201 GENERIC CLEANUP CRITERIA FOR RESIDENTIAL USES: W 40,001 - 72,000 µg/kg (DWP) DWP • DRINKING WATER PROTECTION CRITERIA. • C') 72,001 - 110,000 µg/kg (MAX) 4. MAX = MAXIMUM DETECTED CONCENTRATION IN THE SAMPLES. ~ Rose & Westra , a Division of GZA 601 Fifth Slreol NW, Suite 102 Grand Rapids , Michigan 49504 GZA G110Enlllronm•nlal, Inc. Engk111ws •nd Sel•111lsl• - DA.TE . 1/11/2019 PREPARED FOR: WOLVERINE WORLD WOE , INC .r,ueom PROJECT NO 16.0062355.0 2 REVISK>N NO 10K �Artifact 15 �( -- ' " ------• • • UliU,SS!ll'ECl~ ICA.UYI/JT,ll E0IIY\0,fUITENAGREEt.lENT. lHfi0fUl'1'NOIIIIHEV-lLEl'H(P(RlYOf' INC. (QV,,~ Tl-IL l"lfORW/\TK»ISHOV.:NON lf11:0R>.-Gll$0\..EI.YFOR au, GCOEHIIIROm./ENIM.. U5E 8Y DZ.019 CU EN! OR !Hii cu, NrS OESl{IN,\lEll REPAESUO Al...,;: HIil THI! Sf'l!CFIC PROJECT MIO lOCAflON IOENTl~ED ON ltE Ok/\WIN<.i n-E 0 flA \IIIN(l Sl\lril NOT l'lf. lRN!~~, RRISED C()P11;0 OR -'i.lEA!iO IN Mr l,IMIIEFI. ~OR USE Al AAY OTH~ I OC,, TIOHORfQfl~YDTHER l'URPOSE wm1ou1 rnE PRIOR WRITTEN COOSENT Of GU, NIY IRHl&fEfl l'llUSf'~ 0A ~ICAll".llll t arttEOAAWJP<C8YTH£CUENTORITTHERS. Wll l10UTTHE~nRflleNEliPflE86CONSl:NTOf- Rose & Westra, a Division of GZA 601 Fifth Street NW, Suite 102 Grand Rapids , Michigan 49504 NOTES: 1. LOCATIONS ANO SITE FEATURES ARE APPROXIMATE. PERF LUOROBULFONIC ACID (PF OI) IN S OIL IS OCONCENTRATION (PPBI TANNERY SITE 2. CONCENTRATI ON ISOPLETHS WERE DEVELOPED USING NATURAL NEIGHBOR INTERPOLATION IN ARCGIS . CONCENTRATIONS W ERE NOT EXTRAPOLATED OUTSIDE OF THE AREA OF KNOWN CONCENTRATIONS. GZA G10E11Ym111m,nt al , Inc. Enfjin1en;andScl1mls!S PREPARED FOR: WCl..VERIN E WORLD WIDE, INC. www.51z.ai.com 3. POL= PRACTICAL QUANTITATION LIMIT . 4. MAX= MAXIMUM DETECTED CONCENTRAT ION IN THE SAMPLES. DATE: 1 /111201 9 PROJECT NO 16.0062355.02 REVISION NO 10Q �Artifact 16 �( . ( -" Rose & Westra , a Divis ion of GZA 60 1 Fifth Street NW , Suite 102 Gra nd Rapids, Michigan 49504 TOTAL PERFLUOROALKYL IUBITANCE9 (PFAI) IN GROUNDWATER ISOCONCENTRATION (PPB) NOTES· 1. LOCATIONS AND SITE FEATU RES ARE APPROXIMATE . TANNERY GZA G ■aEnvlronmefltal , Inc. 2. CONCENTRATI ON ISOPLETHS WERE DEVELOPED USING NATURAL NEIGHBOR INTERPOLATION IN ARCGIS . CONCENTRATION S WERE NOT EXTRAP OLATED OU TSIDE OF THE AREA OF KN OWN CONCENTRATIONS. C,Z.\ Engln••rs and Scientists - DATE 111012019 WOLVERINE WORLD W OE. INC. -11u.com F="'--~-1c:~ R·:~:N~ w:~~~ "~ · 3. MAX= MAX IMUM DETECTED CONCENTRATION IN THE SAMPLES. srre PREP ARED FOR ~"''-t~:~::~"'~~c-:r_,.0,--:.,'-:c:.,,. ,-- ,,FIGU RE J PROJECT NO 16.0062355.02 REVISION NO 11 �Artifact 17 ��' , reg uekeepers ����Artifact 18 ��Artifact 19 ��Artifact 20 �L!.: DEMOLITION 0 TANNERY. All l>ay;. lvov I/\_ °'- bei,y0 / ,+,011, .J,) tJ to �All Act, \/-4 ~hid A/di/Im~ o'ldlO 'I~~ coo+, �Oc+oW ii ' /J tJVerr..J,ter ,,-...._ '2010 WWW T4'rw"f 1>~~ 1.r- tOf'\. All l'n a d~~'$- d..Lmol,tr.:,~ e::> - }lo~ )l,a,r\ ~, _, 1(0,~f;,,-J. _ ____ P~eplL- - CVeA/ w ~-- �All ,/1 Hrn11 fbut:e : ,1(, ~/;,7 ~ ~ lk1no!t1Jd>1 : Rrv~r wjo /C:r/'Yllt . � https://digitalcollections.library.gvsu.edu/files/original/f302517aebca7e7b85afde384841ad27.pdf 6a294ad62a3098efb6f0f77665a11439 PDF Text Text Artifact 21 �----Illllll lllll lllll lllll lllll lllll llll llll us EPA RECORDS CENTER REGION 5 407293 SUMMARY OF CONCERNS ·•. , ;, Related to Iha Recant oamolltlon of "8 1·$4c,.. Wolverine Wortcf\lde. Inc. Tannery alta In Roekford, Ml And Its Long-term Environmental Impact on the Rogue River Watershed ·.: •, , .,l,.;\ • :js; .·· .: ~i - ·.' . /)tf\c ~--. _.., -~ ,:r a>~ :':: • -= .•::'--... :'/~~f~> ·-~...... ,: ._ .;;4 . :• ,. ' ~·-_·:· .-_: •• .: ':ft.)~<_--.- ·-·. :· . ~- ·:: -~-rt\\:~-~?::-:._,-:> . ' -.· :, (:';c~- :• •• • ~:: ::~i-t_-<·:· ~- :. - - ;.~ - : ;•,.\•. �June 21, 20ll Rick Karl, Director, Superfund Division - Region 5 United States Environmental Protection Agency Ralph Metcalfe Federal Building 77 West Jackson Blvd. Chicago, IL 60604-3590 Under the authority of CERCLA Section 105 (d), as amended, the petitioners whose names, addresses, and telephone numbers appear on the following signature pages hereby request that Region 5 of the United States Environmental Protection Agency conduct a preliminary assessment of the suspected release of hazardous substances, pollutants, or contamination at the following location: Site of the recently demolished Wolverine World Wide, Inc. tannery located in downtown Rockford, Michigan - commonly identified as 123 North Main Street including contiguous properties owned by the company (which had been used to store tannery-related materials and supplies) as identified on the attached site map. The petitioners are affected by the suspected release due to one or more of the following reasons: • Several petitioners reside in the immediate vicinity of this site. • All petitioners use municipal water drawn from the watershed shared with this site. • Most of the petitioners make regular use of public lands immediately adjacent to this site in all four cardinal directions, including the "Fred Meijer White Pine Trail State Park" to its west which experiences frequent surface runoff events originating from this site. • Several petitioners make additional recreational use of public lands and/or waters downstream from the waters running through this site (including periodic sport fishing, wading, and kayaking). The type and characteristics of the substances involved are described in the attached pages. The nature and history of the activities that have occurred regarding the suspected release are also described in these attachments. We have already contacted our local and state government authorities to address our concerns. 'The results of these exchanges have been documented in the attached pages for reference. We can characterize the responses we have received as ineffectual. Although we have received multiple personal opinions by such authorities, they have been issued with no reference made to any supporting scientific evidence. As far as we know, no study or assessment of possible site ,:ontamination has been conducted according to even the most basic of scientific principals - at least none have been made publicly available. Since our inquiries with the State of Michigan have resulted in a remarkable lack of available data on this tannery which we find particularly disturbing, the petitioners also request the EPA to consider using the authority granted it under CERCLA Section 104(e) to discover all possible data related to this site which may be held by Wolverine World Wide, Inc. or by any •!nvironmental service companies or consultant it might have employed. We believe that time is of the essence to discover available data on the tannery before any such information becomes subject to destruction once minimal retention time limits have been exceeded. �At this point, organized demolition activities have ceased with no evidence of engineered remediation activities having been implemented. Only grass-covered fill dirt lies over the remnant of the tannery facility's interior flooring, the surface which no longer benefits from the tannery's former roof. Ground water washes over its surface beneath the ground with each rain. It is highly improbable that this situation is not leaching chemicals directly into our water table and nearby streams. If indeed this were actually true, it would have been a simple matter for the owners to have conducted a few studies to demonstrate that there is no cause for concern. If we had merely been shown credible evidence that the site was not contaminating our larger community, we would not be approaching you today with our petition. However, without any such evidence, we have taken the time to catalog within this package multiple indicators which we think will easily validate such a study. ln order to assist your offices in reviewing this petition and/or in conducting any subsequent assessment, the following petitioners may be contacted to obtain any additional information required or to clarify any of the facts we have stated in these pages: Please note that we have already discussed to some extent our intent to submit this petition with Mike Gifford from your regional office. He was also able to personally visit the site, and meet ·with some of us briefly. He might be of some assistance in helping you validate the credibility of both our petition and our concerns. Thank you for attending to this matter as promptly as possible. cc: Larry Schmitt, US EPA Susan Erickson, State of Michigan DEQ �,,_., Si(JMture page: Prelimi'fftlry) Assessment Petition Uniler the aut:borit~ of CERCLA Section r05 (3), as amen3e31 we tbe petitioners bereb~ submit this request t:bat Region 5 of tbe Unite3 States Environmental Protection Agency] con3uct a prelimhurr~ assessment of tbe ,~forementio11e3 \Volverine Worfo Wioo, Inc. former ta1111e~ site at 12.3 N. Main Street, Rockfor3, MI. Fo-r all of t:be -reasons citoo i11 tl,e S1mmun~ Report ani) inclui)ei) attachments, ani) witb all t:be unanswerei) ~uestions -reoarimtfJ leacbi110 of COJ1tamina11ts into t:be Rogue River ani) 3owntown communit;y of Rock.for(), we seek ,Your be[p an3 ol,jectivit~ in 3etermining t:be safet;y of our environment. Name Name AMress Si(Jl1ature AMress Pbo11e Nu Si(:111tltu.r Name Name AMress_ A33re Pbone Nu Pbon Si(Jl1atu.re Si(JHatu. Na.- Name AMY AMre Pbon Signa Pbon Pbone Num Si(:111tl Name AMr Pbone Si(JHatu Nam AMr Pbon Si9natu ame AMress- - Pbone S1(:111tltU �Signature page: Prelntrina~ Assessment Petition U113ey the aut,horit:9 of CERCLA Section ms (3), as amen3e31 we tbe petitioneYS bereb:9 submit this Yequest that Region sof the U11itw States Environmental Protection Agency con3uct a prelimina~ assessment of the aforementionel> Wolverine Wor{l> Wil>e, Inc. former tanne~ site at 12.3 N. Main Street, Rockf-oyl)1 MI. Fo-r all of tbe -reasons cite3 in the Summary) Report anl> inclJ.Well attacbme11ts1 anl> with all the UMnswerell questions reoarmno leadfinn of contamiMnts into the R~e River ani) 3owntown communit:9 of Rockfor3, we seek. ;your be{p anl, objectivit;y in 3etermini119 tbe sa{et;y of our environmettt. Page 2. �Si(Jl1Llture page: Preliminary; Assessment Petition Unoor the authorit~ of CERCLA section 105 (()11 as ament}et)1 we the petitioners bereb~ submit t.bis request that Region sof the Unitoo States Environmental Protection AgenQ:J coni)uct a preliminaey assessment of ~1e aforeme11tio1100 wolveri11e Worfo Wibe, I11c. former tanneey site at 123 N. Main Street, Rock{-or31 MI. For all of the reasons citei:) in the Summa~ Report an3 mc[ut}e() attachments, an3 wit/; all the unanswerei:) questiom rB9i1r3m9 lea~ of contamimmts into the Rogue River a113 3owntown communit;y of Rockfor31 we seek ~ur be{p anb objectivit;y in 3etermini"{J the safet;y of our environment. Name AMre Name A~ress Signature_ Name_ AMress Pagej �SigttatJtre page: Prel~ ~ Petition UHi)eT d.,e a ~ of CERCLA Section 105 {ll~ as tmteltlleb, we the petitioners beTeb» sMfmrit tlfe request that Reeion sof the u ~ St.ates Emrironmental Protectiml AfJtMcyJ coJWMCt a prelimi~ assessment of the afo1·eme11tio>too wolverine worfi> Wroe, IMC. former taHHel1) site at 11.3 N. Mtrin Street, Rock{orll, ML For al( of the reasoHS citell in the SHttrtttar» Report mw mclMboo attachments, mw with all the JfflllHSWeroo qitestions regtrrmng leacl,;ng of contaminmtts mto the RogHe River mw oownt.ofVff COtffltfffflity of Rodefora, we ask for your help aw expertiMl. I ,1 Name._ _ _ _ _ _ _ _ _ _ _ __ ANJres.s_ _ _ _ _ _ _ _ _ _ __ Pbcme NUHUr_ _ _ _ _ _ _ _ __ Name_ _ _ _ _ _ _ _ _ _ _ __ ANlrw_-=------------- 'Pbone Number_ _ Name AM,es.,,_-_ _ ,_ _ _ _ _ _ __ fbotre NwnJm___________ Name _ _ _ _ _ _ _ _ _ _ __ AMre.v_,---_ _ _ _ _ _ _ __ Pl,cne Number_ _ _ _ _ _ _ _ __ Name_ _ _ _ _ _ _ _ _ _ _ __ .Mi>re&s_-_ _ _ _ _ _ _ _ __ Pl,,crneNumber_ _ _ _ _ _ _ __ ��Table of Contents I. Summary of Concerns 2. Reference Maps 3. Picture Album Views of Rockford Views of Tannery 4. Tannery Worker Interviews 5. Information Relevant to Interviews Map of hot spots List of significant chemicals 6. Picture Album: Photos relevant to tannery worker interviews The Pit Locations of hides and buried debris Above-ground chemical storage tanks Floors in the hide house Spotlight on Waste Water Treatment Plant 7. Picture Album: Demolition concerns Air Quality issues: Lack of dust control and oversight SESC issues and violations related to the demolition Surface water concerns Post-demolition views of the tannery site: December 2010-June 2011 8. CCRR: Communications with city government and Wolverine World Wide 9. Violations: A sampling of violations found on record at the DEQ 10. Local Well and Water Usage Summary �SUMMARY OF CONCERNS Related to the Recent Demolition of the 15-acre Wolverine World Wide., Inc. Tannery site in Rockford., Ml and its Long-term Environmental Impact on the Rogue River Watershed �Overview Our town The fifteen-acre Wolverine World Wide, Inc. tannery site is embedded in the heart of Rockford, a small residential community of about 5,000 people. It is also located on the eastern banks of the Rogue River, a country scenic river, and Rum Creek, a "cold-transitional small river system that empties into the Rogue River shortly after flowing through the tannery site. As of 1994, the White Pine Trail State Park now skirts the perimeter of the site, and it is a huge draw to bicyclists and pedestrians from all over the Kent County area. Senior citizens, young families, bike racers, school groups all make frequent use of the White Pine Trail. Residential neighborhoods cluster all around the site, to the east, to the north, and just across the river to the west. Rockford's business district is located to the south and to the east of the tannery site. With the city logo being that of a waterfall rnshing over a dam, the Rogue River remains a key attraction to shoppers, fishermen, kayakers, pedestrians, and concert goers who gather at the Garden Park on the banks of the Rogue River to enjoy outdoor evening concerts. Garden Park is located about one hundred feet south of the tannery site. Rockford also boasts many nearby outdoor eateries, parks, festivals, and even a yearly sweetheart splash into the Rogue River on Valentine's Day. Rockford is a family-oriented town with a strong school system. It is nm by a small city government with a voting council of five members. The city manager is the zoning administrator, the Municipal Enforcing Agent for SESC issues, the chief advisor to the city council, and is actively involved with the Downtown Development Authority and Economic Development Council. Our concerns 1. On June 16, 2010, after eighteen months of deliberation, WWW presented its plans for redevelopment of the tannery site. They referred to it as a "Responsible Approach to Redevelopment." The responsible approach included complete demolition of the buildings, the construction of a new Flagship retail store at the downtown, southern portion of the site, and leaving the other twelve acre as undeveloped green space. The plan called for no remediation of the site. "For all we know, it's just a red brick building coming down," says Ken Grady, WWW's legal counsel, to a question from a concerned citizen. "There is no known contamination on the property," claims WWW's environmental lawyers on a document submitted to the state of Michigan. EPA Petition Summmy �2. Citizens were told that since WWW had no plans to sell any of their property, WWW was not required to test for any possible contamination of soils, groundwater, surface water, or impacted building materials. They were in compliance, of course, with the law. They were not operating under best management practices, however. According to Michigan state law (with all its cracks and loopholes) even the DEQ could not require a Phase lor Phase 2 ESA, let alone enforce any clean-up criteria. So we were told. 3. For eight weeks, residents worked tirelessly to express their concerns and convince their city to hire such a consultant. Letters were sent, meetings were attended, and phone calls made. All their efforts were pretty much to no avail. In the end, two weeks before the impending demolition, the city manager hired Materials Testing Consultants to interpret Air Quality reports sent over from Wolverine through the city manager to MTC's consultant. As it turned out, MTC was on site for maybe two visits and their involvement was minimal. Citizens do not recall that the manager's decision to hire MTC was ever put to the city council for a vote. Residents also thought it to be a conflict of interest that the consultant from MTC was the city manager's brother. 4. In early January of 2011, Wolverine World Wide pulled the plug on their re-development plans to build a new Flagship Shoe Store in Rockford. They changed their minds just three weeks prior to construction. The city was shocked and deeply disappointed. It now appears that the site will be mothballed for an indefinite period of time. 5. Rockford is now left with an uncapped, untested vacant tannery site smack dab in the center of its town. Meanwhile, the concerns of its citizens have only increased: What is going to prevent possible contaminants from leaching into soils, the groundwater, and the surface waters of the Rogue River and of Rum Creek? The site is uncapped and open to the elements. Clean fill and turf grass cover some portions of the site, but this will not prevent leaching of significant materials. Other portions, the real "hot spots." remain raw, uncovered, and destabilized. 6. Unfortunately where oil spills are visibly dramatic, inciting public outrage, leaching is a quiet, unseen activity, and off of most people's radar. All the more reason to have regulators involved. Our Petition for Help For all of the reasons cited above, Rockford citizens petition the help of the EPA to help settle the matter once and for all. Is our health at risk? Is our environment safe? Will we and/or our ,:::hildren face health consequences years down the road? What about the wildlife habitat of our beautiful watershed? We need facts. We need data. We need your help. EPA Petition Summary 2 �Pre-Demolition Prior to demolition of the WWW Tannery Site, which was in operation for over 100 years, none of the following pre-demolition assessments were done: • • • No recently reported Phase 1 or Phase 2 ESA. No rep01ied groundwater or reported soil testing done on site or on adjacent properties. No Hazardous Materials Survey done of impacted building materials. Potentially Relevant Pre-Demolition Information 1. The last time a Phase 1 was done was in 1994, when MDOT and WWW traded easements so that the White Pine State Park Trail could go around the Rogue River. This is Project No. F93392 and was prepared by Fishbeck, Thompson, Carr & Huber, Inc. for the Michigan Department of Nahlral Resources, Real Estate Division. Here is a list of but a few of the problems noted and/or observations made. • 1983 - An inspection report shows that wastes were being stored in a building with no roof that was attached to the shoe plant. • 1988 - Three UST's were removed, a 12,000 -gallon UST, a 2000 gallon UST, and a 900-gallon diesel UST. There is no evidence that a site assessment was done at this time, nor were the locations of these US T's to be found in any files, only a letter from WWW to the DNRE stating that no leakage had occurred. • 1992 - Closure of 3 additional gasoline UST's was begun. Soils were stained and had a petroleum odor during closure activities. Elevated levels of lead were discovered in the soils near one of the UST's, the one closest to the WWTP, near the river. A soil lead concentration of 1400 ppm was detected in soils approximately 20' to 30' east pf the site and 100' south of Rum Creek, exceeding the direct contact criteria for lead of 400 ppm. Soil excavation was recommended for the southern end of the site, due to elevated levels of lead detected in borings made 4/-6' bgl, 20' to 30' west of the site and 200' feet south of Rum Creek. • 1994 - Other problems noted were this: improper storage of hides, the detection of brown, odorous, organic wastes, yellow-brown soil staining, patches of black soil, an open top 55-gallon drum and another dmm, wooden pallets, and scrap metal further northeast, and along the riverbank and on the WWW site the 1994 ESA documents the presence brick, scrap wood, broken concrete, and metal. This is only a partial list of the problems noted at that time. No evidence has been found to document the correction of these problems or explain why a Phase 2 was not required. EPA Petition Summmy 3 �2. In August of 2010 a comprehensive search of WWW's files was ordered by the state DEQ offices in Lansing. Records and files were minimal for a tannery that had been in operation for over 100 years. Concerned citizens also looked through files at the local DEQ office and noted these: • 1999 - On December 8 and 9, 1999, WWW received an urgent violation notice for a Hydraulic Oil Release into the surface waters of the Rum creek and Rogue River. • 2004 - A 2004 NPDES inspection report regarding renewal of COC#: MIS5 l 0423 cited numerous ways in which WWW was not in compliance with NPDES requirements. • 2008 - On December 15 WWW received a Violation Notice (VN-003785) from the DEQ for non-compliance with their NP DES practices. (COC# MIS510423 ). • 2010 -The DEQ and MEDC (Michigan Economic Development Council) collaborated to provide WWW with an incentives plan (a tax credit and use of tax increment funding ofup to $250,000) on the condition that WWW would complete the Phase 1 and Phase 2 ESA 's, and settle the question as to whether the site is a "facility,'' and abide by appropriate Part 201 due care obligations. After initially indicating it might do such assessments, WWW unexpectedly changed its mind and declined the offer, to the disappointment of the city and citizens alike. • 201 l - present - Citizens and fisherman have since found mounds of leather scraps and rubber scraps popping up out of the river bank areas adjacent to the \VWW site. They can be seen in the river itself, and also on the banks of Rum Creek. Additionally, all kinds of industrial debris has been found along the river banks, buried within them, partially exposed, or laying right on top. A short list includes the following: asbestos roofing shingles, cement blocks, bricks, pipes, concrete slabs, and chunks of asphalt. A map delineating some locations of this industrial debris is included in the appendix. 3. Citizens of Rockford, at the advice of many professionals a DEQ staff member, Kent County Board of Health supervisor, environmental engineers, an industrial hygienist, two environmental consultants, and professionals involved in the recent remediation of the Whiteha 11 Tannery Site), expressed their concerns to the city of Rockford via letters, phone calls, and attendance at all public meetings relevant to the impending demolition. The sum of all the advice received was this: Urge your city leaders to hire an Independent Environmental Consultant to advise them. A demolition such as this is beyond the scope of a small city. EPA Petition Summmy 4 �4. On June 23, 20 I 0, a letter was sent to the city manager, all city council members and all planning commissioners. Late in August, two weeks prior to demo, the city finally hired Materials Testing Consultants to monitor AQ reports. MTC's involvement was minimal, however, and on-site supervision did not occur. Other than Wolverine, only the city manager had the authority to close down the demolition as he saw fit. The city manager does not have environmental training. The consultant from MTC was his brother. Concluding Remarks on Pre-demolition With very few requirements set by the City of Rockford and with minimal demolition guidelines in place, and in disregard to the stated concerns of neighboring citizens and former employees, the tannery demolition proceeded based entirely on the following cursory opinion drafted by WWW lawyers, Warner, Norcross and Judd: "There is no known contamination on the property." There was no technical foundation to support this bald assertion. This statement appears in WWW's Act 381 Work Plan presented to the state. (6/16/2010) WWW did not hire an environmental engineering firm to oversee the demolition and guide activities on the construction site. They hired Pitsch Demolition and Rockford Construction to handle the project, neither of which have the expertise of an experienced environmental engineering firm. Other than Wolverine, the only other person who had authority to shut down the demolition, for reasons he saw fit, was the city manager. The city manager does not have environmental training. EPA Petition Summary 5 �Demolition 1. Fugitive Dust Plan A. Some wetting and spraying of the buildings did occur as part of a Fugitive Dust Plan. It was clear, however, that nobody was charged with the continuous implementation of this plan, either on behalf of WWW or regulators. Large clouds of dust were photographically documented and did disperse into the downtown community on several occasions. B. Air testing results were inadequate, initially produced through the City to the citizens, sometimes two weeks after sampling (and never directly to the citizens). This did not allow work practices to be modified to protect neighboring homes and businesses. C. Some advice to the city by their own consultants for AQ, Materials Testing Consultants (MTC), was not acted upon by the city. The city was advised to continue testing for asbestos, in addition to the air tests for cadmium, lead, and chrome. MTC also advised that the tests for chrome should differentiate between hexavalent chrome and trivalent chrome. Finally, pictures of air monitors show instances where the monitors were set behind trucks, set up at too low of height, or were not moved to accommodate shifting wind patterns. It was the residents who early on advised the city to advise the demolition crew to use a wind sock to determine accurate wind direction. 2. Storm water run-off and SESC control A. Many heavy storm events occurred during demolition and they are documented with photos. Storm water and sediment discharged into the Rogue River at five different point sources, either flowing over or seeping beneath the White Pine Trail before entering the river. B. The major rainfall events occurred on Sept 6, Sept 18, November 22, and December 31 of 2010. The November 22 event was the most significant in that year. In 2011, the major SESC events occurred during the spring melt in March, and very significantly during the storms of April 26, 27, and April 28. The local DEQ visited the site on April 28, in response to citizen complaints, yet for five days afterwards, possibly impacted storm water continued to flow off the site and discharge into the Rogue River. Finally, storm water run-off discharged into the Rogue River and Rum Creek again on May 14, May 19, May 26, and May 29. On week-ends, after business hours, and on holidays, no efforts were made to thwart the flow of water or pump it off the site. C. Citizens have observed some unusual surface water surface appearances on both the Rogue River and on Rum Creek. Pictures of questionable surface water observations EPA Petition Summa,y 6 �are iYJcluded in the appendix. The overall pattern is this: • At the five main discharge points ( four behind the WWTP and one near the pump house), where storm water and sediment have entered the Rogue River, the surface water has a sudsy, filmy appearance, more like bubbles than foam, more white in color than brown. Also, in certain areas the surface water has an oily sheen and does not seem to be the type of sheen one might see with iron oxide bacteria. Both kinds of sheens have been observed in those areas. Finally surface water of unusual colors has been noticed, as on the evening of August 25, 2010, the night before a reported fish kill of 14 blue gill in the waters of the Rum Creek, just west of the tannery. This fish kill was reported to the DEQ. 3. Hot Spots and Chemicals of Concern Data and information in this section coincides with the seven employee interviews, and ·with chemical lists on file with the DEQ. Hot spots refer to those areas where workers hm·e been eye witness to improper disposal, storage, or practices associated with the handling of "significant materials. " A. The Pit: At the end of December, a much documented Hot Spot, was uncovered known to former workers as the Pit or that nasty crawl space beneath the maintenance floor of the tannery. In fact, no single hot spot raised more concern for the tannery workers than the Pit. Six tannery workers have been interviewed regarding its historical use and why they foresee this particular Hot Spot to be continually problematic. The interview section in the appendix details their concerns, but here is a brief summary. a The Pit was used originally, and perhaps by default, as a large hazardous substance containment and disposal area, back during the days when trains went through the site to transport hides, chemicals, and other items. After the trains stopped operating, this large, crawl-space type area was never cleaned out. WWW simply covered it over with a cement floor and built the new Maintenance Building of the tannery right on top of it. It still remained a containment area, however, for virtually all types of wastes generated at the site, from less toxic sewage and old hides, to toxic dyes and chemicals from the tannery and color dye departments.. Later, when the wastewater treatment unit was built, this toxic soup still flowed beneath the Pit en route to the treatment unit. b. The Pit had/has an unlined dirt bottom and its dimensions were approximately 75' by 35'. c. Vp until 2009, when the tannery officially closed, the transport lines to the treatment unit would back up, and the overflow would fill the pit to EPA Petition Summary 7 \, �overflowing, eventually spilling out onto the floors of the tannery and the surrounding soils. Workers had to wear boots. d. In spring of 2011 photos were acquired showing the inside of the Pit. Views of the Pit from February 20, March 19, April 27, and May 2, show that the water level of the Pit appears not to rise (or very little), no matter how much rainfall is received. This could indicate that impacted !:,'Toundwater continued to flow out of the Pit toward the former treatment unit, or possibly into surface waters directly through point source locations. In contrast, other land depressions on site did fill up and overflow during large rain events. e. Only part of the Pit was uncovered in December of 2010. According to worker testimony, the Pit would have extended further south towards town, if all of it had been uncovered. Pictures of the Pit shown in the appendix of this document only show the uncovered portion. f. As of May 11, the pit has now been filled in with sand and dirt. Impacted concrete side walls have been carted away, likely to a construction waste disposal location, with no known sampling of impacted debris. B. The Waste Water Treatment Plant a. The Waste Water Treatment Plant (WWTP) is built on very low-lying land, very near to the Rogue River. It was "filled in" to make room for the WWTP. The content and toxicity of "fill" is in question, as it is known to include old leather scraps and hides and other materials originating from the tannery. b. Because the WWTP is so near to the Rogue River and Rum Creek, it is the prime area where storm water mns off the site and discharges into surface waters. Workers describe the construction of the WWTP as an ''engineering nightmare.'' It is constmcted on 40' pilings and workers had to drill for days to find solid bedrock. Also, it was built on top of or right near a former city dumping area. Workers recall trash and landfill debris floating to the top of the water's surface while the WWTP was being constmcted. C. Buried UST's and Diesel Railroad Cars/ Absence of Monitoring Wells: In reading the interviews of former tannery workers Leonard and Roger, and in reference to the 1994 site assessment, it is not clear whether all UST's are accounted for. Citizens did note dark stained soils at the sou them end of the site and observed one demolition worker digging into it, start to remove it, then put it all back. There are photographs which show some of this soil. EPA Petition Summary 8 �D. Chemicals of Concern: Historical usages of the following chemicals have been documented on site. This documentation is based on interviews with former employees and from lists on file at the DEQ. A main concern is the likely improper disposal of chemicals prior to the enactment of stricter environmental regulations in the l 970's and I 980's. Even after that time, however, former employees report frequent spills, accidents, and less than ideal housekeeping practices. One supervisor, in particular, was negligent when it came to the safe disposal of significant materials. Higher-ups were likely unaware of such wrong practices on the part of some supervisors. Here is the list of chemicals: a. TCE, carciogenic color dyes (used prior to thel970's), trivalent and hexavalent chromium, acids, chlorobenzene, b. High concentrations of metals such as lead, cadmium, barium, copper arsenic, and c. WWW tannery wastes, according to the 1994 ESA have contained lead, zinc, nickel, cadmium, chromium, and acetone. Other waste manifests on file with the DEQ include TCE, arsenic, and toluene. While these are the primary known constituents of concern, tannery operations often utilize additional chemicals that neighbors would like to see sampled for as part of any prospected sampling efforts. (See Appendix for more detailed list of chemicals used at this tannery) d. Of note: During demolition, WWW was continuously testing the air for three specific substances: chrome, lead, and cadmium. EPA Petition Summary 9 �Post-demolition: No Capping of Site 1. The WWW site likely qualifies as a facility, under Michigan Law, yet the public (and regulators) have been provided with no post-demolition environmental testing or sampling results. Citizens are concerned about WWW's apparent decision not to cap the site. The capping and berming methods utilized by WWW, (presumably) clean fill, top soil, and turf grass are inadequate in controlling leaching of "possible" contaminants into soil and the waters of the Rogue River and Rum Creek, either by surface flow or by point source or groundwater discharges. 2. Significant rainwater/ SESC events continue to occur. WWW has been attempting to control massive rainwater flows with single sheets of plastic on poles and small dirt berms. The result has been major flows of highly turbid water into Rum Creek and the Rogue River, which might also contain any or all of the chemicals of concern listed above. b fact, in the absence of any known testing of surface and groundwater flows to surface water (in spite of repeated complaints), it should be presumed that turbidity is not the only issue of concern. EPA Petition Summary 10 �Final Remarks/Observations 1. High paid lawyers, low-bid on demolition and constrnction activities. Neither Pitsch Demolit1on nor Rockford Constrnction are Environmental Engineering firms. Protection of human health and the environment has been delegated to lay persons who do not qualify as environmental contractors or professionals. There is no indication that these workers have any of the training necessary to implement the already cursory protections outlined in work plans to date. Lawyers for WWW, who seem to be providing all of the legal advice to WWW, seem to have very little awareness of the site and citizen concerns. WWW has refused to interact with neighbors in any significant way, relying instead on a city government hostile to community concerns, as they relate to a major employer. 2. The Big Red Flag: In January of 2011, a few weeks before the planned construction of their new Flagship store, (south end of site), WWW pulled the plug on their redevelopment plans. It appears the site will be mothballed. Initial plans were to cover the site with 6 feet of clean fill to allow unrestricted use. Neighbors are concerned that this will only act to raise the groundwater table, increasing the hydrogeologic gradient and hastening the flow of impacted water into Rum Creek and the Rogue River. EPA Petition Summmy 11 �Final Questions Citizens of Rockford are left with many unanswered questions. This list summarizes the most salient among them. We want to know, through scientific collection of date and through clear answers from WWW whether our watershed is being compromised as a result of this recent demolition and of other unaddressed problems, both current and past. 1. Are there any records of monitoring wells being installed on site after the removal of UST's or for any other reasons meriting their installation, both historically and presently? We have noticed that some monitoring wells have been recently installed in the WWTP area of the site, one near Rum Creek, and one or two farther east of the WWTP. In a conversation with John Pawloski, of the local DEQ (RRD), WWW had notified the RRD offices that they were installing these wells, but WWW gave no details as to why they were installed, and as to who would monitor these monitoring wells. Perhaps the DEQ has more information at this point. 2. If the MOOT ( Michigan Department of Transportation still owns the old railroad bed that used to nm through the site, near the tannery building, why can't testing of soils and groundwater be expedited? Easements were traded when negotiations were made regarding the use of the White Pine Trail, but a land swap never actually occurred. 3. Are fisherman who fish near the spray of the Rockford Dam any more susceptible the inhalation of possible contaminants? Of particular concern would be some of the heavy metals like chrome or lead. 4. When two WWW employees pumped out the large puddle created on site for washing the wheels of the hundred of demolition tmcks that exited the site, should this water have been tested and disposed of in a documented manner and in a special kind of disposal facility? We have pictures showing how the puddle was pumped out right onto the site in an area close to the White Pine Trail.That area is covered with straw and the vegetation around it has not kept pace with the normal pace of spring growth. 5. From our perspective, there has been no point person who has been overseeing the multimedia effects of this demolition. The approach has seemed compartmentalized. In other words, different department of the DEQ have noted some of the trees, but who is looking at the forest'.' 6. Have there been instances of biased sampling? Have records been tracked for accuracy and accountability? We remain concerned about the earthwork and air migration pathways that occurred during the demolition and that continue in an on-going manner as a result of the demolition. 7. Any post-demolition samples? Residents have a pretty keen idea of what areas have EPA Petition Summary 12 �shown erosion and unusual surface water appearances. They would be glad to point out some of these places. Some of us have walked the site perimeter nearly every day. 8. Will our identities be protected in any form or fashion? Regardless of the answer to this question, we would have sent this petition to the EPA. It is our preference, however, that our spec,fic names are not referred to in the exchange of information. tis our lawyer who has expressed concern on this matter. His goal is to spare citizens any negative media attention, and to protect us from the cunning ways of WWW's environmental lawyers. 9. Regarding the tannery sludge that was placed on two different farms in the area, one within the city limits, and one two miles out, should it be concerning that one of these farms ha;; been redeveloped into a residential sub-division? We have heard reports of health problems on one particular street. One child died of cancer, one adult was sickened by it, and reference has made to other health problems on this street. We feel it is our res.ponsibility to at least convey this information to you. We have had little time to follow up on these reports, but we do have specific names of some of the individuals. I 0. More questions will arise. If we uncover any other pertinent information or have additional questions, to whom might we direct them? EPA Petition Summary ,_. 13 �Addendum 1. The signatures on the petition list represent a diverse group of city residents and others who live in the Rockford School District: Their professions and backgrounds draw from these categories: parent of small children, teacher, environmental engineer, recent high school graduate, fisherman , business owner, retired citizen, geologist, young adult, and member of the Rogue River Watershed Council. 2. In addition to contacts made to local, county, and state government agencies, Concerned Citizens for Responsible Remediation (CCRR), have expressed their concerns and sought feedback from the following groups: Rogue River Watershed Council, Trout Unlimited, West Michigan Environmental Action Council, the Izaak Walton League of America, and Kent County Conservation League. 3. Members of CCRR made a concerted effort to keep these issues out of the mainstream and local media. We saw no value in stirring up a frenzy, especially with such a decided lack of facts available. Much hard data, however, has been stored away, such as debris found in the banks of the river and creek: leather hides in various forms of disintegration, old bricks, mortar, asbestos shingles, mucky soil samples, and the like. Our archival picture file includes photos of these items and the locations where they were found. 4. Additional files are available that show some "hits" on water and soil samples taken on public lands adjacent to the river and/or the site. By "hits" we mean samples which show elevated levels of lead, chromium copper, arsenic and cadmium. In preliminary tests of the southwest cove and and of the puddles on the White Pine Trail which spill into the cove, the level of surfactants was also elevated, three times the allowable amount for surface water standards in North Carolina. We have been unable to locate Michigan standards regarding surfactants. Recognizing the importance of third party involvement by hiring a certified agency to grab samples and meet legal chain of custody requirements, citizens have proceeded no further with water and soil testing on their own. Aside from the costs involved, what's most needed, anyway, is for tests to be performed on the actual site. 5. We have striven to be accurate, objective, and fair in our presentation of concerns. If we have made any errors, we are unaware of them, but gladly welcome con-ections of them. On a limited basis, and due to the generously reduced rates of an environmental attorney, we have sought legal counsel at important junctures of this process. Our attorney has also spoken with tannery workers, our city manager, Mike Gifford, staff from the DEQ, and various members of our group, all in an effort to gain a clear picture of the situation and to guide us wisely. He is not a litigation lawyer, but one who seeks to build bridges and help move projects forward for the satisfaction of all parties. EPA Petition Summary 14 ��( ( C 12/15/9J \\ : \.,., ~"!: ~t;UJ, oaotLf._ ~, L") I' ! ,. r ~ ~ i I ~ l ♦ b ~U~M_l't_ ~:..ro-,-..-,;;-c_T__ II..,I ·=--~-·-·-·1 n '1 1 I _ _ _ ____,, ......," I .. • !CJC:11........J □ l:J~ 1 !\ ; • l i~ -s• oo~ ~[0. G:JID . PftPM0N. 0; EJ · · [][O! ~ Z 0 =c-~ ~ r.::.·:~..•) ~ ··- - - i I C1NC01.H sr. t~~--~.-.i••J·':::.••Jl -.::::~,,..1~--.,1.(' • .... ~~~:- ~ □I ADot.l"H ~ 1 □ 1=w~~~ j li ,1 .LJ~ i L !I I r::· go- e. A -:a;.,, :a:.;a,..°":1" r1 z ) ..l z-t o -i A -{ jo ~:;:;;:.::;;~~r=; ,:.,. °",,,,..,no fT1 -t o::Oo -<ii ~ )> -0 ~ • Oo ~ ?::0-n z 20 Q l> z 'I § 1 ~ . .I\" r·-· t r " .. n g ~ ~ 0 ~ -NORl tttt+ ~ COMSTOCK PARK TO CADILLAC RAIL-TRAIL !2 ROCKFORD, MICHIGAN ~ ~~ ENY!RONMENTAL SITE ASSESSMENT LJ _ . __ _ ___ PHASE I ~\'~°§]II . ~--·-·J ........ 0 . I I J frr,&h fishbeck, thompson, carr & huber engineers • scientists • architects Ada • Lansing \ I �II,1 ROCKFORD PARK DR Algoma Township - ~ _,. -=:_~~'(.'iD I <:,~ J~ ! . ifl 4l --- ~ !iifJ ---:-:~ ,,..- J / I • ~~ ! it; ~ u •6Ll'if1'il 1: 1, 1\1\lr'\E '( I ... ~I l; ,, ~,,1__, _._ ,. , t<'L " ?~ ( ! ~~~~ ' ::::: , ,-;: \ i. ~ fr ~-s=-- If "-" ~s-,clt.-di Iii .,,, fNTR~L ; Cr,,. ~--: a: ::,, ..., _, ,, j (3(($'tNess f)IS?"R,.G T' ' 11/ 1 jMAPLE 5 ;:::=~;_J ..... . ..._r,~ ~~ ~· d- - _; I infield Townsh·Ip . /J ~ ' ~ ~ ~~ ~ ..GBES!:J, w -·· ~ # ~ ,-,;'\ • •• • , r"--"'"--' I 1~ ~' 1 RO 11.J.\IL r--="""-:...c-,, ~· "i - . . ~~~1."t '--~t �I 'If llU I • I I ,, 1 } _.. /. ; 1;-_t__.,- (...:"'-::-I r--- , 1 l t,_,.. : Algoma Township i / ., --11 ~ Ill / .,r: I ._ Courtland Township Plalnfleld Towns �~ent County Map Copyright http://gis.kentcountymi.gov/MapPrint.a © 2009 - 2010 County of Kent, Michigan. Al rights reserved. Kent County Geospatial Service DISCLAIMER: This map does not represent a legal document. Kent County Michigan makes no warranty, expressed or implied, regarding the accuracy, completeness or usefulness of infonnation presented. Users of this info_nnatlo_n assume aH Nabity for Its ftness for a particular use. �Page 1 of 1 ,one - Rum Creek, USGS Rockford (MI) Topo Map 0 0 0.3 0.6 0 .2 0.4_ 0.9 0.6 1.2 0,8 1.5 km 1 flli UTM 16 617070E 4775446N (NAD27) Rum Creek, USGS Rockford (MI) Quadrangle Projection is UTM Zone 16 NAD83 Datum ://www.topozone.com/orint.asn?1at=4~ 1?464Rrlcvn= -R" ,e;;,<()QA,{l, ,,;~o-19...- A M=- 5.221 G=0.984 o_, ____ __r-r.r1 n • , �,A-e,ut! Vt'WJ - IOVM of Roe~, Mtcli j>-- Pos~ - d«',.,...,I•'+• 'dn ~ ��f<s,Gl(£rJ , ),t, eh c~ Z>n ~ ., - - = - ~~;._,___--=----=-=-.:.=----..;__~ ~~~~~..:~~~ .<a-h ./'/#ti, j~$f $okH. of -/4,n,)11 srl?e. �v,~s... ~ ~,::s.. All r•r ~~ou.J Jvor~ M?J,'rs+,,-ur ,•,._ R.oc~r~, M.r,. - l WWW t~lA(, ,~a N, Ma,,- tS jct.St wcs+ df -#,t ffOI' �I �wh,t~ p,'M, T~.. , "" ~ -n,,·1 --- ,·s ���WOLVERINE® ......... .lfl'~·~•woRLDWIDE ,.v., • Main Street Office 123 North Main Street ��~ ldsc.-'-', of B4c/f!- •f T;/M•,Y I �'---""' ���\ \ I �Tannery Worker Interviews Wolverine World Wide, Inc. These interview notes were compiled by Concerned Citizens for Responsible Re-development (CCRR), a group of residents, fisherman, environmentalists and others in the Rogue River Watershed concerned about the environmental impact on the Rogue River from the recent demolition of the 15-acre, 100-year-old Wolverine Worldwide (WWW) tannety site in Rockford, MI. The interviews were compiled over the course of nine months, between July 28, 2010 and March 20, 2011. Three of the former tannety workers, George, Sidney, and Roger, are willing to speak further with officials from the EPA or Michigan's DEQ. The interviews represent workers from ages 40 to 83 years old who worked at the tannety anywhere from l 0 to 40 years. A variety of jobs are represented: employees who worked in the tannety, the hide house, the waste water treatment plant, the maintenance department, the color dye department, and in supervisory roles. The names of the tannety workers have been changed to protect their identity, though addresses and phone contacts exist for all of them This list of workers is not exhaustive; a list has been compiled of other former employees who might be willing to share additional information. Summary of Interviews The following interviews give a lot of information about ''Hot Spots" on the site, specific areas where significant chemicals were spilled, stored, or disposed of improperly. They also identify unsafe, sloppy, or environmentally problematic practices that occurred while they were employed at Wolverine World Wide, Inc. In this document important information can be found regarding: 1. 2. 3. 4. 5. The Pit Color Dyes and TCE UST's Above-ground storage ofun-emptied chemical tanks The poorly designed and operated waste water treatment plant area Names of Workers 1. 2. 3. 4. 5. 6. 7. George Sidney Karl Marvin Leonard Roger Max Tannery Worker Interviews �TANNERY WORKER #1: GEORGE Interview Notes George's comments are the compilation of two phone interviews and three interviews at his home. George has validated his comments through reference to specific site maps and photographs. When the Pit was fenced off during the winter of 2011, George drove to the site and verified that this was the exact area where the maintenance building of the tannery once stood, for beneath that building lay the Pit. Background Notes George worked at the tannery and at the waste water disposal area for over 30 years, and worked right up until the time the tannery was closed. The problems related to underground sewers blocking up and overflowing that he mentions continued to occur right up until the tannery closed. George is willing to speak to officials from the EPA or Michigan's DEQ. George's Comments 1. "Now underneath the maintenance department in the tannery is a big problem. This in the area where they used to have those loading docks when the trains went through to load up the hides. Well under those docks was a ditch sort of area, I'd say about 70 to 80 feet long and 30 to 35 feet wide. The place was nasty. One time I crawled down low and looked and I saw huge mounds of hides and stuff 2-3' high and there was all this stuff mixed into it, big wads of paper, like wads of toilet paper, and other waste materials. I believe sewage went through it. I believe the sewage went though it and then over to the waste water treatment plant. Right up until 2009 when we closed, especially the last few years, those pipes/sewers that went from the tannery to the waste water treatment plant were constantly plugging up. The company never really got around to fixing the problem and cleaning them out, so they would just get blocked up again and overflow. I guess they didn't want to spend the money. Those sewers were full of all kinds of stuff: sulfides, chrome, .... Every chemical from the color dye department and the tannery went right through those pipes: chrome, spilled chemicals, sewage, sulfites, formic acid, sulpha hydrates, formate, ammonia sulfate, lime. Those are some of them. Well, once the railroad stopped coming through, Wolverine just filled the ditch area in. They never cleaned it out. They built the maintenance building of the tan yard right over this ditch area Years later you could still smell the stench of that stuff right through the cement floors. Yeah, you could especially smell it on hot summer days. This is all fact, you know. Everything that I am telling you is true. I saw it with my own Tannery Worker Interviews 2 �two eyes before they covered it up. And I know they never cleaned it out." Pictures of the Pit, uncovered in December 2010, are included in the Picture Album. 2. ''You want to know about hexavalent chromium? I did everything but swim in that chromium. Yeah, we used it, it was the real stuff Yeah, it got into the sewers and stuff." 3. "Oh, I forgot to tell you, I think that they built the waste water treatment right over the old city dump. I remember that they needed these huge augers to dig into the soil, way down deep into the bedrock. They had an awful time of it. ... What kind of flooring they put in it? No, I don't remember." 4. "Here's something else that you should know. When Wolverine was re-doing parts of the tannery, there were these two huge cement tanks about 25 feet by 20 feet and 18 feet high. They were pillars that used to hold up the tanning drums. But they also were storage tanks. One tank was filled with chromium and the other tank was filled with sulfides. WWW wanted to be able to re-use these chemicals and not waste them. That was pure chrome in one of them. But the engineering project turned out to be a nightmare, yes it was very poor engineering, and as a result WWW decided to just build the new area armmd these tanks. Yes, they just kept them there. No, they were never emptied out. Yes, they are above ground .... Yes, the tanks just became part of the building structure." During the demolition these two tanks along with two large tanning drums were uncovered. There are photos ofboth in the picture album. 5. At the close ofthe first interview George repeated one more time: "Look under the cement floor of the maintenance department building in the tan yard. That's where that sewer is that used to back up and flood out the openings and fill the ditch right up, that ditch that they covered right over." Tannery Worker Interviews 3 �TANNERYWORKER#2: SIDNEY Interview Notes Sidney's comments are the compilation of two personal interviews and one phone interview. One of the interviews, with his permission, was recorded on tape. Background Notes Sidney is in his early eighties and worked almost all of his adult life at Wolverine Worldwide Leathers, Inc., handling a variety ofresponsibilities, including supervisory ones. He could spell each chemical he named, he recalled the concentrations in which they were used, and he still has the layout of the tannery WWTP site pictured clearly in his mind. Sidney has particular concerns about the tannery building itself, the loading docks areas, the color dyes used on leather, the waste water treatment area and its housekeeping practices, and the Hide House, where the hides were kept cool. Sidney is willing to speak to officials from the EPA or Michigan's DEQ. Sidney's Comments 1. "We carried formic acid around in buckets, also muriatic acid. It would slosh around and spill on the floors. We reused our pails." 2. ''We used TCE (frichlorolethane) to degrease the hides at concentrations of97%." 3. "Another chemical we used was tetrapohl." 4. ''We may have used sulfuric acid at the tannery. I'm not completely sure." 5. "Fluoric acid is the worst one. I don't think we used that one: I'm quite sure we did not. See these burns on my arms, though? They are from the formic acid." 6. "Other things we used were stanosal (a Kerosene-type compound) and ammonia in the color process, and we used tri-sodium phosphate to clean-out the color mills." 7. "The color dyes we used were very heavy, very strong, especially black and red. Oh, yes, there was run-off. It spilled." 8. "The concrete used back in those days when the tannery was built had a low 'R' factor. It \WS more porous and not as watertight as the concrete that they make today." 9. "I am concerned about that settling tank in the WWTP area There were problems there ... 10. "Sometimes the tannery sludge [because it had lime in it] was taken by a wo*er to his farm up on 12 mile. He thought the lime would be good for the soil, so he fertilized his fields with that sludge." Tannery Worker Interviews 4 �11. "Dust? Oh yeah, dust got around all the time." 12. "Yeah, here is my final comment: I can't believe that anyone who knows about these past tanning practices and the chemicals involved, wouldn't have the EPA involved." Tannery Worker Interviews 5 �TANNERYWORKER#3: KARL Interview Notes Karl was interviewed by phone in December of 2010. Background Notes Karl worked in the color dye department right up until the time the tannery was closed. He weighed color dyes among other duties. Karl's Comments 1. ''Yes, we used TCE. It was horrible stuff. We had to be really careful because cold water would activate it." 2. ''Yes, I remember the drains backing up. Sometimes we had to change the schedule: Use only two color mills for three days, or switch and use three mills for two days." 3. "I remember one time when the creek turned red. Stuff was coming right out of those mills and pouring into the creek. They changed things after that." 4. ''You know that WWTP was built on leather scraps, sand, and rocks? Yeah, they dumped chrome hides in there, too." 5. "Someone dumped chrome sludge on some farm west of Rockford. Right near 10 mile, fairly close to town. Right near Childsdale Road, I think." 6. "Final comment: You know that sand that they are putting on the site to cover it up? It won't hold back any contamination from getting through." Tannery Worker Interviews 6 �TANNERY WORKER #4: MARVIN Interview Notes This information was recorded during a phone interview with on Wednesday, Dec 1. 2010. Marvin attests that all of these statements are truthful and accurate. Background Notes Marvin worked at the tannery for over 25 years in a variety of jobs. He is on disability now and has a variety of health problems. He lost one eye due to cancer. Marvin's Comments: 1. "It's all muck and soft dirt around the Waste Water Treatment Plant [WWTP]." 2. "When they built the WWTP they built in on 40 foot pilings, and after digging out all of the muck and soft dirt, they just backfilled it with a lot of sand. They drilled for two days to find bedrock strong enough to hold up the tanning mills ... Yeah, they filled it with sand and stone. It was Gust Construction in Cedar Springs who did the work. They [WWW] always went with the low bidder." 3. "Hey, I'm not a geologist or anything, but there's got to be problems there. They built that part of the WWTP and tan yard in a swamp." 4. ''There were cracks in the floor all over the Hide House. And the sewage pipes were always plugging up with scraps of leather and overflowing. Those pipes under the ground were always cracking and had to be fixed. There were a lot of chemical spills in the Hide House and the Tannery. I mostly remember the chrome and the sulfites. Sometimes a door on a tanning drum would break with no warning, and chrome and other stufflike sulfites would just come splashing out of the drums." 5. There were "hundreds of chemical spills" in the tannery and hide house. 6. "I remember that upstairs in the tannery they had these barrels of ammonia, used for cleaning, that would flow from pipes into the colors. Them barrels were always leaking and ammonia would spill and drip all over the place. It was strong stuff." 7. "One time ammonia backed up into the water system and the drinking water was contaminated." 8. "Lots of the workers got chrome poisoning. They would get hives, a red rash, and itch all over the place. One woman was using a chemical called Bavon [sp?], something used for waterproofing, and she practically lost all her skin. Had to be put on another job. This was about 20 years ago. The color technicians? Their arms were always breaking with rashes." Tannery Worker Interviews 7 �9. "I remember that sewage ditch under the Maintenance Building in the tanyard. It was putrid. You could still smell it in the summer, oh yes." 10. "When they did the pasting over in the pasting area, they would pump the pasting slime right up and out onto the floors. It was black, and yucky, terrible stuff. One area where they did this was right under the office building of the tannery, the brick part of the tannery right near Main Street. I think there was a pasting area in the maintenance building area as well." 11. "I do remember that they stored chromed leather out in the back parking lot. Some of it never came back in." 12. "Harold Bailey, I think he was a company engineer. He was a real clink and a mean one at that. They kept him on for a while. It was the folks who did things right that got thrown out." Tannery Worker Interviews 8 �TANNERY WORKER INTERVIEW #5 LEONARD Interview Notes L~lOnard was interviewed twice by phone in November 2010. Background Notes Lt:onard worked a variety of jobs at the tannery and is very knowledgeable about the existence of and placement of buried UST' s. His general knowledge of work practices at the WWW tannery co-insides with statements made in previous interviews, especially George's comments regarding the Pit. Leonard's Comments 1. "I cannot believe that they [WWW] are not being made to clean up that site. There's pollution, I know, all over the place in that ground." 2. "That area right between the tannery and the powerhouse, about 15 feet or so off to the northwest comer of the powerhouse, WWW buried a tank of#6 oil. It was a railroad car tanker, a very large tank, and they just cut the wheels off the railroad car and buried it in the ground. The tank was never completely removed. To get rid of the problem, Gus Construction came and cut a 4 foot wide hole across the top. They burned off as much oil as they could, then tried to pump the rest out. Then they power washed it. After that, they filled the thing with sand and covered the area over with asphalt." 3. ''Now here is what it important. I am pretty sure that oil must have leaked out while it was in the ground. The reason I think so is this: After the tank had been power-washed and the water sucked out, I went down to check it a few days later. There was two feet of water at the bottom of that thing. The groundwater must have leaked in through holes in the bottom or sides." 4. "There were two other railroad cars tankers that were placed in a small building just off the SW comer of the tannery, at the back of the building. One tanker was filled with 930 oil and the other one filled with Mardol oil. The two were stacked right on top of each other. There was a dirt floor in there. I am quite sure that the oil was leaking, because when I went in that building to check on those tanks, I would stand up to my knees sometimes in mud and oil. In 1998 a strong storm blew the top off of that little building. So they removed the two tanks and got some new ones that they put in the second floor of the tannery. Again, they just filled in that area where the tankers were with sand and covered it up with asphalt." 5. "Another area where there was a lot of problems was just 20 feet south of Rum Creek. Underneath that maintenance area of the tannery, where the old railroad docks were, was a pretty large crawlspace kind of area It had a dirt floor. It'd say it was maybe 100 feet by 60 feet and it was filled with untreated sludge, stuff that was on its way to the WWTP. Many times the lines would get plugged up with hides and stuff and this untreated waste would Tannery Worker Interviews 9 �back up and flow right into the tannery. There were all sorts of chemicals in there as well as animal wastes and grease and such. This area was never cleaned up or emptied it out. They just went and built the maintenance building of the tannery right on top of it. The smell was putrid. Those sewer lines, by the way, were backing up right up until the day the tannery closed." Tannery Worker Interviews IO �TANNERYWORKER#6: ROGER Interview Notes Roger was interviewed twice by phone in November 2010, and once in person in December 2010. Background Notes Roger worked at the tannery for over 20 years and has a particular knowledge of the WWTP area, thfi Pit and the UST's. Roger's Comments 1. The Use ofDyes: "The guys were concerned about using these dyes; they were concerned about being exposed to carcinogens." 2. The Pit: ''Debris from the tan mills and the color mills was always getting stuck in the sewer drains and pipes. That crawl space/ditch area under the maintenance building of the tannery would get flooded up sometimes and all that stuff would overflow onto the floors of the tannery and even out onto the soils arolllld it. It was a large area and it had a dirt floor. It would take 2-3 days for this ditch to fill up when those drains got backed up and the mainline had frozen. I think the ditch might have held over 200,000 gallons or more of water before it all came backing up and out onto the tannery floors." 3. Other Concerns: a) Have all buried oil and gas tanks been accounted for? Is there still the need for test wells? Roger does not recall that there were many (or any) test wells put in to monitor the impact of various US T's on site. b) When two new tanks were added to the WWTP in 2000, they had to dig down into those soft soils. [At present this area is filled with circular depressions that fill up with water.] c) Before the hide house and the tannery were connected by the bridge over the creek, there was an access hole by which sewage and tannery waste would flow into the creek. 4. Chemicals Roger remembers using: a) Chromium b) Sesquacarbonate (?) c) Tri-sodium phosphate d) Sulfuric acid e) Formic acid 0 Powdered lime g) Caustic rock salt h) Tergitol (to wash grease) Tannery Worker Interviews 11 �' - TANNERYWORKER#7: MAX ' Background/Interview Notes Max worked at the tannery for only a few years in the mid 1970's until he decided to look for work elsewhere. Max grew up in the city of Rockford, however, and is very familiar with the site and its butldings. As a child, he remembers playing on the hides stored out back behind the hide house, near Rum Creek. Local fisherman referred to some of the filled in swamp areas as "the islands of the lost soles." Summary of Max's Comments 1. Max is quite clear regarding the significant amounts of hides that are dumped in the banks of Rum Creek and the Rogue River, and as residents have later discovered, in city locations other than the tannery site. 2. He remembers, with sadness, the untimely death of two maintenance workers who were told to go down and unclog the sewage pipes in the WWTP area They were overcome with fumes from hydrogen sulfide gas. No breathing apparatus was used at this time. This happened in 1975. George also remembers and knew these two men. 3. Max also recalls that many of the workers had chrome poisoning. Their arms were breaking out in rashes all of the time. He also referred to the use of two other chemicals: bucane and chlorobenzene. 4. Max still fishes in the Rogue River sometimes, but not much. The waters have become too warm and trout fishing has suffered as a result. Tannery Worker Interviews 12 ��T'dnner--t ~· H ,. d~ Ho,.c..se j },\bi SPoTS \ \ IIATDI a.!DIS • HIDE STORAGE COOLER I . (3 111.UON lBS. S1t1ltAC£ CM'ACITI) S'POTS :1., Pi't lo ~ UrJv mat~1'tl\, WOLVERINE WORLD WIDE TANNERY BUILDING ROCKFORD, MICHIGAN TANNERY FIRST FLOOR 3-3-0<f o2. Color M/lls ( Dyes 3.L.~ltl,.,w.~ -~,§'' 4. ,Wj~ ,.4-bov~ ~ ~~ S. ~ r loC4tfg" ~ t,,_ , rtt,C" ~ - ~1 l �Appell1o1bc A - list o..- Sog111ificant Materials ~:'-~~-:'?':· :·c:· •· t::?::.:E'.:9?:<:· • • ··.?,! --.-~~~!~~~0~~""J.2'.:_. ". ~: r ~~::.£:_-;z.::,;.:!E.~~:::i~-::,~'-:---:·~"!":~::''': ';"'•:r:":JE~~Ji. ~-:.i.£:-!!.:'::.~~ -~::,'~::JE.:t~r:-.-.-:::?::::- ··-~:..:":1:-:,i:-~~= :='.·?-~:: .::.~ ~~•:-:-"!''}~~~:-:=:..?:-,-;"•.:':~: •· ~.3;'";!:~::~-~- 1. Tannery Material/ Chemical Storage - 3rd Floor Chemicals stored in large (10,000-gallon) storage tanks located on the 3rd floor present the greatest concern at the Tannery. However, because this area was designed for this storage and provides the necessary containment, there are enough engineering controls to help contain and limit potential hazards. A table summarizing liquid chemicals stored in -tiun~-on--tlie 3rd -fl6or of the TanneryT6116ws: Maximum amount Containment Two Fiberglass tanks 10,000 gallons each Tanks are surrounded by a concrete containment wall Sulfuric Acid One Fiberglass Tank 8,000 gal Tank is surrounded by a concrete containment wall Formic Acid90% One Fiberglass Tank 10,000 gal Tank is surrounded by a concrete containment wall Barron SE-G Fiberglass Tank 10,000 gallons Tank is surrounded by a concrete containment wall Chemical Name Storage Container Acid naphthalene syntan Chemtan DN Liontan LA 275 gallons 880 gallons 880 gallons Busan 30L AMA 810 Prevento! CTL Plastic Totes Prinol FG-B Plastic Totes are transferred to Stainless Steel tank 750 gallons Leather Protector PM-4700 Plastic tote and metal Mother totes 500 gallons Plastic Container 400 gallons Fat Liquor: Morite AAOK Any spill or loss from these containers would be drained to the in-plant drains which flow to on-site WWTP Any spill or loss from these containers would be drained to the in-plant drains which flow to on-site WWTP Any spill or loss from these containers would be drained to the in-plant drains which flow to on-site WWTP Any spill or loss from these containers would be drained to the in-plant drains which flow to on-site WWTP Appendix A-1 Spill Response Dilute cautiously with water and gradually neutralize with soda ash; then rinse down drain to on-site WWTP Neutralize gradually with soda ash; then dilute with water and rinse down drain to onsiteWWTP Dilute cautiously with water and neutralize gradually with soda ash; then rinse down drain to on-site WWTP Pump to drum and reuse; small amounts can be diluted with water and rinsed down drain to on-site WWTP Try to contain as may affect WWTP biomass; dilute any remaining with water and rinse down drain to on-site WWTP Storm Water Outfall None None None None None Pump to drum and reuse. Small amounts can be diluted with water and rinsed down drain to on-site WWTP None Dilute with water and rinse down drain to onsite WWTP None Dilute with water and rinse down drain to onsite WWTP None �Tannery Material I Chen .. cal Storage - 3rd Floor (Continued) Chemical Name Sodium T etrasulfide 34% Unhairing Assist FR62 Cismollan UAL Storage Container Plastic 55gallon Drums Plastic totes Maximum amount Containment Spill Response Storm Water Outfall 1500 gallons Any spill or loss from these containers would be drained to the in-plant drains which flow to on-site WWTP Avoid contact with acids as deadly H2S gas will form; pump to drum and reuse; small amounts can be diluted with water and rinsed down drain to on-site VVWTP None Dilute with water and rinse down drain to onsiteWWTP None Pump to drum and reuse; small amounts can be diluted with water and rinsed down drain to on-site WWTP None Dilute with water and rinse down drain to onsiteWWTP None Dilute with water and rinse down drain to onsite VVWTP None 2,300 gallons Any spill or loss from these containers would be drained to the in-plant drains which flow to on-site WWTP Two Fiberglass Tanks 18,000 gallons Busan 52 Plastic 55gallon drums 110 gallons (Excess stored on third floor) Process Oil: Lubricating Oil White Oil Metal 55gallon drums 55 gallons each Wayne Tan 175 Basic Chromium Sulfate Tanks are surrounded by a concrete containment wall Any spill or loss from these containers would be drained to the in-plant drains which flow to on-site WNTP Any spill or loss from these containers would be drained to the in-plant drains which flow to on-site WNfP Note: The two Fiberglass tanks labeled "Sulfide" are empty Note: The two Fiberglass tanks formerly used for liquid caustic are empty Appendix A-2 �2. Hide House Daily inventories are kept on various chemicals to help identify any unknown chemical losses. A table summarizing liquid chemicals stored in bulk in the Hide House follows: Chemical Name Ammonium Hydroxide Storage Maximum Container amount Plastic Totes 900 gallons Bleach (Sodium Hypochlorite) Plastic Tote 330 gallons Caustic Soda Plastic 55gallon drums 260 gallons Fat liquor: Upsol SOS Eureka 1067-A Plastic Tates 1650 gallons Plastic 55gallon drums Varies by product average total 3000 gallons Plastic Totes 260 gallons Plastic Totes 520 gallons Plastic Totes 260 gallons Leather Protector PM-4700 Plastic totes 2000 gallons Prino! FG-8) Plastic totes 10,000 gallons Atlasol 177-C Eureka 400 R Eureka 575 S Eupilon WAS Lipsol S Lipsol MSG XerodermP-AF lnvaderm LU Sellasol KM (Syntan) DermafixWA Methylene Guanidine Containment Any spill or loss from these containers would be drained to the in-plant drains which flow to on-site WWTP Any spill or loss from these containers would be drained to the in-plant drains which flow to on-site WWTP Any spill or loss from these containers would be drained to the in-plant drains which flow to on-site WWTP Any spill or loss from these containers would be drained to the in-plant drains which flow to on-site WWTP Any spill or loss from these containers would be drained to the in-plant drains which flow to on-site WWTP Any spill or loss from these containers would be drained to the in-plant drains which flow to on-site W\/VTP Any spill or loss from these containers would be drained to the in-plant drains which flow to on-site WWTP Any spill or loss from these containers would be drained to the in-plant drains which flow to on-site WWTP Appendix A-3 Spill Response Storm Water Outfall Dilute with water and rinse down drain to onsite VI/WTP None Pump to drum and reuse; small amounts can be diluted with water and rinsed down drain to on-site WWTP None Dilute with water and rinse down drain to onsiteWWTP None Dilute with water and rinse down drain to onsite VV\/\/TP None Pump to drum and reuse; small amounts can be diluted with water and rinsed down drain to on-site WWTP None Dilute with water and rinse down drain to onsite WWTP None Dilute with water and rinse down drain to onsiteWWTP None Dilute with water and rinse down drain to onsiteWWTP None �3. Color Department Daily inventories are kept on various chemicals to help identify any unknown chemical losses. A table summarizing liquid chemicals stored in bulk in the Color Department follows: Chemical Name Ammonium Hydroxide Atlasol 177-C Eureka 400 R Eureka 575 S Eupilon WAS Lipsol S Lipsol MSG XerodermP-AF lnvaderm LU Sellasol KM (Syntan) DermafixWA Methylene Guanidine Fat liquor: Lipsol SQS Eureka 1067-A Maximum amount Containment Spill Response Storm Water Outfall Plastic Totes 300 gallons Any spill or loss from these containers would be drained to the in-plant drains which flow to the \NWTP. Dilute with water and rinse down drain to onsiteWWTP None Plastic drums 55 gallons 55 gallons 55 gallons 55 gallons 55 gallons 55 gallons 110 aallons Any spill or loss from these containers would be drained to the in-plant drains which flow to the \NWTP Pump to drum and reuse; small amounts can be diluted with water and rinsed down drain to on-site \NWTP None Dilute with water and rinse down drain to onsiteWWTP None Dilute with water and rinse down drain to onsiteWWTP None Storage Container Plastic Totes 260 gallons 520 gallons 260 gallons Plastic Totes Each 520 gallons Any spill or loss from these containers would be drained to the in-plant drains which flow to the WWTP. Any spill or loss from these containers would be drained to the in-plant drains which flow to the WWfP. Appendix A-4 �4. Wastewater Treatme, l l Plant (WWTP) Daily inventories are kept on various chemicals to help identify any unknown chemical losses. A table summarizing liquid chemicals stored in bulk in the 'NWTP follows: Chemical Name Storage Container Maximum amount Containment Spill Response Storm Water Outfall Sulfuric Acid Phosphoric Acid Muriatic Acid Plastic 55gallon drums 110 gallons each Any spill or loss from these containers would be drained back into WWTP. Dilute with water and rinse down drain to onsiteWWfP None DF 431 Plastic Tote 500 gallons Any spill or loss would be drained back into WWTP. Bleach (Sodium Hypochlorite) Plastic Tote 500 gallons Any spill or loss would be drained back into WWTP. 520 gallons Any spill or loss from these containers would be drained back into the WWTP. Tank 10,000 gallons Yes- Containment Wall. Any spill or loss would be drained back to the WWTP. Lime Slurry Tank 10,000 gallons Yes- Containment Wall. Any spill or loss would be drained back to the WWTP. Perlite Tank 1000 gallons Any spill or loss would be drained back into the WWTP. P-250 HV Plastic 55gallon drums 330 gallons Any spill or loss would be drained back to the WWTP. Caustic Soda Ferric Sulfate Tote Appendix A-5 Pump to drum and reuse; small amounts can be diluted with wateir and rinsed down drain to on-site WWf P Pump to drum and reuse; small amounts can be diluted with water and rinsed down drain to on-site WWTP Dilute with water and rinse down drain to onsiteWWfP Pump to drum and reus8; small amounts can be diluted with water and rinsed down drain to on-site WWTP Attempt to collect and reuse; if not reusable, dilut,3 with water and rinse down drain to onsiteWWfP Attempt to collect and reuse; allow water to drain away and scoop up and reuse material Attempt to collect and reuse; if not reusable, place in drum or dilute with water and rinse down drain to on-site WWTP None None None None None None None ��V,-e&I,.) of P,·t fn,"'" .sfcu·rw~ of- ref~,'I bL( .-,.t' "j �~ ~,_,~ C,red(. ,s l~UA. ~ ... -tw,\ud v,w of: 'R~ c~ foof(,~ .:soetf-1., - ;lue.. ,~ s ,'t~ ~r.·4'(a-' Grosst!s 11,,ac... whuc. cruf' . �). �Tt-,e Frt- - v ,-e.,A ~~pr,-~ rnon-rl\~ �- "i R~t., .· , fu~ ~ f>:c- ��Hides, Hides, and more Hides Members of CCRR, as well as local fishermen, have found scraps of leather hides, in significant quantity, stuffed into the banks of the Rogue River and Rum Creek. These leather scraps have already been tanned and treated with chrome. They have been found wrapped around tree roots, hanging in the river, and bursting up through soils. Tannery workers have verified their origin as being scraps from Wolverine Leathers. Here is a location map to date. Ot:Nr jl\.c{t,c.sfr,~l Jt-br,~ hds 0 tso bur. ~J. 'A the.f.'4- a.re.PS• ........ H;J,s .Tr.. rL6iele,at;;, l area A~V rivu, ~► ii~ a. :S'llbU. }1{'1.t;S ,·I\. ba11K-s .1P- RWh CrUl<.. HlJ~s 1A. 'R~ i ~f; ·-;;,I ttru, DI\,, b~~s of. /?i,.m C~eK H-,a e:s fz,c.rJ ,·~ bic,,'ra~s .s~ct,~ "f ~~ ne~r Wka'hz. ?in~ -rr~; ( ~' 'Prum~J ~ �c::::7-r'------------------~ ..Jn -f1, t!.. b-a~t::: of RG<"""' Creel< �Hides ,n... ~~ b:a,\ t!- ➔ cF R~ Cru,K )1,· J. es lf'\I b~f'\~ • .f 1t -.."~ ,,.,.. .J --•--- H,·dc t" ~ for"".,,. ,-,,.P"'f"'- Pitt',~ Lotj leff ow_+ '" -rhe,J.~,,. e ~ . - ~ ,·., tArc.A . (A r~s,et""+,~( �~ H,·,Lu Arc. bur,~ &u,, wr-ltw~ ~ b?Jr'll:°S ��l~er1 ,. """ w•~ t>nL f.11,L ~,..,,,,. :l. ~,. ta.JC: . f,.,,.., ~"" ~lt,'te• l)l"Wr">:s.. ~ Abov, - Gr~ Che,n,c.;;.( ---,--;.,,.,~.s �Pmu-s fv,1r1,~, U.f -rh~~ 61.r't/uJ.. ·T ~~~~ lf"s- ~Me~ :i)rw,,s] l ,=,·uu ~"12:i:Jl. -Hlnt's,a/s-o . ·: - I P.-IJe.,( ~· W,ih c.hrc,mL w,:.fh .Sutf.r~ �'VJ'NW --n- :":I f\l\ }~~• t.f,;pl\ • o+ A1-1~·--v.1~"1~td---- ~ -fwo c"-.~~te•I fa,.Jc~ • �,. ~c+oW ~ • IIoVttrr..'ot!r ,;Jo to WW'N T~n-,r"' l>~~ I,t ;o,... 1 An c'~ d, ts.- a cl..Lm0llf-r.,n.,. e:> , - ��.:J UY\.tL :.2.0 LI »,'de.. Hot.tu Floor .st~rr1,, · fllrfher- bac.k N. M~il' $t- ,-("\ ~ bacK3n,ur1J ����/V~V2Jt1~ o?.o l 0 Phoro of- ht,me$· TO -#,e, r'l"~wesl- ot-·$1te) ju~ auz,~S ROcfu~ R~ �/tt'r ~l,(:al it1 0;hC ef'r-.5.. ���Two v,·ews furn -th~ r,·vu-. C;,mer!J .ftzas east- nwd,~ T~"""~rr s,"fe_ 0-cr.1-ss W'~• ,l,rtf{%oj#l Gw~ p";"t-~;,~ e,,ifers .;,f- tt d-, Wetl~...J_y .Bnei~ Pw,y H-dt6 T~er1 e,,.s.tel 11' ~vi~ Ottf "m"'-' f4, rivet' . ��·--- Lo ~tiPA 4'p WWTf> b4 / builJ,., �Spr•.,, R,,;., ~ Tv,-.1',·-C. w~+ar f ltMlS tvJ-e r -f-ht_ P"''',,,....~,+dl'ICA.. .,- ~ wfiTP . ., r~•t ~ -&>rMI W"N P,,,e T,1,·( W~t?r -ts,'lr NA~ N~~ w~.s+ & .-J..L ~~ wl-\,t-, P,nt. --rra: I �Jr,v) $ff'~ fa~rJc ikt.. ~&<t ArJ. olesd-ta~c.r Ir 6WPI\ p,;ri'f- -fiu.. ~•-t R,v_,. 'f?,•~r �--~=-~ -~~iiiiiiiiiiiiiiiiiiiiiiiii.~~~iiiiiiiiiiiiiiiiiiiiiiiiii~=~~ 51::,c C.o,-,cern ~: 'NWW l•""•"f ,.-)t'f'L.. w~~,. Vtew $m;,M.S of- 5w.i,t. 5'1~ --1-awa-a<s .5w~ Po,~r r~,"t- fuw. We.st s,;<~ .f- ~~ { �Hu~ ,-s~ Souru. of -H,,,e,_ "-..1..-. ' ~r ~•"'• "''\ vr,+v-~J -,,...., r~w, t-tft5nit~i le ·z ttt:A. i,IWTP are,... -rhw~ e_ orrrirttJ.&I .~;,.... .5 to .(~s ArvJ. • it \.U1lS no .Sm~ll tn·etla . .ll- W#S cift'.Jt'~ Wkl> calrd ~ . l)E~ ho+u,, ... -n,e c;tj c1,,1. n.,-,.. ~au..;;Jlfi::D:.::1:,~:;..::.c,.~~...£.J::..~.:...:...c~ «p~~,. ()t:fi"•~ tn " 1 4 / V ~ ~ , �-·-- I Eclrv po,;.fs ,,f R~1c~ ~ ~ =ER _ -______ W.W. T.P . •• ' ~ ;I ~ - -..,. N DRA1f\J1l-GE AREA DRAINS T" - ~ ~ w~~ - \ ���·v _\ · ..I . ~ .5itrfuu W»le,.... Concetl'rte\ AU ~le.J ~ WIVW ,.,,..1 ���4s,-~ Pt,ttMIJe... ~r Wh,te- .p,~ Tr2>, ~, SuNete£ w~iar~o~WeS Co\/f.,. "e~r WWTP �Ru.W\ &eAJ< _1tt~ w~.st "f N • J,,f:;,,i-, .$~¢AR" t:>t"'\ ~n"e"f :S•'tk. ~ t~ p•p,s CtJr.t•'rt'-'f. +o bn.:, w.>fv ,·,. ti, -llvcr~~K. �'"?~~, s~\, /\J~c.~s~ ��~1,;;~ /1,,,-ttll.ts ;;;,,,, ,;, t(JUJ,-P Al'~IIS wliuw. /"""J'- ~,,,cs- ""'"' .sfoeJ. �COtltn:J +u- S'k- wt#--- ~'/( _;v~•-;r:---::: .sa.nc~fe.-L $-f4,, �~~~\,t. ~~~ ~ -v~~t- t , ~ �Posr-k,-,..,l,nt:in Sc, ,-ls ~~------- �-<,,~ M✓tes hi,,,,, ,;, ~wtP At'us l,Jl/ieta /4,,-Jc. i':,11,Cs- dl'f"- ~fo~ �Colfdl':J +us~w~ i·I( yJe;f- :s.~ ~ LAJk)J~~ ~ '~ _;"ft,-\•~ Sa.ffcAA~ ~-f.a,, �? • µ.,,,._ w,"t dow/\,"'s~wvs • AtUA ·~ JtA'f l\Orf' of -0-c... P,t- - .-. - • M•"worlCc"-. hert. fo, ~-B d~~s • 7hc,, po&&r~~ s+~ff ,·,.. ~"'J. t-,~ $-1,_.ff OM~ �0 �~pee-•">( cor.t. be,cJ- ~Ken h, n,-.;rw.~ RUnl ~ •~ u,.ol( ~ Cr&t,/t! Pt.__, 'RUM.. ,. ~~-r- ) • �"""'"'-C.o "'-~", c,t,JJ04• I I �/ Cc... tL IL ' ti"{ c-,J.. �Dear Friends and Neighbors, June 24, 2010 Tonight, June 24, is the 7pm Planning Commission Meeting. The time of public comment (for any issues of concern) is at the start of the meeting, and these meetings begin promptly in the council chambers at City Hall After the time of comment, there will be a public hearing regarding the re-zoning of four acres of the WWW properties on North Main Street from Industrial to Commercial Of great concern to many citizens is that, according to The Grand Rapids Press (June 20), the demolition of the old tannery site, as well as all the office buildings, will be taking place this summer. Demolitions are not good news for citizens and businesses who are located anywhere near the vicinity of the demolition. Fugitive Dust is of a major concern because the airborne "cocktail mix" of contaminants can be a serious, wide-ranging health concern if: 1. a good Fugitive Dust Plan is not in place; and 2. the demolition site is not continually monitored by local, county, and/or city officials. Tannery sights, are usually most contaminated by the following four substances: chromium (including hexavalent chromium-Erin Brockovitch brought this to the public eye), lead, asbestos and mercury. By disturbing a site via demolition, the toxins increase in their bio-availability to the public. As citizens we want to make sure that all reasonable precautions are taken with good faith, of coune, that WWW will do their part. However, it is important that the public be informed and ask all pertinent questions before the demolition. The DNRE (DEQ+ DNR) has a somewhat limited involvement in the actual pre-demolition process. Complaints made and violations cited are more likely to occur after the fac~ or during the process. This is of little help if hazardous materials have already been released into our backyards, onto the surfaces of our homes, and into the soil and waters of our public environment. Most corporations are glad to work with and address the concerns of their coD1D1unity, and we have reason to hope that WWW will do all it can to safeguard the health and well-being of its local citizens. However, corporations are corporations, actions can be driven by economic profit, and for various reasons important items can be missed or overlooked or underplayed. Just look at the Gulf of Mexico. The unimaginable can happen. That's why Rockford citizens need to pro-active, diligent, cordial, and intelligent in asking pertinent questions. Now. Asking council memben. Asking the city manager. Asking the DNRE. What is Rockford's plan for a 1afe demolition? The city will be the entity that signs the final demolition permit given to WWW. What assurances do we, as citizens, want from WWW before any permit is signed and active demolition takes? This step is critical. Rockford has never faced a demoltion of this size on an industrial sight that contains so many dangerous contaminants. Just ask Kurt Overmyer, Supervisor of Kent County Health Department Problems of great consequence could occur without a safe, regulated clemollhon, especaauy w1tn ne1gnoornooos ano a ousmess OJSmct ano a nver ano a creeK and a bike trail and a parkall within a stone's throw of this site. �Now is the time to be informed and do all we can to ensure the safety of our families, our properties, and our environment. And not just for ounelves, but for all future generations who choose to live in this lovely, charming city. Some good questions to ask at the Planning Commission Meeting. 1. If WWW plansto put in grass on the rest of the site not occupied by the new shoe store, will WWW perform what is called "soil capping" or will they remove contaminated soils? * Capping as a aean Up Method: http://www.egr.msu.edu/tosc/dutchboy/factsheets/What%20is%20capping.pdf (this is an EPA doc from 6/92, seems to do a good job describing in only two pages) * Removing contaminated soils from two sites in Michigan, Battle Creek and Jackson (when you go to the url, do a "find" on "contaminated soil"). http://www.michigan.gov/deq/0,1607,7-135-3311_4110_23244-144685--,00.html 2. Does the Planning Commission enforce any standards for site demolitions? Does the City have standards for demolitions of large-scale sites (such as WWW) that are privately owned and that likely contain health hazards (mercury, lead, hexavalant chromiuim, asbestos) that could be stirred up when the site is disturbed? * Here's an article on two GM plants that were demo'd around 2005, and includes this sentence about fugitive dust: "MCM was also vigilant about dust control on the site. The powdery "fugitive dust" released in the air, a cocktail that emits from the building during the demolition, was combated with frequent watering. A Caterpillar water tanker doused the ground with water to tamp down the rme particles" @ http://www.mcmmanagement.com/Defaultaspx?tabid=l27 3. Who issues the demolition permit to WWW? How much lead time will residents be given prior to the actual demolition? Is there a tentative date set? 4. Why is WWW asking for a re-zoning before we know all the results of their Environment Assessment? What do we know about the buildings on this site and the extent of their contamination? Will changing the Zoning to commercial, prior to demolition, in any way make the regulations for demolition less stringent or open up any unforeseen loopholes whereby they have less accountability. 5. Are these four acres among the most contaminated? Do we have an answer to this question? Why move ahead until we have clear, satisfactory answen. 6. Are their enough commi11ioners present to make a clear, knowledgeable decision? Should we table the decision to re-zone till after the next city council or PC meeting? -coacerned citi7.ens of Rockford �C R Ni\ Cena-al Rockford Neighborhood Association To: From: Date: Re: Michael Young, City Manager, Rockford, MI Mike McIntosh, President, Central Rockford Neighborhood Association July 2, 2010 WWW Tannery Demolition Introduction Members of the Central Rockford Neighborhood Association (CRNA) believe that as citizens they have the privilege of and responsibility for participating with others in our City ''to help preserve the many qualities that make Rockford a great place to live" (CRNA Bylaws, adopted November 2009). CRNA's interest in the upcoming demolition and redevelopment of Wolverine World Wide's tannery site directly correlates with the purposes and aims contained in our Bylaws, which are copied at the end of this document. At Mr. Michael Young's invitation, we are submitting this document to the City for discussion and a Q&A time on Wednesday July 7, at 7:00 p.m. at the City Hall. We are glad and appreciative for the opportunity to meet with our City Manager regarding a topic of mutual interest and concern Assumptions • All in Rockford want a safe and uneventful demolition of WWW's tannery sitelocal children, schools, business owners, citizens, city staff, elected and appointed city officials, visitors, as well as WWW itself. All should work together to this end • The City of Rockford's government officials have the most control over the safety and regulation of the proposed demolition including, for example, pre-demolition and post-demolition testing and regulation of the actual demolition • If the demolition poses health hazards, children are most at risk • Fugitive Dust may be the biggest concern and the most serious health hazard as a result of the demolition. Especially if the site is not decontaminated before demolition, toxic fugitive dust may affect soil, water and air quality. This is a particular concern with the Tannery's proximity to downtown neighborhoods and businesses, parks, Parkside Elementary School, the White Pine Trail, Rum Creek and the Rogue River • If a problem arises with fugitive dust during the demolition, it could affect the economies of local downtown businesses Page I of3 �C R Ni\ Central Rockford Neighborhood Association • Rockford city officials will provide the public with clear, timely communication via multiple channels (meetings, newspaper announcements, website postings, letters, etc.) throughout the process • The City of Rockford should wait to issue WWW a demolition permit until independent experts have reviewed and approved of the full demolition plan (including pre- and post-demolition tasks), regulators are appointed or hired by the City, pre-testing of the site has occurred, and a clear and comprehensive communication plan is being carried out. Questions 1. Pre-demolition-Planning and Preparation a. What are Rockford's current demolition codes and ordinances? Are they sufficient in light of the proposed demolition of a large, historic, industrial tannery? Should they be updated prior to this demolition? (Updating them may prove useful for possible future demolitions-Burch Body Works comes to mind.) b. How will the site be cleaned to eliminate as many toxins ( asbestos, lead, mercury, hexavalent chromium, etc.) as possible before the demolition? c. Will the City perfonn its own independent environmental assessment? Will this include testing of core soil samples so that soil condition is known before demolition? 2. Demolition a. Who will regulate the demolition, oversee its safety, and communicate its progress? b. Will independent environmental hygienists be on site to monitor air quality? c. Under what circumstances would an in-progress demolition be halted? d. Under what conditions should businesses close during demolition? e. Will residents be advised to close windows? Leave their homes for the day? 3. Post-demolition a. How long will it take WWW to remove demolished materials? b. What route will trucks removing the waste take through Rockford? c. How will fugitive dust be controlled as trucks remove the waste, both from the site itself and as the trucks travel on our roads? d. Will the site be covered after demolition until all waste is removed? e. If there is toxic soil on the site, will it be removed or capped? f. What site testing will be perfonned, say, 12 months later? (One year later Whitehall still found problems with toxins that had to be abated.) 4. Overarching Questions re: the demolition Page2 of3 �CR NA Central Rockford Neighborhood Association a. Who will develop and execute a clear communication plan for all aspects of the demolition? 5. Questions re: this meeting a. Will this document and the City's replies become part of the public record? b. Will CC and PC members be invited to this meeting? c. Will WWW officials be invited to this meeting? d. May CRNA request an agenda item at the July 12 CC meeting to comment on the results of this meeting? )r;JJr;rd· \M ?-kl Mike McIntosh President, CRNA ,._, From CRNA Bylaws, adopted Nov. 2009 (referred to above in this document's introduction): Article II. - Purposes and Aims The aim of CRNA is to help preserve the many qualities that make Rockford a great place to live, more specifically: (please number these for ease of talking about them) A. To facilitate communication between neighborhood residents and city government. B. To balance the needs of business and neighborhood. C. To support the City in reviewing, interpreting, and implementing its Master Plan. D. To encourage conservation of the character and fabric of our neighborhood through historic preservation and appropriate adaptive reuse. E. To encourage community and neighborhood involvement in the redevelopment of available, un-used, underused, or misused properties and sites within the City of Rockford. F. To form a voluntary coalition to support projects and programs which promote the common good of the neighborhood. G. To inform, educate, and provide an open forum for the free discussion of topics which affect the neighborhood. Page 3 of3 �C R N 1-\ Central Rocldord Neighborhood Association To: From: Date: Re: Rockford Planning Commission Mike McIntosh, President, CRNA (139 N. Monroe, Rockford) July 22, 2010 Comments about WWW Demo and Site Plan Chairman Scales, Planning Commissioners, City Manager Young, City Staff, and Wolverine Worldwide: Since I would like my comments in full to be in the public record, I'll read from the document I will provide our City Clerk. I come both as a resident and a representative of the Central Rockford Neighborhood Association, as president. I raise questions about the upcoming demolition of the Wolverine tannery at this time because there are limit times during which both the City and WWW hear the same thing from citizens. I will sound like a broken record. Yet we have little from WWW in response to our questions in the last several City Council and Planning Commission meetings. So I raise them again in hopes of a reply. Our City Manager has been forthcoming with information, but he cannot share information he does not have. A CRNA adhoc team has spent over 100 hours in research and meetings on the topic of demolitions. We have researched tannery demolitions that have gone well, ones that have gone south, and ones somewhere in between. We have learned about fugitive dust, hexavalent chromium, soil caps, and asbestos abatement. We've also spoken with the Kent County Health Department, the DNRE in both Kent County and Lansing, MiOSHA, environmental assessment engineers and project managers, and a city council member from Whitehall. To a person, these people have confirmed that we have legitimate concerns. We hear little back at this point from WWW that alleviates our concerns. So these questions: 1. When will WWW have a detailed demolition plan? When will they share it? 2. What hazardous materials are on the site? How will they be mitigated? 3. What state demo requirements does WWW have to meet? What local ones? 4. Who will oversee and enforce requirements? How will the demo be halted if there are problems? 5. Will the site be certified inert before it is demolished? 6. How will fugitive dust be stopped at Wolverine's property lines? My final question is a rhetorical one .. .I hope. Let's imagine that we pick up WWW, with all its buildings including the tannery, all its culture, with all its 100 years of business, including the tanning of leather. The demolition is now some other city's problem. Do you feel relieved? Let's say we pick it up and move it to Ada, on the banks of the Thornapple, perhaps between the Tl7ornapple and Butrick. I don't know for sure if anyone here tonight lives there. If the tannery were in your back yard, a block from your home, where your children live, where you hope your grandchildren will play, in the City you love, among the businesses you appreciate, would you ask very specific questions? Would you ask them in public? Would you expect answers? Respectfully submitted, Mike McIntosh �To Michael Young, City Manager; Chi Chi Rogers, Mayor; Steve Jazwiec, Mayor Pro Tern; council members Mary Eadie, Rich Moll, Brien Dews; and Jim Scales, Chairman of the Planning Commission, ~ We, as Rockford citizens and/or business owners are very concerned that our city is not adequately prepared to oversee a safe, controlled demolition of the WWW tannery site on North Main St. We are concerned because many important things are not yet in place. We are requesting a special public meeting with the council to be held prior to the permitting process of this demolition. We want to know what Rockford's ordinances are for a safe demolition of a large contaminated industrial site, and we request documentation that the building and all building materials have been certified ~~inert" by an outside independent consultant. Below is a compilation of Best Management Practices that have been collected, to date, through independent research (current July 2010). We hope to hear back promptly, as there is no luxury of time. When the DNRE has done demolition work on state-funded projects, the following surveys are conducted prior to preparing the specifications. • • • • Lead survey (analyze paint samples for lead and evaluate for worker safety and waste characterization) Universal Waste survey (mercury switches, fluorescent bulbs and electrical fixtures containing PCBs) Waste characterization (sampling and analyses of building materials as required to determine the appropriate disposal method) Also, depending upon the proximity of the demolition site to neighboring residences, etc., we request a plan to control dust John Pawloski 616-356-0418 E:1:cerpts from a letter presented to the Rockford City Council on July 12· 2010, from a local resident, who has strong knowledge of the field, reads as follows: "\Ve, as taxpayers in Rockford, want to make sure this demolition is done in the right way, for the: environment and all concerned. A defined Pre-Demolition Plan needs to be implemented prior to any demolition permit being issued. This pre-demolition plan should include the use of an independent consulting firm to monitor all aspects of the demolition process. The independent consultant will also implement a hazardous materials survey prior to any demolition being started. This survey will include sampling and testing of any suspected hazardous materials on site and the proper removal, characterization and disposal of any identified hazardous materials.* These are including, but not limited to, - siding, roofing and flooring materials which may have asbestos - all paints of all colors which may have lead - switches, transformers, capacitors and oils which may have PCBs �Overall, this site needs to be certified "inert" by an outside independent consultant prior to demolition for the protection of all citizens and the environment." * further detailing of hazardous materials needing abatement:- refractory, siding and building materials should be tested for asbestos and chromium; window caulk for asbestos; boilers for asbestos; transistors, capacitors, batteries and mercury switches should be sampled, tested, and, if hazardous, need to be removed by a licensed hazardous materials contractor and properly disposed of. At the professional level and in conversation with various environmental engineers, environmental consultants and/or industrial hygienists, we have been made aware that according to Best Management Practices all the following hazards should be addressed. ( Some of these items may have already been addressed in previous text). 1. 2. 3. 4. 5. 6. 7. Chromium Co11tamioat.ed Building Materials (e.g., concrete flooring) Process Wastes/Containers- misc. containers of raw material/wastes Asbestos- Thermal Insulation Floor Tile Roofing Material Universal Waste- Fluorescent light tubes Batteries (lead acid) Mercury Switches/devices Exit Signs Emergency Lights Chlorofluorocarbons- Refrigeration System Air Conditioners Water Coolers Polychlorinated Biphenyls (PCBs)- Transformers Capacitors Hydraulic Fluids (older systems) Used Oils- Present in mechanical equipment Finally regarding the actual demolition process, we would like to know that all options below have been explored by trained personnel so that the best site-specific Fugitive Dust Plan can be crafted and put into place, well before the 10 day waiting period required by the state once the city has signed a demolition permit. Considering that this contaminated Brownfield tannery site is located "slam-dunk" right in the heart of busy business and residential district, there is no margin for error. �Some Important considerations for Fugitive Dust Plan, not limited to this list: How will airborne contaminates be controlled? Will there be Dust Busters on site (similar to a snow-making machines) If so, how many? Wi11 the buildings be misted? Wet down with hoses? If so, how many hoses will be on site, and how large will these hoses be? How will leeching contaminates be handled? To best control the dust, large amounts of water may be required, but this presents a whole new problem with the Rogue River just a stone's throw away. How then, will the migration of the water be monitored so that contaminates do not leech into soils, the Rogue River, and Rum Creek? How many dust monitoring stations will be required over this lengthy, two-month process? Will they be operating at all times? Who has the authority to shut the operation down if things go wrong? How quickly would a shut-down occur if no one from MIOSHA or OSHA were present on site? If the city manager cannot be reached or is out of town? No one from Rockford Construction is on site or available? In other words, imagine what could happen regarding the spread of fugitive dust if it takes 10, 20, 30, 60 minutes ( or longer) to shut the operation down? It doesn't take much contaminated dust to foul a residents backyard, to land on a Rocky's Ice-cream cone, to contaminate a playground, or the Rogue River, or for an uninformed public to breathe it in while walking around town shopping, mailing letters and doing business as usual. In conclusion: When can we meet with WWW officials and our city council regarding these very pressing concerns? �City of Rockford and CRNA Meeting re: WWW's Tannery Demolition Tuesday, August 3, 2010 6:00 - 7:00 pm @ former Court House Attending: • Michael Young, City Manager of Rockford • Michael Shibler, Superintendent of RPS • Tammy Bergstrom, Planning Commission Member • Rich Moll, City Council Member • Larry Watters, Principle of Parkside Elementary School • CRNA Members: Michael and Lynn McIntosh, Larry Vis, Grace Smith, Sonja Glass, Melissa Leitch, Jack McClennen • AJ Birkbeck, CRNA Environmental Attorney • Bob Newberger, Friend of CRNA, Environmental Engineer Brief key notes and next steps: ✓ Tax Credit: WWW will not be accepting $250k tax (TIF) money from MEDC (Michigan Economic Development Corporation) as both the City and CRNA earlier had hoped. The State made the offer dependent on WWW performing additional testing and/or surveys. ✓ Payment for demolition: Michael Young confirmed WWW will pay for the demolition (contrary to rumors, e.g., that the City is paying for the demolition) ✓ Work Plan: WWW's demolition work plan is in progress. The City is actively working with WWW on its contents: • Michael Young shared the document's table of contents with attendees • AJ Birkbeck commented that it covers the salient topics and looks very promising • Michael Young will put the final plan on the web when complete and contact Mike McIntosh when it is available. He indicated that it will be available for some days for review before he would sign the local demo permit. CRNA and AJ Birkbeck will review this plan and make comm nts, as needed. ✓ Communication: in addition to putting the aiding communication about the demolition as they are final, such as the hazardous wa overall to provide good communication regar monitor results will be available on the web Michael Young declined to publish a compre this would be valuable, so all in Rockford wo when. ✓ The City is hiring Materials Testing Consultants (MTC). The City is working with them on safety recommendations for the demolition work plan and the fugitive dust plan. • Chris Kessner is the city contact at MTC. • At this point, the plan is that ork plan on the web, the City committed to posting other documents on the City's site report. In addition, the City committed ing the demolition. For example, dust ee below). CRNA welcomes this. nsive communication plan. CRNA thinks Id know what communication to expect �structures will be wetted down with fire hoses three air monitoring stations will be put around the site. Daily results from these stations will be posted publicly on the city's website, 24 hours after the readings are taken The demolition work plan will explain what will be monitored o o • ✓ Pitsch Companies will be handling the demolition. Gene Gudding is the city's contact at Pitsch. ✓ Additional concerns voiced: • There are no clear State or local (Rockford) demolition ordinances • Chrome tanning at WWW's site • Hexavalent chromium because of the extensive chrome tanning done at this site. • Use of Trichloroethane (TCE) to de-grease hides • Disturbing soil that may be contaminated (WWW will dig down to a depth of 18 inches, which may disturb soil) • Negative publicity or media attention for Rockford ✓ Overall attendees seemed to think the meeting productive. Once the work plan is complete, CRNA's next step is to carefully review this work plan Respectfully Submitted, Mike McIntosh President, Central Rockford Neighborhood Association �Concerned Citizens for Responsible Redevelopment (CCRR) Questions on Pitsch Demo Work Plan for Wolverine Worldwide (WWW) 8131/10 Key Red is CCRR's understanding of City' s answer to the question (from email and Th 8/25 meeting with City Manager) Green is CCRR's additional questions or comments on the original questic ( composed 8/30-8/31) Who? Green-shaded questions ( at the top of this document) are questions to which CCRR has not received a satisfactory answer. Answers from WWW attomc\ m:> WP Sect Satis? Or Unsatis? Ong .# Paoe WWW U 2 Gen WWW U 4 1 1.3 WWW U 5 1 1.3 WWW U 9 5 2.5 Question Halting the Demo: Under what specific circumstances will the demolition be halted and does the City have the authority tc halt the demolition? p rt Iave '"ht right to stop demolition at any time. This will be written in the permit issued by the city. • The city's draft permit states the Oty can halt the demo specifically for weather-related issues {wind, precipitation). In the first paragraph of the draft demo work permit does state, "Deviation from the permit application or permit conditions could result in a stop work order being issued by the City of Rockford, at ,ts discretion." • Does WWW agree the City can halt the demo for any reasonable circumstance for the protection of human health a, the environment? • City car halt ~or an, ·easonable pu, • Jear in . "'r 1it Hazard Recognition: why is this list (asbestos, heavy metals in paint, mercury, PCBs) so short, given the tannery site's history, the fact that cadmium and chromium are identified elsewhere in the report (other than on "certain surfaces" of buildings), and the fact that we know additional chemicals (e.g., TCE) were used at the Facility? Further, what are the base for including the chemicals that have been identified as a hazard, while excluding others? Th 'St de nents e ouna .. o ~~en '\ ,e pre-de nohnon testing that was conducta. on the site. They are the only elements that they are required to test for. • Even if WWW may not be "required" to test for hazardous substances and hazardous wastes ahead of time, there should be a recognition that they might exist (given the site history) and greater attention paid in the Work Plan as how they might be idenbfied and as to how they might be addressed to protect human health and the environment. • Who is qualified? Gutting is former environmental consultant. How much there? Someone there all the time will have experience in recognition hazardous materials and call in Gutting if he's not there--don't want to move it around, affect workers or ne1qhbors. [can't demand much more· can't d'.luire more from them.l Hazard Recognition: since the work plan indicates that no soils will be removed from the site, what happens if soil is contaminated by the demolition activity or if contaminated soils are discovered and disturbed during the demolition process? An o :entially 'lr • rn, a.ed so, ill ")e tested and d " ~ c, a ordmg to ·e ~ rari ·eJul;:a ns. • How will such soil be identified? • Who will test the soil? • How will it be tested, what will it be tested for? • Will demolition be halted If it the soil is found to be contaminated? • What about groundwater contaminated with hazardous substances or wastes, will the same procedures be followed· • If we ID contaminated soils, will dispose per DNRE -egs Removal and Disposal of Hazardous Chemicals: is anyone from Pitsch qualified to identify a hazardous material when is discovered-how will such hazards be brought to that person's attention? Mr •ttinr is a prore.sional eng ",,. 1s traine to 1 01 nsible for hazardous chemical recognition • Pitsch is a demolition company, not an environmental consulting company. Who will be on site as an environmental engineer fully qualified to identify hazardous substances and wastes in the field? 201 0083l_CCRR Questions_Final to WWW Attorney with WWW reply Page I of6 Last Printed6/17/20ll 2:45:57 PM �Concerned Citizens for Responsible Redevelopment (CCRR) Questions on Pitsch Demo Work Plan/or Wolverine Worldwide (WWW) 8/31/ 10 Key Red is CCRR's understanding of City' s answer to the question (from email and Th. 8/25 meeting mth City Manager) Green is CCRR' s additional questions or comments on the original questic (composed 8/30-8/31) Green-shaded questions (at the top of this docwnent) are questions to which CCRR has not received a satisfactory answer. 1\m,--wers from WWW attomev Who? Satis? Or Unsatis? Orig .# WP Paqe Question WP Sect Mr. Gutting is the Project Manager and, as such, it does not sound like he will be on site. Who will be on site to identify contaminants and for what duration? • What are Mr. Martin's qualifications as field supervisor, with respect to hazardous substance and waste identificatio and will he be on site during all work' • City will be notified. I Removal and Disposal of Hazardous Chemicals: if Pitsch finds a hazardous material, the City should also be notified. Please comment. 0 n , for WWW and will report only to them. WWW will report any such findings to the City at that time. • In what document does WWW state when and how they will notify the Qty? • Will such notice be immediate? Wrthin 24 hours' • ves, WNW will not"' +i,e Oty Air monitoring: the cassettes will be analyzed for "lead, cadmium, and chromium (trivalent and hexavalent)," why are th~ the only airborne contaminants chosen to be analyzed? Th~ ait. I e elements 01 nJ " 2sent in the ~1~ ..._,.,olition testing. • The contaminants tested should be representative of those hazardous substances, materials and wastes at the Site that are likely to be disturbed by the demolition activities. It is irrelevant that testing for such constituents 1s "not required" or that a lack of prior testing allows WWW to say that they are "unaware" of additional contamination. U of the facility as a tannery has involved a number of hazardous substances and wastes. Testing should be for all su constituents that are IIkely to become airborne as a result of the demolition activities. • If the substances being tested for were 1dent1fied via a simple wipe test, might not there be additional contaminants in the cement, structure and soils, that will be disturbed by the demolition activities' If so, they should be tested as well. • Monitoring for what they have seen on the site. [dust is primary concern-visual indicator of a problem. VOC.S won be seen (solvents). Solvents not so much a worry unless there is dry air with solvents ma pool. AJ less concerned about dust and :✓hat it may carry • Hexavalent chromium could be in air. i Air monitoring: the cassettes will be analyzed for "lead, cadmium, and chromium (trivalent and hexavalent)": Since we know that volatile organic compounds were used at the site, VOC.S should be monitored as well. This question has not vet been addresser Air monitoring: how much time will be required to analyze compare the cartridges, since the work plan indicates only tha1 results will be posted on site "within 24 hours after receiving the analytical result and compared to the applicable OSHA limits?" If that process takes 6 days, no results will be posted for 7 days. That process should be compressed and expedite such that the posting of results occurs no later than 5 pm on the day following sample collection. Any further delay renders already delayed (by 24 hours) results useless. If that is the case, real time monitoring should be implemented. Anything more than a 24-hour delay is too long. It is u1derc:ron l cnat e ..est ., ill be done the day of the demolition and results will be returned to the city by the end of business the following r1av Mr. Young was going to check if there were any guidelines in place relevant tn the ITlaXimum • WWW U 10 5 2.5 WWW U 12 6 2.7 WWW U 13 6 2.7 WWW U 14 6 2.7 20I00831_CCRR Questions_Final to WWW Attorney with WWW reply Page 2 of6 Last Printed6/ I7/201 I 2:45:57 PM �Conceme4 Citizens for Responsible Redevelopment (CCRR) Questions on Pitsch Demo Work Plan for Wolverine Worldwide (WWJJ? 8/31/10 Key Red is CCRR's understanding of City's answer to the question (from email and Th. 8/25 meeting with City Manager) Green is CCRR's additional questions or comments on the original questic (composed 8/30-8/31) Green-shaded questions (at the top ofthis document) are questions to which CCRR has not received a satisfactory answer. f\nswcrs from WWW attorney IMlo7 WWW Salis?Or Orig vW' vW' UIISiltis7 .# 1w1e Sect u 24 Quesaon In what document does WWW state when and how they will notify the City as to the materials identified and removed? • Not addressed yet [the manifest attests to what the waste is that someone Is coming to pick up-- person signing takes on leaal resoonsibilitv. Evervthino that is leavinq 1s leavma ,,.,hich 1s qood news.l New Question: from 8/26 Rockford Squire article, p. 15, "Much of the building material that is being demolished will remai on site and pushed into the basements of the three buildings that have basernents....The foundations will be broken up to allow drainage before being filled in." • Will d11S be buildin~ -nater aj that has be certified as "not impacted" after testing same? • If WWW is intending to dispose of even a minute quantity of hazardous substances or hazardous Gen wastes In basements, either In the form of Impacted demolition debris or excavated and Impacted son and groundwater, does WWW intend to obtain a permit as a hazardous waste disposal facility? • WWW u 25 Gen WWW 7 4 2.0 WWW s s 8 4 2.3 WWW s 11 6 2.6 WWW s 16 6 2.7 Breaking up the foundations and floors will m essence remove the existing "cap" on the site. Has WWW studied the potential impact of such removal? • Will absolutely not be dumping into the basements. Will fill basements with same fill-sand with thin layer of soil. • They wi//break up foundations, but will notbreak up the floor. So water can flow sideways but not througti the floe i [don't want the basement to be a swimmng pooll New Question: what, if any, qualified third-party expert will be to supervise Pitsch's work from an environmental perspective? How frequently will such person(s) be on site? • P1tscn ,s a demolition compan , not a en ronmenta consulting company. 40 hour training is not adequate for the identification of hazardous substances or hazardous wastes. This should be a Oty question. Both City and Pitsch seem to agree to have MTC (who is a OH) and others there at • critical ooints (':anner\ ~um CreP ., r) Work Tasks: what does item (g) refer to: Removal/disposal of " Universal/Regulated Waste," since these terms are undefinec Universal waste is qualified for any landfill, Regulated waste must be transferred to a class 2 landfill. Asbestos Abatement: "Results of the monitoring will be posted in a conspicuous location the next day." Will it be posted for the public to see, along with other monitoring? No. the results are posted for the wort<:ers and the city material testing consultant to review. Mr. Young has stated that he would make those results available to us daily and supply the PELs (permissible exposure limit: compare to. Demolition of Buildings: What happens if runoff from fire hoses exceeds capacity of ground to absorb the water? There is n mention of berms or other containment measures. These items are covered in section 3.3 - 3.4 Air monitoring: will there be a schedule of what buildings are taken down on what dates, so that if people choose to dose their windows, they will know what to expect? A preliminary schedule is available but, will be subJect to change. May need to explore another way to keep informed about the current schedule (perhaps the blog or via email) • Why won't WWW publish the demolition schedule on their site? I 2010083l_CCRR Questions_Final to WWW Attorney with WWW reply Page 4 of6 Last .Printed6/l7/2011 2:45:57 PM �Concemed Citizens for Responsible Redevelopment (CCRR) Questions on Pitsch Demo Work Plan for Wolverine Worldwide (WW1fJ 8/31/10 Key Roo is CCRR's understanding of City's answer to the question (from email and Th 8/25 meeting with City Manager) Green is CCRR' s additional questions or comments on the original questic (composed 8/30-8/31) Green-shaded questions (at the top of this document) are questions to which CCRR has not received a satisfactory answer. Answers from WWW allorncv Who? l l I "satis?~r Orig WP _ Unsatis? _ .# _ Page Question WP Sect • WWW s 17 7 City u 1 Gen City u 3 1 1.2 City u 6 4 2.0 City u 19 7 3.1 2.8 Why does WWW have no public relations liaison to address this need for communication with potentially impacted neighbors and other members of the interested public? • 8/31-CCRR notes that the City has provided CCRR the current demo schedule Removal of Concrete: will one foot of fill be placed over the site at this time or will the "six feet'' of cover, previously discussed, be brought in at this time? One foot of fill will be placed over the existing grade. In the area of the new retail store, additional fill will be brought in as needed (which would be the 6' of fill previously discussed). • Will one foot of cover, over potentially contaminated fill and environmental media, be sufficiently protective of huma health by those who use the site (e.g., customers and employees of the new shoe store)? • Will an additional 5 feet of fill be added before the public has access to the site? • Who decides what amount of fill is "needed''? Please define the training of and the role the City's consultants, Materials Testing Consultants (MTC), will perform, how muc time it will spend on the site each day, how many days will the person be on site each week, what tests this person will perform, etc. If tests will be performed, what will be tested for? ~ 'Tl-"lr resr.c'lsi lit) 'ill LP t~ Ja Iv ar.al,ze nP ald a llec .el., rrom the air monitors. Will also be on site at key time dunng the demolition. If potential contamination is found, Pitsch will notify WWW, WWW will notify Oty of Rockford and appropriat testing will be performed. • In what document does WWW state when and how they will notify the city? • Who is paying for the MTC worker? • Is tti1:, pe~r a Certr1ed I.,duso al H gic IS1 (C t1 ? Pre-demolition Engineering As'Sessment: has the Oty received copy of Pitsch's Pre-demolition Engineering Assessment, or is the entire "assessment" the mere 10 sentences which comprises Section 1.2? If a separate report, which has not been received, when is it expected? f.Je hav1;. since e, e, ~:i 1emolition survey and it is being reviewed. • Note: the City has not yet provided a copy to CCRR • With demolition scheduled in the next day or two, it seems rather late for the City to finally be receiving copy of this critical assessment. • Will the City's MTC consultant walk the site and buildinqs to review whether the Assessment/Survey is accurate? • The C l.P eques ~ cop C tt ~ ;r [ Work Tasks: has the Qty received copy of Pitsch's item (a) Pre-demolition Survey Report? • ~,i." demo! tior scheoule m he '11;,, d"' o WI..,, se- 11 !) ra , c 1 o th Cit)i t~ finally be receiving copy of this critical assessment. • Will the City's MTC consultant walk the site and buildings to review whether the Survey 1s accurate? • nie CCRR req1.1ests · oo · of this ,-,c;ses_ ri Waste Loading: "In the event of liquid spills ...," sand is too porous to prevent the spread-why will Pitsch not also use plastic sheeting over the sand? 20100831 _CCRR Questions_Final to WWW Attorney with WWW reply Page S of6 Last Printed6/ l 7fl011 2:45:57 PM �Concerned atbens for Responsible Redevelopment (CCRR) Questions on Pitsch Demo Work Pl,an f or Wolverine Worldwide (WWW) 8/31/10 Key Red is CCRR's understanding of City' s answer to the question (from email and Th. 8/25 meeting with City Manager) Gre1.'Tl is CCRR' s additional questions or comments on the original questic (composed 8/30-&'31) Green-shaded questions (at the top of this document) are questions to which CCRR has not received a satisfactory answer. Answ1.TS from WWW attorne\ Who? I I I Satis?_Or Orig WP . Unsatis? _ .# _ Page WP Question Sect City u 21 8 3.3 City s 15 6 2. 7 Mr. Young noted thrs item and will have it included m the won,. plan. • There are no conditions in the draft of the demo permit at this point. • Is this specified in the City's Soil Erosion and Sechment Control Ordinance, mentioned in the draft of the demolition permit Staging of Impacted Concrete: what will be done with the concrete-where will it be taken? How long will it remain in the staging area? Will EPA's 90 day holding period be exceeded? If so, is the site permitted as a hazardous waste storage c disposal facility? Imractea concrete will remain on-site for a minimal amount of time. The site is not approved as a hazardous waste storage site. • What is a "minimal amount of time''7 • In addition to cove ho• \ ill the rasl.e monitored an~ secured? Air monitoring: how will the public be notified of the test results? Mr. Young will initially email the results out to CCRR. Method of delivery can change if needed (e.g., Results available at the city during phases that are less likely to be of concern - warehouse for example) • Note: the CCRR remains concerned regarding the timeliness of sampling data • Has the City's consultant opined as to whether the number of air sampling points and the constituents being sample are sufficiently protective of human health and the environment? 20100831_CCRR Questions_Final to WWW Attorney with WWW reply Page 6 of6 Last Printed6/17/2011 2:45:57 PM �CL ·rL- R.. ."· .~,t t~\ ., )'J �VVOLVERINE• Wwt#wtlwni- DWI. . Spring 2010 Update Rockford Tannery Site A Responsible Approach to Redevelopment Following Wolverine World Wide's 2009 decision to close our Rockford, Michigan-based tanning facility, the Company has been engaged in exploring future options for the centrally located, 15-acre site. ·This process, which has continued to involve discussions with the City of Rockford and area officials, is intended to fulfill Wolverine's stated intent to "do something special for the community and the City of Rockford on this unique waterfront property in the heart of downtown~ The Company's current plans call for a patient, flexible and responsible approach to redeveloping the former tannery site. Our approach is guided by two important objectives: o Preserving and enhancing the overall economic vitality of the City of Rockford both regionally and nationally. As a result, there are currently fewer potential partners with the resources for implementing a broad, near-term plan for the site. On a related note, the economic downturn has been hard on existing Rockford businesses. Any new development activity must be considered in light of current and projected consumer demand. While these challenges do not preclude our working with interested partners to pursue a comprehensive redevelopment plan, Wolverine believes it is in the best interests of both the community and the Company to focus on smaller-scale initiatives in the near term that can help lay the groundwork for additional development activity in the future. o Ensuring that any future development of the site is sustainable over the long term Pursuing sustainable development means taking into account the challenges posed by today's economy. The downturn has taken a heavy toll on real estate investment and development activity, Wolverine Is currently In the process of working with City and state offlclals to move ahead with two specific projects: 1. Constructing a new Wolverine retail store at the south end of the vacant property. Our enhanced retail presence would replace the Company's Rockford Footwear Depot at 235 N. Main Street and provide an added "dlJlw"~fo · the portlon-of...R.o..ddord's downtown <:9m~I district that1Is adjacent to the south end of the former tannery 1site. Wolverine Is In the process of fifing the necessary !applications for our planned retail store. - 2. Clearing lhe site of the former tannery and other related structures and creating a green space setting. We are currently looking Into steps to allow public use -oh portion ofjl]e site. The new green space would be designed to preserve the site's vlablllty for potential Mure development while providing an attractive near· term amenity for the Rockf,,ord area. I company store • ~ n main street - -:=- �\NOLVERINE® Wf#Vf#VwoRLD WID■ Spring 2010 Update Rockford Tannery Site A Responsible Approach to Redevelopment Q&A What specific plans does Wolverine have for the tannery site, looking further into the future? Any future development wollld need to take into account the overall economic environment and support our two primary objectives for the site. These include: preserving Rockford's overall economic vitality and ensuring that any new development is sustainable over the long term. In general, we would expect any future development to be consistent with the City's master plan, which calls for mixeduse development - a potential combination of commercial and residential space. When do you expect additional development to occur on the former tannery site? We can't make that prediction, given the continued uncertainty around how long a regional economic recovery might take. Does Wolverine have plans to sell the tannery site? Wolverine plans to retain ownership of the property. How can the community provide input into the site planning and development process? Area residen~s are welcome to participate via the usual channels, such as publ!c hearings, that are typically available as part of the redevelopment process. When will you provide further details about the progress of your proposed near-term initiatives? Wolverine will continue to share information at appropriate stages in the process. How long will it take to build the new retail store? What will happen to the Rockford Fc,otwear Depot while construction is taking place? Our initia.l, prcposed timeline calls for completing construction of the new store by spring 2011. We expect the Rockford Footwear Depot will continue ~o operate during this time. Eventually, our retail focus will shift to the new store, and the existing facility would be cleared as part of our green space development plan. Will the transition to a new store mean any job losses or gains? We haven't finalized a staffing plan for the new location, but we do not expect any substantial net loss or gain as a result of our proposed move. What will the size of the new store be, compared to the existing location? While the new store will be somewhat smaller that the current facility, an improved layout will allow us to carry the same product variety as the existing store. The new store will feature an improved design and a more exciting retail space. Who will own and operate the new green space? Wolverine will retain ownership of the entire property. We plan to discuss issues related to the eventual operation and maintenance of the green space with the City of Rockford, as part of the overall development process. What kinds of amenities will the green space offer? What will the hours be? Will it be open only to Rockford residents? We haven't worked through these kinds of details yet The green space initiative is currently in an early-stage, conceptual phase. Are you planning to include something to commemorate the important role the tannery played in Rockford's history? The tannery was an important part of our Company and our community for more than 100 years. We deeply respect that legacy and the many people who helped build it We are incorporating some of that legacy into our new store plans while balancing it with a modern, forward-looking retail experience. �9341 Courtland Drive N.E. Rockford, MI 49351 USA tel: 616 866-7315 fax: 616 866-5625 e-mail: gradyke@wwwinc.com E Vt KENNETH A. GRADY General Counsel and Secretary I ' 1 .( ';Jhcr t August 20, 20 I 0 Mr. Michael F. Young City Manager City of Rockford 7 South Monroe Street Post Office Box 561 Rockford, Michigan 49341-0561 ,>. . -'I ; . t ..· , i ' ' Dear Mr. Young: ... The City has asked Wolverine World Wide, Inc. whether it could provide any information regarding the presence of chromium in the building owned by Wolverine in the City of Rockford -l .,~-and formerly used as a tannery. While the tannery was in operation Wolverine, from time-tot .. : time, would have industrial hygiene testing done for certain substances, including chromium. As _,, , . I you know, the tannery operated for many years. olverine has not searched all of its records ,✓ relating to the tannery to attempt to locate all industnaf'nygiene·tesfi-'e"s"ufts-iliat may or may ~ot L- 1,, ,f ·- ,, exist. However, we did fiii.d.1ifdlfSfrial hygtene-report results for four-different years (1998, • I J'" 2002, 2004, 2007). . •. -· . . . ..•.• 1 _,~ l Yf • .' ,J.; \, • - . I' '. ' i -. • i\ i .' ! . • ;. S • ,. ·-------~ ___________ .,,_. 'these tests were run for several parameters, including chromium and particulate matter. In all . : cases, the results are below OSHA criteria (Permissible Exposure Limits and Threshold Limit Values) and nearly all the results are either non-detect or far below the criteria. These test results were obtained during periods when active production was taking place at the tannery and process materials were being handled and managed. Production has ceased and materials have been removed from the tannery, so the current air concentrations for these constituents in the tannery are very likely much lower than shown by these data (which even then show very low levels). By sharing this information, Wolverine is not waiving any rights with respect to the reports, including confidentiality and privilege. As you know, when chromium is included in the leather tanning process, it is in the form of trivalent chromium. This is a well-established fact which is reflected in both federal and state environmental laws where leather tanning wastes are given special exemptions because trivalent chromium, rather than hexavalent chromium, is the form of chromium in the process. Hexavalent chromium is typically used in the electroplating and metal finishing industries, neither of which took place at our tannery. We thought this information would be useful to the City. • I I ..,.f-··, (00022957.00C } j • • - r i V?f !.{ ,, . -~ • i • ;- : :.- _\ ... _/ . / ,;. :· ; ~. ; 'a" .. f'· .. J ~ .... �Mr. Michael F. Young August 20, 2010 Page2 Wolverine also plans to cover portions of the demolition area with soil brought in from offsite for general site restoration. The depths of this soil cover will vary depending on the topography of the site and the need to taper down at the creek and near the river. While the use of soil cover is often a component of a due care plan under Michigan's cleanup law, there is no reason to believe, at this point in time, that there is any soil contamination on-site that would need to be addressed by a due care plan or soil cover. Sincerely, Kenneth A. Grady {00022957.DOC } �9341 Courtland Drive N.E. Rockford, MI 49351 USA tel: 616 866-7315 fax: 616 866-5625 e-mail: gradyke®wwwinc.com KENNETH A. GR.ADY General Coum;eJ and Secret,uy September 21, 2010 Ms. Georgia Donovan The Izaak Walton League Conservation Center 5641 Myers Lake Ave. Belmont, MI 49306 Dear Ms. Donovan: Mr. Krueger asked that I respond to your letter to him regarding Wolverine World Wide, Inc. 's site in downtown Rockford, Michigan. As you note in your letter, Mr. Krueger is a lifetime supporter of Trout Unlimited, and a lifelong fly fisherman. Both he and our Company have been very involved in maintaining and improving the Rogue River watershed. To that end, the Company has made a significant contribution to Trout Unlimited and the Home Rivers project to help fund maintenance and improvement activities for the Rogue River. You have asked about the steps Wolverine World Wide has taken to be environmentally responsible during the initial phase of the site redevelopment process. While those steps are extensive and too many to cover in this letter, I thought I would summarize a few to give you some background on what is being done. hrst, let me note that during opt:rations of the forrner tarrnery, Wolverine maintained a high levei of environmental stewardship, and is not aware of any environmental issues related to the site. In fact, over many years of continual operating, testing and permitting, no significant contamination issues were found. It is well documented that we spent millions of dollars over the years to avoid any environmental issues and to maintain the quality of the Rogue River. Second;we believe it.is n~teworthy thaLboth-the Rogue River and RumCreek, which runs directly under the former tanfiery site, are healthy water systems and have shown no signs of any negative: environmental inipactrelated to the tannery's operations. With respect to the current site redevelopment work, Wolverine World Wide selected Pitsch Companies, based in Grand Rapids, as the contractor who is handling the demolition, {00023080.00CX 2 } �Ms. Georgia Donovan September 21, 2010 Page 2 environmental testing and monitoring work. A copy of their detailed Work Plan is accessible from the City of Rockford website. All required preparations were taken and the necessary permits and approvals were granted prior to the start of any work on the site. These included pre-demolition testing for substances including asbestos-containing materials (ACM) and lead-based paints and filing all notices required under state and federal law. Various remediation steps, such as removal of ACM, were conducted prior to demolition starting. The Michigan Department of Natural Resources and the Environment (MDNRE) conducted an on-site visit prior to any work beginning and the City of Rockford issued a demolition permit. MDNRE and other state and iocal agencies have conducted on-site visits frequently since the site clearing process began and have consistently stated to Wolverine World Wide or its contractors that the on-site precautions meet or exceed the applicable requirements. The primary objective at the site during the clearing process is to safely and properly dispose of the buildings, structures, universal wastes, and non-hazardous wastes from the premises and restore the site to grade. As a precaution, any dust from the clearing activities will be suppressed with water. Air monitoring of the site will be conducted continuously throughout the demolition process. Pitsch has established three monitoring stations on the site that are being used to collect and analyze air samples every 15 minutes. Additionally, representative air samples will be collected from locations where employees are working on the site and analyzed following the same procedures. These samples will be tested for lead, cadmium, chromium and asbestos. Results of the air monitoring will be posted on the site within 24 hours of receiving the analytical results, and will be compared to the applicable OSHA limits. While there are no known hazardous chemicals located on the premises, the Work Plan specifies that if Pitsch encounters any hazardous materials, work will be stopped immediately, notification will be made, and the proper procedures will be followed to analyze, test and handle the materials in accordance with all applicable environmental laws. The City of Rockford has also retained an independent environmental consultant. The City and this consultant have full access to all of the testing results promptly after they have been received from the lab, and the results are being provided to the consultant and the City by Wolverine. {00023080.DOCX 2 l �Ms. Georgia Donovan September 21, 20 l 0 Page 3 Thank you for your interest in this project. As I am sure you know, following site clearing, views of Rogue River and Rum Creek will be open to those visiting downtown Rockford for the first time in approximately 100 years. Reconnecting the community with these wonderful waterways in our hometown is an important (and not inexpensive) goal of this project. We look forward to seeing that happen, and are proceeding in a responsible manner to achieve that goal. {00023080.DOCX 2 l �;·11 ROCKFORD ~ (~ ~"'f..ffl CONST~UCTION ;r:,.~ TANNERY SITE REDEVELOPMENT RUM CREEK WORK PLAN As part of the redevelopment of the current Wolverine World Wide (WWW) tannery site all existing buildings are scheduled for demolition. This includes part of the existing tannery which is currently built over Rum Creek. Rockford Construction (RCCI} is serving as the Construction Manager for WWW for this work. RCCI representatives did meet with the MDNRE Water Quality division on 1/19/09 for a standard pre-application meeting. MDNRE response letter in this regard is attached. Our intended plan of work in the area above and immediately adjacent to Rum Creek is as follows: 1. No work will occur below the ordinary high water mark of the stream. 2. Existing stream banks will not be disturbed. 3. Existing bridge over Rum Creek will remain in place to facilitate movement on the site. 4. All vertical construction including the existing cover slabs over the creek will be removed. o Sequence as follows • All vertical demolition above and immediately adjacent to Rum Creek will be completed before cover slabs are removed. This will proceed as follows: • Vertical structures adjacent to the Creek will be removed by hydraulic excavator and loader. Demolition will start on the perimeter of the south side of the facility working towards the creek. The north side will be cut free from the existing retail building by hand before machine demolition proceeds in this area. o The overall intent is to remove as much structure as possible on either side of the creek to facilitate being able to remove the structure above and immediately adjacent to the creek as carefully as possible. • Building structure on the outer east and west edges of the creek cover slab will be removed as follows: o West side - the appx. 1- 2 'gap elevation difference between the cover slabs will be temporarily closed in such a manner as to not allow any loose debris to fall into the gap. Building wall in this area will be removed in as large pieces as possible by excavator. Any debris will fall onto either the bridge or the cover slab and be removed by excavator. o East side - Prior to demo. in this area a temporary cover consisting of planking and plywood will be established across the creek immediately adjacent (east side) of the building. This will serve to capture any loose debris. Building wall will be removed by hand. • Debris that falls onto the cover slabs will be removed by hydraulic excavator. • • Heavy equipment will not be allowed on the creek cover slabs. Trucks will be loaded either by loader or excavator min. 40' away from the creek �ROCKFORD CON!:=;T;::JUCTION • 5. Once vertical demolition is complete then the cover slabs over the creek will be removed in a controlled fashion using a hydraulic excavator. The cover slabs will be removed in large pieces appx. 6' wide and spanning the entire stream. • During demolition all precautions will be taken in an effort to ensure no debris falls into the creek. • As an emergency precaution during demolition Pitsch will have personnel and equipment (booms/nets/etc ... ) on hand stationed immediately downstream of the bridge over the creek. Positive drainage of surface water away from Rum Creek and associated storm water controls wiil be maintained during all phases of construction. Attachments: • MDNRE pre-application response letter dated 2/16/10 • Aerial showing the area in question • Pictures/narrative of existing conditions under the tannery and on the east/west side. ��LLRW AUTHORITY Fax:517-373-0578 Dec 13 National Response 99 9:31 10 P.01 Urgent Center Incident Report Date /J.am er I J, 1999 INumber ofpageJ includint cover Jheet FROM: - C :n Phone Thor Strong DEQ: Low-Level Raduxu;m,e ~61':~5'~0 · ~8-erBRapids Quality Dtvision • D : :~~ Davwr 0202 · - - -6J(,IJ56-lJ201 ~ - -& ---- 3 Wosu1 A.uthCll'ity Plione l PaxPhonl -.-...: .. ,;. .. ·, '• 335-0430 373-0578 ·-·& For the immediate attention of a staff person in the appropriate division. �::, I~ 1 t: UI- Ml\.;HIGAN DEPARTMENT OF NATURAL RESOURCE~ REPORT OF OIL, SALT OR POLLUTING'MATERIAL-'.\LOSSES Pursuant co !he provisions of Act 245 of the Public Acts of Michigan 1929 as ame~ded. regulations have bi:en issued - which require that all owners. managers or operators of vessels, oil storage or o.n land facilities shall notify tM Water ~ :esources Commission or his authorized representative of oil, salt and polluting material los_ses. This not1ficat1on c.hall b,, ,1ade promptly by telepho:ie or telegraph, giving briefly the particulars. and by mail. giving, a detailed accour,t ul events and conditions. Cotn;nny D,11.: N~me WoLvt::-12., ~ E ~ Loc~oon or Lou 1~ Wo~L:o Lu l O"E tcilicl 0tL I() TD 2.o 6 .... ~,.;.S Timt1 ol o,~eo~ry £?:30A.M 8 --- Torcprion-,.c:I or Tel~raphC'd by Whom C. \-hzR. L- 0\..\ ,r~R. c~u•~ QI Loss ((n.::1vc1e Typ" of Equiprnnn, :ono 0,1,~, Det::iil•I \ LI Fr L6AKED 1 "-.)YO ;.._~_ : , ~D At-lO \+AS ~cA'lS. L, FT N:tlur,; of tos:., (fochJt18 Sce"1 15 Gl.~Eo P-eLA·nveL'f Poe_ ~\J\O\l,~6 5Ho~ 1~-rD s , ' .• . i _:.~ ~ :-- l : F.e.eG- L,f\ri-t- No Kt,.:)0<...,J'µ o, L HvE s·rve-e_- .A~~ .o ~ o, L .S 'i s.-e_~; CO-,nFIC-lt Oc::cnpt,,:n ot O.a.m.sgc:) t:.~,6 Q..l::£) --- '17-\-e Rvl,A C.C-tt::X FL.-cx.u-c;o w \JE66rA'not_j 1\/Y\H,n--e-"-l.t..,-JL-G :·_:~ -6~00:~:0u..,,::n·-ee. S...:M-p a~ .S't--,e.vc:..-nA.R..,\L, ~.s r 1 ~ TD DAWVc6o FP-o~ A ·,2:.-~~e,H OIA\v\G~ :n-tG ~6Ue R1..ue~,, .=Lu-H-tes o,·L ~oreo. l±Yo~c\-G~:·o,c.. s~ S itEe,..i FL.o.A.reD Al:::}.0 J'OOiuo,n~I Commcnrs ffncl~ae Me:l'loc! N C01111·or. Pl 1n• lot PrcventiQr> or Flecur,-ence. ~tc:.J \AffiS r,12.6 CoLL6C..T'W ~ PoL\C,e, By "D6PT5. Co,s\"A1·~ /Ae:soe..n F~.·v\.. Cwy ~'t-ofZ l'V\ l:~c,R.\"-lO O;L Boot--A.S WoWo'a.\NO woeil.co 01,L• $E:i..,J~~ ALL '• u£S'iP---GAM oF D.~i/V\ t?lA=L&O (»l'nt C,·r:r eoc-~fo/2.-0_ r.t:U:'b' S,vt..~ Sewc.e ,CJ· Pit'6£. FP-l>~\A H:Y,O(;Ar...,,L-~£. 0l:(.St'GM D1SC.o~~&:..-eo f\ (I.) 1-tl)L.C -.s l.2 e LBA~· l..vf\S T\M:~~- ,-.> ~-~L,q, (!>-1 K'i D, Woe..L-D W \ 06 Return this form to: TI> 81 fy c:L "~ -. Surface Water- Quality Division . ::_~Michigan Department of Natural Reso:urces 350 Ottawa N.U . Grand Rapids, MI 49503 8nergcncy Not1fication • Number 1-800-292-4706 (616) 456-5071 R.&r.11\ (;.:~ 1' ,'l �R E (J t~,:::: ·-: ·.',f \E: fet 1 -~ MICHIGAN DEPARTMENT OF ENVIRONMENTAL QUALITY l~A.~TE MANAGEMENT DIVIS!OIV GRAND RAPIDS 11 SPILL OR RELEASE REPORT ~OTE: Some regulations require a specific form to use and procedures to follow when reporting a spill or release. Those forms and procedures MUST be used and followed if reporting under that authority. The purpose of this "Spill or Release Report" is to aid persons reporting releases under the various regulations that do not require a specific form. This report is not required to be used. To report a spill, you may telephone the PEAS Hotline, or DEQ District Office which oversees the county where the spill occurred, and other regulating agencies and provide the following information. Keep a copy of this report as documentation that the spill was reported. If you prefer to submit this report electronically by FAX or e-mail, contact the regulating agency for the correct telephone number or e-mail address. Submission of an additional written follow-up report may be required. See the DEO document, Spill Reporting Requirements, a'nd the specific regulations or contact the regulating DEQ division for more information, Please print or type all information. TELEPHONE NUMBER (provide area code) NAME OF PERSON REPORTING SPILL ( "'H£R'-' L () l \ \l E:<2- (~!&;\ '8b3 --3'1'"1 l SPILL LOCATION (provide address If diffenml lhan bui:Jness. If known, and give directions to the spill ~ocation. Include nearest highway, town, road lntarsectlon, etc.) NANE OF BUSIIIESS Wr.Lv02 , t,j& >oi?-L✓'.'O ( .I l u.ne .......S.:rne.t'.Y.l .... s:cu.i.Z:IZ.. ..... Lauu:e.o. ......?..Y..~D::':.... O_f_ STREETADDRESS '2 ?::, ..Z.i3.S..... ll.~T.H........~..~.~----S... ~ ..,...................___ 12 ~C ·······:···9.~.!~..f.i"?..!:.:f: .... ,t, .. \\:'.'\.~.'-,:H .. \..~.~~-·-··'. ...~.Y..i'Y.\....... ~£\( f\'¼~t~ STJ2.,££"·1 ~12..n-t STATE I CITY 'Koc.✓\L.Fo12-o l'v\ \ BUSINESS TELE!'HONE NUMBER (provide area code) I~q35 ZIP CODE I ( b.lG::,) 8b 3 -3CJ'l l Lv-cs, Of l'VY-\,N COUNTY EPA IDENTIFICATION NUMBER (If appllcable) st-e£G,. TOWNSHIP I .!\ Kt:NT TIER/RANGE/SECTION (If known) _:j,{: I C'f t-..i i lit .., I 1-o,V\A c:.. .-~,:) RELEASE DATA. Complete a'I applicable categories. Check all the boxes that apply to the release. Provide the best available information regarding the release and its impacts. Attach additional pages if necessary. DATE I, TIME C•F RELEASE (If known) _, ,z DURATION OF RELEASE (If known) DATE I. TIME OF DISCOVERY e '- 'i'I IZJ /b'1£f 1 am.€!,) a l'll I" y_i: ti>? z. C .. arr-€5 itJ <,) ; l., i:::eo'"" RECEIVED-- ..... ....................................................................................................... ·n· r:- "I" ..."··,,..--- ~- -~ .............................._ .... ....... •·· . ... . .... ,., ... .., Iv FACTORS CONTRIBUTING TO RELEASE B D Training deficiencies Weather conditions Other REquipment failure D Operator error D Faulty process design ,.,.,., { r.RtiNn o-,o,nc.. ti(Pipefine □ Ship □ Tank D MATERIAL LISTED ON IMMEDIATE ACTIONS TAKEN Ea' Containment Sewage D Unknown CERCLA list (40 CFR 302.4) Extremely Hazardous Substances EPCRA Section 302 list (40 CFR 355) 0 Michigan Critical Materials Regis!er D RCRA listed hazardous waste OOtherlist D Unknown r-J Rf. Surface waters (include name of river, lake, drain, etc., involved) Kv,\f\ (, □ ............................ D Truck D Other Tanker ·-- SPILL REACHED - - Container 0 0 0 · · ·····•· ........................................... TYPE OF MATERIAL RELEASED D Other '·t··'•i-7 .. 0 D Hazardous waste Flammable & combustible material l:M'.0iVother petroleum products or waste 0Satt PHYSICAL STATE RELEASED (Indicate If solid, Jlquld, or gas) SOURCE OF LOSS 0 q leak or rupture Vehicle accident Other I C - 2 C <J,llc.tS SURFACE WATER QUALITY DJ\ D Railroad car - 0 0 ESTIMATED QUANTITY RELEASED (Indicate unit e,g, lbs, gals, cu H or yds) 62"-1L L,414Z. - 5 4.-. J,, ..... 18 Pipe/valve Explosion Fire Leaking container Loading/unloading spill .. ... ~ D 0 0 0 CAS NUMBER or HAZARDOUS WASTE CODE MATERIAL RELEASED (ChH1Jcal or trade nam ■ ) PLEASE CHECK HERE IF MSOS ATTACHED TO REPORT 1-\'t Oi!-&.1.A.U'L .~-r TYPE OF INCIDENT days hours minutes Cee- L ·!4 Diversion of release to d Dilution 0 Evacuation ~ Hazard removal D Neutralization (if System shut down j -., ~ a'tv2. D D D treatment Decontamination of persons or equipment Mcnitoring Other Distance from spill location to ,,, k,.,~ surface water, in feet i{(1 • Drain conn!!cled to sanitary sewer (include name of wastewater treatment plant and/or street drain, if nown) _18{Drain conmcted to stoon sewer Onclucle name of drain or waterbody it discharges into, if known} 1 Groundwator Onclude name of aquifer, if known) ..] Soils (include type e.g. day, sand, loam, etc., if known) D Spill contained on impervious surface THIS IS A MASTER COPY. PLEASE MAKE COPIES FROM THIS MASTER COPY AS NEEDED. Page 1 of 2 EQP 3465 (09/97) �WAS ANYONE HOSPITALIZED? EXT EN I Of INJURIES. IF ANY ................~ □ Yes .~~···························...................................................................................... . TOTAL NUMBER OF INJURIES TREA TEO ON•SITE: NUMBER HOSPITALIZED:• ·~ ••••• ••••• • •• ••••••••••••••••••• •• ••••• • •• • • •••• • ••• • • • • •• •• •••••••••••••••••••u•••••••• • • ••• ••• ••• •• ••••• • ••• • ••••••••••••••••••••••• • •••••••••• No DESCRIBE THE INCIDENT, THE n ·pe OF EQUiPMENT INVOLVED IN THE RELEASE. HOW THE VOLUME OF LOSS WAS DETERMINED. ALONG WITH ANY RESULTING ENVIR-JNMENTAL DAMAGE CAUSED BY THI: RELEASE. IDENTIFY WHO IMMEDIATELY RESPONDED TO THE INCIDENT (own employee• or contractor - Include cloanup company name. contact person. and teleph,ine number). ALSO IOENTIFY WHO DID FURTHER CLE/<NUP ACTIVITIES. IF PERFORMED OR KNOWN WHEN REPORT SUBMITTED ~ CHECK HERE IF OESCRIPTIOII OR ADDITIONAL COMMENTS ARE INCLUDED ON ATTACHED PAGE S~..5..'t~f':'.'.\ ......t. .~-.,.>. ........£...'-::-:~~.~ ..~.~? ..... ...L...~ ..E .~..........t~.A..K~.P. ..... 1.~-....::.e:-c. ... ....... H~..O .a.A\...-..~.\. .k .......... "'~--- • (' .... Ei.G.o.J.. ~_ukv.:'A-J~r.?. ...... ~..\'.U.e.......... .C.o.i\.i\.€ ,'-,.n::''".c.\.........t.:P.....T..~ ........S..TP..l~..Y.~....... :?..½~.@. ..~......... '.....•. -~ o F Q OL ..c:: Fo,2. o () :::: F , L-1 AL S" ' ('J • r-i A u , C (:;S p,,,..:,o •N6 ·n-ta.., 6 tr-1 RcL6-\S~::::: ·\.·""·S· v I'"\ y f' 5 h?.6"A""" ....A ..~'·: >c,~ 8~i,.1• BotJ,__...S 1 . 0 .c. 1.~.",:;-:,z.,""o v \,,VL.,A.. KO(:.u.e ~\vZ,?.. IN Sci.; !2-L.e I \\,\MCOIA~ .SIG p.S 10~"->r\hi:':D F'AL,L,rvi. , F,-2.S T. PLALCo Oil., 0;',t05 LuoLv~,z \ ~o S-rv? Lv~2.6' N-\ ~C,'-.l iV c,'-"()t.<;'...(m ;\to.lD 0.!-euZlJ 7 V...~.k~~.D.0..,~....... ~~.)2...........?... r:f::~f:.t:1:-:.i.A.~..L.... _.. ......t:.lhC..n:±1!:;~...........~.~ .~ b.~~.:.............~o.....&&.i.J::t:\1'.;,1....... ·vA\'V~GG ~,y.\S. NO'l'"'C-0 1N Rv;"\ ( f2._ZGL Oi2.. 12.ol>l-d:; Q, LGE-AtJ \)(S(~.. • • • ••• .. ••••••••••••••• • .. • .. • • •• • ••••• • • ••• ••••••• •• • •• • ••• • • •• •••• • • •• • .. •• •••• •• .. • -•• .. • • • • .. • •••••• •••• •••• •• •••• • •••••••••••••• n • .. • • ••• • ••••••••••• • •• •• ••• • •• •• "•• • • ••o oo u ouoo u ou, ,,.,.-.o, oo oO OO OHO ooo,, o o,o o•o o,, oo oo• n o,o , oo u o•o o" o .ouo o•o ••••••• •••• •• •••••• ESTIMj,TED QUANTITY OF ANY Rl'COVERED MATERIALS ANO A Dl:SCRIPTION OF HOW THOSE MATERIALS WERE MANAGED Uncludo dl•posal method II applicable) ......... E-.>...I..\.\~1M"Q... .......::t::J:~T..............e.o .......'T.P......::f..Q..~!.O.........Q .. .F............ B..~. ~.GZ~.s.~:Q......J.Y\&~.~.-'.A.L ................... .. ....... w-A-~ ..........A~?-?..s.o.?1~~0. ............. o.!-Zr. .......... \J...A-.~.~v..:r~.t:.Q........... i...!.. p ~ .. ...... ... .tDj........V.. .f:~.~...::t1Z..\A~.~ ... .. (Sec: A~C:\-rco) ASSES.5 MENT OF ACTUAL OR POTENTIAL HAZARDS TO HUMAN HEAL TH flnclude known acute or Immediato and chronic or delayed ertocls) ........Ro.c.,.lt,,.F.°c?,~0.........\.-~'lf.\-.~@.:......:n?.~Am.1~:-,jT...........E~. ~. l ..k~.t::~-=l••...... ::D..o_':-:'.'.::..t.o:?...~m.~.; A..I~ ~.......... ~.., ..nt..........?...Tu~.r.~Q........•..~ .N=:l~~.........i).\.&.IZ.1.~ .~ ..........d.{?..i..~L.,.....(;,..k!;"A-AJ.":r!.,P ....... R-€:CCA5;; l. .... ...... u. f::,~O A ... -.\) Ai.>D 1tl(.) .v4:L t'Y'.......CAT-N\'6,vl j'. SAl'V\{)U..,1c,,. t\:io ~U('-u~ MICHIGAN DEPARTMENT OF ENVIRONMENTAL QUALITY NOTIFIED: OTHER ENTITIES NOTIAED: 0 pi(National Response Center (NRC): 800424-8802 PEAS: 800-292-4706 Log Number Assigned _ _ _ _ __ ~DEQ District Office D Nr Quafity O O Detroit Gaylord Drinking Waler and Radiological Protection O IS(Grand Rapids Jackson 0 Marquette 0 Plainwell 0 Sauinaw Bay Environmental Response Geological SUNey O Land&WaterManagement ta'Surface Waler Quality O Underground Storage Tank 0 0 O 0 0 O Shiawassee D we •~eel State Police Local Emergency Planning Committee WaslewaterTreatmentPJanlAuthority 0 SI HazmatTeam - K 10 0 LocalHealthDepartmenl D Michigan Department of Consumer & Industry Services D Michigan Department of Agrirul!ure: 800-405-0101 Wasle Management Southeast Michigan (Livonia) OEQ 01slrict Clffices EFFE;(.;.rS. 0 US Coast Guard Office Contacted: D DetroilOGrand Haven D Saul! Ste. Marie 0 US Environmental Protection Agency 1):1. Local Fire Department &{. Local Pol'lce Department DMsion(s) Contacted: O Cadillac 0 .........'?...E. ............... lo change !is] Other RECORD NAME OF DEQ STAFF CONTACTED & PHONE NUMBER (MIOSHA) C ,'1-'\.J I.,\,,~~ ~rn\t:'I...>• RECORD NAME OF OTHER STAFF CONTACTED & PHONE NUMBER ..'.T.Q.;;.~ .......\2~~.0...l.~ ..~?.~;...... .l..4.1.k}.,~~ ..:..9..i.1.::.. ..... .$.J.J;;,.~ .~ .......4.~~..~ . N........(.(.;:.!.6.).3.&:::Q.~ ., I - · ..... .L.£Q..~.~~.D........~~~.b ........... (~.Ie,Y3.~J?. ..::.r:.'P.)1 ... ..l:Y.\.,..\<.~..... $...!§..~...........(.$.(\1).:4.Z..1...:.8..ft?. J,, SIGNATURf::. OF PERSON REPORTil>G SPILL (~~i {(>.).,~ I""' ~ bt"= .. " =o"'w t>.M" ro"~ "' n,I , •~"' ' ,.,~M,w C·...:1:.,;l"\-' ,~z.1to 1't'1 ,c A(' t....:l~Z..i.li..b"-·--..:.f':,~:J-.;= ;:;. ~'l_ _ _ _ _ _.1.-\;,l=-i.Pi..,;,,M _ _..:4-:;._..,;\:.,;'Z.,;,;._ ' ·_..,_~_ _ _a;;.;m/.;.;;.:;p...;m....11aar.....T_e_le_,p_h_o_n.;.e_ _ _ _-a,. lll(._F..,;ax;,;.__'_"_~_"--=0=..;;E;;,,,m:.,;a;;,,,i(_ __ Page 2 of 2 j �DEPARTMENT OF ENVIRONMENTAL QUALllY DI£\ GRAND RAPIDS DISTRlC:1' OFFICE .-JENNIFER M. GRANHOLM STEVEN E. CHESTER GOYERNOR 04RECTOR December 15, 2008 ,.. .t CERTIFIEQ.M&b VIOLATION NOTICE VN No. VN-003785 Mr. Jim Blue Wolverine World Wide, Inc. 9341 Courtland Drive, NE Rockford, Michigan 49351 Dear Mr. Blue: SUBJECT: Violation Notice National Pollutant Discharge Elimination System (NPDES) Certificate of Coverage (COC) M!S510423 On November 19, 2008, Mr. Jack DeRuyter, a representative of the Department of Environmental Quality (DEQ), Water Bureau (WB), Grand Rapids District Office performed an storm water permit compiance inspection of the Wolverine World Wide, Inc. Main Street facility located in Rockford, Michigan. Stonn water from this facility discharges to the Rogue River in Kent Counly. The purpose of this ilspectlon was to determine compllance with NPDES General Permit No. MIS510000 and state and federal stonn water regulations such as Part 31 of the Natural Resources and Environmental Protection Act, 1994 PA451, as amended (NREPA), and Tlffe 40 of lhe Code of Federal Regulations (CFR) Part 122.26. You and Mr. Ismael Rodriguez accompanied our representative during this inspection. .f:L~ i Based on the results of this inspection the W8 has sufficient information to state that Wolverine World Wide, Inc. is operating in violation of.NPQ~~ General Pennit No. M!S510000. The foHowing item was identified during the inspection as a violation of NPDES General Pennit No. M!S510000 V1. If The Stonn Water PoUution Prevention Plan (SWPPP) was reviewed during this inspection and was found to be deficient in several areas as noted below: a. The site map requires up-d.iting and clarification to meet the requirements of the permit. All items noted in General Permit No. M!S51000, Part I, Section C.1.a must be clearly identified. l' r: The list of significant materials must be modified to identify the outfall(s) through ~ which the material may be discharged if released. u. c. The preventive maintenance program description should include the facility's stonn water catch basins. Inspection records and corrective actions are to be maintained. J �Mr. Jim Blue Page2 December 15, 2008 d. Comprehensive site inspections were documented as required. They should also include visual inspection of the observable outfalls and must include a compliance certification statement. •• :. - -·- • .. • .,,, e. The facility's Spill Prevention Control and Countermeasure Plan should be referenced in the SWPPP to incorporate spill response procedures and equipment. f. A description of employee training programs is to be included in the SWPPP and shall identify periodic dates (or frequency- DEQ WB recommends upon hire and annually thereafter) of such training. g_ If the certified operator is changed, the permitee is required to provide the name and certification number of the new certified operator. h. The SWPPP is to be signed by the certified operator and the permitee. In addition, the following items were observed during the inspection: . 1. Outside storage of empty material handling racks was observed with storm water discharge to a down grade catch basin thus to a storm water outfalt The SWPPP is lo include a desaiption of procedures which describes measures to prevent material residues on these types ofitems from being discharged Into storm water_ At a minimum, documented, periodic visual inspection of these items to assure compliance is required_ Relocation of these items ;-•~P to an area that does not discharge to a stonn water outfaH was also discussed_ 2. Exposure of process materials and water treatment chemicals was observed. Storm water from these areas is directed to the on-site wastewater treatment plant. Continued monitoring of outside storage practices and areas to assure appropriate location of these materials is maintained. The violation identified in this Violation Notice is continuing. Wolverine World Wide, Inc. should take immediate action to achieve and maintain compliance with the terms and conditions of NP DES General Permit No. M#S51 qDOO. " are - - -- You_ ~~ested to submit a written response by January 9, 2009, indicating what has or Will be done to address V1 and 1. In addition, please submit a copy of an updated and signed SWPPP. Ii If you have any factual information you would like us to consider regarding the violations identified in this Violation Notice, please provide them with your written respqnse. i:; the Information regarding Michigan's Stonn Water Pollution Prevention Program• can be found on DEQ website at www.mfch[qan.gov/deqstonnwater; at this page, cf'tclc on INDUSTRIAL \; PROGRAM to explore additional information. "} V �,.__., t1p.t11 l J PEAS [ } othr-:r [ J I I ~QJ::J:?..Y~.IN~N_'l' L Name &l"Q t. 5 /jvv ,~~ f S -f: Address _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ PEAS Phone # _6.:c....;/--=:G,4-/__,,._,l?C,,:;._G;:;.__-9t:-,;,.£~' ).-&.7_ _ _ __ I ~OMPIJJ1 JU.~ l'lame of party/ faci li tJi(. Loca'i:i.on &t1 c.,.C(_ l,...,) t) ltt ev, .._._ number PECC name I.A)0 .,./.,/,.,.,I cl-t ¼11H e7 c.,,...-, fdv-4 7k~ Is lvcyz'"C' lt ( /V- lcJ0; ooo ) v~ /g/4J ~; ik.o 1 (Aµ~ J krr /.et.- ~t~ , -I I!) ( o ""- + Nature of Complaint 9 0 bo(l'-e_ jqt,\_ 1 w4' t-4-Q. 7vov'-<o./ Co v--, /fq tt'JI 'sf haJ / 11 Received by: -----~-~---u'-=--°YJ....-,il.___ _ _ _ _ _ _ _ _ _ _ _ __ FOLLOW~UP ACTIVI'.U. Date(s) Action Taken : .. \ : • SEP 2 0 1996 ~ Referred To: 5WG.b Of AOD �STATE OF MICHIGAN ~ YST GUYER JOHN ENGLER, Governor LL _J . . _ , -~T MYERS M. SPANO DEPART[V!ENT Of MATURAL !RESOURCES ROLAND HARMES, Director State Office Building 350 Ottawa, N.W., 6th Floor Grand Rapids, Michigan 49503 August 30, 1993 EI Nos. B2979 B2981 Mr. Harold Bailey Vice President - Engineering Wolverine World Wide, Inc. 123 North Main Street Rockford, MI 49341 Dear Mr. Bailey: On August 19·and August 20, 1993, the Air Quality Division, Department of Natural Resources, conducted an inspection of your facility's air emission sources located at 123 North Main Street, Rockford, and 1005 Baldwin Street, Big Rapids, Michigan. The purpose of these inspections was to determine the compliance status of your facilities with the requirements of the Federal Clean Air Act, as amended; Michigan Air Pollution Act; the rules of the Michigan Air Pollution Control Co:mmission (MAPCC); and conditions of your air use permits. During my inspection I observed the following air pollution violations: Process Description Citation of Rule or Permit Condition Violated Foot apparel coating and manufacturing operations Rules 336.1201 and 336.1208 Comments No Air Use Permits for various coating, adhesive, vapor degreaser and other air emission sources Enclosed are copies of each of the above-cited rules. �'• Harold Bailey Wal verine World Wide, Inc. August 30, 1993 PagE! 2 You should immediately initiate the necessary actions to correct the cited violation. Additionally, within 14 days of the date of this letter, please submit, in writing, a detailed report of the actions you have taken to correct the violations. As a minimum, this report should explain the probable causes of each violation, the duration of each violation including whether the violation is ongoing, remedial action taken, and what steps are being undertaken to prevent a reoccurrence. Additionally, .if the violations have not been corrected within this 14 days period, please submit a written program for correction of these violations and prevention of future violations to this office within 28 days of the date of this letter. This program should describe what equipment you will install, procedures you will implement, processes or process equipment you will shutdown, or other actions you will take and by what dates these actions will take place. Note that MAPCC Rule 201 requires that a permit be obtained prior to installation, construction, reconstruction, relocation, or alteration of any process or process equipment which may be a source of an air contaminant. You should be aware that State and Federal air pollution regulations will prohibit your company from obtaining any new air use permits for major offset sources located in Michigan until the cited violations are corrected or until you have entered into a legally enforceable order specifying an acceptable program and schedule for compliance. We will also be obligated to initiate further enforcement actions to require corrective action pursuant to the Air Pollution Act, Act 348, P.A. of 1965, as amended, if you do not comply with the above request. Furthermore, please complete and submit Air Use Permit application forms as soon as possible but not later than 45 days after the date of this letter. If you have any questions regarding these violations or what must be done to bring your facility back into compliance, please call me. l~ Lawrence Schultz, P.E. Environmental Engineer Air Quality Division (616) 456-5071 1- ' LS:nc Enc. cc: G. Avery, Regional supervisor, Air Quality Division B. Rosenbaum, Compliance & Enforcement, Air Quality Division �I \l]J.;a. c_~~ 4'.AA p...-:v~ �Local Well and Water Usage Summary Most of the data for this section was obtained from the "Wellogic" database operated by the State of Michigan which can be accessed at http://wellviewer.rsgis.msu.edu/. We included municipal water wells for the City of Rockford, local private wells between those public wells and the former tannery site, and a few additional private wells located downstream from our area of concern. We also included several wells not indicated on the "RS & GIS" map which were included in a file labeled "historic" since we are uncertain whether these wells are no longer in use, or have simply not been verified for inclusion in the Wellogic system. We also include three addresses not listed in the Wellogic system since they appear to draw water directly from the Rogue River for private use. We believe this is another significant reason to ensure that the tannery is not leaching contaminants into the water supply. Our spreadsheet page lists significant water usage locations we could identify. The folowing page provides a dot-location printout from the "RS & GIS" map drawn from the Wellogic database. The last few pages provides details for each well listed on our summary page. �Screen Date Well ID ~ I-~ :0 :i c.. ~ 1 ~ Ill > ·c: ll. .!!l i =..., ·c: 0 t;; . ~ ( ( ( Type Size Approximate L.atitudeA.ongltude Current Owner/Oeerator Olde Millpond Condo Assn Cannon Township Olde Millpond Condo Assn City of Rockford City of Rockford City of Rockford 41000004678 41000014979 41000004679 41000009678 41000009682 41000019789 2/28/1986 4/11/1986 3/20/1990 4/23/1998 3/22/1999 7/28/2006 Type I Public Type II Public Type I Public Type I Public Type I Public Type I Public 6" 6" 6" 16" 16" 16" 43.111419/-85.564544 43.114507/-85.547764 43.111382/-85.564249 43.112283/-85.545682 43.112867/-85.545350 43.112338/-85.547138 41000006042 41000004675 41000004673 41000004670 41000008268 41000010296 41000015697 41000016476 41000016603 41000018534 11/27/1968 12/12/1968 6/25/1976 10/3/1986 4/14/2000 5/31/2000 7/17/2001 Household Household Household Household Household Household Household Household Household Household 3" 3" 3.5" 3.5" 5" 5" 5" 3" 4" 3" 43.126170/-85.549355 43.111296/-85.556767 43.111722/-85.555404 43.108103/-85.565326 43.114507/-85. 547764 43.116787 /-85.548182 NA NA NA NA NA NA 4ntl986 9/9/1987 3/26/1993 4/6/1993 6/21/1997 Household Household Irrigation Household Household Irrigation 3" 3.5" 5" 3" 3" 3'' 43.129917/-85.568766 43.117734/-85.554253 43.117267/-85.569022 43.130219/-85.566914 43.131068/-85.566326 43.122374/-85.558192 unknown unknown unknown River Pump River Pump River Pump NA NA 43.113740/-85.559558 43. l 13466/-85.559555 43. 113271/-85.559553 8/14/2004 8/20/2004 10/7/2005 8/18/1989 43.122776/-85.568388 43.109086/-85.565592 43. ll 7169/-85.551093 43.109550/-85.563104 *Not verified* *Not verified* *Not verified* *Not verified* *Not verified* *Not verified* *Not verified* *Not verified* *Not verified* *Not verified"' *Not verified* *Not verified* *Not verified* *Not verified* *Not verified* Pederson Funeral Home Address Millpond Dr NE "'Mailing address only* Millpond Dr NE 8101 Courtland Dr NE 8101 Courtland Dr NE 8101 Courtland Dr NE Rockford, Ml 49341 Rockford, Ml 49341 Rockford, Ml 49341 Rockford, Ml 49341 Rockford, Ml 49341 8845 Courtland Dr NE 8197 Northland Dr NE 8194 Northland Dr NE 8008 }ericho Ave NE 4934 Brownstone Dr NE 5160 10 Mile Rd NE Rockford, Ml 49341 Rockford, Ml 49341 Rockford, Ml 49341 Rockford, Ml 49341 Rockford, Ml 49341 Rockford, Ml 49341 *Mailing address only* Rockford, Ml 49341 8008 Jericho Ave NE 4615 Windcliff Dr NE Rockford, Ml 49341 Rockford, Ml 49341 4728 Windcllff Dr NE 49341 49341 49341 49341 49341 49341 9105 Summit Ave NE 233 E Division St NE 174 W Division St NE 9111 Summit Ave NE 9145 Summit Ave NE 127 N Monroe St NE Rockford, Rockford, Rockford, Rockford, Rockford, Rockford, 251 S Main St NE 265 S Main St NE 275 S Main St NE Rockford, Ml 49341 Rockford, Ml 49341 Rockford, Ml 49341 MI Ml Ml Ml Ml Ml Ill :ii: I'!:! 0 I,. Cl> a:> NA NA NA NA *Not verified* *Not verified* *Not verified* �http://wellviewer.rsgis.msu.edu/viewer.ht .fS Viewer WELLS PRINT LAT /LON Water Well - = c~ _,.,.,,,."ffi!00""1141. 157'1C! 181518 ....... 410000142!1 ~ 100()()()CK)35 ~ 1000009029 - AIRPHOTO • ~1~ LAYERS TCJIOMAP - ciAaALGECILOGV cotiTAiiMta>sffEs WB.LHEM> AREAS MIBIC NIT1WI! OCCIIRRENCE INFO - TCJIO LEGEND~ WLEGEND IAVERINFO CONTACT Back to start page Auto zoom lo selected Well IDs on WELLS SEARCH Pick a county 410000108111. • OlllVln.lUIII ~ 41 4100001M-44 • 06/20/2011 04:09 P: �._, _______ .. Water Well And Pump Record Import ID· Tax No: IPermit No: Countv: Kent Townshln: Cannon WSSN: 1source ID/Well No: Town/Range: !Section: Well Status: ! Active 08N 10W 6 2054241 001 Dlatance and Direction from Road Intersection: 200 FT SOUTH OF BELDING RD;, 1/4 MILE EAST OF MEYERS LAKE RO. CANNON TOWNSHIP COMPLEX f Well ID: 41000014979 Elevation: 850 II. Well Owner: CANNON TOWNSHIP COMPLEX Well Address: Owner Address: 6878 BELDING RD 6878 BELDING RD ROCKFORD, Ml 49341 ROCKFORD, Ml 49341 Latitude: 43.114507 Longitude: (Wellogic) Completion is required under authority of Part 127 Act 368 PA 1978. Failure to comply is a misdemeanor. -85.54TT64 Method of Collection: QQQ - Centroid Drilling Method: Cable Tool Well Ute: Type II pubflC Well Depth: 72.00ft. Date Comnleted: 4/11/1986 Well T.,.,,.: Unknown Height: CHlng Type: Steal - unknown Casing ,Joint: Threaded & coupled Casing Fitting: Drive shoe Pumn Installed: No No Preaaure Tank Installed: Pressure Relief Valve Installed: No Diameter: 6.00 in. to 66.00 H. depth Borehole: Static Water Level: 45.00 H. Below Grade (Not Flowing) Yield Test Method: Unrestricted Flow Rate: Well Yield Test: Pumping level 47.00 ft after 4.00 hrs. at 15 GPM Unknown Filter Packed: No Screen Installed: Yes Blank: Above Screen Diameter: 6.00in. Screen Material Type: Stainless steel-slotted Length Set Between Slot 6.00 ft. 66.00 ft. and 72.00 fl. 12.00 Formation Description Thickness Gravel & Stones BrownClav Sand Coarse Sand Fine RedClav Gravel Sand Medium Gravel Medium To Coarse 25.00 5.00 5.00 15.00 2.00 2.00 16.00 2.00 Depth to Bottom 25.00 30.00 35.00 50.00 52.00 54.00 70.00 72.00 Fittings: None Well Grouted: No Geology Remarks: Wellhead Completion: Pitless adapter Nearest Source of Possible Contamination: Distance Type 50 ft. Sewer line Direction North Drllllng Machine Operator Name: Employment: Unknown RAYMER Contractor Type: Waler Well Drilllng Contractor Buslneas Name: RAYMER CO., INC Bualness Addreas: Reg No: 0384 Water Well Contractor's Certification This well was drilled under my supervision and this report is true to the best of my knowledge and belief. Slanature of Renlatered Contractor General Remarks: Other Remarks: EQP-2017 (4/2010) Page 1 of 1 State of Michigan Date 2/17/2004 11 :21 AM �Water Well And Pump Record caw Completion is required under authority of Part 127 Act 368 PA 1978. Failure to comply is a misdemeanor. lmoortlD· Tax No: Countv: Kent Townshln: Cannon WSSN: Source ID/Well No: Town/Range: !Section: Wall StltUs: 08N 10W 6 Active 5730 WELL2 Distance and Direction from Road Intersection: 3/8 mife South of 10-Mife Road, .25 mile West of Courtland IPwmltNo: ! Well ID:41000009682 ! I Elevation: 798 ft. Latttude: 43.112867 Longitude: -85.54535 Method of Collectlon: GPS Std Positioning Svc SA Off Drllllng Method: Rotary Well Depth: 232.00 It. Well T,,....: New Caalng Type: Steel - black Caalng Joint: Welded Caaing Fitting: None WellOwner: Citv of Rockford Well Addreu: 8101 Courtland Pumn Installed: Well Use: Type I public Date Comnleted: 3/22/1999 Height: 4.00 ft. above grade Owner Address: 7 South Monroe Rockford, Ml 49341 No Pressure Tank Installed: No Pressure Relief Valve Installed: No Diameter: 16.00 in. ID 152.00 ft. depth Borehole: 30.00 in. to 232.00 ft . depth ...., Static Waler Level: H. Below Grade (Not Flowing) Yield Teat Method: Test pump Unrestricted Flow Rate: Well Yield Test: FIiter Packed: Yes Screen Installed: Yes Blank: Screen Diameter: 16.00 in. Screen Material Type: Stainless steel-wire wrapped Length Slot SetBetween 15200 ft. and 232.00 ft. 50.00 ft. 40.00 Formation Description Sand & Gravel Grav Clav Grav Clav & Gravel Sand GravClav Sand & Gravel Grav Clav & Gravel Sand & Gravel Coarse Thickness 45.00 25.00 53.00 12.00 2.00 3.00 8.00 84.00 Depth to Bottom 45.00 70.00 123.00 135.00 137.00 140.00 148.00 232.00 Fittings: Other Well Grouted: Yes Grouting Material Neat cement Wellhead Completk>n: Grouting Method: Unknown D■pth Bags AddltlvN 0.00 ft lo 140.00 ft. 410.00 None Geology Remarks: Wei/house Nearest Source of Possible CCJntamlnation: Type Dlatance 300ft. Septic tank Direction South Drilling Machine Operator Name: Employment: Employee G. Neubecker, Ill Contractor Type: Unknown Bualnesa Name: Business Addrus: Reg No: Water Well Contractor's Certification This well was drilled under my supervision and this report is true to the best of my knowledge and belief. Slnnature of R.,..lslered Contractor General Remarks: PW2· Screen lnlo: 152'-162' screen 162'-172'"'"" 172'-192' screen. 192'-212' n;,,., 212'-232' screen Other Remarks: Screen Fittinas:See General Remarks State of M1ch1gan Page 1 of 1 EQP-2017 (4/2010) Dale 4/10/2002 11 :03 AM �'~ Water Well And Pump Record 11111 lmriortlD· Tax No: (Wellogic;) Completion is required under authority of Part 127 Act 368 PA 1978. Failure to comply is a misdemeanor. 41081101301 IPermit No: Countv: Kent Townshln: Plainfield WSSN: Source ID/Well No: Town/Range: !Section: IWell Status: 08N 11W 1 4963 ! OLD MILLPONDE C Dlat■nce and Direction from Road Intersection: WSSN#04963 I Well ID:41000004678 Elevetlon: 702 ft. WellOWner: OLD MILLPONDE CONDOS Well Addreas: Owner Address: OLD MILLPONDE CONDOS, WELL #1 ROCKFORD, Ml 49341 ROCKFORD, Ml 49341 Latitude: 43.111419 Longitude: -85.564544 Method of Collection: GPS Sid Positioning Svc SA Off Drflllng Method: Rotary Well Use: Type I public Well Depth: 69.00 fl. Date Comn1Ated: 2/28/1986 Well TVDA: New Height: 3.00 fl. above grade C■slng Type: Steel - black Casing Joint: Threaded & coupled ca11ng Fitting: None Pumn Installed: No Pressure Tank ln■talled: No Pressure Rellef Valve Installed: No Diameter: 6.00 in. to 49.00 fl. depth Borehole: 12.00 in. to 69.00 ft. depth Static Water Level: 15.00 fl. Below Grade (Nol Flowing) Yield Test Method: Unrestricted Flow Rate: Well Yield Test: Pumping level 41.00 ft. after 10.00 hrs. at 60 GPM Screen Installed: Yes Screen Diameter: 6.00in. Screen Material Type: Slot Length 20.0011. 20.00 Unknown Filter Packed: No Blank: 0.00 fl. Above Set Between 49.00 fl. and 69.00 ft Formation Description Sand & Gravel GravClav Grav CJav & Gravel GravClav Sand Grav Clav & Gravel Sand Coarse GravCfav Sand Sand & Gravel GravCJav Thickness 17.00 6.00 6.00 4.00 2.00 4.00 1.00 2.00 13.00 13.00 2.00 Depth to Bottom 17.00 23.00 29.00 33.00 35.00 39.00 40.00 42.00 55.00 68.00 70.00 Rttlngs: None wen Grouted: Yes Grouting Materlal Neat cement WeHhead Completion: Grouting Method: Unknown Depth Additives Bags 0.00 ft. to 49.00 fl. 0.00 None Geology Remarks: Other, 12 inches above grade Nearest Source of Possible Contamination: Diatance Type Sewer line 300 ft. Direction West Drllllng Machine Operator Name: Employment: Unknown Contractor Type: Unknown Buslneas Name: Buelneas Address: Reg No: 0384 Water Well Contractor's Certification This well was drilled under my supervision and this report is true to the best of my knowledge and belief. Slanature of Ranlstered Contractor General Remarks: ORIGINAL WELLJD# WAS 01005· Other Remarks: Wellhead Comolelion:12 inch Above Grade Page 1 of 1 EOP-2017 (412010) Date LHD 2/17/2000 4:42 PM �Water Well And Pump Record 111, lmoortlD· Tax No: Countv: Kent Townshln: Cannon WSSN: Source ID/Well No: Town/Range: )Section: Well Status: 08N 10W 6 5730 Active WELL 1 Distance and Direction from Road Intersection: ' .25 mile West of Courtland 3/8 mile South of 10-Mile Road, IPermttNo: Elevation: 795 ft. Latitude: 43.112283 -85.545682 Method of Collection: GPS Sid Positioning Svc SA Ott Drtlllng Method: Rotary Well Depth: 242.00 ft. Well Tv1»: New Casing Type: Steel - black Casing Joint: Welded Casing Attlng: None r l' Well ID:41000009678 Longitude: (Wellog@ Completion is required under authority of Part 127 Act 368 PA 1978. Failure to comply is a misdemeanor. Well Use: Type I public Date Comnleted: 4/23/1998 Height: 4.00 ft. above grade Well Owner: Citv of Rockford Well Add1'89■ : 8101 Courtland PumD Installed: No Pressure Tank Installed: No Pressure Rellef Valve Installed: Owner Address: 7 South Monroe Rockford, Ml 49341 No Diameter: 16.00 in. 10 162.00 tt. depth Borehole: 30.00 in. to 242.00 it. depth Static Water Level: 51 .00 ft. Below Grade (Not Flowing) Ylekl Test Method: Unknown Unrestricted Aow Rate: Well Yield Test: Screen Installed: Yes FIiter Packed: Yes Screen Diameter: 16.00 in. Blank: Screen Material Type: Slainless steel-wire wrapped Length Slot Seteetween 50.00 ft. 162.00 ft. and 242.00 fl 40.00 Formation Description Sand GravClav Sand & Gravel Grav Clav W/Gravel Sand & Gravel Gravel & Sand Thlckneu 23.00 50.00 4.00 67.00 58.00 40.00 Depth to Bottom 23.00 73.00 n .oo 144.00 202.00 242.00 Fittings: Olher Well Grouted: Yes Grouting Material Neat cement Wellhead Completion: Grouting Method: Unknown Bags Depth Additives 0.00 ft. to 150.00 ~ 425.00 None Geology Remarks: Other Nearest Source of Possible Contamination: Type Dltllanc:e Septic tank 500 ft. Direction West Drllllng Machine Operator Name: Employment: Employee G. Neubecker, Ill Contrllctor Type: Unknown Bu1lnes1 Name: Business Addresa: Reg No: Water Well Contractor's Cenfflcatlon This well was drilled under my supervision and this report is true to the best of my knowledge and belief. Slanature of AAnlatared Contractor General Remarka: PW1 • Screen Info: 162'-172" screen/172'-182' nir\A/182"-202' screen/202"-222' ninA/222'-242' screen Other Remarks: Wellhead Comoletion:Above Grade Screen Fittinos:See General Remarks Page 1 of 1 Stale of Michigan EOP-20"17 (4/2010) Dile 4/10/2002 10:49 AM �,. Water Well And Pump Record (Welloglg) Completion is required under authority of Part 127 Act 368 PA 1978. Failure to comply is a misdemeanor. lmgortlD· Tax No: Countv: Kent Townahlo: Cannon Source ID/Well No: WSSN: Town/Range: 'Section: Well Status: Active PW-3 08N 10W 8 5730 Distance and Direction from Road Intersection: ' OF TfAMO LN NE & W OF COURTLAND DR IN WELL FIELD; N SIDE OFF IPermlt No: 66158 I Well ID:41000019789 ! Elevation: WellOWner: CITY OF ROCKFORD Well Address: Latitude: 43.112338 Longitude: -85.547138 Method of Collection: GPS Std Positioning Svc SA Off Ml Drilling Method: Rotary Well Use: Type I public Well Depth: 192.75 ft. Date Comoleted: 7/28/2006 Well Tvoe: New Height: 4.00 ft. above grade Casing Type: Steel - black Ceslng Joint: Solvent welded/glued Casing Fitting: None Pumo Installed: No Pressure Tank Installed: No Pressure Rellef Valve Installed: owner Address: 7 SOUTH MONROE ST PO BOX 561 ROCKFORD, Ml 49341 No Diameter: 16.00 in. to 151.00 ft. depth Borehole: 30.00 in. to 231.00 ft. depth Static Water Level: 89.33 ft. Below Grade (Not Flowing) Yleld Test Method: Unrestricted Flow Rate: Well Yield Test: Pumping level 142.00 ft. alter 1.00 hrs. at 1001 GPM Unknown Filter Packed: Yes Screen Installed: Yes Blank: 10.00 ft. Above Screen Diameter: 16.00 in. Screen Material Type: Stainless steel-wire wrapped Length Set Between Slot 151.00ft. and 191.00 ft. 40.00 30.00ft. Formation Description Thickness Sand Grav Clav Grav Clav & Gravel Sand & Gravel Grav Clav & Gravel Sarni & Gravel Coarse W/Stones 30.00 10.00 85.00 17.00 5.00 84.00 Depth to Bottom 30.00 40.00 125.00 142.00 147.00 231.00 Fittings: Unknown Well Grouted: Yes Grouting Material Neat cement Wellhead Completion: Grouting Method: Additives Bags 0.00 Unknown Unknown Depth o.oo ft. to 140.00 ft. Geology Remarka: Well/-ouse Nearest Source of Possible Contamination: Dist■ nce Type Unknowr Direction Drllllng Machine Operator Name: Employment: Employee JOHN INGRAM Contractor Type: Water Well Drilling Contractor Bu■lneu Name: PEERLESS-MIDWEST INC Bualnea AddreH: Reg No: 2097 Water Well Contractor's Certification This well was drilled under my supervision and this repon is true to the best of my knowledge and belief. I ! I I Slanature of RMl■tered Contractor D■te General Remarks: WELL SCREEN & CASING GROUTED SHUT W/ NEAT CEMENT FROM 231' TO 192.75; NEW DEPTH 192.75 A COPY OF OUR WEbL PRINT IS ATTACHED Other Remarks: Stale of Michigan 11/14/2006 1:15 PM Page 1 of 1 EOP-2017 (4/2010) I! �,. lmoortlD· Tax No: Water Well And Pump Record (Wellog!.£) Completion is required under authority of Part 127 Act 368 PA 1978. Failure to comply Is a misdemeanor. 41081101302 Townshio: Plainfield Countv: Kent WSSN: Source ID/Well No: Town/Range: jSectlon: 1we11 Status: OBN 11W 1 4963 OLD MILLPONOE C Distance and Direction from Road Intersection: WSSN#04963 IPermitNo: I Well ID:41000004679 ! Elevation: 702 ft. Well Owner: OLDE MILLPOND CONDOMINIUMS Well Address: OWner Address: OLD MILLPONDE CONDOS, WELL #3 ROCKFORD, Ml 49341 ROCKFORD, Ml 49341 Latitude: 43.111382 Longitude: -85.564249 Method of Collection: GPS Std Positioning Svc SA Off Drllllng Method: Cable Tool Well Depth: 67.50 ft. Well Tvoe: New Casing Type: Steel - black Casing Joint: Welded Casing Fitting: Drive shoe Well Use: Type I public Date Comoleted: 3/20/1990 Height: 1.50 ft. above grade Diameter: 6.00 in. to 50.50 ft. dapth Pump Installed: Yes Pump Installation Date: Manufacturer: Other Model Number: Drop Pipe Length: 40.00 ft. Drop Pipe Diameter: Draw Down Seal Used: No Pressure Tank Installed: No Presaure Rellef Valve Installed: Pump lnstallstlon Only: No HP: Pump Type: Submersible Pump e■paclty: 60GPM Pump Voltage: Drllllng Record ID: No Borehole: 10.00 in. to 50.50 ft. depth Static Water Level: 14.60 ft. Below Grade (Not Flowing) Yield Test Method: Unrestricted Flow Rate: Well Yield Test: Pumping level 23.00 ft. after 1.00 hrs. at 50 GPM Pumping level 26.00 ft. after 1.00 hrs. at 100 GPM Screen Installed: Yes Screen Diameter: 6.00 in. Screen Material Type: Length Slot 17.00 ft. 30.00 Unknown FIiter Packed: No Blank: 1.00 ft Above Formation Description Sand & Gravel Brown Clav Stirl<v Sand & Clav W/Sand Fine Gravel & Stones ClavSandv Gravel Medium Grav Clav Hard Thickness 12.00 3.00 16.00 4.00 12.00 22.00 1.00 Depth to Bottom 12.00 15.00 31.00 35.00 47.00 69.00 70.00 SetBetween 50.50 ft and 67.50 ft. Fittings: Neoprene packer Well Grouted: Yes Grouting Material Neat cement Wellhead Completion: Grouting Method: Unknown Depth Bags Additives 5.00 ft. to 50.00 ft. 0.00 None Geology Remarks: Pldess adapter Nearest Source of Possible Corrt■ minatlon: Type Distance None Direction Drilling Machine Operator Name: Employment: Unknown MIKE KOOIMAN, WAYNE GEIGER Contractor Type: Unknown Bualneas Name: Business Address: Reg No: 0700 Water Well Contractor's Certification This well was drilled under my supervision and this report is true to the best of my knowledge and bellef. Slanature of Realstered Contractor General Remarks: ORIGINAL WELLID#WAS 01019· Other Remarks: Pumo Manufacturer:BURKS Page 1 of 1 EOP-2017 (4/2010) Date LHD 2/17/2000 4:42 PM ���Artifact 22 �,l Tuesday, September 20, 2011 Ice COMING ro CEDAR RocK Cedar Rock is roller derby central no more. Skate rink to host ice hockey come Sept. 25. P· ge 8 EPA launches probe at tannery site Wolverine World Wide·to host public meeting Wednesday BY DANIELLE ARNDT The Environmental Protection Agency (EPA) is conducting a preliminary assessment of the former Wolverine World Wide (WWW) tannery site as the result of a petition submitted by 25 local residents. The petition was submitted to the Superfund Division of the EPA on June 21 by a group of residents known as the Concerned Citizens for Responsible Redevelopment (CCRR). "As a group, our primary reason for submitting this petition was we were not getting answers to our questions from the city or the DEQ that were Indy file photo based on scientific evidence," ~d city resident and CCRR spokesman Grant crane with Pitsch Companies takes a Medich. 'We got a lot of professional A bite out of the old tannery last fall during opinions, or what we would call per- • the site demolition. sonal opinions, with no testing or hard ..Ji data to back it up." In a letter obtained by The Rockford To LEARN MORE Independent dated Aug. 3, EPA officials What: Public meeting tated the a!lencv has determined the ,AIL - - - ""7 ... _ 0 - - \Al- -' - - - - • Rockford celebrates its 35th Harvest SPECIAL TO THE ROCKFORD INDEPENDENT As the crazy heat-filled days of summer wind down, Rockford is preparing for yet another Harvest Fest. The 2011 festival will celebrate Rockford's Rockford Independent/Danielle Arndt 35th year of gathering a bountiful harvest. The three weekends will be A group of 2~ ~ocal_resi~~nts sub'!litt'!_d t~is binder of observations and concerns as �vv vv vv :,m: 1:, t::11g1u1t:: 1ur 1uru1t::r illiSess- ment under the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA)." The assessment will determine what action, if any, should be taken to perform environmental cleanup at the site. Wolverine wiU host a meeting that is open to the public Wednesday to update the community on how the demolition of the former tannery complex went and to discuss the status of future development plans for the riverfront site. PRELIMINARY ASSESSMENT The Michigan Department of Environmental Quality (DEQ) will conduct the preliminary assessment of the Wolverine property per its Superfund site assessment cooperative agreement with the EPA The preliminary assessment, which officials described as a limited-scope screening investigation, is under way. Representatives from both the Lansing and Grand Rapids DEQ offices visited Rockford on Aug. 30 to review the site and meet with several petitioners. "Right now we are gathering all of the information we need to write our report," said Joe Walct'Ak, environmental quality specialist with the DEQ Remediation Division in Lansing. 'We want to make sure we've looked under all the rocks, so to speak." Walct'Ak said officials will use a large ................' " ' ~ Wtiere: Wolverine World Wide corporate headquarters at 9341 Courtland Drive Why: To update the community on how the demolition of the former tannery complex went and to discuss the status of future development plans for the riverfront site. binder of information and observations they received from local community members, any files and data on Wolverine from within the DEQ and data gathered by Wolverine itself to evaluate the site. He said the process likely will take two to three months before the assessment can be submitted to the EPA for review and acceptance. After the EPA receives the report, it has 30 days to sign off on the assessment and recommend either no further remedial action or that the site b advanced to the next step, which is inspection. POSSIBLE SITE INSPECTION At the site inspection level, Walct'Ak explained actual environmental testing would be done to document contaminants and identify source areas and the potential impacts of contamination. After the testing, the site would be put through the Superfund haz.ard ranking system, at which time the EPA would decide whether or not the site warrant- Division. The EPA has determined the former Wolverine World Wide 'tannery site warrants further investigation, thus the Michigan Department of Environmental Quality is conducting a preliminary assessment on its behalf. ed being placed on the National Priorities List "It may be such that it is not of the magnitude to be placed on the National Priorities List," Walct'Ak said. "Just because something goes through the Superfund process doesn't necessarily mean it goes on the National Priorities List There are other cleanup authorities ... and other avenues for the site to still be tracked and monitored." CITIZEN-DRIVEN EFFORTS RARE Walct'Ak said there are a number of ways a ,site may be discovered and brought to the attention of the Superfund, including via citizens, state agencies and EPA regional offices. "It doesn't happen very often," he said of a citizens' petition acting as the catalyst for discovery through Superfund. ''Typically, discovery happens through the state ... In the past 10 years, there have probably been four or five (citizens' petitions), but it certainly is not (the case) for a majority of sites." CCRR members have been photographing water runoff and interviewing former Rockford tannery workers to document their concerns, among other things, since last August The group conducted its own water sample test near the site and believes chemicals, such as chromium compounds often used in the treatment of leather, are migrating into Rum Creek and the Rogue River and could pose a risk to public health and the city's drinking water. "This might be worth nothing or it might be worth a lot," Medich said. "But that's why we wanted a third party to come out and do an inspection. What we want to hear is that it was a clean demolition. This is Rockford, we all live here. We don't want (the property) to become a Superfund site. But we also think the potential for contamination should be taken seriously." Throughout the demolition and site restoration process, Wolverine and the city have been adamant there are no known contaminants at the former tannery. However, David O'Donnell, district supervisor for the DEQ Remediation Division in Grand Rapids, said that is no longer the case. "I don't believe that is accurate anymore," he said. "I believe the folks working for Wolverine found some stuff, and Wolverine is going to do some additional stuff as a result" But he added it is his understanding Wolverine intends to discuss this mat- EOUEST HOEDOWN Fund raiser for special needs adults and children, Page 4 l17£617 IV\l 'PJOppoH 9 # llWJ8d Ol\td 38\tlSOd ·s·n 11vV11 OlS lHSHd JawoisnJ 1eisod SMHJ3 THE BAIT DEBATE The Indy's Woods & Water special section looks at the Michigan bait ban, Pages 10-11 4 7 WENT y ... to give us feedback. www.stoffordmediasolutions.com/reade~panel DRAGONFISH Grand Rapids joins the semipro scene for men's lacrosse, Page 13 BUSY WEEK v._....,...., ..... ....,..._., .. SEE HARVEST, PAGE WWW ALSO INVESTIGATING SEE WOLVERINE, PAGE , , . .. " " . . . . . J-' .. ...., . . . . . ties, entertainment, music and contests - all designed with the family in mind. The festival will take place the last weekend of September and the first two weekends in October. Last year's rendition of Harvest Fest had many local residents confused as a result of the weekends being divided up among different Rockford organizations, the Rockford Rotary, Rockford Chamber of Commerce and the Heart of Rockford Business Association. However, the chamber is back spear-heading the weekends again and new Executive Many wins for Rockford sports teams, Pages 12-19 Serving more than 42,000 residents in Rockford, Belmont and the townships of Cannon, Plainfield, Courtland, Algoma, Grattan and Oakfield Volume 15 Issue 37 �''' 4 Rockford Independent• Tuesday, September 20, 2011 Healing field flags still available, on display at Bishop Hills BY THE ROCKFORD INDEPENDENT Bishop Hills Elder Care Community in Rockford is continuing the tribute to 9/11 victims this week - giving community members one last chance to sponsor a flag and experience the sighl 'We had many people stopping by Cannonsburg after the display was t:aKen down, sad to find they missed the memorial," said Susan Bodenner, owner of Bishop Hills and chairwoman of the West Michigan Healing Field, which took place Sept. 9-13 at the Cannonsburg Ski Area. "But Healing Field is not just a five-day event ... we hope to give every flag a home in a West Michigan business, school or home to forever continue the conversation about the tragedy and hope of Sept. 11 through the eyes of a victim." Until Friday, 100 of the 3,200 flags will be set up at Bishop Hills. Each flag will be tagged with a victim's name and biography. The flags may be purchased at Bishop Hills, any United Bank location or at www. heal i ngfi eld . o rg/wes t-m ich igan-2011. The event itself drew more than 100,000 people throughout the five days. However, just fewer than 2,000 flags were sold during the evenl 'When you bring a flag to your home, the conversation becomes even more meaningful and personal," Bodenner said. "It also gives us a platform for sharing the story with our young people that were not born when the attacks happened or were too young to remember them." The West Michigan Healing Field has the potential to raise more than $175,000 o1..,1•• u '8vn11 1vv ............... , O f-'lv ,.1il'V'~ . . ..... n, .J- V ....... ... Rockford Independent/Danielle Arndt Rebecca Dady, second from left, reads the biography on the flag sponsored by the North Rockford Middle School with her classmates. • for local first responder organizations if every f:ag is purchased. The cost of sponsoring a flag is $75. LESSER KNOWN FACTS ABOUT THE WEST MICHIGAN HEALING FIELD • Of the 3,200 flags on the 10th anniversary of the 9/11 terrorist attacks. 2,997 flags represented the loss of a single person and was tagged with that person's name. The remaining 203 flags represented the victims that were never identified. • The entry path brought visitors to a center isle, creating a visual break in the flags, each side representing one of the World Trade Center towers. • The field was laid out in 93 rows in honor of United Airlines flight 93 that crashed in a Pennsylvania field . • Each flag was 6 feet from the next, so if the victims were alive and standing in the place of their flag, they could hold hands. • The crest of the hill was at an approximately 1,000-foot incline, the approximate height at which the planes entered the buildings. • Most of the victims were between 28 and 58 years old, in the prime of their working years. The youngest victim was 2 years old. Wolverine ter at Wednesday's meeting. O'Donnell said a consultant for Wolverine contacted the DEQinMay. ''They represented it to us that during the demolition, they saw a couple of things that required some further investigation and they came in to talk with us about that and to get our opinion on what types of testing to do," he said. O'Donnell said, as far as he is aware, all of the recent testing at the site has been groundwater testing via test wells. He added Wolverine also did some testing with respect to the wastewater treatment plant prior to demolishing the factory in early 2010. He confirmed that the DEQ gave Wolverine a copy of the residents' petition and that Wolverine is aware of the EPA preliminary assessment. 'Wolverine is conducting (its investigation) voluntarily," O'Donnell said. ''They do not have to consult with the DEQ to conduct an (environmental) assessment of their own property ... Our role is to perform oversight and to ensure that any investigation that is done complies with the state law. It is a voluntary cleanup program (Wolverine) is participating in and they can go ahead and do the investigation, they don't need us. Wolverine has taken the extra step of actually including the DEQ." COMPANY TO SHED SOME LIGHT .:,,\Alolue..?:.ir\S".'c:,....__ __:v-.t&\.Xno,l,a... , CONTINUED FROM PAGE WHAT 1 Is CERCLA AND SUPERFUNO? CERCLA, which established the Superfund program, was enacted into federal law in 1980. According to the EPA's website, it set forth various criteria for ranking contaminated or hazardous waste sites relative to their threats to the environment and human health. CERCLA also created the National Priorities List. Superfund is the division that evaluates the need for remedial action at a site, as well as develops a plan for this action. Some sites may be cleaned up by state or federal authorities other than the EPA. share how we met or exceeded all of the regulatory steps in that process ... to ensure those buildings did not pose any risks when the came down." Grady confirmed that Wolverine has conducted groundwater testing on the property. He said while the details will be presented on Wednesday, the "good news" that came from the testing is virtually all of the substances Wolverine tested for came in either below detectible levels or below acceptable standards. "There were a few (wells) where we did detect levels but ...»Qhl--=---c. ;-,r-.~ -.--- ·- �vv nea11r1 tJU l l,Y Rob i n. .e tte,, s Apple Hau & Winery Grand Rapids 616-361-5567 robinettes.com Quality Local-Grown Fruit since 1911 I !M~t Find us on Facebook: The Back Shop Ch1ropract1c Center Do You Suffer from Back Pain? According to The National Center for Hea lth Statistics, 14% of all new visits to doctor's offices are due to low back pain and about 25% of peop le with back pain have a herni ated disc. Disc herni ations ca n occur at any level but most commonl y occur in the low back. The disc is the shock absorbi ng cushion located between each vertebral segment. As people age, the disc tends to dehydrate, and in combination with years of wear and tear, increases the risk of injury. Pa in, numbness, ti ngling, or wea kness oflen radiate from the sight of the disc hern iation directly to where the injured nerve !ravels. In the case of low back pain, the numbness or tingling may rad iate down the leg. Spina l decompression ha been shown to relieve the pressure on the inju red nerve w hi ch in turn decreases, pa in, numbness, and tingli ng. Conservati ve decompression treatments produce a vacuu m effect on the di sc whi ch brings nutrients to the disc to help it heal, since the disc itself has very poor circulation, and also may hel p reduce the size of the disc hern iatio n. Spina l decompress ion can also improve symptoms caused by disc bulges, sciatica, sp ina l slenosis, and spondylol isthes is. We also offer chiroprac tic ca re, massage, and electric stimulation. Call or visit www.thebackshop.com today and set up an appointment lo determine if sp inal decompress ion is lhe best treatment for you. V 11 1 '"1"1 U t1 J Y••<u.pJ-' .._. .._.t-" work at the former tannery property on Sept. 1. "It has been about two years since we started," he said. "So we thought because we've reached sort of a milestone, we would update the community on the redevelopment efforts." He said officials with Wolverine and the DEQ will be at the meeting to answer questions from the public. He said they plan to focus discussion on the "facts about the site" from when the tannery was shut down in 2009 until the present. "(It will include) the process of decommissioning the site and the many, many steps that are involved in that process," Grady said. "(The process) also is one that requires many permits to do what we did at that site and we will Rockford ,,.City ~ Manager Michael Young said he was not aware of the EPA assessment nor of the citizen group's petition. ''This group has not shared anything with the city about its end goal - although it has filed more FOIA requests than I've seen in all my previous years as city manager," Young said. "If Wolverine is willing to voluntarily do testing and to share the results of that testing with the public - and how that will play into anything the EPA might do, I don't know - but I don't think we can ask for much more from them. "I look forward to the meeting Wednesday (with Wolverine). I think we will get some good information and a good update." �Artifact 23 �CERCLA PRELIMINARY ASSESSMENT REPORT for WOLVERINE WORLD WIDE FORMER TAN NERY 123 NORTH MAIN STREET ROCKFORD, MICHIGAN 49341 U.S. EPA ID NO.: MIN000510613 Assistance #: Vft00E00778-3 June 14, 2012 Site Assessment and Site Management Unit Superfund Section Remediation Division Michigan Department of Environmental Quality Reviewed And Approved By:J{lht.,~ L,6r£-A.J. Date: Site Assessment Manager Region 5 United States Environmental Protection Agency 6/is/;;z �PRELIMINARY ASSESSMENT Wolverine World Wide Former Tannery TABLE OF CONTENTS PAGE SECTION Section 1.0 Introduction .................................................................................................. 3 Section 2.0 Site Background .......................................................................................... 5 Section 2.1 Site Description .. .. .............................................................................. 5 Section 2.2 Site History ........................................................................................ 5 Section 2.3 Regulatory Status .............. ................................................................ 6 Section 3.0 Environmental Investigations ........................................................................ 7 Section 4.0 Potential Sources ......................................................................................... 9 Section 5.0 Pathway Discussions .................................................................................. 11 Section 5.1 Groundwater .................................................................................... 11 Section 5.2 Surface Water.................................................................................. 12 Section 5.3 Soil Exposure .................................................................................. 13 Section 5.4 Air ................................................................................................... 13 Section 6.0 Summary ................................................................................................... 15 Section 7.0 References ................................................................................................ 17 FIGURES Figure 1 Figure 2 Figure 3 Figure 4 Figure 5 Figure 6 Figure 7 - Site Location Historical/Current Site Features Soil Sample Locations Groundwater Sample Locations Sediment Sample Locations 4-Mile Site Radius Map 15-Mile Target Distance Limit Map TABLES Table 1 Table 2 Table 3 Table 4 - Deep Soil Sample Data Summary Surficial Soil Sample Data Summary Groundwater Sample Data Summary Sediment Sample Data Summary APPENDIX Appendix A - Part 201 Generic Cleanup Criteria and Screening Levels �Section 1.0 Introduction On August 3, 2011, the United States Environmental Protection Agency (U.S. EPA) tasked the Michigan Department of Environmental Quality (MDEQ) to conduct a Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Preliminary Assessment (PA) of the Wolverine World Wide Former Tannery site (Site) (U.S. EPA ID No.: MIN000510613). The need for conducting this PA was as a result of a petition from a local citizens group to the U.S. EPA to conduct this assessment. The petition was dated June 21, 2011 and was sent to Mr. Rick Karl, Director, Superfund Division - Region 5, U.S. EPA. Upon assessment of the petition, the U.S. EPA discovered the Site into the CERCLA Site Assessment process on July 20, 2011. The authority for this PA work was granted to the MDEQ through a cooperative agreement (CA) with the U.S. EPA (Assistance ID No.: V-00E00778-3). The Site consists of an area where the Wolverine World Wide 0fV\l'i/'W) company historically operated a chromium leather tannery plant. The site is located in the city of Rockford, Kent County, Michigan on the east bank of the Rogue River. The PA is performed under the authority of CERCLA and is the initial investigatory step in the CERCLA Superfund process. The PA involves a limited scope investigation that collects readily available information. The PA is designed to distinguish between sites that pose little or no threat to human health and the environment and those that require further investigation. The PA may also support emergency response activities and public information needs. If the findings of the PA determine that further investigation is warranted, the Site will continue to progress through the Superfund investigative process and undergo a CERCLA Site Inspection (SI). The SI will further evaluate threats to human health and the environment and collect additional data for further evaluation in the Superfund process. This evaluation may be accomplished through the collection and analysis of additional waste and environmental media samples to determine whether hazardous substances are present at the Site and are migrating to the surrounding environment and potential human and environmental targets. The SI provides the necessary information required to determine if the Site qualifies for possible inclusion on the National Priorities List (NPL) or if the Site should be designated as No Further Remedial Action Planned (NFRAP) in the Superfund process. At any time throughout the Superfund evaluation process, the Site may be designated as NFRAP, be referred to another state or federal cleanup program (Other Cleanup Authority [OCA]), or be recommended for further Superfund action. In conjunction with this PA work, the MDEQ also assisted the U.S. EPA Emergency Removal Branch (ERB) in their removal assessment of the Site. This work was conducted as part of the Removal Program Support Activities task in the U.S. EPA approved CA. The MDEQ assistance included conducting in-situ X-ray fluorescence (XRF) screening of soils, oversight of soil, groundwater, and sediment sample collection by the site owner's consultant, sediment sample collection and analysis of sediments 3 �from specific areas in the Rogue River, and general Site investigation assistance. The MDEQ also participated in a public meeting held on April 24, 2012 to present information regarding the Superfund process and current Site information to the general public. 4 �Section 2.0 Site Background Section 2.1 Site Description The Site is located at 123 North Main Street on the north end of the downtown district of the city of Rockford, Kent County, Michigan (T.9N., R.11W., section 36) (see Figure 1). The site is currently owned by WWW. The main plant site historically encompassed an area of approximately 15 acres. The location coordinates for the Site at the former main tannery building are latitude 43.123056° and longitude -085.560278°. The Site historically consisted of the former tannery operations including: tannery buildings, an on-site wastewater treatment plant, warehouse and storage buildings, and an office building. See Figure 2 for a map of the historical features of the site. All but one of the tannery structures have been demolished. The structure that remains was one of the tannery operations buildings on the north end of the Site. This building is currently being used for the commercial retail operations for WWW. The Site is situated on the north end of the commercial downtown area of the city of Rockford. Commercial businesses are located to the south of the site, residences are located to the east and north, and the Rogue River and residences are located to the west. A recreational trail, the White Pine Trail, runs through the western portion of the Site along the bank of the Rogue River. Section 2.2 Site History Operations on the Site began in approximately 1903 when G.A. Krause and his sons built a shoe factory on the northern portion of the Site. The tannery operations began on the southern portion of the Site in approximately 1908 when Mr. Krause and his sons built the tannery to supply their shoe factory with leather. The tannery used chromium as a means to tan its hides. Operations at the site included the tanning and coloring of hides for use mainly in shoes. Waste disposal practices in the early years of operation are not known. The company did construct a wastewater treatment plant (WWTP) sometime between 1950 and 1960. Some sludge from plant operations is known to have been disposed of in a gravel pit located several miles south of the Site. Anecdotal reports from former company workers indicate that some sludge may have been spread on at least two separate farms in the area as fertilizer. During construction of the White Pine Trail, the company exchanged easements with the Michigan Department of Transportation (MOOT) to give access to the western portion of the site for the trail along the Rogue River. MOOT had control of the old rail line that traversed a portion of the site from south to north. Tannery operations ceased in 2010 and the buildings on the Site were demolished in 2010 and 2011. Due to concerns at the Site noted during the demolition and general 5 �concerns about potential contamination at the Site, a citizens group petitioned the U.S. EPA on June 21, 2011 to assess the Site in the CERCLA program. Section 2.3 Regulatory Status With the exception of local permits for wastewater discharge to the municipal sewer system and a state storm water discharge permit, there was minimal environmental regulatory actions at the Site until after the demolition at the Site was complete. As a result of the concerns noted during the demolition, the company initiated environmental investigation work to assess the concerns with regard to the voluntary portion of the state's Part 201, Environmental Remediation, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended (Part 201 ). The company installed and sampled three wells and installed another five piezometers as part of this work. As a result of the PA petition, the Site is now discovered to the CERCLIS database and has been entered into the state's cleanup program as a facility needing assessment. In conjunction with the PA, the l).S. EPA ERB is also conducting a removal assessment to determine whether any time critical or non-time critical emergency removal actions are warranted at the Site. 6 �Section 3.0 Environmental Investigations Prior to the work being conducted as a result of this CERCLA activity, there had been only minimal environmental investigation work conducted on the Site. This work was conducted by the company in conjunction with geotechnical investigations at the Site for plant expansions. As noted in the previous section, the company initiated a limited environmental investigation to assess three areas of concern noted during the demolition. This work was started in May of 2011 and completed in September of 2011. The company had three wells and five piezometers installed. Samples collected from the three wells showed arsenic (37 micrograms per liter [ug/1)) and ammonia (20,000 ug/I) at levels elevated above Part 201 drinking water and groundwater surface water interface criteria. As a result of the findings of the initial investigation and the CERCLA PA that was initiated in August of 2011, the company proposed additional investigation work which they designated as Round 2 Environmental Investigation. This work included the installation of additional monitoring wells and the collection of deep and surficial soil and groundwater samples from the Site and sediment and pore water samples from the Rogue River. Figures 3 through 5 show the locations of these samples. This work was done in consultation with the U.S. EPA and the MDEQ and the sampling activities were overseen by a U.S. EPA contractor and MDEQ staff. At the request of the U.S. EPA, the company split the soil and sediment samples with the U.S. EPA contractor for separate analysis. The analytical results of the deep and surficial soil samples collected during this investigation are summarized in Tables 1 and 2, respectively. The data generated by the soil sampling indicates that there has been observed releases of contaminants to the soils on the Site. This is evidenced by contaminant concentrations above sample quantitation limits being more than three times background concentrations. Soil sample concentrations in the tables are also compared to Part 201 Non-residential Direct Contact Criteria (NRDCC) and Groundwater Surface Water Interface Protection Criteria (GSIPC) as a potential risk screening scenario. The complete list of the Part 201 Generic Cleanup Criteria and Screening Levels can be found in Appendix A. Contaminants with their maximum concentrations are noted in the following paragraph. Arsenic (360,000 micrograms per kilogram [ug/kg]), chromium (total) (49,000,000 ug/kg), and lead (930,000 ug/kg) were detected in deep soils at concentrations exceeding NRDCC. No surficial soil samples showed any NRDCC exceedances. Several contaminants were detected in both the deep and surficial soil samples at concentrations exceeding the GSIPC. These include: 1,2-dichlorobenzene (2,300 ug/kg); 1,4-dichlorobenzene (390 ug/kg); fluoranthene (13,000 ug/kg); phenanthrene (11,000 ug/kg); arsenic (360,000 ug/kg); barium (650,000 ug/kg); cadmium (17,000 ug/kg); chromium (total) (49,000,000 ug/kg); hexavalent chromium (17,000 ug/kg); lead (930,000 ug/kg); mercury (total) (640 ug/kg); selenium 7 �(2,200 ug/kg); silver (450 ug/kg); zinc (1,000,000 ug/kg); ammonia (556,000 ug/kg); and cyanide (550 ug/kg) in the deep soils. GSIPC exceedances in the surficial soil samples include: fluoranthene (5,800 ug/kg); phenanthrene (3,600 ug/kg); arsenic (11,000 ug/kg); chromium (total) (180,000 ug/kg); mercury (total) (340 ug/kg); selenium (1,200 ug/kg); silver (150 ug/kg); zinc (210,000 ug/kg); ammonia (316,000 ug/kg); and cyanide (410 ug/kg) Table 3 provides a summary of the groundwater data that was collected during the Round 2 investigation. While there were no background groundwater samples collected during this investigation, the data indicates that there has most likely been an observed release of contaminants to the groundwater on the Site based on the fact that tannery waste contaminants are present in the groundwater samples. Contaminant concentrations in the table are also compared to Part 201 Residential Drinking Water Criteria (RDWC) and Groundwater Surface Water Interface Criteria (GSIC). Groundwater contaminants that exceed one or both of these criterion, along with their maximum concentrations, are noted in the following paragraph. Arsenic (30 micrograms per liter [ug/1]), boron (770 ug/1), iron (9,800 ug/1), vanadium (10 ug/1), ammonia (46,000 ug/1), chloride (480,000 ug/1), and sulfates (500,000 ug/1) were detected at concentrations that exceeded the RDWC. In addition, 4-chloro-3-methylphenol (3 ug/1), arsenic (30 ug/1), chromium (total) (54 ug/1), hexavalent chromium (85 ug/1), ammonia (46,000 ug/1), and cyanide (16 ug/1) were detected at concentrations exceeding GSIC. A summary of the data from the sediment samples collected during Round 2 can be found in Table 4. Due to concerns from the local citizens group regarding potential impacts to the Rogue River, the U.S. EPA and MDEQ determined that it would be beneficial to collect additional sediment samples from specific areas of the river. These data are also summarized in Table 4. The sediment data indicate an observed release of contaminants above background levels to the surface water pathway. Sediment contaminant concentrations are also compared to the range of Part 201 Sediment Screening Levels in the table. Sediment contaminants that exceeded at least one of these screening levels are noted in the following paragraph along with their maximum concentration. Contaminants that had a maximum concentration that exceeded all screening levels include: chromium (total) (520,000 ug/kg) and mercury (total) (5,100 ug/kg). Contaminants that had concentrations that exceeded at least one screening level include: fluoranthene (620 ug/kg); pyrene (550 ug/kg); arsenic (16,000 ug/kg); cadmium (1,300 ug/kg); copper (66,000 ug/kg); lead (130,000 ug/kg); and zinc (290,000 ug/kg). 8 �Section 4.0 Potential Sources There are four known source areas on the Site. These include a former abandoned underground storage tank (UST), the "pit" area, soils in the former wastewater treatment area, and soils on the western portion of the Site along the river. Soil samples collected from these areas have shown some elevated levels of contaminants. The UST source area consists of soils around the abandoned UST that have shown elevated levels of both organic and inorganic contaminants, including 1,2-dichlorobenzene; 1,4-dichlorobenzene; xylenes; anthracene; benzo(a)anthracene; benzo(a)pyrene; benzo(b)fluoranthene; benzo(g,h,i)perylene; benzo(k)fluoranthene; chrysene; fluoranthene; indeno(1,2,3-cd)pyrene; phenanthrene; pyrene; arsenic; barium; chromium (total); hexavalent chromium; copper; lead; mercury; and zinc. This area has not been fully delineated. The "pit" area consists of an approximately 50 by 50 feet area under the former maintenance building and the soils around this area where wastes from the plant operations are reported by former workers to have pooled prior to discharge to the \/WvTP. Historical anecdotal accounts report that this area could potentially be larger and that it would sometimes backup and the wastes would overflow out of the "pit." The company contends that this area was a spot where cracks in waste piping caused a void to be created under the maintenance building floor. By either account, wastes were released in this area. During demolition, the company reported that they removed approximately 252 cubic yards of contaminated soils and sludges from this area but no testing was done to confirm the waste concentrations in the removed material or whether a clean closure was attained. Soil samples from the area contained elevated levels of the following contaminants: ethylbenzene; n-propylbenzene; toluene; 1,2,3-trimethylbenzene; 1,2,4-trimethylbenzene; 1,3,5-trimethylbenzene; xylenes; acenaphthene; acenaphthylene; anthracene; benzo(a)anthracene; benzo(a)pyrene; benzo(b)fluoranthene; benzo(g, h,i)perylene; benzo(k)fluoranthene; chrysene; dibenzofuran; fluoranthene; fluorene; indeno(1,2,3-cd)pyrene; 2-methylnaphthalene; naphthalene; phenanthrene; pyrene; arsenic; barium; chromium (total); hexavalent chromium; copper; lead; mercury; zinc; ammonia; cyanide; and sulfide. Soils in one area of the former \/WvTP were also noted by the company to be visually contaminated during the demolition. Soil sampling documented some inorganic contamination in this area. Contaminants in this area include: chromium (total); hexavalent chromium; mercury; ammonia; and sulfide. This contamination was also not fully delineated. Soil sampling was also conducted along the banks of the Rogue River on the west side of the site. These samples documented some elevated levels of inorganic contaminants in the surficial soils. Screening of these soils with an XRF unit also detected inorganic contaminants. Contaminants in this area include: anthracene; benzo( a)anthracene; benzo(a)pyrene; benzo(b)fluoranthene; benzo(g, h, i)perylene; benzo(k)fluoranthene; chrysene; fluoranthene; fluorene; indeno(1,2,3-cd)pyrene; 9 �phenanthrene; pyrene; arsenic; chromium (total); hexavalent chromium; mercury; zinc; ammonia; and cyanide. The extent of this contamination has not been fully delineated. 10 �Section 5.0 Pathway Discussions Section 5.1 Groundwater Given the data available to date, it is very likely that there has been a documented release of contaminants into the groundwater pathway at the Site. Groundwater samples collected from monitoring wells on the Site have shown detectable levels of ammonia, arsenic, cyanide, hexavalent chromium, and sulphates. No background samples have been collected to date since no background monitoring wells have been installed but given that these contaminants can be associated with tannery wastes, and the fact that the samples were collected from wells just downgradient of source areas, there is a high likelihood that these contaminants in the groundwater are the result of releases from source areas on the Site. There is also a likelihood that contaminants in the groundwater pathway may be located in other areas of the Site that have not been investigated due to historic operations on the Site. The near surface geology in the area of the Site consists of glacial outwash sand and gravel deposits and end moraine complexes. These deposits occur as fluvial terraces along the Rogue River with the end moraine complexes flanking the river and underlying the terrace deposits. The terrace deposits range in thickness from approximately 10 to 60 feet while the morainal deposits can exceed 300 feet in thickness. The bedrock geology of the area consists of the Red Beds and Grand River Formation. The depth to bedrock in the Site area ranges from approximately 215 to over 320 feet. The groundwater migration pathway is considered a pathway for contaminant migration in this area due to the highly permeable sand and gravel soils that are present, the fact that groundwater is used for drinking water within the 4-Mile Target Distance Limit (TDL), and the fact that groundwater flows toward and discharges into Rum Creek and the Rogue River. Analysis of groundwater samples collected from the Site monitoring wells has shown elevated levels of contaminants associated with tannery wastes. All area residents within the 4-Mile TDL utilize groundwater wells for obtaining their drinking water. See Figure 6 for the 4-Mile Site Radius Map. Residents of the city of Rockford are served by a municipal system that utilizes wells located approximately one mile southeast of the Site. Approximately 5,484 residents are served by this system. The remainder of the residents located within the 4-Mile TDL utilize private drinking water wells. The approximate residential population served by private wells by radius ring is listed in the table below: 11 �Distance from Site 0-¼ Mile ¼-½Mile ½- 1 Mile 1 - 2 Mile 2-3 Mile 3-4 Mile Total Estimated population served by residential wells 0 0 269 3,079 7,591 8,433 19,372 Section 5.2 Surface Water The surface water pathway is a major exposure pathway of concern for this Site. Surface drainage in the area of the Site flows either directly into Rum Creek or the Rogue River. The Rogue River eventually discharges into the Grand River approximately seven miles downstream of the Site. See Figure 7 for the 15-Mile Target Distance Limit Map. Analysis sediment samples collected from the Rogue River adjacent to the Site showed some elevated levels of inorganic analytes including: arsenic; total chromium; hexavalent chromium; copper; lead; mercury; and zinc. The Probable Point of Entry (PPE) of contaminants into the surface water pathway is all along Rum Creek as it passes through the Site and all along the eastern bank of the Rogue River on the west side of the Site. The furthest downstream PPE is at the southwest corner of the Site on the bank of the Rogue River. The 15-Mile TDL for the surface water pathway includes Rum Creek through the Site, the Rogue River at and downstream of the Site, a portion of the Grand River downstream of the confluence with the Rogue River, and the associated wetlands along the 15-Mile TDL. The Grand River eventually discharges into Lake Michigan outside of the 15-mile TDL. There are no known surface water intakes along the 15-Mile TDL but the city of Rockford historically operated an intake on the Rogue River downstream of the Site. The Rogue and Grand Rivers are used quite extensively for recreation and fishing. The city has a canoe/kayak launch on the east bank of the river just downstream of the Site. The city also just completed construction of a boardwalk with fishing platforms on the western bank of the river opposite the Site. Approximately 14.45 miles of wetland frontage have been documented along the 15-Mile TDL. Sensitive environmental resources along the 15-mile TDL include: six state threatened species, seven state endangered species, and two federal threatened species. These are all located downstream of the PPE and downstream of where sediment samples were collected. 12 �Section 5.3 Soil Exposure Soil samples collected from the Site in three known source areas have been shown to be contaminated with elevated levels of several organic and inorganic contaminants. These soils are located at relatively shallow depths but are all in the main plant area that has been demolished, covered with topsoil, and is fenced. There are, however, some soils located along the recreational trail that were once part of the Site operational area that do have some slightly elevated levels of organic and inorganic contaminants at or near the surface. This area is not fenced and is accessible to the general public. The potential exists for soil contamination in other areas of the main plant area of the Site based on the former tannery processes at the Site. There are no schools located within 200 feet of the Site but some residences are located with 200 feet of the Site boundary. The recreational trail located on the west side of the Site is regularly used by bikers and walkers. The approximate population affected by soil exposure within a 1-mile radius of the Site is detailed in the table below: Distance from Site 0-¼Mile ¼-½ Mile ½-1 Mile Total Estimated oopulation 513 1,249 2,693 4,455 Section 5.4 Air Migration of contaminants via the air pathway is possible, though not very likely. The majority of the known contamination is either in areas that are well vegetated or are subsurface. Some surficial soil contamination is present along the recreational trail on the west side of the Site but this area is fairly well vegetated to prevent possible windblown particulate migration. There is a minimal potential for migration of Site contaminants through the air pathway. Some of the potential contaminants associated with the tannery operations are volatile and have a potential for gas migration. The approximate population affected by the air exposure pathway within a 4-mile radius of the Site is detailed in the table below: 13 �Distance from Site 0- ¼ Mile ¼-½ Mile ½- 1 Mile 1 -2 Mile 2-3 Mile 3-4 Mile Total Estimated population 513 1,249 2,693 4,377 7,591 8,433 24,856 14 �Section 6.0 Summary The MDEQ was tasked by the U.S. EPA to conduct a PA of the Site to evaluate the current and potential impacts to surrounding human populations and environmental resources through the groundwater, surface water, soil exposure, and air pathways and to use this evaluation to determine the status of the Site in the Superfund process. The U.S. EPA initiated the PA as a result of a petition which they received from a local citizens group. This evaluation is based on existing data and information for the Site and research of available information for the Site area and the Site's potential contaminant sources. The Site consists of a parcel totaling approximately 15 acres located on the north end of the downtown area of the city of Rockford. The site is located in a residential/commercial area of the city along the eastern bank of the Rogue River. The tannery began operations at the Site in 1908. The plant operated until 2010 when demolition of the plant building began. Due to concerns during the demolition, a local citizens group petitioned the U.S. EPA to assess the Site through the CERCLA Site Assessment process. The Site was discovered into CERCLIS on July 20, 2011. As a result of environmental concerns documented during the demolition and the initiation of the CERCLA process, WWW initiated some environmental investigation work on areas of the Site where wastes and a UST were discovered during demolition and where some concerns were reported due to storm water runoff during demolition operations. Analysis of samples collected during this investigation work found some releases of contaminants into the environment Groundwater on the Site has likely been impacted by tannery contaminants. Samples from monitoring wells located at and downgradient of source areas have shown elevated levels of ammonia, arsenic, cyanide, hexavalent chromium, and sulphates. All residents within a 4-mile radius of the Site use groundwater for drinking water. These include the residents of the city of Rockford that are serviced by wells operated by the city as well as those residents outside the city limits who utilize residential wells. Given the proximity to the river and the groundwater flow direction toward the river, it is also likely that contaminated groundwater discharges to the river. Sediments in the Rogue River have been shown to be impacted from contaminants associated with the Site. Total chromium, hexavalent chromium, and mercury have been detected in sediment samples at levels elevated above background concentrations.. The PPE of contaminants to the river is along Rum Creek as it passes through the Site, along the western Site boundary and potentially where groundwater from the Site discharges to the river. The 15-mile TDL includes Rum Creek through the Site, approximately seven miles of the Rogue River downstream of the Site, and eight miles of the Grand River downstream of its confluence with the Rogue River. These rivers are used for recreation and fishing. Approximately 14.45 miles of wetlands 15 �frontage are also present along the 15-mile TDL along with several documented occurrences of state and federal threatened and endangered species. Area residents are potentially at risk of direct contact to contaminated soils at the Site. Slightly elevated levels of organic and inorganic contaminants have been detected in the surficial soils along the western side of the Site along the recreational trail and the bank of the Rogue River. The majority of the Site where the main plant buildings were located is fenced and has been covered with topsoil. The area along the trail on the western side of the Site is accessible. The trail is used regularly by walkers and bikers. The potential for air migration of contaminants is minimal given the fact that the Site is relatively well vegetated. The potential for gas migration of contaminants is also minimal due to the low levels of volatile contaminant found to date. 16 �Section 7 .0 References Concerned Citizens for Responsible Redevelopment (CCRR), Preliminary Assessment Petition and Summary of Concerns, Related to the Recent Demolition of the 15-acre Wolverine World Wide Inc. Tannery site in Rockford, Ml and its Long-term Environmental Impact on the Rogue River Watershed, June, 2011. Environmental Data Resources, Inc. (EDR), Certified Sanborn® Map Report: Wolverine World Wide Former Tannery, 123 North Main Street, Rockford, Ml 49341 (Inquiry Number: 3331727.3), May 29, 2012. EDR, The EDR Aerial Photo Decade Package: Wolverine World Wide Former Tannery, 123 North Main Street, Rockford, Ml 49341 (Inquiry Number: 3331727.5), May 31, 2012. Fishbeck, Thompson, Carr & Huber, Phase I Environmental Site Assessment, Michigan Northern Railroad Between Courtland and Main Streets, Rockford, Michigan, January 1994. Michigan Department of Environmental Quality (MDEQ), Public water supply intakes in Michigan: Great Lakes and connecting waters. Appendix N - public water supply intake map, 1999. MDEQ, Quality Assurance Project Plan for Region 5 Superfund Site Assessment and Brownfield Activities in Michigan, January 16, 2003. MDEQ, Community Water Supply Inventory. A Microsoft Excel workbook containing community water supply information, courtesy of Ms. Kristen S. Philip, Resource Specialist, MDEQ Water Bureau Field Operations Section, Lansing, Michigan, January 16, 2004. MDEQ, Remediation Division (RD) Operational Memorandum No. 1, Part 201 Cleanup Criteria and Part 213 Risk-based Screening Levels, March 25, 2011. MDEQ, RRD Operational Memorandum No. 4 (Site Characterization and Remediation Verification), Attachment 3 (Sediments), Interim Final, August 2, 2006. Michigan Department of Information Technology (MDIT), Aerial photographs that include the Wolverine World Wide Former Tannery site: 1992, 1998. Michigan Department of Environmental Quality, (MDEQ), Remediation Division, Superfund Section, Wolverine World Wide Former Tannery site file, June 2012. Rose & Westra, Inc., Wolverine World Wide - Former Rockford, Michigan TanneryPost Demolition Environmental Investigation, September 19, 2011. 17 �Rose & Westra, Inc., Wolverine World Wide (WWW}- Former Rockford, Michigan Tannery - Round 2 Environmental Investigation, February 6, 2012. United States Geological Survey, Cannonsburg Quadrangle, Mich., 7.5 minute series, 1972; Cedar Springs Quadrangle, Mich., 7.5 minute series, 1967, photorevised 1972; Cedar Springs SW Quadrangle, Mich., 7.5 minute series, 1967, photorevised 1972; Evans Quadrangle, Mich. , 7.5 minute series, 1972, photorevised 1982; Rockford Quadrangle, Mich., 7.5 minute series, 1967, photorevised 1981; Sparta Quadrangle, Mich., 7.5 minute series , 1967, photorevised 1972. 18 �FIGURES �Figure 1 Site Location f ~~ • 'I - - --1,:" ,\ , , I I Wolverine World Wide Former Tannery Site Boundary - Roads CJ Water Bodi es 0 0.25 0.5 1 Miles Compiled by: Leni L. Steiner-Zehender June 2012 Souroe : Michigan Geographic Data Library �Figure 2 Historical/Current Site Features Legend = White Pine Trail Site Boundary 0 75 150 300 450 --==--=======---• Feet Compiled by: Leni Steiner-Zehender June 2012 Soc1roe: Michigan Geographic Data Library �Figure 3 Soil Sample Locations ~";::-:"'~....-:r-..-- ~-=:1"11::'r'- - : ~ ~ - ~- N Legend \V . ~.-: ~E S-1 Soil Sample Locations . _ __ __ _ _ _ _:___ _ ___J "'<l,W s Q■-1•2=5=2::J5Q·--5■Q=Q==:::=i75Q Feet ;::ep~1 2by. LeniStein«-Zehender Soi.rce: Michigan GeogaphlcOala Library & GPS Data �Figure 4 Groundwater Sample Locations 0 Legend 0 MW-1 Monitoring Well Locations 0 P-1 & RP-O1 Piezorneter/River Piezorneter Locations 25 50 100 150 200 -==-=---======--■ Feet Compiled by: Leni Steiner-Zehender June 2012 Source: Michigan Geographic Data libraiy & GPS Data N w W~E s �Figure 5 Sediment Sam le Locations r.-:l'r'T--::=:'l"-ir=":::--xni~~~=-T:""W"--::-tllll!'ll9"III~~-""'. Legend 0 Sediment Sample March 2012 .& Sediment Sample December 2011 ii~m.rrr=~em~~;;i 0 125 250 500 750 1,000 -c=i•-==---i::::::=====---- Feet ■ Compiled by: Leni Steiner-Zehender June 2012 Source : Michigan Geographic Data Library & GPS Data �07 08 09 10 Figure 6 4 Mile Site Radius Map 10 09 13 14 15 CoUt Uan I Legend 24 23 22 ® D 0 Groundwater Wells Site Boundary Radius Ring c:J Township . 00 0 0 00 & 0 25 26 27 Section 0{/ @ 0_ ~0 ~:;} 0 0 of 06 _ N I w · ·· . 01 . . . .E s 14 15 K 13 ·.-. 23 22 0 0.5 2 Miles 24 ~uon~p~~2by: Leni Steiner•Zehender I 27 P-• 26 Source : Michigan Geographic Data Library 25 �Figure 7 15 Mile Target Distance Limit Map Legend LJ Site Bounday ~ 15 llfile Target Distance Limit - - WeUand Fromage (14.45 Miles TotaO k ~ ::~ Naion~ Wetlands lnvertory MNFI - State Threatened & Endangered Species 0 0.5 2 Miles N * W . E s Ccmpiled by: Leni Steiner-Zehender June 2012 Source: Michigan Geographic Data Library & Michigan National Features lnvemory �TABLES �TABLE 1 DEEP SOIL SAMPLE DATA SUMMARY Wolverine World Wide Former Tannery Overall Deep Soil Data Summary for WWW colleceted samples Number of Samples: 12 Concentrations in micrograms per kilogram (ug/kg - parts per billion) Analyses: VOA- 12 / SVOA- 12 / lnorganics - 12 / Ammonia, Cyanide, Sulfide - 8 Part 201 Lowest Highest Non-residential Part 201 GSI # of Cone. Cone. Background Direct Contact Protection Analyte/Compound Detects Detected Detected Cone. Criteria Criteria VOA 1,2-Dichlorobenzene 1 2,300 50U 210,000 280 1,4-Dichlorobenzene 1 230 50U 1,900,000 360 Ethyl benzene 1 120 50U 140,000 360 2-Methylnaphthalene 1 470 250U 26,000,000 4,200 Naphthalene 1 340 250U 52,000,000 730 n-Propylbenzene 1 87 50U 8,000,000 Toluene 1 380 50U 250,000 5,400 1,2,3-Trimethylbenzene 1 sou 160 ----1,2,4-Trimethylbenzene 1 220 50U 110,000 570 1,3,5-Trimethylbenzene 1 62 50U 94,000 1,100 Xylenes (total) 1 970 150U 150,000 820 Page 1 of7 # of Samples Exceeding Criteria 1 �TABLE 1 DEEP SOIL SAMPLE DATA SUMMARY Wolverine World Wide Former Tannery Overall Deep Soil Data Summary for WWW colleceted samples Number of Samples: 12 Concentrations in micrograms per kilogram (ug/kg - parts per billion) Analyses: VOA - 12 / SVOA- 12 / lnorganics - 12 / Ammonia, Cyanide, Sulfide - 8 Part 201 Lowest Highest Non-residential Part 201 GSI # of Cone. Cone. Background Direct Contact Protection Analyte/Compound Detects Detected Detected Cone. Criteria Criteria SVOA Acenaohthene 2 340 500 330U 130,000,000 8,700 Acenaphthylene 1 360 330U 5,200,000 --5 780 1,200 330U Anthracene 730,000,000 --410 Benzo(a)anthracene 6 3,800 330U 80,000 --Benzo(a)pyrene --360 3,100 330U 8,000 5 2,700 Benzo(b)fluoranthene 6 360 330U 80,000 ----Benzo(g, h, i)Perylene 3,000 7,000,000 4 960 330U Benzo(k)fluoranthene 6 240 2,700 330U 800,000 --Benzoic acid 1 710 330U 1,000,000,000 --Chrysene 6 820 4,300 330U 8,000,000 --Dibenzofuran 1 500 330U 1,700 --Fluoranthene 5 1,700 7,800 330U 130,000,000 5,500 87,000,000 Fluorene 3 360 380 330U 5,300 2,100 lndeno(1,2,3-cd)ovrene 5 450 330U 80,000 --2-Methvlnaphthalene 1 800 330U 26,000,000 4,200 Naphthalene 1 910 330U 52,000,000 730 Phenanthrene 6 640 4,500 330U 5,200,000 2,100 1 5,000 330U 12,000,000 Phenol 9,000 --Pyrene 5 730 6,800 330U 84,000,000 Page 2 of7 # of Samples Exceeding Criteria 2 4 �TABLE 1 DEEP SOIL SAMPLE DATA SUMMARY Wolverine World Wide Former Tannery Overall Deep Soil Data Summary for WWW colleceted samples Number of Samples: 12 Concentrations in micrograms per kilogram (ug/kg - parts per billion) Analyses: VOA- 12 / SVOA- 12 / lnorganics - 12 / Ammonia, Cyanide, Sulfide - 8 Part 201 Highest Lowest Non-residential Part 201 GSI # of Cone. Cone. Background Direct Contact Protection Detected Cone. Analyte/Compound Detects Detected Criteria Criteria lnorganics 12 360,000 2,100 37,000 Arsenic 650 4,600 3,100 650,000 27,000 130,000,000 Barium 12 440,000 17,000 Cadmium 10 69 63 2,100,000 3,600 --160,000 120,000,000 1,200,000 Calcium 12 --Chromium ftotall 12 4,200 49,000,000 8,700 9,200,000 3,300 Hexavalent Chromium 7 1,100 17,000 500U 9,200,000 3,300 Copper 12 1,400 740,000 2,900 73,000,000 750,000 Lead 11 3,400 930,000 5,000 900,000 2,800,000 Mercury ftotall 8 56 630 50U 580,000 50; 1.2 Selenium 10 240 2,200 270 9,600,000 400 4 180 450 100U 9,000,000 100; 27 Silver Zinc 12 3,800 1,000,000 14,000 630,000,000 170,000 Ammonia 7 4,100 950,000 No sample 580 --No sample Cyanide 5 120 8,300 250,000 100 --Sulfide 6 4,600 7,600,000 No sample --- Page 3 of 7 # of Samples Exceeding Criteria 5 1 2 12 3 1 8 8 4 3 7 5 �TABLE 1 DEEP SOIL SAMPLE DATA SUMMARY Wolverine World Wide Former Tannery Overall Deep Soil Data Summary for U.S. EPA split samples Number of Samples: 11 Concentrations in ug/kg Analyses: VOA - 10 / SVOA - 11 / lnorQanics - 11 # of Analyte/Compound VOA Acetone Benzene n-Butylbenzene sec-b utvlbenzene Carbon disulfide Cyclohexane 1,2-Dichlorobenzene 1,4-Dichlorobenzene Ethvlbenzene lsopropylbenzene 4-lsooroovltoluene n-Propylbenzene Toluene Trichlorofluoromethane 1,2,4-Trimethvlbenzene 1,3,5-Trimethylbenzene Xylenes (total) # of Detects 3 1 2 1 1 2 2 2 1 2 1 1 7 3 2 2 3 Lowest Cone. Detected Highest Cone. Detected 150J 250J 30J 40J 16J 53J 79J 1,900 390 15J 13J 37J 19J 20J 21J 130 28J 320 11J 30J 28J 8.5J 11J 10J 14J 64J 15J 170 Part 201 Non-residential Background Direct Contact Cone. Criteria 140U 55U 55U 55U 280U 280U 110U 110U 55U 280U 110U 110U 110U 110U 110U 110U 110U Page 4 of 7 73,000,000 400,000 8,000,000 8,000,000 280,000 Part 201 GSI Protection Criteria 34,000 4,000 --- --- --- ----- 210,000 1,900,000 140,000 390,000 280 360 360 3,200 -- ----- 8,000,000 250,000 560,000 110,000 94,000 150,000 Samples Exceeding Screening Levels 5,400 --570 1,100 820 1 1 �TABLE 1 DEEP SOIL SAMPLE DATA SUMMARY Wolverine World Wide Former Tannery Overall Deep Soil Data Summary for U.S. EPA split samples Number of Samples: 11 Concentrations in ug/kg Analyses: VOA - 10 / SVOA- 11 / lnorganics - 11 Analyte/Compound SVOA Acenaphthene Acenaphthvlene Anthracene Benzo( a)a nth racene Benzo(a)pyrene Benzo(b)fl uo ranthene Benzo(g, h, i)Pervlene Benzo(k)fluoranthene Bis(2-ethyl hexyl)p hthalate Butvlbenzylphthalate Chrysene Dibenz(a,h)anthracene Dibenzofuran 1,4-dichlorobenzene Fluoranthene Fluorene lndeno(1,2,3-cd)pyrene Part 201 Non-residential Background Direct Contact Cone. Criteria # of Detects Lowest Cone. Detected Highest Cone. Detected 4 4 7 8 7 8 8 8 94J 23J 82J 18J 15J 16J 8.7J 13J 960J 330J 2,400J 6.000J 4,400J 7,700J 2,600J 3,200J 410U 410U 410U 410U 410U 2.8J 2.4J 2.4J 130,000,000 5,200,000 730,000,000 80,000 8,000 80,000 7,000,000 800,000 4 2 10 4 5 1 8 6 7 80J 23J 15J 140J 39J 7,500J 59,000 5,200J 1,300J 760J 31J 13,000 1,500J 2,500J 11J 2.8J 2.0J 410U 410U 410U 410U 410U 410U 10,000,000 310,000 8,000,000 8,000 19J 31J 7.7J Page 5 of7 --360 130,000,000 87,000,000 80,000 Part 201 GSI Protection Criteria # ot Samples Exceeding Screening Levels 8,700 ------- ----------- 120,000 --- --1,700 1,900,000 5,500 5,300 --- 1 �TABLE 1 DEEP SOIL SAMPLE DATA SUMMARY Wolverine World Wide Former Tannery Overall Deep Soil Data Summary for U.S. EPA split samples Number of Samples: 11 Concentrations in ug/kg Analyses: VOA - 10 / SVOA - 11 / lnorganics - 11 # of Analyte/Compound SVOA 2-Methvlnaphthalene Naphthalene N-nitroso-diphenvlamine Phenanthrene Pyrene lnorganics Arsenic Barium Cadmium Calcium Chromium ftotall Hexavalent Chromium Copper Lead Mercury ftotall Selenium Silver Zinc # of Detects Part 201 Non-residential Background Direct Contact Cone. Criteria Lowest Cone. Detected Highest Cone. Detected 47J 27J 410U 410U 410U 410U 2.8J 26,000,000 52,000,000 7,800,000 5,200,000 84,000,000 1,800J 30,000 59J 1,200,000 6,100 2,S00U 3,300 4,300J 9.4J 400 10J 16,000 37,000 130,000,000 2,100,000 5 8 1 7 10 460J 26J 320J 510J 640J 11,000 14,000 11 11 11 11 11 11 11 11 11 8 11 11 2,900 11,000 80 1,000,000 5,800 290J 3,000 5,300 10J 260 15J 18,000 14,000 190,000 1,300 78,000,000 480,000 6,300 76,000 260,000 640 1,700 310 430,000 Page 6 of7 Part 201 GSI Protection Criteria Samples Exceeding Screening Levels 4,200 730 --- 2,100 1 --4,600 440,000 3,600 --- --- 9,200,000 9,200,000 73,000,000 900,000 580,000 9,600,000 9,000,000 630,000,000 3,300 3,300 750,000 2,800,000 50; 1.2 400 100;27 170,000 8 11 3 7 7 3 1 �TABLE 1 DEEP SOIL SAMPLE DATA SUMMARY Wolverine World Wide Former Tannery Overall Deep Soil Data Summary for U.S. EPA split samples Number of Samples: 11 Concentrations in ug/kg Analyses: VOA - 10 / SVOA - 11 / lnorganics - 11 Analyte/Compou nd lnorganics Ammonia Cyanide Sulfide # of Detects Lowest Cone. Detected Highest Cone. Detected 11 8 5 9,190 38J 32,000 556,000 550 200,000 Part 201 GSI Protection Criteria # of Samples Exceeding Screening Levels 250,000 580 100 11 4 --- --- Part 201 Non-residential Background Direct Contact Cone. Criteria 39,200 43J 12,000U J - Estimated concentration. U - Non-detect at reported detection limit. --- - No criteria available. Page 7 of7 --- �TABLE 2 SURFICIAL SOIL SAMPLE DATA SUMMARY Wolverine World Wide Former Tannery Overall Surficial Soil Data Summary for WWW colleceted samples Concentrations in ug/kg Number of Samples: 4 Analvses: VOA - 4 I SVOA - 4 I lnorganics - 4 Analyte/Compound VOA No detections SVOA Anthracene Benzo(a)a nth race ne Benzo(a)ovrene Benzo(b)fluoranthene Benzo(a, h, i) Pervlene Benzo(k)fluoranthene Chrvsene Fluoranthene lndeno(1,2,3-cd)ovrene Phenanthrene Pyrene # of Detects Lowest Cone. Detected Highest Cone. Detected 2 2 2 2 2 2 2 3 2 3 3 460 2,000 2,000 1,800 1,300 1,800 2,500 480 1,100 360 450 680 2,700 2,500 2,400 1,600 2,100 3,200 5,800 1,400 3,300 5,100 Part 201 Non residential Background Direct Contact Cone. Criteria 330U 330U 330U 330U 330U 330U 330U 330U 330U 330U 330U Page 1 of S 730,000,000 80,000 8,000 80,000 7,000,000 800,000 8,000,000 130,000,000 80,000 5,200,000 84,000,000 Part 201 GSI Protection Criteria #of Samples Exceeding Criteria ---------- --5,500 2 -2,100 -- 2 �TABLE 2 SURFICIAL SOIL SAMPLE DATA SUMMARY Wolverine World Wide Former Tannery Overall Surficial Soil Data Summary for WWW colleceted samples Concentrations in ug/kg Number of Samples: 4 Analyses: VOA- 4 / SVOA - 4 / lnorganics - 4 Analyte/Compound lnorganics Arsenic Barium Cadmium Calcium Chromium [total] Hexavalent Chromium Copper Lead Mercury [total] Selenium Silver Zinc # of Detects 4 4 4 4 4 3 4 4 3 4 2_ 4 Lowest Cone. Detected Highest Cone. Detected 11,000 3,600 50,000 120,000 130 860 13,000,000 37,000,000 65,000 180,000 1,400 540 15,000 31,000 14,000 170,000 88 320 210 490 150 100 210,000 42,000 Part 201 Non residential Background Direct Contact Cone. Criteria 2,500 30,000 180 2,200,000 6,800 soou 4,500 35,000 50U 330 100U 81,000 Page 2 of 5 37,000 130,000,000 2,100,000 --9,200,000 9,200,000 73,000,000 900,000 580,000 9,600,000 9,000,000 630,000,000 Part 201 GSI Protection Criteria 4,600 440,000 3,600 --3,300 3,300 750,000 2,800,000 50; 1.2 400 100;27 170,000 # of Samples Exceeding Criteria 3 4 3 2 1 1 �TABLE 2 SURFICIAL SOIL SAMPLE DATA SUMMARY Wolverine World Wide Former Tannery Overall Surficial Soil Data Summary for U.S. EPA split samples Concentrations in ug/kg Number of Samples: 4 Analyses: VOA - 4 I SVOA - 4 I lnorganics - 4 Analyte/Compound VOA Toluene Trichlorofluoromethane 1,2,4-Trimethvlbenzene Xylenes (total) SVOA Acenaphthene Acenaohthvlene Anthracene Benzo(a)anthracene Benzo(a)ovrene Benzo(b)fluoranthene Benzo(q,h,i)Pervlene Benzo(k)fluoranthene Bis(2-ethvlhexvl)ohthalate Butvlbenzylphthalate Chrvsene Dibenz(a,h)anthracene Dibenzofuran Fluoranthene Fluorene Part 201 Non residential Background Direct Contact Criteria Cone. Part 201 GSI Protection Criteria Lowest Cone. Detected Highest Cone. Detected 3 2 1 1 11J 19J 19J 20J 7.4J 14J 150U 150U 150U 150U 250,000 560,000 110,000 150,000 5,400 3 4 4 4 4 4 4 4 2 4 4 2 3 4 4 43J 22J 49J 250J 250J 400J 150J 120J 45J 13J 220J 320J 34J 420J 18J 240J 250J 650J 3,700 2,400 4,900 1,600J 1,300J 210J 23J 2,500 720J 150J 4,800 340J 430U 430U 3.1J 2.3J 15J 42J 14J 11J 27J 430U 19J 430U 430U 31J 430U 130,000,000 5,200,000 730,000,000 80,000 8,000 80,000 7,000,000 800,000 10,000,000 310,000 8,000,000 8,000 8,700 # of Detects Page 3 of 5 --130,000,000 87,000,000 --570 820 --------- - - ----- 120,000 ----1,700 5,500 5,300 #of Samples Exceeding Criteria �TABLE 2 SURFICIAL SOIL SAMPLE DATA SUMMARY Wolverine World Wide Former Tannery Overall Surficial Soil Data Summary for U.S. EPA split samples yoncentrations in ug/kg Number of Samples: 4 Analyses: VOA - 4 I SVOA - 4 / lnorganics - 4 # of Detects Lowest Cone. Detected Highest Cone. Detected lndeno(1,2,3-cd)pyrene 2-Methvlnaphthalene Naphthalene Phenanthrene Pyrene lnorganics 4 4 4 4 4 150J 5.9J 12J 190J 400J 2,000J 74J 110J 3,600 5,900 Arsenic Barium Cadmium Calcium Chromium ftotall Hexavalent Chromium Copper Lead Mercury {total] Selenium Silver Zinc Ammonia Cyanide 4 4 4 4 4 2 4 4 4 4 4 4 Analyte/Compound SVOA 4 4 4,600 9,000 40,000 130,000 180 800 11,000,000 56,000,000 22,000 120,000 1,400J 360J 12,000 33,000 24,000 160,000 40J 340 620 1,200 110 41J 65,000 200,000 316,000 102,000 71J 410 Part 201 Non residential Background Direct Contact Cone. Criteria Part 201 GSI Protection Criteria --- 11J 8.8J 5.7J 21J 37J 80,000 26,000,000 52,000,000 5,200,000 84,000,000 4,200 730 2 ,100 2,200 27,000 170 1,600,000 4,600 2,600U 3,100 31,000 19J 340 18J 71,000 332,000 150 37,000 130,000,000 2,100,000 4,600 440,000 3,600 -- --- 9,200,000 9,200,000 73,000,000 900,000 580,000 9,600,000 9,000,000 630,000,000 --250,000 3,300 3,300 750,000 2,800,000 50; 1.2 400 100;27 170,000 580 100 Page 4 of 5 # of Samples Exceeding Criteria 1 --3 4 3 4 1 1 4 2 �TABLE 2 SURFICIAL SOIL SAMPLE DATA SUMMARY Wolverine World Wide Former Tannery Analyte/Compound # of Detects Lowest Cone. Detected Highest Cone. Detected Part 201 Non residential Background Direct Contact Cone. Criteria J - Estimated concentration. U - Non-detect at reported detection limit. --- - No criteria available. Page 5 of 5 Part 201 GSI Protection Criteria # of Samples Exceeding Criteria �TABLE 3 GROUNDWATER SAMPLE DATA SUMMARY Wolverine World Wide Former Tannery Overall Groundwater Data Summary for WWW colleceted samples Number of Samples: 9 Concentrations in micrograms per liter (ug/I - parts per billion} Analyses: VOA - 3 / SVOA - 3 / lnorganics - 3 / Ammonia, Arsenic, Cyanide - 6 Part 201 Lowest Highest Residential # of Cone. Cone. Background Drinking Water Part 201 GSI Analyte/Compound Detects Detected Detected Cone. Criteria Criteria # of Samples Exceeding Criteria VOA 1, 1-Dichloroethane SVOA 4-Chloro-3-methylphenol Phenol lnorganics Arsenic Boron Cadmium Chromium ftotall Hexavalent Chromium Copper Iron Maonesium Molybdenum Nickel Sodium Vanadium Zinc 1 3 NA 880 740 1 1 9 12 NA NA 150 4,400 7 450 1 30 770 0.3 54 85 6 9,800 36,000 50 30 310,000 9 10 NA NA NA NA NA NA NA NA NA NA NA NA NA 10 500 5 100 100 1,000 300 400,000 73 100 120,000 5 2,400 10 5,000 3 11 11 13 2 1 --- 3 7 3 1 2 2 2 3 3 1 1 3 1 1 2 210 19 10 4 490 28,000 90,000 Page 1 of2 2 1 --- 3,200 73 --- 2 12 170 1 �TABLE 3 GROUNDWATER SAMPLE DATA SUMMARY Wolverine World Wide Former Tannery Overall Groundwater Data Summary for WWW colleceted samples Number of Samples: 9 Concentrations in micrograms per liter (ug/I - parts per billion) Analyses: VOA - 3 I SVOA - 3 / lnorganics - 3 / Ammonia, Arsenic, Cyanide - 6 Part 201 Highest Lowest Residential Cone. Background Drinking Water Part 201 GSI Cone. # of Detected Cone. Criteria Analyte/Compound Detects Detected Criteria 3,800 1,300 3 NA Acetate 7,700 4,200 NA 46,000 29 Ammonia 9 10,000 290 3 NA 250,000 480,000 97,000 Chloride --Cyanide 3 16 NA 200 5 5.2 1 500 NA --Formate --1 490 NA 10,000 --Nitrate 1 NA Nitrite 780 1,000 --2 NA 430 120 Phosphorus (total) 63,000 1,000 NA 500,000 250,000 --190,000 Sulfates 3 J - Estimated concentration. U - Non-detect at reported detection limit. NA - Not available. --- - No criteria available. Page 2 of 2 # of Samples Exceeding Criteria 9 1 2 2 �TABLE 4 SEDIMENT SAMPLE DATA SUMMARY Wolverine World Wide Former Tannery Overall Sediment Data Summary for WWW colleceted samples Number of Samples: 12 Concentrations in ug/kg Analvses: VOA - 12 / SVOA - 12 / lnoroanics - 12 Analyte/Compound lnorganics Arsenic Barium Cadmium Calcium Chromium rtotall Hexavalent Chromium Coooer Lead Mercurv ftotall Zinc # of Detects Lowest Cone. Detected Highest Cone. Detected 12 12 12 12 12 10 12 12 9 12 3,700 27,000 200 18,000,000 18,000 510 5,600 10,000 120 29,000 10,000 160,000 1,200 120,000,000 520,000 6,200 66,000 130,000 1,600 210,000 Part 201 Part 201 # of Sediment Sediment Samples Background Screening Level Screening Level Exceeding Cone. Lowest Highest Criteria 3,000 38,000 110 10,000,000 7,600 500U 4,300 4,500 Page 1 of 4 sou 19,000 5,900 85,000 --- --- 580 10,000 --- --- 26,000 145,000 --- --- 16,000 31,000 150 98,000 390,000 250,000 2,000 820,000 10 6 10 4 7 6 5 �TABLE4 SEDIMENT SAMPLE DATA SUMMARY Wolverine World Wide Former Tannery Overall Sediment Data Summary for U.S. EPA split samples Concentrations in ug/kg Number of Samples: 12 Analyses: VOA-12 / SVOA-12 / lnorganics -12 Analyte/Compound lnorganics Arsenic Barium Cadmium Calcium Chromium ftotall Hexavalent Chromium Copper Lead Mercury ftotall Zinc # of Detects Lowest Cone. Detected Highest Cone. Detected 12 12 12 12 12 6 12 12 12 12 3,300 21,000 180 15,000,000 14,000 S00J 3,400 9,600 35J 26,000 12,000 140,000 1,300 130,000,000 450,000 1,200J 50,000 92,000 2,100 290,000 Part 201 Part 201 # of Sediment Sediment Samples Background Screening Level Screening Level Exceeding Lowest Highest Cone. Level 3,000 33,000 170 9,500,000 6,300 1, 100J 2,700 4,500 22J 22,000 Page 2 of4 5,900 --580 --26,000 --16,000 31,000 150 98,000 85,000 7 --10,000 --145,000 --390,000 250,000 2,000 820,000 5 7 3 5 7 5 �TABLE 4 SEDIMENT SAMPLE DATA SUMMARY Wolverine World Wide Former Tannery Overall Sediment Data Summary for MDEQ collected samples Number of Samples: 10 Concentrations in ug/kg Analyses· PCB - 4 / SVOA - 5 / lnorganics - 10 Analyte/Compound # of Detects Part 201 Part 201 # of Sediment Sediment Samples Background Screening Level Screening Level Exceeding Cone. Highest Lowest Level Lowest Cone. Detected Highest Cone. Detected 360 330 620 550 NA NA 31 44 10,200 8,500 2 2 2,400 12,000 220 20,000,000 5,700 16,000 99,000 700 91,000,000 430,000 390J 15,000 30,000 5,100 1,200 230 92,000 3,000 38,000 170 10,000,000 7,600 1, 100J 4,300 4,500 22J 5,900 85,000 2 NA NA ----- --- 2,200 98,000 820,000 PCB No PCBs detected SVOA Fluoranthene Pyrene lnorganics Arsenic Barium Cadmium Calcium Chromium ftotall Hexavalent Chromium Copper Lead Mercury ftotall Selenium Silver Zinc 2 2 10 10 8 10 10 1 10 10 6 10 3 10 2,000 2,500 180 230 140 16,000 Page 3 of 4 --- --- 580 10,000 --- --- 26,000 145,000 --- --- 16,000 31,000 150 390,000 250,000 2,000 --- 3 3 6 �TABLE 4 SEDIMENT SAMPLE DATA SUMMARY Wolverine World Wide Former Tannery Analyte/Compound # of Detects Lowest Cone. Detected Highest Cone. Detected Part 201 Part 201 # of Sediment Sediment Samples Background Screening Level Screening Level Exceeding Cone. Lowest Highest Level J - Estimated concentration. U - Non-detect at reported detection limit. NA - Not available. --- - No criteria available. Page 4 of 4 �APPENDIX A PART 201 GENERIC CLEANUP CRITERIA AND SCREENING LEVELS �Attachment 1 TABLE 1. GROUNDWATER: RESIDENTIAL AND NONRESIDENTIAL PART 201 GENERIC CLEANUP CRITERIA AND SCREENING LEVELS; PART 213 TIER 1 RISK-BASED SCREENING LEVELS (RBSL.s) DOCUMENT RELEASE DATE: MARCH 25, 2011 All criteria, unless otherwise noted, are expressed in units of parts per billion (ppb). One ppb is equivalent to one microgram per liter (ug/L). Criteria with six or more digits are expressed in scientific notation. For example, 200,000 is presented as 2.0E+S. The lowest generic groundwater criterion for a given hazardous substance is presented in a bold box. A footnote is designated by a letter in parentheses and is explained in the footnote pages that follow the criteria tables. When the risk-based criterion Is less than the target detection limit (TDL), the TDL is listed as the criterion (R 299.5707). In these cases, two numbers are present in the cell. The first number is the criterion (i.e., TDL), and the second number is the risk-based or solubility value, whichever is lower (R299.5708). Criteria were originally promulgated December 21, 2002 within the Administrative Rules for Part 201, Environmental Remediation, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. This table reflects revisions to the criteria pursuant to the December 201 o Part 201 amendments and new criteria consistent with the provisions of R299.5706a. The effective dates of the criteria and screening levels in this table vary. Please contact the Remediation Division Toxicology Unit for additional information. Guidesheet Number Hazardous Substance Acenaphthene Acenaphthylene - Chemical Abstract Service Number #1 #2 #3 Groundwater Residential Nonresidential Surface Water Drinking Water Drinking Water Interface Criteria & RBSLs Criteria & RBSLs Criteria & RBSLs #4 #5 #6 Residential Nonresidential Groundwater Groundwater Groundwater Volatili:tatlon Contact Volatilization to to Indoor Air Criteria & RBSLs Indoor Air Inhalation Inhalation Criteria & RBSLs Criteria & RBSLs #7 Water Solubility #8 #'iJ Flammability and Explosi vity Screening Level Acute Inhalation Screening Level 83329 1,300 3,800 38 4,200 (S) 4,200 (S) 4 ,200 (S) 4,240 ID ID 208968 52 150 ID 3,900 ($) 3,900 (S) 3,900 (S) 3.930 JD ID 2.3E+6 4.2E+7 1.0E+9 8.9E+6 2.6E-+-7 Acetaldehyde (I) 75070 950 2,700 130 1.1E+6 Acetate 71501 4,200 12,000 (G) ID JD ID ID ID ID Aceficacid 64197 4,200 12,000 (G) NLV NLV 1.BE+8 6.0E+9 1.0E+9 (D) 1.0E+9 (D) Acetone (l) 67641 730 2,100 1,700 1.0E+9 (D,S) 1.0E +9 (D,S) 3.1E+7 1.0E+9 1.5E+7 1.0E+9 (D) 140 400 NA 2.4E+7 4.5E+7 5.6E+6 2.00E+8 2.1E+7 2.0E+8 6.1E+6 (S) 6.1E-+-6 (S) 6.1E+6 ID ID 4,200 3.4E+6 2.1 0E+B 6.7E+6 3.4E+5 Acetonitrile 75058 I Acetophencne 98862 1,500 4,400 ID 6.1E+6 (S) Acrolein (I) 107028 120 330 NA 2,100 Acrylamide 79061 0.5 (A) 0.5 (A) 10(X) NLV NLV 13,000 2.20E+9 NA ID Acrylic acid 79107 3,900 11,000 NA 1.2E+7 2.8E+7 7.6E+7 1.0E+9 1.0E+9 (D) ID 107131 2.6 11 2.0 (M); 1.2 34,000 1.9E+5 14,000 7.50E+7 6.4E+6 ID Acrylonitrile (I) Alachlor" 15972608 2.0 (A) 2.0 (A) 11 (X) NLV NLV 1,700 1.83E+5 10 ID Aldicarb 116063 3.0 (A) 3.0 (A) NA NLV NLV 1.2E+5 6.00E+S 10 ID Aldicarb sulfone 1646884 2.0 (A) 2.0 (A) NA NLV NLV 2.1E+6 7.SOE+6 ID ID Aldicarb sulfoxide 1646873 4.0 (A) 4.0 (A) NA NLV NLV 2.7E+6 2.80E+7 ID ID Aldrin 309002 0.098 0.4 0.01 (M); 8.7E-6 180 ($) 180 (S) 0.34 (AA) 180 ID 10 Aluminum (B) 7429905 50 (V) 50 (V) NA NLV NLV 6.4E+7 NA ID ID Ammonia 7664417 10,000 (N) 10,000 (N) (CC) 3.2E+6 7.1E+6 ID 5.30E+8 ID 3.SE+G t-Amyl methyl ether (TAME) 994058 190(E) 190 (E) NA 2.GE+S 5.7E+5 2.6E+6 (S) 2.64E+6 NA NA 53 220 4.0 NLV NLV 1.4E+5 3.60E+7 NA ID Aniline March 25, 2011 62533 Page 1 of 14 �Attachment 1 TABLE 1. GROUNDWATER: RESIDENTIAL AND NONRESIDENTIAL PART 201 GENERIC CLEANUP CRITERIA AND SCREENING LEVELS; PART 213 TIER 1 RISK-BASED SCREENING LEVELS (RBSLs) DOCUMENT RELEASE DATE: MARCH 25, 2011 All criteria, unless otherwise noted, are expressed in units of parts per billion (ppb). One ppb is equivalent to one microgram per liter (ug/L). Criteria with six or more digits are expressed in scientific notation. For example, 200,000 is presented as 2.0E+S. The lowest generic groundwater criterion for a given hazardous substance is presented in a bold box. A footnote is designated by a letter in parentheses and is explained in the footnote pages that follow the criteria tables. When the risk-based criterion is less than the target detection limit (TDL), the TDL is listed as the criterion (R 299.5707). In these cases, two numbers are present in the cell. The first number is the criterion (i.e., TDL), and the second number is the risk-based or solubility value, whichever Is lower (R299.5708). Criteria were originally promulgated December 21, 2002 within the Administrative Rules for Part 201, Environmental Remediation, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. This table reflects revisions to the criteria pursuant to the December 2010 Part 201 amendments and new criteria consistent with the provisions of R299.5706a. The effective dates of the criteria and screening levels in this table vary. Please contact the Remediation Division Toxicology Unit for additional information. Guidesheet Number Hazardous Substance Anthracene - Chemical Abstract Service Number #1 #2 #3 Groundwater Residential Nonresidential Surface Water Drinking Water Drinking Water Interface Criteria & RBSLs Criteria & RBSLs Criteria & RBSLs 120127 43 ($) 43 (S) 6.0 (A) #4 #5 #6 Residential Nonresidential Groundwater Groundwater Groundwater Contact Volatilization Volatilization to to Indoor Air Criteria & RBSLs Indoor Air Inhalation Inhalation Criteria & RBSLs Criteria & RBSLs #7 Water Solubility #8 #9 Flammability and Explosivity Screening Level Acute Inhalation Screening Level ID 43 (S) 43 (S) 43 ($) 43.4 ID ID NLV 68,000 NA ID ID Antimony 7440360 6.0 (A) 130 (X) NLV Arsenic 7440382 10 (A) 10 (A) 10 NLV NLV 4,300 NA ID ID Asbestos (BB) 1332214 7.0E-+-6 f/ml (A) 7.0E-+-6 f/ml (A) NA NLV NLV ID NA NA ID Atrazine 1912249 3.0 (A} 3.0 (A) 7.3 NLV NLV 5,400 70,000 ID ID 103333 23 94 ID 6,400 (S} 6,400($) 1,600 6,400 ID ID 2,000 (A) NLV 1.4E-+-7 NA ID ID Azobenzene Barium (8) 7440393 2,000 (A) (G) NLV Benzene (!) 71432 5.0 (A) 5.0 (A) 200 (X) 5,600 35,000 11,000 1.75E-+-6 68, 000 67,000 Benzidine 92875 0.3 (M}: 0.0037 0.3 (M); 0.015 0.3 (M); 0.073 NLV NLV 7.1 5.20E+5 ID ID Benzo(a}anthracene (Q) 56553 2.1 8.5 ID NLV NLV 9.4($,M) 9.4 ID ID Ben:,:o(b)fluoranthene (Q) 205992 1.5 ($,AA) 1.5(S,M) 10 ID ID 1.5 (S.AA) 1.5 ID ID Benzo(k)fluoranthene (Q) 207089 1.0 (Ml: 0.8 (S) 1.0 {M); 0.8 ($) NA NLV NLV 0.8 ID ID Benzo(g,h,i)perylene 191242 1.0 (M); 0.26 ($) 1.0 (M); 0.26 (S) ID NLV NLV 0.26 ID ID Benzo(a)pyrene (Q) 50328 5.0 (A) 5.0 (A) ID NLV NLV 1.0 (M,M ); 0.8 /Sl 1.0 (M,M); 0.26 /SI 1.0 (M,M); 0.64 1.62 ID ID Benzoic acid 65850 32,000 92,000 NA NLV NLV 3.SE-+-6 (S) 3.50E+6 ID ID Benzyl alcohol 100516 10.000 29.000 NA NLV NLV 4.4E+7 (S) 4.40E+7 ID ID Benzyl chloride 100447 7.7 32 NA 12,000 77,000 3.600 4 .90E+S NA ID 74404 17 4.0(A) 4.0 (A) (G) NLV NLV 2.9E+5 NA ID ID ID 1.89E+7 ID ID Beryllium bis(2-Chloroethoxy)ethane 112265 bis(2-Chloroethyl)ether (I) 111444 bis(2- Ethylhe><yl)phthalate 117817 March 25, 2011 ID ID NLV NLV 2.0 8.3 1.0 (M); 0.79 38,000 2.1E+5 5,700 1.72E+7 1.7E+7 (S) 1.7E+7 (S) 6.0 (A} 6.0 (A) 25 NLV NLV 320 (M) 340 NA 340 (S) ID I :I Page 2 of 14 �Attachment 1 TABLE 1. GROUNDWATER: RESIDENTIAL AND NONRESIDENTIAL PART 201 GENERIC CLEANUP CRITERIA AND SCREENING LEVELS; PART 213 TIER 1 RISK-BASED SCREENING LEVELS (RBSLs) DOCUMENT RELEASE DATE: MARCH 25, 2011 All criteria, unless otherwise noted, are expressed in units of parts per billion (ppb). One ppb is equivalent to one microgram per liter (ug/L). Criteria with six or more digits are expressed in scientific notation. For example, 200,000 is presented as 2.0E+S. The lowest generic groundwater criterion for a given hazardous substance is presented in a bold box. A footnote is designated by a Jetter in parentheses and is explained in the footnote pages that follow the criteria tables. When the risk-based criterion is less than the target detection limit (TDL), the TDL is listed as the criterion (R 299.5707). In these cases, two numbers are present in the cell. The first number is the criterion (i.e., TDL), and the second number is the risk-based or solubility value, whichever is lower (R299.5708). Criteria were originally promulgated December 21, 2002 within the Administrative Rules for Part 201, Environmental Remediation, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. This table reflects revisions to the criteria pursuant to the December 2010 Part 201 amendments and new criteria consistent with the provisions of R299.5706a. The effective dates of the criteria and screening levels in this table vary. Please contact the Remediation Division Toxicology Unit for additional information. Guidesheet Number Hazardous Substance Boron (B) Bromate - Chemical Abstract Service Number 7440428 15541454 #1 #2 #3 Groundwater Nonresidential Surface Water Residential Drinking Water Drinking Water Interface Criteria & RBSLs Criteria & R8SLs Criteria & RBSLs 500 (F) 10 (A) #4 #5 #6 Residential Nonresidential Groundwater Groundwater Groundwater Volatilization Contact Volatilization to to Indoor Air Criteria & RBSLs Indoor Air Inhalation Inhalation Criteria & RBSLs Criteria & RBSLs #7 Water Solubility #8 #9 Flammability and Explosivity Screening Level Acute Inhalation Screening Level 5,000 (X) NLV NLV 6.2E+7 NA 10 ID 10 (A) 40 (X) NLV NLV 4,800 38,000 ID ID 500 (F) Bromobenzene (I) 108861 18 50 NA 1.8E+S 3.9E+5 12,000 4.13E+5 ID ID Sromodichloromethane 75274 80 (A,W} 80 (A,W} 10 4 ,800 37,000 14.000 6.74E+6 10 10 Bromoform 75252 80 {A,W} 80 (A,W} ID 4.7E+5 3.1E+6 (S) 1.4E+5 3.10E+6 10 10 74839 10 29 35 4 ,000 9,000 70,000 1.45E+7 ID ID NLV 8.8E+6 7.40E+7 4.7E+7 7.4E+7 (S) Bromomethane n-Sutanol (I) 71363 950 2,700 NA NLV 2-Sutanone (MEK) (I) 78933 13,000 36,000 2,200 2.4E+S (S) 2.4E+8 (S) 2.4E+S (S) 2.40E+8 ID 2.4E+8 ($) n-8utyl acetate 123864 550 1,600 NA 6.7E+6 (S) 6.7E+6 (S) 1.8E+6 6.70E+6 2.5E+6 6 .7E+6 (S) 1-Butyl alcohol 75650 3,900 11,000 NA 1.0E+9 (D,S) 1.0E+9 (D,S) 7.9E+7 1.0E+9 6.1E+7 ID NLV 2.700(S) 2,690 ID ID ID 5,900 NA ID ID Butyl benzyl phthalate 85687 1,200 2.700 (S) 67 (X) NLV n-Sutylbenzene 104518 80 230 ID ID sec-Butylbenzene 135968 80 230 ID ID ID 4,400 NA ID ID t-Sutylbenzene (I) 98066 80 230 JD ID ID 8,900 NA ID 10 7440439 5.0 (A) 5.0(A) (G,X) NLV NLV 1.9E+5 NA JD ID ID 33,400 10 JD 1.0E+9 (0) Cadmium (B) I Camphene (I) 79925 ID 10 NA 440 1,000 Caprolactam 105602 5,800 17,000 NA NLV NLV 3.9E+8 5.25E+9 NA 63252 700 2,000 NA ID ID 1.3E+5 (S) 1.25E+5 ID ID Carbazole 86748 85 350 10 (M); 4.0 NLV NLV 7.400 7,460 ID ID Carbofuran 1553662 40 (A) 40 (A) NA NLV NLV 3.4E+5 7.00E+S 10 10 75150 800 2,300 ID 2.SE+S 5.5E+5 1.2E+6 (S) 1.19E+6 13,000 ID Carbary! Carbon disulfide (l.R) March 25, 2011 Page 3 of 14 �Attachment 1 TABLE 1. GROUNDWATER: RESIDENTIAL AND NONRESIDENTIAL PART 201 GENERIC CLEANUP CRITERIA AND SCREENING LEVELS; PART 213 TIER 1 RISK-BASED SCREENING LEVELS (RBSLs) DOCUMENT RELEASE DATE: MARCH 25, 2011 All criteria, unless otherwise noted, are expressed in units of parts per billion (ppb). One ppb is equivalent to one microgram per liter (ug/L). Criteria with six or more digits are expressed in scientific notation. For example, 200,000 is presented as 2.0E+5. The lowest generic groundwater criterion for a given hazardous substance is presented in a bold box. A footnote is designated by a letter in parentheses and is explained in the footnote pages that follow the criteria tables. When the risk-based criterion is less than the target detection limit (TDL), the TOL is listed as the criterion (R 299.5707). In these cases, two numbers are present in the cell. The first number is the criterion (i.e., TDL), and the second number is the risk-based or solubility value, whichever is lower (R299.5708). Criteria were originally promulgated December 21, 2002 within the Administrative Rules for Part 201, Environmental Remediation, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. This table reflects revisions to the criteria pursuant to the December 2010 Part 201 amendments and new criteria consistent with the provisions of R299.5706a. The effective dates of the criteria and screening levels in this table vary. Please contact the Remediation Division Toxicology Unit for additional information. Guidesheet Number Hazardous Substance Carbon tetrachloride Chlordane (J) - Chemical Abstract Service Number #1 Groundwater Nonresidential Surface Water Residential Drinking Water Drinking Water Interface Criteria & RBSLs Criteria & RBSLs Criteria & RBSLs I 5.0 (A) 5.0 (A) 57749 2.0 (A) 2.0 (A) 56235 #3 #2 #4 #5 116 Residential Nonresidential Groundwater Groundwater Groundwater Contact Volatilization Volatilization to to Indoor Air Criteria & RBS Ls Indoor Air Inhalation Inhalation Criteria & RBSLs Criteria & RBSLs tr/ Water Solubility #8 #9 Flammability and Explosivity Screening Level Acute Inhalation Screening Level 45(X) 370 2,400 4,600 7.93E•5 ID 96,00D 2.D (M); O.D0D25 56 (S) 56 (S) 15 {AA) 56 ID ID ID 168870D6 2.5E+5 (E) 2.5E+5 (E) (FF) NLV NLV ID NA ID Chlorobenzene (I) 1D8907 10D (A) 100 (A) 25 2.1 E+5 4.7E+5 (S) 86,000 4.72E+5 1.6E+5 ID p-Chlorobenzene sulfonic acid 98668 7,300 21 ,0D0 ID ID ID ID NA ID ID 1-Chloro-1,1-difluoroethane 75683 15,0D0 44,0D0 NA 3.9E+6 (S) 3.9E+6 (S) 3.9E+6 (S) 3.9E•06 NA ID 430 1,7D0 1,10D (X) 5.7E+6 (S) 5.7E+6 (S) 4.4E+S 5.74E+6 1.1E+5 ID Chloride Chloroethane 75D03 2-Chloroethyl vinyl ether 11D758 ID ID NA ID ID ID 1.5DE+7 ID ID Chloroform 67663 80 (A,W} 80 (A.W} 350 28,0D0 1.8E+5 1.5E+5 7.92E+6 ID ID Chloromethane (I) 74873 260 1.100 ID 8,600 45,000 4.9E+5 6.34E+6 36,000 2.1 E+5 59507 150 420 7.4 NLV NLV 79 ,00D 3.90E+6 ID ID 5.200 NA ID ID 6,70D (S) 6,740 ID ID 4-Chloro-3-methylphenol 1,800 beta-Chloronaphthalene 91587 2-Chlorophenol 95578 45 130 18 4.9E+S 1.1E+6 94,DOO 2.2DE+7 ID ID 95498 150 420 ID 2.2E+5 3.7E+5 (S) 44.D00 3.73E+5 ID ID 2921882 22 63 2.0 (M); 0.002 2.9 6.6 1,100(S) 1,120 ID ID (G.X) NLV NLV 2.9E+8 NA ID ID ID o-Chlorotoluene (I) Chlorpyrifos Chromium (Ill) {B,H) 16D65831 10D (A) 100 (A) I Chromium (VI) 18540299 100(A) 100 (A) 11 NLV NLV 4.6E+5 NA ID Chrysene (Q) 218019 1.6 (S) 1.6 (S) ID ID ID 1.6 (S,AA) 1.6 ID ID Cobalt 7440484 40 10D 100 NLV NLV 2.4E+6 NA ID ID Copper (B) 7440508 1,0D0 (E) 1,000 (E) (G) NLV NLV 7.4E+6 NA ID ID 56 (X) NLV NLV 2,800 1.70E+5 ID ID Cyanazine March 25, 2011 21725462 r I 2.3 9.4 Page 4 of 14 �Attachment 1 TABLE 1. GROUNDWATER: RESIDENTIAL AND NONRESIDENTIAL PART 201 GENERIC CLEANUP CRITERIA AND SCREENING LEVELS; PART 213 TIER 1 RISK-BASED SCREENING LEVELS (RBSLs) DOCUMENT RELEASE DATE: MARCH 25, 2011 All criteria, unless otherwise noted, are expressed in units of parts per billion (ppb). One ppb is equivalent to one microgram per liter (ug/L). Criteria with six or more digits are expressed in scientific notation. For example, 200,000 is presented as 2.0E+5. The lowest generic groundwater criterion for a given hazardous substance is presented in a bold box. A footnote is designated by a letter in parentheses and is explained in the footnote pages that follow the criteria tables. When the risk-based criterion is less than the target detection limit (TDL), the TDL is'listed as the criterion (R 299.5707). In these cases, two numbers are present in the cell. The first number is the criterion (i.e., TDL), and the second number is the risk-based or solubility value, whichever is lower (R299.5708). Criteria were originally promulgated December 21, 2002 within the Administrative Rules for Part 201, Environmental Remediation, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. This table reflects revisions to the criteria pursuant to the December 2010 Part 201 amendments and new criteria consistent with the provisions of R299.5706a. The effective dates of the criteria and screening levels in this table vary. Please contact the Remediation Division Toxicology Unit for additional information. Guidesheet Number Hazardous Substance Cyanide (P,R) Cyclohexanone - Chemical Abstract Service Number #1 #2 #3 Groundwater Nonresidential Surface Water Residential Orin king Water Orin king Water Interface Criteria Criteria & RBSLs Criteria & RBSLs &RBSLs #4 #5 #6 Residential Nonresidential Groundwater Groundwater Groundwater Volatilization Contact Volatilization to to Indoor Air Criteria & RBSLs Indoor Air Inhalation Inhalation Criteria & RBSLs Criteria & RBSLs #7 Water Solubility #8 #9 Flammability and Explosivity Screening Level Acute Inhalation Screening Level ID 57125 200 (A) 200 (A) 5.2 NLV NLV 57,000 NA ID 108941 33,000 94,000 NA 1,500 3,300 2.3E+7 (S) 2.30E+7 NA ID NLV 500 (S) 500 ID ID ID Dacthal 1861321 73 210 NA NLV Dalapon 75990 200(A) 200 {A) NA NLV NLV 1.2E+7 5.02E+8 ID 4-4'-DDD 72548 9.1 37 NA NLV NLV 44 (AA) 90 10 ID 4-4'-DDE 72559 4.3 15 NA NLV NLV 27 (AA) 120 ID ID 4-4'-DDT 50293 3.6 10 NLV NLV 13 (AA) 25 NA ID NA 30 (S) 30 (S) 30 (S) 30 ID ID 9.7 ID I 0.02 (M); 1.1 E-5 1163195 30 (S) 30 (S) Di-n-butyl phthalate 84742 880 2,500 NLV NLV 11,000 (S) 11,200 NA Di(2-ethylhexyl) adipate 103231 400 (A) 400 (A) ID NLV NLV 470 (S) 471 ID ID Di-n-octyl phthalate 117840 130 380 ID NLV NLV 400 3,000 ID ID Diacetone alcohol (I) 123422 ID ID NA NLV NLV ID 1.0E+9 1.0E+9 (S) ID NLV 1,300 68,800 NA ID ID Decabromodiphenyl ether I NLV 333415 1.3 3.8 Dibenzo(a,h)anthracene (Q) 53703 2.0 (M); 0.21 2.0 (M); 0.85 ID NLV NLV 2.0 (M.AA); 0.31 2.49 ID Dibenzofuran 132649 ID ID 4.0 10,000 (S) 10.000 (S) ID 10,000 ID ID Dibromochloromethane 124481 80 (A,W) 80 (A,W) ID 14,000 1.1 E+S 18.000 2.60E+6 ID ID Oibromochloropropane 96128 0.2 (A) 0.2 (A) ID 1,200 (S) 1,200 (S) 390 1,230 NA ID ID Diazinon 1.0 (M); 0.004 74953 80 230 NA ID ID 5.3E+5 UOE+7 ID 1918009 220 630 NA NLV NLV 5.9E+5 4.5E+6 ID ID 1,2-Dichlorobenzene 95501 600 (A) 600 (A) 13 1.6E+S (S) 1.6E+5 (S) 1.6E+S (S) 1.56E+S NA 1.6E+5 (S) 1,3-Dichlorobenzene 541731 6.6 19 28 18,000 41,000 2,000 1.11E+S ID JD Oibromomethane Dicamba March 25, 2011 I I Page 5 of 14 �Attachment 1 TABLE 1. GROUNDWATER: RESIDENTIAL AND NONRESIDENTIAL PART 201 GENERIC CLEANUP CRITERIA AND SCREENING LEVELS; PART 213 TIER 1 RISK-BASED SCREENING LEVELS (RBSLs) DOCUMENT RELEASE DATE: MARCH 25, 2011 DI\\ All criteria, unless otherwise noted, are expressed in units of parts per billion (ppb). One ppb is equivalent to one microgram per liter (ug/L). Criteria with six or more digits are expressed in scientific notation. For example, 200,000 is presented as 2.0E+5. The lowest generic groundwater criterion for a given hazardous substance is presented in a bold box. A footnote is designated by a letter in parentheses and is explained in the footnote pages that follow the criteria tables. When the risk-based criterion is less than the target detection limit (TDL), the TDL is listed as the criterion (R 299.5707). In these cases, two numbers are present in the cell. The first number is the criterion (i.e., TDL), and the second number is the risk-based or solubility value, whichever is lower (R299.5708). Criteria were originally promulgated December 21, 2002 within the Administrative Rules for Part 201, Environmental Remediation, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. This table reflects revisions to the criteria pursuant to the December 2010 Part 201 amendments and new criteria consistent with the provisions of R299.5706a. The effective dates of the criteria and screening levels in this table vary. Please contact the Remediation Division Toxicology Unit for additional information. Guidesheet Number Hazardous Substance - Chemical Abstract Service Number #1 #2 #3 Groundwater Nonresidential Surface Water Residential Orin king Water Drinking Water Interface Criteria & RBSLs Criteria & RBSLs Criteria & RBSLs #4 #5 #6 Residential Nonresidential Groundwater Groundwater Groundwater Volatilization Contact Volatilization to to Indoor Air Criteria & RBSLs Indoor Air Inhalation Inhalation Criteria & RBSLs Criteria & RBSLs Water Solubility #3 #9 Flammability and Explosivity Screening Level Acute Inhalation Screening Level 17 16,000 74,000 (S) 6 ,400 73,800 NA ID 0.3 (M); 0.2 NLV NLV 180 3,110 ID ID ID 2.2E+5 3.0E+5 (S) 3.0E+5 (S) 3.00E+S ID ID 740 1.0E+6 2.3E+6 2.4E+6 5.06E+6 3.8E+5 ID 9.600 59.000 19,000 8.52E+6 2.5E+6 ID 2.25E+6 97.000 1.4E+5 3.50E+6 5.3E+5 ID 106467 75(A) 75 (A) 3,3'-Dichlorobenzidine 91941 1.1 4.3 Dichlorodifluoromethane 75718 1,700 4,800 1,1-Dichloroethane 75343 880 2,500 1,2-Dichloroethane {I) 107062 5.0 (A) 5.0 (A) 360 (X) 1,1-Dichloroethylene (I) 75354 7.0 (A) 7.0 (A) 130 200 1,300 11,000 cis-1,2-Dichloroelhylene 156592 70 (A) 70 (A) 620 93,000 2.1E+5 2.0E+5 1,4-Dichlorobenzeoe #7 trans-1 ,2-Dichloroethylene 156605 100 (A) 100 (A) 1,500 (X) 85,000 2.0E+5 2.2E+5 6.30E+6 2.3E+5 ID 2,6-Dichloro-4-oitroaniline 99309 2,200 6,300 NA NLV NLV 7,000 (S) 7,000 ID ID 2,4-Dichlorophenol 120832 ID 2,4-Dichlorophenoxyacetic acid 94757 I I 73 210 70 (A) 70 (A) I 11 NLV NLV 48.000 4.50E+6 ID 220 NLV NLV 1.2E+5 6.80E+5 ID ID 36,000 16,000 2.80E+6 5.5E+5 2.8E+6 (S) 1.2-Dichloropropane (I) 78875 5.0 (A) 5.0 (A) 230 (X) 16,000 1,3-Dichloropropene 542756 8.5 35 9.0 (X) 3,900 26,000 5,500 2.80E+6 1.3E+5 ID Dichlorovos 62737 1.6 6.7 NA NLV NLV 5,900 1.60E+7 NA ID Dicyclohexyl phthalate 84617 ID ID NA 10 ID ID 4 .000 ID ID Dieldrin 6057 1 0.1 1 0.43 200($ ) 2 00($) 2.4 (AA) 195 ID 10 Diethyl ether 60297 10 (E) 10 (E) ID 6.1E+7 (S) 6.1E+7 (S) 3.5E+7 6.10E+7 6.5E+5 6.1E+7 (S) Diethyl phthalate 84662 5,500 16,000 110 NLV NLV 1.1E+6 (S) 1.08E+6 NA ID Diethyleoe glycol monobutyl ether Diisopropyl ether 112345 88 250 NA NLV NLV 4.0E+6 1.0E+9 ID ID 108203 30 86 ID 8,000 (S) 8,000 (S) 8,000 {S) 8,041 8,000 (S) ID 108189 5.6 16 NA 2.1E+7 3.7E+7 (S) 2 1,000 3.69E+7 4.6E+6 10 Diisopropylamine (I) March 25, 2011 I 0.02 (M); 6.SE-6 Page 6 of 14 �Attachment 1 TABLE 1. GROUNDWATER: RESIDENTIAL AND NONRESIDENTIAL PART 201 GENERIC CLEANUP CRITERIA AND SCREENING LEVELS; PART 213 TIER 1 RISK-BASED SCREENING LEVELS (RBSLs) DOCUMENT RELEASE DATE: MARCH 25, 2011 All criteria, unless otherwise noted, are expressed in units of parts per billion (ppb). One ppb is equivalent to one microgram per liter (ug/L). Criteria with six or more digits are expressed in scientific notation. For example, 200,000 is presented as 2.0E+S. The lowest generic groundwater criterion for a given hazardous substance is presented in a bold box. A footnote is designated by a letter in parentheses and is explained in the footnote pages that follow the criteria tables. When the risk-based criterion is less than the target detection limit (TDL), the TDL is listed as the criterion (R 299.5707). In these cases, two numbers are present in the cell. The first number is the criterion (i.e., TDL), and the second number is the risk-based or solubility value, whichever is lower (R299.5708). Criteria were originally promulgated December 21, 2002within the Administrative Rules for Part 201, Environmental Remediation, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. This table reflects revisions to the criteria pursuant to the December 201 O Part 201 amendments and new criteria consistent with the provisions of R299.5706a. The effective dates of the criteria and screening levels in this table vary. Please contact the Remediation Division Toxicology Unit for additional information. Guidesheet Number Hazardous Substance - Chemical Abstract Service Number #1 #3 #2 Groundwater Nonresidential Surface Water Residential Drinking Water Drinking Water Interface Criteria & RBSLs Criteria & RBSLs Criteria & RBSLs #4 #S #6 Residential Nonresidential Groundwater Groundwater Groundwater Contact Volatilization Volatilization to to Indoor Air Criteria & RBSLs Indoor Air Inhalation Inhalation Criteria & RBSLs Criteria & RBSLs #7 Water Solubility #8 #9 Flammability and Explosivity Screening Level Acute Inhalation Screening Lev el 131113 73,000 2.1E+5 NA NLV NLV 4.2E+6 ($ ) 4.19E+6 NA ID N .N-Dimethylacetamide 12719S 180 520 4,100 (X) NLV NLV 2.3E+7 1.0E+9 NA ID N.N-Oimethylaniline 121697 16 46 NA 2.4E+5 1:3E+6 (SJ 20,000 1.27E+6 NA 1.3E+6 (S) Dimethylformamide (I) 68122 700 2,000 NA NLV NLV 1.1E+8 1.0E+9 ID ID 2,4-0imethylphenol 105679 370 1.000 380 NLV NLV 5.2E+5 7.87E+6 ID ID 2,6-0imethylphenol 576261 4.4 13 NA NLV NLV 6,300 6.14E+6 ID ID 29 NA NLV NLV 18,000 4.93E+6 ID ID 1.9E+5 NLV NLV 1.7E+8 (S) 1.66E+8 ID ID NA NLV NLV 8,600 2.70E+5 ID ID 1.0 (M); 0.48 NLV NLV 7,000 52,000 ID ID 2,800 (X) NLV NLV 1.7E+6 9.00E+ 8 1.4E+8 ID NA NLV NLV 7.0E+5 (S) 7 .00E+5 ID ID Dimethyl phthalate I 3,4-Dimethylphenol 95658 10 Dimethylsulfoxide 67685 2.2E+5 6.3E+5 2,4-0initrotoluene 121142 7.7 32 Dinoseb 88857 7.0 (A) 7.0 (A) 85 350 1,4-Dioxane (I) 123911 I I I 85007 20 (A) 20 (A) NA ID ID (EE) ID ID ID NA NA NA Diuron 330S41 31 90 NA NLV NLV 37,000 ($) 37, 300 ID ID Endosulfan (J) 115297 44 130 0.03 (M); 0.029 ID ID 51 0 (S) 510 10 ID 100 (A) NLV 2.5E+7 (AA) 1.00E+8 ID ID 160 (AA} 250 ID ID Diquat Dissolved oxygen (DO) Endothall 145733 100(A) NA NLV Endrin 72208 2.0 (A) 2.0 (A) ID NLV NLV Epichlorohydrin (I) 106898 5.0 ( M); 2.0 (A) 5.0 (M); 2.0 (A) NA 3.2E+5 6.3E+S 11,000 6.60E+7 4.7E+7 ID Ethanol (I) 64175 1.9E+6 3.8E+6 10 NLV NLV 1.0E+9 (D.S) 1.0E+9 9.7E+7 10 Ethyl acetate (I) 141786 6,600 19,000 NA 6.4E+7 ($) 6.4E+7 (SJ 6.4E+7 (S) 6.40E+7 4.2E+6 ID ID 2.9E+6 5.6E+6 (S) ID 5.63E+6 ID ID Ethyl-tert-butyl ether (ETBE) March 25, 2011 637923 49 (E) 49 (E) Page 7 of 14 �Attachment 1 TABLE 1. GROUNDWATER: RESIDENTIAL AND NONRESIDENTIAL PART 201 GENERIC CLEANUP CRITERIA AND SCREENING LEVELS; PART 213 TIER 1 RISK-BASED SCREENING LEVELS (RBSLs) DOCUMENT RELEASE DATE: MARCH 25, 2011 All criteria, unless otheiwise noted, are expressed in units of parts per billion (ppb). One ppb is equivalent to one microgram per liter (ug/L). Criteria with six or more digits are expressed in scientific notation. For example, 200,000 is presented as 2.0E+S. The lowest generic groundwater criterion for a given hazardous substance is presented in a bold box. A footnote is designated by a letter in parentheses and is explained in the footnote pages that follow the criteria tables. When the risk-based criterion is less than the target detection limit (TDL), the TDL is listed as the criterion (R 299.5707). In these cases, two numbers are present in the cell. The first number is the criterion (i.e., TDL), and the second number is the risk-based or solubility value, whichever is lower (R299.5708). Criteria were originally promulgated December 21, 2002 within the Administrative Rules for Part 201, Environmental Remediation, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. This table reflects revisions to the criteria pursuant to the December 201 O Part 201 amendments and new criteria consistent with the provisions of R299.5706a. The effective dates of the criteria and screening levels in this table vary. Please contact the Remediation Division Toxicology Unit for additional information. Guidesheet Number Hazardous Substance Ethylbenzene (I) Ethylene dibromide - Chemical Abstract Service Number #1 #2 #3 Groundwater Residential Nonresidential Surface Water Drinking Water Drinking Water Interface Criteria & RBSLs Criteria & RBSLs Criteria & RBSLs #4 #5 #6 Residential Nonresidential Groundwater Groundwater Groundwater Volatilization Contact Volatilization to to Indoor Air Criteria & RBSLs Indoor Air Inhalation Inhalation Criteria & RBSLs Criteria & RBSLs #7 Water Solubility #8 #9 Flammability and Explosivity Screening Level Acute Inhalation Screening Level 100414 74 (E) 74 (E) 18 1.1E+5 1.7E+5 (S) 1.7E+5 (S) 1.69E+5 43,000 1.7E+5 (S) 106934 0.05 (A) 0.05 (A) 5.7 (X) 2.400 15,000 25 4.20E+6 ID ID NLV Ethylene glycol 107211 15,000 42,000 1.9E+5 (X) NLV 1.0E+9 (D.S) 1.0E+9 NA 1.0E+9 (D,S) Ethylene glycol monobutyl ether 111762 3,700 10,000 NA 2.9E+6 6.5E+6 5.3E+7 2.24E+8 NA ID Fluoranthene 206440 210 ($) 210 ($) 1.6 21 O (S} 210 ($) 210($) 206 ID ID 86737 880 2,000 ($) 12 2,000 ($) 2.000 (S) 2,000 (S) 1,980 ID ID TT82414 2,000 (E) 2,000 (E) ID NLV NLV 1.2E+7 NA ID ID Fluorene Fluorine (soluble fluoride) (B) Formaldehyde 50000 1,300 3,800 120 63,000 3.6E+5 3.0E+7 5.50E+8 ID 61,000 Formic acid (l,U) 64186 10,000 29,000 10 7.7E+6 1.5E+7 6.0E+8 1.0E+9 1.0E+9 (D) 3.5E+8 1-Formylpiperidine 2591868 80 230 NA ID ID JD NA ID ID 548629 15 63 NA NLV NLV 1.0E+6 (S) 1.00E+6 ID ID NA NLV NLV 1.2E+7 (S,AA) 1.16E+7 ID ID 180 (S) 180 (S) 2.9 (AA) 180 ID ID 9.0 (AA) 200 ID ID Gentian violet Glyphosate 1071836 700 (A) 700 (A) Heptachlor 76448 0.4 (A) 0.4 (A) 1024573 0.2 (A) 0.2 (A) ID NLV NLV NA 2,700 ($) 2,700 ($) 2,700 (S) 2,690 200 2,700 (S) ID ID ID 0.17 (S): 1,500 0.17 ID ID Heptachlor epoxide 142825 2,700 (S) 2,700 (S) Hexabromobenzene 87821 0.17 (S): 20 0.17 (S); 58 Hexachlorobenzene (C-66) 118741 1.0 (A) 1.0 (A) Hexachlorobutadiene (C-46) 87683 15 42 alpha-Hexachlorocyclohexane 319846 0.43 1.7 beta-Hexachlorocyclohexane 319857 0.88 3.6 Hexachlorocyclopentadiene 77474 50 (A) 50 (A) n-Heptane I 0.01 (M); 0.0018 I 0.2 (M): 0.0003 I 0.053 440 3,000 4.6 6,200 ID ID 1,600 3,200 (S) 400 3,230 ID ID ID 2.000 (S) 2.000 (S) 60 2,000 ID ID ID NLV NLV 120 .240 ID ID ID 130 420 1.600 1,800 ID JD IC-56\ March 25, 2011 Page 8 of 14 �Attachment 1 TABLE 1. GROUNDWATER: RESIDENTIAL AND NONRESIDENTIAL PART 201 GENERIC CLEANUP CRITERIA AND SCREENING LEVELS; PART 213 TIER 1 RISK-BASED SCREENING LEVELS (RBSLs) DOCUMENT RELEASE DATE: MARCH 25, 2011 All criteria, unless otherwise noted, are expressed in units of parts per billion (ppb). One ppb is equivalent to one microgram per liter (ug/L). Criteria with six or more digits are expressed in scientific notation. For example, 200,000 is presented as 2.0E+5. The lowest generic groundwater criterion for a given hazardous substance is presented in a bold box. A footnote is designated by a letter in parentheses and is explained in the footnote pages that follow the criteria tables. When the risk-based criterion is less than the target detection limit (TDL), the TDL is listed as the criterion (R 299.5707). In these cases, two numbers are present in the cell. The first number is the criterion (i.e., TDL), and the second number is the risk-based or solubility value, whichever is lower (R299.5708). Criteria were originally promulgated December 21, 2002 within the Administrative Rules for Part 201, Environmental Remediation, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. This table reflects revisions to the criteria pursuant to the December 201 o Part 201 amendments and new criteria consistent with the provisions of R299.5706a. The effective dates of the criteria and screening levels in this table vary. Please contact the Remediation Division Toxicology Unit for additional information. Guidesheet Number Hazardous Substance - Chemical Abstract Service Number #1 #2 #3 Groundwater Residential Non residential Surface Water Drinking Water Drinking Water Interface Criteria Criteria & RBSLs Criteria & RBSLs & RBSLs #4 #5 #S Residential Nonresidential Groundwater Groundwater Groundwater Volatilization Contact Volatilization to to Indoor Air Criteria & RBSLs Indoor Air Inhalation Inhalation Criteria & RBSLs Criteria & RBSLs #7 Water Solubility 118 #9 Flammability and Explosivity Screening Level Acute Inhalation Screening Level Hexachloroethane 67721 7.3 21 6.7 (X) 27.000 50,000 (S) 1,900 S0,000 ID ID n-Hexane 110543 3,000 8,600 NA 12,000 (S) 12,000 (S) 12,000 (S) 12,000 12,000 (S) ID 2-Hexanone 591786 1,000 2,900 ID 4.2E+6 8.7E+6 5.2E+6 1.60E+7 NA ID lndeno(1,2,3-cd)pyrene (Q) 193395 ID NLV NLV ID ID NA NLV NLV 2.0 (M,AA); 0.022 rS\ 5.8E+7 0.022 Iron (8) 2.0 (M); 0.022 IS\ 300 (E) NA ID ID NA 7.6E+7 (S) 7.6E+7 (S) 2.5E+7 7.60E+7 ID ID 1,300 (X) NLV NLV 9.9E+5 1.20E+7 ID 1.2E+7 (S) 1.0E+9 (D.S) I 7439896 2.0 (M); 0,022 (S) 300 (E) lsobutyl alcohol (I) 78831 2,300 6,700 lsophorone 78591 770 3,100 lsopropyl alcohol (I) 67630 470 1.300 57,000 (X) NLV NLV 1.3E+7 1.0E-+-9 6.0E-+-7 98828 800 2,300 28 56,000 (S) 56,000 (S) 56,000 (S) 56,000 29,000 ID 7439921 4.0 (L) 4.0 (L) (G.X) NLV NLV ID NA ID ID ID lsopropyl benzene Lead (8) lindane I I 58899 0.2 (A) 0.2 (A) ID ID 190 6 ,800 ID Lithium (8) 7439932 170 350 440 NLV NLV 5.4E+6 NA ID ID Magnesium (8) 7439954 4.0E+5 1.1E+6 NA NLV NLV 1.0E-+-9 (D) NA ID ID Manganese (8) I 0.03 (M): 0.026 7439965 50 (E) 50 (E) (G,X) NLV NLV 9.1E+6 NA ID ID Mercury (Total) (B,Z) Varies 2.0(A) 2.0 (A) 0.0013 56 (S) 56 (S) 56 (S) 56 ID ID Methane 74828 ID ID NA (K) (K) ID NA 520 10 Methanol 67561 3,700 10,000 5.9E+5 (X) 2.9E+7 (S) 2.9E+7 (S) 2.9E+7 (S) 2.90E+7 4 .SE-+-6 2.9E+7 ($} Methoxychlor 72435 40 (A) 40 (A) NA ID ID 45 (S) 45 10 ID 2-Methoxyethanol (I) 109864 7.3 21 NA NLV NLV 8.3E+5 1.0E-+-9 ID ID 2-Methyl-4--chlorophenoxyacetic acid 2-Methyl-4,S--dinitrophenol 94746 7.3 21 NA NLV NLV 9,200 9.24E+5 ID ID 534521 20 (M): 2.6 20 (M); 7.3 NA NLV NLV 9,500 2.00E-+-5 ID ID March 25, 2011 Page 9 of 14 �Attachment 1 TABLE 1. GROUNDWATER: RESIDENTIAL AND NONRESIDENTIAL PART 201 GENERIC CLEANUP CRITERIA AND SCREENING LEVELS; PART 213 TIER 1 RISK-BASED SCREENING LEVELS (RBSLs) DOCUMENT RELEASE DATE: MARCH 25, 2011 All criteria, unless otherwise noted, are expressed in units of parts per billion (ppb). One ppb is equivalent to one microgram per liter (ug/L). Criteria with six or more digits are expressed in scientific notation. For example, 200,000 is presented as 2.0E+S. The lowest generic groundwater criterion for a given hazardous substance is presented in a bold box. A footnote is designated by a letter in parentheses and is explained in the footnote pages that follow the criteria tables. When the risk-based criterion is less than the target detection limit (TDL), the TDL is listed as the criterion (R 299.5707). In these cases, two numbers are present in the cell. The first number is the criterion (i.e., TDL), and the second number is the risk-based or solubility value, whichever is lower (R299.5708). Criteria were originally promulgated December 21, 2002 within the Administrative Rules for Part 201, Environmental Remediation, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. This table reflects revisions to the criteria pursuant to the December 201 O Part 201 amendments and new criteria consistent with the provisions of R299.5706a. The effective dates of the criteria and screening levels in this table vary. Please contact the Remediation Division Toxicology Unit for additional information. Guidesheet Number Hazardous Substance N-Methyl-morpholine (I) Methyl parathion 4-Methyl-2-pentanone (MIBK) m Methyl-1ert-butyl ether (MTBE) Chemical Abstract Service Number #1 #2 #3 Groundwater Residential Nonresidential Surface Water Drinking Water Drinking Water Interface Criteria Criteria & RBSLs Criteria & RBSLs & RBSLs #4 #S #6 Residential Nonresidential Groundwater Groundwater Groundwater Volatilization Contact Volatilization to Criteria & RBSLs to Indoor Air Indoor Air Inhalation Inhalation Criteria & RBSLs Criteria & RBSLs #7 Water Solubility #8 #9 Flammability and Explosivity Screening Level Acute Inhalation Screening Level ID 109024 20 56 NA NLV NLV 1.5E+6 1.0E+9 ID 298000 1.8 5.2 NA NLV NLV 3,000 50,000 ID ID 1.3E+7 2.00E+7 ID 2.0E+7 (S) 6.1E+S 4.68E+7 10 ID 108101 1634044 r 1,800 5,200 ID 2.0E+7 (S) 2.0E+7 (S) 40 (E) 40 (E) 7,100(X) 4.7E+7 (S) 4.7E+7 (S) Me1hylcyclopentane (I) 96377 ID ID NA 22,000 49,000 ID 73,890 ID ID 4,4'-Methylene-bis-2chloroaniline (MBOCA) Methylene chloride 101144 1.1 4.5 NA NLV NLV 110 (AA) 14.000 ID ID 75092 5.0(A) 5.0(A) 1,500 (X) 2.2E+5 1.4E+6 2.2E+S 1.70E+7 ID ID 2-Methylnaph1halene 91576 260 750 19 25.ooo (S) 25 .000 (S) 25,000 (S) 24,600 ID ID 1319773 370 1,000 30 (M); 25 NLV NLV 8.1E+5 2.80E+7 NA ID NLV 91.000 5.30E+5 ID ID Methylphenols (J) Metolachlor 51218452 240 990 15 NLV Metribuzin 21087649 180 520 NA ID ID 1.2E+6 (S) 1.2E+6 ID ID Mirex 2385855 ID ID 6.8E-6 NA ID Molybdenum (B) 7439987 0.02 (M); 6.BE-6 IS) 73 91203 520 1,500 7440020 100 (A) 100 (A) Naph1halene Nickel (8) 0.02 (M); 6.8E-6 1.02 (M); 6.BE-6 (S /S\ 210 3.200 {X) 11 (G) NLV NLV 0.02 (M); 6.SE-6 /S\ 9.7E+5 NA ID 10 31,000 (S) 31 ,000 (S) 31 ,000 (S) 31 ,000 NA 31,00D (S) NLV NLV 7.4E+7 NA ID ID NLV 3.1E+8 NA ID ·10 Nitrate (B,N) 14797558 10,0D0 (A,N) 10,000 (A,N) 10 NLV Nitrite (B,N) 14797650 1,000 (A,N) 1,D00 (A,N) NA NLV NLV ID NA ID ID 3.4 9.6 180 (X) 2.8E+5 5.5E+5 11,000 2.09E+6 NA ID ID NLV NLV 79,000 2.50E+6 ID ID NA NLV NLV 360 9.891::+6 ID ID Nitrobenzene (I) 2-Nitrophenol n-Nitroso-di-n-propylamine March 25, 2011 98953 88755 621647 r 20 5.0 (M); 0.19 58 5.D (M); 0.77 Page 10 of 14 �Attachment 1 TABLE 1. GROUNDWATER: RESIDENTIAL AND NONRESIDENTIAL PART 201 GENERIC CLEANUP CRITERIA AND SCREENING LEVELS; PART 213 TIER 1 RISK-BASED SCREENING LEVELS (RBSLs) DOCUMENT RELEASE DATE: MARCH 25, 2011 All criteria, unless otherwise noted, are expressed in units of parts per billion (ppb). One ppb is equivalent to one microgram per liter (ug/L). Criteria with six or more digits are expressed in scientific notation. For example, 200,000 is presented as 2.0E+5. The lowest generic groundwater criterion for a given hazardous substance is presented in a bold box. A footnote Is designated by a letter in parentheses and is explained in the footnote pages that follow the criteria tables. When the risk-based criterion is less than the target detection limit (TDL), the TDL is listed as the criterion (R 299.5707). In these cases, two numbers are present in the cell. The first number is the criterion (i.e., TDL), and the second number is the risk-based or solubility value, whichever is lower (R299.5708). Criteria were originally promulgated December 21, 2002 within the Administrative Rules for Part 201, Environmental Remediation, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. This table reflects revisions to the criteria pursuant to the December 201 O Part 201 amendments and new criteria consistent with the provisions of R299.5706a. The effective dates of the criteria and screening levels in this table vary. Please contact the Remediation Division Toxicology Unit for additional information. Guidesheet Number Hazardous Substance N-Nitrosodiphenylamine Oxamyl -- Chemical Abstract Service Number #1 #2 #3 Groundwater Residential Nonresidential Surface Water Orin king Water Drinking Water Interface Criteria Criteria & RBSLs Criteria & RBSLs & RBSLs #4 #5 #6 Residential Nonresidential Groundwater Groundwater Groundwater Volatilization Contact Volatilization to to Indoor Air Criteria & RBSLs Indoor Air Inhalation Inhalation Criteria & RBSLs Criteria & RBSLs #7 Water Solubility #8 #9 Flammability and Explosivity Screening Level Acute Inhalation Screening Level 86306 270 1,100 NA NLV NLV 35,000 ($) 35,100 ID ID 23135220 200 (A) 200 (A) NA NLV NLV 6.2E+7 2.80E+6 ID ID Oxo-hexyl acetate 88230357 73 210 NA ID ID 10 NA ID ID Pendimethalin 40467421 260($) 280 (S) NA NLV NLV 280 (S) 275 ID ID Pentachlorobenzene Pentachloronitrobenzene Pentachlorophenol 608935 6.1 17 5.0 (M); 0.019 ID ID 240 650 ID ID 62666 32 (S) 32($) NA 32 (S) 32 ($) 32($) 32 ID 10 67665 1.0 (A) 1,0 (A) (G.X) NLV NLV 200 1.85E+6 ID ID 38,000 (S) Pentane 109660 ID ID NA 38,000 (S) 36,000 (S) ID 36,200 340 2-Pentene (I) 109682 ID 10 NA ID ID ID 2,03E+5 ID 10 NA 6.5 to 8.5 (E) 6.5 to 6.5 (E) 6.5 to 9.0 ID ID ID NA NA NA pH 65016 52 150 2.0 (M); 1.4 1,000 ($) 1,000 (S) 1,000 (S) 1,000 ID ID 108952 4,400 13,000 450 NLV NLV 2.9E+7 8.26E+7 NA 10 7723140 63,000 2.4E+5 (EE) NLV NLV ID NA ID ID Phthalic acid 68993 14,000 40,000 NA NLV NLV 1.4E+7 (S) 1.42E+7 ID ID Phthalic anhydride Phenanthrene Phenol Phosphorus (Total) 85449 15,000 44,000 NA NLV NLV 6.2E+6 (S) 6.2E+6 NA ID Picloram 1918021 500 (A) 500 (A) 46 NLV NLV 4.3E+5 (S) 4.30E+5 ID ID Piperic!ine 110894 3.2 9.2 NA NLV NLV 34,000 1.0E..,9 ID ID 67774327 0.03 0.09 Polychlorinated biphenyls (PCBs) (J,n Prometon Polybrominated biphenyls (J) 1336363 0.5 (A) 0.5 (A) 1610160 160 460 Propachlor 1918167 95 270 March 25, 2011 NLV NLV ID 1.66E+7 lD ID 45 (S) 45 ($) 3.3(AA) 44.7 ID 10 NA NLV NLV 1.8E+5 7.SOE..,5 ID ID NA NLV NLV 4.4E+S 6.5SE+S ID ID ID I 0.2 (M); 2.SE-5 Page 11 of 14 �Attachment 1 TABLE 1. GROUNDWATER: RESIDENTIAL AND NONRESIDENTIAL PART 201 GENERIC CLEANUP CRITERIA AND SCREENING LEVELS; PART 213 TIER 1 RISK-BASED SCREENING LEVELS (RBSLs) DOCUMENT RELEASE DATE: MARCH 25, 2011 All criteria, unless otherwise noted, are expressed in units of parts per billion {ppb). One ppb is equivalent to one microgram per liter {ug/L). Criteria with six or more digits are expressed in scientific notation. For example, 200,000 is presented as 2.0E+S. The lowest generic groundwater criterion for a given hazardous substance is presented in a bold box. A footnote is designated by a letter in parentheses and is explained in the footnote pages that follow the criteria tables. When the risk-based criterion is less than the target detection limit (TDL), the TDL is listed as the criterion (R 299.5707). In these cases, two numbers are present in the cell. The first number is the criterion (i.e., TDL), and the second number is the risk-based or solubility value, whichever is lower (R299.5708). Criteria were originally promulgated December 21, 2002 within the Administrative Rules for Part 201, Environmental Remediation, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. This table reflects revisions to the criteria pursuant to the December 2010 Part 201 amendments and new criteria consistent with the provisions of R299.5706a. The effective dates of the criteria and screening levels in this table vary. Please contact the Remediation Division Toxicology Unit for additional information. Guidesheet Number Hazardous Substance Chemical Abstract Service Number #1 #2 #3 Groundwater Residential Nonresidential Surface Water Drinking Water Drinking Water Interface Criteria Criteria & RBSLs Criteria & RBSLs & RBSLs #4 #5 #6 Residential Nonresidential Groundwater Groundwater Groundwater Contact Volatilization Volatilization to to Indoor Air Criteria & RBSLs Indoor Air Inhalation Inhalation Criteria & RBSLs Criteria & RBSLs #7 Water Solubility #8 #9 Flammability and Explosivity Screening Level Acute Inhalation Screening Level Propazine 139402 200 560 NA NLV NLV 8,600(S) 8,600 ID ID Propionic acid 79094 12,000 35,000 ID NLV NLV 2.8E+8 1.0E+9 1.0E+9 (D) ID Propyl alcohol (I) 71238 1,400 4,000 NA NLV NLV 2.8E+7 1.0E+9 7.1E+7 1.0E+9 (D,S) n-Propylberu:ene (I) 103651 80 230 ID ID 10 15,000 NA ID ID Propylene glycol 57556 1.5E+5 4.2E+5 2.9E+5 NLV NLV 1.0E +9 (D,S) 1.0E+9 ID ID Pyrene 129000 140 (S) 140 (S) ID 140 (S) 140 (S) 140 (S) 135 ID ID Pyridine (!) 110861 20 (M); 7.3 21 NA 5,500 12,000 94,000 3.00E+S 81,000 10 Selenium (B) 7782492 50 (A) 50(A) 5.0 NLV NLV 9.7E+5 NA 10 10 Silver (B) 7440224 34 98 0.2 (Ml: 0.06 NLV NLV 1.5E+6 NA ID ID Silvex (2.4,5-TP) 93721 50 (A) 50 (A) 30 NLV NLV 43,000 1.40E+5 ID ID Simazine 122349 4.0(A) 4.0 (A) 17 NLV NLV 4,500 (S) 4,470 ID 10 Sodium 17341252 1.2E+5 3.5E+5 NA NLV NLV 1.0E+9 (D) NA ID ID Sodium azide 26628228 88 250 50 (M); 7.3 ID ID ID NA ID ID Strontium (B) 7440246 4,600 13,000 21,000 NLV NLV 1.2E+8 NA ID ID Styrene 100425 100(A) 100(A) 80 (X) 1.7E+5 3.1E+S (S) 9,700 3.10E+5 1.4E+5 3.1E+5 (S) Sulfate 14808798 2.SE+S {E) 2.5E+5 (E) I I NA NLV NLV ID NA ID ID NLV 2.SE+6 (S) 2.50E+6 ID ID (0) 0.00996 ID ID Tebuthiuron 34014181 510 1,500 NA NLV 2,3,7,8-Tetrabromodibenzo-p-dic 50585416 (O} (0) (0) NLV NLV (0) 1,2,4,S-Tetrachlorobenzene 2,3,7,8-Tetrachlorodibenzo-p-dic (0) 1,1.1.2-Tetrachloroethane March 25, 2011 95943 1.300 (S) 1,300(S) 2.9 (X) 1,300 (S) 1,300 (S) 1,300 (S) 1,300 ID ID 1746016 3.0E-5 (A) 3.0E-5 (A) P.OE-5 (M); 3.1E-~ NLV NLV 1.0E-5 (M ,0 ,AA) 0.019 ID ID 630206 77 320 ID 15,000 96,000 30 ,000 1.10E+6 ID ID Page 12 of 14 �Attachment 1 TABLE 1. GROUNDWATER: RESIDENTIAL AND NONRESIDENTIAL PART 201 GENERIC CLEANUP CRITERIA AND SCREENING LEVELS; PART 213 TIER 1 RISK-BASED SCREENING LEVELS (RBSLs) DOCUMENT RELEASE DATE: MARCH 25, 2011 All criteria, unless otherwise noted, are expressed in units of parts per billion (ppb). One ppb is equivalent to one microgram per liter (ug/L). Criteria with six or more digits are expressed in scientific notation. For example, 200,000 is presented as 2.0E+S. The lowest generic groundwater criterion for a given hazardous substance is presented in a bold box. A footnote is designated by a letter in parentheses and is explained in the footnote pages that follow the criteria tables. When the risk-based criterion is less than the target detection limit (TDL), the TDL is listed as the criterion (R 299.5707). In these cases, two numbers are present in the cell. The first number is the criterion (i.e., TDL), and the second number is the risk-based or solubility value, whichever is lower (R299.5708). Criteria were originally promulgated December 21, 2002 within the Administrative Rules for Part 201, Environmental Remediation, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. This table reflects revisions to the criteria pursuant to the December 2010 Part 201 amendments and new criteria consistent with the provisions of R299.5706a. The effective dates of the criteria and screening levels in this table vary. Please contact the Remediation Division Toxicology Unit for additional information. Guidesheet Number Hazardous Substance Chemical Abstract Service Number #1 #3 #2 Groundwater Nonresidential Surface Water Residential Drinking Water Drinking Water Interface Criteria Criteria & RBSLs Criteria & RBSLs & RBSLs #4 #5 #6 Residential Nonresidential Groundwater Groundwater Groundwater Volatili:iation Contact Volatilization to to Indoor Air Criteria & RBSLs Indoor Air Inhalation Inhalation Criteria & RBSLs Criteria & RBSLs #7 Water Solubility #8 #9 Flammability and Explosivity Screening Level Acute Inhalation Screening Level 1,1,2,2-Tetrachloroethane 79345 8.5 35 78 (X) 12,000 77,000 4,700 2.97E+6 ID ID Tetrachloroethylene 127184 5.0 (A) 5.0 (A) 60 (X) 25,000 1.7E+5 12,000 2.0E+S ID 2.0E+S ($) Tetrahydrofuran 109999 95 270 11,000 (X) 6.9E+6 1.6E+7 1.6E+6 1.0E+9 60,000 3.6E+6 ID ID NA 580 3,200 ID 85,000 ID ID 2.0(A) 2.0 {A) 3.7 (X) NLV NLV 13,000 NA ID ID 108883 790 (E) 790 (E) 270 5.3E+S ($) 5.3E+5 (S) 5.3E+5 (SJ 5.26E+S 61,000 ID 106490 15 62 NA NLV NLV 24,000 7 .60E+6 NA ID ID 10 NA NA NA 740 (S) Tetranitromethane 509148 Thallium (B) 7440280 Toluene (I) p-Toluidine I I NA 5.0E+5 (E) 5.0E+5 (E) (EE) ID Toxaphene 8001352 3.0 (A) 3.0 (A) 1.0 (M): 6.8E•5 NLV NLV 44 740 ID Triallate 2303175 95 270 NA ID ID 4,000 {S) 4,000 ID ID Tributylamine 102829 10 29 ID 14,000 32,000 2,300 75,400 ID ID 1,2,4-Trichlorobenzene 120821 70 (A) 70 (A) 99 (X) 3.0E+5 (S) 3.0E+5 (S) 19,000 3.00E+5 NA 3.0E+5 (S) ID 1.3E+6 ($) Total dissolved solids (TD$) 1, 1,1-Trichloroethane 71556 200 (A) 200 (A) 89 6.6E+5 1.3E+6 ($) 1.3E+6 (S) 1.33E+6 1,1,2-Trichloroethane 79005 5.0 (A) 5.0 (A) 330 (X) 17,000 1.1 E+S 21 ,000 4.42E+6 NA ID Trichloroethylene 79016 5.0 (A) 5.0 (A) 200 (X) 15,000 97,000 22,000 1.10E+6 10 1.1E+6 ($) Trichlorofluoromethane 75694 2,600 7,300 NA 1.1E+6 (S) 1.1E+6 ($) 1.1E+6 ($) UOE+6 10 1.1E+6 (S) 95954 730 2,100 NA NLV NLV 1.7E+5 1.20E+6 ID ID 2,4,6-Trichlorophenol 88062 120 470 5.0 NLV NLV 10,000 8.00E+S ID ID 1,2,3--Trichloropropane 96184 42 120 NA 8,300 18,000 84,000 1.90E+6 NA ID 1, 1,2-Trichloro-1 ,2,2-trifluoroeth, 76131 1.7E+5 (S) 1.7E+S (S) 32 1.7E+5 (S) 1.7E+5 ($) 1.7E+S (S) 1.70E+5 ID 1.7E+5 (S) Triethanolamine 102716 3,700 10,000 NA NLV NLV 1.0E+9 (D,S) 1.0E+S ID ID 2,4,5-Trichlorophenol March 25, 2011 I Page 13 of 14 �Attachment 1 TABLE 1. GROUNDWATER: RESIDENTIAL AND NONRESIDENTIAL PART 201 GENERIC CLEANUP CRITERIA AND SCREENING LEVELS; PART 213 TIER 1 RISK-BASED SCREENING LEVELS (RBSLs) DOCUMENT RELEASE DATE: MARCH 25, 2011 All criteria, unless otherwise noted, are expressed in units of parts per billion (ppb). One ppb is equivalent to one microgram per liter (ug/L). Criteria with six or more digits are expressed in scientific notation. For example, 200,000 is presented as 2.0E+5. The lowest generic groundwater criterion for a given hazardous substance is presented in a bold box. A footnote is designated by a letter in parentheses and is explained in the footnote pages that follow the criteria tables. When the risk-based criterion is less than the target detection limit (TDL), the TDL is listed as the criterion (R 299.5707). In these cases, two numbers are present in the cell. The first number is the criterion (i.e., TDL), and the second number is the risk-based or solubility value, whichever is lower (R299.5708}. Criteria were originally promulgated December 21, 2002 within the Administrative Rules for Part 201, Environmental Remediation, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. This table reflects revisions to the criteria pursuant to the December 2010 Part 201 amendments and new criteria consistent with the provisions of R299.5706a. The effective dates of the criteria and screening levels in this table vary. Please contact the Remediation Division Toxicology Unit for additional information. Guidesheet Number Hazardous Substance - Chemical Abstract Service Number Triethylene glycol 3-Trifluoromethyl-4-nitrophenol #1 #2 #3 Groundwater Nonresidential Surface Water Residential Drinking Water Drinking Water Interface Criteria & RBSLs Criteria & RBSLs Criteria & RBSLs #4 #5 #6 Residential Nonresidential Groundwater Groundwater Groundwater Volatilization Contact Volatilization to to Indoor Air Criteria & RBSLs Indoor Air Inhalation Inhalation Criteria & RBSLs Criteria & RBSLs #7 Water Solubility #3 #9 Flammability and Explosivlty Screening Level Acute Inhalation Screening Level 112276 4,300 12,000 NA NLV NLV 1.0E+6 (S) 1.00E+6 ID ID 88302 4.500 13.000 NA NLV NLV 5.0E+6 (S) 5.00E+6 ID ID Trifluralin 1582098 37 110 NA ID ID 2,400 8,100 ID ID 2.2,4-Trimethyl pentane 540841 ID 10 NA 2.300($) 2.300 ($) ID 2.330 160 10 2.4.4-Trimethyl-2-pentene (I) 107404 ID ID NA ID ID ID 11,900 ID ID 1,2,4-Trimethylbenzene (l) 95636 63 (E) 63 (E) 17 56,000 ($) 56 ,000 (S) 56,000 (S) 55,890 56,000 (S) ID 1,3,5-Trimethylbenzene (I) 108678 72 (E) 72(E) 45 61 ,000 (S) 61 ,000 ($) 61,000 ( S) 61 ,150 ID ID Triphenyl phosphate 115866 1.200 1,400 (S) NA NLV NLV 1.400 (S) 1.430 ID ID tris(2.3-Dibromopropyl)phosphat 126727 10 (M); 0.71 10 (M); 2.9 10 4,700 (S) 4,700 (S) 2,100 4,700 ID ID Urea 57 136 ID ID NA NLV NLV ID NA ID ID 7440622 4 .5 62 12 NLV NLV 9.7E+5 NA ID ID 8.9E+6 8.0E+6 2.00E+7 1.8E+6 4.BE+6 ID Vanadium Vinyl acetate (I) 108054 640 1.800 NA 4.1E+6 Vinyl chloride 75014 2.0 (A) 2.0 (A) 13 (X) 1,100 13,000 1,000 2.76E+6 33,000 Vllhite phosphorus (R) 12185103 0.11 0.31 NA NLV NLV 2,900 NA ID ID Xylenes (I) 1330207 280 (E) 280 (E) 41 1.9E+5 (S) 1.9E+5 (S) 1.9E+5 (S) 1.86E+S 70.000 1.9E+5 (S) Zinc (8) 7440666 2,400 5,000 (E) NLV NLV 1.1E+8 NA ID ID March 25, 2011 (G) Page 14 of 14 �Attachment 1 TABLE 2. SOIL: RESIDENTIAL PART 201 GENERIC CLEANUP CRITERIA AND SCREENING LEVELS; PART 213 TIER 1 RISK-BASED SCREENING LEVELS (RBSLs) DOCUMENT RELEASE DATE: MARCH 25, 2011 All criteria, unless otherwise noted, are expressed in units of parts per billion (ppb). One ppb is equivalent to one microgram per kilogram (ug/kg). Criteria with six or more digits are expressed in scientific notation. For example, 200,000 is presented as 2.0E+S. The lowest generic soil criterion for a given hazardous substance is presented in a bold box. A footnote is designated by a letter in parentheses and is explained in the footnote pages that follow the criteria tables. When the risk-based criterion is less than the target detection limit (TDL), the TDL is listed as the criterion (R 299.5707). In these cases, two numbers are present in the cell. The first number is the criterion (i.e., TDL), and the second number is the risk-based value. Criteria were originally promulgated December 21, 2002 within the Administrative Rules for Part 201, Environmental Remediation, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. This table reflects revisions to the criteria pursuant to the December 2010 Part 201 amendments and new criteria consistent with the provisions of R299.5706a. The effective dates of the criteria and screening levels in this table vary. Please contact the Remediation Division Toxicology Unit for additional information. Guidesheet Number Hazardous Substance Acenaphthene - Groundwater Protection #11 #10 #12 Ambient Air (Y) Indoor Air #13 Groundwater Groundwater Surface Water Contact Protection Interface Protection Criteria & RBSLs Criteria &RBSLs #14 #15 Soil Volatilization to Indoor Air Inhalation Criteria & RBSLs Infinite Source Volatile Soil Inhalation Criteria (VSIC) & RBSLs Direct Contact #16 #17 #18 #19 #20 FiniteVSIC tors Meter Source Thickness FiniteVSIC for2 Meter Source Thickness Particulate Soil Inhalation Criteria & RBSLs Direct Contact Criteria & RBSLs Soil Saturation Concentration Screening Levels Chemical Abstract Service Number Statewide Default Background Levels Drinking Water Protection Criteria & RBSLs 83329 NA 3.0E+5 8,700 9.7E+5 1.9E+8 8.1E+7 8.1E+7 8.1E+7 1.4E+10 4.1E+7 NA 5,900 ID 4.4E+S 1.6E+6 2.2E+6 2.2E+6 2.2E+6 2.3E-t-9 1.6E-t-6 NA 1.1E+8 Acenaphthylene 208968 NA Acetaldehyde (I) 75070 NA 19,000 2,600 1.1 E+S (C) 2.2E+5 1.7E+S 1.7E+S 2.8E+5 6.0E+8 2.9E+7 Acetate 71501 NA ID (G) ID ID ID ID ID ID ID ID Acetic acid 64197 NA 84,000 (G) 6.5E+8 (C) NLV NLV NLV NLV 1.7E+10 1.3E+8 6.SE+S Acetone (I) 67641 NA 15,000 34,000 1.1E+8 (C) 1.1E+8 (C) 1.3E+8 1.3E+8 1.9E+8 3.9E+11 2.3E+7 1.1 E+8 Acetonitrile 75058 NA 2,800 NA 2.2E+7 (C) 4.8E+6 1.6E+6 1.6E+6 2.1E+6 4.0E+9 4.3E+6 2.2E+7 Acetophenone 98862 NA 30,000 ID 1.1E+6 (C) 1.1E+6 (C) 4.4E+7 4.4E+7 4.4E+7 3.3E+10 1.1E+6 (C) 1.1E+6 Acrolein (I) 107028 NA 2,400 NA 2.3E+7 {C) 410 310 310 610 1.3E+6 3.6E+6 2.3E+7 Acrylamide 79061 NA 10 200 (X) 2.6E+S NLV NLV NLV NLV 2.4E+6 1,900 NA Acrylic acid 79107 NA 78,000 NA 1.1E+8 (C) 2.4E+6 1.9E+5 2.3E+S 2.3E+S 6.7E+7 3.5E+7 (DD) 1. 1E+8 Acrylonitrile (I) 107131 NA 100 (M): 40 2.8E+S 6,600 5,000 S,100 10,000 4.6E+7 16,000 8.3E+6 NA 1100 (M): 52 Alachlor 15972608 NA 52 290 {X) 44,000 NLV NLV NLV NLV ID 93,000 Aldicarb 116063 NA 60 NA 2.4E+6 NLV NLV NLV NLV ID 2.3E+5 NA 1646884 NA 200 (M); 40 NA 4.2E+7 NLV NLV NLV NLV ID 2.5E+5 NA 1646873 NA 200(M): 80 NA 5.4E+7 NLV NLV NLV NLV ID 2.9E+5 NA 1.3E+6 58,000 58,000 58,000 6.4E+5 1,000 NA Aldicarb sulfone Aldicarb sulfoxide I 309002 NA NLL NLL NLL Aluminum (8) 7429905 6.9E+6 1,000 NA 1.0E+9 (0) NLV NLV NLV NLV ID 5.0E+7 (DD) NA Ammonia 7664417 NA ID (CC) ID ID ID ID ID 6.7E+9 ID 1.0E+7 994058 NA 3,900 NA 4.4E+5 (C) 58,000 3.4E+5 7.6E+5 1.8E+6 4 .1E+9 4.4E+5 (C} 4.4E+S NA 1.100 2.8E+6 NLV NLV NLV NLV 6.7E+7 3.3E+S 4.SE+6 Aldrin !-Amyl methyl ether (TAME) Aniline March 25, 2011 62533 I 330 (M); 80 I Page 1 of 14 �Attachment 1 TABLE 2. SOIL: RESIDENTIAL PART 201 GENERIC CLEANUP CRITERIA AND SCREENING LEVELS; PART 213 TIER 1 RISK-BASED SCREENING LEVELS (RBSLs) DOCUMENT RELEASE DATE: MARCH 25, 2011 All criteria, unless otherwise noted, are expressed in units of parts per billion (ppb). One ppb is equivalent to one microgram per kilogram (ug/kg). Criteria with six or more digits are expressed in scientific notation. For example, 200,000 is presented as 2.0E+5. The lowest generic soil criterion for a given hazardous substance is presented in a bold box. A footnote is designated by a letter in parentheses and is explained in the footnote pages that follow the criteria tables. When the risk-based criterion is less than the target detection limit (TOL), the TDL is listed as the criterion (R 299.5707). In these cases, two numbers are present in the cell. The first number is the criterion (i.e., TDL), and the second number is the risk-based value. Criteria were originally promulgated December 21, 2002 within the Administrative Rules for Part 201, Environmental Remediation, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. This table reflects revisions to the criteria pursuant to the December 2010 Part 201 amendments and new criteria consistent with the provisions of R299.5706a. The effective dates of the criteria and screening levels in this table vary. Please contact the Remediation Division Toxicology Unit for additional information. - #10 Chemical Abstract Service Number Statewide Default Background Levels Drinking Water Protection Criteria & RBSLs 120127 NA 41,000 ID 7440360 NA 4,300 94.000 (X) Guidesheet Number Hazardous Substance Anthracene Antimony Groundwater Protection #11 I #12 Ambient Air M Indoor Air #14 #1S Soil Volatilization to Indoor Air Inhalation Criteria & RBSLs Infinite Source Volatile Soil Inhalation Criteria (VSIC) &RBSLs 41 ,000 1.0E+9 (0) 4.9E+7 NLV #13 Groundwater Groundwater Surface Water Contact Interface Protection Protection Criteria Criteria & RBSLs & RBSLs Direct Contact #16 #17 #18 #19 #20 FiniteVSIC for s Meter Source Thickness Finite VSIC for 2 Meter Source Thickness Pa rticulate So il Inhalation Criteria &RBSLs Direct Contact Criteria & RBSLs Soil Saturation Concentration Screening Levels 1.4E+9 1.4E+9 1.4E+9 6.7E+10 2.3E+8 NA NLV NLV NLV 1.3E+7 1.8E+5 NA NLV NLV Arsenic 7440382 5,800 4,600 4,600 2.0E+6 NLV NLV 7.2E+S 7,600 NA Asbeslos (88) 1332214 NA NLL NLL NLL NLV NLV NLV NLV 1.0E+7 (M): 10 NA Alrazine 1912249 NA 60 150 1.1E+S NLV NLV NLV NLV ID 71,000 (OD) NA A,:obenzene 103333 NA 4,200 ID 3.0E+S 6.1E+6 6.3E+S 6.3E+S 6.3E+5 1.0E+8 1.4E+S NA Barium (B) 7440393 75,000 1.3E+6 (G) 1.0E+9 (D) NLV NLV NLV NLV 3.3E+8 3.7 E+7 NA Benzene (I) 71432 NA 100 4,000 (X) 2 .2E+5 1,600 13,000 34,000 79,000 3.8E+8 1.8E+5 4.0E+S Benzidlne 92875 NA NLV NLV NLV NLV 46,000 NA NA I <:QnM I Benzo(a)anthracene (Q) 56553 NA 1,000 (M); 6.0 NLL 1,000 (M); 6.0 1,000 (M); 140 NLL NLL NLV NLV NLV NLV ID 1,000 (M); 23 20,000 Benzo(b)fluoranthene (Q) 205992 NA NLL NLL NLL ID ID ID lD ID 20,000 Benzo{k)fluoranthene (Q) NA 207089 NA NLL NLL NLL NLV NLV NLV NLV ID 2.0E+S NA Benzo(g,h,i)perylene 191242 NA NLL NLL NLL NLV NLV NLV NLV 8.0E+8 2.5E+6 NA Benzo(a)pyrene (Q) 50328 NA NLL NLL NLL NLV NLV NLV NLV 1.SE+6 2,000 NA Benzoic acid 65850 NA 6.4E+5 NA 7.0E+7 NLV NLV NLV NLV ID 9.9E+8 NA Benzyl alcohol 100516 NA 2.0E+S NA S.8E+6 (C) NLV NLV NLV NLV 3.3E+1 1 5.8E+6 (C) 5.8E+6 BenZyl chloride 100447 NA 150 NA 72,000 6,300 14,000 14,000 17,000 6.2E+7 48,000 2.3E+S 7440417 NA 51,000 (G) 1.0E+9 (0) NLV NLV NLV NLV 1.3E+6 4.1E+S NA NLV Be ryllium bis(2-Chloroethoxy)ethane 112265 NA ID ID ID NLV NLV NLV ID ID 2.7E+6 bis(2-Chloroethyl)ether (I) 111444 NA 100 100 (M); 20 1.1 E+S 8,300 3,800 3,800 3,800 9.4E+6 13,000 2.2E+6 bis(2-Ethylhexyl)phthalate 117817 NA NLL NLL NLL NLV NLV NLV NLV 7.0E+8 2.8E+6 1.0E+7 March 25, 2011 I Page 2 of 14 �Attachment 1 TABLE 2. SOIL: RESIDENTIAL PART 201 GENERIC CLEANUP CRITERIA AND SCREENING LEVELS; PART 213 TIER 1 RISK-BASED SCREENING LEVELS (RBSLs) DOCUMENT RELEASE DATE: MARCH 25, 2011 All criteria, unless otheiwise noted, are expressed in units of parts per billion (ppb). One ppb is equivalent to one microgram per kilogram (ug/kg). Criteria with six or more digits are expressed in scientific notation. For example, 200,000 is presented as 2.0E+5. The lowest generic soil criterion for a given hazardous substance Is presented in a bold box. A footnote is designated by a letter in parentheses and is explained in the footnote pages that follow the criteria tables. When the risk-based criterion is less than the target detection limit (TOL), the TOL is listed as the criterion (R 299.5707). In these cases, two numbers are present in the cell. The first number is the criterion (i.e., TDL), and the second number is the risk-based value. Criteria were originally promulgated December 21, 2002 within the Administrative Rules for Part 201, Environmental Remediation, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. This table reflects revisions to the criteria pursuant to the December 2010 Part 201 amendments and new criteria consistent with the provisions of R299.5706a. The effective dates of the criteria and screening levels in this table vary. Please contact the Remediation Division Toxicology Unit for additional information. - #10 Chemical Abstract Service Number Statewide Default Background Levels Drinking Water Protection Criteria & RBSLs 7440428 NA 10,000 1.0E+S (X) 1.0E+9 (D) NLV 200 800 (X) 96,000 NLV Guidesheet Number Hazardous Substance Boron (B) Groundwater Protection #11 #12 Indoor Air #13 Groundwater Groundwater Surface Water Contact Protection Interface Protection Criteria Criteria & RBSLs & RBSLs Ambient Air (Y) #14 #15 Soil Volatilization to Indoor Air Inhalation Criteria & RBSLs Infinite Source Volatile Soil Inhalation Criteria (VSIC) &RBSLs Direct Contact #16 #17 #18 #19 #20 Finite VSIC for 5 Meter Sou rce Thickness Finite VSIC for2 Meter Source Thickness Particulate Soil Inhalation Criteria & RBSLs Direct Contact Criteria &RBSLs Soil Saturation Concentration Screening Levels NLV NLV NLV ID 4.8E+7 (DD) NA NLV NLV NLV ID 17,000 NA 7.6E+5 15541454 NA 8romobenzene (I) 108861 NA 550 NA 3.6E+5 3.1E+S 4,SE+S 4.SE+S 4.5E+S 5.3E+8 5.4E+5 Bromodichloromethane 75274 NA 1,600 (IN) ID 2.8E+5 1,200 9,100 9,700 19,000 8.4E+7 1.1E+S 1.5E+6 Bromoform 75252 NA 1,600 (IN) ID 8.7E+5 (C) 1.SE+S 9.0E+S 9.0E+5 9.0E+5 2.8E+9 8.2E+5 8.7E+5 Bromomethane 74839 NA 200 700 1.4E+6 860 11,000 57,000 1.4E+5 3.3E+8 3.2E+S 2.2E+6 n-Butanol (I) 71363 NA 19,000 NA 8.7E+6 (C) NLV NLV NLV NLV 2.3E+10 8,7E+6 (C) 8.7E+6 2-Butanone (MEK) (I) 78933 NA 2.6E+5 44.000 2.7E+7 (C) 2.7E+7 (C) 2.9E+7 2.9E+7 3.5E+7 6.7E+10 4.7E+1 1 2.7E+7 IC.DD\ 1.1E+6 (C) 2.7E+7 3.2E+8 Bromate n-Butyl acetate 123864 NA 11.000 NA 1.1E+6 (C) 1.1 E+6 (C) 1.1 E+8 2.SE+S t-Butyl alcohol 75650 NA 78,000 NA 1.1E+8 (C) 1.1E+8 (C) 9.7E+7 2.0E+S 2.0E+S 1.3E+11 1.1E+8 (C) 1.1 E+8 Butyl benzyl phthalate 85687 NA 3.1E+5 (C) 1.2E+5 (X) 3.1E+5 (C) NLV NLV NLV NLV 4.7E+10 3.1E+5 (C) 3.1E+5 n-Butylbenzene 104518 NA 1,600 ID 1.2E+S ID ID ID ID 2.0E+9 2.5E+6 1.0E+7 1,600 ID 88,000 ID ID ID ID 4.0E+8 2.5 E+6 1.0E+7 sec-Butylbenzene t-Butylbenzene (I) Cadmium (B) Camphene (I) Caprolactam 135988 NA 98066 NA 1,600 ID 1.8E+5 ID ID ID ID 6.7E+8 2.5E+6 1.0E+7 7440439 1,200 6,000 (G,X) 2.3E+8 NLV NLV NLV NLV 1.7E+6 5.5E+S NA 79925 NA ID NA IP 3,700 1.SE+5 9.1E+5 2.2E+6 5.3E+9 ID NA 105602 NA 1.2E+5 NA 1.0E+9 (D) NLV NLV NLV NLV 6.7E+8 5.3E+7 (DD) NA NA NA 2.6E+6 ID ID ID ID ID 2.2E+7 1,100 8.2E+5 NLV NLV NLV NLV 6.2E+7 5.3E+5 NA 800 NA 6.8E+6 NLV NLV NLV NLV ID 1.1E+6 NA 16.000 lD 2.8E+5 (C) 76.000 1.3E+6 7.9E+6 1.9E+7 4.7E+10 2.8E+5 IC.DD\ 2.8E+5 Carbary! 63252 NA 14.000 Carbazole 86748 NA 9,400 Carbofuran 1563662 NA 75150 NA Carbon disulfide (l,R) March 25, 2011 1.1E+6 I Page 3 of 14 �Attachment 1 TABLE 2. SOIL: RESIDENTIAL PART 201 GENERIC CLEANUP CRITERIA AND SCREENING LEVELS; PART 213 TIER 1 RISK-BASED SCREENING LEVELS (RBSLs) DOCUMENT RELEASE DATE: MARCH 25, 2011 All criteria, unless otherwise noted, are expressed in units of parts per billion (ppb). One ppb is equivalent to one microgram per kilogram (ug/kg). Criteria with six or more digits are expressed in scientific notation. For example, 200,000 is presented as 2.0E+S. The lowest generic soil criterion for a given hazardous substance is presented in a bold box. A footnote is designated by a letter in parentheses and is explained in the footnote pages that follow the criteria tables. When the risk-based criterion is less than the target detection limit (TDL), the TDL is listed as the criterion (R 299.5707). In these cases, two numbers are present in the cell. The first number is the criterion (i.e., TDL), and the second number is the risk-based value. Criteria were originally promulgated December 21, 2002 within the Administrative Rules for Part 201, Environmental Remediation, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. This table reflects revisions to the criteria pursuant to the December 2010 Part 201 amendments and new criteria consistent with the provisions of R299.5706a. The effective dates of the criteria and screening levels in this table vary. Please contact the Remediation Division Toxicology Unit for additional information. Groundwater Protection Guidesheet Number Hazardous Substance Carbon tetrachloride Chlordane (J) Chloride Chlorobenzene (I) ~ #10 #11 Drinking Water Protection Criteria & RBSLs #12 Indoor Air #13 Ground water Groundwater Surface Water Contact Protection Interface Protection Criteria Criteria &RBSLs & RBSLs Ambient Air (Y) #14 #15 Soil Volatilization to Indoor Air Inhalation Criteria &RBSLs Infinite Source Volatile Soil Inhalation Criteria (VSIC) & RBSLs Direct Contact #16 #17 #18 #19 #20 FiniteVSIC for 5 Meter Source Thickness FiniteVSIC for2 Meter Source Thickness Particulate Soil Inhalation Criteria &RBSLs Direct Contact Criteria & RBSLs Soil Saturation Concentration Screening Levels 96,0 00 3.9E+5 31,000 NA Chemical Abstract Service Number Statewide Default Background Levels 56235 NA 100 900 (X) 92,000 190 3.500 12,000 28,000 1.3E+8 57749 NA NLL NLL NLL 1.1E+7 1.2E+6 1.2E+6 1.2E+6 3.1E+7 16887006 NA NA 5.0E+6 (X) 2,000 500 108907 I ID NLV NLV NLV NLV ID 5.0E+5 ( F) NA 2.6E+5 (C) 1.2E+5 7.7E+5 9.9 E+5 2.1E+6 4.7E+9 2.6E+5 (C) 2.6E+5 p-Chlorobenzene sulfonic acid 98668 ID NA ID ID ID ID ID 2.3E+8 ID 75683 NA NA 1.SE+S 1-Chloro-1,1-<lifluoroethane 3.0E+5 NA 9.6E+5 (C) 9.6E+5 (C) 7.9E+7 5.6E+8 1.4E+9 3.3E+12 9.6E+5 (C) 9.6 E+5 Chloroethane 75003 NA 8,600 22,000 (X) 9.5E+5 (C) 9.5E+5 (C) 3.0E+7 1.2E+8 2.8E+8 6.7E+11 9.5E+5 (C) 9.5E+5 ID NA ID ID ID ID ID ID ID 1.9E+6 1,600 (VV) 7,000 1.5E+6 (CJ 7,200 45,000 1.2E+5 2.7E+5 1.3E+9 1.2E+6 1.5E+6 1.1E+6 2-Chloroethyl vinyl ether 110758 Chloroform 67663 Chloromelhane (I) 74873 4-Chloro-3-methylphenol beta-Chloronaphthalene NA NA 5,200 ID 1.1E+6 (CJ 2,300 40,000 4.1E+5 1.0E+6 4.9E+9 1.1E+6 (C) 59507 NA NA 5,800 280 3.0E+6 NLV NLV NLV NLV ID 4.5E+6 NA 91 587 NA 6.2E+5 NA 2.3E+6 ID ID ID ID ID 5.6E+7 NA 2-Chlorophenol 95578 NA 900 360 1.9E+6 4.3E+5 9.6E+S 9.6E+5 9.6E+5 1.2E+9 1.4E+6 1.9E+7 o-Chlorotoluene (I) 95498 NA 3,300 ID 5.DE+5 (C) 2.7E+5 1.2E+6 2.9E+6 6.3E+6 4.7E+9 5.0E+5 (C) 5.0E+S NA 2921882 NA 17,000 1,500 8.4E+5 130 4,600 23 ,000 55,000 1.3E+8 1.1E+7 16065831 18,000 (total) 1.0E+9 (D) (G.X) 1.0E+9 (D) NLV NLV NLV NLV 3.3E+8 7.9E+8 NA Chromium (VI) 18540299 NA 30,000 3,300 1.4E+8 NLV NLV NLV NLV 2.6E+5 2.5E+6 NA Chrysene (0) 218019 NA NLL NLL NLL ID ID ID ID ID 2.0E+6 Cobalt 7440484 6,800 800 2,000 4.8E+7 NLV NLV NLV NLV 1,3E+7 2.6E+6 NA NA Copper (B) 7440508 32,000 5.8E+6 (G) 1.0E+9 (0) NLV NLV NA 21725462 NA 56,000 NLV NLV NLV NLV 2.0E+7 1,100(X) NLV NLV 1.3E+8 200 10 14,000 NA Chlorpyrifos Chromium {Ill) (B,H) Cyanazine March 25, 2011 I Page 4 of 14 �Attachment 1 TABLE 2. SOIL: RESIDENTIAL PART 201 GENERIC CLEANUP CRITERIA AND SCREENING LEVELS; PART 213 TIER 1 RISK-BASED SCREENING LEVELS (RBSLs) DOCUMENT RELEASE DATE: MARCH 25, 2011 All criteria, unless otherwise noted, are expressed in units of parts per billion (ppb). One ppb is equivalent to one microgram per kilogram (ug/kg). Criteria with six or more digits are expressed in scientific notation. For example, 200,000 is presented as 2.0E+5. The lowest generic soil criterion for a given hazardous substance is presented in a bold box. A footnote is designated by a letter in parentheses and is explained in the footnote pages that follow the criteria tables. When the risk-based criterion is less than the target detection limit (TDL), the mL is listed as the criterion {R 299.5707). In these cases, two numbers are present in the cell. The first number is the criterion (i.e., TDL), and the second number is the risk-based value. Criteria were originally promulgated December 21, 2002 within the Administrative Rules for Part 201, Environmental Remediation, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. This table reflects revisions to the criteria pursuant to the December 2010 Part 201 amendments and new criteria consistent with the provisions of R299.5706a. The effective dates of the criteria and screening levels in this table vary. Please contact the Remediation Division Toxicology Unit for additional information. - #10 Chemical Abstract Service Number Statewide Default Background Levels Guidesheet Number Hazardous Substance Groundwater Protection #11 Drinking Water Protection Criteria & RBSLs #12 Indoor Air #13 Groundwater Groundwater Surface Water Contact Interface Protection Protection Criteria Criteria &RBSLs & RBSLs Ambient Air (Y) #14 #15 Soil Volatilization to Indoor Air Inhalation Criteria & RBSLs Infinite Source Volatile Soil Inhalation Criteria (VSIC) & RBSLs Direct Contact #16 #17 #18 #19 #20 FiniteVSIC tors Meter Source Thickness FiniteVSIC for2 Meter Source Thickness Particulate Soil Inhalation Criteria & RBSLs Direct Contact Criteria & RBSLs Soil Saturation Concentration Screening Levels 57125 390 (total) 4,000 100 2.SE-+-5 NLV NLV NLV NLV 2.5E-+-5 12,000 NA Cyclohexanone 108941 NA 5.2E-+-6 NA 2.2E+8 (C) 17,000 1.0E+6 1.1E+7 2.7E+7 6.7E+10 2.2E+8 (C) 2.2E-+-8 Dacthal 1861321 NA 50,000 NA 3.4E-+-S NLV NLV NLV NLV ID 2.3E+6 NA Dalapon 75990 NA 4 ,000 NA S.9E-+-7 (C) NLV NLV NLV NLV ID 1.9E+7 5.9E+7 NA Cyanide (P,R) 4-4'-DDD 72548 NA NLL NLL NLL NLV NLV NLV NLV 4.4E-+-7 95,000 4-4'-DDE 72559 NA NLL NLL NLL NLV NLV NLV NLV 3.2E+7 45,000 NA NLL Nll NLL NLV NLV NLV NLV 3.2E+7 57,000 NA 50293 NA 1163195 NA 1.4E+5 Di-n-butyl phthalate 84742 NA 7.6E-+-5 (C) Di(2-ethylhexyl) adipate 103231 NA 9.6E-+-5 (C) Di-n-octyl phthalate 117840 NA 123422 NA 4-4'-DOT Decabromodiphenyl ether Diacetone alcohol (I} NA 1.4E-+-S 1.0E+9 (D} 8.6E+7 8.6E-+-7 8.6E+7 2.3E+9 3.8E+6 NA 11,000 7.6E+5 (C) NLV NLV NLV NLV 3.3E+9 7.6E+5 (C) 7.6E+5 ID 9.6E+5 (C) NLV NLV NLV NLV 9.2E+9 9.6E+5 1.0E+8 ID 1.4E+8 (C) NLV NLV NLV NLV 3.1E+10 9.6E+5 IC DD\ 6.9E-+-6 ID NA ID NLV NLV NLV NLV 1.6E+11 ID 1.1E+8 72 95,000 NLV NLV NLV NLV ID 12,000 (DD) 3.1 E-+-5 2,000 NA I 1.4E+8 Diazinon 333415 NA 95 Dibenzo(a,h)anthracene (0) 53703 NA NLL NLL NLL NLV NLV NLV NLV ID Dibenzofuran 132649 NA ID 1,700 ID 2.0E+S 1.3E+5 1.3E-+-5 1.3E+5 6.7E+6 ID NA Dibromochloromethane 124481 NA 1,6000N) ID 3.6E-+-5 3,900 24,000 24,000 33,000 1.3E+8 1.1 E+S 6.1E-+-5 Dibromochloropropane 96128 NA 10 (M); 4.0 ID 1,200 {C) 1.200 (C) 13,000 13,000 13,000 1.3E-+-7 1,200 (C) 1,200 2.0E+6 I 74953 NA 1,600 NA 2.0E+6 (C) ID ID ID ID ID 2.0E-+-6 (C) 1918009 NA 4.400 NA 1.2E+7 NA NLV NLV NLV ID 3.4E-+-6 NA 1,2-0ichlorobenzene 95501 NA 14.000 280 2.1E-+-5 (C) 2.1E+5 (C) 3.9E+7 3.9E+7 5.2E+7 1.0E+11 2.1E+5 (C) 2.1E+5 1,3-Dichlorobenzene 541731 NA 170 680 51 ,000 26,000 79,000 79,000 1.1E-+-5 2.0E+8 1.7E+5 (C) 1.7E+5 Dibromomethane Dicamba March 25, 2011 Page 5 of 14 �Attachment 1 TABLE 2. SOIL: RESIDENTIAL PART 201 GENERIC CLEANUP CRITERIA AND SCREENING LEVELS; PART 213 TIER 1 RISK-BASED SCREENING LEVELS (RBSLs) DOCUMENT RELEASE DATE: MARCH 25, 2011 All criteria, unless otherwise noted, are expressed in units of parts per billion (ppb}. One ppb is equivalent to one microgram per kilogram (ug/kg). Criteria with six or more digits are expressed in scientific notation. For example, 200,000 is presented as 2.0E+5. The lowest generic soil criterion for a given hazardous substance is presented in a bold box. A footnote is designated by a letter in parentheses and is explained in the footnote pages that follow the criteria tables. When the risk-based criterion is less than the target detection limit (TDL}, the TDL is listed as the criterion (R 299.5707). In these cases, two numbers are present in the cell. The first number is the criterion (i.e., TDL), and the second number is the risk-based value. Criteria were originally promulgated December 21, 2002 within the Administrative Rules for Part 201, Environmental Remediation, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. This table reflects revisions to the criteria pursuant to the December 2010 Part 201 amendments and new criteria consistent with the provisions of R299.5706a. The effective dates of the criteria and screening levels in this table vary. Please contact the Remediation Division Toxicology Unit for additional information. Guidesheet Number Hazardous Substance - Groundwater Protection #10 Chemical Abstract Service Number Statewide Default Background Levels 106467 #11 Drinking Water Protection Criteria &RBSLs #12 Indoor Air Ambient Air (Y) #16 #17 #18 #19 #20 FiniteVSIC for 5 Meter Source Thickness Finite VSJC for 2 Meter Source Thickness Particulate Soil Inhalation Criteria & RBSLs Direct Contact Criteria & RBSLs Soil Saturation Concentration Screening Levels 77,000 77.000 1.1E+5 4.5E+8 4.0E+5 NLV NLV NLV 6.5E+6 6,600 NA NA #14 #15 Soil Volatilization to Indoor Air Inhalation Criteria & RBSLs Infinite Source Volatile Soil Inhalation Criteria (VSIC) & RBSLs 1.4E+5 19,000 4,600 NLV #13 Groundwater Groundwater Surface Water Contact Interface Protection Protection Criteria Criteria & RBSLs &RBSLs Direct Contact 3,3'-Dichlorobenzidine 91941 NA NA Dichlorodifluoromethane 75718 NA 95,000 ID 1.0E+G (C) 9.0E+S 5.3E+7 5.5E+8 1.4E+9 3.3E+12 1.0E+6 (C) 1.0E+6 1,1-Dichloroethane 75343 1B,000 15,000 8.9E+5 (C) 2.3E+5 2.1E+6 5.9E+6 1.4E+7 3.3E+10 8.9E+5 (C) 8.9E+5 1,2-Dichloroethane (I) 107062 NA NA 100 7,200 (X) 3.BE+S 2,100 6,200 11,000 26,000 1.2E+B 91,000 1.2E+6 NA NA 140 2,600 2.2E+S 62 1,100 5,300 13,000 6.2E+7 2.0E+S 5.7E+5 1,400 12,000 6.4E+5 (C) 22,000 1.8E+5 4.2E+5 9.9E+5 2.3E+9 6.4E+5 (C) 6.4E+5 1.4E+6 1,4-Dichlorobenzene 1,700 360 j2,0DD (M); 28 2,000 (M); 7.4 1,1-Dichloroethylene (I) 75354 cis-1,2-Dichloroethylene 156592 trans-1,2-Dichloroethylene 156605 30,000 (X) 1.4E+6 (C) 23,000 2.SE+S 8.3E+5 2.0E+6 4.7E+9 1.4E+6 (C) 99309 NA NA 2,000 2,6-0ichloro-4-nitroaniline 44,000 NA 1.4E+5 NLV NLV NLV NLV ID 6.8E+7 NA 2,4-Dichlorophenol 120832 NA 1,500 330 (M); 220 9.6E+5 NLV NLV 6.6E+5 (DD) 1.8E+6 94757 NA 1,400 4,400 2.4E+6 NLV NLV NLV NLV 5.1E+9 2,4-Dichlorophenoxyacetic acid NLV NLV 6.7E+9 2.5E+6 NA 1,2-Dichloropropane (I) 78875 100 4,600 (X) 3.2E+5 4,000 25,000 50,000 2.7E+8 1.4E+S S.SE+S 1,3-Dichloropropene 542756 NA NA 1.1E+5 170 180 (X) 1.1E+5 1,000 18,000 68,000 1.6E+5 7.8E+8 10,000 6.2E+5 Dichlorovos 62737 NA 50 (M); 32 NA 1.2E+5 NLV NLV NLV NLV 3.3E+7 10.000 2.2E+6 84617 ID NA NLL ID ID ID ID ID 10 ID NA NLL 1.4E+5 19,000 19,000 19,000 6.SE+S 1,100 NA Dieldrin 60571 NA NA Diethyl ether 60297 NA 200 ID 7.4E+6 (C) 7.4E+6 (C) 8.5E+7 1.5E+8 3.4E+8 8.0E+11 7.4E+6 (C) 7.4E+6 Diethyl phtha!ate 84662 NA NA 1.1E+5 2,200 7.4E+5 (C) NLV NLV NLV NLV 3.3E+9 7.4E+5 (C) 7.4E+5 1,800 NA 8.0E+7 NLV NLV NLV NLV 1.3E+9 2.7E+6 1.1E+8 NA NA 600 ID 1,300 (C) 1,300 (C) 3.4E+S 7.GE+S 1.8E+6 4.1E+9 1,300 (C) 1,300 110 NA 4.2E+5 5.5E+6 6.2E+6 6.2E+6 7.3E+6 1.3E+10 1.7E+5 6.7E+6 Dicyclohexyl phthalate Diethylene glycol monobuty! ether Diisopropyl ether Oiisopropylamine (I) March 25, 2011 112345 108203 108189 NLL Page 6 of 14 �Attachment 1 TABLE 2. SOIL: RESIDENTIAL PART 201 GENERIC CLEANUP CRITERIA AND SCREENING LEVELS; PART 213 TIER 1 RISK-BASED SCREENING LEVELS (RBSLs) DOCUMENT RELEASE DATE: MARCH 25, 2011 All criteria, unless otherwise noted, are expressed in units of parts per billion (ppb). One ppb is equivalent to one microgram per kilogram (ug/kg). Criteria with six or more digits are expressed in scientific notation. For example, 200,000 is presented as 2.0E+S. The lowest generic soil criterion for a given hazardous substance is presented in a bold box. A footnote is designated by a letter in parentheses and is explained in the footnote pages that follow the criteria tables. When the risk-based criterion is less than the target detection limit (TDL), the TDL is listed as the criterion (R 299.5707). In these cases, two numbers are present in the cell. The first number is the criterion (i.e., TDL), and the second number is the risk-based value. Criteria were originally promulgated December 21, 2002 within the Administrative Rules for Part 201, Environmental Remediation, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. This table reflects revisions to the criteria pursuant to the December 2010 Part 201 amendments and new criteria consistent with the provisions of R299.5706a. The effective dates of the criteria and screening levels in this table vary. Please contact the Remediation Division Toxicology Unit for additional information. Guidesheet Number Hazardous Substance - Indoor Air Groundwater Protection #11 #10 #12 #13 Groundwater Groundwater Surface Water Contact Protection Interface Protection Criteria & RBSLs Criteria &RBSLs Ambient Air (Y} #14 #15 Soil Volatilization to Indoor Air Inhalation Criteria & RBSLs Infinite Source Volatile Soil Inhalation Criteria (VSIC) & RBSLs Direct Contact #16 #17 #18 #19 #20 FiniteVSIC for S Meter Source Thickness Finite VSIC for 2 Meter Source Thickness Particulate Soil Inhalation Criteria & RBSLs Direct Contact Criteria & RBSLs Soil Saturation Concentration Screening Levels Chemical Abstract Service Number Statewide Default Background Levels Drinking Water Protection Criteria &RBSLs 7.9E+5 (C} NA 7.9E+5 (C} NLV NLV NLV NLV 3.3 E+9 7.9E+5 (C} 7.9E+5 3,600 82,000 (X) 1.1E+8 (C) NLV NLV NLV NLV ID 5.6E+6 1.1E+S NA 4.0E+5 1.7E+5 1.5E+5 1.5E+5 1.5E+5 2.6E+8 5.0E+5 8.0E+5 131113 NA N,N-Dimethylacetamide 127195 NA N.N-Dimethylaniline 121697 NA 320 Dimethylformamide (I) 68122 NA 14,000 NA 1.1E+8 (C) NLV NLV NLV NLV 2.0E+9 2.2E+7 1.1E+8 2,4-Dimethylphenol 105679 NA 7,400 7,600 1.0E+7 NLV NLV NLV NLV 4.7E+9 1.1E+7 NA 576261 NA 330 (M); 88 NA 1.3E+5 NLV NLV NLV NLV 1.3E+8 1.4E+5 NA 95658 NA 330 (M); 200 NA 3.6E+5 NLV NLV NLV NLV 2.3E+8 3.2E+S NA NLV NLV 1.3E+9 1.8E+7 (C} 1.8E+7 Dimethyl phthalate 2,6-Dimethylphenol 3,4-Dimethytphenol I Dimethylsulfoxide 67685 NA 4.4E+6 3.BE+6 NLV NLV 2,4-Dinitrotoluene 121 142 NA 430 NA 1.7E+5 NLV NLV NLV NLV 1.6E+7 48,000 NA Dinoseb 88857 NA 300 200 (M}; 43 1.4E+S (C) NLV NLV NLV NLV 2.7E+8 66,000 ( DD) 1.4E+5 1,4-0io,cane (I) 123911 NA 1,7 00 56,000 (X) 3.4E+7 NLV NLV NLV NLV 5.7E+8 5.3E+S 9.7E+7 400 NA 1.4E+7 NLV NLV NLV NLV ID 5.0E+S NA NLV NLV 4.7E+B 9.7E+5 NA Diquat Diuron 85007 330541 NA I 1.8E+7 (C) NA 620 NA 7.4E+5 NLV NLV Endosulfan (J} 115297 NA NLL NLL NLL ID ID 10 ID ID 1.4E+6 NA Endothall 145733 NA NLL NLL NLL N LV NLV NLV NLV 2.3E+9 3.8E+6 NA 72208 NA NLL NLL NLL NLV NLV NLV NLV ID 65,000 NA 2.2E+5 64,000 31,000 31,000 35,000 6.7E+7 8 ,900 7.3E+6 NLV NLV 1.3 E+1 2 1. 1E+8 7. SE+6 Endrin Epichlorohydrin (I) 106898 NA 100 NA Ethanol (I) 64175 NA 3.8E+7 ID 1.1 E+B (C) NLV NLV Ethyl acetate (I) 141786 NA 1.3E+S NA 7.5E+6 (C) 7.SE+S (C) 4.9E+7 4.9E+7 9.8E+7 2.1E+1 1 1.1 E+B I C.DD) 7.SE+6 (C) 637923 NA 980 ID ID 5.4E+5 1.9E+6 4.5E+6 1.1E+7 2.5E+ 10 ID 6.5E+S 100414 NA 1,500 360 1.4E+S (C) 87,000 7.2 E+5 1.0E+6 2.2E+6 1.0E+10 1.4E+5 (C) 1.4E+S Ethyl-tert-butyl ether (ETBE} Ethylbenzene (I) March 25, 2011 I Page 7 of 14 �Attachment 1 TABLE 2. SOIL: RESIDENTIAL PART 201 GENERIC CLEANUP CRITERIA AND SCREENING LEVELS; PART 213 TIER 1 RISK-BASED SCREENING LEVELS (RBSLs) DOCUMENT RELEASE DATE: MARCH 25, 2011 All criteria, unless otherwise noted, are expressed in units of parts per billion {ppb). One ppb is equivalent to one microgram per kilogram (ug/kg). Criteria with six or more digits are expressed in scientific notation. For example, 200,000 is presented as 2.0E+S. The lowest generic soil criterion for a given hazardous substance is presented in a bold box. A footnote is designated by a letter in parentheses and is explained in the footnote pages that follow the criteria tables. When the risk-based criterion is less than the target detection limit (TOL), the TOL is listed as the criterion (R 299.5707). In these cases, two numbers are present in the cell. The first number is the criterion (i.e., TOL), and the second number is the risk-based value. Criteria were originally promulgated December 21, 2002 within the Administrative Rules for Part 201, Environmental Remediation, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. This table reflects revisions to the criteria pursuant to the December 2010 Part 201 amendments and new criteria consistent with the provisions of R299.5706a. The effective dates of the criteria and screening levels in this table vary. Please contact the Remediation Division Toxicology Unit for additional information. Groundwater Protection Guidesheet Number Hazardous Substance Ethylene dibromide -· Soil Volatilization to Indoor Air Inhalation Criteria & RBSLs #16 #17 #18 #19 #20 FiniteVSIC for S Meter Source Thickness FiniteVSJC for 2 Meter Source Thickness Particulate Soil Inhalation Criteria & RBSLs Direct Contact Criteria & RBSLs Soil Saturation Concentration Screening Levels 20 (M): 1.0 110 (X) 500 670 1,700 1,700 3,300 1.4E+7 92 8.9E+5 3.0E+S 3.8E+6 (X) 1.1E+8 (C) NLV NLV NLV NLV 6.7E+10 1.1E+8 (C) 1.1E+8 74,000 NA 4.1E+7 (C) 7.4E+5 1.8E+7 1.5E+8 3.6E+8 8.7E+11 4.1E+7 (C) 4.1E+7 7.3E+5 5,500 7.3E+5 1.0E+9 (D) 7.4E+B 7.4E+8 7.4E+8 9.3E+9 4.6E+7 NA 3.9E+5 5,300 8.9E+S 5.8E+8 1.3E+8 1.3E+8 1.3E+8 9.3E+9 2.7E+7 7782414 NA NA 40,000 10 2.4E+8 NLV NLV NLV NLV 10 9.0E+6 (DO) NA NA 50000 NA 26,000 2.400 6.0E+7 (C) 12,000 13,000 23,000 52,000 2.4E+8 4.1E+7 6.0E+7 1.4E+5 1.3E+8 UE+B (C) 1.1E+8 2.5E+6 1.0E+7 NA 206440 Fluorene 86737 Glyphosate #15 Infinite Source Volatile Soil Inhalation Criteria (VSIC) & RBSLs NA NA NA NA 111762 Gentian violet Groundwater Groundwater Surface Water Contact Protection Interface Criteria Protection Criteria & RBSLs &RBSLs #14 106934 Fluoranthene 1-Formylpiperidine #13 Drinking Water Protection Criteria &RBSLs 107211 Formic acid (1.U) #12 Direct Contact Statewide Default Background Levels Ethylene glycol monobuiyl ether Formaldehyde #11 Ambient Air (Y) Chemical Abstract Service Number Ethylene glycol Fluorine (soluble fluoride) (B) #10 Indoor Air 64186 NA 2.0E+5 ID 1.1E+8 (C) 1.5E+6 2.1E+S 1.4E+5 2591868 1,600 NA ID JD ID ID ID ID 548629 NA NA 300 NLV NLV NLV NLV ID 96,000 1071836 NLL NA NLL 2.0E+7 NA NLL NLV NLV NLV NLV 10 1.1E+7 (00) NA 3.5E+5 62,000 62,000 62.000 2.4E+6 5,600 76448 NA NLL NLL Heplachlor epoxide 1024573 NLL NLL NLV NLV NLV NLV 1.2E+6 3,100 NA NA n-Heptane 142825 NA NA NLL NLL 2.4E+5 (C) NA 2.4E+5 (C) 2.4E+5 (C) 2.1E+7 4.4E+7 1.0E+8 2.3E+11 2.4E+5 (C) 2.4E+5 Hexabromobenzene 87821 NA NA 5,400 10 5.400 ID 10 ID ID 10 1.1 E+6 NA 350 8,200 41,000 17,000 17,000 17,000 6.8E+6 8,900 NA 26,000 91 3.5E+5 (C) 1.3E+5 1.3E+5 1.3E+5 1.3E+5 1.4E+8 1.0E+S 3.5E+5 NA Heptachlor Hexachlorobenzene (C-66) 118741 He><achlorobutadiene (C-46) 87683 1,800 I I alpha-Hexachlorocyclohexane 319846 NA NA 18 ID 2,500 30,000 12,000 22,000 25,000 1.7E+6 2,600 beta-Hexachlorocyclohexane 319857 NA 37 ID 5,100 NLV NLV NLV NLV 5.9E+6 5,400 NA 77474 NA 3.2E+5 ID 7.2E+5 (C) 30,000 50.000 50,000 50,000 1.3E+7 7.2E+5 (C) 7.2E+5 67721 NA 430 1,800 (X} 1.1E+5 40,000 5.SE+S 9.3E+5 9.3E+S 2.3E+8 2.3E+5 NA He><achlorocyclopentadiene <C-56\ Hexachloroethane March 25, 2011 I Page 8 of 14 �Attachment 1 TABLE 2. SOIL: RESIDENTIAL PART 201 GENERIC CLEANUP CRITERIA AND SCREENING LEVELS; PART 213 TIER 1 RISK-BASED SCREENING LEVELS (RBSLs) DOCUMENT RELEASE DATE: MARCH 25, 2011 All criteria, unless otherwise noted, are expressed in units of parts per billion (ppb). One ppb is equivalent to one microgram per kilogram (ug/kg). Criteria with six or more digits are expressed in scientific notation. For example, 200,000 is presented as 2.0E+S. The lowest generic soil criterion for a given hazardous substance is presented in a bold box. A footnote is designated by a letter in parentheses and is explained in the footnote pages that follow the criteria tables. When the risk-based criterion is less than the target detection limit (TDL), the TDL is listed as the criterion (R 299.5707). In these cases, two numbers are present in the cell. The first number is the criterion (i.e., TDL), and the second number is the risk-based value. Criteria were originally promulgated December 21, 2002 within the Administrative Rules for Part 201, Environmental Remediation, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. This table reflects revisions to the criteria pursuant to the December 2010 Part 201 amendments and new criteria consistent with the provisions of R299.5706a. The effective dates of the criteria and screening levels in this table vary. Please contact the Remediation Division Toxicology Unit for additional information. Guidesheet Number Hazardous Substance - Indoor Air Groundwater Protection #10 #11 Chemical Abstract Service Number Statewide Default Background Levels Drinking Water Protection Criteria & RBSLs #12 #13 Groundwater Groundwater Surface Water Contact Protection Interface Protection Criteria Criteria & RBSLs & RBSLs Ambient Air (Y) #14 #15 Soil Volatili:z:ation to Indoor Air Inhalation Criteria & RBSLs Infinite Source Volatile Soil Inhalation Criteria (VSIC) & RBSLs Direct Contact #16 #17 #18 #19 #20 FiniteVSIC for 5 Meter Source Thickness FiniteVSIC for 2 Meter Source Thickness Particulate Soil Inhalation Criteria & RBSLs Direct C ontact Criteria &RBSLs Soil Saturation Concentration Screening Levels 110543 NA 44,000 (C) NA 44,000 (C) 44,000 (C) 3.0E+6 3.2E+6 6.2E+6 1.3E+10 44,000 (C) 44,000 2-Hexanone 591786 NA 20,000 ID 2.5E+6 (C) 9.9E+5 1.1E+6 1.1E+6 1.4E+6 2.7E+9 2.5E+6 (C) 2.5E+6 lndeno(1 ,2,Xd)pyrene (Q) 193395 NA NLL NLL NLL NLV NLV NLV NLV ID 20,000 NA 7439896 1.2E+7 6,000 NA 1.0E+9 (D) NLV NLV NLV NLV ID 1.6E+8 NA lsobutyl alcohol (I) 78831 NA 46,000 NA B.9E+6 (C) 8.9E+6 (C) 7.9E+7 7.9E+7 7.9E+7 1.0E+11 8.9E+6 (C) 8.9E+6 lsophorone n-Hexane Iron (B) 78591 NA 15,000 26.000 (X) 2.4E+6 (C) NLV NLV NLV NLV 1.2E+10 2.4E+6 (C) 2.4E+6 lsopropyl alcohol (I) 67630 NA 9,400 1.1E+6 (X) 1.1E+8 (C) NLV NLV NLV NLV 1.5E+10 1.4E+7 1.1E+8 lsopropyl benzene 98828 NA 91,000 3,200 3.9E+5 (C) 3.9E+5 (C) 1.7E+6 1.7E+6 2.8E+6 5.8E+9 3.9E+5 (C) 3.9E+5 Lead (B) 7439921 21,000 7.0E+5 (G,X) ID NLV NLV NLV NLV 1.0E+B 4.0E+S NA Lindane 58899 NA 20 (M); 7.0 20 (M); 1.1 7,100 ID ID ID 10 10 8,300 NA 7439932 9,800 3,400 8,800 1.1E+8 NLV NLV NLV NLV 10 4.2E+6 (DD) NA Magnesium (B) 7439954 NA 8.0E+6 NA 1.0E+9 (D) NLV NLV NLV NLV 6.7E+9 1.0E+9 (D) NA Manganese (B) 7439965 4.4E+5 1,000 (G,X) 1.BE+B NLV NLV NLV NLV 3.3E+6 2.5E+7 NA Mercury (Total) (B,Z) Varies 130 1,700 50 (M); 1.2 47,000 48,000 52,000 52,000 52,000 2.0E+7 1.6E+5 NA Methane 74828 NA ID NA ID ID ID ID ID ID ID 3. 1E+6 Lithium (B) I Methanol 67561 NA 74,000 3.1E+6 (C) 3.1E+6 (C) 8.4E+6 ug/m3 (GG\ 3.1E+6 (C) 3.1E+7 4.4E+7 9.6E+7 2.2E+11 3.1 E+6 (C) Methoxychlor 72435 NA 16,000 NA 18,000 ID ID ID ID ID 1,9E+6 NA NA 1.7E+7 NLV NLV NLV NLV 1.3E+9 2.3E+5 • 1.1E+8 4.9E+5 NLV NLV NLV NLV ID 2.3E+5 2-Methoxyethanol (I) 109864 NA 150 2-Methyl-4-chlorophenoxyacetic acid 2-Methyl-4,6-dinitrophenol 94746 NA 390 NA 534521 NA 830 (M); 400 NA 1.9E+5 NLV NLV NLV NLV ID 79,000 NA N-Methyl-morpholine (I) 109024 NA 400 NA 3.0E+7 NLV NLV NLV NLV ID 6. 1E+5 1.1E+8 March 25, 2011 NA Page 9 of 14 �Attachment 1 TABLE 2. SOIL: RESIDENTIAL PART 201 GENERIC CLEANUP CRITERIA AND SCREENING LEVELS; PART 213 TIER 1 RISK-BASED SCREENING LEVELS (RBSLs) DOCUMENT RELEASE DATE: MARCH 25, 2011 All criteria, unless otherwise noted, are expressed in units of parts per billion (ppb). One ppb is equivalent to one microgram per kilogram (ug/kg). Criteria with six or more digits are expressed in scientific notation. For example, 200,000 is presented as 2.0E+5. The lowest generic soil criterion for a given hazardous substance is presented in a bold box. A footnote is designated by a letter in parentheses and is explained in the footnote pages that follow the criteria tables. When the risk-based criterion is less than the target detection limit (TOL), the TOL is listed as the criterion (R 299.5707). In these cases, two numbers are present in the cell. The first number is the criterion (i.e., TDL), and the second number is the risk-based value. Criteria were originally promulgated December 21, 2002 within the Administrative Rules for Part 201, Environmental Remediation, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. This table reflects revisions to the criteria pursuant to the December 2010 Part 201 amendments and new criteria consistent with the provisions of R299.5706a. The effective dates of the criteria and screening levels in this table vary. Please contact the Remediation Division Toxicology Unit for additional information. Guidesheet Number Hazardous Substance Methyl parathion 4-Methyl-2-pentanone (MIBK) - Chemical Abstract Service Number Indoor Air Groundwater Protection #10 Statewide Default Background Levels #11 Drinking Water Protection Criteria &RBSLs #12 #13 Groundwater Groundwater Surface Water Contact Protection Interface Criteria Protection Criteria & RBSLs &RBSLs Ambient Air (Y) #14 #15 Soil Volatilization to Indoor Air Inhalation Criteria & RBSLs Infinite Source Volatile Soil Inhalation Criteria (VSIC) & RBSLs Direct Contact #16 #17 #18 #19 #20 Finite VSIC for 5 Meter Source Thickness Finite VSIC for2 Meter Source Thickness Particulate Soil Inhalatio n Criteria & RBSLs Direct Contact Cr iteria & RBSLs Soi l Saturation Concentration Screening Levels 298000 NA 46 NA 76,000 NLV NLV NLV NLV ID 56,000 NA 108101 NA 36,000 ID 2.7 E+6 (C) 2.7E+6 (C) 4.5E+7 4.SE+7 6.7E+7 1.4E+11 2.7E+6 (C) 2.7E+6 1634044 NA 800 1.4E+S (X) 5.9E+6 (C) 5.9E+6 (C) 2.5E+7 3.9E+7 8.7E+7 2.0E+11 1.SE+6 5.9E+6 NA ID 92,000 2.3E+6 8.2E+6 2.0E+7 4.7E+10 ID 3.SE+S NLV NLV NLV NLV 8.4E+7 6,800 NA (I) Methyl-tert-butyl ether (MTBE) Methylcyclopentane (I) 96377 NA ID 4,4'-Methylene-bis-2• chloroaniline /MBOCAl Methylene chloride 101144 NA NLL NLL NLL 75092 NA 100 30,000 (X) 2.3E+6 (C) 45,000 2.1E+S 5.9E+5 1.4E+6 6.6E+9 1.3E+6 2.3E+6 2-Methylnaphthalene 91576 NA 57,000 4,200 5.SE+S 2.7E+6 1.SE+6 1.5E+6 1.5E+6 6.7E+8 8.1E+6 NA 1319773 NA 7,400 1,000 {M); 1.6E+7 NLV NLV NLV NLV 6.7E+9 1.1E+7 NA Metolachlor 51218452 NA 4,800 300 4.4E+5 (C) NLV NLV NLV NLV ID 4.4E+5 Metribuzin 21087649 NA 3,600 NA 2.4E+7 ID ID ID ID ID 4.4E+5 IC DD\ 9.6E+6 Mirex 2385855 NA NLL NLL NLL ID ID ID ID ID 9,600 NA Molybdenum (B) 7439987 NA 1,500 64,000 (X) 1.9E+7 NLV NLV NLV NLV ID 2.6E+6 NA 91203 NA 35,000 730 2.1E+6 2.SE+S 3.0E+S 3.0E+S 3.0E+S 2.0E+8 1.6E+7 NA Nickel ($) 7440020 20,000 1.0E+S (G) 1.0E+9 (D) NLV NLV NLV NLV 1.3E+7 4.0E+7 NA Nitrate (B,N) 14797558 NA 2.0E+S (N) ID 1.0E+9 (D) NLV NLV NLV NLV ID ID NA Nitrite (B,N) Methylphenols (J) Naphthalene soa I NA 14797650 NA 20,000 (N) NA 3.8E+8 NLV NLV NLV NLV ID 10 NA Nitrobenzene (I) 98953 NA 330 (M): 68 3,600 (X) 2.2E+5 91,000 54,000 54 ,000 54,000 4.7E+7 1.0E+S 4.9E+5 2-Nitrophenol 88755 NA 400 ID 1.6E+6 NLV NLV NLV NLV ID 6.3E+5 NA 621647 NA 330 (M): 100 NA 7,200 NLV NLV NLV NLV 1.6E+6 1,200 1.SE+6 86306 NA 5,400 NA 7,0E+S NLV NLV NLV NLV 2.2E+9 1.7E+6 NA n-Nitroso-di-n-propylamine N-Nitrosodiphenylamine March 25, 2011 Page 10 of 14 �Attachment 1 TABLE 2. SOIL: RESIDENTIAL PART 201 GENERIC CLEANUP CRITERIA AND SCREENING LEVELS; PART 213 TIER 1 RISK-BASED SCREENING LEVELS (RBSLs) DOCUMENT RELEASE DATE: MARCH 25, 2011 All criteria, unless otherwise noted, are expressed in units of parts per billion (ppb). One ppb is equivalent to one microgram per kilogram (ug/kg). Criteria with six or more digits are expressed in scientific notation. For example, 200,000 is presented as 2.0E+5. The lowest generic soil criterion for a given hazardous substance is presented in a bold box. A footnote is designated by a letter in parentheses and is explained in the footnote pages that follow the criteria tables. When the risk-based criterion is less than the target detection limit (TDL), the TDL is listed as the criterion (R 299.5707). In these cases, two numbers are present in the cell. The first number is the criterion (i.e., TDL), and the second number is the risk-based value. Criteria were originally promulgated December 21, 2002 within the Administrative Rules for Part 201, Environmental Remediation, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. This table reflects revisions to the criteria pursuant to the December 2010 Part 201 amendments and new criteria consistent with the provisions of R299.5706a. The effective dates of the criteria and screening levels in this table vary. Please contact the Remediation Division Toxicology Unit for additional information. Guidesheet Number Ha:zardous Substance - Chemical Abstract Groundwater Protection #10 Number Statewide Default Background Levels Service #11 Drinking Water Protection Criteria & RBSLs #12 Indoor Air #13 Groundwater Groundwater Surface Water Contact Interface Protection Protection Criteria Criteria & RBSLs & RBSLs Ambient Air (Y) #14 #15 Soil Volatilization to Indoor Air Inhalation Criteria & RBSLs Infinite Source Volatile Soil Inhalation Criteria (VSIC) &RBSLs Direct Contact #16 #17 #18 #19 #20 FiniteVSIC for S Meter Source Thickness Finite VSIC for 2 Meter Source Thickness Particulate Soil Inhalation Criforia &RBSLs Direct Contact Criteria &RBSLs Soil Saturation Concentration Screening Levels 23135220 NA 4,000 NA 1.0E+9 (D) NLV NLV NLV NLV ID 8.6E+6 NA Oxo-hexyl acetate 86230357 NA 1,500 NA ID ID ID ID ID 5.4E+9 2.3E+6 1.0E+7 Pendimethalin 40487421 NA 1.1E+6 NA 1.1 E+6 NLV NLV NLV NLV ID 4.6E+7 NA Pentachlorobenzene 608935 NA 29,000 9,500 1.9E+5 (C) 10 ID 10 ID ID 1.9E+5 (C) 1.9E+5 Pentachloronitrobenzene 82688 NA 37,000 NA 37,000 1.2E+5 2.3E+5 2.3E+5 2.3E+5 3.3E+8 1.7E+6 NA Pentachlorophenol 87865 NA 22 {G,X) 4,300 NLV NLV NLV NLV 1.0E+8 90,000 NA Pentane 109660 NA ID NA ID 2.4E+5 (C) 3.7 E+7 3.1E+8 5.8E+8 1.2E+12 ID 2.4E+5 2-Pentene {I) 109682 NA ID NA ID ID ID ID ID ID ID 2.2E+5 Phenanthrene 85018 NA 56,000 2,100 1.1E+6 2.BE+6 1.6E+5 1.6E+5 1.6E+5 6.7E+6 1.6E+6 NA Phenol 108952 NA 88,000 9,000 1.2E+7 (C) NLV NLV NLV NLV 4.0E+10 1.2E+7 Oxamyl 7723140 NA 1.3E+6 (EE) ID NLV NLV NLV NLV 6.7E+7 1.2E+7 ( C.DD) 1.0E+9 (D) Phthalic acid 88993 NA 2.SE+S NA 1.7E+6 (C) NLV NLV NLV NLV ID 1.7E+6 (C) 1.7E+6 Phthalic anhydride 85449 NA 3.0E+S NA 1.1E+6 (C) NLV NLV NLV NLV ID 1.1E+6 (C) 1.1E+6 Picloram 1918021 NA 10,000 920 8.6E+6 NLV NLV NLV NLV ID 1.6E+7 NA Piperidine 110894 NA 64 NA 6.8E+5 NLV NLV NLV NLV 9.3E+9 99,000 1.2E+8 I 1,200 NA I (T) NA S.OE+6 NA NA Phosphorus (Total) Polybrominated biphenyls (J) Polychlorinated biphenyls fPCBs\ (J.n Prometon 67774327 NA NLL NLL NLL NLV NLV NLV NLV ID 1336363 NA NLL NLL NLL 3.0E+6 2.4E+5 7.9E+6 7.9E+6 5.2E+6 1610180 NA 4,900 NA 5.SE+6 NLV NLV NLV NLV ID NLV NA Propachlor 1918167 NA 1,900 NA 8.8E+6 NLV NLV NLV ID 2.9E+6 Propazine 139402 NA 4,000 NA 1.7E+S NLV NLV NLV NLV ID 6.1E+6 NA Propionic acid 79094 NA 2.4E+5 ID 1.1E+8 (C) NLV NLV NLV NLV 2.0E+10 1.1E+8 (C) 1.1 E+8 March 25, 2011 Page11of14 �Attachment 1 TABLE 2. SOIL: RESIDENTIAL PART 201 GENERIC CLEANUP CRITERIA AND SCREENING LEVELS; PART 213 TIER 1 RISK-BASED SCREENING LEVELS (RBSLs) DOCUMENT RELEASE DATE: MARCH 25, 2011 All criteria, unless otherwise noted, are expressed in units of parts per billion (ppb). One ppb is equivalent to one microgram per kilogram (ug/kg). Criteria with six or more digits are expressed in scientific notation. For example, 200,000 is presented as 2.0E+5. The lowest generic soil criterion for a given ha:zardous substance is presented in a bold box. A footnote is designated by a letter in parentheses and is explained in the footnote pages that follow the criteria tables. When the risk-based criterion is less than the target detection limit (TDL), the TDL is listed as the criterion (R 299.5707). In these cases, two numbers are present in the cell. The first number is the criterion (i.e., TDL), and the second number is the risk-based value. Criteria were originally promulgated December 21, 2002 within the Administrative Rules for Part 201, Environmental Remediation, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. This table reflects revisions to the criteria pursuant to the December 2010 Part 201 amendments and new criteria consistent with the provisions of R299.5706a. The effective dates of the criteria and screening levels in this table vary. Please contact the Remediation Division Toxicology Unit for additional information. Guidesheet Number Hazardous Substance Propyl alcohol (I} - #10 Chemical Abstract Service Number Statewide Default Background Levels Drinking Water Protection Criteria & RBSLs 71238 NA 28,000 NA 1,600 ID Indoor Air Groundwater Protection #11 #12 #13 Ambient Air (Y) #14 #15 Soil Volatilization to Indoor Air Inhalation Criteria &RBSLs Infinite Source Volatile Soil Inhalation Criteria (VSIC) &RBSLs 1.1 E+8 (C) NLV 3.0E+5 ID Groundwater Groundwater Surface Water Contact Interface Protection Protection Criteria Criteria & RBSLs & RBSLs Direct Contact #16 #17 #18 #19 #20 FiniteVSIC for 5 Meter Source Thickness Finite VSIC for2 Meter Source Thickness Particulate Soil Inhalation Criteria & RBSLs Direct Contact Criteria & RBSLs Soil Saturation Concentration Screen ing Levels NLV NLV NLV 4.9E+1 0 1.3E+7 (DD) 1.1E+8 ID ID ID 1.3E+9 2.SE+6 1.0E+7 1.1E+8 103651 NA Propylene glycol 57556 NA 3.0E+6 5.8E+6 1.1E+8 (C) NLV NLV NLV NLV 4.0E+11 1.1E+8 (C) Pyrene 129000 NA 4.8E+5 ID 4.8E+5 1.0E+9 (0) 6.5E+8 6.5E+8 6.5E+8 6.7E+9 2.9E+7 NA Pyridine (I) 110861 NA 400 NA 37,000 (C) 1.100 8,200 40,000 97,000 2.3E+8 37,000 (C) 37,000 7782492 410 4,000 400 7.8E+7 NLV NLV NLV NLV 1.3E+8 2.6E+6 NA 7440224 1,000 4,500 100 (M); 27 2.0E+8 NLV NLV NLV NLV 6.7E+6 2.SE+6 NA n-Propylbenzene (I) Selenium (B) Silver (8) Silvex (2,4,S-TP) 93721 NA 3,600 2,200 3.1E+6 NLV NLV NLV NLV ID 1.7E+6 NA Simazine 122349 NA 80 340 90,000 NLV NLV NLV NLV ID 1.2E+6 NA 17341252 NA 2.5E+6 NA 1.0E+9 (D) NLV NLV NLV NLV ID 1.0E+9 (D) NA Sodium azide 26628228 NA 1,800 1,000 ID ID ID ID ID ID 2.7E+6 NA Strontium (B) 7440246 NA 92,000 4.2E+S 1.0E+9 (D) NLV NLV NLV NLV ID 3.3E+8 NA Styrene 100425 NA 2,700 2,100 (X) 2.7E+5 2.5E+5 9.7E+5 9.7E+5 1.4E+6 5.5E+9 4.0E+5 5.2E+5 Sulfate 14808798 NA 5.0E+6 NA ID NLV NLV NLV NLV ID 10 NA Tebuthiuron 34014181 NA 10,000 NA 5.0E+7 NLV NLV NLV NLV ID 4.6E+6 (DD) NA 2,3,7,8-Tetrabromodibenzo-p-dic 50585416 NA NLL NLL NLL NLV NLV NLV NLV (0) (0) NA 95943 NA 1.5E+6 3,400 (X) 1.5E+6 5.8E+5 2.3E+5 2.3E+5 2.3E+5 6.7E+7 7.7E+7 NA 1746016 NA NLL NLL NLL NLV NLV NLV NLV 71 (0) 0.09 (0) NA 1,1,1,2-Tetrachloroethane 630206 NA 1,500 ID 4.4E+5 (C) 6,200 36,000 54.000 1.0E+S 4.2E+B 4.4E+5 (C) 4.4E+5 1,1,2,2-Tetrachloroethane 79345 NA 170 1.600 (X) 94,000 4,300 10,000 10,000 14,000 5.4E+7 53,000 8.7E+5 Tetrachloroethylene 127184 NA 100 1,200 (X) 88,ooo (Cl 11,000 1.8E+5 4.8E+5 1.1E+6 5.4E+9 88 ,000 (C) 88,000 Sodium (0) 1,2,4,5-Tetrachlorobenzene 2,3 ,7,8--Tetrachlorodibenzo-p-d ic (0) March 25, 2011 I Page 12 of 14 �Attachment 1 TABLE 2. SOIL: RESIDENTIAL PART 201 GENERIC CLEANUP CRITERIA AND SCREENING LEVELS; PART 213 TIER 1 RISK-BASED SCREENING LEVELS (RBSLs) DOCUMENT RELEASE DATE: MARCH 25, 2011 All criteria, unless otherwise noted, are expressed in units of parts per billion (ppb). One ppb is equivalent to one microgram per kilogram (ug/kg). Criteria with six or more digits are expressed in scientific notation. For example, 200,000 is presented as 2.0E+5. The lowest generic soil criterion for a given hazardous substance is presented in a bold box. A footnote is designated by a letter in parentheses and is explained in the footnote pages that follow the criteria tables. When the risk-based criterion is less than the target detection limit (TDL), the TDL is listed as the criterion (R 299.5707). In these cases, two numbers are present in the cell. The first number is the criterion (i.e., TOL), and the second number is the risk-based value. Criteria were originally promulgated December 21, 2002 within the Administrative Rules for Part 201, Environmental Remediation, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. This table reflects revisions to the criteria pursuant to the December 2010 Part 201 amendments and new criteria consistent with the provisions of R299.5706a. The effective dates of the criteria and screening levels in this table vary. Please contact the Remediation Division Toxicology Unit for additional information. Guidesheet Number Hazardous Substance Tetrahydrofuran - Groundwater Protection #10 Chemical Abstract Service Number Statewide Default Background Levels 109999 NA #11 Drinking Water Protection Criteria &RBSLs I #12 Ambient Air M Indoor Air #13 Groundwater Groundwater Contact Surface Water Interface Protection Criteria Protection Criteria & RBSLs &RBSLs #14 #15 Soil Volatilization to Indoor Air Inhalation Criteria & RBSLs Infinite Source Volatile Soil Inhalation Criteria (VSIC) & RBSLs Direct Contact #16 #17 #18 #19 #20 FinlteVSIC forS Meter Source Thickness FiniteVSlC for 2 Meter Source Thickness Particulate Soil Inhalation Criteria & RBSLs Direct Contact Criteria & RBSLs Soil Saturation Concentration Screening Levels 1,900 2.2E+S (X) 3.2E+7 1.3E+6 1.3E+7 S.7E+7 1.SE+B 3.9E+11 2.9E+6 1.2E+8 ID NA 10 500(M): 110 500 (M); 51 10 10 2.1E+5 10 10 Tetranitromethane 509148 NA Thallium (B) 7440280 NA 2,300 4,200 {X) 1.5E+7 NLV NLV NLV NLV 1.3E+7 35,000 NA Toluene (I) 108883 NA 16,000 I 5,400 2.SE+S {C) 2.5E+5 (C) 2.8E+6 5.1E+6 1.2E+7 2.7E+10 2.5E+5 (C) 2.5E+S p-Toluidine 106490 NA 660 (M); 300 NA 4.8E+5 NLV NLV NLV NLV 1.0E+S 94,000 1.2E+6 8001352 NA 24,000 I 8,200 3.6E+5 NLV NLV NLV NLV 9.7E+6 20,000 NA 2.5E+5 (C) 10 10 ID 10 ID 2.SE+S (C) 2.SE+S 3.7E+6 Toxaphene 2303175 NA Tributylamine 102829 NA 7,800 10 1.8E+6 5.BE+S 6.0E+S 6.0E+S 6.0E+S 4.7E+8 7.9E+5 1,2,4-Trichlorobenzene 120821 NA 4,200 5,900 (X) 1.1E+6 (C) 1.1 E+6 (C) 2.8E+7 2.BE+7 2.BE+7 2.5E+ 10 9.9E+S (00) 1.1E+6 1.1,1-Trichloroethane 71556 NA 4,000 1,800 4.6E+5 (C) 2.SE+S 3.8E+6 1.2E+7 2.BE+7 6.7E+10 4.6E+5 (C) 4.SE+S 1,1,2-Trichloroethane 79005 NA 100 6,600 (X) 4.2E+5 4,600 17,000 21,000 44,000 1.9E+B 1.8E+5 9.2E+5 78,000 1.7E+5 3.9E+5 1.BE+9 5.0E+5 9.2E+7 6.3E+B 1.SE+9 3.BE+12 5.0E+S IC.DD\ 5.6E+5 (C) Triallate NA I 95,000 Trichloroethylene 79016 NA 100 4.000 (X) 4.4E+5 7,100 Trichlorofluoromethene 75694 NA 52,000 NA 5.6E+5 (C) 5.6E+5 (C) 2,4,5-Trichlorophenol 95954 NA 39,000 NA 9.1E+6 NLV NLV NLV NLV 2.3E+10 2.3E+7 NA 2,4,6-Trichlorophenol 88062 NA 2,400 330 (M); 100 2.0E+S NLV NLV NLV NLV 1.0E+9 7.1 E+S NA 1,2,3-Trichloropropane 961$4 NA 840 NA 8.3E+5 (Cl 4,000 9,200 9,200 11,000 2.0E+7 8.3E+5 (C) 8.3E+S S.SE+S (C) 1,700 5.SE+S (C) 5.SE+S (C) 1.8E+8 8.8E+B 2.1E+9 5.1E+12 5.SE+S (C) 5.SE+S 5.6E+5 1, 1,2-Trichlor<>-1,2,2-trifluoroethi 76131 NA Triethanolamine 102716 NA 74,000 NA 1.1 E+B (C) NLV NLV NLV NLV 3.3E+9 1.1E+8 1.1E+8 Triethylene glycol 112276 NA 1.1E+S (C} NA 1.1E+5 (C) NLV NLV NLV NLV ID 1.1 E+S 3-Trifluoromethyl-4-nitrophenol 88302 NA 1.1E+5 NA 1.2E+8 NLV NLV NLV NLV ID 1.1E+5 IC,DD1 4.1E+7(DD) 1582098 NA 1.9E+5 NA 1.2E+7 ID iD ID ID ID 2.0E+6 NA Trifluralin March 25, 2011 NA Page 13 of 14 �Attachment 1 TABLE 2. SOIL: RESIDENTIAL PART 201 GENERIC CLEANUP CRITERIA AND SCREENING LEVELS; PART 213 TIER 1 RISK-BASED SCREENING LEVELS (RBSLs) DOCUMENT RELEASE DATE: MARCH 25, 2011 All criteria, unless otherwise noted, are expressed in units of parts per billion (ppb). One ppb is equivalent to one microgram per kilogram (ug/kg). Criteria with six or more digits are expressed in scientific notation. For example, 200,000 is presented as 2.0E+S. The lowest generic soil criterion for a given hazardous substance is presented in a bold box. A footnote is designated by a letter in parentheses and is explained in the footnote pages that follow the criteria tables. When the risk-based criterion is less than the target detection limit (TDL), the TDL is listed as the criterion (R 299.5707). In these cases, two numbers are present in the cell. The first number is the criterion (i.e., TDL), and the second number is the risk-based value. Criteria were originally promulgated December 21, 2002 within the Administrative Rules for Part 201, Environmental Remediation, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. This table reflects revisions to the criteria pursuant to the December 2010 Part 201 amendments and new criteria consistent with the provisions of R299.5706a. The effective dates of the criteria and screening levels in this table vary. Please contact the Remediation Division Toxicology Unit for additional information. Guidesheet Number Hazardous Substa nee - #10 Chemical Abstract Service Number Statewide Default Background Levels Indoor Air• Groundwater Protection #11 Drinking Water Protection Criteria & RBSLs #12 #13 Groundwater Groundwater Contact Surface Water Protection Interface Protection Criteria Criteria & RBSLs & RBSLs Ambient Air (Y) #14 #15 Soil Volatilization to Indoor Air Inhalation Criteria &RBSLs Infinite Source Volatile Soil Inhalation Criteria (VSIC) & RBSLs Direct Contact #16 #17 #18 #19 #20 FiniteVSIC for S Meter Source Thickness FiniteVSIC for2 Meter Source Thickness Particulate Soil Inhalation Criteria &RBSLs Direct Contact Criteria & RBSLs Soil Saturation Concentration Screening Levels 540841 NA ID NA ID 19,000 (C) 5.2E+6 3.9E+7 9.6E+7 2.3E+11 10 19,000 2,4 ,4-Trimethyi-2-pentene (I) 107404 NA ID NA ID ID 10 10 10 ID 10 56,000 1,2 ,4-Trimethylbenzene (I) 95636 NA 2,100 570 1.1E+5 (C) 1.1 E+5 (C) 2.1E+7 5.0E+B 5.0E+8 B.2E+1 0 1.1E+5 (C) 1.1 E+5 1,3,5-Trimethylbenzene (I) 108678 NA 1,800 1,100 94,000 (C) 94,000 (C) 1.6E+7 3.8E+8 3.SE+B B.2E+1 0 94,000 (C) 94,000 Triphenyl phosphate 115866 NA 1.1E+5 (C) NA 1.1E+5 (C) NLV NLV NLV NLV ID 1.1E+5 (C) 1.1E+5 tris(2,3-Dibromopropyl)phospha! 126727 NA 930 10 27,000 (C) 27,000 (C) 18,000 18,000 18,000 5.9E+6 4,400 27,000 57136 NA ID NA ID NLV NLV NLV NLV 10 10 NA NA 2.4E+6 2,2,4-Trimethyl pentane Urea Vanadium 7440622 NA 108054 NA I ' 72,000 1.9E+5 1.0E+9 (D) NLV NLV NLV NLV ID 7.5E+5 (OD) 13,000 NA 2.4E+6 (C) 7.9E+5 1.7E+6 2.6E+6 5.8E+6 1.3E+10 75014 NA 40 260 (X) 20,000 270 4 ,200 30,000 73,000 3.SE+B 2.4E+6 rc.001 3,800 12185103 NA 2.2 NA 58,000 NLV NLV NLV NLV ID 2,300 (OD) NA Xylenes (I) 1330207 NA 5,600 820 1.5E+5 (C) 1.SE+S (C) 4.6E+7 6.1E+7 1.3E+8 2.9E+11 1.5E+5 (C) 1.5E+5 Zi nc (B) 7440656 47,000 2.4E+6 (G) 1.0E+9 (D) NLV NLV NLV NLV ID 1.7E+8 NA Vinyl acetate (I) Vinyl chloride White phosphorus (R) March 25, 2011 I 4.9E+5 Page 14 of 14 �Attachment 1 TABLE 3. SOIL: NONRESIDENTIAL PART 201 GENERIC CLEANUP CRITERIA AND SCREENING LEVELS; PART 213 TIER 1 RISK-BASED SCREENING LEVELS (RBSLs) DOCUMENT RELEASE DATE: MARCH 25, 2011 All criteria, unless otherwise noted, are expressed in units of parts per billion (ppb). One ppb is equivalent to one microgram per kilogram (ug/kg). Criteria with six or more digits are expressed in scientific notation. For example, 200,000 is presented as 2.0E+S. The lowest generic soil criterion for a given hazardous substance is presented in a bold box. A footnote is designated by a letter in parentheses and is explained in the footnote pages that follow the criteria tables. When the risk-based criterion is less than the target detection limit (TDL), the TDL is listed as the criterion (R 299.5707). In these cases, two numbers are present in the cell. The first number is the criterion (i.e., TDL), and the second number is the risk-based value. Criteria were originally promulgated December 21, 2002 within the Administrative Rules for Part 201, Environmental Remediation, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. This table reflects revisions to the criteria pursuant to the December 2010 Part 201 amendments and new criteria consistent with the provisions of R299.5706a. The effective dates of the criteria and screening levels in this table vary. Please contact the Remediation Division Toxicology Unit for additional information. Guldcsheet Number - Huardous Substance > Chemical Abstract Service Number #10 #11 Statc,wtde Resldcntla Drinking Default Water Background Levels. #21 Non.. Residential Orinldng ProtectJon W.oter Criteria &RBSLs Protection Criteria & RBSLs #12 Ambient Air (Y) lnd<>Dr Air Groun4w.,ter Protectl<>n #13 #22 Groundwater Groundwate, 5<>11 Sur'face C<>ntact VolatlllzatJon Protection to Indoor Water Interface Criteria Ai r Protection & RBSL.s lnh•latlon Criteria Criteria & RBSLs &RBSLs #23 #24 #25 Direct C<>ntact #2& Infinite Source Finite Finite Particulate Volatile VSIC VSIC Soll for S Meter for 2 Meter SDII Inhalation Source Source lnhalatJon Criteria Thickness Thickness Criteria (VSIC) & RBSLs & RBSLs #27 #20 Olrect Contact Criteria &RBSLs Soll Saturation Concentration Screening Leve-la. Aeenaphthene 83329 NA 3.0E+S 8.8E+5 8,700 9.7E+5 3.5E•8 9.7E•7 9.7E•7 9.7E•7 6.2E+9 1.3E•B NA Acenaphthylene 208958 NA 5,900 17.000 ID 4.4E+5 3.0E+6 2.7E+6 2.7E+6 2.7E+6 1.0E+S S.2E+6 NA Acetaldehyde {I) 75070 NA 19,000 54,000 2,600 Acetate 71501 NA ID ID Acellcacld 64197 NA 84,000 Acetone II) 67641 NA 15,000 Acetonltrilc 75058 NA Acetophenone 98862 NA 1.1E+8{C) 4.0E+S 2.1E+5 2 .1E+5 2.9E+5 2 .SE+S 9.5E+7 1.1E+8 (G) ID ID ID ID ID ID ID ID 2.4E+5 (G) 6.5E•8{C) NLV NLV NLV NLV 7.4E+9 4.2E+8 6.SE+S 42,000 34,000 1.1E•8(C) 1.1E-•8 (C) 1.6E+8 1.6E+8 2.0E+8 1.7E•11 7.3E•7 1. 1E•8 2,800 8,000 NA 2.2E•7 (C) 8.8E+6 1.9E•6 1.9E•6 2.2E+6 1.SE+S 1,4E+7 2,2E•7 30,000 88,000 ID 1.1E+S (CJ 1.1E•S (C) 5.2E+7 5.2E+7 5.2E+7 1.4E+10 1.1E+6 IC) 1.1E+6 2.3E+7 (CJ 760 370 370 630 5.9E+5 1.2E+7 2 .3E+7 Acroleln (I) 107028 NA 2.400 6.600 NA Acrylamide 79061 NA 10 10 200 (X) 2.6E+S NLV NLV NLV NLV 3.0E+6 8,700 NA Acrylic acid 79107 NA 78,000 2.2E+5 NA 1.1E+8 (C) 5.5E+6 2.2E•5 2.7E+5 2.7E•5 2,9E+7 1.1E+8 Acrylonitnle II) 107131 NA 220 100 (M); 40 2.BE+S 35,000 17,000 17,000 3 1,000 5.8E+7 1,1E+8 (C DDl 74,000 8.3E•6 Alachlor 15972608 NA 100(M); 52 52 52 290(XJ 44,000 NLV NLV NLV NLV ID 3.9E+5 NA Aldicarb 116063 NA 60 60 NA 2.4E•6 NLV NLV NLV NLV ID 7.3E•5 NA Aldicarb sulfone 1646884 NA 200 (M); 40 NA 4.2E+7 NLV NLV NLV NLV ID 8.0E•S NA Aldicarb suffoxlde 1646873 NA 200(M); 40 200(M); 80 200 (M); 80 NA 5.4E+7 NLV NLV NLV NLV ID 9.5E+5 NA Aldrin 309002 NA NLL NLL NLL NLL 7 .1E•6 2.0E•S 2.0E+5 2.0E•S 8.0E+S 4 ,300 NA Aluminum (8) 7429905 6.9E+6 1,000 1,000 NA 1.0E+9{D) NLV NLV NLV NLV 10 3.7E+8 {DD) NA Ammonia 7664417 NA ID ID ID ID ID ID ID 2.9E+9 10 1.0E+7 I-Amyl methyl ether (TAME) 994058 NA 3,900 3,900 NA 4.4E+S IC) 1.1E+5 4.0E+5 7.BE•S 1.8E•6 1.8E+9 4.4E•5 (C) 4.4E•5 62533 NA 1,100 4,400 330 (M); 80 2.8E+6 NLV NLV NLV NLV 2.9E+7 1.5E+6 4 .5E+6 Aniline March 25, 2011 (CC) Page 1 of 14 �Attachment 1 TABLE 3. SOIL: NONRESIDENTIAL PART 201 GENERIC CLEANUP CRITERIA AND SCREENING LEVELS; PART 213 TIER 1 RISK-BASED SCREENING LEVELS (RBSLs) DOCUMENT RELEASE DATE: MARCH 25, 2011 All criteria, unless otherwise noted, are expressed in units of parts per billion (ppb). One ppb is equivalent to one microgram per kilogram (ug/kg). Criteria with six or more digits are expressed in scientific notation. For example, 200,000 is presented as 2.0E+S. The lowest generic soil criterion for a given hazardous substance is presented in a bold box. A footnote is designated by a letter in parentheses and is explained in the footnote pages that follow the criteria tables. When the risk-based criterion is less than the target detection limit (TDL), the TDL is listed as the criterion (R 299.5707). In these cases, two numbers are present in the cell. The first number is the criterion (i.e., TDL), and the second number is the risk-based value. Criteria were originally promulgated December 21, 2002 within the Administrative Rules for Part 201, Environmental Remediation, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. This table reflects revisions to the criteria pursuant to the December 2010 Part 201 amendments and new criteria consistent with the provisions of R299.5706a. The effective dates of the criteria and screening levels in this table vary. Please contact the Remediation Division Toxicology Unit for additional information. Groundwate-r Protectlon Gulde-sheet Number - Hanrdous Substance > Chemical Ab$tract Service Number #10 #11 Statewide Resldentla Drinking Default Background Water Level& Protection Criteria & RSSLs #21 Non. Residential Drinking Water Protection Criteria & RSSLS #12 Ambient Air (Y) Indoor Air #13 #22 Groundwater Groundwater S<>II Surface Contact Volatilization Prc,tectlon to Indoor Water Criteria Air Interface Protection & RBSLs Inhalation Criteria Criteria & RSSLs & RSSLs #23 #24 #25 Direct Contact #26 Infinite Source Finite Finite Particulate V<>latlle VSlC VSIC f<>r 5 Meter for 2 Meter S<>II S<>II lnhalatlc,n Source Source Inhalation Criteria Thickness Thickness Criteria (VSIC) & RSSLs & RSSLs #27 Direct Contact Criteria & RSSLs #20 SC>II Saturation Concentration Screening Levels Anthracene 120127 NA 41,000 41,000 10 4 1,000 1.0E+9 (D) 1.6E+9 1.6E+9 1.6E+9 2.9E+1 0 7.3E+8 Antimony 7440360 NA 4,300 4,300 94,000 (X) 4.9E•7 NLV NLV NLV NLV 5.9E+6 6.7E+5 NA Arsenic 7440382 5,800 4,600 4,600 4 ,600 2.0E+6 NLV NLV NLV NLV 9.1E+5 37,000 NA Asbestos (BB) 1332214 NA NLL NLL NLL NLL NLV NLV NLV NLV !0 NA Atrazlne 1912249 NA 60 60 150 1. 1E+5 NLV NLV NLV NLV 1.0E+7 (M); 85000 ID 3.3E+5(DD) NA Azobenzene 103333 NA 4,200 17,000 ID 3.0E+5 3.2E+7 2.1E+6 2.1E+6 2.1E+6 1.3E+8 6.6E+5 NA Barium (8) 7440393 75,000 1.3E+6 1.3E+6 (G} 1.0E+9(D) NLV NLV NLV NLV 1.5E+8 1.3E+8 NA Benzene (I) 71432 NA 10D 10D 2.2E+S 8.400 45,000 99,000 2.3E+S 4.7E+8 4.0E+5 (C) 4.0E+5 Benzldine 92875 NA NLV NLV NLV NLV 59,000 56553 NA NLV NLV NLV NLV ID 1.000 (M); 110 80,000 NA Benzo(a)anthracene (0) 1,000(M); 140 NLL NA Benzo(b)nuoranthene (Q) 205992 NA NLL NLL NLL NLL 10 ID ID ID ID 80,000 NA Benzo(k)fluoranthene (Q) 207089 NA NLL NLL NLL NLL NLV NLV NLV NLV ID 8.0E+5 NA 3.SE+8 7.0E+S NA NA 4,000()() 1,000(M); 1,000 (M); 6.0 1,000 (M); 6.0 6.0 NLL NLL NLL NA Benzo(g.h,i)perylene 191242 NA NLL NLL NLL NLL NLV NLV NLV NLV Benzo{a)pyrene (Q) 50328 NA NLL NLL NLL NLL NLV NLV N LV NLV 1.9E+6 8,000 Benzo lc acid 65850 NA 6.4E•5 1.BE+S NA 7.0E+7 NLV NLV NLV NLV ID 1.0E+9 (D) NA Benzyl alcohol 100516 NA 2.0E+5 5.8E• 5 NA 5.SE+S(C) NLV NLV NLV NLV 1.5E+1 1 5.8E+6 (C) 5 .8E+6 Benzyl chlortde 100447 NA 150 640 NA 72,000 33,000 48,000 46,000 52,000 7.8E+7 2 .2E• 5 2.3E+5 Beryllium 7440417 NA 5 1,000 5 1,000 1.0E•9 (D) NLV N LV NLV NLV 5.SE+S 1.6E+6 NA bis{2-Chloroelhoxy)ethane 112265 NA ID ID ID ID NLV NLV NLV NLV ID ID 2.7E+6 bis(2-Chloroethyl)ett\er (l) 111444 NA 100 170 100 (M), 20 1.1E+S 44,000 13,000 13,000 13,000 1.2E•7 58,000 2.2E+6 March 25, 2011 (G) Page 2 of 14 �Attachment 1 TABLE 3. SOIL: NONRESIDENTIAL PART 201 GENERIC CLEANUP CRITERIA AND SCREENING LEVELS; PART 213 TIER 1 RISK-BASED SCREENING LEVELS (RBSLs) DOCUMENT RELEASE DATE: MARCH 25, 2011 All criteria, unless otherwise noted, are expressed in units of parts per billion (ppb). One ppb is equivalent to one microgram per kilogram (ug/kg}. Criteria with six or more digits are expressed in scientific notation. For example, 200,000 is presented as 2.0E+5. The lowest generic soil criterion for a given hazardous substance is presented in a bold box. A footnote is designated by a letter in parentheses and is explained in the footnote pages that follow the criteria tables. When the risk-based criterion is less than the target detection limit (TDL), the TDL is listed as the criterion (R 299.5707). In these cases, two numbers are present in the cell. The first number is the criterion (i.e., TDL), and the second number is the risk-based value. Criteria were originally promulgated December 21, 2002 within the Administrative Rules for Part 201, Environmental Remediation, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. This table reflects revisions to the criteria pursuant to the December 2010 Part 201 amendments and new criteria consistent with the provisions of R299.5706a. The effective dates of the criteria and screening levels in thiS table vary. Please contact the Remediation Division Toxicology Unit for additional information. Groundwater Protection Guldesheet Number - Hazardous Substance > Chemical Abstract Service Number #10 #11 Statewide Residential Default Drinking Background Water Protection Level$ Criteria & RBSI.$ #21 NonResidential Drinking Water Protection Criteria & RBSLs #12 Ambient Air M Indoor Air #13 #22 Groundwater Groundwate, Soll Volatlllzatlon Surface Contact Water Protection to Indoor Air Criteria Interface Inhalation & RBSI.$ Protection Criteria Criterni & RBSI.$ & RBSl.s #23 #24 #25 Direct Contact #26 Infinite Particulate Finite Finite Source VSIC Volatlle VSIC for 5 Meter lor2 Meter Soll Soll Inhalation Source Source Inhalation Criteria Thlckne,a Thlckne,a Criteria (VSIC) & RE!Sl.s & RBSl.s #27 1120 Direct Cont..ct Criteria &RBSLs Soll Saturation Concentration Screening Levels 117817 NA NLL NLL NLL NLL NLV NLV NLV NLV 8 .9E+8 1.0E+7 (C) 1.0E+7 Boron (B) 7440428 NA 10,000 10,000 1.0E•5 (X) 1,0E+9(D) NLV NLV NLV NLV ID 3.SE+S (DD) NA Bromate 15541454 NA 200 200 SOO(X) 96,000 NLV NLV NLV NLV ID 91,000 NA Bromobenzene (I) 108861 NA 550 1,500 NA 3,6E+5 5.8E+5 5 .4E+5 5.4E+5 5.4E+5 2.4E+8 7.6E+5 (C) 7.6E+5 Bromodichloromethane 75274 NA 1,600(\'\') 1,600 (IN) ID 2.8E+5 6,400 31,000 31,000 57,000 1.1E+8 4.9E+5 1.5E+6 Bromoform 75252 NA 1,600 (IN) 1,600 (IN) ID 8.7E+S (CJ 7.7E+5 3.1E+6 3,1E+6 3.1E+6 3,6E+9 8,7E+5 (C) 8,7E+5 Bromomethane 74839 NA 200 580 700 1.4E•6 1,600 13,000 57,000 1.4E+5 1.5E+8 1.0E+6 2.2E+6 n-Butanol (I) 71363 NA 19,000 54,000 NA 8.7E•6(C) NLV NLV NLV NLV 1.0E+10 8.7E+6 (C) 8.7 E+6 2-Butanone (MEI<) (I) 78933 NA 2.6E+5 7.6E+5 44,000 2.7E+7 (C) 2.7E+7(C) 3.5E+7 3.5E+7 3.6E+7 2.9E+10 2.7E•7 bis(2-Ethylhexyl)phlhalate n-Butyl acetate 123864 NA 11 ,000 32,000 NA 1.1E+6 (C) 1. 1E+6 (C) 1.4E+8 3.1E+6 3.5E+6 2. 1E+11 2.7E+7 (CDD) 1.1E+6 (C) t-Bulyl alcohol 7 5650 NA 78,000 2.2E+5 NA 1.1E+8(C) 1.1E+8 (C) 1.2E+8 2.4E+8 2.4E+8 5.6E+ 10 UE+B (C) 1.1E+B Butyl benzyl phthalate 85687 NA 3.1E+5 (C) 3.1E+5 (C) 1.2 E+ 5 (X) 3.1E+5 (C) NLV NLV NLV NLV 2.1E+10 3.1E+S (C) 3.1E+5 1.1E+6 n-Butylbenzene 104518 NA 1,600 4 ,600 10 1.2E+S ID ID ID ID 8 .8E+8 8.0E• 6 1.0E•7 sec-Butylbenzene 135988 NA 1,600 4,600 JD 88,000 ID ID ID ID 1.8E•8 8.0E+6 1.0E+7 t-Butylbonzene (I) 98066 NA 1,600 4,600 ID 1.8E+S ID ID ID ID 2.9E•8 8.0E•6 1.0E+7 Cadmium (B) 7440439 1,200 6,000 6,000 (G.X) 2.3E•8 NLV NLV NLV NLV 2.2E• 6 2.1E+6 NA Camphene (!) 79925 NA ID ID NA ID 6,700 1.8E+5 9.1E+5 2.2E+6 2.4E+9 ID NA Caprolactam 105602 NA 1.2E+5 3.4E+5 NA 1.0E+ 9 (D) NLV NLV NLV NLV 2.9E+8 3.1E+8 (DD) NA Carbaryl 63252 NA 14,000 40,000 NA 2.6E+6 ID ID ID ID ID 7.0 E+7 NA Catbazote 86748 NA 9,400 39,000 1,100 8.2E+S NLV NLV NLV NLV 7.8E+7 2.4E+6 NA Carbofuran 1563662 NA 800 800 NA 6.8E+6 NLV NLV NLV NLV ID 3.6E+6 NA March 25, 2011 Page 3 of 14 �Attachment 1 TABLE 3. SOIL: NONRESIDENTIAL PART 201 GENERIC CLEANUP CRITERIA AND SCREENING LEVELS; PART 213 TIER 1 RISK-BASED SCREENING LEVELS (RBSLs) DOCUMENT RELEASE DATE: MARCH 25, 2011 All criteria, unless otherwise noted, are expressed in units of parts per billion (ppb). One ppb is equivalent to one microgram per kilogram (ug/kg}. Criteria with six or more digits are expressed in scientific notation. For example, 200,000 is presented as 2.0E+5. The lowest generic soil criterion for a given hazardous substance is presented in a bold box. A footnote is designated by a letter in parentheses and is explained in the footnote pages that follow the criteria tables. When the risk-based criterion is less than the target detection limit (TDL), the TDL is listed as the criterion (R 299.5707). In these cases, two numbers are present in the cell. The first number is the criterion (i.e., TDL), and the second number is the risk-based value. Criteria were originally promulgated December 21, 2002 within the Administrative Rules for Part 201, Environmental Remediation, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. This table reflects revisions to the criteria pursuant to the December 2010 Part 201 amendments and new criteria consistent with the provisions of R299.5706a. The effective dates of the criteria and screening levels in this table vary. Please contact the Remediation Division Toxicology Unit for additional information. Guldesheet Number - Hazardous Substance > Chemical Abstract Service Number #10 #11 Statewide Reshlentlal Default Drinking Water Background Level& F>roteetlon Criteria & RBSI.S #21 NonResidential Drinking Water Protection Criteria & RBSLs #12 Ambient Air (Y) lndoor AJr Groundwiltet Protection #13 #22 Soll Groundwater Groundwater Volatilization Surface Contact to Indoor Water Protection Criteria Air Interface Inhalation Protection & RBSLs Criteria Criteria &RBSLs & RBSI.S #23 #24 #25 Direct Contact #26 Infinite Source Finite Finite Particulate VSIC VSIC Volatile Soll tors Meter for2 Meter Soll Inhalation Source Source Inhalation Thickness Thickness Criteria Criteria (VSIC) & RBSI.S &RBSI.S #27 #20 Direct Contact Criteria &RBSLs Soll Saturation Coneenttadon Screening Levels Carbon dlsul1ide (1,R) 75150 NA 16,000 46,000 ID 2.BE+S(C) 1.4E+S 1.6E+6 8.0E+6 1.9E+7 2.1E+10 Carbon tetrachloride NA 100 100 900 (X) 92,000 990 12,000 34.000 79,000 1.7E•8 2.8E+5 re DD\ 3.9E+5 (C) 2.8E+5 56235 NLL S.9E+7 4.2E•S 4,2E+S 4.2E+6 2.1E+7 1.SE+S NA Chlordane (J) 57749 NA NLL NLL Nll 3.9E+5 16887006 NA 5.0E+6 5.0E+S (X) 10 NLV NLV NLV NLV ID S.OE+S (F) NA Chlorobenzene {I) 1089D7 NA 2,000 2,000 500 2.6E+5(C) 2.2E•5 9.2E+S 1.1E+6 2.1E+6 2.1E+9 2.SE+S(C) 2.SE+S p-Chlorobenzene sulfonic acid 98668 NA 1.SE+S 4.2E+5 ID NA ID ID 10 ID ID 7.3E+8 10 1-Chloro-1, 1-difluoroethane 75683 NA 3.0E+S 8.SE+S NA 9.SE+S (C) 9.6E•5(C) 9.4E+7 5.7E•8 1.4E•9 1.5E+12 9.SE+S (C) 9.SE+ S Chloroethane 750D3 NA 8,600 34,000 22.000 (X) 9.SE+S (C) 9.5E•5(C) 3.6E+7 1.2E+S 2.8E+8 2.9E+1 1 9.SE+S (C) 9.SE+S Chloride 2-Chloroethyl vinyl ether 11D758 NA 10 10 NA ID lD 10 ID ID JO 10 1.9E+S Chloroform 67663 NA 1,600 (W) 1,600 (W) 7,000 1.SE+S (C) 38,000 1.SE+S 3.4E+S 7.9E+S 1.6E+9 1.SE+S(C) 1.SE+S Chloromethane (I) 74873 NA 5,200 22,000 ID 1.1E+6(C) 10.000 1.2E+5 1.0E+S 2.5E+6 2.6E+9 1.1E+6 (C) 1. 1E+6 5,800 16,000 280 3.0E+S NLV NLV NLV NLV ID 1.SE+? NA 1.8E+6 NA ID ID 1.SE+S NA 4-Chloro-3-methylphenol 59507 NA 91587 2-Chlorophenol 95578 NA 900 2,600 360 o-Chlorotoluene (I) 95498 NA 3,300 9.300 ID 2921882 NA 17,000 48,000 1,500 Chlorpyrifos NA 6.2E+S t>eta-Chloronaphlhalene ID ID 1.9E+6 8.0E+S 1.1E+6 1.1E+S 1.1E•S 5.3E+8 4.5E+6 1.9E+7 5.0E+S(C) 5.DE+S (C) 1.SE+S 3.1E+6 6.4E+6 2.1E+9 5.0E+5 (C) 5.0E+S 8.4E+S 240 5,500 23,000 56,000 5.9E+7 3.4E+7 NA 1.0E+9(D) NLV NLV NLV NLV 1.SE+B 1,0E+9 (D) NA 18,000 natal\ 1.0E+9 (D) 1.DE•9 (D) (G,X) 18540299 NA 30,000 30,000 3,300 1.4E+8 NLV NLV NLV NLV 2.4E+S 9.2E+6 NA 218019 NA NLL NLL NLL NLL ID ID ID ID ID 8.0E+S NA 4 .8E+7 NLV NLV NLV NLV 5.9E+6 9.0E+S NA 1.0E+9 (D) NLV NLV NLV NLV S.9E+7 7.3E+7 NA Chromium (Ill) (B,H) 16065831 Chromium (VI) Chrysene (Q) Cobalt 7440484 6,800 800 2,000 Copper (B) 7440508 32,000 5.BE+S 5.BE+6 March 25, 2011 ID 2.3E+6 2,000 (G) Page 4 of 14 �Attachment 1 TABLE 3. SOIL: NONRESIDENTIAL PART 201 GENERIC CLEANUP CRITERIA AND SCREENING LEVELS; PART 213 TIER 1 RISK-BASED SCREENING LEVELS (RBSLs) DOCUMENT RELEASE DATE: MARCH 25, 2011 All criteria, unless otherwise noted, are expressed in units of parts per billion (ppb). One ppb is equivalent to one microgram per kilogram (ug/kg). Criteria with six or more digits are expressed in scientific notation. For example, 200,000 is presented as 2.0E+5. The lowest generic soil criterion for a given hazardous substance is presented in a bold box. A footnote is designated by a letter in parentheses and is explained in the footnote pages that follow the criteria tables. When the risk-based criterion is less than the target detection limit (TDL), the TDL is listed as the criterion (R 299.5707). In these cases, two numbers are present in the cell. The first number is the criterion (i.e., TDL), and the second number is the risk-based value. Criteria were originally promulgated December 21, 2002 within the Administrative Rules for Part 201, Environmental Remediation, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. This table reflects revisions to the criteria pursuant to the December 2010 Part 201 amendments and new criteria consistent with the provisions of R299.5706a. The effective dates of the criteria and screening levels in this table vary. Please contact the Remediation Division Toxicology Unit for additional information. Guldcshcct Number - Hazardous Substance > Chemical Abstract Service Number #10 #11 Statewide Resldentla Drinking Default Background Water Protection Levels Criteria & RBSLS #21 NonResidential Drinklng Water Protection #12 #13 Groundwater Groundwate1 Surface Contact Water Protection Criteria &RBSLs Interface Criteria & RBSLs Prc>tectlc>n Criteria &RBSu Ambient Air (Y) Indoor Air Groundwater Protection #22 Soll Volatlllzatlon to Indoor Air Inhalation Criteria &RBSLs Direct Contact #23 #24 #25 #26 Infinite Source Volatile Finite VSIC Finite VSIC Particulate Soll for5 Meter for 2 Meter ltahalatlon Source Source lnhalatlc>n Criteria Thickness Thickness Criteria (VSIC) & RBSLs & RBSl.$ Soil #27 #20 Direct Contact Soil SaturatJon Concentration Criteria & RBSLs Screening Levels 21725462 NA 200 200 1,100(X) 56,000 NLV NLV NLV NLV ID 66,000 NA Cyanide (P,R) 57125 390 (total) 4,000 4,000 100 2.5E+5 NLV NLV NLV NLV 2 .5E+5 2.5E•5 NA Cyclohexanone 108941 NA 5.2E+6 1.SE+7 NA 2.2E+8 (C) 32,000 1.3E+6 1.1E•7 2.7E+7 2.9E+10 2.2E+8 (C) 2.2E+8 NA 3.4E+5 NLV NLV NLV NLV ID 7.3E+6 NA 5.9E+7 Cyanazine Oacthal 1861321 NA 50,000 1.4E+5 Dalapon 75990 NA 4,000 4,000 NA 5.9E+7 (CJ NLV NLV NLV NLV ID 5.9E+7 (C) 4-4'-DDD 72548 NA NLL NLL NLL NLL NLV NLV NLV NLV 5.6E+7 4.0E+5 NA 4-•r-DDE 72559 NA NLL NLL NLL NLL NLV NLV NLV NLV 4.0E+7 1.9E+5 NA 4-4'.0DT 50293 NA NLL NLL NLL NLL NLV NLV NLV NLV 4.0E+7 2.BE+5 NA 1.0E+B 1.0E+B 1.0E+9 1.1E+ 7 NA Decabromodlphenyl ether Dl-<1-butyl phthalate 01(2-elhylhexyl) adipate 1163195 NA 1.4E+5 1.4E+5 NA 1.4E+5 1.0E+9 (D) 1,0E+B 84742 NA 7.6E+S (C) 7.6E+5 (C) 11,000 7.6E+5(C) NLV NLV NLV NLV 1.5E+9 7.6E+S (C) 7.6E+5 103231 NA 9.6E+5(C) 9.6E+5 (C) 1D 9.6E+5 (C) NLV NLV NLV NLV 1.2E+10 1.4E+8 (C) NLV NLV NLV NLV 1.4E+10 9.6E+5 /CDD) 2.0E+7 1.4E•8 9.6E+5 Dl-n-octyl phthalale 117840 NA 1.0E+8 1.4E•8(C) ID Diacetone alcohol (I) 123422 NA ID ID NA ID NLV NLV NLV NLV 7.1E+10 ID 1.1E+8 Diazinon 333415 NA 95 280 72 95,000 NLV NLV NLV NLV ID 70,000 (DD) 3.1E+5 53703 NA NLL NLL NLL NLL NLV NLV NLV NLV ID 8,000 NA NA ID !D 1,700 ID 3.6E+6 1.6E+5 1.6E+5 1.6E+5 2.9E+6 ID NA 98,000 1.6E+B 5.0E+S 6.1E+5 Dibenzo(a,h)anthracene (Q) Dlbenzofuran 132649 Olbromoehloromethane 124481 NA 1,600 (V\I) 1,600(V\I) ID 3.6E+5 21,000 80.000 80,000 Dlbromochloropropane 96128 NA 10(M); 4.0 10(M); 4.0 ID 1.200 [C) 1.200 (C) 15.000 15,000 15.000 5.9E+6 1,200 (C) 1.200 Oibromomethane 74953 NA 1.600 4,600 NA 2.0E+6(C) ID ID ID ID ID 2.0E+6(C) 2 .0E+6 1918009 NA 4.400 13,000 NA 1.2E+7 NLV NLV NLV NLV ID 1.7E+7 NA 14,000 280 2.1E+5 (C) 2.1E•5 (C) 4.6E+ 7 4.6E•7 5.SE+7 4.4E+10 2.1E+5 [C) 2.1E+5 Dicamba 1.2-Dlchlorobenzene March 25, 2011 95501 NA 14,000 Page 5 of 14 �Attachment 1 TABLE 3. SOIL: NONRESIDENTIAL PART 201 GENERIC CLEANUP CRITERIA AND SCREENING LEVELS; PART 213 TIER 1 RISK-BASED SCREENING LEVELS (RBSLs) DOCUMENT RELEASE DATE: MARCH 25, 2011 All criteria, unless otherwise noted, are expressed in units of parts per billion {ppb). One ppb is equivalent to one microgram per kilogram (ug/kg). Criteria with six or more digits are expressed in scientific notation. For example, 200,000 is presented as 2.0E+S. The lowest generic soil criterion for a given hazardous substance is presented in a bold box. A footnote is designated by a letter in parentheses and is explained in the footnote pages that follow the criteria tables. When the risk-based criterion is less than the target detection limit (TDL), the TDL is listed as the criterion (R 299.5707). In these cases, two numbers are present in the cell. The first number is the criterion (i.e., TDL), and the second number is the risk-based value. Criteria were originally promulgated December 21, 2002 within the Administrative Rules for Part 201, Environmental Remediation, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. This table reflects revisions to the criteria pursuant to the December 2010 Part 201 amendments and new criteria consistent with the provisions of R299.5706a. The effective dates of the criteria and screening levels in this table vary. Please contact the Remediation Division Toxicology Unit for additional information. Groundwater Protection Guideshe-et Number - Hazardous Sub.sti:oee > C~emlcal Ab•tract Se-rvlce N~mber #10 #11 Statewide Resldcntla Default Drinking Background Water ProtectJon Levels Criteria & RBSLs #21 Non• Residential Drlnklng Water Protection Criteria & RBSL.s #12 Indoor Air #13 #22 Groundwater Groundwate, Soll Surface Contact Volatlllzatlon Water Protection to Indoor Interface Criteria Air Inhalation Protectlon &RBSLs Crltena Criteria & RBSLs & RSSL.s Ambient Air (Y) #23 #24 #25 Olrix:t Contact #2& Infinite Source Finite Finite Particulate Volatile VSIC VS!C Soll forS Meter for 2 Meter Soll Inhalation Source Source Inhalation Criteria lblc~ness Thickness Criteria (VSIC) & RBSL.s & RBSL.s #27 #20 Olrect Contact Criteria & RBSLs Soll Saturation Concentration Screening Levels 1,3~0ichlorobenzene 541731 NA 170 480 680 51,000 48,000 94,000 94,000 1.1E+5 8 .8E+7 1.7E+5 (C) 1.7E+5 1,4-Dichlorobenzene 106467 NA 1,700 1,700 360 1.4E+5 1.0E+S 2.6E+5 2.6E+5 3.4E+5 5 .7E+6 1.9E+6 NA 3,3',Dlchlorobenzldine 91941 NA 4,600 NLV NLV NLV NLV 8.2E+6 30,000 NA 2,000 (M); 2,000 (M); 110 2,000 (M); 7.4 28 95,000 2.7E+5 ID Dichlorod'.ifluoromethane 75718 NA 1, 1-Dlchloroelhane 75343 NA 18,000 50,000 15,000 1.2-Dlchloroelhane (I) 107062 NA 100 100 75354 NA 140 140 cls-1,2-D,chloroelhylene 156592 NA 1,400 trans-1,2-Dichloroethylene 156605 NA 2,000 2,6-Dichloro-4-nilfoanlline 99309 NA 44,000 2,4-Dlchlorophenol 120832 NA 2 ,4-Dlctllorophenoxyacetic acid 94757 1.2-Dichloropropane (I) 76875 542756 62737 Dlcyclohexyl phlhala\e 84617 NA ID ID NA ID ID ID ID ID Dleldrln 60571 NA NLL NLL Nl l NLL 7.2E+5 64.000 64,000 64,000 Diethyl ether 60297 NA 200 200 ID 7.4E+6 (C) 7.4E+6 (C) 1.0E+S 1.6E+8 3.5E+8 Diethyl phlhalate 84662 NA 1.1E+5 3.2E+5 2,200 7.4E+S(C) NLV NLV NLV NLV Diethylene glycol monobutyl ether 112345 NA 1,800 5,000 NA 8 .0E+7 NLV NLV NLV NLV Dlisopropyl ether 108203 NA 600 1,300(C} ID 1,300(C) 1,300 (C} 3.2E•6 4.BE+6 1.0E+7 1.1-Dlchloroethylene (I) 1.3-Dlchloropropene Dlchlorovos March 25, 2011 1.0E+6(C) 1.7E+6 6.3E+7 5.5E+8 1.4E+9 1.5E+12 1.0E+6 (CI 1.0E+6 8.9E+5(C) 4.3E+5 2.5E+6 6.0E+6 1.4E+7 1.5 E+10 8.9E+5 (C) 8.9E+5 7 .200(X} 3.8E• 5 11,000 21 ,000 33,000 74,000 1.5E+8 4.2E•5 1.2E•6 2.600 2.2E+5 330 3,700 15,000 37,000 7.8E+7 5.7E+5 [C) 5.7E+5 1,400 12,000 6.4E+5 (C} 41,000 2.1E+5 4.3E+5 1.0E+6 1.0E+9 6 .4E+5 [C) 6.4E+5 2,000 30,000(X) 1.4E+6 (C) 43.000 3.3E+5 8.4E+5 2 .0E+6 2.1E•9 1.4E+6 (C) 1.4E+6 1.3E+5 NA 1.4E•5 NLV NLV NLV NLV ID 2.2E+6 NA 1,500 4,200 330 (M); 220 9.6E+5 NLV NLV NLV NLV 2.3E•9 1.8E+6 NA 1,400 1.400 4,400 2.4E+6 NLV NLV NLV NLV 2.9E+9 1.8E+6 fCDD) 8.6E+6 NA 100 100 4,600(X) 3.2E+5 7,400 30,000 51,000 1.2E+5 1.2E+8 5.SE+S (C) 5.SE+S NA 170 700 180 (X) 1.1E+S 5.400 60.000 2.0E+5 4.7E+5 5.9E•8 2.4E+5 6.2E•5 NA 50 (M); 32 130 NA 1.2E+5 NLV NLV NLV NLV 1.5E+7 47,000 2.2E+6 ID ID NA 8.5E+5 4,700 NA 3.5E+11 7.4E+6 (C} 7.4E+6 1.5E+9 7.4E+5(C) 7.4E+5 5.9E+8 8.7E+6 1.1E+8 1.1E+10 1,300 (C) 1,300 NA Page 6 of 14 �Attachment 1 TABLE 3. SOIL: NONRESIDENTIAL PART 201 GENERIC CLEANUP CRITERIA AND SCREENING LEVELS; PART 213 TIER 1 RISK-BASED SCREENING LEVELS (RBSLs) DOCUMENT RELEASE DATE: MARCH 25, 2011 All criteria, unless otherwise noted, are expressed in units of parts per billion (ppb). One ppb is equivalent to one microgram per kilogram (ug/kg). Criteria with six or more digits are expressed in scientific notation. For example, 200,000 is presented as 2.0E+5. The lowest generic soil criterion for a given hazardous substance is presented in a bold box. A footnote is designated by a letter in parentheses and is explained in the footnote pages that follow the criteria tables. When the risk-based criterion is less than the target detection limit (TDL), the TDL is listed as the criterion (R 299.5707). In these cases, two numbers are present in the cell. The first number is the criterion (i.e., TDL), and the second number is the risk-based value. Criteria were originally promulgated December 21, 2002 within the Administrative Rules for Part 201, Environmental Remediation, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. This table reflects revisions to the criteria pursuant to the December 2010 Part 201 amendments and new criteria consistent with the provisions of R299.5706a. The effective dates of the criteria and screening levels in this table vary. Please contact the Remediation Division Toxicology Unit for additional information. Indoor Air Groun<!Watcr Protection Guidesheet Number - Hazardous Substance > Chemical Abstract Service Number #10 #11 Statewide Resldentla Default Drinking Backgtound Water ProtectJon Levels Criteria &RBSLs #21 Non.. Residential Drinking Water Protection Criteria &RBSLs #12 #13 #22 Groundwater Groundwatco Soll Surface Contact Volatlllzatlon Water Protection to lndoor Interface Criteria Air Inhalation Protection &RBSLs Criteria Criteria & RBSLs &RBSLs Ambient Air (Y) #23 #24 #25 Direct Contact #26 Infinite Finite Finite Particulate Source Volatile VSIC VSIC Soll tors Meter 1or 2 Meter Soll Inhalation Source Source Inhalation Criteria Thickness Thickness Criteria (VSIC) & RBSLs & RBSLs #ZT #20 Direct Contact Criteria & RBSl.s Soll Saturation Concentration Screening Levels Dlisopropylamlne (l) 108189 NA 110 320 NA 4.2E+S 6.7E+6 (C) 7.4E+6 7.4E+6 7.7E+6 5 .9E+9 5.6E+5 6.7E+6 Dimethyl phthalate 131113 NA 7,9E+5(C) 7.9E+5(C] NA 7.9E+S (C) NLV NLV NLV NLV 1.5E+9 7.9E+5 (C) 7.9E+5 N,N-Dlmethylacetamlde 127195 NA 3.6DD 10,000 82,000 (X) 1.1E+8(C) NLV NLV NLV NLV ID 1.8E•7 1.1E•8 NA 4.0E•S 8.0E+S (C) 5.2E•5 5.2E+5 5.2E+5 3 .3E+8 8.0E+S(C) 8.0E+S N,N-Dimethylanlline 121697 NA 320 920 Dimelhylformamide (J) 68122 NA 14,000 40,000 NA 1.1E+8(C) NLV NLV NLV NLV 8.BE•B 7.0E+7 1. 1E•B 2, 4-Dlmethylphenol 105879 NA 7.400 20,000 7,600 1.0E+ 7 NLV NLV NLV NLV 2 .1 E•9 3.6E+7 NA 2.6-Dimethylphenol 576261 NA 330 (M); 260 NA 1.3E+5 NLV NLV NLV NLV 5.9E+7 4.4E+5 NA 1.0E•S 1.0E+6 NA 5.9E+8 1.8E+7 (C) 1.8 E+7 640 3,4-Dimethylphenol 95656 NA Dlmethylsulfoxide 67685 NA 330{M); 88 330 (M); 200 4.4E+6 2,4-Dlnitrotoluene 121142 NA 430 580 NA 3.6E•5 NLV NLV NLV NLV 1.3E•7 3.8E+6 1.8E+7 (C) NLV NLV NLV NLV NA 1.7E+5 NLV NLV NLV NLV 2.0E+7 2.2E•5 NA 1.4E+5(C) NLV NLV NLV NLV 1.2E+8 1.4E+5 NA Dinoseb 88857 NA 300 300 200 (M); 43 1,4-Dloxane (I) 123911 NA 1.700 7,000 56,000 (X) 3.4E+7 NLV NLV NLV NLV 7.1E+8 1.4E+5 rcDm 2.4E+6 85007 NA 400 400 NA 1.4E+7 NLV NLV NLV NLV ID 1.6E+6 620 1,800 NA 7.4E+5 NLV NLV NLV NLV 2.1E+8 3.1E+6 NA ID ID ID ID 4.4E+6 NA Dlquat Dluron 330541 NA 9.7E+7 Endosulfan (J) 115297 NA NLL NLL NLL NLL 10 Endothall 145733 NA NLL NLL NLL NLL NLV NLV NLV NLV 1.0E+9 1.2E•7 NA Endrin 72208 NA NLL NLL NLL NLL NLV NLV NLV NLV ID 1.9E+5 NA Epichlorohydrln (I) 106898 NA 100 100 NA 2.2E+5 1.2E+5 37,000 37,000 37,000 2.9E+7 41 ,000 7.3E+6 64175 NA 3.8E+7 7.6E+7 ID 1.1E+8 (C) NLV NLV NLV NLV 5.6E•11 1.1E•8 Ethyl acetate (I) 141786 NA 1.3E+5 3 .8E+5 NA 7.5E+6 (CJ 7.5E• 6 (C) 5.9E+7 5.9E+7 1.0E+8 9.4E+10 1.1E+8 ICDDl 7.5E•6 (C) 7.5E•6 Ethyt-tert-butyl ether (ETBE) 637923 NA 980 980 ID ID 6.SE+S (CJ 2.3E•6 4.6E+6 1.1E+7 1.1E+1 0 ID 6 .SE+S Ethanol (I) March 25, 2011 Page 7 of 14 �Attachment 1 TABLE 3. SOIL: NONRESIDENTIAL PART 201 GENERIC CLEANUP CRITERIA AND SCREENING LEVELS; PART 213 TIER 1 RISK-BASED SCREENING LEVELS (RBSLs) DOCUMENT RELEASE DATE: MARCH 25, 2011 All criteria, unless otherwise noted, are expressed in units of parts per billion (ppb). One ppb is equivalent to one microgram per kilogram (ug/kg). Criteria with six or more digits are expressed in scientific notation. For example, 200,000 is presented as 2.0E+S. The lowest generic soil criterion for a given hazardous substance is presented in a bold box. A footnote is designated by a letter in parentheses and is explained in the footnote pages that follow the criteria tables. When the risk-based criterion is less than the target detection limit (TDL), the TOL is listed as the criterion (R 299.5707). In these cases, two numbers are present in the cell. The first number is the criterion (i.e., TDL), and the second number is the risk-based value. Criteria were originally promulgated December 21, 2002 within the Administrative Rules for Part 201, Environmental Remediation, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. This table reflects revisions to the criteria pursuant to the December 2010 Part 201 amendments and new criteria consistent with the provisions of R299.5706a. The effective dates of the criteria and screening levels in this table vary. Please contact the Remediation Division Toxicology Unit for additional information. Indoor Air Groundwater Protection Guidesheet Number - Hazardous Substance > Chemical Abstract Service Number #10 #11 Statewide Resldentla Default Drinking Background Water Protection Levels Criteria &RBSLs #21 NonResJdentlal Drinking Watel' Protection Criteria &RBSLs #12 #13 #22 Groundwater Groundwate, Soil Surface Contact Volatlllzatlon Water Protection to Indoor Criteria Air interface &RBSu; Inhalation Protection Criteria Criteria & RBSLs &RBSLs Ambient Air (Y) #23 #24 #25 Direct Contact #26 lnflnlte Source Finite Finite Particulate Volatlle VSIC VSIC Soll !ors Meter !or 2 Meter Soll Inhalation Source Source Inhalation Criteria Thickness Thickness Criteria (VSIC) &R8SLs & RBSu; 1127 #20 Direct Contact Criteria & RBSLs Soll Saturation Concentration Screening Level$ Ethylbenzene (I) 100414 NA 1,500 1,500 360 1.4E+5 (C) 1.4E+5 (C) 2.4E+6 3.1E+6 6.SE+6 1.3E+10 1.4E•5 (C) 1.4E+5 Ethylene dibromide 106934 NA 20 (M); 1.0 20 (M); 1.0 110(X) 500 3,600 5,800 5,800 9,800 1.8E+7 430 8.9E+S Ethylene glycol 107211 NA 3.0E+S 8.4E+5 3.8E+6 (X) 1.1E+8(C) NLV NLV NLV NLV 2.9E+10 1.1E+8 (C) 1.1E•8 Ethylene glycol monobutyl ether 111762 NA 74,000 2.0E+S NA 4.1E+7 (C) 1.4E+6 2.1E+7 1.5E+8 3.6E+8 3.8E+11 4.1E+7 (C) 4. 1E+7 Fluoranthena 206440 NA 7.3E+5 7.3E•5 5,500 7.3E+5 1.0E+9 (D) 8.9E+8 8.8E+8 8.8E+8 4 .1E+9 1.3E•8 NA Fluorene 86737 NA 3.9E+5 8.9E+5 5,300 8.9E+5 1.0E+9 (D) 1.5E+8 1.SE+S 1.SE+a 4.1E+9 8.7E+7 NA 7782414 NA 40,000 40,000 ID 2.4E+8 NLV NLV NLV NLV ID 6,7E+7 (DD) NA 50000 NA 26,000 75,000 2.400 6.DE•7 (C) 65,000 43,000 69,000 1.SE+S 3.0E+8 6.0E+7 (C) 6.0E+7 Fluorine (soluble fluoride) {B) Formaldehyde 64186 NA 2.0E+S 5.SE+S ID 1.1E+8(C) 2.8E+6 2.6E+5 1.6E•5 1.6E+5 5.9E+7 1.1E+8 (C) 1.1E+8 2591868 NA 1,600 4,500 NA ID ID 10 ID ID ID 8.0E+6 1.0E+7 Gentian violet 548629 NA 300 1,300 NA 2.0E+7 NLV NLV NLV NLV ID 4.4E+S NA Glyphosate 1071836 NA NLL NLL NLL NLL NLV NLV NLV NLV ID 5.7E+7 (DD) NA Heptachlor 76448 NA NLL NLL NLL NLL 1.9E•6 2.1E+5 2.1E+S 2 .1E+5 3.0E•6 23,000 NA Formic acid (I.LI) 1-Formylpiperidino Heptachlor epoxide 1024573 NA NLL NLL NLL NLL NLV NLV NLV NLV 1.5E+6 9,500 NA n-Heptane 142825 NA 2.4E+5 (C) 2.4E+5 (C) NA 2.4E+S(C) 2.4E•5 (C) 2.SE+7 4.5E+7 1.0E+8 1.0E+11 2.4E+S(C) 2.4E+S Hexabromobenzene 87821 NA 5,400 5.400 ID 5.400 ID ID ID ID ID 3.1E+6 NA Hexachlorobenzene (C-66) 118741 NA 1,800 1,800 350 8,200 2.2E+5 56,000 56,000 56,000 8.5E+6 37,000 NA 3,SE+S(C) 3.5E+5(C) 4.6E+5 4.6E+5 4.6E+5 1,8E+8 3.SE+S (C) 3.5E+5 NA Hexachlorobutadiene (C-46) 87683 NA 26,000 72,000 91 alpha-Hexachlorocyclohexane 319848 NA 18 71 ID 2,500 1,SE+S 41,000 86,000 86,000 2,1E•6 12,000 beta-Hexachlorocyclohexane 319857 NA 37 150 ID 5,100 NLV NLV NLV NLV 7.4E•6 25,000 NA 77474 NA 3.2E•S 3.2E+5 !D 7.2E•S (C) 56,000 60,000 60,000 60,000 5.9E•6 7.2E•5 (C) 7.2E• S Hexachlorocyclopentadlene (C-56) March 25, 2011 , Page 8 of 14 �Attachment 1 TABLE 3. SOIL: NONRESIDENTIAL PART 201 GENERIC CLEANUP CRITERIA AND SCREENING LEVELS; PART 213 TIER 1 RISK-BASED SCREENING LEVELS (RBSLs) DOCUMENT RELEASE DATE: MARCH 25, 2011 All criteria, unless otherwise noted, are expressed in units of parts per billion (ppb). One ppb is equivalent to one microgram per kilogram {ug/kg). Criteria with six or more digits are expressed in scientific notation. For example, 200,000 is presented as 2.0E+S. The lowest generic soil criterion for a given hazardous substance is presented in a bold box. A footnote is designated by a letter in parentheses and is explained in the footnote pages that follow the criteria tables. When the risk-based criterion is less than the target detection limit (TDL), the TDL is listed as the criterion {R 299.5707). In these cases, two numbers are present in the cell. The first number is the criterion (i.e., TDL), and the second number is the risk-based value. Criteria were originally promulgated December 21, 2002 within the Administrative Rules for Part 201, Environmental Remediation, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. This table reflects revisions to the criteria pursuant to the December 2010 Part 201 amendments and new criteria consistent with the provisions of R299.5706a. The effective dates of the criteria and screening levels in this table vary. Please contact the Remediation Division Toxicology Unit for additional information. Guldesheet Number - > #11 #21 #12 Ambient Air (YJ Indoor Air Groundwater Protection #10 #13 #22 #23 #24 #25 Direct Contact #26 #27 #20 Direct Contact Criteria & RBSLs Soll Saturation Concentration Screening Levels Infinite Hazardous Substance Chemical Abstract Service Number Statewide Resldentla Default Drinking Background Water Level$ Protection Criteria & RBSLs Non.. Residential Drlnklng Water Protection Criteria & RBSLs Groundwater Groundwater Soll Surface Contact Volatilization Water Protection to Indoor Air Criteria Interface Inhalation Protection & RBSLs Criteria Criteria &RBSLs & RBSLs Source Finite Finite Particulate Volatile VSJC VSIC Soll for 5 Meler for 2 Meter Soll Source Source Inhalation Inhalation Criteria ThJckness Thickness Criteria (VSIC) &Rl!Sls & RBSLs Hexaehloroethane 67721 NA 430 1,200 1,800 (X) 1.1E•5 79,000 6.6E+5 1.4E•6 1.4E+6 1.0E•8 7.3E+5 NA n-Hexane 110543 NA 44,000 (C) 44,000 (C) NA 44,000 [C) 44,000{C) 3.SE•S 3.5E•6 6.4E+6 5.9E•9 44.000(C) 44,000 2-Hexanone 5917B6 NA 20,000 58,000 ID 2.5E•6 (Cl 1.8E•6 1.3E+6 1.3E•6 1.5E+6 1.2E•9 2.SE•S (C) 2.SE+6 lndeno[1,2.3-cd)pyrene (Q) 193395 NA NLL NLL NLL Nll NLV NLV NLV NLV ID 80,000 NA Iron (8) 7439896 1.2E+7 6,000 6,000 NA 1.0E+9 (D) NLV NLV NLV NLV ID 5.8E•8 NA 78831 NA 46,000 1.3E+5 NA 8.9E•6(C) 8.9E•6 (C) 9.5E+7 9.SE•7 9.5E+7 4.4E+10 8.9E+6(C) 8.9E+6 lsophOrone 78591 NA 15,000 62,000 26,000 (X) 2.4E+6(C) NLV NlV NLV N LV 8.2E+9 2.4E•6 (C) 2.4E•6 lsopropyl alcohol (I) 67630 NA 9.400 26,000 1.1E•6 (X) 1.1E+8 (C) NLV NLV NLV NLV 6.5E+9 4.7E+7 1.1E+8 3.200 3,9E+S{C) 3.9E+5(C) 2.0E+S 2.0E•S 3.0E•6 2.6E+9 3.9E• 5 (C) 3.9E+5 NA Jsobutyl alcohol (I) 91 ,000 2.6E•5 98828 NA Lead {B) 7439921 21,000 7.0E•5 7.0E+S ID NLV NLV NLV NLV 4.4E+7 9.0E+S (DD) Lindane 58899 NA 20 (Ml: 7.0 20 (M): 7.0 20 (M): 1.1 7,100 ID ID ID ID ID 42,000 NA Lithium (B) 7439932 9,800 3,400 7,000 8,800 1.1E•8 NLV NLV NLV NLV JO 3.1E+7(DD) NA Magnesium (B) 7439954 NA 8.0E+6 2.2E+7 NA 1.0E+9 (D) NLV NLV NLV NLV 2 .9E•9 1.0E+9 (D) NA Manganese (B) lsopropyl benzene (C,X) 7439965 4.4E+5 1,000 1,000 (C,X) 1.8E+8 NLV NLV NLV NLV 1.5E•6 9.0E•7 NA Mercury (Total) (B,Z) vanes 130 1,700 1,700 SO(M): 1.2 47,000 89.000 62.000 62,000 62,000 8.8E+6 5.8E+5 NA Methane 74828 NA lD ID NA ID ID ID ID ID ID ID 3.1E+6 (CJ 3.7E+7 4.6E+7 9.7E• 7 9.6E• 10 3.1E+6 (C) 3.1E•6 uaJ~4:;JG\ 3.1E+6 (C) Methanol 67561 NA 74,000 2.0E+S 3,1E+6 (C) Methoxyehlor 72435 NA 16,000 16,000 NA 18,000 ID 10 ID 10 ID 5.6E+6 NA 2-Methoxyethanol (I) 109864 NA 150 420 NA 1.7E+7 NLV NLV NLV NLV 5.9E+8 7.3E•5 1.1E•8 2-Melhyl-4-chlorophenoxyacetic acid 94746 NA 390 1,100 NA 4.9E+5 NLV NLV NLV NLV ID 7.3E+5 NA 830 (M): 400 NA 1.9E+S NLV NLV NLV NLV ID 2.6E+5 NA 2-Methyl-4,6-dinltrophenol March 25, 2011 534521 NA 830(M): 400 Page 9 of 14 �Attachment 1 TABLE 3. SOIL: NONRESIDENTIAL PART 201 GENERIC CLEANUP CRITERIA AND SCREENING LEVELS; PART 213 TIER 1 RISK-BASED SCREENING LEVELS (RBSLs) DOCUMENT RELEASE DATE: MARCH 25, 2011 All criteria, unless otherwise noted, are expressed in units of parts per billion (ppb). One ppb is equivalent to one microgram per kilogram (ug/kg). Criteria with six or more digits are expressed in scientific notation. For example, 200,000 is presented as 2.0E+S. The lowest generic soil criterion for a given hazardous substance is presented in a bold box. A footnote is designated by a letter in parentheses and is explained in the footnote pages that follow the criteria tables. When the risk-based criterion is less than the target detection limit (TDL), the TDL is listed as the criterion (R 299.5707). In these cases, two numbers are present in the cell. The first number is the criterion (i.e., TDL), and the second number is the risk-based value. Criteria were originally promulgated December 21, 2002 within the Administrative Rules for Part 201, Environmental Remediation, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. This table reflects revisions to the criteria pursuant to the December 2010 Part 201 amendments and new criteria consistent with the provisions of R299.5706a. The effective dates of the criteria and screening levels in this table vary. Please contact the Remediation Division Toxicology Unit for additional information. Groundwater Protection Guldesheet Number - Hazardous Substance > Chemical Abstract Service Number #10 #11 Statewide Residentla Drinking Default Background Waler Proteetlon levels Criteria & RBSLs #21 NonResidential Drlnklng Water Protection Crtterla & RBSLs #12 Ambient Air M Indoor Air #13 #22 Groundwater Groundwater Soll Surface Contact Volatilization Water Protection to Indoor Criteria Air Interface Protection & RBSLs lnhalatlon Crttena Criteria & R8SLs & RBSLs #23 #24 #25 Direct Contact #2& lnllnltc Finite Finite PartJculale Source VSIC Volatlle VSIC for 6 Meter for 2 Meter Soll Soll Inhalation Source Source Inhalation Criteria Thickness Thickness Criteria (VSIC) & RBSLs & RBSLs #27 #20 Direct Contact Criteria & RBSLs Soll Saturath:>n Concentration Screening Levels 1.1E+8 N-Methyl-morpholine (I) 109024 NA 400 1,100 NA 3.0E•7 NLV NLV NLV NLV ID 2.0E+S Methyl parathion 298000 NA 46 130 NA 76,000 NLV NLV NLV NLV ID 1.BE+S NA 2,7E•6 (C) 2.7E•6 (C) 5.3E•7 5.3E+7 7.0E+7 6.0E+10 2.7E•6(C) 2.7E+6 5.9E•6(C) 5.9E+6 (C) 3 .0E+7 4 .1E•7 8,9E•7 8.8E+10 5.9E+6(C) 5.9E+6 3.5E+5 4-Methyl-2-pentanone [MIBK) (I) 108101 NA 36,000 1.0E•5 ID Methyl4eri-butyl ether (MTBE) 1634044 NA 800 800 1.4E•S (X) Methylcyciopentane (I) 96377 NA ID ID NA ID 1.7E•5 2.8E•6 8.3E+6 2.0E+7 2.1E+10 ID 4,4'-Melhylene-bls-2- chloroaniline <MBOCA) Methylene chloride 101144 NA NLL NLL NLL NLL NLV NLV NLV NLV 1.1E•8 32,000 NA NA 100 100 30,000(X) 2.3E•6 (C) 2.4E+S 7.0E+S 1.7E•6 4.0E+6 B.3E+9 2.3E+6 [C) 2.3E+6 2-Methylnaphthalene 91576 NA 57,000 1.7E+5 4,200 5.5E•6 4.9E+6 1.8E+6 1.BE+6 1.8E+6 2.9E+S 2.6E•7 NA 1319773 NA 7,400 20,000 1,000 (M): 600 1.6E+7 NLV NLV NLV NLV 2.9E+9 3.6E•7 NA Melolach!or 51218452 NA 4,800 20.000 300 4.4E•S(C) NLV NLV NLV NLV ID 4.4E+S 4.4E+S Metribuz1n 21087649 NA 3,600 10,000 NA 2.4E+7 ID ID ID ID ID 2.BE+7 NA Mirex 2385855 NA NLL NLL NLL NLL ID ID 1D ID ID 40,000 NA Molybdenum (B) 7439987 NA 1,500 4,200 64,000(X) 1.9E+7 NLV NLV NLV NLV ID 9.6E+6 NA 91203 NA 35,000 1.0E•5 730 2.1E•6 4 .7E+5 3.SE•S 3.5E+5 3.SE+S 8 .8E+7 5.2E+7 NA Nickel (B) 7440020 20,000 1.0E+S 1.01;+5 (G) 1.0E+9 (D) NLV NLV NLV NLV 1.6E+7 1.5E•8 NA Nitrate (B.N) 14797558 NA 2.0E+S{N) 2.0E+5(N) ID 1.0E+9(D) NLV NLV NLV NLV 10 ID NA Nitrite (B,N) 14797650 NA 20,000 (N) 20,000 (N) NA 3.8E+8 NLV NLV NLV NLV ID ID NA 98953 NA 330 (M): 330 (M): 190 3,600 (X) 2.2E•5 1,7E+5 64,000 64,000 64,000 2.1E+7 3.4E+S 4.9E+S 1.6E•6 NLV NLV NLV NLV ID 2.0E•6 NA Methylphenols (J) Naphthalene Nilrobenzene (I) 75092 re.om 68 2-Nitrophenol n-Nitroso,..ctl..n-propylamlne N-Nitrosodiphenylamine March 25, 2011 88755 NA 400 1,200 ID 621647 NA NA 7,200 NLV NLV NLV NLV 2.0E•6 5,400 1.5E+6 NA 330 (M); 100 5,400 330(M); 100 86306 22,000 NA 7.0E+S NLV NLV NLV NLV 2.8E+9 7.8E+6 NA Page 10 of 14 �Attachment 1 TABLE 3. SOIL: NONRESIDENTIAL PART 201 GENERIC CLEANUP CRITERIA AND SCREENING LEVELS; PART 213 TIER 1 RISK-BASED SCREENING LEVELS (RBSLs) DOCUMENT RELEASE DATE: MARCH 25, 2011 All criteria, unless otherwise noted, are expressed in units of parts per billion (ppb). One ppb is equivalent to one microgram per kilogram (ug/kg). Criteria with six or more digits are expressed in scientific notation. For example, 200,000 is presented as 2.0E+S. The lowest generic soil criterion for a given hazardous substance is presented in a bold box. A footnote is designated by a letter in parentheses and is explained in the footnote pages that follow the criteria tables. When the risk-based criterion is less than the target detection limit (TDL), the TDL is listed as the criterion (R 299.5707). In these cases, two numbers are present in the cell. The first number is the criterion (i.e., TDL), and the second number is the risk-based value. Criteria were originally promulgated December 21, 2002 within the Administrative Rules for Part 201, Environmental Remediation, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. This table reflects revisions to the criteria pursuant to the December 201 O Part 201 amendments and new criteria consistent with the provisions of R299.5706a. The effective dates of the criteria and screening levels in this table vary. Please contact the Remediation Division Toxicology Unit for additional information. Gulde-sheet Number - Hazardous Substance > Chemle<1l Abstract Service Number #10 Statewide Residential Drinking Default Background Water Levels Protection Criteria & RBSL.s #21 NonRe$ldentlal Drinking Water Protection Criteria & RBSL.s #12 Ambient Air M 1ndoorAlr Groundwater Protec:tlon #11 #13 #22 Groundwater Groundwater Soll Surface Contact Volallllzallon Protection to Indoor Water Air Interface Criteria Protcctlon &RBSL.s Inhalation Criteria Criteria & RBSL.s & RBSLs #23 #24 #2$ Direct Contact #26 Infinite Source Finite Finite Particulate Volatlle VSIC VSIC Soll lr>r 5 Meter for2 Meter Soll Inhalation Source Inhalation Source Criteria Thickness Thlckne" Criteria (VSIC) & RBSL.s & RBSL.s #27 #20 Direct Contact Criteria & RBSL.s Soil Saturation Conc:t'ntration Screening Levels Oxamyl 23135220 NA 4,000 4,000 NA 1.0E+9{D) NLV NLV NLV NLV ID 2.8E+7 NA Oxo-hexyl acetate 88230357 NA 1,500 4,200 NA ID ID ID !D ID 2.4E•9 7.3E+6 1.0E+7 Pendimethalin 40487421 NA 1.1E+6 1.1E+6 NA 1.1E+6 NLV NLV NLV NLV ID 1.3E+8 NA 1.9E+5 NA 608935 NA 29,000 81,000 9,500 1.9E+5 (C) ID ID ID lD !D 1.9E•5 (C) Pentachloronltrobenzene 82688 NA 37,000 37,000 NA 37,000 2.2E•5 2.8E+5 2,8E+ 5 2,8E+5 1.SE+S 5 ,5E+6 Pentachlorophenol 87865 NA 22 22 (G.X) 4,300 NLV NLV NLV NLV 1.3E+8 3 .2E+5 NA Pentane 109680 NA ID ID NA ID 1.8E+5 4.4E+7 3.4E•8 6.0E•8 5.3E+11 ID 2.4E•5 2-Pentene (I) 109682 NA ID ID NA ID ID lD ID ID ID ID 2.2E+5 1,9E+5 1,9E+S 2,9E+5 S.2E+6 NA Pentachlorobenzene 56,000 1.6E+5 2,100 1.1E+6 5.1E+6 1,9E+5 NA 88,000 2.6E+5 9,000 1.2E+7 (C) NLV NLV NLV NLV 1.8E+10 1.3E+6 4.BE+S (EE) ID NLV NLV NLV NLV 2.9E+7 1.2E•7 <CDDl 1.0E•9 (D) 1.2E•7 NA NLV NLV NLV NLV !D 1.7E+6(C) 1.7E+6 1.1E+6 85ll18 NA Phenol 108952 Phosphorus (Total) 77Zl140 Phenanthrene NA Phthallc acid 88993 NA 2.8E+5 8.0E+S NA 1.7E+6 (C) Phthallc anhydride 85449 NA 3.0E+S 8.8E+5 NA 1.1E+6(C) NLV NLV NLV NLV 10 1.1E+6 (CJ Picloram 1918021 NA 10,000 10,000 920 8 .6E+6 NLV NLV NLV NLV ID 5.1E+7 NA Plperidlne 110894 NA 64 180 NA 6.8E+5 NLV NLV NLV NLV 4.1E+9 3.2E+5 1.2E+8 sm4327 NA NLL NLL NLL NLL NLV NLV NLV NLV ID 4,800 NA NA Polybromlnated blphenyls {J) Polychlorlnated biphenyls (PCBs) IJTl Prometon 1336363 NA NLL NLL NLL NLL 1.6E+7 8.1E+5 2 .BE+7 2.8E•7 6.SE+6 (T) 1610180 NA 4.SOO 14,000 NA 5.5E+6 NLV NLV NLV NLV 1D 1.6E+7 NA Propachlor 1918167 NA 1,900 5.400 NA 8.8E+6 NLV NLV NLV NLV ID 9.5E+6 NA Propazin,, 139402 NA 4,000 11,000 NA 1.7E+5 NLV NLV NLV NLV ID 2.0E+7 NA Propionic acid 79094 NA 2.4E+5 7.0E•S ID 1.1E+8(C) NLV NLV NLV NLV 8.8E+9 1.1E+8 (C) 1.1E+8 March 25, 2011 Page 11 of 14 �Attachment 1 TABLE 3. SOIL: NONRESIDENTIAL PART 201 GENERIC CLEANUP CRITERIA AND SCREENING LEVELS; PART 213 TIER 1 RISK-BASED SCREENING LEVELS (RBSLs) DOCUMENT RELEASE DATE: MARCH 25, 2011 All criteria, unless otherwise noted, are expressed in units of parts per billion (ppb). One ppb is equivalent to one microgram per kilogram (ug/kg). Criteria with six or more digits are expressed in scientific notation. For example, 200,000 is presented as 2.0E+S. The lowest generic soil criterion for a given hazardous substance is presented in a bold box. A footnote is designated by a letter in parentheses and is explained in the footnote pages that follow the criteria tables. When the risk-based criterion is less than the target detection limit (TDL), the TDL is listed as the criterion (R 299.5707). In these cases, two numbers are present in the cell. The first number is the criterion (i.e., TDL), and the second number is the risk-based value. Criteria were originally promulgated December 21, 2002 within the Administrative Rules for Part 201, Environmental Remediation, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. This table reflects revisions to the criteria pursuant to the December 2010 Part 201 amendments and new criteria consistent with the provisions of R299.5706a. The effective dates of the criteria and screening levels in this table vary. Please contact the Remediation Division Toxicology Unit for additional information. Indoor Air Groundwater Protection Guldeshcct Number - > Chemical Hazardous Substance Abstract Service Number #10 #11 #21 Statewide Residential NonDefault Drinking Residential Background Water Drinking Water' levels Protec:tion Criteria Protection & RBSls Criteria & RBSLs #12 #13 #22 Groundwater Groundwate, Soll Surface Contact Volatlllzatlon Water Protection to Indoor Criteria Air Interlace Inhalation Protection &RBSls Criteria Criteria & RBSls &RBSls Ambient Air (Y) #23 #24 #25 Direct Contact #2& Infinite Finite Partteulate Source Finite VolaUle VSIC VSIC for 5 Meter for2 Meter Soll Soll Inhalation Source Source Inhalation Thickness Thickness Criteria Criteria (VSIC) & RBSLs &RBSLs #27 #20 Direct Contact Criteria & RBSLs Soll Saturation Concentratlon sc,ccntng Levels Propyl alcohol (I) 71238 NA 28,000 80.000 NA 1.1E+S(C) NLV NLV NLV NLV 2. 1E•10 7.4E•7 {DD) 1.1E• 8 n-Propylbenzene (I} 1036S1 NA 1,600 4,600 ID 3.0E+5 ID ID !D ID 5.9E+8 8,0E+6 1.0E•7 Propylene glycol S7556 NA 3.0E+6 8.4E+6 5.8E+6 1.1E•8{C) NLV NLV NLV NLV 1.8E+11 1.1E+8(C) 1.1E+S NA 4.8E+5 4.SE•S ID 4.8E+5 1.0E+9{D) 7.8E+8 7 .8E+8 7.8E+8 2 .9E+9 8.4E+7 NA Pyrene 129000 Pyridine (I) 110861 NA 400 420 NA 37,000 (C) 2,000 9,800 40,000 97,000 1.0E•8 37,000 IC) 37,000 Selenium (B) 7782492 410 4,000 4,000 400 7.8E+7 NLV NLV NLV NLV 5.9E•7 9.6E+6 NA Silver (BJ 7440224 1,000 4.500 13,000 100 (M); 27 2.0E•S NLV NLV NLV NLV 2 .9E+6 9.0E+6 NA Silvex (2,4,5-TPJ 93721 NA 3,600 3.60D 2.200 3.1E+6 NLV NLV NLV NLV ID 5.5E+6 NA Simazine 122349 NA 80 80 340 90.000 NLV NLV NLV NLV ID 3.8E+6 NA Sodium 17341252 NA 2.SE+6 7.0E+6 NA 1.0E+9{DJ NLV NLV NLV NLV ID 1.0E+9 (D) NA Sodium azlde 26628228 NA 1,800 5,000 1,000 ID ID ID ID ID ID 8.7E+6 NA Strontium (BJ 7440246 NA 92.000 2.6E+5 4.2E+S 1.0E+9 (D) NLV NLV NLV NLV ID 1.0E+9 (D) NA 2,100 (XJ 2.7E+5 5.2E+S (CJ 3.3E+6 3.3E+6 4.2E+6 6.9E+9 5.2E+S(CJ S.2E+S Styrene 100425 NA 2.700 2,700 Suttate 14808798 NA 5.0E+6 5.DE+6 NA ID NLV NLV NLV NLV ID ID NA T ebuthiuron 34014181 NA 10,000 30,000 NA 5.0E+7 NLV NLV NLV NLV ID 2.7E+7 (DD) NA 2,3,7 ,8-Tetrabromodibenz(>.?-d,oxin 10) 1.2.4.5-Tetrachlorobenzene 50585416 NA NLL NLL NLL Nll NLV NLV NLV Nl V (0) (OJ NA 95943 NA 1.5E+6 1.5E+6 3,400 (XJ 1.5E+6 1.1E+6 2.7E+5 2.7E+5 2.7E+5 2.9E+7 2.SE+B NA 2,3,7.8-Tetrachlorodibenzo-p-dioxin 1746016 NA NLL Nll NLL NLL NlV NLV NLV NLV 89 (OJ 0.99(0) NA 1,1,1,2-Tetrachloroetnane 630206 NA 1,500 6,400 ID 4 .4E•5 (C) 33,000 1.2E+5 2.1E+5 3.3E+5 5.3E•8 4.4E+5 (C) 4.4E+5 1,1,2,2-Tetrachlaroethane 79345 NA 170 700 1,600(X) 94.000 23.000 34,000 34,000 34.000 6 .8E+7 2.4E+S 8.7E•5 Tetrachloroothylene 127184 NA 100 100 1,200(X) 88,000 (CJ 60,000 6.0E+S 1.4E+6 3.3E+6 6 .8E+9 88,000 (C) 88.000 (01 March 25, 2011 Page 12 of 14 �Attachment 1 TABLE 3. SOIL: NONRESIDENTIAL PART 201 GENERIC CLEANUP CRITERIA AND SCREENING LEVELS; PART 213 TIER 1 RISK-BASED SCREENING LEVELS (RBSLs) DOCUMENT RELEASE DATE: MARCH 25, 2011 All criteria, unless otherwise noted, are expressed in units of parts per billion (ppb}. One ppb is equivalent to one microgram per kilogram (ug/kg}. Criteria with six or more digits are expressed in scientific notation. For example, 200,000 is presented as 2.0E+5. The lowest generic soil criterion for a given hazardous substance is presented in a bold box. A footnote is designated by a letter in parentheses and is explained in the footnote pages that follow the criteria tables. When the risk-based criterion is less than the target detection limit (TDL), the TDL is listed as the criterion (R 299.5707). In these cases, two numbers are present in the cell. The first number is the criterion (i.e., TDL), and the second number is the risk-based value. Criteria were originally promulgated December 21, 2002 within the Administrative Rules for Part 201, Environmental Remediation, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. This table reflects revisions to the criteria pursuant to the December 2010 Part 201 amendments and new criteria consistent with the provisions of R299.5706a. The effective dates of the criteria and screening levels in this table vary. Please contact the Remediation Division Toxicology Unit for additional information. lndQQr Air Groundwater Protection Guldesheet NumDer - Hazardous Substance > Chemical Abstract Service Number #10 #11 Statewide ResidcntJa Drinking Oefault Background water levels Prote<:tlon Criteria & RBSLs #21 N<>nResidential Orinklng Wator Protectlon Criteria & RBSLs #12 #13 #22 GroundWater Groundwater Soll Surface Contact Volatlllzatlon to Indoor Water Protection Criteria Air Interface Protection & RBSLs Inhalation Criteria Criteria & RBSLs & RBSLs Ambient Air [Y) #23 #24 #25 Olrect Contact #26 Infinite Finite Particulate Finite Source Volatile VSIC VSIC Soil forSMeter tor2 Meter Soll Inhalation Source Source Inhalation Criteria Ttllc~ness Thickness Criteria [VSIC) & RBSLs & RBSLs #27 #20 Direct Contact Criteria & RBSLs SaturatJon ConcentratJon Screening Soll Levels Tetrahydrofuran 109999 NA 1,900 5,400 2.2E•S(X) 3.2E•7 2.4E+6 1.5E•7 6.7E+7 1.6E+8 1.7E+1 1 9.5E+6 1.2E+8 Tetranltromethane 509148 NA lD ID NA ID 600 ID ID 2.6 E•5 ID ID NLV NLV 5.9E+6 1.3E+S NA 3.6E•7 3.6E+7 1.2E+10 2.5E+5 (C) 2.5E+5 Thallium (Bl 7440280 NA 2,300 2,300 4,200 (X) 1.5E+7 NLV 500 (M): 180 NLV Toluene (I) 108883 NA 16,000 16,000 5,400 2.SE+S (C) 2.5E•5 IC) 3.3E• 6 p-Toluidine 106490 NA 1,200 NA 4.SE•S NLV NLV NLV NLV 1.3E+8 4.3E+5 1.2E+6 24,000 8,200 3.6E• 5 NLV NLV NLV NLV 1.2E+7 85,000 NA Toxaphene 8001352 NA 660(M); 300 24,000 Trlallate 2303175 NA 95,000 2 .SE+ S IC) NA 2.SE+S (C) ID ID ID ID ID 2.SE+ S(C) 2.SE+S Tributylamlne 102829 NA 7,800 23,000 ID 1.8E• 6 1.1E+6 7 .2 E+ 5 7.2E•5 7.2E•5 2.1E+8 2 .6E+6 3.7E• 6 1,2,4-Trichlorobenzene 120821 NA 4 ,200 4,200 5,900 (X) 1.1E+6 (C) 1.1E•6(C) 3.4E+ 7 3.4E+7 3.4E•7 1.1E+10 4 ,000 4,000 1,800 4.6E+5 (C) 4.6E+5 4.5E+6 1.5E•7 3.1E• 7 2.9E+10 1.1E+6 ICDD\ 4 .6E+5 IC) 4.6E+5 1.1E+6 1, 1,1-Trichloroethane 71556 NA 1,1.2-Trichloroethane 79005 NA 100 100 6,600 (X) 4.2E+5 24,000 57,000 57.000 1.2 E+5 2.SE+B 8.4E+5 9.2E+5 Trichloroethylene 79016 NA 100 100 4,000 (X) 4.4E+5 37.000 2.6E+5 4.4E+5 1.1E+6 2.3E+9 5.0E+S Trlchloronuoromethane 75694 NA 52,000 1.5E+5 NA 5 .6E+5(C) 5 .6E+S(C) 1.1 E• 8 1.4E+11 1.4E+11 1.7E•12 5.0E+S IC DD\ 5.6E+5 (C) 2.4,5-Triehlorophenol 95954 NA 39,000 1.1E+5 NA 9.1E•6 NLV NLV NLV NLV 1.0E+ 10 7.3E+7 NA 2,4,6-Trichlorophenol 88062 NA 2,400 9,400 330 (M); 100 2.0E+S NLV NLV NLV NLV 1.3E+9 3.3E+6 NA 1,2.3-Trichloropropane 96184 NA 840 2,400 NA 8.3E+5 (C) 7,500 11,000 11,000 12,000 8 .8E+6 8.3E+5 (C) 8.3E+S 1,1.2-Trichloro-1,2,2-oifluoroethane 76131 NA 5.SE+S(C) 5.SE+S (C) 1,700 5.SE•S (C) 5.5E+5 (C) 2.1E• 8 8.9E+S 2, 1E+9 2.3 E+12 5.SE•S(C) 5,SE+S Trlethat\Olamine 102716 NA 74,000 2.0E+S NA 1.1E+8 (C) N LV NLV NLV NLV 1.5E• 9 1.1E+S(C) 1.1E+8 Triethylene glycol 112276 NA 1.1E+5 (C) 1.1E+5 {C) NA 1.1E•S (C) NLV NLV NLV NLV ID 88302 NA 1.1 E• 5 3.1E+5 NA 1.2E+8 NLV NLV NLV NLV ID 1.1E+5 rC DD) 2.4E+8 [DD) 1. 1E+5 3-Trifluoromethyl-4-nltrophenol 1582098 NA 1.9 E+5 5.7E+S NA 1.2E+7 ID ID ID 10 ID 5.7E+6 NA Trifluralin March 25, 2011 5.6E+5 NA Page 13 of 14 �Attachment 1 TABLE 3. SOIL: NONRESIDENTIAL PART 201 GENERIC CLEANUP CRITERIA AND SCREENING LEVELS; PART 213 TIER 1 RISK-BASED SCREENING LEVELS (RBSLs) DOCUMENT RELEASE DATE: MARCH 25, 2011 All criteria, unless otherwise noted, are expressed in units of parts per billion (ppb). One ppb is equivalent to one microgram per kilogram (ug/kg). Criteria with six or more digits are expressed in scientific notation. For example, 200,000 is presented as 2.0E+S. The lowest generic soil criterion for a given hazardous substance is presented in a bold box. A footnote is designated by a letter in parentheses and is explained in the footnote pages that follow the criteria tables. When the risk-based criterion is less than the target detection limit (TDL), the TDL is listed as the criterion (R 299.5707). In these cases, two numbers are present in the cell. The first number is the criterion (i.e., TDL), and the second number is the risk-based value. Criteria were originally promulgated December 21, 2002 within the Administrative Rules for Part 201, Environmental Remediation, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. This table reflects revisions to the criteria pursuantto the December 2010 Part 201 amendments and new criteria consistent with the provisions of R299.5706a. The effective dates of the criteria and screening levels in this table vary. Please contact the Remediation Division Toxicology Unit for additional information. Gtot.rndwatet Protection Guldesheet Number - Hazardous. Substance > Chemical Abstract Service Number #10 #11 Statewide Resldentla Default Drinking Background Water Levels ProtectJon Criteria & RBSL.s #21 Non.. ResJdentlal Drinking Watcl' Protection Crlterla & RBSL.s #12 Ambient Air M lndOC>r Air #13 #22 Groundwater Groundwater Soll Surface Contact Volatilization Water Protection to Indoor Interlace Criteria A ir Protection & RSSI.S Inhalation Criteria Criteria & RBSI.S &RBSLs #23 #24 #25 Direct Contact #26 lnflnlte Source Finite Finite Particulate Volatile VSIC VSJC for 5 Mete, for 2 Meter Soll Soll Inhalation Source Sou rce Inhalation Criteria Thickness Thickness Crlterla {VSIC) & RBSLs & RBSLs #ZT #20 Direct Contact Criteria & RBSI.S Soll Saturation Concentration Screening Levels 2,2,4-Trimethyl pentane 540841 NA ID ID NA ID 19,000(C) 6.3E+6 4 .0E+7 9.6E•7 1.0E+11 ID 19,000 2,4,4-Trimethyl-2-pentene (I) 107404 NA ID ID NA ID ID ID ID ID ID ID 56,000 1,2,4-Trimelhylbenzene {I) 95636 NA 2,100 2,100 570 1.1E+5 (C) 1.1E+5(C) 2.5E+7 6 .0E+8 6.0E+8 3.6E+10 1.1E+5(C) 1.1E+5 1,3,5-Trimethylbenzene (I) 108678 NA 1,800 1,800 1,100 94.000 (C) 94,000 (C) 1.9E+7 4 .6E+8 4.6E+8 3.6E+10 94,000 (C) 94,000 Triphenyl phosphate 115866 NA 1.1E•5(C) 1.1E•5(C) NA 1.1E+5 (C) NLV NLV NLV NLV ID 1.1E•5 (C) 1.1E•5 tris(2,3-Dibromopropyl)phosphate 126727 NA 930 930 ID 27,000 (C) 27,000 (C) 60,000 60,000 6 0,000 7.4E•6 20,000 27,000 Urea 57136 NA ID ID NA ID NLV NLV NLV NLV ID ID NA 7440622 NA 72,000 9.9E•5 1.9E+5 1.0E+S(D) NLV NLV NLV NLV ID 5.SE+6(DD) NA 108054 NA 13,000 36,000 NA 2.4E+6 (C) 1.5E+6 2.0E•6 2.7E•6 5.9E•6 5.9E•9 2.4E•6 2.4E+6 Vanadium Vinyl acetate (I) (C DD\ 75014 NA 40 40 260 (X) 20,000 2,800 29,000 1.7E•5 4.2E•5 8.9E+8 34,000 12185103 NA 2.2 6.0 NA 58,000 NLV NLV NLV NLV ID 17,000 (DD) NA Xylencs (I) 1330207 NA 5,600 5,600 820 1.5E+5 (C) 1.SE+S (C) S.4E+7 6.SE+7 1.3E+8 1.3E+11 1.SE+S (C) 1.SE+S Zinc (B) 7440666 47,000 2.4E+6 5.0E• 6 (G) 1.0E+9 (D) NLV NLV NLV NLV ID 6.3E+8 NA Vinyl chloride W'lite phosphorus (R) March 25, 2011 4.9E+5 Page 14 of 14 �Attachment 1 TABLE 4. TOXICOLOGICAL AND CHEMICAL-PHYSICAL DATA PART 201 GENERIC CLEANUP CRITERIA AND SCREENING LEVELS; PART 213 TIER 1 RISK-BASED SCREENING LEVELS (RBSLs) DOCUMENT RELEASE DATE: MARCH 25, 2011 Dlt\ Developed pursuant to R 299.5752 of the Administrative Rules for Part 201 Environmental Remediation of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. Scientific notation is represented by E+ or E- a value, for example 200,000 is presented as 2.0E+5. Units are as indicated in each column heading. The dataset for each hazardous substance requires 22 columns. Review all 22 columns across 2 pages when evaluating data for a specific hazardous substance. Hazardous Substance Chemical Abstract Service Number Oral Reference Dose (RFD) Oral Slope Factor (SF) Inhalation Chronic Inhalation Unit Reference Risk Factor Concentration (IURF) (RfC) mg/Kg-day 1 (mg/Kg-dayf 3 ug/m (ug/m3)"1 Relative Occupation• I Short Tenn Source Exposure Contribution Level for Drinking ($TEL) Water (RSC) ugim3 Ingestion Absorption Efficiency (AEi) Dennal Absorption Efficiency (AEd) Relativ e Source Contribution for Soil (RSC) Soil Organic Log Octanol- Carbon-Water Water Partition Partition Coefficients Coefficient for Organic (Log Kow) Compounds (Koc) unitless unitless unitless unitless unitless l/Kg NA 0.2 1.0 0.1 1.0 3.92 7,140 NA NA 0.2 1.0 0.1 1.0 3.6 3.460 0.2 1.0 0.1 1.0 -0.367 0.613 Acenaphthene 83329 1.8E-1 NA 2.1E+2 NA Acenaphthylene 208968 7.1E-3 NA 3.5E+1 Acetaldehyde (I) 75070 1.3E-1 NA 9.0E+O 2.2E-6 4.5E+4 Acetate 71501 5.7E-1 NA NA NA NA 0.2 NA NA NA NA NA Acetic acid 64197 5.7E-1 NA 2.5E+2 NA 3.7E+4 0.2 1.0 0.1 1.0 -0.23 0.595 Acetone (I) 67641 1.0E-1 NA 5.9E+3 NA 1.7E+6 0.2 1.0 o.1 1.0 -0.240 0.581 Acetonitrile 75058 1.9E-2 NA 6.0E+1 NA 1.01 E+5 0.2 1.0 0.1 1.0 -0.337 0.648 37.4 Acetophenone 98862 2.1E-1 NA 4.9E+2 NA NA 0.2 1.0 0.1 1.0 1.6 Acrolein {I) 107028 1.6E-2 NA 2.0E-2 NA 6.9E+2 0.2 1.0 0.1 1.0 •0.01 1.1 8 Acrylamide 79061 2.0E-4 2.8E+0 6 1.3E-3 NA 0.2 1.0 0.1 1.0 -0.96 0.114 Acrylic acid 79107 5.3E-1 NA 1.0E+0 NA NA 0.2 1.0 0.1 1.0 0.35 2.21 Acrylonitrile (I) 107131 NA 3.3E-1 2.0E+0 6.SE-5 NA 0.2 1.0 0.1 1.0 0.255 1.78 1.0 3.52 734 1.0 1.1 12.1 0.275 Alachlor 15972608 1.0E-2 9.SE-2 NA NA NA 0.2 0.5 0.1 Aldicarb 116063 1.0E-3 NA NA NA NA 0.2 1.0 0.1 Aldicarb sulfone 1646884 1.1E·3 NA NA NA NA 0.2 1.0 0.1 1.0 -0.57 Aldicarb sulfoxide 1646873 1.3E-3 NA NA NA NA 0.2 1.0 0.1 1.0 -0.67 0.22 8.7E+O NA 4.9E·3 NA 0.2 0.5 0.1 1.0 6,5 2.45E+6 309002 2.5E-5 Aluminum (8) 7429905 3.3E-1 NA NA NA NA 0.2 0.5 0.01 1.0 NR NR Ammonia 7664417 NA NA 1.0E+2 NA 2.4E+4 0.2 1.0 0. 1 1.0 NA NA 994058 1.3E-1 NA G.2E+1 NA NA 0.2 1.0 0. 1 1.0 1.73 28.1 NA NA 0.2 1.0 0.1 1.0 0.978 9.15 Aldrin t-Amyl methyl ether (TAME) Aniline March 25, 2011 62533 NA 1.6E-2 1.0E+0 Page 1 of 14 �Attachment 1 TABLE 4. TOXICOLOGICAL AND CHEMICAL-PHYSICAL DATA PART 201 GENERIC CLEANUP CRITERIA AND SCREENING LEVELS; PART 213 TIER 1 RISK-BASED SCREENING LEVELS (RBSLs) DOCUMENT RELEASE DATE: MARCH 25, 2011 Developed pursuant to R 299.5752 of the Administrative Rules for Part 201 Environmental Remediation of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. Scientific notation is represented by E+ or E- a value, for example 200,000 is presented as 2.0E+5. Units are as indicated in each column heading. The dataset for each hazardous substance requires 22 columns. Review all 22 columns across 2 pages when evaluating data for a specific hazardous substance. Hazardous Substance Chemical Abstract Service Number Soil Koc for Ionizing Organic Compounds at pH=6.8 Soil-Water Distribution Coefficients for Inorganic Compounds at pH=6.8 (Kd) UKg Water Diffusivity (0..) (HLC) Air Diffusivity (D1orD.pr O•I') Lower Explosive Limit in Air (LEL) UKg 3 atm-m /mol 2 cm /s cm2/s unitless OF ug/L unitless g/mol NR NR 1.55E-4 0.0421 7.69E-6 NA NA 4,240 Solid 154.2 Henry's Law Constant at 2s c 0 Flash Point (FP) Water Solubility (S) Physical State at Standard Temperature & Pressure Molecular Weight (MW) Acenaphthene 83329 Acenaphthylene 208968 NR NR 1.48E-3 0.08 8.0E-6 NA NA 3,930 Solid 152.271 Acetaldehyde (I) 75070 NR NR 7.95E-5 0.08 8.0E-6 0.04 -36 1.0 E+9 Liquid 44.1 Acetate 71501 NA NA NA NA NA NA NA ID NA NA Acetic acid 64197 NR NR 1.00E-7 0.08 8.0E-6 0.04 103 6.0E+9 Liq uid 60.05 Acetone (I) 67641 NR NR 3.BBE-5 0.124 U4E-5 0.025 0.0 1.0E+9 Liquid 58.08 Acetonitrile 75058 NR NR 2.40E-5 0.13 1.7E-5 0.03 42 2.00E+8 Liquid 41.05 Acetophenone 98862 NR NR 1.,E-5 0.08 8.0E-6 NA NA 6.1E+6 Liquid 120.2 Acrolein (I) 107028 NR NR 9.40E-5 0.11 1.2E-5 0.028 -15 2.10E+8 Liquid 56.06 Acrylamide 79061 NR NR 3.22E-10 0.097 1.1E-4 NA 280 2.20E+9 Solid 71 .08 Acrylic acid 79107 NR NR 3.20E-7 0.08 8.0E-6 0.024 121 1.0E+9 Liquid 72.06 Acrylonitrile (I) 107131 NR NR 1.00E-4 0.12 1.3E-5 0.03 30 7.50E+7 Liquid 53.06 Alachlor 15972608 NR NR 8.32E-9 0.08 8.0E-6 NA NA 1.83E+5 Solid 269.77 Aldicarb 116063 NR NR 4.17E-9 0.08 8.0E-6 NA NA 6.00E+6 Solid 190.25 0.08 8.0E-6 NA NA 7.80E+6 Solid 222.27 206.27 Aldicarb sulfone 1646884 NR NR 3.37E-9 Aldicarb sulfoxide 1646873 NR NR 9.69E-10 0.08 8.0E-6 NA NA 2.80E+7 Solid Aldrin 309002 NR NR 1.70E-4 0.0132 4.86E-6 NA NA 180 Solid 364.9 Al uminum (B) 7429905 NR NA NR NR NR NA NA NA I norganic 26.982 Ammonia 7664417 NR NR 3.20E-4 0.08 8.0E-6 0.15 NA 5.30E+8 liquid 17.04 t-Amyl methyl ether (TAME) 994058 NR NR 2.68E-3 0.08 8.0E-6 NA NA 2.64E+6 Liquid 102.18 Aniline 62533 NR NR 2.30E-6 0.07 B.3E-6 0.013 158 3.60E+7 Liquid 93.13 March 25, 2011 Page 1 of 14 �Attachment 1 TABLE 4. TOXICOLOGICAL AND CHEMICAL-PHYSICAL DATA PART 201 GENERIC CLEANUP CRITERIA AND SCREENING LEVELS; PART 213 TIER 1 RISK-BASED SCREENING LEVELS (RBSLs) DOCUMENT RELEASE DATE: MARCH 25, 2011 Developed pursuant to R 299.5752 of the Administrative Rules for Part 201 Environmental Remediation of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. Scientific notation is represented by E+ or E- a value, for example 200,000 is presented as 2.0E+S. Units are as indicated in each column heading. The dataset for each hazardous substance requires 22 columns. Review all 22 columns across 2 pages when evaluating data for a specific hazardous substance. Hazardous Substa nee Anthracene Antimony Chemical Abstract Service Number Inhalation Chronic Inhalation Unit Risk Factor Reference Concentration (IURF) (RfC) Oral Reference Dose (RFD) Oral Slope Factor (SF) mg/Kg-day 1 (mg/Kg-dayj 3 ug/m 120127 1.DE+0 NA 1.0E+3 7440360 3.SE-4 NA 2.0E-1 Occupational Relative Short Term Source Contribution Exposure Level for Drinking (STEL) Water (RSC) Ingestion Absorption Efficiency (AEi) Dermal Absorption Efficiency (AEd) Relative Source Contribution for Soil (RSC) Soil Organic Log Octanol- Carbon-Water Water Partition Partition Coefficients Coefficient for Organic (Log Kow) Compounds (Koc) ug/m3 unitless unitless unitless unities& unitless UKg NA NA 0.2 1.0 0.1 1.0 4.55 29,700 NA NA 0.2 0.5 0.01 1.0 NR NR 0.2 0.5 0.03 1.0 NR NR (ug/m3)"1 Arsenic 7440382 2.7E-4 1.5E+O NA 4.3E-3 NA Asbestos (BB) 1332214 NA NA NA 4.6E-2 NA 1.0 1.D 0 1.D NR NR Atrazine 1912249 3.5E-2 7.4E·2 NA NA NA D.2 1.0 0.1 1.0 2.7 451 103333 NA 3.7E-2 NA 3.1E-5 NA 0.2 1.0 D.1 1.0 3.82 5,690 7.0E-2 NA 5.0E+D NA NA 1.0 0.5 0.01 1.0 NR NR Azobenzene Barium (B) 7440393 Benzene (I) 71432 NA 2.9E-2 3D B.3E·6 8.0E+3 0.2 1.0 0.1 1.0 2.13 58.2 Benzidine 92875 2.7E-3 2.3E+2 NA 6.7E-2 NA 0.2 1.0 0.1 1.0 1.66 42.9 Benzo(a)anthracene (Q) 56553 NA 4.1E-1 NA NA NA 0.2 0.5 0.13 1.0 5.7 4.01E+5 Benzo(b)fluoranthene (Q) 205992 NA 4.1E-1 NA NA NA 0.2 0.5 0.13 1.0 6.2 1.24E+6 0.2 0.5 0.13 1.0 6.2 1.24E+6 Benzo(k)fluoranthene (0) 207089 NA 4.1 E-2 NA NA NA Benzo(g,h,i)perylene 191242 7.1E-3 NA 1.2E+1 NA NA 0.2 0.5 0.13 1.0 6.7 3.86E+6 Benzo(a)pyrene (Q) 50328 NA 4.1E+0 NA 2.lE-3 NA 0.2 0.5 0.13 1.0 6.11 1.01 E+6 Benzoic acid 65850 4.4E+0 NA NA NA NA 0.2 1.0 0.1 1.0 1.86 0.6 5.0E+3 0.2 1.0 0.1 1.D 1.11 12.3 0.2 1.0 0.1 1.0 2.30 182 Benzyl alcohol 100516 1.4E+0 NA NA NA Benzyl chloride 100447 NA 1.1E-1 NA 5.0E-5 NA 7440417 1.SE-3 NA 2.0E-2 2.4E·3 1.0E+1 0.2 1,0 0 1.0 NR NR bis(2-Chloroetho,<y)ethane 112265 NA NA NA NA NA 0.2 1.0 0.1 1.0 1.28 18.1 bis(2-Chloroethyl)ether (I) 111444 NA 4.2E-1 NA 3.3E-4 5.BE+4 0.2 1.0 0.1 1.0 1.21 10.9 0.5 0.1 1.0 7.3 1.50E+7 Beryllium bis(2-Ethylhe,<yl)phthalate March 25, 2011 117817 1.9E-2 3.2E-3 NA 4.43E-6 1.0E+4 0.2 Page 2 of 14 �Attachment 1 TABLE 4. TOXICOLOGICAL AND CHEMICAL-PHYSICAL DATA PART 201 GENERIC CLEANUP CRITERIA AND SCREENING LEVELS; PART 213 TIER 1 RISK-BASED SCREENING LEVELS (RBSLs) DOCUMENT RELEASE DATE: MARCH 25, 2011 Developed pursuant to R 299.5752 of the Administrative Rules for Part 201 Environmental Remediation of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. Scientific notation is represented by E+ or E- a value, for example 200,000 is presented as 2.0E+S. Units are as indicated in each column heading. The dataset for each hazardous substance requires 22 columns. Review all 22 columns across 2 pages when evaluating data for a specific hazardous substance. Hazardous Substance Chemical Abstract Service Number Soil Koc for Ionizing Organic Compounds at pH=6.8 Soil-Water Distribution Coefficients for Inorganic Compounds at pH=6.8 (Kd) L/Kg L/Kg Physical State at Standard Temperature & Pressure Henry's Law Constant at 25°C (HLC) Air Diffusivity (l>jor Dpr Dal') Water Diffusivity (D,J Lower Explosive Limit in Air (LEL) 3 atm-m /mol cm2is crrt/s unitless OF ug/L unitless 9/mol 7.74E-6 NA NA 43.4 Solid 178.24 Flash Point (FP) Water Solubility (S) Molecular Weight (MW) 120127 NR NR 6.S0E-5 0.0324 Antimony 7440360 NR 45 NR NR NR NA NA NA Inorganic 121 .760 Arsenic 7440382 NR 29 NR NR NR NA NA NA Inorganic 74.922 Asbestos (SB} 1332214 NR NA NR NR NR NR NR NA Inorganic NA Atrazine 1912249 NR NR 2.63E-9 0.08 8.0E-6 NA NA 70,000 Solid 215.72 Azobenzene 103333 NR NR 1.35E-5 0.08 8.0E-6 NA NA 6,400 Solid 182.23 137 .327 Anthracene Barium (Bl 7440393 NR 41 NR NR NR NA NA NA Inorganic Benzene (I) 71432 NR NR 5.55E-3 0.088 9.BE-6 0.012 12 1.75E+6 Liquid 78.11 Benzidine 92875 NR NR 3.90E-11 0.08 1.5E-5 NA NA 5.20E+5 Solid 184.24 Benzo(a)anthracene (0) 56553 NR NR 3.35E-6 0.051 9.0E-6 NA NA 9.4 Solid 228.3 Benzo(b)fluoranthene (0) 205992 NR NR 1.11E-4 0.0226 5.56E-6 NA NA 1.5 Solid 252.32 Benzo(k)fluoranthene (Q) 207089 NR NR 8.29E•7 0.0226 5.56E·6 NA NA 0.8 Solid 252.32 Benzo(g,h,i)perylene 191242 NR NR 5.34E-8 0.08 8.0E-6 NA NA 0.26 Solid 276.34 Benzo(a)pyrene (Q} 50328 NR 1.13E-6 0.043 9.0E-6 NA NA 1.62 Solid 252.32 0.0536 7.97E-6 NA NA 3.S0E+6 Solid 122.1 NR Benzoic acid 65850 0.6 NR 1.54E-6 Benzyl alcohol 100516 NR NR 3.90E-7 0.08 8.0E-6 NA NA 4.4DE+7 Liquid 108.13 Benzyt chloride 100447 NR NR 4.00E-4 0.075 7.SE-6 0.011 153 4.90E+5 Liq uid 126.58 7440417 NR 790 NR NR NR NA NA NA Inorganic 9.012 0.08 8.0E-6 NA NA 1.89E+7 Liquid 187.07 Beryllium bis(2-Chloroethox:y)ethane 112265 NR NR 7.81E-7 bis(2-Chloroethyl)ether (I) 111444 NR NR 1.80E-5 0.0692 7.53E-6 0.027 131 1.72E+7 Liquid 143.01 bis(2-Ethy!hex:yl)phthalate 117817 NR NR 1.02E-7 0.0351 3.66E-6 NA 420 340 Liquid 390.57 March 25, 2011 Page 2 of 14 �Attachment 1 TABLE 4. TOXICOLOGICAL AND CHEMICAL-PHYSICAL DATA PART 201 GENERIC CLEANUP CRITERIA AND SCREENING LEVELS; PART 213 TIER 1 RISK-BASED SCREENING LEVELS (RBSLs) DOCUMENT RELEASE DATE: MARCH 25, 2011 Developed pursuant to R 299.5752 of the Administrative Rules for Part 201 Environmental Remediation of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. Scientific notation is represented by E+ or E- a value, for example 200,000 is presented as 2.0E+S. Units are as indicated in each column heading. The dataset for each hazardous substance requires 22 columns. Review all 22 columns across 2 pages when evaluating data for a specific hazardous substance. Hazardous Substance Chemical Abstract Service Number Oral Reference Dose (RFD) Oral Slope Factor (SF) Chronic Inhalation Inhalation Unit Reference Risk Factor Concentration (IURF) (RfC) mg/Kg-day 1 (mg/Kg-dayl 3 ug/m (ug/m3)·1 Occupational Relative Short Tenn Source Exposure Contribution for Drinking Level (STEL) Water (RSC) 3 Ingestion Absorption Efficiency (AEi) Dennal Absorption Efficiency (AEd) Relative Source Contribution for Soil (RSC) Soil Organic Log Octanol• Carbon-Water Water Partition Partition Coefficients Coefficient for Organic (Log Kow) Compounds (Koc) unitless unitless unitless unitless unitless Boron (B) 7440428 3.2E-1 NA NA NA NA 0.2 0.5 0.01 1.0 NR NR Bromate 15541454 4.0E-3 7.0E-1 NA NA NA 0.2 0.5 0.01 1.0 0.63 NR Bromobenzene (I) 108861 2.4E-3 NA 8.0E+O NA NA 0.2 1 .0 0.1 1.0 2.99 870 Bromodichloromethane 75274 1.SE-2 5.0E-2 NA 3.7E- 5 NA 0.2 1.0 0.1 1.0 2.1 55.1 87.0 ug/m UKg Bromoform 75252 1.SE-2 6.4E-3 NA 1.lE-6 NA 0.2 1.0 0.1 1.0 2.35 Bromomethane 74839 1.4E-3 NA 5.0E+O NA NA 0.2 1.0 0.1 1.0 1.18 14.5 n-Butanol (I) 71363 1.3E-1 NA 3.5E+2 NA 1.52E+5 0.2 1.0 0.1 1.0 0.851 5.65 2-Butanone (MEK) (I) 78933 1.8E+O NA 1.0E+3 NA 6.85E+5 0.2 1.0 0.1 1.0 0.279 1.99 n-Butyl acetate 123864 7.6E-2 NA 7.1E+3 NA 9.SE+S 0.2 1.0 0.1 1.0 1.78 30.8 I-Butyl alcohol 75650 5.4E-1 NA 1.89E+3 NA NA 0.2 1.0 0.1 1.0 0.35 2.27 Butyl benzyl phthalate 85687 1.6E-1 NA 7.0E+2 NA NA 0.2 1.0 0.1 1.0 4.84 57,300 n-Butylbenzene 104518 1.1E-2 NA 30 NA NA 0.2 1.0 0. 1 1.0 4.38 20,200 sec-Butylbenzene 13598B 1.1E-2 NA 6E+O NA NA 0.2 1.0 0. 1 1.0 4 .57 31,100 t•Butylbenzene (I) 98066 1.1E-2 NA 10 NA NA 0.2 1.0 0.1 1.0 4.11 11,000 Cadmium (B) 7440439 1.0E-3 NA NA 1.BE-3 NA 0.2 0.5 0.001 1.0 NR NR Camphene {I) 79925 NA NA 80 NA NA 0.2 1.0 0.1 1.0 3.53 2,950 Caprolactam 105602 8.0E-1 NA 1.0E+1 NA 4.6E+4 0.2 1.0 0.1 1.0 -0.19 0.65 Carbaryl 63252 9.6E-2 NA NA NA NA 0.2 1.0 0.1 1.0 2.4 229 Carbazole 86748 NA 1.0E-2 NA 5.0E·S NA 0.2 1.0 0.1 1.0 3.59 3,380 Carbofuran 1563662 S.OE-3 NA NA NA NA 0.2 1.0 0.1 1.0 1.6 37.4 75150 1.1 E-1 NA 7.0E+2 NA NA 0.2 1.0 0.1 1.0 2 45.9 Carbon disulfide (I.R) March 25, 2011 Page 3 of 14 �Attachment 1 TABLE 4. TOXICOLOGICAL AND CHEMICAL-PHYSICAL DATA PART 201 GENERIC CLEANUP CRITERIA AND SCREENING LEVELS; PART 213 TIER 1 RISK-BASED SCREENING LEVELS (RBSLs) DOCUMENT RELEASE DATE: MARCH 25, 2011 Developed pursuant to R 299.57S2 of the Administrative Rules for Part 201 Environmental Remediation of the Natural Resources and Environmental Protection Act, 1994 PA 4S1, as amended. Scientific notation is represented by E+ or E- a value, for example 200,000 is presented as 2.0E+S. Units are as indicated in each column heading. The dataset for each hazardous substance requires 22 columns. Review all 22 columns across 2 pages when evaluating data for a specific hazardous substance. Hazardous Substance Chemical Abstract Service Number Soil Koc for Ionizing Organic Compounds atpH:6.8 Soil-Water Distribution Coefficients for Inorganic Compounds at pH=6.8 (Kd) L/Kg Water Diffusivity (D..J (HLC) Air Diffusivity (OjorDa>r Dal') Lower Explosive Limit in Air (LEL) L/Kg 3 atm-m /mol crrt/s crrt/s unitless NR NR NA NA Henry's Law Constant at 0 2s c Boron (B) 7440428 NR NA NR Bromate Flash Point (FP) OF Water Solubility (S) Physical State at Standard Temperature & Pressure Molecular Weight (MW) ug/L unitless g/mol NA Inorganic 10.811 15541454 NR NA 1.00E+0 NR NR NA NA 38,000 Solid 79.9 Bromobenzene (I) 108861 NR NR 4.74E-4 0.08 8.0E-6 NA NA 4 .13E+5 Liquid 157.015 Bromodichloromethane 75274 NR NR 1.60E-3 0.0298 1.06E-5 NA NA 6.74E+6 Liquid 163.8 Bromoform 75252 NR NR 5.35E-4 0.0149 1.03E-5 NA NA 3.10E+6 Liquid 252.8 Bromomethane 74839 NR NR 1.42E-2 0.08 8.0E-6 0.1 NA 1.45E+7 Liquid 94.94 n-Butanol (J) 71363 NR NR 8.81E-6 0.08 9.6E-6 0.014 84 7.40E+7 Liquid 74.14 2-Butanone (MEK) (!) 78933 NR NR 3.60E-5 0.081 9.SE-6 NA 16 2.40E+8 Liquid 72.1 n-Buty! acetate 123864 NR NR 3.20E-4 0.08 8.DE-5 0.017 72 6.70E+6 Liquid 116.16 t-Butyl alcohol 75650 NR NR 1.17E-5 0.08 8.0E-6 0.024 52 1.0E+9 Liquid 74.12 Butyl benzy! phlhalate 85687 NR NR 1.26E-6 0.0174 4.83E-6 NA NA 2,690 Liquid 312.37 n-Butylbenzene 104518 NR NR NA 0.08 8.0E-6 NA NA NA Liq uid 134.22 sec-Butylbenzene 135988 NR NR NA 0.08 8.0E-6 NA NA NA Liquid 134.22 t-Butylbenzene (I) 98066 NR NR NA 0.08 8.0E-6 NA NA NA Liquid 134.22 NR NR NA NA NA Inorganic 112.411 136.26 Cadmium (B) 7440439 NR 75 NR Camphene (I) 79925 NR NR 2.05E+0 0.08 8.0E-6 NA NA 33,400 Solid Caprolactam 105602 NR NR 2.53E-8 0.08 8.0E-6 0.014 282 5.25E+9 Solid 11 3.2 Carbary! 63252 NR NR 6.S0E-4 0.08 8.0E-6 NA NA 1.26E+5 Solid 201.24 Carbazole 86748 NR NR 1.53E-8 0.039 7.03E-6 NA NA 7.480 Solid 167.21 NA 7.00E+5 Solid 221.3 -22 1.19E+6 Liquid 76.14 Carbofuran Carbon disulfide (l,R) March 25, 2011 1553652 NR NR 3.90E-10 0.08 8.0E-6 NA 75150 NR NR 3.03E-2 0.104 1.0E-5 0.013 Page 3 of 14 �Attachment 1 TABLE 4. TOXICOLOGICAL AND CHEMICAL-PHYSICAL DATA PART 201 GENERIC CLEANUP CRITERIA AND SCREENING LEVELS; PART 213 TIER 1 RISK-BASED SCREENING LEVELS (RBSLs) DOCUMENT RELEASE DATE: MARCH 25, 2011 Developed pursuant to R 299.5752 of the Administrative Rules for Part 201 Environmental Remediation of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. Scientific notation is represented by E+ or E- a value, for example 200,000 Is presented as 2.0E+5. Units are as indicated in each column heading. The dataset for each hazardous substance requires 22 columns. Review all 22 columns across 2 pages when evaluating data for a specific hazardous substance. Hazardous Substance Chemical Abstract Service Number Oral Reference Dose (RFD) Oral Slope Factor (SF) Chronic Inhalation Unit Inhalation Reference Risk Factor Concentration (IURF) (RfC) mg/Kg-day (mg/Kg-dayJ1 ugim3 (ug/m3r1 Occupational Relative Short Tenn Source Exposure Contribution Level for Drinking (STEL) Water (RSC) ugim 3 Ingestion Absorption Efficiency (AEi) Oennal Absorption Efficiency (AEd) Relative Source Contribution for Soil (RSC) Soil Organic Log Octanol- Carbon-Water Water Partition Partition Coefficients Coefficient for Organic (Log Kow) Compounds (Koc) unitless unitless unitless unitless unitless Carbon tetrachloride 56235 7.1E-4 5.5E-2 100 2.36E-5 6.3E+4 0.2 1.0 0.1 1.0 2.73 174 Chlordane (J) 57749 1.5E-3 3.5E-1 7.0E-1 l.OE-4 NA 0.2 0.5 0.04 1.0 6.32 1.21E+5 16887006 NA NA NA 0.5 0.01 1.0 NR NR 7.0E+1 NA NA 0.2 1.9E-2 NA NA NA 108907 0.2 1.0 0.1 1.0 2.86 220 Chloride Chloroben:wne (1) UKg p-Chlorobenzene sulfonic acid 98668 1.0E+O NA NA NA NA 0.2 1.0 0.1 1.0 -0.52 4.64E-1 1-Chloro-1,1-difluoroethane 75683 2.1E+O NA 5.0E+4 NA 0.2 1.0 0.1 1.0 1.81 32.5 Chloroethane 75003 1.8E+1 2.0E-3 1.0E+4 NA NA NA 0.2 1.0 0.1 1.0 1.4 23.8 2-Chloroethyl vinyl ether 110758 NA NA NA 0.2 1.0 0.1 1.0 1.07 8.43 67663 1.3E-2 4.4E-3 NA NA NA Chloroform 2.4E·6 NA 0.2 1.0 0.1 1.0 1.92 39.7 Chloromethane (I) 74873 NA 3.3E-3 9.0E+1 6.39E•7 2.07E+5 0.2 1.0 0.1 1.0 0.91 6.30 4-Chloro-~methylphenol 59507 2.0E-2 NA NA NA 0.2 1.0 0.1 1.0 3.1 1,120 beta-Chloronaphthalene 91587 2.5E-1 NA NA NA NA 0.2 1.0 0.1 1.0 4.1 10.700 2-Chlorophenol 95578 6.2E-3 1.8E+1 1.0 0.1 1.0 2.15 388 95498 2.0E-2 7.0E+1 NA NA 0.2 o-Chlorotoluene (I) NA NA NA NA NA 0.2 1.0 0.1 1.0 3.42 612 Chlorpyrifos 2921882 3.0E-2 NA 2.0E+0 0.5 0.1 1.0 5.3 18,900 16065831 1.5E+0 NA 5.0E+0 NA NA 0.2 Chromium (Ill) (B,H) NA NA 0.7 0.5 0.01 1.0 0.5 0.01 1.0 NR NR NR 0.7 NR 1,0 5.7 4.01E+S Chromium (VI) 18540299 4.BE-3 NA 8.0E-3 1,2E-2 NA Chrysene (Q) 218019 NA 4.1E-3 NA NA NA 0.2 0.5 0.13 Cobalt 7440484 5.0E-3 NA 2.0E-1 NA 0.5 0.01 1.0 7440508 3.BE-2 NA 2.0E+O NA NA NA 0.2 Copper (B) 1.0 0.5 0.01 1.0 NR NR NR NR Cyanazine 21725462 3.0E-3 3.7E-1 NA NA NA 0.2 1.0 0.1 1.0 2.2 146 March 25, 2011 Page 4 of 14 �Attachment 1 TABLE 4. TOXICOLOGICAL AND CHEMICAL-PHYSICAL DATA PART 201 GENERIC CLEANUP CRITERIA AND SCREENING LEVELS; PART 213 TIER 1 RISK-BASED SCREENING LEVELS (RBSLs) DOCUMENT RELEASE DATE: MARCH 25, 2011 Developed pursuant to R 299.5752 of the Administrative Rules for Part 201 Environmental Remediation of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. Scientific notation is represented by E+ or E- a value, for example 200,000 is presented as 2.0E+5. Units are as indicated in each column heading. The dataset for each hazardous substance requires 22 columns. Review all 22 columns across 2 pages when evaluating data for a specific hazardous substance. Hazardous Substance Carbon 1etrachloride Chlordane (J) Chloride Chlorobenzene (I) Soil Koc for Ionizing Organic Compounds at pH=6.8 Soil-Water Distribution Coefficients for Inorganic Compounds at pH=6.8 (Kd) L/Kg Henry's Law Constant at 25°C (HLC) Air Diffusivity (DJor D_pr oai') Water Diffusivity (0..J Lower Explosive Limit in Air (LEL) Flash Point L/Kg atm-m3/mol crrf'/s cm2/s unitless OF ug/L unitless g/mol 56235 NR NR 3.04E-2 0.078 8.BE-6 NA NA 7 .93E+5 Liquid 153.92 Chemical Abstract Service Number (FP) Water Solubility (S) Physical State at Standard Temperature & Pressure Molecular Weight (MW) 57749 NR NR 4.86E-5 0.0118 4.37E-6 NA NA 56 Solid 409.8 16887006 NR NA NR NR NR NA NA NA Inorganic 35.453 108907 NR NR 3.70E-3 0.073 8.7E-6 0.013 82 4 .72E+5 Liquid 112.56 p-Chlorobenzene su!fonic acid 98668 NR NR NA NA NA NA 226 NA Solid 192.62 100.5 1-Chloro-1.1-difluoroethane 75683 NR NR 6.16E-2 0.08 8.0E-6 0.06 NA 3.9E+06 Gas Chloroethane 75003 NR NR 8.80E-3 0.08 8.0E-6 0.038 -58 5.74E+6 Liquid 64.52 2-Chloroethyl vinyl ether 110758 NR NR 6.25E-4 0.08 8.0E-6 NA NA 1.50E+7 Liquid 106.55 Chloroform 67663 NR NR 3.67E-3 0.104 1.0E-5 NA NA 7.92E+6 Liquid 119.38 Chloromethane (I) 74873 NR NR 4.52E-2 0.13 6.5E-6 0.081 -60.8 6.34E+6 Liquid 50.49 4-Chloro-3-methylphenol 59507 NR NR 4.00E-7 0.08 8.0E-6 NA NA 3.90E+6 Solid 142.6 beta-Chloronaphthalene 91587 NR NR 3.10E-4 0.08 8.0E-6 NA NA 6,740 Solid 162.62 2-Chlorophenol 95578 388 NR 3.91E-4 0.0501 9.46E-6 NA NA 2.20E+7 Liquid 128.56 o-Chlorotoluene (I) 95498 NR NR 3.57E-3 0.08 8.0E-6 NA 96 3.73E+5 Liquid 126.58 NA NA 1,120 Solid 350.59 NA Inorganic 51.996 Chlorpyrifos 2921882 NR NR 7.80E+0 0.08 8.0E-6 Chromium (Ill) (8,H) 16065831 NR 1.8E+6 NR NR NR NA NA Chromium (VI) 18540299 NR 19 NR NR NR NA NA NA Inorganic 51 .996 Chrysene (Q) 218019 NR NR 9.46E-5 0.0248 6.21E-6 NA NA 1.6 Solid 228.3 Cobalt 7440484 NR NA NR NR NR NA NA NA Inorganic 58.933 Copper (B) 7440508 NR 360 NR NR NR NA NA NA Inorganic 63.546 Cyanazine 21725462 NR NR 1.00E-10 0.08 8.0E- 6 NA NA 1.70E+5 Solid 241 March 25, 2011 Page 4 of 14 �Attachment 1 TABLE 4. TOXICOLOGICAL AND CHEMICAL-PHYSICAL DATA PART 201 GENERIC CLEANUP CRITERIA AND SCREENING LEVELS; PART 213 TIER 1 RISK-BASED SCREENING LEVELS (RBSLs) DOCUMENT RELEASE DATE: MARCH 25, 2011 Developed pursuant to R 299.5752 of the Administrative Rules for Part 201 Environmental Remediation of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. Scientific notation is represented by E+ or E- a value, for example 200,000 is presented as 2.0E+5. Units are as indicated in each column heading. The dataset for each hazardous substance requires 22 columns. Review all 22 columns across 2 pages when evaluating data for a specific hazardous substance. Hazardous Substance Chemical Abstract Service Number Oral Reference Dose (RFD) Oral Slope Factor (SF) mg/Kg-day (mg/Kg-dayJ Cyanide (P.R) 57125 5.4E-3 Cyclohexanone 108941 4.5E+O NA NA Dacthal 1861321 1.0E-2 NA Chronic Inhalation Inhalation Unit Risk Factor Reference Concentration (IURF) (RfC) 1 ug/m3 5.0E+1 1.0E+3 Occupational Relative Short Term Source Exposure Contribution for Orin king Level ($TEL) Water (RSC) Ingestion Absorption Efficiency (AEI) Dermal Absorption Efficiency (AEd) Relative Source Contribution for Soil (RSC) Soll Organic Log Octanol• Carbon-Water Water Partition Partition Coefficients Coefficient for Organic (Log Kow) Compounds (Koc) ug/m3 unitless unitless unitless unitless u nitless NA NA NA NA 0.2 1.0 0 1.0 NA NA 0.2 1.0 0.1 1.0 0.81 6.26 NA 0.2 1.0 0.1 1.0 4.4 21,200 (u9/m3).1 UKg Dalapon 75990 8.5E-2 NA NA NA NA NA NA 0.2 1.0 0.1 1.0 0.77 5.72 4-4'-DDD 72548 3.0E-3 9.4E-2 NA 7.0E-5 NA 0.2 0.5 0.1 1 .0 6.1 81,100 4-4'-DDE 72559 7.0E-4 2.0E-1 NA 9.7E-5 0.5 0.1 1.0 6.76 2.70E+5 50293 2.0E-1 NA 9.7E-5 NA NA 0.2 5.0E-4 0.2 0.5 0.03 1.0 6.53 1.78E+5 1163195 1.0E-2 NA 3.5E•1 4.0E-7 NA 0.2 0.5 0.1 1.0 5.24 1.42E+5 Di-n-butyl phthalate 84742 1.2E·1 NA 5.0E-t-1 NA NA 0.2 1.0 0.1 1.0 4.61 34,000 Di(2-ethylhexyl) adipate 103231 1.7E•O 5.9E-4 NA 3.4E·7 0.2 0.5 0.1 1.0 6.11 1,01E+6 Di-n-octyl phthalate 117840 1.8E-2 NA 4.7E+2 NA NA NA 0.2 0.5 0.1 1.0 7 .51 2.41E+7 NA NA 0.2 1.0 0.1 1.0 -0.34 0.464 0.2 1.0 0.1 1.0 3.4 2.200 0.2 0.5 0.13 1.0 6.69 3.77E+6 4-4'-DDT Decabromodiphenyl ether Diacetone alcohol (I) 123422 NA NA 2.4E+3 NA Diazinon 333415 53703 1.8E-4 NA NA 4.1E+O NA NA NA NA Dibenzofuran 132649 NA NA 1E-1 NA NA NA 0.2 1.0 0.1 1.0 4.2 13,500 Dibromochloromethane 124481 2.1 E-2 4.9E-2 NA 2.45E·5 NA 0.2 1.0 0.1 1.0 2.17 62.6 0.2 1.0 0.1 1,0 2.68 431 Dibenzo(a,h)anthracene (Q) Dibromochloropropane Dibromomethane Dicamba 1,2-Dichlorobenzene 1,3-Dichlorobenzene March 25, 2011 96128 NA 1.2E+O 2.0E-1 NA NA 74953 1.1 E-2 NA NA NA NA 0.2 1.0 0.1 1.0 1.62 39.2 1918009 3.0E-2 NA NA NA NA 0.2 0.5 0.1 1.0 2.4 95.3 95501 8.SE-2 NA 1.5E+3 3.01E+5 0.2 1.0 0.1 1.0 3.43 623 9.0E-4 NA 3E+O NA NA NA 0.2 1.0 0.1 1.0 3,5 708 541731 Page 5 of 14 �Attachment 1 TABLE 4. TOXICOLOGICAL AND CHEMICAL-PHYSICAL DATA PART 201 GENERIC CLEANUP CRITERIA AND SCREENING LEVELS; PART 213 TIER 1 RISK-BASED SCREENING LEVELS (RBSLs) DOCUMENT RELEASE DATE: MARCH 25, 2011 Developed pursuant to R 299.5752 of the Administrative Rules for Part 201 Environmental Remediation of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. Scientific notation is represented by E+ or E- a value, for example 200,000 is presented as 2.0E+S. Units are as indicated in each column heading. The dataset for each hazardous substance requires 22 columns. Review all 22 columns across 2 pages when evaluating data for a specific hazardous substance. Hazardous Substance Cyanide (P,R) Chemical Abstract Service Number Soil Koc for Ionizing Organic Compounds at pH=6.8 Soil-Water Distribution Coefficients for Inorganic Compounds at pH=6.8 (Kd) UKg Henry's Law Constant at 2s0 c Air Diffusivity (Dior D,Pr Water Diffusivity (0,,) Lower Explosive Limit in Air (LEL} Flash Point (FP) Water Solubility ($) Physical State at Standard Temperature & Pressure Molecular Weight (MW) (HLC) o•''l UKg 3 atm-m /mol 2 cm /s crrl-is unitless OF ug/L unitless g/mol 57125 NR NR NR 0.08 B.OE-6 NA NA NA Inorganic 26.02 98.14 Cyclohexanone 108941 NR NR 7.80E+0 0.08 8.0E-6 NA 146 2.30E+7 Liquid Dacthal 1861321 NR NR 2.18E-6 0.08 B.0E-6 NA NA 500 Solid 331 Dalapon 75990 NR NR 6.43E-8 0.08 8.0E-6 NA NA 5.02E+8 Liquid 142.97 4-4'-ODD 72548 NR NR 4.00E-6 0.0169 4.76E-6 NA NA 90 Solid 320.05 4-4'-DDE 72559 NR NR 2.10E-5 0.0144 5.87E-6 NA NA 120 Solid 518.03 4-4'-DDT 50293 NR NR 8.10E-6 0.0137 4.95E-6 NA 162 25 Solid 354.49 1163195 NR NR 4.02E-5 0.08 8.0E-6 NA NA 30 Solid 959.22 84742 NR NR 9.38E-10 0.0438 7.B6E-6 NA 315 11,200 Liquid 278.34 Di(2-ethylhexyl) adipate 103231 NR NR 4.34E-7 0.08 B.0E-6 NA NA 471 Liquid 370 Oecabromooiphenyl ether Di-n-butyl phthalate Di-n-octyl phthalate 117840 NR NR 7.66E-7 0.0151 3.58E-6 NA NA 3,000 Liquid 390.62 Diacetone alcohol (I) 123422 NR NR 2.61E-7 0.08 8.0E-6 0.018 125 1.0E+9 Liquid 116.2 Diazinon 333415 NR NR 1.13E-7 0.08 8.0E-6 NA 180 68,800 Liquid 304.3 0.0202 5. 18E-6 NA NA 2.49 Solid 278.36 NA NA 10,000 Solid 168.21 208.29 Dibenzo(a,h)anthracene (0) 53703 NR NR 1.47E-8 Dibenzofuran 132649 NR NR 1.30E·S 0.08 B.OE-6 Dibromochloromethane 124481 NR NR 7.B3E-4 0.0229 1.0SE-5 NA NA 2.60E+6 Liquid Dibromochloropropane 96128 NR NR 1.90E-4 0.08 8.0E-6 NA 170 1,230 Liquid 236.34 Dibromomethane 74953 NR NR 9.00E-4 0.08 8.6E-6 NA NA 1.10E+7 Liquid 173.85 1918009 NR NR 7.90E-9 0.08 8.0E-6 NA NA 4.5E+6 Solid 221.04 Dicamba 1,2-Dichlorobenzene 95501 NR NR 1.90E-3 0.069 7.9E-6 0.022 151 1.56E+5 Liquid 147.01 1,3-Dichlorobenzene 541731 NR NR 1.BOE-3 0.08 8.0E-6 NA NA 1.11E+5 Liquid 147.01 March 25, 2011 Page 5 of 14 �Attachment 1 TABLE 4. TOXICOLOGICAL AND CHEMICAL-PHYSICAL DATA PART 201 GENERIC CLEANUP CRITERIA AND SCREENING LEVELS; PART 213 TIER 1 RISK-BASED SCREENING LEVELS (RBSLs) DOCUMENT RELEASE DATE: MARCH 25, 2011 Developed pursuant to R 299.5752 of the Administrative Rules for Part 201 Environmental Remediation of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. Scientific notation is represented by E+ or E- a value, for example 200,000 is presented as 2.0E+S. Units are as indicated in each column heading. The dataset for each hazardous substance requires 22 columns. Review all 22 columns across 2 pages when evaluating data for a specific hazardous substance. Chronic Inhalation Inhalation Unit Risk Factor Reference Concentration (IURF) (RfC) Occupational Relative Short Term Source Exposure Contribution Level for Drinking (STEL) Water (RSC) Ingestion Absorption Efficiency (AEi) Dermal Absorption Efficiency (AEd) unitless unitless unitless unitless unitless L/Kg 0.2 1.0 0.1 1.0 3.42 612 0.2 1.0 0.1 1.0 3.51 721 0.1 1.0 2.15 60.4 0.1 1.0 1.79 31.3 0.1 1,0 1.47 17.5 1.0 0.1 1.0 2.13 58.2 1.0 0.1 1.0 1.86 35.6 1.0 0.1 1.0 2.07 52.2 517 Oral Slope Factor (SF) mg/Kg-day 1 (mg/Kg-dayf uglm3 106467 NA 1.3E-2 8E·>2 6.9E~ NA 91941 NA 8.0E-1 NA 4.SE-4 NA Dichlorodifluoromethane 75718 2.3E-1 NA 4.95E-+4 NA NA 0.2 1.0 1, 1-Dich!oroethane 75343 1.2E-1 NA 5.0E-+2 NA NA 0.2 1.0 1,2-Dich!oroethane (I) 107062 NA 5.BE-2 NA 2.6E-5 NA 0.2 1,0 1.1-Dichloroethylene (I) 75354 9.0E-4 NA 2E·"2 5.DE·S 7.9E+4 0.2 cis-1 .2-Dichloroethylene 156592 1.1E-2 NA 3.4E+1 NA NA 0.2 NA NA 0.2 1,4-Dichlorobenzene 3,3'-Dichlorobenzidine trans-1,2-Dichloroethy!ene 156605 1.7E-2 NA 7.0E-+1 (ug/m3)-1 ugim3 Soil Organic Log Octanol• Carbon-Water Water Partition Partition Coeffici ents Coefficient for Organic (Log Kow) Compounds (Koc) Relative Source Contribution for Soil (RSC) Oral Reference Dose (RFD) Hazardous Substance Chemical Abstract Service Number 2,6-Dichloro-4-nitroaniline 99309 3.0E-1 NA NA NA NA 0.2 1.0 0.1 1.0 2.76 2,4-Dichloropheno! 120832 1.0E-2 NA 7.7E+1 NA NA 0.2 1.0 0.1 1.0 3.08 147 2,4-Dichlorophenoxyacetic acid 94757 1.0E-2 NA 1.0E+2 NA NA 0.2 1.0 0.05 1.0 2.7 451 1.2-Dichloropropane (I) 78875 4.4E-1 3.7E-2 4.0E-+0 NA 5.0BE-+5 0.2 1.0 0.1 1.0 1.97 43.5 1,3-Dichloropropene 542756 3.4E-2 1.0E- 1 2.0E+1 4.0E~ NA 0.2 1.0 0.1 1.0 2.0 45.9 D ichlorovos 62737 4.0E-4 5.2E-1 5.0E- 1 NA NA 0.2 1.0 0.1 1.0 1.4 15.4 Dicyclohexyl phthalate 84617 NA NA NA NA NA 0.2 0.5 0.1 1.0 6.2 1.24E+6 Dieldrin 60571 7.6E-5 8.0E-+O NA 4.6E·3 NA 0.2 0.5 0.1 1.0 5.37 21,400 60297 5.0E-1 NA 1.2E-+4 NA 1.52E-+6 0.2 1.0 0.1 1.0 0.83 6.55 Diethyl phtha!ate 84662 7.5E·1 NA 5.0E-+1 NA NA 0.2 1.0 0.1 1.0 2.5 287 Diethylene glycol monobutyl ether Oiisopropyl ether 112345 1.2E-2 NA 2.0E-+1 NA NA 0.2 1.0 0.1 1.0 0.32 2.06 108203 4.1E-3 NA 3.58E+2 NA NA 0.2 1.0 0.1 1,0 1.67 25.2 Diisopropylamine (I) 108189 7.7E-4 NA 2E+2 NA NA 0.2 1.0 0.1 1.0 1.6 37.4 Diethyl ether March 25, 2011 Page 6 of 14 �Attachment 1 TABLE 4. TOXICOLOGICAL AND CHEMICAL-PHYSICAL DATA PART 201 GENERIC CLEANUP CRITERIA AND SCREENING LEVELS; PART 213 TIER 1 RISK-BASED SCREENING LEVELS (RBSLs) DOCUMENT RELEASE DATE: MARCH 25, 2011 Developed pursuant to R 299.5752 of the Administrative Rules for Part 201 Environmental Remediation of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. Scientific notation is represented by E+ or E- a value, for example 200,000 is presented as 2.0E+S. Units are as indicated in each column heading. The dataset for each hazardous substance requires 22 columns. Review all 22 columns across 2 pages when evaluating data for a specific hazardous substance. Soil Koc for Ionizing Organic Compounds at pH=6.8 Soil-Water Distribution Coefficients for Inorganic Compounds at pH=6.8 (Kd) UKg UKg 105467 NR 3,3'-Dichlorobenzidine 91941 Dichlorodifluoromethane 75718 NR NR Hazardous Substance 1,4-Dichlorobenzene Chemical Abstract Service Number Air Diffusivity (D1orDpr Water Diffusivity (DJ Lower Explosive Limit in Air (LEL) atm-m3/mol crrr'/s crrr'/s unitless OF ug/L unitless g/mol NR NR 2.43E-3 0.069 7.9E·6 0.025 150 73.800 Solid 147 4.00E-9 0.0194 6.74E-6 NA NA 3,110 Solid 253.1 NR 2.60E+0 0.08 8.0E-6 NA NA 3.00E+5 Liquid 120.9 1 Henry's Law Constant at 2s c 0 (HLC) o•"'l Flash Point (FP) Water Solubility (S) Physical State at Standard Temperature & Pressure Molecular Weight (MW) 1, 1-Dichloroethane 75343 NR NR 5.62E-3 0.0742 1.0SE-5 0.054 2.0 5.06E+6 Liquid 98.96 1.2-Dichloroethane (I) 107062 NR NR 9.79E-4 0.104 9.9E-6 0.062 56 B.52E+6 Liquid 98.97 1,1-Dichloroethylene (l) 75354 NR NR 2.61E-2 0.09 1.04E-5 0.065 -2 2.25E+6 Liquid 96.94 96.94 cis-1 .2-Dichloroethylene 156592 NR NR 4.0SE-3 0.0736 1.13E-5 0.056 36 3.50E+6 Liquid trans-1.2-Dichloroethylene 156605 NR NR 9.38E-3 0.0707 1.19E-5 0.056 36 6.30E+6 Liquid 96.94 2,6-Dichloro-4-nitroaniline 99309 NR 4.67E-8 0.08 8.0E-6 207.02 147 3.16E-6 0.0346 8.TTE-6 NA NA Solid 120832 NA NA 7,000 2.4-Oichlorophenol NR NR 4.50E+6 Liquid 163 Solid 221.04 2,4-Dichlorophenoxyacetic acid 94757 0.059 6.SE-6 NA NA 78875 NR NR 4.S0E-6 1,2-Dichloropropane (I) NR NR 6.80E+S 2.B0E-3 0,0782 8.73E-6 0.034 60 2.80E+6 Liquid 112.99 1,3-Dichloropropene 542756 NR NR 1.77E-2 0.0626 1.0E-5 0.053 77 2.80E+6 Liq uid 110.97 Dichlorovos NR NR 9.58E-7 0.08 8.0E-6 NA 175 1.60E+7 Liquid 220.98 7.61E-5 0.08 8.0E-6 NA NA 4,000 Solid 330.43 62737 NR Dicyclohexyl phtha!ate 84617 NR Dieldrin 60571 NR 1.51E-5 0.0125 4.74E•6 195 Solid 380.9 Diethyl ether 60297 NR NR NA NA NR 8.70E-4 0.074 9.3E-6 0.019 -49 6.10E+7 Liquid 74.12 Diethyl phthalate 84662 NR NR 4.S0E-7 0.0256 6.35E-6 NA 322 1.08E+6 Liquid 222.23 Diethylene glycol monobutyl ether Diisopropyl ether 112345 NR NR 1.52E-9 0.08 8.0E-6 NA NA 1.0E+9 Liquid 162.23 108203 NR NR 1.3E-3 0.08 8.0E-6 0.014 -18 8,041 Liquid 102.18 Diisopropylamine (I) 108189 NR NR 9.60E-5 0.08 8.0E-6 0.011 20 3.69E+7 Liquid 101.22 March 25, 2011 Page 6 of 14 �Attachment 1 TABLE 4. TOXICOLOGICAL AND CHEMICAL-PHYSICAL DATA PART 201 GENERIC CLEANUP CRITERIA AND SCREENING LEVELS; PART 213 TIER 1 RISK-BASED SCREENING LEVELS (RBSLs) DOCUMENT RELEASE DATE: MARCH 25, 2011 Developed pursuant to R 299.5752 of the Administrative Rules for Part 201 Environmental Remediation of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. Scientific notation is represented by E+ or E- a value, for example 200,000 is presented as 2.0E+5. Units are as indicated in each column heading. The dataset for each hazardous substance requires 22 columns. Review all 22 columns across 2 pages when evaluating data for a specific hazardous substance. Hazardous Substance Chemical Abstract Service Number Oral Reference Dose (RFD) Oral Slope Factor (SF) mg/Kg-day (mg/Kg-dayj1 Chronic Inhalation Inhalation Unit Reference Risk Factor Concentration (IURF) (RfC) ugim3 (ug/m3).1 Occupational Relative Short Term Source Exposure Contribution Level for Drinking (STEL) Water (RSC) 3 ug/m Ingestion Absorption Efficiency (AEi) Dermal Absorption Efficiency (AEd) Relative Source Contribution for Soil (RSC) Soil Organic Log Octanol- Carbon-Water Water Partition Partition Coefficients Coefficient for Organic (Log Kow) Compounds (Koc) unitless unitless unitless unitless unitless Dimethyl phthalate 131113 1.0E+1 NA 5.0E+1 NA NA 0.2 1.0 0.1 1.0 1.64 UKg 41.0 N,N-Dimethylacetamide 127195 2.5E-2 NA NA NA NA 0.2 1.0 0.1 1.0 -0.77 0.1 75 N,N-Dimethylaniline 121697 2.2E-3 NA NA 1.lSE-5 5.0E+4 0.2 1.0 0.1 1.0 2.46 262 Dimethylformamide (I) 68122 9.6E-2 NA 3.0E+1 NA NA 0.2 1.0 0.1 1.0 - 1.01 0.1 02 2,4-Dimethylphenol 105679 5.0E-2 NA 7.0E+1 NA NA 0.2 1.0 0,1 1,0 2.36 209 2,6-Dimethylphenol 576261 6.0E-4 NA 2E+0 NA NA 0.2 1.0 0.1 1.0 2.36 209 3,4-Dimethylphenol 95658 1.4E-3 NA 3.SE+O NA NA 0.2 1.0 0.1 1.0 2.23 156 0.2 1.0 0.1 1.0 -1.66 0.0234 Oimethylsulf0)Cide 67685 3.0E+1 NA 2E+1 NA NA 2.4-Dinitrotoluene 121142 2.0E-3 1.1E-1 2.0E+0 2.0E-4 NA 0.2 1.0 0.1 1.0 2.01 94.6 Dinoseb 88857 1.0E-3 NA 4E+O NA NA 0.2 1.0 0.1 1.0 3.15 1,250 1,4-Dioxane (l) 123911 NA 1.0E-2 100 S.SE-6 NA 0.2 1.0 0.1 1.0 -0.39 0.588 Diquat 85007 2.2E-3 NA NA NA NA 0.2 1.0 0.1 1.0 -2.82 0.00169 NA NA NA NA NA NA NA NA NA NA NA NA 330541 4.3E-3 NA 7.0E+0 NA NA 0.2 1.0 0.1 1.0 2.77 187 Endosulfan (J) 115297 6.0E-3 NA NA NA NA 0.2 1.0 0.1 1.0 4.1 2,110 Endothall 145733 1.7E-2 NA 3.5E+1 NA NA 0.2 1.0 0.1 1.0 -0.55 0.288 Endrin 72208 1.7E-4 NA NA NA NA 0.2 0.5 0.1 1.0 5.06 12,200 Dissolved oxygen (DO) Diuron Epichlorohydrin (I) 106898 1.0E-3 5.9E-1 1.0E+0 1.2E-6 NA 0.2 1.0 0.1 1,0 0.26 1.92 Ethanol (I) 64175 6.2E+1 NA 1.9E+4 NA NA 1.0 1.0 0,1 1,0 -0.31 0.496 Ethyl acetate {I) 141786 9.0E-1 NA 3.2E+3 NA NA 0.2 1.0 0.1 1.0 0.69 4.77 Ethyl-tert-butyl ether (ETBE) 637923 NA NA 3.73E+2 NA NA NA 1.0 0.1 1.0 1.92 3.97 March 25, 2011 Page 7 of 14 �Attachment 1 TABLE 4. TOXICOLOGICAL ANO CHEMICAL-PHYSICAL DATA PART 201 GENERIC CLEANUP CRITERIA AND SCREENING LEVELS; PART 213 TIER 1 RISK-BASED SCREENING LEVELS (RBSLs) DOCUMENT RELEASE DATE: MARCH 25, 2011 Developed pursuant to R 299.5752 of the Administrative Rules for Part 201 Environmental Remediation of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. Scientific notation is represented by E+ or E- a value, for example 200,000 is presented as 2.0E+5. Units are as indicated in each column heading. The dataset for each hazardous substance requires 22 columns. Review all 22 columns across 2 pages when evaluating data for a specific hazardous substance. Hazardous Substance Chemical Abstract Service Number Soil Koc for Ionizing Organic Compounds at pH=6.8 Soil-Water Distribution Coefficients for Inorganic Compounds at pH;;6.8 (Kd) UKg Water Diffusivity (D,..) (HLC) Air Diffusivity (Dior D,Pr cal') Lower Explosive Limit in Air (LEL) UKg 3 atm-m /mol 2 cm /s 2 cm /s unitless OF ug/L Henry's Law Constant at 2s0 c Flash Point (FP) Dimethyl phthalate 131113 NR NR 5.7BE-7 0.067 6.3E-6 NA 295 N,N•Dimethylacetamide 127195 NR NR 1.31E--8 0.08 8.0E-6 NA 158 N,N-Dimethylaniline 121697 NR NR 8.12E-5 0.08 8.0E-6 NA 142 Dimethylformamide (I) Water Solubility (S) Physical State at Standard Temperature & Pressure Molecular Weight (MW) unitless g/mol 4.19E+6 Liquid 194.19 1.0E+9 Liquid 87.14 1.27E+6 Liquid 121.18 68122 NR NR 7.39E-8 0.08 8.0E-6 NA 136 1.0E+9 Liquid 73.1 2,4-Dimethylphenol 105679 NR NR 2.0E-6 0.0584 8.69E-6 NA NA 7.87E+6 Solid 122.16 2,6-Dimethylphenol 576261 NR NR 5.02E-6 0.08 8.0E-6 NA NA 6.14E+6 Solid 122.16 3,4-Dimethylpheno! 95658 NR NR 3.78E-7 0.08 8.0E-6 NA NA 4.93E+6 Solid 122.16 Dimethylsulfoxide 67685 NR NR 5.80E--8 0.08 8.0E-6 NA NA 1.66E+8 Liquid 78.14 2,4-Oinitrotoluene 121142 NR NR 9.26E--8 0.203 7.06E-6 NA NA 2.70E+5 Solid 183.15 Dinoseb 88857 NR NR 4.60E-7 0.08 8.0E-6 NA NA 52,000 Liquid 240.2 . 1,4-Dioxane (I) 123911 NR NR 4.90E-6 0.23 1.0E-5 0.02 55 9.00E+8 Liquid 88,11 Diquat 85007 NR NR 1.42E-13 0.08 8.0E-6 NA NA 7.00E+5 Solid 344.08 NR NA NA NA NA NA NA NA NA NA 37,300 Solid 233.1 Dissolved oxygen (DO) NA NR NA Diuron 330541 NR NR 2.70E-6 0.08 8.0E-6 Endosulfan (J) 115297 NR NR 1.12E-5 0.01 15 4.55E-6 NA NA 510 Solid 406.9 Endothall 145733 NR NR 2.60E-10 0.08 8.0E-6 NA NA 1.00E+S Solid 186.18 Endrin 72208 NR NR 7.52E-6 0.0125 4.74E-6 NA NA 250 Solid 380.9 Epichlorohydrin (I) 106898 NR NR 3.00E-5 0.086 9.SE-6 0.038 93 6.S0E+7 Liquid 92.53 46.07 64175 NR NR 6.29E-6 0.08 8.0E-6 0.033 55 1.0E+9 Liquid Ethyl acetate (I) 141786 NR NR 1.70E-4 0.073 9.7E-6 0.02 24 6.40E+7 Liquid 88.12 Ethyl-tert-butyl ether (ETB E) 637923 NR NR 1.389E·3 0.08 8.0E-6 NA NA 5.63E+6 Liquid 102.18 Ethanol (I) March 25, 2011 Page 7 of 14 �Attachment 1 TABLE 4. TOXICOLOGICAL AND CHEMICAL-PHYSICAL DATA PART 201 GENERIC CLEANUP CRITERIA AND SCREENING LEVELS; PART 213 TIER 1 RISK-BASED SCREENING LEVELS (RBSLs) DOCUMENT RELEASE DATE: MARCH 25, 2011 Developed pursuant to R 299.5752 of the Administrative Rules for Part 201 Environmental Remediation of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. Scientific notation is represented by E+ or E- a value, for example 200,000 is presented as 2.0E+5. Units are as indicated in each column heading. The dataset for each hazardous substance requires 22 columns. Review all 22 columns across 2 pages when evaluating data for a specific hazardous substance. Hazardous Substance Chemical Abstract Service Number Oral Reference Dose (RFD) Oral Slope Factor (SF) Chronic Inhalation Inhalation Unit Risk Factor Reference Concentration (IURF) (RfC) Occupational Relative Short Tenn Source Exposure Contribution for Drinking Level Water (STEL) (RSC) ug/m3 Ingestion Absorption Efficiency (AEi) Dennal Absorption Efficiency (AEd) Relative Source Contribution for Soil {RSC) Soil Organic Log Octanol- Carbon-Water Water Partition Partition Coefficients Coefficient for Organic (Log Kow) Compounds (Koc) mg/Kg-day 1 (mg/Kg-day5 ug/m unitless unitless unitless unitless unitless 100414 9.7E-2 NA 1.0E+3 3.lE-7 5.43E+5 0.2 1.0 0.1 1.0 3.14 367 Ethylene dibromide 106934 NA 5.7E+1 SE+O 2.2E-4 NA 0.2 1.0 0.1 1.0 1.75 52.5 Ethylene glycol 107211 2.0E+O 0.2 1.0 0.1 1.0 -1.4 0.0421 5.0E-1 1.3E+4 NA NA 1.0E+S 111762 NA NA 1.0E+3 Ethylene glycol monobutyl ether NA 0.2 1.0 0.1 1.0 0.83 6.55 Fluoranthene 206440 1.2E-1 NA 1.4E+2 NA NA 0.2 0.5 0.1 1.0 5.12 1.08E+05 86737 1.2E-1 NA 1.4E+2 0.2 1.0 0.1 1.0 4 .21 13,800 6.0E-2 NA NA NA NA NA 3.1E+3 1.0 0.5 0.01 1.0 NR NR NA NA NA 1.3E-S 3.7E+2 0.2 1.0 0.1 1.0 -0.051 1.09 2.0E+O NA 1.9E+4 0.2 1.0 0.1 1.0 -0.538 0.449 NA NA NA NA 0.2 1.0 0.1 1.0 NA NA 0.2 1.0 0.1 1.0 0.51 3.17 NA 0.2 0.5 0.1 1.0 -4.47 4.04E-5 Ethylbenzene (I) Fluorene Fluorine (soluble fluoride) (B) 7782414 Formaldehyde 50000 1.8E-1 Formic acid (I.U) 64186 1.4E+O 2591868 1.1 E-2 NA NA Gentian violet 548629 1.4E-1 5.5E-2 NA Glyphosate 1071836 1.0E-1 NA 1-Formylpiperidine Heptachlor Heptach!or epoxide 3 (ug/m3)-1 L/Kg 76448 2.3E-3 1.6E+O NA NA 1.3E· 3 NA NA 0.2 0.5 0.1 1.0 6.26 1.43E+6 1024573 8.SE--6 2.9E+O NA 2.6E-3 NA 0.2 0.5 0.1 1.0 5.0 82,300 142825 4.4E+O NA 3.5E+3 2.05E+6 0.2 1.0 0.1 1.0 4 .72 43,700 NA 0.2 0.5 0.1 1.0 6.1 9.92E+5 Hexabromobenzene 87821 2.8E-3 NA NA NA NA Hexachlorobenzene (C-66) 118741 8.0E-4 1.0E+O NA 4.6E-4 NA 0.2 0.5 0.1 1.0 5,89 55,300 NA NA NA 2.2E-5 1.0 o., 1.0 4.81 53.500 0.2 1.0 0.1 1.0 3.8 1.220 5.3E-4 NA NA NA 0.2 1.83E-3 0.2 1,0 0.1 1.0 3.81 1,250 NA NA 0.2 0.5 0.1 1.0 5.39 1.99E+05 n-Heptane Hexachlorobutadiene (C-46) 87683 2.0E-3 5.2E-2 alpha-Hexachlorocyclohexane 319846 NA 2.0E+O beta-Hexachlorocyclohexane 319857 NA 9.7E-1 Hexachlorocyclopentadiene (C-56) March 25, 2011 77474 6.0E-3 NA 2.0E-1 Page 8 of 14 �Attachment 1 TABLE 4. TOXICOLOGICAL AND CHEMICAL-PHYSICAL DATA PART 201 GENERIC CLEANUP CRITERIA AND SCREENING LEVELS; PART 213 TIER 1 RISK-BASED SCREENING LEVELS (RBSLs) DOCUMENT RELEASE DATE: MARCH 25, 2011 Developed pursuant to R 299.5752 of the Administrative Rules for Part 201 Environmental Remediation of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. Scientific notation is represented by E+ or E- a value, for example 200,000 is presented as 2.0E+S. Units are as indicated in each column heading. The dataset for each hazardous substance requires 22 columns. Review all 22 columns across 2 pages when evaluating data for a specific hazardous substance. Hazardous Substance Chemical Abstract Service Number Soil Koc for Ionizing Organic Compounds at pH=G.8 Soil-Water Distribution Coefficients for Inorganic Compounds at pH=G.8 (Kd) UKg Henry's Law Constant at 25°C (HLC) Air Diffusivity (Dior OJ>r QOlr) Water Diffusivity (OJ Lower Explosive Limit in Air (LEL) Flash Point (FP) Water Solubility (S) Physical State at Standard Temperature & Pressure UKg atm-m3/mol crrt/s crrt/s unitless OF Molecular Weight (MW) ug/L unitless g/mol Ethyl benzene (I) 100414 NR NR 7.SSE-3 0.075 7.SE-6 0.008 55 1.69E+S Liquid 106.17 Ethylene dibromide 106934 NR 4.60E-4 0.08 8.0E-6 NA NA 4.20E+6 Liquid 187.9 Ethylene glycol 107211 NR NR NR 6.00E-8 0.08 8.0E-6 0.032 232 1.0E+S Liquid 62.07 Ethylene glycol monobutyl ether 111762 NR NR 0.08 8.0E-6 2.24E+8 Liquid 118.2 1.61E-5 0.0302 6.35E-6 NA NA 143 206440 NR NR 5.13E-2 Fluoranthene NA 206 Solid 202.24 NR NR NR NA 6.36E-5 0.0363 7.88E-6 166.23 NR NR NA NA Solid NR NA NA 1,980 7782414 NA Inorganic 38 Formaldehyde 50000 NR NR 2.80E-4 0.18 2.0E-5 0.07 NA 5.50E+8 Liquid 30.03 Formic acid (l,U) 64186 NR NR NR 2.50E-6 0.079 1.4E-6 0.18 122 1.0E+9 Liquid 46.03 NR NA 0.08 8.0E-6 NA Liquid 113.2 3.0SE-16 0.08 8.DE-6 Solid 408 1.S0E-9 0.08 8.0E-6 1.16E+7 Solid 169.09 1.48E-3 0.0112 5.69E-S 180 Solid 373.4 1024573 NR NR 9.S0E-6 0.0132 4.23E-6 NA NA NA NA NA NA NA 1.00E+6 76448 NR NR NR NA NA NA NR NR NR 200 Solid 389.32 n-Heptane 142825 NR 2.11E+0 0.08 8.0E-6 0.0105 25 2.690 liquid 100.2 Hexabromobenzene 87821 1.30E-5 0.08 8.0E-6 NA NA 0.17 Solid 551 Hexachlorobenzene (C-66) 118741 NR NR NR NR NR 1.32E-3 0.0542 5.91E-6 NA NA 6,200 Solid 284.78 Hexachlorobutadiene (C-46) 8.15E-3 0.0561 6.16E-6 NA NA NA NA 3,230 Liquid 260.76 7.34E-6 Fluorene Fluorine (soluble fluoride) (B) 1-Formylpiperidine 86737 2591868 Gentian violet 548629 Glyphosate 1071836 Heptachlor Heptachlor epoxide 87683 NR NR alpha·Hexachlorocyclohexane 319846 NR NR 1.06E-5 0.0142 2,000 Solid 290.82 beta-Hexachlorocyclohexane 319857 NR NR 7.43E-7 0.0142 7.34E-6 NA NA 240 Solid 290.82 Hexachlorocyclopentadiene rC-561 77474 NR NR 2.70E-2 0.0161 7.21E-6 NA NA 1,800 Liquid 272.77 March 25, 2011 Page 8 of 14 �Attachment 1 TABLE 4. TOXICOLOGICAL AND CHEMICAL-PHYSICAL DATA PART 201 GENERIC CLEANUP CRITERIA AND SCREENING LEVELS; PART 213 TIER 1 RISK-BASED SCREENING LEVELS (RBSLs) DOCUMENT RELEASE DATE: MARCH 25, 2011 Developed pursuant to R 299.5752 of the Administrative Rules for Part 201 Environmental Remediation of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. Scientific notation is represented by E+ or E- a value, for example 200,000 is presented as 2.0E+S. Units are as indicated in each column heading. The dataset for each hazardous substance requires 22 columns. Review all 22 columns across 2 pages when evaluating data for a specific hazardous substance. Hazardous Substance Chemical Abstract Service Number Oral Reference Dose Inhalation Chronic Inhalation Unit Reference Risk Factor (IURF) Concentration (RfC} (RFD} Oral Slope Factor (SF} mg/Kg-day (mg/Kg-day}1 ug/m3 (ug/m3).1 Occupational Relative Short Term Source Contribution Exposure for Orin king Level (STEL} Water (RSC) 3 ug/m Ingestion Absorption Efficiency (AEi) Dermal Absorption Efficiency (AEd} Relative Source Contribution for Soil (RSC) Soil Organic Log Octanol- Carbon-Water Water Partition Partition Coefficients Coefficient for Organic (Log Kow) Compounds (Koc) unitless unitless unitless unitless unitless UKg Hexachloroethane 67721 1.0E-3 8.5E-3 3.5E+O 4.0E-6 NA 0.2 1.0 0.1 1.0 4.0 1.760 n-Hexane 110543 4.1E-1 NA 2.0E+2 NA NA 0.2 1.0 0.1 1.0 4.0 1,760 2-Hexanone 591786 1.4E-1 NA 4.0E+1 0.1 1.0 1.4 23.8 NA 4.1E·1 NA NA NA 1.0 193395 NA NA 0.2 !ndeno(1,2,3-cd)pyrene (Q) 0.2 0.5 0.13 1.0 6.65 3.45E+6 7439896 3.0E-1 NA NA NA NA 0.2 0.5 0.01 1.0 NR NR lsobutyl alcohol (I) 78831 3.2E-1 NA 1.5E+3 NA NA 0.2 1.0 0.1 1.0 0.75 5.46 lsophorone 78591 1.5E-1 1.1E-3 2.8E+2 2.?E-7 2.8E+4 0.2 1.0 0.1 1.0 1.699 46.8 1.0 0.1 1.0 0.05 1.31 3,460 Iron (B) 98828 1.1 E-1 NA NA 8.7E+1 NA 1.0 0.1 1.0 3.6 7439921 NA NA 1.5E+0 NA NA NA 0.2 Lead (B) 0.2 0.5 0.01 1.0 NR NR Undane 58899 3.3E-4 7.1E-1 NA NA NA 0.2 1.0 0.04 1.0 3.73 1,080 7439932 2.8E-2 NA NA NA NA 0.2 0.5 0.01 1.0 NR NR 1.0 0.5 0.01 1.0 NA NA 0.5 0.5 0.01 1.0 NR NR NR 0.2 0.5 0,01 1.0 5.95 NR NA 0.2 1.0 0.1 1.0 1.09 11.8 1.0 0.1 1.0 -0.72 0.196 12,600 lsopropyl alcohol (I) lsopropyl benzene Lithium (B} 67630 6.4E-2 2.2E+2 NA 1.23E+6 0.2 NA NA 1.0E+2 NA NA 5.0E-2 NA NA NA 3.0E-1 NA NA NA NA 5.0E-1 NA 3.25E+3 NA 3.28E+6 0.2 NA NA 0.2 0.5 0.1 1.0 5.08 0.2 1.0 0.1 1.0 -0.77 0.175 0.2 1.0 0,1 1.0 3.25 1,570 0.2 1.0 0. 1 1.0 2.1 116 Magnesium (B) 7439954 1.1E+1 Manganese (B} 7439965 4.7E-2 Mercuiy (Total) (B,Z) Varies 3.0E-4 Methane 74828 Methanol 67561 Methoxychlor 72435 S.0E-3 2-Methoxyethanol (I) 109864 1.0E-3 NA NA 2.0E+1 NA NA 2-Methyl-4-chlorophenoxyacetic acid 2-Methyl-4,6-dlnitrophenol 94746 1.0E-3 NA NA NA NA NA 534521 3.5E-4 NA NA NA NA March 25, 2011 NR Page 9 of 14 �Attachment 1 TABLE 4. TOXICOLOGICAL AND CHEMICAL-PHYSICAL DATA PART 201 GENERIC CLEANUP CRITERIA AND SCREENING LEVELS; PART 213 TIER 1 RISK-BASED SCREENING LEVELS (RBSLs) DOCUMENT RELEASE DATE: MARCH 25, 2011 Developed pursuant to R 299.5752 of the Administrative Rules for Part 201 Environmental Remediation ofthe Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. Scientific notation is represented by E+ or E- a value, for example 200,000 is presented as 2.0E+5. Units are as indicated in each column heading. The dataset for each hazardous substance requires 22 columns. Review all 22 columns across 2 pages when evaluating data for a specific hai:ardous substance. Hazardous Substance Chemical Abstract Service Number Soil Koc for Ionizing Organic Compounds at pH=6.8 Soil-Water Distribution Coefficients for Inorganic Compounds at pH=6.8 (Kd) UKg Water Diffusivity (Owl (HLC) Air Diffusivity (Dior D.pr oal') Lower Explosive Limit In Air (LEL) UKg 3 atrn-m /mol crr("/s 2 cm /s unitless OF ug/L unitless g/mol NR 3.89E-3 0.0025 6.8E-6 NA NA 50,000 Solid 236.74 Henry's Law Constant at 25°C Flash Point {FP) Water Solubility (S) Physical State at Standard Temperature & Pressure Molecular Weight (MW) Hexachloroethane 67721 NR n-Hexane 110543 NR 0.08 8.0E-6 0.011 -7 12,000 Liquid 86.1 8 591786 NR NR NR 1.40E-2 2-Hexanone 9.57E-5 0.08 8.0E-6 NA 77 1.60E+7 Liquid 100.16 193395 NR NR NR 1.60E-6 0.019 5.66E-6 276.34 NR NR NA NA Solid NR NA NA 0.022 NA NA Inorganic 55.845 NR 1.30E-5 0.08 8.0E-6 NA 82 7.60E+7 Liquid 74.14 138.23 lndeno(1,2,3-cd)pyrene (Q) Iron (B) 7439896 lsophorone 78591 NR NR NR 6.20E-6 0.0623 6.76E-6 0.008 184 1.20E+7 Liquid lsopropyl alcohol (I) 67630 NR NR 8.07E-6 0.08 8.0E-6 0.02 53 1.0E+9 Liquid 60.09 lsopropyl benzene 98828 NR NR 1.50E-2 0.086 7.1E-6 0.009 96 56,000 Liquid 122.1 6 7439921 NR 11,000 NR NR NR NA NA NA Inorganic 207.2 lsobutyl alcohol (I) 78831 Lead (8) 58899 NR NR 1.40E-S 0.0176 7.34E-6 290.9 NR NA NR NR NA Inorganic 6.941 Magnesium (8) 7439954 NR NA NA NR NR NA NA Solid 7439932 NA NA 6 ,800 Lithium (8) NR NA NA NA NA NA NA 24.305 NR NR NR Inorganic NR Inorganic 54.938 52 7.10E-10 0.037 6.3E-6 NA NA 56 Inorganic 200.59 NR NR NR NR 6.58E-1 0.08 8.0E-6 0.053 -306 NA Gas 16.04 1.70E-4 0.15 1.3E-5 0.06 52 2.90E+7 Liquid 32.05 NR NR 1.58E-5 0.0156 4.46E-6 45 Solid 345.7 0.08 8.0E-6 NA NA NA 9.51 E-7 NA 1.0E+9 Liquid 76.1 Lindane Manganese (8) 7439965 Mercury (Total) (B,Z) Varies Methane 74828 Methanol 67561 Methoxychlor 72435 NR NR 2-Methoxyethano! (I) 109864 NR NR 2-Methyl-4-chlorophenoxyacetic acid 2-Methyl-4,6-dinitrophenol 94746 NR NR 1.33E-9 0.08 8.0E-6 NA NA 9.24E+5 Solid 305.79 534521 NR NR 4.30E-7 0.08 8.0E-6 NA NA 2.00E+S Solid 198.13 March 25, 2011 Page 9 of 14 �Attachment 1 TABLE 4. TOXICOLOGICAL AND CHEMICAL-PHYSICAL DATA PART 201 GENERIC CLEANUP CRITERIA AND SCREENING LEVELS; PART 213 TIER 1 RISK-BASED SCREENING LEVELS (RBSLs) DOCUMENT RELEASE DATE: MARCH 25, 2011 Developed pursuant to R 299.5752 of the Administrative Rules for Part 201 Environmental Remediation of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. Scientific notation is represented by E+ or E- a value, for example 200,000 is presented as 2.0E+S. Units are as indicated in each column heading. The dataset for each hazardous substance requires 22 columns. Review all 22 columns across 2 pages when evaluating data for a specific hazardous substance. Hazardous Substance Chemical Abstract Service Number Inhalation Chronic Inhalation Unit Reference Risk Factor (IURF) Concentration (RfC) Oral Reference Dose (RFD) Oral Slope Factor (SF) mg/Kg-day (mg/Kg-dayf1 ug/m3 (ug/m3)-t Occupational Relative Short Term Source Exposure Contribution for Drinking Level (STEL) Water (RSC) 3 ug/m Ingestion Absorption Efficiency (AEi) Dermal Absorption Efficiency (AEd) Relative Source Contribution for Soil (RSC) Soil Organic Log Octanol- Carbon-Water Water Partition Partition Coefficients Coefficient for Organic (Log Kow) Compounds (Koc) unitless unitless unitless unitless unitless L/Kg N-Methyl-morpholine (I) 109024 2.7E-3 NA NA NA NA 0.2 1.0 0.1 1.0 -0.33 0.474 Methyl parathion 298000 2.SE-4 NA NA NA NA 0.2 1.0 0.1 1.0 2.9 710 1.0 0.1 1.0 1.18 14.5 4-Methyl-2-pentanone (MIBK) (I) Methyl-tert-buty! ether (MTBE) 108101 2.SE-1 NA 2.05E+3 NA 3.07E+6 0.2 1634044 3.3E-2 3.4E-3 3.0E+3 NA NA 0.2 1.0 0.1 1.0 0.99 9.41 Methylcyclopentane (I) 96377 NA NA 700 NA NA 0.2 1.0 0.1 1.0 3.37 2,060 4,4'-Methylene-bis-2chloroaniline (MBOCA) Methylene chloride 101144 7.3E-4 7.7E-1 NA 3.7E-S NA 0.2 1.0 0.1 1.0 3.92 7,140 75092 5.SE-2 4.2E-3 NA 4.7E-7 NA 0.2 1.0 0.1 1.0 1.26 11.9 91576 3.SE-2 NA 1E+1 NA NA 0.2 1.0 0.1 1.0 3.9 6.820 Methylphenols (J) 1319773 5.0E-2 NA 1.0E+2 NA NA 0.2 1.0 0.1 1.0 1.99 45.1 Metolachlor 51218452 2.3E-1 3.5E-3 NA NA NA 0.2 1.0 0.1 1.0 3.13 361 Metribuzin 21087649 2.5E-2 NA NA NA NA 0.2 0.5 0.1 1.0 1.7 46.9 2385855 2.3E-4 9.3E-1 NA NA NA 0.2 0.5 0.1 1.0 6.70 3.86E+6 NA NA NA NA 0.4 0.5 0.0 1 1.0 NR NR 2.010 2-Methylnaphthalene Mirex Molybdenum (B) 7439987 5.0E-3 91203 7.1 E-2 NA 3.0E+0 3.lE-6 7.9E+4 0.2 1.0 0.1 1.0 3.36 Nickel (B) 7440020 7.SE-2 NA NA 2.4E-4 NA 0.2 0.5 0.01 1.0 NR NR N~rate (B.N) 14797558 1.SE+0 NA NA NA NA 1.0 0.5 0.01 1.0 NR NR Nitrite (B,N) 14797650 1.0E-1 NA NA NA NA 1.0 0.5 0.01 1.0 NR NR 64.4 Naphthalene Nitrobenzene (I) 98953 4.SE-4 NA 7.0E-1 2.0E-5 NA 0.2 1.0 0.1 1.0 1.84 2-Nitrophenol 88755 2.8E-3 NA NA NA NA 0.2 1.0 0.1 1.0 1.8 58.8 621647 2.5E-1 4.SE+O NA 2.0E·3 NA 0.2 1.0 0.1 1.0 1.4 23.8 86306 2.SE-1 3.1 E-3 NA 1.4E·6 NA 0.2 1.0 0.1 1.0 3.16 381 n-Nitroso-di-n-propylamine N-Nitrosodiphenylamine March 25, 2011 Page 10 of 14 �Attachment 1 TABLE 4. TOXICOLOGICAL AND CHEMICAL-PHYSICAL DATA PART 201 GENERIC CLEANUP CRITERIA AND SCREENING LEVELS; PART 213 TIER 1 RISK-BASED SCREENING LEVELS (RBSLs) DOCUMENT RELEASE DATE: MARCH 25, 2011 Developed pursuant to R 299.5752 of the Administrative Rules for Part 201 Environmental Remediation of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. Scientific notation is represented by E+ or E- a value, for example 200,000 is presented as 2.0E+S. Units are as indicated in each column heading. The dataset for each hazardous substance requires 22 columns. Review all 22 columns across 2 pages when evaluating data for a specific hazardous substance. Hazardous Substance Chemical Abstract Service Number Soil Koc for Ionizing Organic Compounds at pH=G.8 Soil-Water Distribution Coefficients for Inorganic Compounds at pH=6.8 (Kd) L/Kg UKg Henry's Law Constant at Lower Explosive Limit in Air (LEL) Molecular Weight (MW) Water Diffusivity (Dv) (HLC) atm-m3/mol crrt/s cm /s unitless OF ug/L unitless gtmol NA 1.0E+9 Liquid 101.17 2s0 c 2 Flash Point (FP) Water Solubility (S) Physical State at Standard Temperature & Pressure Air Diffusivity (Dior Dpr o•I') N-Methyl-morpholine (I) 109024 NR NR 2.50E-7 0.08 6.0E-6 NA Methyl parathion 298000 NR NR 1.10E-7 0.08 8.0E-6 NA NA 50,000 Solid 263.23 4-Methyl-2-pentanone (MIBK) 108101 NR NR 1.20E-4 0.075 7.8E-6 NA 64 2.00E+7 Liquid 100.2 (I) Methyl-tert-butyl ether (MTBE) 1634044 NR NR 6,39E-4 0.08 8.0E-6 NA NA 4.68E+7 Liquid 88.15 Methylcyclopentane (I) 96377 NR NR 3,63E-1 0.08 8.0E-6 NA NA 73,890 Liquid 84.16 4,4'-Methylene-bis-2chloroaniline IMBOCA1 Methylene chloride 101144 NR NR 4.10E-11 0.08 8.0E-6 NA NA 14,000 Solid 267.17 75092 NR NR 2.40E-3 0.101 1.17E-5 0.13 NA 1.70E+7 liquid 50.5 2-Methylnaphthalene 91576 NR NR 4.99E-4 0.08 8.0E-6 NA NA 24,600 Solid 142.2 1319773 NR NR 1,60E-6 0.074 8.3E-6 NA 178 2.80E+7 Solid 108.13 9.90E-9 0.08 8.0E-6 NA NA 5.30E+5 Liquid 283.83 Solid 214.29 545.54 Methylphenols (J) Melolachlor 51218452 NR NR Metribuzin 21087649 NR NR 8.B0E-2 0.08 8.0E-6 NA NA 1.2E+6 Mirex 2385855 NR NR 5.16E-4 0,08 8.0E-6 NA NA 6.BE-6 Solid Molybdenum (B) 7439967 NR NA NR NR NR NA NA NA Inorganic 95.94 91203 NR NR 4.83E-4 0.059 7.5E-6 0.009 174 31,000 Solid 128.17 Nickel (B) 7440020 NR 65 NR NR NR NA NA NA Inorganic 58.7 Nitrate (8,N) 14797558 NR NA NR NR NR NA NA NA Inorganic 62 Nitrite (B,N) 14797650 NR NA NR NR NR NA NA NA Inorganic 46 N~robenzene (I} 98953 NR NR 2.40E-5 0,076 8.6E-6 NA 190 2.09E+6 Liquid 123.11 2-Nitrophenol 88755 NR NR 3.S0E-6 0.08 8.0E-6 NA NA 2.50E+6 Solid 139.11 NA 9.89E+6 liquid 130.22 NA 35,100 Solid 198.22 Naphthalene n-Nitroso-di-n-propylamine 621647 NR NR 2.25E-6 0.0545 8.17E-6 NA N-Nitrosodiphenylamine 86306 NR NR 5.00E-6 0.0312 6.35E-6 NA March 25, 2011 Page 10 of 14 �Attachment 1 TABLE 4. TOXICOLOGICAL AND CHEMICAL-PHYSICAL DATA PART 201 GENERIC CLEANUP CRITERIA AND SCREENING LEVELS; PART 213 TIER 1 RISK-BASED SCREENING LEVELS (RBSLs) DOCUMENT RELEASE DATE: MARCH 25, 2011 Developed pursuant to R 299.5752 of the Administrative Rules for Part 201 Environmental Remediation of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. Scientific notation is represented by E+ or E- a value, for example 200,000 is presented as 2.0E+5. Units are as indicated in each column heading. The dataset for each hazardous substance requires 22 columns. Review all 22 columns across 2 pages when evaluating data for a specific hazardous substance. Hazardous Substance Chemical Abstract Service Number Oral Reference Dose (RFD) Oral Slope Factor (SF) Chronic Inhalation Inhalation Unit Risk Factor Reference Concentration (IURF) (RfC) mg/Kg-day 1 (mg/Kg-dayf ugim 3 Occupational Relative Short Term Source Exposure Contribution Level for Drinking ($TEL) Water (RSC) (ug/m3)·1 3 ug/m Ingestion Absorption Efficiency (AEi) Dermal Absorption Efficiency (AEd) Relative Source Contribution for Soil (RSC) Soil Organic Log Octanol• Carbon-Water Water Partition Partition Coefficients Coefficient for Organic (Log Kow) Compounds (Koc) unitless unitless unitless unitless unitless UKg Oxamyl 23135220 3.8E-2 NA NA NA NA 0.2 1.0 0.1 1.0 -0.47 0.508 Oxo-he><)II acetate 88230357 1.0E-2 NA 3.1E+1 NA NA 0.2 1.0 0.1 1.0 NA NA Pendimethalin 40487421 1.2E-1 NA NA NA NA 0.2 0.5 0.1 1.0 5.18 1.24E+5 ?entachlorobenzene 608935 8.3E--4 NA NA NA NA 0.2 0.5 0.1 1.0 5.26 1.48E+5 ?entachloronitrobenzene 82688 7.SE-3 NA 5.0E+0 NA NA 0.2 1.0 0.1 1.0 4.64 36,400 Pentachlorophenol 87865 3.0E-2 6.8E-2 1.0E-+-2 3.0E-5 NA 0.2 0.5 0.25 1.0 5.09 592 0.1 1.0 Pentane 109660 NA NA 1.8E+4 NA 2.21E+6 0.2 1.0 3.42 2.300 2-Pentene (I) 109682 NA NA NA NA NA 0.2 1.0 0.1 1.0 2.58 344 NA NA NA NA NA NA NA NA NA NA NA NR ?henanthrene 85018 7.1E-3 NA 1.0E-1 NA NA 0.2 1.0 0.1 1.0 4.6 33,300 Phenol 108952 6.0E-1 NA 6.0E+2 NA NA 0.2 1.0 0.1 1.0 1.48 17.8 1,0 NR NA 1.0 0.73 5.22 pH Phosphorus (Total) Phthalic acid Phthalic anhydride Picloram 7723140 1.1E+1 NA 1E+0 NA NA 0.2 0.5 0.1 88993 1.9E+0 NA NA NA NA 0.2 1.0 0.1 85449 2.1E+0 NA NA NA NA 0.2 1.0 0.1 1.0 1.6 37.4 1918021 7.0E-2 NA NA NA NA 0.2 1.0 0.1 1.0 0.3 1.97 NA NA 0.2 1.0 0.1 1.0 0.84 6.7 110894 4.4E-4 NA 1.4E+2 67774327 4.3E-6 7.2E+0 NA NA NA 0.2 0.5 0.1 1.0 7.07 8.91E+6 1336363 2.0E-5 2.0E+0 NA 6.0E-4 NA 0.2 0.5 0.14 1.0 5.58 3.06E+5 1610180 2.2E-2 NA NA NA NA 0.2 1.0 0.1 1.0 2.99 870 Propachlor 1918167 1.3E-2 NA NA NA NA 0.2 1,0 0.1 1.0 2.01 94.6 Propazine 139402 2.7E-2 NA NA NA NA 0.2 1.0 0.1 1.0 2.75 505 Piperidine Polybrominated biphenyls (J) Polychlorinated biphenyls (PCBs) (J.n Prometon March 25, 2011 Page 11 of 14 �Attachment 1 TABLE 4. TOXICOLOGICAL AND CHEMICAL-PHYSICAL DATA PART 201 GENERIC CLEANUP CRITERIA AND SCREENING LEVELS; PART 213 TIER 1 RISK-BASED SCREENING LEVELS (RBSLs) DOCUMENT RELEASE DATE: MARCH 25, 2011 Developed pursuant to R 299.5752 of the Administrative Rules for Part 201 Environmental Remediation of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. Scientific notation is represented by E+ or E- a value, for example 200,000 is presented as 2.0E+5. Units are as indicated in each column heading. The dataset for each hazardous substance requires 22 columns. Review all 22 columns across 2 pages when evaluating data for a specific hazardous substance. Hazardous Substance Chemical Abstract Service Number Soil Koc for Ionizing Organic Compounds at pH=6.8 Soil-Water Distribution Coefficients for Inorganic Compounds at pH=6.8 (Kd) UKg Henry's Law Constant at 2s"c (HLC) Air Diffusivity (DIor D,Pr D•I') Water Diffusivity (D,,) Lower Explosive Limit in Air (LEL) UKg 3 atm-m /mol crrf/s crrfis 2.37E-10 0.08 Flash Point (FP) Water Solubility (S) unities& OF ug/L NA g/mol 2.80E+8 Solid 219.29 NA Liquid 144.2 NA 275 Solid 281.31 NA NA 650 Liquid 250.3 NA NA 32 Solid 295.32 NA NA 1.85E+6 Solid 266.32 0.015 -57 38,200 Liquid 72.15 NA 2.03E+5 Liquid 70.13 23135220 NR NR 8.0E-6 NA Oxe>-hexyl acetate 88230357 NR NR NA 0.08 8.0E-6 NA NA Pendimethalin 40487421 NR NR 8.56E-7 0.08 8.0E-6 NA Pentachlorobenzene 608935 NR NR 8.40E-4 0.067 6.3E-6 Pentachloronitrobenzene 82688 NR NR 2.90E-2 0.08 8.0E-6 Pentachlorophenol 87865 592 NR 2.44E--8 0.056 6.1E-6 Pentane 109660 NR NR 1.26E+0 0.08 8.0E-6 2-Pentene (I} 109682 NR NR 2.3E-1 0.08 8.0E-6 NA pH Phenol Phosphorus (Total} Phthalic acid Phthalic anhydride Molecular Weight (MW) unitless Oxamyl Phenanthrene Physical State at Standard Temperature & Pressure NA NR NA NR NA NA NA NA NA NA NA 85018 NR NR 2.3E-5 0.08 8.0E-6 NA NA 1,000 Solid 178.24 108952 NR NR 3.97E-7 0.082 9.1E-6 0.018 175 B.28E+7 Liquid 147.01 7723140 NR NR NR 0.08 8.0E-6 NA NA NA Solid 30.974 88993 NR NR 2.18E-12 0.08 8.0E-6 NA NA 1.42E+7 Liquid 166.1 3 0.08 B.OE-6 1.7E+7 305 6.2E+6 Liquid 148.1 85449 NR NR 1.63E-8 Picloram 1918021 NR NR 4.05E•11 0.08 8.0E-6 NA NA 4.30E+5 Solid 241.48 Piperidine 110894 NR NR 4.45E-6 0.08 8.0E-6 NA NA 1.0E+9 Liquid 85.15 67774327 NR NR 3.90E-6 0.08 8.0E-6 NA NA 1.66E+7 Solid NA Polychlorinated biphenyls (PCBs) (J.TI Prometon 1336363 NR NR 4.20E-4 0.08 8.0E-6 NA NA 44.7 Solid 268.4 1610180 NR NR 1.9BE-9 0.08 8.0E-6 NA NA 7.S0E+5 Solid 225.29 Propachlor 1918167 NR NR 1.09E-7 0.08 8.0E-6 NA NA 6.5SE+S Solid 211.69 Propazine 139402 NR NR 4.60E-9 0.08 8.0E-6 NA NA a.600 Solid 229.75 Polybrominated biphenyls (J} March 25, 2011 Page 11 of 14 �Attachment 1 TABLE 4. TOXICOLOGICAL AND CHEMICAL-PHYSICAL DATA PART 201 GENERIC CLEANUP CRITERIA AND SCREENING LEVELS; PART 213 TIER 1 RISK-BASED SCREENING LEVELS (RBSLs) DOCUMENT RELEASE DATE: MARCH 25, 2011 Developed pursuant to R 299.5752 of the Administrative Rules for Part 201 Environmental Remediation of the Natural Resources and Environmental Protection Act, 1994 PA 451 , as amended. Scientific notation is represented by E+ or E- a value, for example 200,000 is presented as 2.0E+S. Units are as indicated in each column heading. The dataset for each hazardous substance requires 22 columns. Review all 22 columns across 2 pages when evaluating data for a specific hazardous substance. Hazardous Substance Chemical Abstract Service Number Oral Reference Dose (RFD) Oral Slope Factor (SF) Inhalation Chronic Inhalation Unit Reference Risk Factor Concentration (IURF) (RfC) mg/Kg-day 1 (mg/Kg-dayf 3 ug/m {ug/m3).1 Occupational Relative Short Term Source Contribution Exposure Level for Drinking Water (STEL) (RSC) Ingestion Absorption Efficiency (AEi) Dermal Absorption Efficiency (AEd) Relative Source Contribution for Soil (RSC) ug/m3 unitless unitless unitless unitless Soil Organic Log Octanol- Carbon-Water Water Partition Partition Coefficients Coefficient for Organ ic (Log Kow) Compounds (Koc) unitless UKg Propionic acid 79094 1.7E+0 NA 3.0E+2 NA NA 0.2 1.0 0.1 1.0 0.28 1.89 Propyl alcohol (I) 71238 1.9E-1 NA 7.3E+2 NA 6.14E+5 0.2 1.0 0.1 1.0 0.25 1.89 0.2 1.0 0.1 1.0 3.69 4,240 n-Propylbenzene (l) 103651 1.1 E-2 NA 2.0E+1 NA NA Propylene glycol 57556 2.0E+1 NA 6.0E+3 NA NA 0.2 1.0 0.1 1.0 ·0.92 0.125 Pyrene 129000 7.SE-2 NA 1.0E+2 NA NA 0.2 0.5 0.1 1.0 5.11 1.06E+5 110861 1.0E-3 NA 3.SE+0 NA NA 0.2 1.0 0.1 1.0 0.67 4.56 7782492 5.0E-3 NA 2.0E+0 NA NA 0.2 0.5 0.01 1.0 NR NR 0.5 0.01 1.0 NR NR 1.0 0.1 1.0 3.4 2,200 Pyridine (I) Selenium (B) Silver (B) Silvex (2.4,5-TP) 7440224 4.7E-3 NA 1.0E-1 NA NA 0.2 93721 7.5E-3 NA NA NA NA 0.2 122349 5.2E-3 NA NA NA NA 0.2 1.0 0.1 1.0 1.93 79.0 Sodium 17341252 3.4E+1 NA NA NA NA 0.1 0.5 0.01 1.0 NR NR Sodium azide 26628228 1.2E-2 NA NA NA NA 0.2 1.0 0.1 1.0 NA NA 0.2 0.5 0.01 1.0 NR NR 777 Simazine 7440246 6.3E-1 NA NA NA NA Styrene 100425 2.0E-1 1.3E-2 1.0E+3 5.7E-7 1.7E+5 0.2 1.0 0.1 1.0 2.94 Sulfate 14808798 NA NA NA NA NA NA 0.5 0.1 1.0 NR NR Tebuthiuron 34014181 7.0E-2 NA NA NA NA 0.2 1.0 0.1 1.0 1.78 56.2 2,3,7,8-Tetrabromodibenzo-p-<lic (0) 1,2,4,5-Tetrachlorobenzene 50585416 NA 7.5E+4 NA NA NA 0.2 0.5 0.03 1.0 7.24 1.31E+7 95943 3.4E-1 NA 1E+0 NA NA 0.2 1.0 0.1 1.0 4.64 36,400 2.3.7 .8-Tetrachlorodibenzo-p-dio 1746016 NA 7.5E+4 NA 4.4E+1 NA 0.2 0.5 0.03 1.0 7.04 8.33E+6 1.1.1,2-Tetrachloroethane 630206 8.9E-2 1.1E-2 NA 7.4E-6 NA 0.2 1.0 0.1 1.0 2.63 145 1, 1,2,2-Tetrachloroethane 79345 NA 1.0E-1 NA 5.BE-5 NA 0.2 1.0 0.1 1.0 2.39 93.5 Strontium (B) (0) March 25, 2011 Page 12 of 14 �Attachment 1 TABLE 4. TOXICOLOGICAL AND CHEMICAL-PHYSICAL DATA PART 201 GENERIC CLEANUP CRITERIA AND SCREENING LEVELS; PART 213 TIER 1 RISK-BASED SCREENING LEVELS (RBSLs) DOCUMENT RELEASE DATE: MARCH 25, 2011 Developed pursuant to R 299.5752 of the Administrative Rules for Part 201 Environmental Remediation of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. Scientific notation is represented by E+ or E- a value, for example 200,000 is presented as 2.0E+5. Units are as indicated in each column heading. The dataset for each hazardous substance requires 22 columns. Review all 22 columns across 2 pages when evaluating data for a specific hazardous substance. Hazardous Substance Chemical Abstract Service Number Soil Koc for Ionizing Organic Compounds at pH=6.8 Soil-Water Distribution Coefficients for Inorganic Compounds at pH=6.8 (Kd) UKg UKg Water Diffusivity (Dv) (HLC) Air Diffusivity (01or D.pr o•I') Lower Explosive Limit in Air (LEL) atm-m3/mol crr?-1s c.rr?ts unitless OF ug/L unitless glmol NR NR 4.45E-7 0.08 8.0E-6 0.029 126 1.0E+9 Liquid 74.09 Henry"s Law Constant at 0 2s c Flash Point (FP) Water Solubility (S) Physical State at Standard Temperature & Pressure Molecular Weight (MW) Propyl alcohol (I) 71238 NR NR 7.41 E-6 0.08 8.0E-6 0.022 72 1.0E+9 Liquid 60.11 n-Propylbenzene (I) 103651 NR NR NA 0.08 8.0E-6 NA NA NA Liquid 120.19 Propionic acid 79094 Propylene glycol 57556 NR NR 0.08 8.0E-6 76.1 0.0272 7.24E-6 NA NA Liquid 1.10E-5 NA NA 1.0E+9 129000 NR NR 1.24E-B Pyrene 135 Sol id 202.26 Pyridine (I) 110861 NR NR 7.00E-3 0.091 7.6E-6 0.018 68 3.00E+5 liquid 79. 11 Selenium (8) 7782492 NR 5 NR NR NR NA NA NA Inorganic 78.96 Silver (8) 7440224 NR 8.3 NR NR NR NA NA NA Inorganic 107.868 Silvex (2,4,5-TP) 93721 1.30E-8 0.08 8.0E-6 NA NA 1.40E+5 Solid 269.51 122349 NR NR NR Simazine NR 3.37E-9 0.08 8.0E-6 Solid 201.67 NR NA NR NR 23 8.0E-6 NA NA NA Inorganic 0.08 NA NA NA 4.470 NA NA NA NA Solid 65.01 Sodium 17341252 Sodium azide 26628228 NR NR Strontium (8) 7440246 NR NA NR NA NA NA NA NA Inorganic 87.62 Styrene 100425 0.071 8.0E-6 0.009 88 3.10E+5 Liquid 104.15 14808798 NR NA 2.75E-3 Sulfate NR NR NR 0.08 8.0E-6 Inorganic 96.066 34014181 NR NR 2.40E-10 0.08 8.0E-6 NA NA NA Tebuthiuron NA NA 2.50E+6 Solid 228.31 2,3,7,8-Tetrabromodibenzo-p-dic 50585416 NR NR 2.95E-7 0.08 8.0E-6 NA NA 0.00996 Solid 499.6 95943 NR NR 1.20E-3 0.08 8.0E-6 NA NA 1,300 Solid 215.28 1746016 NR NR 9.20E-6 0.047 8.0E-6 NA NA 0.019 Solid 322 630206 NR NR 2.40E-3 0.071 7.9E-6 NA NA 1.1 0E+6 Liquid 167.85 79345 NR NR 3.45E--4 0.071 7.9E-6 NA NA 2.97E+6 Liquid 167.85 (0\ 1,2.4,5-Tetrachlorobenzene 2,3,7,8-Tetrachlorodibenzo-i>-dio (0\ 1.1 , 1,2-Tetrachloroethane 1, 1,2,2-Tetrachloroethane March 25, 2011 Page 12 of 14 �Attachment 1 TABLE 4. TOXICOLOGICAL AND CHEMICAL-PHYSICAL DATA PART 201 GENERIC CLEANUP CRITERIA AND SCREENING LEVELS; PART 213 TIER 1 RISK-BASED SCREENING LEVELS (RBSLs) DOCUMENT RELEASE DATE: MARCH 25, 2011 Dlt\ Developed pursuant to R 299.5752 of the Administrative Rules for Part 201 Environmental Remediation of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. Scientific notation is represented by E+ or E- a value, for example 200,000 is presented as 2.0E+S. Units are as indicated in each column heading. The dataset for each hazardous substance requires 22 columns. Review all 22 columns across 2 pages when evaluating data for a specific hai:ardous substance. Hazardous Substance Chemical Abstract Service Number Oral Reference Dose (RFD) Oral Slope Factor (SF) Chronic Inhalation Inhalation Unit Reference Risk Factor Concentration (IURF) (Rte) mg/Kg-day 1 (mg/Kg-day} ugim3 (uglm3)"1 Relative Occupational Short Tenn Source Exposure Contribution Level for Orin king (STEL) Water (RSC) ugim3 Ingestion Absorption Efficiency (AEi) Dermal Absorption Efficiency (AEd) Relative Source Contribution for Soil (RSC) Soil Organic Log Octa nol- Carbon-Water Water Partition Partition Coefficients Coefficient for Organic (Log Kow) Compounds (Koc) unitless unitless unitless unitless unitless Tetrachloroethylene 127184 1.0E-2 2.6E·2 NA 5.BE-7 6.85E+5 0.2 1.0 0.1 1.0 2.67 156 Tetrahydrofuran 109999 1.3E-2 NA 5.9E+3 2.0E--6 7.37E+5 0.2 1.0 0.1 1.0 0.46 2.83 9.66E-3 · L/Kg Tetranitromethane 509148 NA 1.SE-2 NA NA 1.0 -2.05 6.7E-5 0.2 NA NA NA 0.2 7440280 NA NA 4E-1 Thallium (B} 0.2 0.5 0.01 1.0 NR NR Toluene (I) 108883 2.2E-1 NA 4.0E+2 NA NA 0.2 1.0 0.1 1.0 2.75 180 p-Toluidine 106490 NA 5.6E-2 NA 3.lE-5 NA 0.2 1.0 0.1 1.0 1.39 23.3 NA NA NA NA NA NA NA NA NA NA NA NR Total dissolved solids (TDS} Toxaphene 8001352 NA 4.4E-1 NA 3.2E-4 1.0E+3 0.2 0.5 0.1 1.0 5.5 2.55E+5 Triallate 2303175 1.3E·2 NA NA NA NA 0.2 1.0 0.1 1.0 4.57 3 1,1 00 Tributylamine 102829 3.SE-3 7.0E+0 0.2 1.0 0.1 1.0 4.46 24,200 120821 1.5E-2 3.7E+2 NA NA NA 1,2,4-Trichlorobenzene NA NA 3.7E+4 0.2 1.0 0.1 1.0 4.01 1,790 NA 2.46E+6 0.2 1.0 0.1 1.0 2.48 110 1,1,1-Trichloroethane 71556 2.2E+0 NA 1.0E+3 1,1,2-Trichloroethane 79005 3.9E-3 2.9E-2 NA 1.6E-5 NA 0.2 1.0 0.1 1.0 2.05 50.3 Trichloroethylene 79016 1.7E-3 1.0E-2 NA 1.7E-6 5.37E+5 0.2 1.0 0.1 1.0 2.71 168 Trichlorofluoromethane 75694 3.SE-1 NA 5.62E+4 5.62E+6 0.2 1.0 0.1 1.0 2.53 121 2,4,5-Trichlorophenol 95954 1.0E-1 NA 3.5E+2 NA NA NA 0.2 1.0 0.1 1.0 3.9 1,597 2,4,6-Trichlorophenol 88062 NA 7.4E-3 NA 3.1E-6 NA 0.2 1.0 0.1 1.0 3.7 381 1,2,3-Trichloropropane 96184 5.7E-3 NA 0.3 NA NA 0.2 1.0 0.1 1.0 2.26 167 1, 1,2-Trichloro-1 ,2.2-trilluoroethi 76131 2.7E+1 NA 7.67E+4 NA 9.59E+6 0.2 1.0 0.1 1.0 3.15 1.250 Triethanolamine 102716 5.0E-1 NA 5.0E+1 NA NA 0.2 1.0 0.1 1,0 -1.38 0.044 NA NA 0.2 1.0 0.1 1.0 -1.69 0.0218 Triethylene glycol March 25, 2011 112276 5.9E-1 NA NA Page 13 of 14 �Attachment 1 TABLE 4. TOXICOLOGICAL AND CHEMICAL-PHYSICAL DATA PART 201 GENERIC CLEANUP CRITERIA AND SCREENING LEVELS; PART 213 TIER 1 RISK-BASED SCREENING LEVELS (RBSLs) DOCUMENT RELEASE DATE: MARCH 25, 2011 Developed pursuant to R 299.5752 of the Administrative Rules for Part 201 Environmental Remediation of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. Scientific notation is represented by E+ or E- a value, for example 200,000 is presented as 2.0E+S. Units are as indicated in each column heading. The dataset for each hazardous substance requires 22 columns. Review all 22 columns across 2 pages when evaluating data for a specific hazardous substance. Hazardous Substance Chemical Abstract Service Number Soil Koc for Ionizing Organic Compounds at pH:.6.8 Soil-Water Distribution Coefficients for lnorgan ic Compounds at pH"6.8 (Kd) UKg UKg Henry's Law Constant at Water Diffusivity (Dw) Lower Explosive Limit In Air (LEL) unitless (HLC) Air Diffusivity (D1or D_pr O•I') 3 atm-m /mol 2 cm /s cnf/s 2s0 c Flash Point (FP) Water Solubility (S) Physical State at Standard Temperature & Pressure Molecular Weight (MW) OF ug/L unitless g/mol 165.83 Tetrachloroethylene 127184 NR NR 1.84E-2 0.072 8.2E-6 NA NA 2.0E+5 Liquid Tetrahydrofuran 109999 NR 9.63E-3 0.08 8.0E-6 0.02 6.0 1.0E+9 Liquid 72.12 Tetranitromethane 509148 NR NR NR NR 2.60E-5 0.08 8.0E-6 NA NA 85,000 Liquid 196.03 Thallium (B) 71 NR NR NR NA NA NA Inorganic 204.383 NR 6.64E-3 0.087 8.6E-6 0.011 40 5.26E+5 Liquid 92.14 NR NA 6.10E-6 0.08 8.0E-6 7.60E+6 liquid 107.17 NR NA NA NA NA 188 NR NA NA NA NA 8001352 NR NR 6.00E-6 0.0116 4.34E-6 NA NA 740 Solid 4 14 2303175 NR NR 1.93E•5 0.08 8.0E-6 NA NA Liquid 304.66 0.08 NA NA 4,000 8.0E-6 75,400 Liquid 185.4 NR NR 1.42E-3 0.03 8.23E-6 NA 222 3.00E+S Liquid 181.45 1.72E-2 0.078 8.BE-6 0.075 1.33E+6 Liquid 133.4 NR 9.13E-4 0.078 8.BE-6 0.06 NA NA 4.42E+6 Liquid 133.4 0.08 131.39 7440280 Toluene (I) 1088B3 p-Toluidine 106490 NR NR NA Toxaphene Triallate Total dissolved solids (TDS) Tributylamine 102829 NR NR 1,2.4-Trichlorobem:ene 120821 NR 1, 1, 1-Trichloroethane 71556 1, 1.2-Trichloroethane 79005 NR NR 5.60E-3 Trichloroethylene 79016 NR NR 1.03E-2 0.079 9.1E-6 1.10E+6 Trichlorofluoromethane 75694 NR NR 1.3E-1 0.0B7 9.7E-6 NA NA NA Liquid 1.10E+6 Liquid 137.38 2.4,5-Trichlorophenol 95954 1.597 NR 4.33E-6 0.0291 7.03E-6 Solid 197.5 88062 381 NR 7.79E-6 0.0318 6.25E-6 NA NA 1.20E+6 2.4,6-Trichlorophenol NA NA 8.00E+S Solid 197.5 1,2,3-Trichloropropane 96184 NR NR 3.B0E-4 0.071 7 .9E-6 NA 160 1.90E+6 Liquid 147.43 1,1.2-Trichloro-1.2,2-trifluoroeth. 76131 NR NR 0.078 8.2E-6 1.70E+5 Liquid 187.38 3.38E-19 0.08 B.0E-6 NA NA NA 102716 NR NR 5.30E-1 Triethanolamine NA 1.0E+9 Liquid 149.19 Triethylene glycol 112276 NR NR 2.61E-10 0.0427 8.06E-6 NA NA 1.00E+6 Liquid 150.1 7 March 25, 2011 Page 13 of 14 �Attachment 1 TABLE 4. TOXICOLOGICAL AND CHEMICAL-PHYSICAL DATA PART 201 GENERIC CLEANUP CRITERIA AND SCREENING LEVELS; PART 213 TIER 1 RISK-BASED SCREENING LEVELS (RBSLs) DOCUMENT RELEASE DATE: MARCH 25, 2011 DEt\ Developed pursuant to R 299.5752 of the Administrative Rules for Part 201 Environmental Remediation of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. Scientific notation is represented by E+ or E- a value, for example 200,000 is presented as 2.0E+5. Units are as indicated in each column heading. The dataset for each hazardous substance requires 22 columns. Review all 22 columns across 2 pages when evaluating data for a specific hazardous substance. Hazardous Substance Chemical Abstract Service Number Oral Reference Dose (RFD) Oral Slope Factor (SF) Chronic Inhalation Inhalation Unit Reference Risk Factor Concentration (IURF) (RfC) Occupational Relative Short Term Source Exposure Contribution Level for Drinking ($TEL) Water (RSC) Ingestion Absorption Efficiency (AEi) Dermal Absorption Efficiency (AEdl Relative Source Contribution for Soil (RSC) Soil Organic Log Octanol- Carbon-Water Water Partition Partition Coefficients Coefficient for Organic (Log Kow) Compounds (Koc) ug/m3 unitless unitless unitless unitless unitless NA NA 0.2 1.0 0.1 1.0 2.87 663 NA NA NA 0.2 0.5 0.1 1.0 5.3 1.62E+5 NA 3.5E+3 NA NA 0.2 1.0 0.1 1.0 4.09 2,080 NA NA NA NA NA 0.2 1.0 0.1 1.0 4.0 1,760 95636 1.4E-1 NA 1.23E+3 NA NA 0.2 1.0 0.1 1.0 3.67 965 1,3,5-Trimethylbenzene (I) 108678 1.4E-1 NA 1.23E+3 NA NA 0.2 1.0 0.1 1.0 3.5 708 Triphenyl phosphate 115866 1.6E-1 NA NA NA NA 0.2 1,0 0.1 1.0 4.67 39,000 tris(2,3-Dibromopropyl)phosphat, 126727 NA 1.2E+O NA 5.3E-4 NA 0.2 1.0 0.1 1.0 3.51 2 ,820 Urea 57136 NA NA NA NA NA 0.2 1.0 0.1 1.0 -2.11 0.0256 7440622 5.0E-3 NA NA NA NA 0.2 0.5 0.01 1.0 NR NR Vinyl acetate (I) 108054 8.8E-2 NA 2.0E+2 NA 5.3E+4 0.2 1.0 0.1 1.0 0.73 5.22 Vinyl chloride 75014 3.0E-3 1.4E+O 1.0E+2 8.BE-6 NA 0.2 1.0 0.1 1.0 1.5 18.5 mg/Kg-day 1 (mg/Kg-dayj 3 ug/m 88302 6.2E-1 NA NA Trifluralin 1582098 5.1 E-3 4.SE-3 2,2.4-Trimethyl pentane 540841 NA 2,4,4-Trimethyl-2-pentene (I) 107404 1,2,4-Trimethylbenzene (I) 3-Trifluoromethyl-4-nitrophenol Vanadium (ug/m3).1 UKg White phosphorus ( R) 12185103 1.5E-S NA NA NA NA 0.2 0.5 0.01 1.0 NR NR Xylenes (I) 1330207 1.8E+O NA 4.4E+3 NA 6.S1E+S 0.2 1.0 0.1 1.0 3.11 348 Zinc (B) 7440666 3.3E-1 NA NA NA NA 0.2 0.5 0.01 1.0 NR NR March 25, 2011 Page 14 of 14 �Remediation Division Michigan De arlment of Environmental Quality FOOTNOTES for Part 201 Criteria and Part 213 Risk-Based Screening Levels Document Release Date: March 25, 2011 (A) (8) (C) (D) (E) Criterion is the state of Michigan drinking water standard established pursuant to Section 5 of 1976 PA 399, MCL 325.1005. Background, as defined in R 299.5701 (b), may be substituted if higher than the calculated cleanup criterion. Background levels may be less than criteria for some inorganic compounds. Value presented is a screening level based on the chemical-specific generic soil saturation concentration (Csat) since the calculated risk-based criterion is greater than Csat• Concentrations greater than Csat are acceptable cleanup criteria for this pathway where a site-specific demonstration indicates that free-phase material containing a hazardous substance is not present. Calculated criterion exceeds 100 percent, hence it is reduced to 100 percent or 1.0E+9 parts per billion (ppb). Criterion is the aesthetic drinking water value, as required by Section 20120a(5) of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended (NREPA). A notice of aesthetic impact may be employed as an institutional control mechanism if groundwater concentrations exceed the aesthetic drinking water criterion, but do not exceed the applicable health-based drinking water value provided in the following table: Hazardous Substance Aluminum tertiarv Amvl methvl ether Conner Diethvl ether Ethvlbenzene Iron Manaanese Methvl-tert-butvl etherIMTBE) Toluene 1,2,4-Trimethvlbenzene 1, 3, 5-Trimethvlbenzene Xvlenes (F) (G) Chemical Abstract Service Number 7429905 994058 7440508 60297 100414 7439896 7439965 1634044 108883 95636 108678 1330207 NonRestdentlal Residential Health-Based Health-Based Drinking Drinking Water Value Water Value 4,100 300 910 2,600 1,400 4,000 3,700 10,000 700 700 5,600 2,000 2,500 860 240 690 1,000 1,000 2,900 1,000 2,900 1,000 10,000 10,000 Criterion is based on adverse impacts to plant life and phytotoxicity. Groundwater surface water interface (GSI) criterion depends on the pH or water hardness, or both, of the receiving surface water. The final chronic value (FCV) for the protection of aquatic life shall be calculated based on the pH or hardness of the receiving surface water. Where water hardness exceeds 400 mg CaCO3/L, use 400 mg CaCO3/L for the FCV calculation. The FCV formula provides values in units of ug/L or ppb. The generic GSI criterion is the lesser of Document release date: March 25, 2011. Page 1 of 9 �Remediation Division Michi an De artment of Environmental Qua/it the calculated FCV, the wildlife value (VW), and the surface water human nondrinking water value (HNDV). The soil GSI protection criteria for these hazardous substances are the greater of the 20 times the GSl criterion or the GSI soil-water partition values using the GSI criteria developed with the procedure described in this footnote. Hazardous Substance Acetate Acetic Acid Barium Beryllium Cadmium 21 Chromium (Ill} 0 Copper Lead0 Manganese0 Nickel Pentachloroohenol" Zinc WV HNDV FCV Formula FCV Conversion Factor (CF) ua/L ua/L UQ/L EXP(0.2732*(pH) + 7.0362) NA NA 1.3E+6 NA 1.3E+6 NA EXP(0.2732*(pH) + 7.0362) NA 1.6E+5 NA EXP(1.0629*(LnH)+1.1869) NA NA 1,200 EXP(2.5279*(LnH)-10. 7689) 130 (EXP(0. 7852*(LnH)-2. 715))*CF 1.101672-((LnH)*(0.041838)) NA NA 9,400 0.86 (EXP(0.819*(LnH)+0.6848))*CF 0.96 NA 38,000 (EXP(0.8545*(LnH)-1.702)) *CF NA 190 1.46203-((LnH)*(0.14571 )) (EXP(1.273*(LnH)-3.296))*CF NA 59,000 EXP(0.8784*(LnH)+3.5199) NA 0.997 NA 2.1E+5 (EXP(0.846*(LnH)+0.0584))*CF NA 2.8 NA EXP(1.005*(pH)-5.134) NA 16,000 0.986 (EXP(0.8473*(lnH)+0.884))*CF where, EXP(x) LnH 0 (H) (I) = = = = The base of the natural logarithm raised to power x (ex). The natural logarithm of water hardness in mg CaCO:i!L. The multiplication symbol. The GSI criterion developed here may not be protective for surface water that is used as a drinking water source. Refer to footnote (X) for further guidance. A spreadsheet that may be used to calculate GSI and GSI protection criteria for (G)-footnoted hazardous substances is available on the Department of Environmental Quality (DEQ) internet web site. Valence-specific chromium data (Cr Ill and Cr VI) shall be compared to the corresponding valence-specific cleanup criteria. If both Cr Ill and Cr VI are present in groundwater, the total concentration of both cannot exceed the drinking water criterion of 100 ug/L. If analytical data are provided for total chromium only, they shall be compared to the cleanup criteria for Cr VI. Cr Ill soil cleanup criterion for protection of drinking water can only be used at sites where groundwater is prevented from being used as a public water supply, currently and in the future, through an approved land or resource use restriction. Hazardous substance may exhibit the characteristic of ignitability as defined in 40 C.F.R. §261.21 (revised as of July 1, 2001), which is adopted by reference in these rules and is available for inspection at the DEQ, 525 West Allegan Street, Lansing, Michigan. Copies of the regulation may be purchased, at a cost as of the time of adoption of these rules of $45, from the Superintendent of Documents, Government Printing Office, Washington, DC 20401 (stock number 869-044-00155-1), or from the DEQ, Remediation and Redevelopment Division (RRD), 525 West Allegan Street, Lansing, Michigan 48933, at cost. Document release date: March 25, 2011. Page 2 of 9 �Remediation Division Michigan De artmei1t of Environmental Quality (J) (K) (L) Hazardous substance may be present in several isomer forms. Isomer-specific concentrations shall be added together for comparison to criteria. Hazardous substance may be flammable or explosive, or both. Criteria for lead are derived using a biologically based model, as allowed for under Section 20120a(10) of the NREPA, and are not calculated using the algorithms and assumptions specified in pathway-specific rules. The generic residential drinking water criterion of 4 ug/L is linked to the generic residential soil direct contact criterion of 400 mg/kg. A higher concentration in the drinking water, up to the state action level of 15 ug/L, may be allowed as a site-specific remedy and still allow for drinking water use, under Section 20120a(2) of the NREPA if soil concentrations are appropriately lower than 400 mg/kg. If a sitespecific criterion is approved based on this subdivision, a notice shall be filed on the deed for all property where the groundwater concentrations will exceed 4 ug/L to provide notice of the potential for unacceptable risk if soil or groundwater concentrations increase. Acceptable combinations of site-specific soil and drinking water concentrations are presented in the following table: Acceptable Combinations of Lead in Drinkinq Water and Soil Drinking Water Concentration Soil Concentration (mg/kg) luo/U 386-395 5 376-385 6 376-385 7 366-375 8 356-365 9 346-355 10 336-345 11 336-345 12 326-335 13 316-325 14 306-315 15 (M) (N) (0) Calculated criterion is below the analytical target detection limit, therefore, the criterion defaults to the target detection limit. The concentrations of all potential sources of nitrate-nitrogen (e.g., ammonia-N, nitrite-N, nitrate-N) in groundwater that is used as a source of drinking water shall not, when added together, exceed the nitrate drinking water criterion of 10,000 ug/L. Where leaching to groundwater is a relevant pathway, soil concentrations of all potential sources of nitrate-nitrogen shall not, when added together, exceed the nitrate drinking water protection criterion of 2.0E+5 ug/kg. The concentration of all polychlorinated and polybrominated dibenzodioxin and dibenzofuran isomers present at a facility, expressed as an equivalent concentration of 2,3,7,8-tetrachlorodibenzo-p-dioxin based upon their relative potency, shall be added together and compared to the criteria for 2,3,7,8tetrachlorodibenzo-p-dioxin. The generic cleanup criteria for 2,3,7,8tetrachlorodibenzo-p-dioxin are not calculated according to the algorithms presented in R 299.5714 to R 299.5726. The generic cleanup criteria are being held at the values that the DEQ has used since August 1998, in recognition of Document release date: March 25, 2011. Page 3 of9 �Remediation Division Michigan De artment of Environmental Qua/it • (P) (Q) (R) (S) (T) the fact that national efforts to reassess risks posed by dioxin are not yet complete. Until these studies are complete, it is premature to select a revised slope factor and/or reference dose for calculation of generic cleanup criteria. Amenable cyanide methods or method OIA-1677 shall be used to quantify cyanide concentrations for compliance with all groundwater criteria. Total cyanide methods or method OIA-1677 shall be used to quantify cyanide concentrations for compliance with soil criteria. Nonresidential direct contact criteria may not be protective of the potential for release of hydrogen cyanide gas. Additional land or resource use restrictions may be necessary to protect for the acute inhalation concerns associated with hydrogen cyanide gas. Criteria for carcinogenic polycyclic aromatic hydrocarbons were developed using relative potential potencies to benzo(a)pyrene. Hazardous substance may exhibit the characteristic of reactivity as defined in 40 C.F.R. §261.23 (revised as of July 1, 2001 ), which is adopted by reference in these rules and is available for inspection at the DEQ, 525 West Allegan Street, Lansing, Michigan. Copies of the regulation may be purchased, at a cost as of the time of adoption of these rules of $45, from the Superintendent of Documents, Government Printing Office, Washington, DC 20401 (stock number 869-044-00155-1 ), or from the DEQ, RRD, 525 West Allegan Street, Lansing, Michigan 48933, at cost. Criterion defaults to the hazardous substance-specific water solubility limit. Refer to the federal Toxic Substances Control Act (TSCA), 40 C.F.R. §761, Subpart D and 40 C.F.R. §761, Subpart G, to determine the applicability of TSCA cleanup standards. Subpart D and Subpart G of 40 C.F.R. §761 (July 1, 2001) are adopted by reference in these rules and are available for inspection at the DEQ, 525 West Allegan Street, Lansing, Michigan. Copies of the regulations may be purchased, at a cost as of the time of adoption of these rules of $55, from the Superintendent of Documents, Government Printing Office, Washington, DC 20401, or from the DEQ, RRD, 525 West Allegan Street, Lansing, Michigan 48933, at cost. Alternatives to compliance with the TSCA standards listed below are possible under 40 C.F.R. §761 Subpart 0. New releases may be subject to the standards identified in 40 C.F.R. §761, Subpart G. Use Part 201 soil direct contact cleanup criteria in the following table if TSCA standards are not applicable. TSCA, Subpart D Cleanup Standards Land Use Category Residential Nonresidential (U) 1,000 ppb, or 10,000 nnb if canned 1,000 ppb, or 10,000 nob if canned Part 201 Soil Direct Contact Cleanup Criteria 4,000 ppb 16,000 ppb Hazardous substance may exhibit the characteristic of corrosivity as defined in 40 C.F.R. §261.22 (revised as of July 1, 2001), which is adopted by reference in Document release date: March 25, 2011 . Page 4 of 9 �DEd (V) (W) (X) Remediation Division Michi an Department of Environmental Qua/it these rules and is available for inspection at the DEQ, 525 West Allegan Street, Lansing, Michigan. Copies of the regulation may be purchased, at a cost as of the time of adoption of these rules of $45, from the Superintendent of Documents, Government Printing Office, Washington, DC 20401 (stock number 869-044-00155-1 ), or from the DEQ, RRD, 525 West Allegan Street, Lansing, Michigan 48933, at cost. Criterion is the aesthetic drinking water value as required by Section 20120(a)(5) of the NREPA. Concentrations up to 200 ug/L may be acceptable, and still allow for drinking water use, as part of a site-specific cleanup under Section 20120a(2) of the NREPA. Concentrations of trihalomethanes in groundwater shall be added together to determine compliance with the Michigan drinking water standard of 80 ug/L. Concentrations of trihalomethanes in soil shall be added together to determine compliance with the drinking water protection criterion of 1,600 ug/kg. The GSI criterion shown in the generic cleanup criteria tables is not protective for surface water that is used as a drinking water source. For a groundwater discharge to the Great Lakes and their connecting waters or discharge in close proximity to a water supply intake in inland surface waters, the generic GSI criterion shall be the surface water human drinking water value (HOV) listed in the table in this footnote, except for those HOV indicated with an asterisk. For HOV with an asterisk, the generic GSI criterion shall be the lowest of the HOV, the WI/, and the calculated FCV. See formulas in footnote (G). Soil protection criteria based on the HOV shall be as listed in the table in this footnote, except for those values with an asterisk. Soil GSI protection criteria based on the HOV shall be as listed in the table in this footnote, except for those values with an asterisk. Soil GSI protection criteria for compounds with an asterisk shall be the greater of 20 times the GSI criterion or the GSI soil-water partition values using the GSI criteria developed with the procedure described in this footnote. Document release date: March 25, 2011. Page 5 of 9 �Remediation Division Michigan De artment of Environmental Quality Hazardous Substance Acf"Jlamide Alachlor Antimonv Benzene Boron Bromate Butvl benzvl ohthalate Cadmium Carbon tetrachloride Chloride Chloroethane Chromium 1111) Cvanazine 1,2-Dichloroethane trans-1,2-Dichloroethvlene 1,2-Dichlorooropane 1, 3-0 ichforooropene N, N-Dimethvlacetamide 1,4-Dioxane Ethvfene dibromide Ethvfene alvcol Hexachloroethane lsoohorone lsooroovl alcohol Lead Manaanese Methanol Methvl-tert-butyl ether (MTBE) Methvlene chloride Molvbdenum Nitrobenzene Pentachloroohenol Stvrene 1,2,4, 5-Tetrachlorobenzene 1, 1,2,2-Tetrachloroethane Tetrachloroethvlene Tetrahvdrofuran Thallium 1,2,4-Trichlorobenzene 1, 1,2-Trichloroethane T richloroethvle ne Vinvl chloride (Y) Chemical Abstract Service Number 79061 15972608 7440360 71432 7440428 15541454 85687 7440439 56235 16887006 75003 16065831 21725462 107062 156605 78875 542756 127195 123911 106934 107211 67721 78591 67630 7439921 7439965 67561 1634044 75092 7439987 98953 87865 100425 95943 79345 127184 109999 7440280 120821 79005 79016 75014 Surface Water Human Drinking Water Values (HOV) (ug/L) 0.5 (M); 0.12 3.5 2.0 (M); 1.7 12 1,900 10 (M); 0.5 6.9 2.5* 5.6 50,000 170 120* 2.0 (M); 0.93 6.0 470 9.1 3.3 700 34 0.17 56,000 5.3 310 28,000 14* 1,300* 14,000 100 47 120 4 .7 1.8* 20 2.8 3.2 11 350 2.0 (M); 1.2 80 12 29 1.0 (M); 0.25 Soil GSI Protection Criteria forHDV (ug/ka) 10 88 1,200 240 38,000 200 13,000 * 110 1.0E+6 3,400 * 200 (Ml; 40 120 9,400 180 100 (M\; 66 14,000 680 20 (M); 3.4 1.1E+6 310 6,200 5.6E+5 * • 2.8E+5 2,000 940 2,400 330 (M); 94 • 530 3,300 64 220 7,000 1,400 4,700 240 580 40 (M\; 20 Source size modifiers shown in the following table shall be used to determine soil inhalation criteria for ambient air when the source size is not one~half acre. The modifier shall be multiplied by the generic soil inhalation criteria shown in the Document release date: Marc h 25, 2011. Page 6 of 9 �Remediation Division Michigan De artment of Environmental Qua/it . table of generic cleanup criteria to determine the applicable criterion. Source Size sa. feet or acres 400 sa feet 1000 sq feet 2000 SQ feet 1/4 acre 1/2 acre 1 acre 2 acre 5 acre 10 acre 32 acre 100 acre Modifier 3.17 2.2 1.76 1.15 1 0.87 0.77 0.66 0.6 0.5 0.43 (Z} Mercury is typically measured as total mercury. The generic cleanup criteria, however, are based on data for different species of mercury. Specifically, data for elemental mercury, chemical abstract service (CAS} number 7439976, serve as the basis for the soil volatilization to indoor air criteria, groundwater volatilization to indoor air, and soil inhalation criteria. Data for methyl mercury, CAS number 22967926, serve as the basis for the GSI criterion; and data for mercuric chloride, CAS number 7487947, serve as the basis for the drinking water, groundwater contact, soil direct contact, and the groundwater protection criteria. Comparison to criteria shall be based on species-specific analytical data only if sufficient facility characterization has been conducted to rule out the presence of other species of mercury. (AA) Comparison to these criteria may take into account an evaluation of whether the hazardous substances are adsorbed to particulates rather than dissolved in water and whether filtered groundwater samples were used to evaluate groundwater. (BB) The state drinking water standard for asbestos is in units of fibers per milliliter of water (f/mL} longer than 10 millimicrons. Soil concentrations of asbestos are determined by polarized light microscopy. (CC) Groundwater: The generic GSI criteria are based on the toxicity of unionized ammonia (NH 3); the criteria are 29 ug/L and 53 ug/L for cold water and warm water surface water, respectively. As a result, the GSI criterion shall be compared to the percent of the total ammonia concentration in the groundwater that will become NH 3 in the surface water. This percent NH3 is a function of the pH and temperature of the receiving surface water and can be estimated using the following table, taken from Emerson, et al., (Journal of the Fisheries Research Board of Canada, Volume 32(12):2382, 1975). Document release date: March 25, 2011. Page 7 of9 �Remediation Division Michi an De artment of Environmental Qua/it • Percent NH 3 in Aqueous Ammonia Solutions for 0-30 °C and pH 6-10 pH Temp Temp (OF) (OC) 6.0 6.5 7.0 7.5 8.0 8.5 9.0 9.5 10.0 32.0 33.8 35.6 37.4 39.2 41.0 0 1 2 3 4 5 0.00827 0.00899 0.00977 0.0106 0.0115 0.0125 0.0261 0.0284 0.0309 0.0336 0.0364 0.0395 0.0826 0.0898 0.0977 0.106 0.115 0.125 0.261 0.284 0.308 0.335 0.363 0.394 0.820 0.891 0.968 1.05 1.14 1.23 2.55 2.77 3.00 3.25 3.52 3.80 7.64 8.25 8.90 9.60 10.3 11.1 20.7 22.1 23.6 25.1 26.7 28.3 45.3 47.3 49.4 51.5 53.5 55.6 42.8 44.6 46.4 48.2 50.0 6 7 8 9 10 0.0136 0.0147 0.0159 0.0172 0.0186 0.0429 0.0464 0.0503 0.0544 0.0589 0.135 0.147 0.159 0.172 0.186 0.427 0.462 0.501 0.542 0.586 1.34 1.45 1.57 1.69 1.83 4.11 4.44 4.79 5.16 5.56 11.9 12.8 13.7 14.7 15.7 30.0 31 .7 33.5 35.3 37.1 57.6 59.5 61.4 63.3 65.1 51.8 53.6 55.4 57.2 59.0 11 12 13 14 15 0.0201 0.0218 0.0235 0.0254 0.0274 0.0637 0.0688 0.0743 0.0802 0.0865 0.201 0.217 0.235 0.253 0.273 0.633 0.684 0.738 0.796 0.859 1.97 2.13 2.30 2.48 2.67 5.99 6.44 6.92 7.43 7.97 16.8 17.9 19.0 20.2 21.5 38.9 40.8 42.6 44.5 46.4 66.8 68.5 70.2 71.7 73.3 60.8 62.6 64.4 66.2 68.0 16 17 18 19 20 0.0295 0.0318 0.0343 0.0369 0.0397 0.0933 0.101 0.108 0.117 0.125 0.294 0.317 0.342 0.368 0.396 0.925 0.996 1.07 1.15 1.24 2.87 8.54 22.8 48.3 74.7 3.08 9.14 24.1 50.2 76.1 3.31 9.78 25.5 52.0 77.4 3.56 10.5 27.0 53.9 78.7 3.82 11 .2 28.4 55.7 79.9 69.8 71.6 73.4 75.2 77.0 21 22 23 24 25 0.0427 0.0459 0.0493 0.0530 0.0569 0.135 0.425 0.145 0.457 0.156 0.491 0.167 0.527 0.180 0.566 78.8 80.6 82.4 84.2 86.0 26 27 28 29 30 0.0610 0.0654 0.0701 0.0752 0.0805 0.193 0.207 0.221 0.237 0.254 0.607 0.651 0.697 0.747 0.799 1.33 4.10 11.9 29.9 57.5 81.0 1.43 4.39 12.7 31.5 59.2 82.1 1.54 4.70 13.5 33.0 60.9 83.2 1.65 5.03 14.4 34.6 62.6 84.1 1.77 5.38 15.3 36.3 64.3 85.1 1.89 2.03 2.17 2.32 2.48 5.75 6.15 6.56 7.00 7.46 16.2 17.2 18.2 19.2 20.3 37.9 39.6 41.2 42.9 44.6 65.9 67.4 68.9 70.4 71.8 85.9 86.8 87.3 88.3 89.0 The generic approach for estimating NH3 assumes a default pH of 8 and default temperatures of 68°F and 85°F for cold water and warm water surface water, respectively. The resulting percent NH3 is 3.8 percent and 7.2 percent for cold water and warm water, respectively. This default percentage shall be multiplied by the total ammonia-nitrogen (NH3-N) concentration in the groundwater and the resulting NH 3 concentration compared to the applicable GSI criterion. As an Document release date: March 25, 2011. Page 8 of 9 �Remediation Division Michigan De arlment of Environmental Qua/it alternative, the maximum pH and temperature data from the specific receiving surface water can be used to estimate, from the table in this footnote, a lower percent unionized ammonia concentration for comparison to the generic GSI. Soil: The generic soil GSI protection criteria for unionized ammonia are 580 ug/kg and 1,100 ug/kg for cold water and warm water surface water, respectively. (DD) Hazardous substance causes developmental effects. Residential direct contact criteria are protective of both prenatal and postnatal exposure. Nonresidential direct contact criteria are protective for a pregnant adult receptor. (EE) The following are applicable generic GSI criteria as required by Section 20120a(15) of the NREPA. Hazardous Substance Phosphorus GSI (ua/L) 1,000 Total dissolved solids (TDS) 5.0E+5 Dissolved Oxygen (DO): Cold receiving waters Warm receiving waters 2! 7,000 2! 5,000 Notes Criteria applicable unless receiving water is a surface water that has a phosphorus waste load allocation or is an inland lake. In those cases, contact the deoartment for annlicable values. If TDS data are not available, the TDS criterion may be used a screening level for the sum of the concentrations of the following substances: Calcium, Chlorides, Iron, Magnesium, Potassium, Sodium, Sulfate. Since a low level of DO can be harmful to aquatic life, the criterion represents a minimum level that on-site samples must exceed. This is in contrast to other criteria which represent "not to exceed" concentrations. DO criteria are not applicable if groundwater Carbonaceous Biochemical Oxygen Demand (CBOD) is less than 10,000 ug/L and groundwater ammonia concentration is less than 2,000 uo/L. (FF) The chloride GSI criterion shall be 125 mg/I when the discharge is to surface waters of the state designated as public water supply sources or 50 mg/I when the discharge is to the Great Lakes or connecting waters. Chloride GSI criteria shall not apply for surface waters of the state that are not designated as a public water supply source, however, the total dissolved solids criterion is applicable. (GG) Risk-based criteria are not available for methane due to insufficient toxicity data. An acceptable soil gas concentration (presented for both residential and nonresidential land uses) was derived utilizing 25 percent of the lower explosive 3 level for methane. This equates to 1.25 percent or 8.4E+6 ug/m . "ID" means insufficient data to develop criterion. "NA" means a criterion or value is not available or, in the case of background and CAS numbers, not applicable. "NLL" means hazardous substance is not likely to leach under most soil conditions. "NLV" means hazardous substance is not likely to volatilize under most conditions. Document release date: March 25, 2011 . Page 9 of9 �Remediation and Redevelopment Division Michigan Department of Environmental Quality Interim Final - August 2, 2006 RRD OPERATIONAL MEMORANDUM NO. 4 SITE CHARACTERIZATION AND REMEDIATION VERIFICATION ATTACHMENT 3 - SEDIMENTS Key definitions for terms used in this document: NREPA: Part 201: Part 213: MDEQ: RRD: U.S.EPA: Benthic Community: Bioaccumulative Chemicals: Contamination: Criteria or criterion: Facility: Release: Sediment: Surface Water: The Natural Resources and Environmental Protection Act, 1994 PA 451, as am ended Part 201, Environmental Remediation, of the NREPA Part 213, Leaking Underground Storage Tanks, of the NREPA Michigan Department of Environmental Quality Remediation and Redevelopment Division United States Environmental Protection Agency Aquatic organisms adapted for living near, on and within sediment Chemicals that tend to accumulate in the tissues of aquatic and terrestrial organisms as defined in R 323.1043(1) and Table 5 of R 323.1057 Includes hazardous substances that have been released and are present above criteria Includes the cleanup criteria for Part 201 of the NREPA and the Risk Based Screening Levels as defined in Part 213 of the NREPA and R 299.5706a(4) Includes "facility" as defined by Part 201 of the NREPA and "site" as defined by Part 213 of the NREPA Includes "release" as defined by both Part 201 and Part 213 of the NREPA Particulate matter that exists at or has settled to the bottom in surface water bodies including those of Intermittent streams, creeks, brooks, ditches, drains or wetlands Surface waters of the state as defined in R 323.1044(v) and R 323.1043(s) 1 of 26 �Remediation and Page No. TABLE OF CONTENTS 1.0 INTRODUCTION ............................................................................................................. 3 2.0 CHARACTERIZATION .................................................................................................... 4 3.0 4.0 2.1 Identification or confirmation of a release to sediments ........................................... 4 2.2 Initial characterization of the nature and extent of sediment contamination ............ 4 2.3 Sediment toxicity testing ........................................................................................... 5 SITE-SPECIFIC SEDIMENT CRITERIA DEVELOPMENT .............................................. 6 3.1 Development of site-specific sediment criteria for protection of aquatic Ii fe ............ 6 3.2 Development of site-specific sediment criteria for protection of other potential use impairments .............................................................................. 6 REMEDIATION ................................................................................................................. 6 4.1 Presumptive remedy ............................................................................................... 6 4.2 Response action monitoring and verification of remediation .................................... 6 APPENDIX A. Tables 1 and 2, Sediment Quality Guidelines, from the U.S. EPA's A Guidance Manual to Support the Assessment of Contaminated Sediments in Freshwater Ecosystems, Volumes Ill, December, 2002. ................................................................... 8 APPENDIX 8. U.S.EPA, Region 5, RCRA Ecological Screening Levels ............................... 13 RRD Operational Memorandum No. 4 Attachment 3, Sediments Interim Final 2 of26 August2,2006 �Remediation and J ••. 1.0 INTRODUCTION The particulate matter that exists at, or has settled to the bottom in lakes, ponds, streams, wetlands, and other surface water bodies is called sediment. Sediment represents an essential element of aquatic ecosystems, providing nutrients and habitat for aquatic flora and fauna essential in the aquatic and aquatic-dependent food web. Contamination of sediments by a wide variety of toxic and bioaccum ulative chemicals can negatively impact aquatic ecosystems, aquatic dependent wildlife (birds, reptiles and mammals) and human health. Many contaminants, which may be found in only trace amounts in the water column, can accumulate to elevated levels in sediments. Many of these, such as organochlorine pesticides and polychlorinated biphenyls may have been released long ago, but they continue to persi st in the environment. In addition to being sinks for contaminants, sediments can also serve as potential sources of pollutants as conditions change in the receiving water system (such as periods of anoxia, inundation/scouring from severe storms or human activity). At any Part 201 facility or Part 213 site at which surface waters or sediments have been contaminated or at which there is the potential for contamination to have reached surface waters or sediments, characterization of the nature and extent of contamination must address surface water sediments in accordance with R 299.5730, which requires: Rule 730. (1) Any remedial action plan that addresses surface water or sediments associated with waters of the state shall include site-specific cleanup criteria established QY the department on the basis of sound scientific principles and evaluation of bulks ediment chemistry, sediment toxicity and benthic community populations. Criteria shall be established considering the need to eliminate or mitigate the following use impairments, as appropriate to the facility in question: (a} Restrictions on fish or wildlife consumption. (b) Tainting of fish and wildlife flavor. (c) Degraded fish or wildlife populations. (d) Fish tumors or other deformities. (e) Bird or animal deformities or reproductive problems. (f) Degradation of benthos. (g) Restrictions on dredging activities. (h) Eutrophication or undesirable algae. (i) Restrictions on drinking water consumption or taste or odor problems. (j) Beach closings. (k) Degradation of aesthetics. (I) Added costs to agriculture, industry, or a local unit of government. (m) Degradation of phytoplankton or zooplankton populations. (n) Loss of fish and wildlife habitat. (o) Unacceptable risk through human contact as a result of absorption of hazardous substances through the skin or by incidental ingestion of sediments. (p) Other unacceptable risks to human receptors exposed to hazardous substances in sediments. (2) The basis for, and information used by the department to develop, cleanup criteria under this rule shall be made available to the public upon request. RRD Operational Memorandum No. 4 Attachment 3, Sediments 3 of26 Interim Final August 2, 2006 �Remediation and In addition to the required analysis of bulk sediment chemistry, sediment toxicity and benthic community populations, the characterization of nature and extent of contamination at a facility where sediment contamination is or may be present should include an assessment of the presence of any of the above-listed use impairments. There are no generic sediment cleanup criteria. Due to the wide range of potential use impairments, development of site-specific sediment criteria may require addressing multiple exposure scenarios. Each may require different sampling strategies for criteria development and compliance for the protection of aquatic life, wl ldlife, human health and the ecosystem. In order for the MDEQ to develop site-specific sediment cleanup criteria as required by R 299.5730(1) and provide the public information as required by R 299.5730(2), any proposal for response activities that includes the development of si le-specific sediment criteria must be submitted to the RRD project manager for MDEQ review and approval. 2.0 CHARACTERIZATJON Proper characterization of sediment must determine the potential for contaminated sediments to result in violations ofwaterquality standards (Section 20120a(15)) or use impairments specified in R 299.5730(1) and the nature and extent of contamination. Phasing the sediment characterization may be beneficial. Useful information on evaluating contam inated sediments can be found in U.S.E PA's A Guidance Manual to Support the Assessment of Contaminated Sediments in Freshwater Ecosystems, Volumes I, II, and Ill, December, 2002. (EPA-905-B02001-A, B, and C). http://www.cerc.usgs.gov/pubs/sedtox/guidance m anual.htm. 2.1 Identification or confirmation of a release to sediments Where it is suspected that sediment contamination is present, it may be advisable to conduct preliminary sampling to confirm whether there is any sediment contamination. Such initial sampling should be targeted to those areas where sediment contamination is likely to have concentrated. Such areas may include locations of groundwater contamination discharge; locations where contaminated soils, water, or waste materials entered the surface water body; and locations where fine grained materials tend to accumulate such as pools, backwaters, and the inner portions of river bends. Upstream locations, outside the impact area of the facility should also be sam pied, to differentiate the impact of the facility from that of upgradient sources or background. Results from this preliminary sampling effort should be used only to evaluate the presence or absence of contamination. This preliminary sampling effort is not intended to provide sufficient information to evaluate the risk posed by contaminants or the need for further response activities where hazardous substance contamination is present. 2.2 Initial characterization of the nature and extent of sediment contamination Where sediment contamination exists, a work plan must be prepared to determine the lateral and vertical extent of the hazardous substances contamination. Guidance for preparing a sediment sampling plan is available in U .S.EPA's Methods for Collection, Storage, and Manipulation of Sediments for Chemical and Toxicological Analyses: Technical Manual, October 2001. (EPA 823-B-01-002). http://www.epa.gov/waterscience/cs/coltectionmanual.pdf Where It is known that multiple sediment contaminants; significant "unknown" contaminants or RRD Operational Memorandum No. 4 Attachment 3, Sediments 4 of26 Interim Final August 2, 2006 �Remediation and bioaccumulative contaminants are present, it may be prudent to conduct the sediment toxicity or bioaccumulation testing discussed in Section 2.3 below in the initial phase of characterization and include the results with the characterization report. Because the results of this characterization will form the basis for development of site-specific sediment cleanup criteria by the MDEQ, the work plan must be submitted to the RRD project manager for MDEQ review and approval prior to implementation. In the initial sediment evaluation phase, the analytical data can be compared to published sediment chemical quality guideline information, which are used as screening values for the potential that the presence of hazardous substances will cause water quality standards violations or any of the use impairments identified in R 299.5730(1). Chemical values for screening sediment chemical sampling results may be found in: Appendix A: U.S.EPA's A Guidance Manual to Support the Assessment of Contaminated Sediments in Freshwater Ecosystems, Volumes Ill, December, 2002, Tables 1 and 2. (EPA-905-802001-C). http://www.cerc.usqs.gov/pubs/sedtoxlguidance m anual.htm . Appendix B: U.S.EPA, Region 5, RCRA Ecological Screening Levels http://www.epa.gov/RCRIS-Region5/ca/ES L. pdf Upon completion of the sediment characterization and comparison of the concentrations of contaminants to screening values, all of the sampling results and comparisons as well as identification of the presence any of the use impairments specified in R 299.5730(1) must be provided in a report to the RR D project manager. M DEQ staff will review the report to determine its approvability and whether additional sediment analysis and site specific sediment criteria development is necessary. 2.3 Sediment toxicity testing If upon review of the sediment characterization report, the MDEQ determines that the sediment concentrations indicate the potential for toxicity to aquatic life and/or the bloaccum ulation of sediment contaminants, appropriate sediment toxicity tests must be performed to determine whether violations of water quality standards may be occurring. A sediment toxicity sampling and analysis work plan must be submitted to the RRD project manager for prior MDEQ review and approval. Guidance for preparing an appropriate plan is available in the U.S . EPA's Methods for Measuring the Toxicity and Bioaccumulation of Sediment-associated Contaminants with Freshwater Invertebrates, March 2000, EPA600/R-99/064. http://www.epa.gov/osVcs/fr eshfact.htm I. Upon completing the sediment toxicity sampling and analysis, a sediment toxicity and/or bioaccumulation report must be submitted to the RRD project manager. MDEQ staff will review this report to determine whether there is a potential water quality violation, and whether the development of site-specific sediment criteria is appropriate. RRD Operational Memorandum No. 4 Attachment 3, Sediments 5 of26 Interim Final August2,2006 �Remediation and 3.0 SITE-SPECIFIC SEDIMENT CRITERIA DEVELOPMENT 3.1 Development of site-specific sediment criteria for protection of aquatic life If upon review, MDEQ determines that violations of water quality standards are likely to occur, site-specific sediment cleanup criteria will be developed by the M DEQ and documented along with the basis for the criteria. Response action(s) taken at a facility will need to address sediments that exceed site-specific cleanup criteria (Sec. 20118). 3.2 Development of site-specific sediment criteria for protection against other potential use impairments Site-specific chemical criteria developed to protect aquatic life may not sufficiently address all potential use impairments. The MDEQ will: 1) determine if ecological risks for other than aquatic life need further evaluation; 2) assess the potential for unacceptable risk through human contact as a result of absorption of hazardous substances through the skin or by incidental ingestion of sediments; 3) determine whether additional review of use impairments may be necessary where there is no established basis for calculating numeric or qualitative criteria (e.g., aesthetics), or if conditions warrant further consideration to address Rule 730 elements. Where appropriate, site-specific sediment criteria will be developed to protect against such other potential use impairments. 4.0 Remediation 4.1 Presumptive remedy Where after site characterization the nature and extent of sediment contamination above screening levels and any use impairments are well defined, and bioaccumulative contaminants are not an issue, it may be more cost effective or otherwise appropriate to proceed with remedy design and implementation to address contamination above the screening levels, rather than proceed with extensive toxicity testing and site-specific criteria development. Although screening levels would not be considered enforceable cleanup criteria, with the exception of bioaccumulative contaminants they would be protective and if they were met and any use impairments addressed, further response action to address sediment contamination would not be required. Response action monitoring, and verification of remediation 4.2 Facilities with sediment contamination require significant planning for remediation, operation and maintenance, monitoring, and remedy verification. A monitoring plan shou Id be developed and included in any plan for response action involving contaminated sediments. Things that need to be considered in a monitoring plan include: • • • • • The media affected ( e.g., sediment, surface water, floodplain soils, surface water, groundwater, biota); The variety of contaminants of concern and (potentially ongoing) sources of those contaminants; The area and ecological and physical conditions where remediation and monitoring will need to be performed; The spatial and temporal variability of sediments and biota to be monitored; The nature of the relationship between contaminant levels in sediment and biota; and RRD Operational Memorandum No. 4 Attachment 3, Sediments 6 of 26 Interim Final August 2, 2006 �Remediation and • At large facilities, the impact and effectiveness of multiple response actions across the facility. In some situations nonnum eric parameters such as color or the presence of waste may need to be used to monitor the effectiveness of individual actions. Physical, chemical and biological monitoring all may play a part in evaluation of the effectiveness of a response action. If remediation is designed for removal of sediments to a specific depth or some erosion-resistant surface (e.g., hardpan), bathymetric or geophysical surveys could be used to deter mine compliance with the design. Where response action is designed to meet specific concentration criteria, monitoring to assess the effectiveness of response action should include chemical concentrations in sediment, surface water or biota with comparison to cleanup criteria or to environmental and health standards. Verification of the effectiveness of response action may also need to include evaluation of any of the use impairments identified in R 299.5730(1) to assess improved conditions over time. Response actions conducted to address contaminated sediments may require a variety of permits or compliance with the substantive requirements of the relevant permitting programs (e.g., State Part 301 permits for most sampling, dredging or containment activities in surface water bodies, Federal Section 404 permits for dredging and containment activities, N PDES permits for discharge from dewatering activities). For further information regarding sediment remediation, operation and maintenance and remedy verification see, the U.S. EPA's Contaminated Sediment Remediation Guidance for Hazardous Waste Sites, December, 2006 (EPA-540-R-05-012, OSWER 9355.0-85), http://www.epa.gov/superfund/resources/sediment/pdfs/quidance.pdf. RRD Operational Memorandum No. 4 Attachment 3, Sediments 7 of 26 Interim Final August 2, 2006 �APPENDIX A Tables 1 and 2, Consensus-Based Sediment Quality Guidelines for Freshwater Ecosystems From U.S.EPA's A Guidance Manual to Support the Assessment of Contaminated Sediments in Freshwater Ecosystems, Volumes Ill, December, 2002. (EPA-905-B02-001-C). http://www.cerc.usgs.gov/pubs/sedtox/guidance manual. htm . RRD Operational Memorandum No. 4 Attachment 3, Sediments 8 of26 Interim Final August2,2006 �Table 1. Sediment quality guidelines that reflect threshold effect concentrations (TECs; i.e., below which harmful effects are unlikely to be observed; from MacDonald et al. 2000b). Threshold Effec:t Concentrations Substance Metals (m mg/kg DJJ? Arsenic Cadmium Chromium Copper Lead Mercury Nickel Zinc TEL LEL MET 5.9 6 0.6 7 0.9 55 28 42 0.2 3S 150 0.596 37.3 35.7 35 0.174 18 123 26 16 31 0.2 16 120 ERL TEL-HA28 SQAL Consensus-Based TEC 33 5 80 11 0.58 36 NG NG 9.79 0.99 43.4 70 28 35 0.1S 30 37 NG 120 20 98 NG NG 31.6 NG 35.8 NG NG NG 0.18 NG 57.2 77.4 22.7 121 Polycyclic Aromatic Hydrocarbons (PAHs; in µglkg DffJ 190 NG NG NG 400 560 400 320 370 340 400 500 600 NG 60 NG 111 750 490 4000 600 700 Anthracene Fluorene Naphthalene Phenanthrene Benz[a]anthracene Benzo(a)pyrene Cb.rysene NG NG NG 41.9 31.7 220 31.9 Dibenz[a,hJanthracene Fluoranthene Pyrene TotalPAHs RRD Operational Memorandum No. 4 Attachment 3, Sedimenls 57.1 53 NG NG 9 of26 85 35 340 225 10 10 15 230 19 16 540 470 1800 NG 400 400 32 27 NG NG 60 10 600 350 4000 31 44 260 NG 6200 176 204 108 150 166 33.0 423 NG NG 195 1610 Interim Final August 2, 2006 �Table 1. Sediment quality guidelines that reflect threshold effect concentrations (TECs; i.e.t below which harmful effects are unlikely to be observed; from MacDonald ef al 2000b). Substance TEL Polyc/,lorlnated Biphenyls (PCBs; in µglkg D w,I TotalPCBs 34.l Organochlorine Pesticides (ur µglkg Dff') 4.5 Chlordane Dieldrin 2.85 SumDDD 3.54 1.42 Sum.DOE SmnDDT NG Total DDTs 7 Endrin Heptachlor epoxide Lindane (gamma-BHC) 2.67 0.6 0.94 LEL 70 7 2 8 5 8 7 3 5 3 Threshold Effect Concentrations MET ERL TEL-HA28 200 7 2 10 7 9 of26 9 NG 8 5 3 SQAL Consensns-Based. TEC 50 32 NG 59.& 0.5 NG NG 3.24 1.90 4.88 3.16 4.16 NG 5.28 42 NG NG NG NG NG NG NG NG NG NG NG 3.7 2.22 2.47 2.37 O.Q2 2 2 1 3 0.02 110 NG NG NG TEC = Thn:shold effect concentration (from Mac:Dollllld et aL 2000a). TEL= Threshold effect level; dry weight (Smith r:t al 1996). I.EL• Lowest effeet level, dry v,,eight (Persaud et al. 1993). MET= Minimal effect threshold; dry weight (EC & MENVIQ 1992). ERL= Effects range low; dry 'Mlight (Long and Morgan 1991). TEL-HA28 • Threshold effect level for Hyalefla ar.teca; 28 day test; dry wcight (USEPA 1996). SQAL =Sediment quality advisory levels; dry weight at 1% OC (USEPA 1997). NG"" No guideline; DW - dry weight. RRD Operational Memorandum No. 4 Attachment 3. Sediments 10 of 26 Interim Final August 2. 2006 �Table 2. Sediment quality guidelines that reflect probable effect concentrations (PECs; i.e., above which harmful effects are likely to be observed; from MacDonald et aL 2000b). •Probable Effect Concentratibns Substance Metals(m mg/kgDW) Arsenic Cadmium Chromium Copper Lead Mercury Nickel Zinc PEL SEL TET ERM PEL-HA28 17 33 17 33.0 10 110 110 250 3 85 9 145 390 48 3.53 3.2 120 4.98 100 90 197 91.3 0.486 36 315 2 75 820 Polycyclic Aromatic Hydrocarbons (PAHs; in µglkg DW) Anthracene NG 3700 Fluorene NG 1600 Naphthalene NG NG Phenanthrene 515 9500 Benz[a]anthracene 14800 385 Benzo(a)pyrene 782 14400 Cmysene 862 4600 Fluoranthene 2355 10200 Pyrene 875 8500 TotalPAHs NG · 100000 Polychlorinated Biphenyls (PCBs; in µglkg DW) TotalPCBs 277 RRO Operational Memorandum No. 4 Attachment 3, Sediments 5300 100 86 170 1 61 540 Consensus-Based PEC 111 110 82 1.3 50 270 NG 149 128 1.06 33 . 540 48.6 459 170 150 140 410 280 320 845 NG 960 640 2100 1380 1600 2500 2800 3600 2200 35000 3400 S61 1170 1050 1450 1290 2230 1520 22800 1000 400 240 676 NG NG 600 800 500 700 800 . 2000 1000 410 320 490 536 lnt&lim Final 11 of26 August 2. 2006 �. ---·-------------------------· -- -- - - - - - - - - - - - Table 2. Sediment quality guidelines that reftect probable effect concentrations (PECs; i.e., above which harmful effects are likely to be observed; from MacDonald et al. 2000b) . . Substance PEL Organochlorine Pestiddes (in µglkg DJJ? 8.9 Chlordane 6.67 Dieldrin SumDDD SwnDDE Sum DDT TotalDDTs Endrin Heptachlor Epoxide Lindane (gamma-BHC) 8.51 6.75 SEL 60 910 60 Probable E/1._ect Concentrations PEL-HA28 TET ERM 30 300 .60 6 8 20 50 50 15 4450 62.4 190 710 120 NG 350 1300 500 2.74 so 1.38 10 30 9 45 NG NG NG 7 Consensus-Based PEC NG 17.6 NG NG NG NG NG NG NG 61.8 28.0 31.3 62.9 NG 572 207 16.0 4.99 PECs = probable effect coocentmions (from MacDonald et al. 2000a) ?EL= Probable effect level; dry weight (Smith et al. 1996). SEL- Severe effect level, dry weight (Persaud et al. 1993). TET = Toxic effect threshold; dry weight (EC &. MENVIQ 1992). ERM• Effects range median; dry weight (Long and Morg;,:o 1991). PEL-HA23 - Probable effect levcl for Hyalella att=z; 23-dey test; dxy weight (USEPA 1996a). NG,. No guideline; DW"' dry weight. RRD Operational Memorandum No. 4 Attachment 3, Sediments 12 of26 Interim Anal August 2. 2006 �APPENDIX B U.S.EPA, Region 5, RCRA Ecological Screening Levels, August 22, 2003 http://www.epa.gov/RCRIS-Region-5/ca/ESL.pdf RRD Operational Memorandum No. 4 Attachment 3, Sediments 13 of 26 Interim Final August 2, 2006 �Ecological Screening Levels U.S. EPA, Region 5, RCRA Chemical Air mg/m3 CAS No. Water ug/1 August 22, 2003 Sediment5 ug/kg .swv ug/kg 3s• 6.71' 6.82 e+5 4.84 e+3° 5.87' 6.82 e+5 959 1100··•· 2 9.9' 2500w 17.1 12 e+3d,z 56 1370w Acenaphthene 83-32-9 Acenaphthylene 208-96-8 Acetone 67-64-1 Acetonitrile 75-05-8 Acetophenone 98-86-2 Acetylaminofluorenc [2-J 53-96-3 Acrolein 107-02-8 Acrylonitrile 107-13-1 Aldrin 309-00-2 Ally! chloride 107-05-1 Aminobiphenyl [4-J 92-67-1 Aniline 62-53-3 Anthracene 120-12-7 Antimony (Total) 7440-36-0 Aramite 140-57-8 3.09g 1.11 e-3 1.66 e+5 Arsenic (Total) 7440-38-2 148 1 979ou 5700 Azobenzene [p-(dimethylamino)] 60-11-7 J.65° 318 40 Barium (Total) 7440-39-3 Benzene 71-43-2 Benzo[aJanthracene 56-55-3 RRD Operational Memorandum No. 4 Attachment 3, Sediments 2 3 e+5 535b 15.3 596 0.578 0,19<,> 1.52 e-3' 5270w 0.797 66" 1.2 23.9w 1.7 e-2•·• 2' 3.32x 13.4 1.22 3.05 4.ld 0.31 56.8w 0.0351 57.2u 1.48 e+6 80< 142 220d,z 9.76 14 of 26 1040 114r 142 255 0,025<,Z 108" 52 IO Interim Final August 2, 2006 �U.S. EPA, Region 5, RCRA Ecological Screening Levels August 22, 2003 Sm.iv ug/kg Chemical CAS No. Benzo[a]pyrene 50-32-8 0,014h 1sou 1520 Benzo[b]fluoranthene 205-99-2 9.07b 1.04 e+4 5.98 e+4 Benzo[ghi]perylene 191·24-2 7.64b 170' 1.19 e+5 Benzo[k]fluoranthene 207-8-9 240' 1.48 e+5 Benzyl alcohol 100-51-6 1.04' 6.58 e-+4 Beryllium (fotal) 7440-41-7 BHC [alpha-] 319-84-6 12.4b 6' 99.4 BHC [beta-] 319-85-7 0.495b 5t 3.98" BHC [delta-] 319-86-8 667' 7.15 e+4 9940 BHC [gamma-] 58-89-9 0.026· 2,37u sx Bromodichloromethane 75-27-4 Bromoform 75-25-2 Bromophenyl phenyl ether [4-] 101-55-3 Butylamine [N-Nitrosodi-n-] 924-16-3 Butylbenzyi phthalate 85-68-7 Cadmium (Total) 7440-43-9 Carbon disulfide 75-15-0 Carbon tetrachloride 56-23-5 Chlordane Chlorethyl ether [bis(2-] RRD Operational Memorandum No. 4 Attachment 3, Sediments Air mg/m3 Water ug/1 8,6h,z Ssldiment• ug/kg 1060 3,6d,k,z 540 9Jl 2Jod,z 492' I.Sh 1550 1.59 e+4 267 23d,z 1970' 239 0.151,J.k 99ou 2.22 3.67 15d,z 23.9' 94.1 1.41 240d 1450 2980 57-74-9 4.3 e-31 3.24"· 2 224" I 11-44-4 19 e+31 3520 2.37 e+4w 15 of 26 Interim Final August 2, 2006 �U.S. EPA, Region 5, RCRA Chemical Ecological Screening Levels CAS No. Chloro-1-methylethyl)ether [bis(2-] 108-60-1 Chloroaniline [p-] 106-47-8 Chlorobenzene 108-90-7 Chlorobenzilate 510-15-6 Chloroethane 75-0-3 Chloroform 67-66-3 Chloronaphthalene [2-] Air mg/m3 Water ug/1 August 22, 2003 Sediment• ug/kg SoW ug/kg 1.99 e+4 2328 146 1100 47• 291 1.31 e+4 7.168 860 5050 140d 121 1190 91-58-7 0.396b 417 12.2 Chlorophenol [2-J 95-57-8 24• 31.9 243 Chlorophenyl phenyl ether [4-] 7005-72-3 Chloroprene 126-99-8 Chromium+3 (Total) 7440-47-3 Chrysene 218-1-9 Cobalt (Total) 7440-48-4 Copper (Total) 7440-50-8 Cresol [4,6-dinitro-o-] 120 20 1.34 2.9 4.16E-2 42i,k 4.34 e+4u 400Y 166u 4730 24d 5.00 e+4' 140 1.ss1,k, • 3.16 e+4u 5400 534-52-1 23m 104 144 Cresol [m-J 108-39-4 62d 52.4 3490 Cresol [o-] 95-48-7 67° 55.4 4.04 e+4 Cresol [p-chloro-m-] 59-50-7 34.88 388 7950 Cresol [p-J 106-44-5 25• 20,2 l.63 e+5 Cyanide 57-12-5 5.2· 0.1 1 1330\V RRD Operational Memorandum No. 4 Attachment 3, Sediments 16 of 26 Interim Final Al.lgust 2, 2006 �U.S. EPA, Region 5, RCRA Chemical Ecological Screening Levels CAS No. Air mg/m3 Water ug/1 August 22, 2003 Sedim~nt' ug/kg .s.cilv ug/kg 4.88"•z 758 4.51 e-9• 3.16" 596 50-29-3 1.1 e-5"·' 4.16" 3S Di-n-butyl phthalate 84-74-2 9.71 1114 150 Di-n-octyl phthalate 117-84-0 3or 4.06 e+4 7.09 e+5 Diallate 2303-16-4 Dibenzofuran 132-64-9 Dibenz[a,h]anthracene 53-70-3 Dibromo-3-chloropropane [ 1,2-] 96-12-8 Dibromochloromethane 124-48-1 Dibromoethane [l ,2-] 106-93-4 176 Di chloro-2-bu tene [trans-1,4-J 110-57-6 4.03 Dichlorobenzene [m-J 541-73-1 273 38"·· 1315' 3.77 e+4 Dichlorobenzene [o-] 95-50-1 270 14h 294 2960 Dichlorobenzene [p-J 106-46-7 275 9.4d,z 318' 546 Dichlorobenzidine (3,3'-] 91-94-1 4.s•·· 127 646 Dichlorodifluoromethane 75-71-8 1550 Dichloroethane [ 1, 1-J 75-34-3 1240 47h 0.575 2.01 e+4 Dichloroethane [ 1,2-] 107-6-2 29.7 910h 260 2.12 e+4 Dichloroethene [I, 1-J 75-35-4 0.303 65··· 19.41 8280 DOD [4,4'-] 72-54-8 DOE [4,4'-] 72-55-9 DDT (4,4'-] RRD Operational Memorandum No. 4 Attachment 3, Sediments 452w 4•,z 449• 33" 0.32 1.84 e+4 35.2 2050 17 of 26 1230 3.95 e+4 Interim Final August2, 2006 �U.S. EPA, Region 5, RCRA Ecological Screening Levels Air mg/m3 Water ug/1 August 22, 2003 CAS No. Dichloroethylene [trans-1,2-J 156-60-5 Dichlorophenol (2,4-J 120-83-2 Dichlorophenol [2,6-) 87-65-0 Dichloropropane [1 ,2-J 78-87-5 70.6 Dichloropropene [cis-1 ,3-] 10061-1-5 5.89 398 Dichloropropene [trans-1,3-) 10061-2-6 5.89 398 Dieldrin 60-57-1 Diethyl O-2-pyrazinyl phosphorothioate [O,O-J 297-97-2 Diethyl phthalate 84-66-2 Dimethoate 60-51-5 Dimethyl phthalate 131-11-3 7.34 e+5 Dimethylbenzidine [3,3'-] 119-93-7 104 Dimethylbenz[aJanthracene [7, 12-J 57-97-6 Dimethylphenethylamine (alpha,alpha-] 122-9-8 Dimethylphenol [2,4-J 105-67-9 Dinitrobenzene [m-J 29.l Sedim~nt• ug/kg fuillv ug/kg Chemical 970d 654 784 11d,i 81.7' 8.75 e+4 1170 360",z 7.1 e-s· 333• 1,9u, z 3.27 e+4 2.38 799 110· 295 2.48 e+4 218 0.548b 6.64 e+4 1.63 e+4 300 100b 304 10-~ 99-65-0 22d 8.61 655 Dinitrophenol [2,4-J 51 -28-5 19" 6.21 60.9 Dinitrotoluene [2,4-J 121-14-2 44d,z 14.42 1280 Dinitrotoluene [2,6-) 606-20-2 81d 39.8 32.8 RRD Operational Memorandum No. 4 Attachment 3, Sediments 18 of 26 Interim Final August2,Z006 �U.S. EPA, Region 5, RCRA Chemical Ecological Screening Levels CAS No. Air mg/m3 Water ug/1 August 22, 2003 Sediment• ug/kg SoUV ug/kg 0.48" 14.5 21.8 22 e+J• 119 2050\V 4J2b 34.6 1010 298-4-4 4.02 e-2• 324 19.9 D [2,4-] 94-75-7 220· 1273 27.2 Endosulfan I 959-98-8 0.0561 3.26 119 Endosulfan II 33213-65-9 0.0561 1.94 119 Endosulfan sulfate 1031-7-8 2.22b 34.6 35.8 Endrin 72-20-8 0.036" 2.2iu•• 10.I Endrin aldehyde 7421-93-4 0.}5b 480' 10.5 Ethyl methacrylate 97-63-2 Ethyl methane sulfonate 62-50-0 Ethylbenzene 100-41-4 Famphur 52-85-7 Fluoranthene 206-44-0 Fluorene Dinoseb 88-85-7 Dioxane [1,4-] 123-91-1 Diphenylamine 122-39-4 Disulfoton 367 356 304 3 e+4 140,z 175 5160 49.7 1.9'·· 423u 1.22 e+5 86-73-7 19d 77.4" 1.22 e+5 Heptachlor 76-44-8 3.8 c-31 0.6' 5.98 Heptachlor epoxide 1024-57-3 3.8 e-31 2.47" 152 Hexachlorobenzene 118-74-1 3 e-4" 201 199 Hexachlorobutadiene 87-68-3 0.053 1· • 26.5' 39.8 RRD Operational Memorandum No. 4 Attachment 3, Sediments 19 of 26 Interim Final Augusl2,2006 �U.S. EPA, Region 5, RCRA Chemical Ecological Screening Levels CAS NQ . Air mg/m3 Water ug/l August 22, 2003 Sediment• ug/kg Sml'' ug/kg Hexachlorocyclopentadiene 77-47-4 77b 901 755 Hexachloroethane 67-72-1 s··· 584 2 596 Hexachlorophene 70-30-4 o.22s· 2.3 1 e+5 199 Hexachloropropene 1888-71 -7 Hexanone [2-] 591-78-6 Indeno ( 1,2,3-cd) pyrene 193-39-5 Isobutyl alcohol 78-83-1 Isodrin 465-73-6 Isophorone 78-59-1 Isosafrole 120-58-1 Kepone 143-50-0 Lead (Total) 105 99h,z 4.3J b 58.2 2 1.26 e+4 2001 1.09 e+5 2.08 e+4w 32.8 3.09 e-2• 55.2 3.32' 920d • 432 1.39 e+5 9940 0.132° 3.31 32.7 7439-92-1 l.}7J,k, 1 3.58 e+4u 53.7 Mercury (fotal) 7439-97-6 1.3 e-3• 1741 lOOY Methacryloni trile 126-98-7 Methane [bis(2-chloroethoxy)J 111-91-1 Methapyrilene 91 -80-5 Methoxychlor 72-43-5 Methyl bromide 74-83-9 26.5 Methyl chloride 74-87-3 2.63 Methyl ethyl ketone 78-93-3 642 RRD Operational Memorandum No. 4 Attachment 3, Sediments 57w 3.38 302w 2780w 20 of 26 0,019h 13.6 19.9 16d 1.37 235"' 1.04 e+4w 2200··· 42.4' 8.96 e+4w Interim Final August2,2006 �U.S. EPA, Region 5, RCRA Chemical Ecological Screening Levels CAS No. Air mg/m3 Water ug/1 August 22, 2003 S~!.limenl ug/kg SQUY ug/kg 1230 Methyl iodide 74-88-4 Methyl mercury 22967-92-6 Methyl methacrylate 80-62-6 Methyl methanesulfanate 66-27-3 315"' Methyl parathion 298-0-0 0.292 Methyl-2-pentanone [4-] I 08-10-1 Methylcholanthrene [3-] 56-49-5 Methylene bromide 74-95-3 Methylene chloride 75-9-2 Methylnaphtbalene [2-] 91-57-6 Naphthalene 91-20-3 Naphthoquinone [ 1,4-J 130-15-4 1610 Naphthylamine [l-J 134-32-7 9340 Naphthylamine [2-] 91-59-8 3030 Nickel (Total) 7440-2-0 Nitroaniline [m-] 99-9-2 Nitroaniline [o-] 88-74-4 7.41 e+4 Nitroaniline [p-J 100-1-6 2.19 e+4 Nitrobenzene 98-95-3 Nitrophenol [o-] 88-75-5 RRD Operational Memorandum No. 4 Attachment 3, Sediments 11.7 87.1 45.9 2.46 e-3• 0.01 1.58 2800g 168 9.84 e+5w 170h,z 25.1' 4.43 e+5 8.91 e-2b 8.19 e+6 77.9 6.5 e+4w 344 4780 80.l 940• 159' 4050w 330b 20.2' 3240 13•,z 176" 99.4 2s,9i,k,• 2.27 e+4" 1.36 e+4 3160 220"'' 145' 1310 1600 21 of 26 Interim Final August 2, 2006 �U.S. EPA, Region 5, RCRA Chemical Ecological Screening Levels CAS No. Air mg/m3 Water ug/1 60" August 22, 2003 Sediment' ug/kg 13.3 Soil" ug/kg 5120 Nitrophenol (p-J 100-2-7 Nitroquinoline-1-oxide [4-] 56-57-5 Nitrosodiethylamine [N-] 55-18-5 Nitrosodimethylamine [N-] 62-75-9 0.0321w Nitrosodiphenylamine [N-] 86-30-6 545 Nitrosomethylethylamine [N-] 10595-95-6 1.66w Nitrosomorpholine [N-] 59-89-2 70.6w Nitrosopiperidine [N-] 100-75-4 6.65"' Nitrosopyrrolidine [N-] 930-55-2 12.6w Parathion 56-38-2 O.OJ3•·d 0.757 0.J4Y Pentachlorobenzene 608-93-5 0.019"•• 24• 497 Pentachloroethane 76-1-7 56.48 689 1.07 e+4 Pentachloronitrobenzene 82-68-8 Pentachlorophenol 87-86-5 Phenacetin 62-44-2 Phenanthrene 85-1-8 Phenol 108-95-2 Phenylenediamine [p-] 106-50-3 Phorate 298-02-2 3.628 0.861 0.496 Phthalate [bis(2-ethylhexyl)J 117-81-7 o,3q,z 182' 925 RRD Operational Memorandum No. 4 Attachment 3, Sediments 122 7688 0.68 22.8 69.3w 7090 4.oJ· p, z 2.3 e+4i 119 l.17 e+4 4.31 3.6' 204" 4.57 e+4 180° 49.1 1.2 e+5 6160w 22 of 26 Interim Final August 2, 2006 �U.S. EPA, Region 5, RCRA Chemical Ecological Screening Levels CAS No. Air mg/m3 August 22, 2003 Sediment1 ug/kg ~ ug/1 SoW ug/kg 9900\V 140 Picoline [2-] 109-6-8 Polychlorinated biphenyls 1336-36-3 1.2 e-4"• 1 59.su 0.332 Polychlorinated dibenzo-p-dioxins PCDD-S 2.78 e-7b 0.011 1.99 e-4 Polychlorinated dibenzofurans 51207-31-9 0.0386 Pronamide 23950-58-5 13.6x Propionitrile 107-12-0 Propylamine [N-nitrosodi-n-] 621-64-7 Pyrene 129-0-0 Pyridine 110-86-1 Safrole 94-59-7 Selenium (Total) 7782-49-2 Si Silver (Total) 7440-22-4 0.12'·· 5001 4040 Silvex 93-72-1 30"• 2 675' 109' Styrene 100-42-5 J2d,z 2542 4690 Sulfide 18496-25-8 Tetrachlorobenzene [1 ,2,4,5-] 95-94-3 49.8\V 1.87 544 13.7 0.38 195u 7.85 e+4 23808 106 1030w 404 0.946 27.6 3.58 Tetrachlorodibenzo-p-dioxin [2,3, 7,8-] 1746-1-6 3"·' 12522 2020 3 e-9•·• 1.2 e-41 1.99 e-4 2.25 e+5 Tetrachloroethane [l,1,1,2-J 630-20-6 22.5 Tetrachloroethane [ 1, 1,2,2-] 79-34-5 353 3801 850 127 Tetrachloroethene 127-18-4 69 45• 990 9920 RRD Operational Memorandum No. 4 Attachment 3, Sedime nts 23 of 26 Interim Final August 2, 2006 �Ecological Screening Levels U.S. EPA, Region 5, RCRA Chemical Air mg/m3 CAS No. Water ug/1 August 22, 2003 Sediment' ug/kg fuillv ug/kg Tetrachlorophenol [2,3,4,6-) 58-90-2 1.2··· 129' 199 Tetraethyl dithiopyrophosphate 3689-24-5 13.9b 560 596 Thallium (Total) 7440-28-0 10· 56.9 Tin (Total) 7440-31-5 180d 7620 Toluene 108-88-3 • Toluidine [5-nitro-o-] 99-55-8 8730 Toluidine [o-] 95-53-4 2970w Toxaphene 8001-35-2 Trichlorobenzene [ 1,2,4-] 120-82-1 Trichloroethane [ 1, 1, 1-] 71-55-6 Trichloroethane [ 1, 1,2-J 1040 253f 1220' 5450 1,4 e-4•,z 0.077' 119 30"•' 506l2 1.11 e+4 4170 76d,z 213' 2.98 e+4 79-0-5 11.6 soo•,z 518' 2.86 e+4 Trichloroethylene 79-1-6 1220 47h,z 112' 1.24 e+4 Trichlorofluoromethane 75-69-4 5150 Tricblorophenol [2,4,5-J 95-95-4 Trichlorophenol [2,4,6-] 88-6-2 Trichloropropane [ 1,2,3-] 96-J 8-4 Trichlorphenoxyacetic acid [2,4,5-] 93-76-5 686g 5.87 e+4 596 Triethyl phosphorothioate [0,0,0-] 126-68-1 58.2b 189 818 Trinitrobenzene [Sym-] 99-35-4 Vanadium (Total) 7440-62-2 RRD Operational Memorandum No. 4 Attachment 3, Sediments 1.64 e+4 1.41 e+4 4,9d 208 9940 3360 3.32 376\Y 12··· 24 of 26 1590 Interim Final August 2, 2006 �U.S. EPA, Region 5, RCRA Chemical Ecological Screening Levels CAS No. Vinyl acetate 108-5-4 Vinyl chloride 75-1-4 Xylenes (total) 1330-20-7 Zinc (Total) 7440-66-6 Air mg/m3 Water ug/l August 22, 2003 Sediments ug/kg SoUV ug/kg 359 248& 13 1.27 e+4w 0.221 930• 202 646 135 27d,z 433• 1 e+4x 6S.7J,k,z 1.21 e+5" 6620Y •=Michigan water quality standards, Rule 57 water quality values, July 23, 2003. Available at: http://www.michigan.gov/deq/0,1607,7-135-3313_3686_3728-11383--,00.html. The water ESL data for acenaphthene, BHC (gamma), cyanide and parathion are Michigan (final chronic value or FCV) Tier I criteria. Likewise, water ESL data for dieldrin, dioxin, DDT, endrin, hexachlorobenzene:, hexachlorobutadiene, mercury, PCB' s and toxaphene represent wildlife values (see Notes at end of these footnotes for dioxin, DDT, mercury and PCB's). All ofthe remaining data are Tier II values. b = Water Ecological Screening Level (ESL) based on exposure to a mink (Mustela vison). 0 = Indiana water quality standards, Title 327, Article 2, of the Indiana Administrative Code, Feb. 4, 2002. Available at: http://www.ai.org/1egislative/iac/t03270/a00020.pdf The water ESL for toxaphene is from the Indiana chronic aquatic criterion for all waters outside of mixing zones (see Table 1 under Rule 1 of 327 lAC 2-1-6 Minimum Surface Water Quality Standards at the above Internet site). The remaining water ESL data are either wildlife values (for dioxin, DDT, mercury and PCB 's) or Tier I1 values for the Indiana Great Lakes Basin (see Great Lakes Basin Criteria and Values Table as developed under Rule 1.5 of 327 IAC Article 2 as referenced above). d = Ohio water quality standards, Chapter 3745-1 of the Ohio Administrative Code, Dec. 30, 2002. Available at: http://www.epa.state.oh.us/dsw/rules/3745-l .html The water ESL data for endrin and parathion are Ohio aquatic life Tier 1 criteria from the Outside Mixing Zone Average (OMZA). Wildlife values are available for dioxin, DDT, mercury and PCB's. All of the remaining data are Ohio aquatic life Tier II values from the O:MZA. See Ohio summary tables for water quality criteria and values along with reference on the development ofTier I criteria and Tier II values. • = Water ESL based on exposure to a belted kingfisher (Ceryle alcyon). f = Minnesota water quality standards, Rule 7052.0100, Subpart 2 (water ESL data for arsenic & benzene represents aquatic life chronic standards and dioxin, DDT, mercury and PCB's represents wildlife values), April 13, 2000. Rule 7050.0222, Subpart 2, Feb. 12, 2003. Available at http://www.revisor. leg.state.nm.us/arule/7050/0100.html and http://www.revisorJeg.state.mn.us/arule/7052/0222.html & = Region 5, RCRA Interim Criteria, based on Aquire database with acceptable review codes and endpoints (life cycle). Must have eight or more acceptable studies (i.e., chronic and/or acute). h = GL WQI Tier II value as presented in: Suter, G. W. n and Tsao, C.L. 1996. Toxicological benchmarks for screening potential contaminants of concern for effects on aquatic biota, l 996 Revision. ES/ER/TM-96/R2. Available at: http://www.esd.oml. i:wv/proerams/ecorisk/ecorisk. html RRD Operational Memorandum No. 4 Attachment 3, Sediments 25 of 26 Interim Final August2,2006 �U.S. EPA, Region 5, RCRA Ecological Screening Levels August 22, 2003 ; = U.S. EPA 2001 Update of Ambient Water Quality Criteria for Cadmium (EPA 822-R-01-001). i = U.S. EPA National Recommended Water Quality Criteria: 2002 (EPA 822-R-02-047) 3 k = For hardness-dependent metals (beryllium, cadmium, chromium+ , copper, lead, nickel and zinc), freshwater chronic criteria are based on soft water with a total hardness of 50 mg/Las CaCO3 • Soft water is common within Region 5 and this water ESL may be recalculated when site specific water baroness is less than 50 mg/L. 1 = U.S. EPA Ambient Water Quality for Chloroalkyl Ethers (EPA 440/5-80-030). No definitive data available concerning chronic toxicity. The water ESL is based on no adverse effects for a chronic toxicity embryo-larval test of the fathead minnow. m = U.S. EPA Ambient Water Quality for Nitrophenols (EPA 440/5-80-063). The acute value of230 ug/1 was adjusted with an uncertainty factor of ten for 2,4-dinitrophenol and 4,6-dinitro-o-cresol since no chronic criteria are available. n = Wisconsin Surface Water Quality Criteria and Secondary Values for Toxic Substances, NR 105.07(1)(b), Sept. I, 1997. Available at: http://www.legis.statc.wi.us/rsb/code/nr/nr100.html 0 = Illinois water quality standards, Title 35, Part 302.208, Dec. 20, 2002. Available at: http://www.ipcb.state.il.us/SLR/IPCB nndIEPAEnvironmentaIRe m1 lations-Title3 5.asp P =The criterion for pentachlorophenol is pH dependent and is based on a pH of 6.5. q = U.S. EPA Ambient Water Quality for Phthalate Esters (EPA 440/5-80-067). A chronic value of 3 ug/L that resulted in significant reproductive impairment was adjusted with an uncertainity foctor of ten. ' = Environment Canada. September 199f Interim Sediment Quality Assessment Values. Ecosystem Conservation Directorate. Evaluation and Interpretation Branch. ·• = Unless noted otherwise, all Sediment ESLs were derived using equilibrium partitioning (EqP) equation and the corresponding water ESL. Note: Sediment ESL=~ x Water ESL x 0.01. 1 = Ontario Ministry of the Environment. August 1993. Guidelines for the Protection and Management of Aquatic Sediment Quality in Ontario. u = Consensus based threshold effect concentrations (TEC) as presented in MacDonald et. al. 2000. Development and evaluation of consensus-based sediment quality guidelines for freshwater ecosystems. Arch Environ Contam Toxicol 39:20-31 (see Table 2). The TEC for mercury had a high incidence of toxicity and was not used. These values do not consider bioaccumulation nor biomagnification. v =Unless noted otherwise, all Soil ESLs are based on exposure to a masked shrew (Sore:c cinerus). w = Soil ESL is based on exposure to a meadow vole (Microtus pennsylvanicus). x = Soil ESL is based on exposure to a plant. Y = Soil ESL is based on exposure to soil invertebrates (e.g., earthworms). z = New ESL data is lower than the previous table. Notes: New ESL data are displayed in bold font and a dashed line (e.g.,-----) is used to show when data was deleted from the previous table (i.e., supporting data was inadequate). All six states in EPA Region 5 have the same water ESL's for dioxin, DDT, mercury and PCB's which are based on a wildlife value. A summary report will be created on the development of soil benchmarks including equations, criteria and references. Likewise, a report will be prepared on the development of water benchmarks that are based on mink and belted kingfisher exposure. RRD Operational Memorandum No. 4 Allachment 3, Sediments 26 of 26 Interim Final August 2, 2006 �Artifact 24 �UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REG ION 5 77 WEST JACKSON BOLiLEVARD CHICAGO, IL 60604-3590 REPLY TO THE ATTENTION OF ,!UN 2 0 ZOil Re: S-61 Wolverine World Wide Tannery Site, Rockton, MI This letter is in response to your petition to the U.S. Environmental Protection Agency, Region 5, dated June 21, 2011 requesting an investigation of the Wolverine World Wide, Inc. Tannery Site, located at 123 North Main St. in Rockford, Michigan under the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA). EPA has conducted a Preliminary Assessment, as described in 40 C.F.R §§ 300.419(c) and 300.420, to determine whether a CERCLA action is warranted at the Site. The Michigan Department ofEnviromnental Quality (MDEQ) and EPA's Superfund Removal Program participated in the Preliminary Assessment. It is likely that contaminated groundwater discharges to the Rogue River. Elevated levels of several inorganjc contaminants have been detected mthe surface and subsurface soils in portions of the Site. Chromium, arsenic and mercury have been detected in sediment samples. Arsenic and chromium have also been detected in groundwater. However, EPA has concluded that a CERCLA removal response action is not warranted at this time, since the concentration and quantity of known contaminants do not present an immediate and substantial threat of release. The Preliminary Assessment did determine that the Site scores above 28.50 in EPA' s Hazardous Ranking System and merits further investigation. MDEQ has recommended that the Site be referred to it'tor further investigation under "Other Cleanup Authority". EPA has concluded that such a referral is appropriate for the Site. MDEQ has based its request for referral upon receiving a letter from Wolverine World Wide (dated June 11, 2012) in which they commit to working with the MDEQ under Section 14b of Part 201. Section 14b requires MDEQ approval of the work being conducted. We wish to emphasize, however, that by making such a referral~ EPA does not waive our authority under CERCLA. We will periodically review the work being performed at the Site, retain our enforcement authority, and reserve the ability to resume the status oflead agency if necessary. For this Site, MDEQ has agreed to report to EPA at least twice a year. Recycled/Recyclable • Prinled witn Vegatable Oil Based Inks on 100% Recycled Paper (50% Poslconsumer) �If you have any further questions, please contact Nuria Muniz, NPL Coordinator, at (312) 886-6312 or nuria.muniz@epa.gov or Tom Williams, Associate Regional Counsel, at (312) 886-5932 or tom.wiluams@epagov. Sincerely, /wet<~ Richard C. Karl, Director Superfuod Division Enclosures 1. Letter from MDEQ dated June 14, 2012 2. CERCLA Preliminary Assessment Report dated June 15, 201 2 �STATll OF MICHIGAN DEPARTMENT OF ENVIRONMENTAL QUALITY LANSING DEti RICK SNYDER DAN WYANT GOVERNOR DIRECTOR June 14, 2012 Ms. Nuria Muniz National Priorities List Coordinator United States Environmental Protection Agency Region 5 77 West Jackson Boulevard (SR-6J) Chicago, Illinois 60604-3507 ' Dear Ms. Muniz: SUBJECT: Preliminary Assessment Recommendation for the Wolverine World Wide Former Tannery Sile, U.S. EPA ID No. MIN000510613 The Wolverine World Wide Former Tannery site is a former tannery operation that operated from 1908 to 2010. The site was operated by and is currently owned by Wolverine World Wide ()NWW). The site is localed along the east bank of the Rogue River in a residential/commercial area of the city of Rockford, Michigan. A designated recreational trail ls located on the west side of the site along the bank of the Rogue River. A limited environmental Investigation of the site has documented releases of tannery related wastes including hexavalent chromium. The company has demolished most of the plant buildings and has reported that they have removed some wastes from the site. The waste contaminant concentrations, however, were never documented and confirmation samples were never collected after the removal of the wastes. There are four known source areas that are relatively small but the full extent of these areas has not been determined. Groundwater samples from on-site monitoring wells have indicated an observed release of contaminants from the site to the groundwater. All residents within the 4-Mile Target Distance Limit (TDL) utilize groundwater for drinking water. Residents In the immediate vicinity of the site are served by the city of Rockford municipal system which utilizes groundwater wells localed approx1imately one mile southeast of the site. Analysis of sediment samples collected from the Rogue River adjacent to the site has indicated an observed release of contaminants to the surface waler pathway. The surface water pathway includes Rum Creek which flows through the site, the Rogue River downstream of the site, and the Grand River downstream of its confluence with the Rogue River. The surface water pathway is used for recreation and fishing, and there are several miles of wetland frontage and several state and federal threatened and endangered species located within the 15-Mile TDL. There is no documented evidence of adverse population exposure to soil contamination at the site. The main area of the former plant that was demolished is covered with topsoil and is fenced to restrict access. Analyses of soil samples from the west side of the site in the area of the recreational trail have revealed some elevated levels of contamination. Visual observations from along the bank of the river in this area noted waste material, such as leather and shoe scraps, tannery building flooring brick, and concrete rubble are present. CONSTITI.JTION HALL • 526 Vv£ST ALLEGAN STREET • P.O. BOX 30473 • LANSING, MICHIGAN 4890~7973 www.mlchlgen.gov/deq • (800) 662-9278 �Ms. Nuria Muniz 2 June 14, 2012 There are no documented samples that indicate air contamination originating from the site. Also, there is a limited potential for air migration of contaminants via windblown particulates or gas migration from the site due to the site being fairly well vegetated. Due to the documented releases of contaminants to the groundwater and surface water pathways, the limited data evaluating only a portion of the site, and the history of the site and site operations, the site does qualify for further Superfund Site Assessment activities. However, WWW has indicated in a letter to the Michigan Department of Environmental Quality {MDEQ), dated June 11, 2012 (see enclosure), that they plan to proceed with further site investigation and remediation activities under Section 14 b of Part 201, Environmental Remediation, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. Proceeding in this manner will req1,1fre WWW to submit response activity plans to the MDEQ for review and approval. WWW also slated that they are willing to discuss with the MDEQ and U.S. Environmental Protection Agency (U.S. EPA) the scope of any needed site investigation work. Given that WWW has committed to working under Section 14b of Part 201, MDEQ staff recommends that the site be designated as "Other Cleanup Activity." It is our understanding that the U.S. EPA wants to see progress toward investigation and remediation and a continued commitment from WWW for this designation lo remain in effect. If at any time in the future the U.S. EPA determines that actions at the site are not effectively remediating contamination concerns a t the site, the MDEQ will work with the U.S. EPA and WWW to either address the issues or possibly redeslgnate the site's status in the Superfund Site Assessment process. Please contact me if you have any questions regarding this recommendation. Any questions you may have regarding the Preliminary Assessment may be directed to Mr. Joseph Walczak, Brownfield Assessment Program Manager, Site Assessment and Site Management Unit, Superfund Section, Remediation Division, at walczakj@michigan.gov or 517-335-2151 . Sincerely, Dtt1£11 lo l)eAJt~ Daria W. Devantier, Chief Site Assessment and Site Management Unit Superfund Section Remediation Division devantierd@michigan.gov 5 17-373-8436 Enclosure cc: Mr. David Kline, MDEQ Mr. Joseph Walczak, MDEQ Site Files - Wolverine World Wide Former Tannery, Kent County �Artifact 25 �T Permit No. 73 Rockford, Ml 49341 Volume 29, No. 27, Thursday, July 5, 2012 EPA turns tannery site back to Wolverine, MDEQ by BETH AlTENA One year after beginning an investigation into the potential leak of contaminants on the Wolverine Worldwide (WWW) former tannery site and surrounding areas, the federal Environmental Protection Agency (EPA) has returned authority to local agencies while reserving the ability to resume control if necessary. The EPA was petitioned June 2011 by three Rockford residents, Lynn McIntosh, Grant Medich and Gail Mancewicz. In a June 27 letter to Wolverine attorney Michael Robinson, the EPA states that the federal Preliminary Assessment requested by citizens on June 21 has been completed. The letter states that under the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) the EPA has one year to conduct a study unless it determines that such assessment is not appropriate. The Michigan Department of Environmental Quality (MDEQ) and EPA's Superfund Removal Program participated in the assessment and found: "Elevated levels of several inorganic contaminants have been detected in the surface and subsurface soils in portiO{IS of the Site . Chromium , arsenic-.-.~~-and mercury have been detected in sediment samples. Arsenic and chromium have also been detected in groundwater. It is likely that contaminated groundwater di scharges to the Rogue River. However, the EPA has concluded that a CERCLA removal response action is not warranted at this time, since the concentration and quantity of known contaminants A public meeting held jointly by the Michigan Department of Environmental Quality and the does not present an immediate and federal Environmental Protection Agency drew a large crowd in April. The subject was the progress of a study of the former Wolverine tannery property. The study was prompted by substantial threat of release." petition of three individuals in Rockford concerned with potential contamination from the site. The letter continues, noting i• I I. ( �Inside this week's Squire ... • Education Blackboard -page 8 • Cruise to Cedar Rock - page 8 • Plainfield Avenue/ Northland Drive Directory -page 9 • Rockford High School Honor Roll -pages 16-17 • Rockford Middle School Honor Rolls in the EPA's Hazardous Ranking System and merits further investigation. On June 14 a letter from the MDEQ recommends further investigation under "Other Cleanup Authority." "The EPA has concluded that such a referral is appropriate for the Site. MDEQ has based its request for referral upon receiving your [Wolverine'sl letter (date June 11 , 2012) in which Wolverine Worldwide inc. commits to working with the MEDQ." With this decision in hand, WWW will develop an assessment plan to continue the evaluation of the property. The plan will be reviewed and approved by the MDEQ, and WWW will decide what further steps need to be taken, if any, based on the plan. In a Jetter dated June 14 from the EPA's Nuria Muniz to the MDEQ, Muniz states that the property in question was operated Please see EPA, page 7 - pages 18- 19 • Local sports - page 21 • In Your Own Backyard - page 22 Cheek out our amazing meat department, Check out our Healthy Living section! ATF investigating local fire The National Response Team (NRT) of the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) has been activated Beyond The Rock crew runs video production at Big Ticket Festival by KRIS DEYOUNG Loud music, famous bands, world-renowned speakers, thousands of fans and, most importantly, elephant cars are all part of this year's Big Ticket Festival, which took place at Allegan County Fairgrounds June 14-16. The Big Ticket Festival is one of the largest Christian music festivals in the state of Michigan. It is a ministry run by the nonPlease see VIDEO, page 5 The Beyond The Rock crew gets the opportunity to run a large part of the video production for the Big Ticket Festival. by request from the Michigan State Police to investigate a fire at Nelson's Speed Shop,4566 South Greenville Road, in Greenville. A fire was reported to the Montcalm Township Fire Department Friday, June 22, at approximately I :30 a.m. Montcalm Fire reported heavy flames through the roof of the structure upon arrival. The Greenville Daily News reported that 11 fire departments and about 75 firefighters fought the blaze and cleared the scene I 0-12 hours later. The fire reportedly started in the back of the business, where fuel and oil was stored. The structure and contents are a total loss. The structure occupies approximately 50,000 square feet and the total estimated loss exceeds Please see FIRE, page 5 �+- Page 7 The Rockford Squire, Thursday, July 5, 2012 From page 1 Consignment shop offer~ free lunch as thank-you as a tannery from 1908 to 2010. She continues that there are four known source area<; that arc relatively small but the full extent of these areas has not been determined. The letter says groundwater samples from wells indicated an observed release of conraminates from the site to the groundwater and that residents in the area utilize groundwater for drinking water. "Residents in the immediate vicinity of the site are served by the city of by ERIN COLE Rockford municipal "The concentration system which utilizes and quantity of For 10 years Gild the Lily, a consignment shop groundwater wells located approximately known contaminants located in Rockford, has sold top-quality secondhand women's clothing , home decor and furniture . They are one mile southwest of does not present more than just a shop, though; they are a valuable part the site." an immediate and of the community. "There is no docIn 2010, Kimberly Johnson and Carol Keller, ownu mcn t cd evidence substantial threat of ers of Gild the Lily, started a monthly event, called of adverse popula- release." tion exposure to soil - Michigan Department of "First Friday." 1t started as a way to give back to the contamination at the Environmental Quality and the community after being blessed by the community's site;' wrote Muniz. Environmental Protection Agency continued support for the store. "First Friday" takes place on the first Friday of She also stated that there arc no documented samples that indicate air every month. As a thank-you for its valued customers, contamination originating from the site. "Also there is Gild the Lily offers a free catered lunch for them to a limited potential for air migration of contaminants via enjoy as they shop and socialize . Each event supports a specific charity, and 10 perwindl;Jluwn particulates or gas migration from the site due cent of the proceeds made during the day are donated. to the site being fairly well vegetated." City Manager Michael Young called the recommenda- Since it began, "First Friday" has raised approximately tion "very good news" and said, "The findings do indicate $4,500 for charities. North Kent Community Services (NKCS) is the further investigation is warranted based on the preliminary assessment and the historic use of the site. This is nut sur- charity sponsored for July's "First Friday" event prising and something we have been told and expecting on July 6, 2012. NKCS helps out families in need for some time. However, due to the areas which have been by providing them with food, clothing, and health characterized as 'relatively small,' that there is no evidence care products. According to Sandy Waite, NKCS executive direcof adverse population exposure and because ufWWW's history of cooperation- the MDEQ recommended to the EPA tor, NKCS sees the needs go up twice a year, around the that this will be addressed under 'OtherCleanupAuthmity... holidays and during summer, especially for kids who Ironically this is where WWW and MDEQ were just over don ' t fall under the free-and-re.duced lunch program a year ago prior to the residents' petition being submitted. in the summer. "The people we are helping aren't strangers . They This is also what the City formally requested as part of our are the people next door. neighbors helping neighbors," involvement in the process." Waite said. ln an effort to boost efforts for the NKCS, Gild the Lily wilt also be collecting both food and health care uFirst Friday" a monthly event at Gild the Lily items at the store during the "First Friday" event. Gild the Lil y is located at 450 E. Division (10 Mile Rd.), Rockford. They can be reached at (616) 863-8491. Cedar Springs Area Chamber reborn The Cedar Springs Chamber of Commerce is pleased to announce the organization's resurgence. Sixteen businesses .in the Cedar Springs area have banded together to found a new Cedar Springs Area Chamber of Commerce. The group has been meeting regularly over the last couple of months, as well as communicating through e-mail and Facebook about what they hope to bring to businesses and the community through the new Chamber. "This rebirth is an exciting time for the business community, as they look ahead to what Cedar Springs could become," -said interim preside11t Shawn Kiphart. "The new chamber plans to organize community events, and offer resources to businesses such as advertising, communications, a voice. representation aud support with local and state government issues, business education, and more." The chamber is now legally incorporated, and is working Oll adopting their bylaws and setting up a fee structure. The businesses have talked about hosting a meet and greet with legislative candidates, creating new community events to draw business downtown such Please see CHAMBER, page 15 �Artifact 26 �. CO/./CR.ETE (/r:N D S~I J...J • L0Afj£]:) lNTO 'vV4tTING-- tRUCK:S r-- !_uyusf di.,, ~o/1 Jf.,ny Ieap/s e-f So,., ,,. J C4'h~r~t< rL.wicv..J -F,,#tf\ .s ;~: ~t,s1 ;)olo A"!:}tfs f eJo/1 �Artifact 27 ��������������Artifact 28 �5 t'-; I SanV\p/•~ / WWW ~NlveR'l Soil Excawai-ldnS ( ~ JC> -~1 7 R~l{p,"'., )J.J; .51TE : - Site: Soil Sam ,. 10cuydof contaminated soil removed • 1 250 cu yd of soil removed (per CERCLA report) 2a 4 soil samples: S-6, -7, -8, -BA N~E ,, / ' 3 soil samples: S-3, -4, -5 / ~ sampling & soil renioval ~ANO:Llfil?, ' ,> NO~E ... _,, 2017 ,. ' , NONE NQNE NONE ' NONE ' ' NONE NONE NONE NONE .... " t40NE ' NONE NONE ,,. ,; ...... 3 ~ ....... ,,. ' NONI: NONE NONI: ' 4 removed ~ 5 NONE 6 Covesediment !JotJIS ...... ,,,. Rose & Westra Work Plans ; } R Nt: ,:,~ NO testing of soils, Comments: .,. .... Pump House sediment, soil 7 1 soil sample: wrong location sediment, or water pre-demo or during demo by www or DEQ XRF screening but NO soil sampling 5 samples (wrong location) NO soil removal ' NONE ,; ' .... NO~E ' NOJl.,E XRF screening but !:40 soil sampling NONE ' NONE NONE NONE! NONE ,, ,_ ' ,.., ' NONE .;, Work Plan 1 Round 3 sampling by WWW l\iONE NONE NONE NONE NONE NONE NONE XRF screening but N_Qsoil sampling Round 2 Round 1: Three CERCLA: split monitoring wells samples EPA & installed b WWW W\/1/W , ~ ...... 1 soil sample: S-2 (flawed) ., N01-.JE ' ·N~✓ ., 2b ... Proposed 2016 2015 2014 2013 2012 2011 2010 Hot Spot as of 11/1 7/2017 .... I Soil Excavation '~ / ,I' NO soil testin (pore water/ MW sampling only) NO soil testin ~ NONE NONE Work Plan 3 Work Plan 2 (N. of Creek) NOT DEQ a roved "' .. WorK Plan 4 : PFAS testing in limited locations ~ .=.This..1 O_cy_reprnsents _the_ONLY_waste..record produced.by.Wolverine. for.the,entir~.15-acre.demolition .......................l...................................1... .............................. Republic Services manifest #127442, dated 11/23/10, taken to Ottawa Co. LF) I ,.,. = NO soil samples tested for PFAS pre-2017 ,..,. �Artifact 29 �Transcript of Interview with Earl Ario Tefft: February 23, 2017 DETAILS: Mr. Tefft, former employee of Bell Pick-up, was interviewed by Janice Tompkins in his home, 16078 Northland Drive on February 23, 2017, regarding off-site disposal of Tannery sludge and other wastes in Rockford, Michigan and Plainfield Township. MS. TOMPKINS: Hi, this is Janice Tompkins, and I am with Earl Tefft, and it is February the MR. TEFFT: -- 23rd -- MS. TOMPKINS: -- 23rd of 2017, and it is around 2:35 on this day, and I am a concerned citizen. I'm also a retired Department of Environmental Quality staff. I've worked in water division for 31 -- or water-related programs for DEQ -for 31 years approximately. And I retired in [sic] November first of 2010. I am with Earl Tefft. He is -- he had some interaction with Wolverine and we're about to let Earl tell us a little bit about those interactions. So Earl, would you first again give me your full name? MR. TEFFT: Earl Ario Tefft. MS. TOMPKINS: And your date of birth is? MR. TEFFT: April 15, 1940. MS. TOMPKINS: And your mother's maiden name is? MR. TEFFT: Ostrom. MS. TOMPKINS: Thank you. Can you just give me a really broad brush of your general employment history? MR. TEFFT: I've had a lot of jobs. Starting with on the farm, and then I went in the Navy and went active duty and came out and went into the Reserve program with a total of 30 years. And I worked for Bell Pick-up, and I had a gas station in Rockford, or ran a gas station. Bell Pick-up, I worked on a route to start with, and John Douthett signed a contract with Wolverine Worldwide to take care of all their junk and sludge and what-have-you. MS. TOMPKINS: And John Douthett is who? MR. TEFFT: Douthett is the man that owns the Bell Pick-up services. EAT Interview Transcript 1 �MS. TOMPKINS: Ok, continue about this contract with Wolverine. MR. TEFFT: All right, and they had a 24-hour system that they, you know, haul sludge out of, and it was out of a disposal plant, which is behind the tannery in Rockford. MS. TOMPKINS: Can you describe -- when you say the disposal plant -- what was included, what did the -- what consisted of the disposal plant? MR. TEFFT: Well, inside the building -- it was a cement block building -- and inside the building was a machine that they had to have a couple operators to run the machine and they had different chemicals that they mixed with whatever was coming from the tannery to turn grey. Some of it was fairly solid and some of it was like water. MS. TOMPKINS: Ok. [pause] So they have a building and inside there was this process where they mixed the tannery waste with this [sic] other chemicals -- MR. TEFFT: -- right -- MS. TOMPKINS: -- to create -- MR. TEFFT: -- sludge. MS. TOMPKINS: Sludge. MR. TEFFT: All right, and then that was dumped into buckets. They were, I think, about six feet wide and eight feet long, maybe five foot [sic] deep. MS. TOMPKINS: So six by five by eight. MR. TEFFT: Yeah, roughly. MS. TOMPKINS: Ok. So, deep ... MR. TEFFT: And they had two arms with chains hooked onto the buckets that swung onto the truck, and then you had a hook that it would hook into a pin when you dumped. MS. TOMPKINS: So was your truck like a flatbed that these buckets when up onto -- MR. TEFFT: -- yes, right -- EAT Interview Transcript 2 �MS. TOMPKINS: -- and it had some kind of metal arms -- MR. TEFFT: -- one on each side -- MS. TOMPKINS: -- that would actually pick up these large bucket-like containers? MR. TEFFT: Mmm-hmm [affirming]. MS. TOMPKINS: And they would be lifted up straight and then set -- MR. TEFFT: -- onto the bed. MS. TOMPKINS: On the bed, ok. Was there any top or covering on these containers? MR. TEFFT: No, none. Nothing. MS. TOMPKINS: Ok. Were they pretty full to the top? MR. TEFFT: Some of them were. MS. TOMPKINS: So when you drove -- MR. TEFFT: -- they would splash. MS. TOMPKINS: They would splash onto the road? MR. TEFFT: Mmm-hmm [affirming]. MS. TOMPKINS: Ok. MR. TEFFT: In town, we had to clean them up, so we worked with the fire department and washed the streets and got 'em fairly clean. MS. TOMPKINS: So, what was your -- how did your day start when you were going to go to this treatment disposal area? When would you start, and what would you find when you got there? MR. TEFFT: Well, I'd drive my truck or motorcycle or whatever I had down to the disposal plant and talk to the operator and he would tell me how many buckets he had done, you know, the night before, and so then I would -if I had one that was almost full, I would pull it out and, of course you had to replace it with an empty, but then load that up and take it to the dump and then come back and do the same thing on the ones that he had EAT Interview Transcript 3 �setting [sic] there from overnight and take them to whatever dump we were using. MS. TOMPKINS: Ok. Normally, how many did you normally see in a day? MR. TEFFT: Well, a lot of that depended on how much [sic] hides they were running. But anywhere from two to ten. MS. TOMPKINS: Ok. [pause] So, once you loaded up this truck with these large dumpster-like buckets, where did you take them to? MR. TEFFT: Well, different places. Some up on 12 Mile Road, some up on the East Beltline near 4 Mile Road, out on House Street west of Rockford. MS. TOMPKINS: So the one by 12 Mile, was that just west of what's now considered the White Pine Trail -- MR. TEFFT: -- yes -- MS. TOMPKINS: -- before it crosses -- MR. TEFFT: -- it ran right along the railroad tracks, which is the White Pine Trail. MS. TOMPKINS: Ok. So the one that was by the East Beltline, was that the landfill that was formerly an operation near 4 Mile Road and East Beltline? MR. TEFFT: Yes. MS. TOMPKINS: In Plainfield Township? MR. TEFFT: Yep. MS. TOMPKINS: How were the drums, or were there drums as well as -- MR. TEFFT: -- some of them. MS. TOMPKINS: What did the drums look like? MR. TEFFT: They're 55-gallon drums. Metal. MS. TOMPKINS: Ok. Was that contained [sic] the same sludge? MR. TEFFT: No. EAT Interview Transcript 4 �MS. TOMPKINS: Did it have the the same material? MR. TEFFT: That had other stuff. And I never knew what was in 'em. MS. TOMPKINS: Were they covered? Was that covered? MR. TEFFT: Yeah, it was a sealed drum. MS. TOMPKINS: How often did you have these sealed drums? MR. TEFFT: Oh golly. Not real often. But we had a regular dump truck we hauled those in. MS. TOMPKINS: Ok. And you'd take them to the same three locations? MR. TEFFT: Yep. Normally we took them to East Beltline. MS. TOMPKINS: Ok. [long pause, sound of writing] Were you ever -- when you picked this stuff up -- did you ever ask them any questions about whether or not what this material was, was it safe? MR. TEFFT: Well, they used to joke with each other, you know, "don't get it on your skin, it'll eat ya". [chuckles] MS. TOMPKINS: Ok. [pause, sound of writing] MR. TEFFT: What was in it, I have no idea. MS. TOMPKINS: Ok. Did they ever tell you it was safe? MR. TEFFT: Oh yeah. "Don't worry about it." "You're good to go." MS. TOMPKINS: Did they use the word "it's safe"? Or just "don't worry about it"? MR. TEFFT: Pretty much, you know, "it's all right, don't worry about it, just ..." MS. TOMPKINS: Ok. [long pause] There was -- this is something I forgot to ask, so I'm going to go back -- what was the timeframe, what was the timeframe that you were working for Bell's, that this was occurring? MR. TEFFT: Mid-60's. EAT Interview Transcript 5 �MS. TOMPKINS: So you don't, you can't give me more -- MR. TEFFT: -- probably '65, '66. I worked for Bell for about 13 months. MS. TOMPKINS: Ok. [pause] Did you notice, what were the things that when you were around the sludge, did you notice anything about it related to -- MR. TEFFT: -- well, it'd burn your eyes and burn your nose. Sometimes, not always, but sometimes. MS. TOMPKINS: Did it have an odor? MR. TEFFT: Yes, it stunk like high heavens. [pause, sound of writing] MS. TOMPKINS: So when you were at the Plainfield Township landfill, how did you unload the materials? MR. TEFFT: All right. Which one? There's two Plainfield Township dumps. MS. TOMPKINS: This is the one on 4 Mile and East Beltline. MR. TEFFT: Ok, ok. That had a pit that was probably 25, 30 feet deep and you'd back up to the edge of the pit and just dump. MS. TOMPKINS: Did the -- did the buckets fall in? MR. TEFFT: No, 'cause when you put it in gear and your arms would come up but you had two chains on each side and would hook to the dump. Well -- MS. TOMPKINS: -- to the buckets? MR. TEFFT: To the buckets. Like, if this was your bucket, it'd have two chains on each side. So it'd pick it straight up and then move it out to the back. And then as you're moving to the back, you had a hook in the middle, and there was a bar on the bucket that would come into the hook so it would dump it rather than slide it off. MS. TOMPKINS: Ok. MR. TEFFT: If the hook wasn't there, it would just slide off and sat [sic] on the ground level. EAT Interview Transcript 6 �MS. TOMPKINS: Ok. And then you would load it back onto -- the empty bucket then would be loaded back on the truck? MR. TEFFT: Nope, it was already on the truck. All it did was dump it and then just come back and set [sic] on the bed. MS. TOMPKINS: How did you get multiple buckets then to dump? MR. TEFFT: You only took one at a time. MS. TOMPKINS: Oh, ok. So it would be one of these buckets at a time, each time you would go out, and then do it one at a time, and then go back to the tannery and pick up another one and take it out? [sounds of affirmation from Mr. Tefft] Ok. Do you know if the pit appeared lined or not? MR. TEFFT: It wasn't. MS. TOMPKINS: Ok. How could you tell that it wasn't? MR. TEFFT: It was just dirt. MS. TOMPKINS: Ok. MR. TEFFT: They had a -- MS. TOMPKINS: -- was it clay dirt? MR. TEFFT: No, it was kind of a sandy loam. MS. TOMPKINS: So in your opinion, it was a sandy loam. MR. TEFFT: Yep. MS. TOMPKINS: That's what it looked like. So when you went to House Street, what was that like? So when you took these sludge buckets out there, to House, what did -- tell me what happened. MR. TEFFT: All right, they had trenches that were probably six, eight feet wide and six, eight feet deep, and ran all the way across the field. And you just kept backing up and dumping and when you got up to almost the ground level, you went, you know, went down the line until the trench was filled and then they'd take a bulldozer or something and level the ground out. EAT Interview Transcript 7 �MS. TOMPKINS: Would they level the ground out while you were there -- MR. TEFFT: -- no -- MS. TOMPKINS: -- while you went onto the next trench? Did you leave it -- you just -- MR. TEFFT: -- once I dumped, I went back to Wolverine. MS. TOMPKINS: Ok. And so, I'm trying to picture what you're saying, so is the same process the same -- this bucket's there, this kind of comes up and tips -- MR. TEFFT: -- yep -- MS. TOMPKINS: -- and then it hooks, and it kinda dumps out ... How did you control it coming out? MR. TEFFT: Ok, if you can ... I have a coffee cup here. All right, here's your hook. As it tips, it would tip like this. All right? And then your arms -- you can use the handle as your arm -- and your arm, when you're dumped, it would bring it right back up level. MS. TOMPKINS: Ok. So, your finger -- MR. TEFFT: -- now, if the pin, you control that pin from inside the cab. And 'cause it was up all the time. And when you dropped it down, then it would, when you pick it up, your arms would come all the way back behind the truck, like, assuming this is the bed of the truck, it would pick it up like this and [sound of mug hitting table] set it down on the ground. MS. TOMPKINS: After it was empty? MR. TEFFT: Mmm-hmm [affirming]. MS. TOMPKINS: Ok. MR. TEFFT: Well, even if it was full. [sound of mug hitting table] But if you didn't have that pin on there, it wouldn't dump. MS. TOMPKINS: Ok. And the pin was at the bottom of the dumpster? MR. TEFFT: Yeah. EAT Interview Transcript 8 �MS. TOMPKINS: That's where you're showing your finger is. MR. TEFFT: No, the pin was -- the hook -- was on the truck and then you had a hole in the dumpster that had a rod going through it or a pin, and that's what caught. MS. TOMPKINS: Ok. So you could -- so you drove slowly while this bucket was kinda tipped, and then just go, you just -- MR. TEFFT: -- no. You stop. Dump. Put back on the bed and go. MS. TOMPKINS: And then come back and get another one? MR. TEFFT: Uh-huh [affirming]. MS. TOMPKINS: And then dump just where you left off in the trench before? Had they covered it by the time you came back? MR. TEFFT: No. MS. TOMPKINS: So you -- MR. TEFFT: When I was at House Street, I never saw anybody that was covering. MS. TOMPKINS: Ok. MR. TEFFT: Would get a trench filled, and then they would -- somebody would come and cover it, and I have no idea who that was. MS. TOMPKINS: How did you know somebody covered it? Did you go back? MR. TEFFT: Well, you can see where there's a pile of dirt that was leveled out. MS. TOMPKINS: Ok. MR. TEFFT: That's why I knew someone had leveled it out. MS. TOMPKINS: Did you ever dump in the same -- did they ever dig trenches in the same place? That you re-did the sludge? MR. TEFFT: Well, once you got done with that trench, they'd move, you know, toward the road further and build another trench. EAT Interview Transcript 9 �MS. TOMPKINS: Ok. So I'm looking at a viewer's map from Kent County. And this shows that piece of property that Wolverine owned and it shows House Street. And just to the ... is that south? MR. TEFFT: Well, this is south, and this runs along the expressway. MS. TOMPKINS: Yep. MR. TEFFT: And this is north and south here. MS. TOMPKINS: And that's Herrington, becomes Herrington. So you entered on House Street. MR. TEFFT: Yep. Right in here somewhere. MS. TOMPKINS: Ok, so -- MR. TEFFT: -- and then went right up north. And where this light is -- I think if I remember right, that's where we started our trenches. MS. TOMPKINS: So this on the map is where there seems to be -- we're looking at Wolverine's property, where it's highlighted. And to my understanding they still own this, and the first -- the very top part -- is wooded. MR. TEFFT: Yes. MS. TOMPKINS: And then you begin to see much more sandy, open soils. MR. TEFFT: Mmm-hmm [affirming]. MS. TOMPKINS: And so what you're saying is, probably directly across -- MR. TEFFT: -- this was all open field when we were dumping. MS. TOMPKINS: Even this area here? MR. TEFFT: Yep, yep. MS. TOMPKINS: Ok, was this open field too? MR. TEFFT: I think so. MS. TOMPKINS: Ok. But where you think you started dumping, if we took what now is EAT Interview Transcript 10 �Brent Street and drove that, or take that right back, it's kind of like there's a beginning area -- MR. TEFFT: -- probably if you extended it right to the end. MS. TOMPKINS: Yeah. MR. TEFFT: But we didn't go up in here. MS. TOMPKINS: So you didn't go up into the area where the development is now. MR. TEFFT: No. We just -- MS. TOMPKINS: -- so you went behind it to the -- would that be the east? MR. TEFFT: If you draw the line right along here, this was the area we dumped. MS. TOMPKINS: Ok. And so in that year that you did it, did you get all the way down to House Street with the trenches? MR. TEFFT: No. MS. TOMPKINS: So how far do you think you came down? MR. TEFFT: I would say, where this little line is here, if you go all the way across, you're probably right in there somewhere. MS. TOMPKINS: Ok. And that took about a year? To fill up those trenches? MR. TEFFT: Well, between that and the other two places we were dumping. MS. TOMPKINS: Right. But at least on this property, to do the trenches that you were doing, that took about a year to get -- MR. TEFFT: -- right -- MS. TOMPKINS: -- down to where this other point comes in, that other piece of property, and it goes across. Okay. MR. TEFFT: Now, one of the things I just happened to remember ... [pause] They were trying to experiment a little bit and use it as fertilizer for farmers. MS. TOMPKINS: Oh man. Ok. How do you know that? EAT Interview Transcript 11 �MR. TEFFT: Word of mouth. MS. TOMPKINS: From employees who were there? MR. TEFFT: I was -- yep -- I'm going to say yes but, you know, I can't remember exactly who it was, but they were, you know, joking about using it for fertilizer. MS. TOMPKINS: So this came from Wolverine staff, not from your boss -- MR. TEFFT: -- right, no -- MS. TOMPKINS: -- or -- MR. TEFFT: -- the boss didn't know anything about farming. MS. TOMPKINS: So they were just sayin' -- and what were they joking about it [sic]? What were they laughing about? What made it funny to them? MR. TEFFT: Well, at that time you had barnyard manure and you had commercial fertilizer. And all of a sudden they're using sludge as a fertilizer, and everybody thought that was a little odd. MS. TOMPKINS: Why did they think it was odd? MR. TEFFT: It just seemed, you know, out of the realm, you know ... MS. TOMPKINS: Did they have any -- did any of the employees express that they had concern for it? MR. TEFFT: No. Not that I remember. MS. TOMPKINS: Ok, so it wasn't -- MR. TEFFT: -- it just seemed, you know, like using dirt instead of flour -- MS. TOMPKINS: -- ok-- MR. TEFFT: -- when you're making a cake, you know, it just -- it just seemed like it wasn't supposed to be. MS. TOMPKINS: Ok. So did they -- did they think there was enough nutrients--when they EAT Interview Transcript 12 �were experimenting, did you know if they did any type of testing on that sludge before they applied -- MR. TEFFT: -- that was after -- it was after I'd moved on that they were trying that. MS. TOMPKINS: So you didn't hear that while you were working for them? MR. TEFFT: Nope, no, but they tried that afterwards. But I heard that farm on the corner of Oak and 10 Mile, that they experimented with that farm. But I don't know how good it was or anything. MS. TOMPKINS: Ok. MR. TEFFT: And that was owned by Vance Harger. MS. TOMPKINS: Ok. [long pause; sound of writing, shuffling papers, breathing, coughing] MS. TOMPKINS: Ok. Did you ever take two buckets at a time out there? MR. TEFFT: No. You couldn't. Only one would fit. [pause] As I say, we hauled a lot of buckets out there, but one at a time. MS. TOMPKINS: So what would you estimate in a 24-hour period, five days a week, that the tannery produced how many buckets? MR. TEFFT: Probably 800, 820, 810, somewhere in there. (After his review of the draft transcript of the February 23, 2017 interview, Mr. Tefft realized he meant to say he estimates that Wolverine produced between 100 -120 buckets per week or about 20/Day. This correction was added to the final transcript before Mr. Tefft signed and notarized this document on June 30, 2017. He fully attests to the accuracy of this correction. MS. TOMPKINS: Ok. [pause, sound of shuffling papers] Did you ever have to dispose of anything else besides just the sludge? MR. TEFFT: That we dumped out on House there? Yeah, what they call grease. Underneath, actually was in the tannery, it was a shoot going, you had to go underneath the building almost and -- MS. TOMPKINS: -- so it was like a pit? EAT Interview Transcript 13 �MR. TEFFT: It was. And they had one dumpster in there that you'd have to drag out and it'd hook onto and put on, but that was a fairly low-sided dumpster and the only dump that -- oh maybe once a month -- but that was all the, you know, crud and stuff. They called it grease but it was ... [pause] it was rotten smelling. MS. TOMPKINS: Ok. MR. TEFFT: It smelled a lot like rancid bacon. MS. TOMPKINS: Who was Butch Ellis, and what was his job? MR. TEFFT: All right, Butch worked for Wolverine, and he was an operator at the disposal plant. MS. TOMPKINS: So would you talk to him, or have any -- MR. TEFFT: -- oh yeah -- MS. TOMPKINS: -- things when you went to get the stuff? MR. TEFFT: Always had to catch up on world news. [chuckles] MS. TOMPKINS: Did he ever help you load or tell you anything about loading, or -- MR. TEFFT: -- well, when he was working nights, what the operator would do was take my truck -- I called it my truck but it belonged to Bell, but anyway -take my truck and pull the dumpster out and then set it aside, and then in the morning I would pick up however many they had hauled out and go dump 'em. MS. TOMPKINS: Ok. [sigh, cough] So in your conversations with Butch Ellis, did he ever express any concern about what they were doing, or frustrations over the operations or anything like that? MR. TEFFT: Not that I can remember. MS. TOMPKINS: Did you, while you were there, did you ever see them having to stop the process and clean things out of that pit? MR. TEFFT: Now, you're talking pit, you mean the grease pit? MS. TOMPKINS: Yeah, underneath the thing where they have -- did you ever see it where EAT Interview Transcript 14 �they had to stop things because pipes had broken or slowed down or anything in that year that you were there? MR. TEFFT: Not that I remember. MS. TOMPKINS: Ok. MR. TEFFT: You gotta remember, that was mid-60's. [chuckles] MS. TOMPKINS: Yes, you're doing extremely well! I don't know that I could remember all ofthis stuff. So where would you take this, dispose of this grease? Where did that go? MR. TEFFT: Well, some of it went to East Beltline 4 Mile and some of it went to the one out on House. Whichever we were dumping at at the time. MS. TOMPKINS: Did that, was that liquid enough that it would still go into a trench easy by just -- MR. TEFFT: Yeah. It was more like oil than it was grease -- MS. TOMPKINS: -- ok-- MR. TEFFT: -- the consistency of it. MS. TOMPKINS: And it was -- it smelled rancid? MR. TEFFT: Yeah, it was nasty. MS. TOMPKINS: Ok. MR. TEFFT: And it always had a -- MS. TOMPKINS: -- and that was about once a month -- MR. TEFFT: -- yeah, and it always had a scum on the top, about two, three inches and when you went to dump it, it would break that seal and, oh my God, it was terrible. [chuckles] MS. TOMPKINS: Ok. [pause] So did you wear any protective gear at all? MR. TEFFT: Just a pair of gloves. And I did that on my own because I wanted to keep my hands clean. EAT Interview Transcript 15 �MS. TOMPKINS: Have you had any health concerns since working there? MR. TEFFT: As far as, you know, have I had cancer and that kind of stuff, I had colon-rectal, which I had radiation, chemo, and surgery. MS. TOMPKINS: Ok. [pause] What made you willing to contact the concerned citizen group, to make you want to share your story? MR. TEFFT: Well actually, I didn't contact anybody. Mrs. McIntosh contacted my son and somehow had a conversation with my son, and he told her that I worked for Bell and what I was doing, and then he contacted me and then Mrs. McIntosh contacted me, by telephone. And she came to the house a couple times and did an interview. MS. TOMPKINS: Ok. And what made you be willing to be interviewed? MR. TEFFT: Well, I guess ... [pause] you try to right a wrong, even though at the time I didn't know I was wrong. That, those areas, there's an extreme amount -or extreme high level of cancer, you know, and some areas like out on House, I understand there was [sic] two or three children that passed away from cancer, and they figured it was because of that sludge. MS. TOMPKINS: Ok. MR. TEFFT: And I feel bad about that because I was partially responsible. You know, I realize that ignorance is no defense, but the reason I did that was I had to have a job to feed my family. MS. TOMPKINS: Right. And again, you had no idea. MR. TEFFT: No. MS. TOMPKINS: And they told you it was ok. MR. TEFFT: Yep. MS. TOMPKINS: So it was later on as you began to hear things that made you cause to wonder if it could have been related to the sludge that you disposed of. MR. TEFFT: And it probably was. But, it was, what, a couple years ago that I met Mrs. McIntosh. Might have been three. But two or three years. I'm old, I keep forgetting things. [chuckles] EAT Interview Transcript 16 �MS. TOMPKINS: You're doing well. [pause] So, was it really on House St. where there were cancer, or was it by north, by Cahill? MR. TEFFT: I don't know where Cahill is. MS. TOMPKINS: That's on the other side of 10 Mile. Where your son lives? MR. TEFFT: Oh, he lived on Knollcrest. MS. TOMPKINS: Knollcrest? Ok. So, did you also hear that there was possibly some people got cancer [sic] by House too? MR. TEFFT: Yes. And in this settlement right here I heard that there was two or three kids. Now I don't know, I was just told that. MS. TOMPKINS: Ok. Do you remember by who? MR. TEFFT: No. MS. TOMPKINS: Ok. So in the development that's off Herrington, on streets Brittany and Brent, you heard that there was possibly some cancer cases there? MR. TEFFT: Mmm-hmm [affirming]. MS. TOMPKINS: Ok. And again, you wondered -- did anybody else in conversation wonder about it, or did you just, as soon as you heard that it was Brent -- you thought of the possible -- MR. TEFFT: Well, my granddaughter was three when she got cancer. And they lived on Knollcrest at the time. And through the course of conversation with different people they said, oh yeah, over there off on Herrington, in that new development, you know, they've got kids that had cancer. So I never checked it out, you know, to see if it was true or untrue, or how many there was [sic], or nothing. MS. TOMPKINS: Ok, well I really appreciate you taking time to do this interview with me. And do you have anything else you want to add before we end? MR. TEFFT: No, not really. MS. TOMPKINS: Ok. So again, I appreciate the time. EAT Interview Transcript 17 �INTERVIEWEE: Printed name:_ _ _ _ _ _ _ _ _ _ _ _ _ _ __ Date: _ _ _ _ _ _ _ __ Signature: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ Earl Ario Tefft Date: _ _ _ _ _ _ __ 16078 Northland Dr.NE, Sand Lake, Ml 49343 INTERVIEWED BY: Printed name: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ Date: _ _ _ _ _ _ __ Signature: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ Janice Tompkins Date: - - - - - - - - NOTARIZED BY: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ Date: _ _ _ _ _ _ _ __ EAT Interview Transcript 18 �Artifact 30 �Michigan Department of Environmental Quality Water Resources Division WATER QUALITY MONITORING REQUEST DIG. Completion of this form is voluntary. SubmiSllion of this form is not required. MAILING ADDRESS PHONE# '> . / ,39 /V. .A!onrcJ-e-CITY O (f\: M.I" /'...Oc/:µ7rcf ..-. E-MAIL ADDRESS STATE , /' Cc. l"'r (.,,aa { da ,;__:_2 ¼of~¼ Section: ~ - Town: T_ · ·._ , R~iige: R ~ . Township: :...__:__. County: ~r 2-~ll.,-,~[F -Kt,c J:::~J PLEASE DESCRIBE THE REASON FOR MONITORING, LIST ANY QUESTIONS YOU WOULD LIKE ANSWERED, AND SPECIFY THE MONITORING PARAMETERS DESIRED: •C;{-ze.,-,~ CCRi:. Ch# /or?-7- ·f ern-? ~/~a.£ . /~6t {J.Je~ JP ~ /anner1 ~ /llow ~fa /2a:s r(?.$u/f tJ{. co--xe,/1.E..· __,, 4/LC lm;acf re~e0fty -/1v /4 ~ - _;fcXj'u( ~ Yec:e,-,f . Aav,r.. Onl'I Kti/-vi. . /4n--io(.1~--d~ ~lve:,./1.L Ub/ /p{ /¾J~/'f- CERLLA -/he. o.kvf .it:1-11--i A/. Ata1,,.J ~ <'«l:'/;d /~3 J C:o :?ce,--ned Clr<2.. /~r7'!edraf~ W,k ,,-l_ of J ~-1-- . /4.s. £:~:, ccnpf.ek:d.- EPA P,t?li.~~no,,-i /4se..ssn---t3")f_; ll"}Cr(!~UcP, looks b,aA o--wl . s ~ /I~ kol 1;, 71-tk SC--t,~U U/a,.,n2r ce_rb1;,,.., ,Ke/ arr?a~ ·U Jher e -/'Ae.r-e- wo~ a. /of- _oF :!iE~C l<u.,,-, -of'-F oluI,~ fat-? et/~nfrJn /hflU/ d/reo.r.- -#--e Na /c,--- /2::ts a- ~~vtoi~y, _- f{/~ <3/:/2f <t/c1r>~ 411 Sea.lb/1~1 --11·/I cl< al.~.., a-1{) ftw. se..e::l,'a-e,f- ..t:e~lft.i ha..c.- _C L, If latitude and longitude coordinates are not listed above, please attach one or more maps or drawings of suggested sampling locations Of possible). Include in the map or drawing nearby roads and other landmarks. The decimal degrees fonnat of latitude/longitude coordinates is preferred (e.g.. 42. 123456, -84, 123456), though not required. • • Please e-mall, mail, or fax completed fonn to: . ?✓ciu.~~ I a.--,d n-r~ 4r<2--- ric lu~ ., t-u,JCi·· --/h,~ _,6_4-d :./(/;;/fa,, •ra3~f . Jeff Varricchione Department of Environmental Quality Water Resources Division P.O. Box 30458 Lansing, Michigan 48909-7958 varricchionej@michlgan.gov Fax: 517-373-9958 EQP5892 /4~cJ) : C.~, h ?e-,,,J .a.>e.--- c-o--ic c:r,,.-wc.R /4, ~ r✓-v~ &,,-,Jc documenf<?d- ~ a-...,,{ /s ,'///t?,A £+,// ab°"/- 1a1orI c_. t<.J,a,/t2r.c- ~df 4 cc(>u . ~ co.,,"PrrN>'l::t~ -1;/J</ ct4k.°,,;A:rf,,,,,..p RPrrn.~-h,b,,, .\I} Aas- kc>-, ; ,,.. -lh/-(° a,-.ac. ' � https://digitalcollections.library.gvsu.edu/files/original/ec91a2f69050008f26517db3cd1f7ac9.pdf 485d5558649b4bc17fe986d0f10c3a2b PDF Text Text Artifact 31 �MI/DEQ/WRD-15/031 MICHIGAN DEPARTMENT OF ENVIRONMENTAL QUALITY WATER RESOURCES DIVISION AUGUST 2015 STAFF REPORT A BIOLOGICAL SURVEY OF THE ROGUE RIVER WATERSHED KENT COUNTY, MICHIGAN AUGUST 2013 INTRODUCTION Objective Qualitative biological surveys of the Rogue River watershed (Hydrologic Unit Code 04050006) were conducted by staff of the Michigan Department of Environmental Quality (MDEQ), Water Resources Division (WRD), Surface Water Assessment Section (SWAS), during August 2013. The surveys were performed according to the SWAS Procedure 51 (MDEQ, 1990; Creal et al., 1996) at five stations (Figure 1), to evaluate biological communities and physical conditions of selected locations. Additional targeted monitoring was completed throughout the watershed to address specific concerns in Cedar Creek in Cedar Springs and the Rogue River and Rum Creek in Rockford. Background and Historical Sampling The Rogue River watershed is within the Southern Michigan Northern Indiana Till Plain (SMNITP) ecoregion (Omernik and Gallant, 1988). The SMNITP is characterized by lacustrine clay and silt soils, and historically white oak-white pine forest. The Rogue River is a natural river with a primarily agricultural watershed. Biological, chemical, and physical habitat conditions of the Rogue River watershed were monitored at 23 sites by the MDEQ, WRD, in 2003 (Rockafellow, 2004) and at 21 sites in 2008 (Walterhouse, 2009). In 2003, all macroinvertebrate ratings were acceptable or excellent and habitat ratings were good or excellent except for one marginal site on Nash Creek at Phelps Avenue. Rum Creek, assessed at 10-Mile Road for its coldwater fishery, was dominated by brown trout and mottled sculpin and also included brook trout and bluegill. Trout represented 50 percent of the fish; therefore, this stream is meeting its coldwater designation. In 2008, all macroinvertebrate ratings were acceptable or excellent and habitat ratings were marginal or better. Four creeks (Stegman, Cedar, Duke, and Spring) were assessed for their coldwater fishery, and were meeting the coldwater designated use with brook trout and brown trout present. The Wolverine World Wide tannery was located along the Rogue River in Rockford, Michigan, and was torn down between August 2010 and the fall of 2011. Local groups requested the assessment of water, sediment, macroinvertebrate, and fish for contamination and effects from the former Wolverine World Wide tannery. Trout Unlimited also requested a Procedure 51 macroinvertebrate/habitat assessment at Rum Creek to review the current status from the former Wolverine World Wide tannery impacts. Trout Unlimited requested targeted monitoring at Cedar Creek for continuous temperature monitoring due to concerns for the coldwater fishery. 1 �METHODS Procedure 51 describes the methodology for macroinvertebrate, fish, and habitat surveys of wadeable streams, and was used to evaluate the stations. Procedure 51 rates macroinvertebrate communities as Poor (-9 to -5), Acceptable (-4 to +4), and Excellent (+5 to +9), based on the proportions of each taxa found, and the sensitivity of the community assemblage to water quality. Habitat was rated on a scale of Poor {<56), Marginal (56-104), Good (105-154), or Excellent (>154) based on in-stream and riparian characteristics and impairments. The coldwater fish community is evaluated for the presence of at least 50 fish, relative abundance of anomalies (less than 2 percent of the catch), and relative abundance of salmonids collected (at least 1 percent of the catch). Two site-selection methods were used to assess the Rogue River watershed in 2013: stratified random to address statewide, regional, and watershed questions about water quality and targeted to address specific areas of interest. There were four randomly selected status sites and one randomly selected trend site that is now fixed to be sampled every five years (Figure 1, Table 1a). Procedure 51 was used to assess the macroinvertebrates and habitat at each random site. A target of 300 individual macroinvertebrates was counted at each site. Targeted monitoring included water, sediment, and fish contamination analysis at four sites along the Rogue River and Rum Creek (Figure 2, Table 1b.). Two of these sites were also assessed using Procedure 51 for macroinvertebrates and habitat. Fish contaminant data will be reported in a separate MDEQ Fish Contaminant Monitoring Program report. Additional targeted sites included three locations on Cedar Creek (Maple Road, Algoma Avenue, Friske Drive) where temperature was monitored using continuous temperature data loggers by Trout Unlimited and monthly grab samples were taken by the MDEQ (Figure 3, Table 1c.). The Maple Road site was assessed for the coldwater fishery and all sites were assessed for habitat using Procedure 51. 2 �,, Wth•SC SUeoJM I l...L rr~auna..U. ~ Starns Locatl-0ns ■ 3 I) (, Trend Locations Figure 1. Status and Trend Locations in the Rogue River Watershed. 3 9 t'i �Table 1a. Status and Trend Locations in the Rogue River Watershed. Site ID 1 2 3 4 5 Water Body Cedar Creek Duke Creek Rogue River Duke Creek Cedar Creek Location Friske Road 17 Mile Road Algoma Avenue Hanna Avenue 17 Mile Road STORET County Latitude Longitude Habitat Evaluation 410615 Kent 43.15614 -85.60295 Excellent 156 Excellent 8 410692 Kent 43.21981 -85.68018 Good 108 Acceptable 4 410778 Kent 43.13594 -85.61089 Good 134 Acceptable 3 410691 Kent 43.23715 -85.64082 Excellent 166 Excellent 7 410750 Kent 43.22000 -85.56200 Good 117 Acceptable -3 4 Macroinvertebrate Community �• Macroinvertebrate, Sediment, Water Sample Sites 0 Sediment and Water Sample Sites 0 0.15 0.3 0.45 miles Figure 2. Targeted Monitoring Locations on the Rogue River and Rum Creek. 5 �Table 1b. Targeted Monitoring Locations on the Rogue River and Rum Creek. Site Water Macroi nvertebrate County Latitude Longitude Habitat Evaluation Body Community ID Rogue 1 Kent 43.13277 -85.55710 Excellent 161 Acceptable 2 River Rum 2 Kent 43.12360 -85.56139 109 Poor -6 Good Creek Rogue 3 Kent 43.12307 -85.56208 River Rogue 4 Kent 43.12094 -85.56142 River 6 �• FishSite ■ Temperature/DO/Habitat Site 0.75 0 1.5 miles Figure 3. Targeted Monitoring Locations on Cedar Creek. 7 2.25 �Table 1c. Targeted Monitoring Locations on Cedar Creek. Site ID 1 2 3 Water Body Cedar Creek Cedar Creek Cedar Creek Location Maple Road Algoma Avenue Friske Drive County Latitude Longitude Kent 43.22618 -85.55283 Good 151 Kent 43.17443 -85.61639 Excellent 162 Kent 43.14917 -85.59813 Excellent 159 Habitat Evaluation Fish Community Coldwater Stream No Scores Provided RESULTS Status and Trend Surveys Macroinvertebrate communities in wadeable streams were sampled and scored using Procedure 51 (Tables 2 and 3). Two sites had Excellent macroinvertebrate community ratings, while the other three sites were rated Acceptable. The habitat was sampled and scored using Procedure 51 (Table 4). Two sites had Excellent habitat scores, while the rest had Good habitat scores (Figure 1, Table 1a). Site 1. This riffle/run station had an Excellent (8) macroinvertebrate score and an Excellent (156) habitat score. This station includes a forested buffer on the south side of the creek, but an open canopy over the creek. The substrate is composed of mostly gravel and cobble with sand interspersed throughout the reach. The macroinvertebrate community had a high level of diversity (30 taxa) including mayflies, stoneflies, and caddisflies. 8 �Duke Creek at 17 Mile Road Site 2. This glide/pool site had an Acceptable (4) macroinvertebrate score and a Good (108) habitat score. The site was dominated by sand substrate, had forested wetlands surrounding the reach, and consisted of moderate undercut banks and overhanging vegetation. The macroinvertebrate community consisted of mayflies, stoneflies, and caddisflies but also had high levels of tolerant taxa including dipterans and amphipods, resulting in a lower score. Rogue River at Algoma Avenue Site 3. This riffle/run site had an Acceptable (3) macroinvertebrate community and a Good (134) habitat score. The substrate was dominated by sand with some gravel and cobble. The stretch was surrounded by forested wetlands and had a moderate level of aquatic macrophytes throughout the stretch. This site had little habitat with sparse amounts of large woody debris, undercut banks, and overhanging vegetation. Amphipods, a tolerant taxa, was dominant at this site; however, two taxa of stoneflies (Perlidae and Pteronarcyidae) were present. 9 �Duke Creek at Hanna Avenue Site 4. This riffle/run site had an Excellent (7) macroinvertebrate score and an Excellent (166) habitat score. This stretch had a mix of cobble, gravel, and sand for substrate and had trees and shrubs along the banks for vegetative cover. The macroinvertebrate community had a good mix of mayflies, stoneflies, and caddisflies. Thirty-two taxa were found in this stretch of stream. Cedar Creek at 17 Mile Road Site 5. This glide/pool station had an Acceptable (-3) macroinvertebrate community and a Good ( 117) habitat score. This stretch of the creek was mostly sand substrate with silty edges and large amounts of garbage most likely from surrounding parking lots and businesses. Minimal structure was available for macroinvertebrate colonization resulting in a majority of tolerant taxa such as amphipods and physids. 10 �Targeted Monitoring Surveys Rogue River and Rum Creek Targeted Sites Rogue River u/s Wolverine Site 6. This glide/pool site scored Acceptable (2) for macroinvertebrate community and Excellent (161) for habitat {Tables 5 and 6). This stretch of the river had cobble substrate with small amounts of sand, silt, and gravel. The community had high numbers of Heptageniidae (44 percent mayflies) along with a few perlids. Sediment and water samples were collected to review the site for hexavalent chromium and metals {Tables 9 and 10). The sediment sample had no exceedances of consensus-based Probable Effect Concentrations (PEC) (MacDonald et al., 2000). The water sample had no exceedances of Michigan's Water Quality Standards (WQS). ' Rum Creek u/s Rogue River Site 7. This site is a glide/pool with Poor (-6) macroinvertebrate community and Good (109) habitat score (Tables 5 and 6). The site was dominated by corixids, with high numbers of chironomids and amphipods. This is a highly disturbed site with 75 percent silt bottom and very little stable habitat for macroinvertebrates. Sediment and water samples were collected to 11 �review the site for hexavalent chromium and metals (Tables 9 and 10). The sediment sample had no exceedances of consensus-based PECs (MacDonald et al., 2000). The water sample had no exceedances of WQS. Rogue River d/s Rum Creek Site 8. Sediment and water samples were collected to review the site for hexavalent chromium and metals (Tables 9 and 10). The sediment sample had no exceedances of consensus-based PE Cs (MacDonald et al., 2000). The water sample had no exceedances of WQS. Rogue River u/s Rockford Dam Site 9. Sediment and water samples were collected to provide data on hexavalent chromium and metals (Tables 9 and 10). The sediment sample had no exceedances of consensus-based PECs (MacDonald et al. , 2000). The water sample had no exceedances of WQS. 12 �Cedar Creek Targeted Sites Cedar Creek at Maple Road Site 10. This riffle/run station had a Good (151) habitat score (Table 7). This stretch had a good mix of cobble, gravel, sand, and silt substrates. There were moderate levels of structure available for macroinvertebrate colonization including undercut banks, overhanging vegetation, and large woody debris. Backpack shocking for fish provided 46 fish with a 12 percent catch of salmonids (four brown trout ranging in size of 7 to 13 inches) (Table 8). Cedar Creek at Algoma Avenue Site 11. This glide/pool station had an Excellent (162) habitat score (Table 7). The substrate through this stretch consisted of sand and gravel. The stream banks were filled with herbaceous vegetation; however, the tree canopy was lacking throughout this reach. 13 �Cedar Creek at Friske Road Site 12. This riffle/run station had an Excellent (159) habitat score (Table 7). This stretch consisted primarily of cobble substrate with gravel and some sand. Four brown trout were spotted through this stretch while assessing the habitat. The banks of the stream were well vegetated with a mix of herbaceous and tree canopy cover. 14 �Sediment and Water Chemistry Sampling Table 9. Sediment Results for the Rogue River and Rum Creek. Site 1 Site 2 Site 3 Site 4 Sediment PEC 43.13277, -85.55710 43.12360, -85.56139 43.12307, -85.56208 43.12094, -85.56142 NA Not Detected Not Detected Not Detected Not Detected Not Detected 0.9 mg/kg 4.5 mg/kg 5.4 mg/kg 5.8 mg/kg <33 mg/kg 12 mg/kg 56 mg/kg 59 mg/kg 86 mg/kg No Standard for PEC Cadmium Not Detected 0.4 mg/kg 0.4 mg/kg 0.6 mg/kg <4.98 mg/kg Chromium 3.0 mg/kg 32 mg/kg 16 mg/kg 21 mg/kg <111 mg/kg Copper 2.1 mg/kg 16 mg/kg 14 mg/kg 18 mg/kg <149 mg/kg Lead 2.6 mg/kg 18 mg/kg 14 mg/kg 21 mg/kg <128 mg/kg Mercury Not Detected 0.06 mg/kg 0.06 mg/kg 0.1 mg/kg <1.06 mg/kg Selenium Not Detected 1.3 mg/kg 1.1 mg/kg 1.6 mg/kg <1.9 mg/kg Silver Not Detected Not Detected Not Detected Not Detected Not Detected 12 mg/kg 59 mg/kg 56 mg/kg 87 mg/kg <459 mg/kg Latitude/ Longitude Hexavalent Chromium Arsenic Barium Zinc 15 �Table 10. Water Results for the Rogue River and Rum Creek. Site 1 Site 2 Site 3 Site 4 Site 4 Duplicate was Latitude/ Longitude Hexavalent Chromium Arsenic Barium 43.13277, 85.55710 43.12360, 85.56139 43.12307, 85.56208 43.12094, 85.56142 43.12094, 85.56142 NA Not Detected Not Detected Not Detected Not Detected Not Detected Not Detected 1.1 µg/L 1.3 µg/L Not Detected Not Detected Not Detected <340 µg/L 35 µg/L 32 µg/L 34 µg/L 34 µg/L 34 µg/L <1487 µg/L Cadmium Not Detected Not Detected Not Detected Not Detected Not Detected Not Detected Chromium Not Detected Not Detected Not Detected Not Detected Not Detected Not Detected Copper 1.3 µg/L 1.8 µg/L 1.4 µg/L 1.1 µg/L 1.3 µg/L <23.93 µg/L Lead Not Detected Not Detected Not Detected Not Detected Not Detected Not Detected Mercury Not Detected Not Detected Not Detected Not Detected Not Detected Not Detected Selenium Not Detected Not Detected Not Detected Not Detected Not Detected Not Detected Silver Not Detected Not Detected Not Detected Not Detected Not Detected Not Detected Zinc Not Detected Not Detected Not Detected Not Detected Not Detected Not Detected 16 �DISCUSSION Status and Trend The status and trend sites in the Rogue River watershed are in good condition. All sites are meeting the Other Indigenous Aquatic Life and Wildlife designated use. In general, narrow buffers between agricultural fields and streams could be increased and multiple culverts, as seen at Duke Creek Hanna Avenue (2 culverts) and Cedar Creek Friske Road (3 culverts), should be replaced with one appropriate-sized culvert or bridge for the road crossing. In addition, Cedar Creek at 17-Mile Road would benefit from stable habitat, reduced runoff from adjacent parking lots, and additional structure for macroinvertebrate colonization. Targeted Rogue River and Rum Creek The Rogue River upstream of the Wolverine World Wide tannery site has acceptable macroinvertebrates and excellent habitat. Rum Creek is a highly impacted site with a silted bottom and poor macroinvertebrate scores. Upstream from the sampling location on Rum Creek is a channelized stream with concrete banks causing high levels of runoff from the Wolverine World Wide tannery site. This site would benefit from restoration by removing the concrete channel and stabilizing the banks to improve the macroinvertebrate community. The two downstream locations on the Rogue River are impounded due to the Rockford Dam. All four sites had water and sediment samples taken to assess public concerns with hexavalent chromium and metals from the Wolverine World Wide tannery site. Tanneries are known to have discharged chromium, hexavalent chromium, and arsenic. The water samples showed signs of arsenic, barium, and copper, but all samples were below Michigan's was. The sediment samples showed levels of arsenic, barium, cadmium, chromium, copper, lead, mercury, selenium, and zinc; but all samples were below the sediment PECs (MacDonald et al., 2000). Hexavalent chromium was not detected in the sediment or water samples. Cedar Creek The targeted sites at Cedar Creek showed good cobble/gravel substrate for fish habitat. The banks along these three sites were well vegetated and did not show problems with runoff into the stream. Cedar Creek at Algoma Avenue would benefit from additional tree cover as the canopy is very open and could result in increased water temperatures. The Maple Road site was sampled for the fish community and showed 12 percent salmon ids with 4 brown trout ranging in size from 7 to 13 inches (Table 8). Under the guidelines of Procedure 51, fish sampling should occur no longer than 45 minutes. During this survey, sampling occurred for 45 minutes and produced a total of 46 fish. According to the procedure, if less than 50 fish are obtained and/or less than 1 percent of the catch are salmonids, the stream should be labeled poor. After reviewing this site, it does not support a poor designation. Coldwater streams like Cedar Creek generally have fewer numbers of fish than a warmwater stream. One potential reason for a reduced number of fish at this site would be a beaver dam that was viewed upstream of the sampling location, just upstream from the White Pine Trail. Removal of the dam should improve fish passage and improve fish numbers downstream in the sampled site. Temperature data loggers were installed within Cedar Creek at three locations to collect hourly readings of the temperature from May 30-September 29. In addition, Nichol DeMol from Trout Unlimited and an MDEa biologist took temperature grab samples of the water from June-August. The handheld readings by Trout Unlimited and the MDEa did not show any exceedances of the 68° Fahrenheit temperature was for Cedar Creek; however, the 17 �temperature data loggers showed occurrences in June, July, and August where the temperatures are exceeding the 68° Fahrenheit WQS. In some instances the loggers were showing a 5° increase in temperature within one hour, which does not seem likely. In July, a data logger was found along the stream banks outside the water and its data was disregarded. Temperature data logger readings matched grab sample readings taken in the field. Cedar Creek may have some high fluctuations in water levels that could have resulted in data loggers being exposed to air instead of water temperature. An additional study should be conducted in the future at these locations to assess the fish community and temperature, with the data loggers installed in deeper pools to assure that only water temperature data are recorded. Field work by: Marcy Knoll Wilmes, Aquatic Biologist Tom Alwin, Aquatic Biologist Jeff Varricchione, Aquatic Biologist Tamara Lipsey, Aquatic Biologist Bill Keiper, Aquatic Biologist Surface Water Assessment Section Water Resources Division Report by: Marcy Knoll Wilmes, Aquatic Biologist Surface Water Assessment Section Water Resources Division 18 �Literature Cited Creal, W., S. Hanshue, S. Kosek, M. Oemke, and M. Walterhouse. 1996. Update of GLEAS Procedure 51 Metric Scoring and Interpretation. MDEQ Staff Report #MI/DEQ/SWQ-96/068. Revised May 1998. MacDonald, D.D., C.G. Ingersoll, and T.A. Berger. 2000. Development and Evaluation of Consensus-Based Sediment Quality Guidelines for Freshwater Ecosystems. Archives of Environmental Contamination and Toxicology 39:20-31. MDEQ. 1990. SWAS Procedure 51 - Qualitative Biological and Habitat Survey Protocols for Wadable Streams and Rivers, April 24, 1990. Revised June 1991, August 1996, January 1997, May 2002, and December 2008. Omernik, J.M. and A. Gallant. 1988. Ecoregions of the Upper Midwest States. United States Environmental Protection Agency, Environmental Research Laboratory. EPA/600/3-88/037. Rockafellow, D. 2004. A Biological Survey of the Rogue River Watershed, Kent and Newaygo Counties, August 2003. MDEQ Staff Report# MI/DEQ/WD-03/129. Walterhouse, M. 2009. A Biological Survey of Sites in the Rogue River Watershed, Kent and Newaygo Counties, Michigan July 2008. MDEQ Staff Report# MI/DEQ/WB-09/057. 19 �Table 2 Qualitative :macroinvertebrate sar:q,Iing results for Cedar Creek Duko Creek Friske Rd 17MiloRoad 8/612013 8/612013 TAXA ANNELIDA (segmented worm.) Hirudinea (leeches) Oligochaeta (worm.) ARTHROPODA Crustacea A,q,hipoda (scuds) Decapoda (crayfish) Isopoda (sowbugs) Amchnoidea Hydmcarina Insecta Fph~roptera (II11yflies) Baetidae Ephem,ridae Heptageniidae Isonychiidae Leptophlebiidae Tricorythidae Odonata Anisoptera (dragonflies) Aeshnidae Gon:phidae Zygoptera (d.ar:melflies) Calopte,ygulae Plecoptera (stoneflies) Perlidae Pteronarcyidae llomiptera (true bugs) Corixidae Gerridae Notonectidae Veliidae Megaloptera Cotydalidae (dobson flies) S:ialidae(alderflies) Trichoptera (caddisflies) Brachycentridae Helicopsychidae Hydropsychidae I.eptoceridae Iinnephilidae Molannidae Philopotamidae Coleoptem (beetles) Dytiscidae (totaQ Hydrophilidae (total) Psepbenulae (aduhs) D,yopulae Flmidae Psephenidae (larvae) Diptera (!lies) Athericidae Ceratopogonidae Chironomidae Culicidae SllDlliidae Stratiomyidae Tipulidae MOILUSCA Gas1ropoda(snails) Hydrobiidae 1¥nnaeidae Physidae Planorbidae Viviparidae Pelecypoda (bivalves) Sphaeriidae (clami) TOTAL INDIVIDUAfS MEI'RIC TOTALNUMBEROFTAXA NUMBER OF MAYFLYTAXA NUMBER OF CADDJSFLYTAXA NUMBEROFSTONFFLYTAXA PFRCENTMAYFLYCOMP. PFRCENT CADDISFLYCOMP. PFRCENT DOMINANT TAXON PFRCENT JSOPOD, SNAII, IBFCH PFRCENTSURF.AIRBREATIIERS Duke Creek Hanna Avenue 8/612013 Rogue River AlgoII11Avenue 8/612013 26 36 70 4 31 10 22 15 4 4 20 13 1 20 13 11 10 4 35 77 2 16 21 95 2 42 2 13 10 15 2 17 2 10 4 70 1 36 27 23 12 40 12 2 11 32 30 300 272 288 Doke Creek 17MiloRoad 81612013 Vahle Score Cedar Creek Friske Rd 81612013 Value Score 30 26 289 Rogue River AlgoIIB Avenue 81612013 Vahle Score Duke Creek Hanna Avenue 8/612013 Value Score 29 32 4 10.07 13.89 24.31 27.43 4.51 15.92 36.33 26.64 0.69 3.46 4 24.67 35.00 31.67 2.33 4.67 0 6.62 23.90 25.74 0.00 3.31 -1 TOTALSCORE MACROINV. COMMUNITYRATING EXCElLENT Aa:EP'f. Aa:EP'f. EXCEUENT 20 �Table 3. Qualitative macroinvertebrate sampling results for Cedar Creek 17MileRoad 8/6/2013 TAXA ANNELIDA (segmented worm,) Hirudinea (leeches) Oligochaeta (worm,) ARTHROPODA Crustacea Amphipoda (scuds) Decapoda (crayfish) lsopoda (sowbugs) Arachnoidea Hydracarina lnsecta F;phemeroptera (mayflies) Baetidae Heptageniidae Odonata Zygoptera (damselflies) Calopteiygidae Hemiptera (true bugs) Corixidae Gerridae Trichoptera (cad dis flies) Hydropsychidae Linmephilidae Coleoptera (beetles) Elmidae Diptera (flies) Cliironornidae Simuliidae Syrphidae MOillJSCA Gastropoda (snails) Physidae Planorbidae Viviparidae Pelecypoda (bivalves) Sphaeriidae (clams) TOTAL INDIVIDUALS METRIC TOTAL NUMBER OF TAXA NUMBER OF MAYFLYTAXA NUMBER OF CADDISFLYTAXA NUMBER OF STONEFLYTAXA PERCENT MAYFLYCOMP. PERCENT CADDISFLYCOMP. PERCENT DOMINANT TAXON PERCENT ISOPOD, SNAIL, LEF.CH PERCENT SURF. AIR BREATHERS TOTALSCORE MACROINV. COMMUNITY RATING 69 28 4 5 1 15 5 4 21 1 2 104 31 298 Cedar Creek 17MileRoad 8/6/2013 Value Score 21 2 2 0 2.01 2.01 34.90 37.25 1.34 0 0 0 -1 -1 -1 0 -1 -3 ACCFPT. 21 �Table 4. Habitat evaluation for Cedar Creek Friske Rd RIFFLE/RUN Duke Creek 17 Mile Road GLIDE/POOL Rogue River Algoma Avenue RIFFLE/RUN Duke Creek Hanna Avenue RIFFLE/RUN Cedar Creek 17 Mile Road GLIDE/POOL HABITAT METRIC Substrate and lnstream Cover Epifaunal Substrate/ Avail Cover (20) Embeddedness (20)* Velocity/Depth Regime (20)* Pool Substrate Characterization (20)** Pool Variability (20)** Channel Morphology Sediment Deposition (20) Flow Status - Mainl Flow Volume (10) Flow Status - Flashiness (10) Channel Alteration (20) Frequency of Riffles/Bends (20)* Channel Sinuosity (20)** Riparian and Bank Structure Bank Stability (L) (10) Bank Stability (R) (10) Vegetative Protection (L) (10) Vegetative Protection (R) (10) Riparian Veg. Zone Width (L) (10) Riparian Veg. Zone Width (R) (10) 17 18 18 16 18 14 10 7 8 9 13 15 10 9 19 5 8 7 7 16 10 8 9 19 4 19 9 10 15 15 9 8 6 18 8 TOTAL SCORE (200): HABITAT RATING: 14 12 14 5 8 8 8 9 9 4 7 6 6 5 4 9 5 9 6 9 9 6 5 9 9 9 9 8 6 7 7 6 8 5 10 156 108 134 166 117 GOOD (SLIGHTLY IMPAIRED) EXCELLENT (NONIMPAIRED) GOOD (SLIGHTLY IMPAIRED) GOOD EXCELLENT (NONIMPAIRED) (SLIGHTLY IMPAIRED) Note: Individual metrics may better describe conditions directly affecting the biological community while the Habitat Rating describes the general riverine environment at the site(s). Date: Weather: Air Temperature: Water Temperature: Ave. Stream Width: Ave. Stream Depth: Surface Velocity: Estimated Flow: Stream Modifications: Nuisance Plants (Y/N): Report Number: STORETNo.: Stream Name: Road Crossing/Location: County Code: TRS: 8/6/2013 Cloudy 70 58 20 1.5 2 60 None N Deg. F. Deg. F. Feet Feet Ft./Sec CFS 8/6/2013 Cloudy 68 54 16 2 0.5 16 None N Deg. F. Deg. F. Feet Feet Fl/Sec CFS 8/6/2013 Cloudy 77 57 40 2.5 2 200 None N Deg. F. Deg. F. Feet Feet Fl/Sec CFS 8/6/2013 Cloudy Deg. F. 72 Deg. F. 64 Feet 15 Feet 1.5 Ft./Sec. 0.75 CFS 16.875 Canopy Removal N 410615 Cedar Creek Friske Rd 41 09N11W22 410692 Duke Creek 17 Mile Road 41 10N12W25 43.15614 -85.60295 SMNITP Coldwater 43.21981 -85.68018 SMNITP Coldwater 43.13594 -85.61089 SMNITP Coldwater 43.23715 -85.64082 SMNITP Coldwater 43.22 -85.562 SMNITP Coldwater 4050006 4050006 4050006 4050006 4050006 Latitude (dd): Longitude (dd): Ecoregion: Stream Type: USGS Basin Code: 410778 Rogue River Algoma Avenue 41 09N11W28 8/6/2013 Cloudy 64 55 13 2 2 52 None y • Applies only 1o Riffle/Run stream Surveys •• Applies only 1o Glide/Pool stream Surveys 22 410691 Duke Creek Hanna Avenue 41 10N11W20 410750 Cedar Creek 17 Mile Road 41 10N11W25 Deg. F. Deg. F. Feet Feet Fl/Sec. CFS �Table 5. Qualitative macroinvertebrate sampling results for RnmCreek at Rogue River (IIDuth ofRnm Creek) Rogue River upstream Wolverine Worldwide Tannery Site 9/16/2013 9/16/2013 TAXA ANNELIDA (segm,nted worms) Hirudinea (leeches) Oligochaeta (worms) ARTHROPODA Crustacea Amphipoda (scuds) Decapoda (crayfish) lsopoda (sowbugs) Arachnoidea Hydracarina Insecta Fphem,roptera (mayflies) Fphem,ridae Heptageniidae lsonychiidae Polymitarcyidae 14 7 38 51 15 3 113 3 4 Odonata Anisoptera (dragonflies) Aeshnidae Go1IJ>hidae Zygoptera (damselflies) Calopte,ygidae Plecoptera (stoneflies) Perlidae Hemiptera (true bugs) Belostomatidae Corixidae Gerridae Notonectidae Pleidae Veliidae Megaloptera Sialidae (alder flies) Trichoptera (caddisflies) Hydropsychidae Coleoptera (beetles) Haliplidae (adults) 6 132 36 4 Elmidae Psephenidae (larvae) Diptera (flies) Chironomidae Culicidae Sinntliidae Tabanidae MOlllJSCA Gastropoda (snails) Physidae Pelecypoda (bivalves) Sphaeriidae (clams) 49 2 2 2 252 TOTAL INDIVIDUALS MEfRIC TOTALNUMBEROFTAXA NUMBEROFMAYFLYTAXA NUMBEROFCADD!SFLYTAXA NUMBER OF STONEFLYTAXA PERCENT MA YFLYOOMP. PERCENT CADDISFLYCOMP. PERCENT DOMINANT TAXON PERCENT ISOPOD, SNAIL, IEECH PERCENT SURF. AIRBRFATHERS 2 277 RnmCreek at Rogue River (m,uth ofRnm Creek) Rogue River ,stream Wolverine Worldwide Tanne,y S 9/16/2013 9/16/2013 Value 15 0 0 0 0.00 0.00 52.38 2.38 54.37 0 -1 -1 -1 -1 -1 -1 Score 25 4 -1 43.68 1.44 40.79 1.81 14.44 -1 -1 -1 0 2 -{j TOTALSOORE MACROINV. COMMUNITY RA TING Value Score POOR ACCEPT. 23 �Table 6. Habitat evaluation for Rum Creek Rogue River at Rogue River (mouth of Rum Creek) u/s Wolverine Worldv,,;de Tannery Site GUDE/POOL GUDE/POOL HABITATME1RIC Substrate and lnstream Cover 5 16 11 7 15 7 8 9 9 13 16 9 9 19 5 17 9 9 7 7 3 7 9 9 9 9 8 9 109 161 Epifaunal Substrate/ Avail Cover (20) Embeddedness (20)* Velocity/Depth Regime (20)* Pool Substrate Characterization (20)** Pool Variability (20)** Channel Morphology Sediment Deposition (20) Flow Status - Main!. Flow Volume (10) Flow Status - Flashiness (10) Channel Alteration (20) Frequency of Riffles/Bends (20)* Channel Sinuosity (20)** Riparian and Bank Structure Bank Stability (L) (10) Bank Stability (R) (10) Vegetative Protection (L) (10) Vegetative Protection (R) (10) Riparian Veg. Zone Width (L) (10) Riparian Veg. Zone Width (R) (10) TOTAL SCORE (200): GOOD HABITAT RATING: EXCELLENT (NONIMPAIRED) (SLIGHTLY IMPAIRED) Note: lndil<idual metrics may better describe conditions directly affecting the biological community while the Habitat Ratin1 describes the general riverine enl<ironment at the site( s). 9/16/2013 Cloudy 62 54 22 1.5 0.5 16.5 Dredged N Date: Weather: Air Temperature: Water Temperature: Ave. Stream Width: Ave. Stream Depth: Surface Velocity: Estimated Flow: Stream Modifications: Nuisance Plants (Y/N): Report Number: STORETNo.: Stream Name: Road Crossing/Location: County Code: TRS: 9/16/2013 Partly Cloudy Deg. F. Deg. F. Feet Feet Ft/Sec. CFS 58 50 3 0.2 30 None N Deg. F. Deg. F. Feet Feet Ft/Sec. CFS 410788 410787 Rum Creek Rogue River at Rogue River (mouth of Rum Creek) upstream Wolverine Worldv.ide Tannery Site . ~ . ~ 09N11W36 09N11W25 Latitude (dd): Longitude (dd): Ecoregion: Stream Type: 43.1236 -85.5612 SMNITP 43.13285 -85.55729 SMNITP USGS Basin Code: 4050006 4050006 * Applies only to Riffle/Run stream Surveys ** Applies only to Glide/Pool stream Surveys 24 �Table 7. Habitat evaluation for Cedar Creek Maple Road (Site 1) RIFFLE/RUN HABITAT METRIC Substrate and lnstream Cover Epifaunal Substrate/ Avail Co-.er (20) Embeddedness (20)* Velocity/Depth Regime (20)* Pool Substrate Characterization (20)** Pool Variability (20)** Channel Morphology Sediment Deposition (20) Flow Status - Maint. Flow Volume (10) Flow Status - Flashiness (10) Channel Alteration (20) Frequency of Riffles/Bends (20)* Channel Sinuosity (20)** Riparian and Bank Structure Bank Stability (L) (10) Bank Stability (R) (10) Vegetati-.e Protection (L) (10) Vegetati-.e Protection (R) (10) Riparian Veg. Zone Width (L) (10) Riparian Veg. Zone Width (R) (10) Cedar Creek Algoma (Site 2 Larry's House) GLIDE/POOL 17 16 15 Cedar Creek Site 3 DNR Park off Friske Dri-.e RIFFLE/RUN 13 18 18 14 16 11 15 9 9 13 12 19 10 10 19 18 9 4 18 19 10 TOTAL SCORE (200): HABITAT RATING: 8 9 8 8 3 9 10 10 10 10 7 7 7 7 9 7 10 151 162 159 EXCELLENT (NONIMPAIRED) EXCELLENT (NONIMPAIRED) GOOD (SLIGHTLY IMPAIRED) Note: lndi1o1dual metrics may better describe conditions directly affecting the biological community while the Habitat Rating describes the general ri-.erine en1o1ronment at the site(s ). Date: Weather. Air Temperature: Water Temperature: A-.e. Stream Width: A-.e. Stream Depth: Surface Velocity: Estimated Flow: Stream Modifications: Nuisance Plants (Y /N): Report Number. STORETNo.: Stream Name: Road Crossing/Location: County Code: TRS: 7/8/2013 Cloudy 63.9 10 0.7 4 28 ,nk Stabilization N Deg. F. Deg. F. Feet Feet Ft./Sec. CFS 410789 Cedar Creek Maple Road (Site 1) 41 10N11W25 • Latitude (dd): Longitude (dd): Ecoregion: Stream Type: USGS Basin Code: 8/30/2013 Sunny 80 64 27 1.5 0.5 20.25 None N 7/8/2013 Cloudy Deg. F. Deg. F. Feet Feet Ft./Sec. CFS 410790 Cedar Creek Algoma (Site 2 Larry's House) 41 09N11W16 • 65.1 15 0.5 0.6 4.5 Canopy Removal N 410791 Cedar Creek Site 3 DNR Park off Friske Dri-.e 41 09N11W22 • 43.22618 -85.55283 SMNITP Coldwater 43.17443 -85.61639 SMNITP Coldwater 43.14917 -85.59813 SMNITP Coldwater 4050006 4050006 4050006 • Applies only to Riffle/Run stream Sur-.eys •• Applies only to Glide/Pool stream Sur-.eys 25 Deg. F. Deg. F. Feet Feet Ft./Sec. CFS �Table 8. Qualitative fish sampling results for TAXA Cedar Creek Maple Road (Site 1) 7/8/2013 STATION 1 Sahronidae (trouts) Salmo trutta (Brown trout) Umbridae(mudminnows) Umbra limi (Central mudminnow) Cyprinidae (minnows and carps) Semotilus atromaculatus (Creek chub) Rhinichthys atratulus (Blacknose dace) Cottidae (sculpins) Cottus bairdii (Mottled sculpin) Catostomidae (suckers) Catostomus commersoni (White sucker) Centrarchidae (sunfish) Lepomis cyanellus (Green sunfish) Lepomis macrochirus (Bluegill sf) 4 2 10 2 21 4 2 1 TOTAL INDIVIDUALS Numberofhybridsunfish Number of anomalies Percent anomalies Percent sahronids Reach sampled (ft) Area sampled (sq ft) Density(# fish/sq ft) Gear 46 0 0 0.000 8.696 200 #DN/0! bps Table lB. Fish metric evaluation of METRIC Cedar Creek Maple Road (Site 1) 7/8/2013 STATION 1 Value Score 8 1 TOTALNUMBEROFTAXA NO. OF DARTER, SCULPIN, MADTOM TAXA NUMBER OF SUNFISH TAXA NUMBER OF SUCKER TAXA NUMBER OF INTOLERANT TAXA PERCENT TOLERANT PERCENT OMNIVOROUS TAXA PERCENT INSECTNOROUS TAXA PERCENT PISCNOROUS TAXA % SIMPIBLITHOPHII1C SPAWNER TAXA 2 1 2 43.48 39.13 52.17 0.00 13.04 26 �Artifact 32 �APPENDIX A Storage Tanks and Storage Areas '--..__/ �• APPENDIX A The following list construction material includes all bulk and contain~ent stored materials, tank volumes, information where applicabl~. Also included in this list are the major non-bulk storage and major use areas in reference to the labelled site plan found in Appendix F of this report. �I . I OUTDOOR CHEMICAL STORAGE The following chemicals are presently stored in area 14: # 1 Ac et i c Ac i d #38 Muriatic (Hydrochloric) Acid The followino chemicals are presently stored in area 15: #13 #18 #24 #27 #51 #65 #74 #80 #88 Busan 30 Chemo 1 21 0-Terge X 348 Emulsan 20W . Scotchguard FC-236A, fC~236B, FC-152 Texo l - C Mardol 55 Oil and 930 Oil Surfonfc J - 4 Mitco A - 5 - 2 The followinq chemicals are presently stored in area 17: Busan 30 #51 Scotchguard FC-236A, FC-236B, FC-152 #89 Silicone #90 LS - 1644 - R #13 M.I.B.K. The following chemicals are presently being stored in area 18: #33 #77 #34 Isopropyl Alcohol Eastern 930 Oil Linea Levelin L �( ( ., ( STORAGE TANKS AND AREAS DSA* A. Stored Material Wastewater Location Elevation Volume Tank Construct WW Plant Screening Channel Sub 6,700 gal Concrete B. Wastewater W W Pl ant Wet Well Sub 7,900 qal Concrete C. Wastewater WW Plant S. Clarifier Elev 286,300 gal Concrete D. f✓a stew at er W W Pl ant Transfer Well Sub 19,200 gal Concrete E. Wastewater W W Pl ant Aeration Tank Elev. • 864,000 gal F. Wastewater W W Pl ant N. Clarifier Elev 286,300 gal Concrete G. Sludge W W Pl ant Sl udqe Thickener Elev 176,000 gal Concrete H. S1 ud ge W W Pl ant S1udq e Cond Tank Elev 1,000 gal Steel Fiberglass Coating I. Lime W vJ Pl ant Lime Storage Bin Elev 1,900 Ft Steel J. Lime Slurry vJ W Pl ant Elev 680 Gal Fiberglass Lime Slurry Tank Containment Dimensions Containment Volume Containment Construction none none none 17'xl6'x0.33' with drain 680 gal Concrete Steel *Designated Storage Area - These areas are denoted on the enclosed site plan. �( . ., _( ( . STORAGE TANKS AND AREAS (continued) ·· DSA Stored Material Loe at-ion Elevation Volume Tank Construct . Containment Dimensions Cont a·i nment Volume Containment Construction K Ferrous Chloride W W Pl ant Ferrous Chloride Tank Elev 10,350 gal Fiberglass 30 1 xl4 1 x4 1 with drain 9200 gal Concrete L. Alum W W Pl ant Alum Storage Tank Elev 10,350 gal Fiberglass 30 1 xl4 1 x4 1 with drain 9200 gal Concrete M. Polymer W W Pl ant Polymer Mixing Tank Elev 80 qal Fi _ b ergl ass 680 gal Concrete 1. Grease Hide house Air Flotation Un it Elev 5800 gal Steel drain 2. Grease · Hide house Fat Settling Column Elev 350 gal Steel drain 3. Grease Hide house Cooker Elev 2@ 2500 gal Wood drain 4. Fat Hide house Fat Storage Tank · Elev 4000 gal Steel drain 5. Grease Col or Depart. Grease Storage Tank Elev 20,000 gal Steel drain 6. Sulfide Hi de house Sulfide surge Tank - Elev 12,000 gal Concrete drain 17 1 xl6 1 xQ.33 1 . with drain �( ( ., ( STORAGE TANKS AND AREAS {continued) DSA Stored Material Location Elevation Volume Tank Construct Containment Dimensions Containment Volume Containment Construction 7. Sult i de Hide house Sult i de recovery Tanks Elev 4 @ 7500 gal Fiberglass 28'6"x33'6 11 x3' with sump 21,400 gal Concrete 8. Sod i l1TI Hydroxide Hi de house Caustic Tanks Elev 2 @ 7500 Fiberglass 28' 6 11 x33' 6 11 x3' with sump 21,400 gal Concrete 9. Chrome Tanyard Chrome Recovery Tanks Elev 2 @ 4400 gal Fiberglass drain 10 . Chrome Ta nyard Chrome Storage Tanks Elev 2 @ 4500 gal Fiberglass 12'x26'x4' with drain 7800 gal Concrete 11. Formic Acid Tanyard same room as Chrome Tanks Elev 8,100 gal Fiberglass 12'x26 1 x4 1 with drain 7800 gal Concrete 12. Chrome Tanya rd Recovered Chrome Storage Tank El ec 5,000 gal Fiberglass drain 13. Lime Lime Shed Near RR Tracks Elev 14. See listinq Outside Lime Shed 15. See l i st ing Eas t of Lime Shed 16 . Surf on i c J-4 Outside Color Dept. Adjacent ·t o So ut h Sh i pping Dock Elev. \1ood · 11,000 gal Steel none �( ( STORAGE TANKS AND AREAS (continued) DSA Stored Material Location El evation Volume • Tank Construct Contai nrnent Dimensions 17. See listing ~Jest of Warehouse 18. See 1 i st i nq SW Corner of Power Plant 19. 930 Oi 7 & 55 Oil Col or De pt. Elev 11,000 gal Steel none 20. Sulfuric Acid Above Pasting Department Elev 9,600 qal Stee 1 none 21. Leukanol Tanyard Elev 11,000 qal (2 Tanks) Fiberglass - none 22. #6 Fuel Oil Under~round Near Power Pl ant Sub grade 11,000 gal Steel none 23. Dyes \~a rehouse 24. Finishes & Lacquers Warehouse 25. Empty Orum Westside of Tannery Outside Storage 26. Hide house l.oading dock 27. \4arehou se loading dock 28. Hydraulic Oil Tin Shed ' Containment Volume Containment co·nstruction - none �APPENDIX B Chemical List '-...__,/ �APPENDIX B The follo.-!ing list includes a1l the ch emicals used in the leather processing operation. Unless othenv·ise noted, all chemicals are stored in the warehouse. \>ihere noted, chemicals are stored in assigned areas and marked on the site pl an. Materials marked material as not being hazardous determined from the material in a:ccording the information Chemicals marked as hazardous were safety data sheets and the hazardous compound sheet. Unless otherv1ise noted, all liquids stored in 55 gallon drums and solids are stored in paper sacks or drums. \__., to Those marked N/A were not avail ab1e either f;~om supplier or the manufacturer. noted done so safety data sheets supplied by the manufacturer or by common know1edge of the cherr,ical. the i,,1er2 are �.CHEMICALS '-------' #2 #1 Name Acetic Ac id 56% Formula Use Hazardous? Hazardous Compound Other lnfo Aerotex Fire Retardant NOS and Gl ac i a 1 Colorin9 (Basic Dyes) No Fire retardant N/A N/A Liquid in 30 gal drums stored in Area 14 Liquid #4 #3 Name Formula Use Hazardous? Hazardous Compound \..J Ami cal 48 A'llmoni um Bicarbonate Fungicide N/A N/A Coloring (pH) No Sol id Solid Other Info . Stored St ate #5 Name Fonnul a Use Hazardous ? Hazardous Compound #6 Ammoni urn Sulfate Aqu a Arnmoni a Tanning No Co loring (pH) No Sol id Liquid Other lnfo . Stored St ate #8 #7 :, '-...../ Name Formula Use Hazardous? Hazardous Compound Bavon D Baychrome #2402 & 2403 Waterproofing No No Contains Triva 1ent Chrome Other Info Stored state Tanning Liquid Solid �#10 #9 Name Ba_ymol AE & AN Betasol OT 75% Formula Use Hazardous? • Hazardous Compound Wetting Agent No Surfactant No Liquid Liquid Other Info Stored St ate #11 " Name Formula Use Hazardous? Hazardous Compound ·: Bi soft 670-G_ Fat Liquor • No #12 Magnesol 30/40 Maqnesium Silicate Chrome Recovery No Other Info Stored St ate Liquid Solid #14 #13 Name Busan 30 Busan 52 - Formula • Us2 Hazardous? Hazardous Compound Fungicide Fungicirle Yes Yes 2 -(thiocyanonietliylthio)-Potassium N - Hydroxymethyl N-methyl dithio carbamate benzothiazole and sodium 2 - mercaptobenzothiazole Other Info Stored State Name Formula Use Hazardous? _Liquid Liquid - 55 gal drums stored in Areas 1~ & 17 #15 #16 Cassofix FRZ Catalix GS liquid Dye Fixing Agent No Cationic Softener No Liquid Liquid Hazardous Compound Other Info Stored State �#18 #17 \_____,I Name Formula Use Hazardous? Hazardous Compound Caustic Soda NaOH Chemol 21 Fat Liquor No No Other Info Stored St ate Sol id Liquid - 55 gal Drum Stored in Area 15 #19 Name Formula Use Hazardous? Hazadrous Compound #20 A-60 Chemtan A-55 Chemtan Tanning Yes Formaldehyde Tanning Yes Formaldehyde Ul22 Ul22 Sol id Sol id 10% Other Info :\_____,I Stored State #21 ~1ame Formula Use Ha.zardou s? Hazardous Compound #22 Chemtan E..:32 Chemt an T -20 Syntan Yes Phenol Ul88 Neutralizing Agent No So 1 id Sol id Other Info St □ red St ate #23 ~. '-._,/ Name Formula Use Hazardous? Hazardous Compound #24 Coropol DXF D - Terge Pl ate 348 Fat Liquor Pasting Pl ate Wash Concentrate No No Other Info St □ red St ate Liquid Liquid in 55 gal Drums Stored in Area 15 �#25 Name Formula Use Hazardous? Hazardous Compound #26 Dow Corning 1101 Emulsion Eastein # 1662-A Silicone Emulsion No Emulsifier No Other Info Stored St ate Liquid • Liquid #28 #27 Name Formula Use Hazardous? Hazardous Compound Emulsan 20W Ferrous chloride Dispersing Solvent Fat Liquor No Wastewater Treatment No Other Info Stored State Liquid in 55 gal drums . Stored in Area 15 Bulk Liquid; 10,350 gallon max volume stored in Area K #30 #29 Name ' Formula. Use Hazardous? Hazardous Compound Fixanol Pi'IA Hydrated Lime Dye Fixative Yes Formaldehyde ul22 Tanning & Waste Tr~atment No Other Info Stored State 50 # bass in Area 13 30 ton bulk storage WWTP in Area I Liquid Solid �#32 #31 . '--....--- Name Formula Use Hazardous? Hazardous Compound Intrasoft OCN Invaderm LU Cationic Softener No Dyeing Auxiliary Liquid Liquid No • Other Info Stored St ate #33 Name Formula Use Hazardous? Hazardous Compound Isporopyl Alcohol #34 Linea Leve1in L Filler No No Liquid in 55 gal drums Stored in Area 18 Li quid - 55 gal drums Other Info Stored State Stored in Area 18 #35 #36 Na.'Tle Linco Enzopan E;_:4-m Liquichlor Bleach Formula Use Hazardous? Hazardou.s Compound Bate No Bleaching Agent Sol id Liquid No Other Info Stored State #37 Name ~ Formul a Use Hazardous? Hazardous Compound #38 Magnes i urn Oxide Muriatic Acid Hydrochloric Acid No No Solid Liquid - 30 gal drums Stored in Are a 14 Other Info Stor ed St ate �#39 '--../ #40 Name Formula Nytal 200 Talc Magnesium & Calciufu Silicate Oxalic Acid Use Hazardous? Hazardous Compound No No Other Info Stored State · Solid Sol id i #41 · -. Name Formula : Use Hazardous? Hazardous Compound Oleine Soap #42 P-540-AC Paste & P-540-TG Paste · Powder Adhesives No Soap No Other Info -.______/ Stored State Liquid Sol.id #43 #44 . NaiTie Po lyrner WT-3000 Forrnul a . Use Hazardous? Hazardous Compound 1-Ja ste;vater Tr ea unent No Resin Emulsion No Solid - 55 # b aq s @ WWTP in Area~ Liquid Other Info Stored St ate #45 .i Name Formula · Use Hazardous? Hazardous Compound Purex Granulated Salt Remsyno 1 m~s No Fat Liquor N/A Other Info ,Stored . St ate #46 Sol id �#47 Name Formu1 a Use Hazardous? Hazardous Compound #48 Resogen EW Solution Retan 540 Cationic Dye Fixative N/A Acrylic Syntan-Aqueou s N/A Liquid Liquid Other Info Stored St ate #49 Name Formula Use . Hazardous? Hazardous Compound #50 Salem Oil & Grease #282 Oil Satin Top #1478 Fat Liquor No Talc and Wax No Liquid Liquid #51 #52 Scotchauard _, . FC 236A FC 236B FC-152 . Seabophil #10 ~later Repe 11 ent Agent No Filler No Liquid - 55 ga1 drums Stored in Areas 15 & 17 Liquid . Other Info Stored St ate Name Formula Use Hazardous? Hazardous Compound Other Info Stored St ate .__,; �- - - - - - -- - - - - - - - - - - - - '--' Name Formula Use Hazardous? Hazardous Compound #53 #54 Soda Ash #100 Light Sodium Acetate Tanning or coloring No Coloring No Solid Solid #55 #56 Sodium Bicarbonate Sodium Bi sulfite Coloring No Coloring No Sol id Sol id #57 #58 Sodium Formate Sodium Perborate Tanning or Coloring No Colorino No Solid Solid #59 #60 Sodium Se sgu i carbon ate Sodium Sulfhydrate Tanning or coloring No Tanning No Sol id Solid Other Info Stored St ate ·. --: Name Formula Use Hazardous? Hazardous Compound Other Info Stored St ate \...__.,,, Name - Formula Use Hazardous? Hazardous Compound Other Info Stored State (; Name •· Formul a Use Hazardous? Hazardous Compound Other Info Stored State �#61 #62 \,_______,, Name Formula Use Hazardous Hazardous Compound Sod i um Su lf i de Sodium Tetrasulfide Tanning No Tanning No Other Info 30,000 gal recovery Stored State Solid Liquid-Recovery system 30,000 gal in Areas 7 Name Formula Use Hazardous? Hazardous Compound Solid &8 #63 #64 Sulfuric Ac id Tamol SD - ND Tanninq No Syntan No Bulk Liquid 9,600 gal max volume in Area 20 Liquid #65 #66 Te xo l C Titanium Dioxide A-410 Fat Liquor No Pigment No Liquid - 55 gal drums in ·Area 15 Sol id Other Info ,\_____,/ Stored St ate Name • Form ula Use Hazardous? Hazardous Compound Other Info Stored St ate �Name Formula Use Hazardous? Hazardous Compound #67 #68 Trisodium Phosphate Ucar Tanning Agent G-50 Cleaning Agent No Tanning Material No Solid Liquid #69 #70 Other Info Stored St ate Name Formula Use Hazardous? Hazardous Compound · Uni-Slip Zirotan 33 Anti Friction No Tanning Agent No So·li d Solid Other Info Stored State ~ : .. Name #71 #72 Lipsol ES Leukotan MB Fat Liquor No Resin Syn tan Liquid Liquid #73 #74 Syntan LP 1028 Mardo1l 55 oil Acrylic · Syn tan Yes Formaldehyde Fat Liquor No Liquid Liquid 55 gal drums in Area 15 Formula Use Hazardous? Hazardous Compound Other Info Stored State Name Formula Use Hazardous? Hazardous Compound \__J Other Info Stored St ate �Name Formula Use Hazordous? Hazardous Compound #75 #76 Causti c Soda NaOH Chrome Li quor Trivalent Chrome Tann ing Material No Mo Other Info Stored State Name Formula Use Hazardous ? Hazardous Compound Liquid Bulk Storage Volume 11,000 gal • In Area 8 Bulk Storage volume 13,800 ga.- - Recovery Stored in Areas 9 & 12 9,000 Delivery Stored in Area 10 #77 #78 Eastern 930 oil Formic Acid Fat Li quo-r No No Ot her Info ·Stored St ate 11,000 gal bulk storage Bulk liquid; 8100 gal max Area 19, 55 gal drums volume in Area 11 Area 18 • #79 Name Formula Use Hazardous? Hazardous Compound #80 Leukano l \.IJ-40 Surfonic JL-80X Syn tan Yes Formaldehyde Vl22 No Bul k liquid 11 ,000 gal max volume in Area 21 Biodeqradeable Surfactant in area 16 Bulk Liquid; maximum volume 11,000 ga l in Area 16 55 gal drums in Area 15 Nonionic ~urfactant Ot her Info Stor ed St ate �#81 #82 Kathon LP Wastev1ater Name Formula Use Hazardous? Haz~rdous Compound Funqicide Other Info 2-N-octyl-4 ISO Thiazolin - 3-one N/A - No Stored in Areas A- F • All plant wastewater, process waste and plant spills Max volume: 1,470,400 gal #83 . .. Name Formula Use · Hazardous? · Hazardous Compound Other Info #84 Sludge Alum No No Settled sludge from wastewater . Liquid bulk: 10,350 gal Maximum volume . in Area L Max Volume 177,000 gal in Areas G & H #85 Name Fo rmula Us e Hazardous? Haz ardous Compound Other Info _Grease/Fat #86 Manoanous Sulfate _, . . ~/aste1t1ater Treatment No No Recovery system m~x volume 35,150 gal in Areas 1-5 Including 20,000 gal bulk storage in Area 5 Solid-55 lb bags �i I • I #88 #87 Name Formula Use Hazardous? Hazardous Compound Other Info #6 Fuel Oil Mitco A-5-2 Reserve Fuel Supply Corrosion Controin Boilers No No 11,000 gal bulk storage 55 gal drums in Area 15 Tank underground, Area 22 #90 #89 Name Formula Use Hazardous? Hazardous Compound Silicone T-5032 & 55-4277 LS 1644-R Waterproofing Agent Lacquer cut solvent for Leather Dressing No No Liquid - 55 gal drums in Area 17 Liquid - 55 gal drums in Area 17 Other Info Solid . State �I APPENDIX C Dyes, Finishes and Solvents �APPENDIX C \.__,,I The follo1t1ing list includes all dyes presently being used at the facil~ty and their hazard potential. All dyes are stored in the warehouse and used in the dye area on the second floor of the tannery. The dyes are de1 ivered to the dye area as needed. It is in this area that spillage is most likely to occur, however little or no hazard to the environment is posed. Follo't11ng the dye facility. All list is a list of finishes and solvents used at the flammable materials are presently being stored outside the warehouse, all other materials are stored in the warehouse and delivered to the paint area on the second floor of the tannery as needed. Again , these materials pose little or no threat to the environment. The facility also uses a wide variety of chemicals on an experimental basis. These are all stored in the designated iJ.rea of the warehouse. . Because their quantity is so small, their use is limited, and the inventory is continually \____,/ \.....__/ changinq, these chemicals will not be listed. It should be noted that these chemicals are handled in the same manner as all other chemicals. �DYES Chemical \.___,,I 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 11. 12. 13. 14. \.____/ 15. 16. .17. 18. 19. 20. 21. 22. 23. a \.____/ 24. 25. 26. 27. 28. 29. 30. 31. 32. 34. Calcocid Milling Yell 01,<1 R Calcomine Yell ow 2G Calcomine Yellow 6G Calcomine Yell ow 8G Chrome Yello0 Light Code 95 Calcozine Phosphine 3G Calcocid Orange RR Calcofast Orange YF Caleocid Violet 4 BS Caleozine Bismark Brown RX Cone Intraehrome Yellow GR Cone Intralon Yellow GL Intraehrome Orange G Intrapel Blue R Intrape l Brown NOA Intrapel Brown HH 150% Intrape l Dark Brown PRL Calcoeid Eosin G Calcoeid Milling Red 3R Caleoeid Rubine XX Cone Se 11 a Fast Yell O\v G Se 11 a Fast Orange 2GC Sol ophenyl Blue GL Cone 150% Sol ophenyl Turquoise Blue GL Extra <:n 1 ·0,.,henyl pi Violet A2RL Sol ophenyl Violet 4BL Erio Green ET Extra Eriosin Vi olet 3B Se 11 a Fast Bro1tm CR Sella Fast Brown HL Leather Olive Brown G Sellaflor Grey RLN Neal an Black WA ..JU Hazard? Hazardous Compound N/A N/A ll II II II II II Yes N/A Lead Chromate N/A II II II II II II II II II II II II II II II II II II II II II II II II II II II II No No N/A II II N/A II II . II II II II II II II II II II II II No N/A N/A II II I �35. Neolan Yellow GR N/A 36. Auramine O Cone 37. · Sulfonine Red 3B 38. Derma Brown 2G Cone 39. Leathet Brown 2D C6nc 140% 40. Basic Black SLJ 41. Elcacid Metanil Yellow 42. Elcacid Orange YP 43. Elcacid Viol amine 44. E1cacid Black 10 BR 126% 45. Eltacid Nigrosine WSB Crystals • • 46. Bernatan Bro1tm -RMF 47. Calcozine Rhodamine 6GX ·• 48. Calcozine Rhodamine BX Cone · . 49. Calcozine Methylene Blue 2B Cone 50. Calcocid Naphthol Green B Coric 51. Ca lcoc id Mi 11 i ng Green CR Ex Con 52. Calcocid Hrmvn RD Ex . 53. Bernata.n Grey RG 54. Procion Yellow MX-3RA Further Testing Being Done • 55. Procion Yello'.<1 MX-8G 56. Proci on Ye 11 mv MX-GR 57. Procion Orange MX-G 58. Procion Orange MX-2R II 59. Procioh Red MX-5B 60. Procion Red MX~BB 61. Procion Scarlet MX-BRA 62. Procion Scarlet MX-G 63. Procion Blue MX-2G 64. Ptocion Blue MX~R N/A 65, Prbcion Navy MX-RB Further Testing Being Done 66. Procion Green MX-CBA No 67. Procion Brown MX~GRN Further Testing Being Done 68. Procion Brown MX-5BR II 69. N_yl amine Black D-2R II 70. AZO Silk Red 3B Cone N/A II II II II II II II II II II II 11 II II II II II II II II II II II II II II II II II II It II II II II II II II II II . II II II II II II II II II N/A None II II II �\.._/ , \,_/ i ~ \...__,/ 71. Chemtan Red NG 72. Chemtan Direct Fast Blue 16 BLLA Cone· N/A Yes N/A 0-d i an is id in e 73. Chernt an Direct Dark Green B-NB N/A N/A 74. Chemtan Para Green NN2 N/A N/A 75. Chemtan Direct Black GBFN No 76. Chemtan Direct BH-NB 77. Che11t an Direct Black BH-NB 78. LeVanol Fast Cyanine 5RN 182% 79. Saygenal 01 ive L-2G 80. Baygenal Brown CRV II II 81. Baygenal Dark Brown CGV II II 82. Baygenal Brown CGG II II 83. Ac i derm Brovm ER N/A N/A II " II N/A N/A " II No 84. Baygenal Brown CT II 85. Baygenal Brown L-N2G II II 86. Baygenal Grey L-NG II II 87. Baygenal 01 ive Brown LG No 88. St il bene Ye 11 ow 5G N/A N/A 89. Phenamire Fast Scarlet 4BGP N/A N/A 90. Brilliant Millinq Blue BA II II 91. Lugatol Broi,-m NT II II 92. Luqato l Brovm NGB No 93. Lugatol Brown N3G II II 94. I sol an Yell m,1 NW 250% N/A N/A 95. ./'.\c i derm Fast Orange GS II II 96. Lugatol Blue NL ll II 97. Lugato l Violet NR II II 98. Luga to l Green NG II II 99. Hydroso1 Ye 11 ow 3RT II ll 100. Hydrosol Brilliant Red BCL II II 102. Hydro sol Supra Brovm GGL II II 103. Hydrosol Orange Brown RR II II 104. Hydro sol Yell ow Brown GG II Ii 105. Hydrosol Red Bro~vn GR II II 106. Hydrosol Brown BR II II 107. Hydrosol Supra Brown BT II II 108. Hydrosol Supra Cutch RL II II �109. Presto #3925 Calco Orange 110. Presto #4072 Haun Dawg llO. Presto #4468 Windsor Greeh 111. Presto #4960 Classic Camel 112. Presto #3606 113. Presto #4221 114. Atlantic Direct Fast Orange WS Cone 150% . 115. Atlantic Direct Fast Orange EGL 150% 116. Presto #4959 Wi sky 117 . Presto #4610 Coppertone 118. Presto #4969 Friar Bro\'m N/A N/A II II II II II II II II II II II II II II II II II II II II �INVENTORY OF PAINTS ANO SOLVENTS Product Name Storage Location Product Use MIBK Outside solvent Wh se Whse ~~h se Whse Wh SC Whse Pigment Pigment Piqment Pigment Pigment Pigment LS 585 LI>/ 2584 M LW 2591 M LW 2592 M LW 2593 M ll•J 2595 M U~ 2582 M SP 9109 PT 756 RI 1144 LS 3003 WV 2500 WV 2502 WV 2568 S 546 P 241 ~~hse Wh se Whse Whse Whse Wh se 41 41 41 41 41 41 41 41 41 41 41 41 Wh se 41 7420 em ulsion emulsion emulsion emulsion emulsion emulsion Water base additive (soap) Water base penetrator Water base impregnation resin Alcohol cut dye solution Water cut urethane emulsion Water cut urethane cat alyst Water·cut urethane emulsion Silicone solution ~Jater base resin Water base driver FL 20 Primql Cherry Red ~lh se 41 Water base resin Water base pigment . 3763. Wh se 41 ~1hse 41 Water base resin 2252 A JA-91-902 JL 2 382 Hhse 41 Wh se 41 R50 T- 5032 SS-4277 UPKR-347-08 Isopropyl Alcohol 997 ,\____,, lacquer lacquer lacquer lacquer lacquer lacquer Meth-yl Ox ito l Outside Outside Outside Water base resin Water base resin Water base resin Water base resin L-Jax emulsion Silicone solution Silicone solution Urethane emulsion pigment Alcohol Water base resin So1vent �Product Name Mineral Spifi ts 15-190 71-261M RU-4612 • 2357 RB1600 UJ88HF 2084NP • 2089NP 666 4503 • FL1423 PT 790 \,__,I Storaae Location w'hse \,Jh se Whse \,Jh se \,/hse t✓h se . v/hse Whse Whse \,Jh se •. \,Jhse Wh se t./hse 41 41 41 41 41 41 41 41 . 41 41 41 41 41 Product Use Solvent Water base f i 11 er Water base filler Ureth emulsion resin Water base resin Water base resin Water cut lacquer emulsiion Water base pigment • Water base pigment Water base resin Water base pigment Water base wax emulsion Water base driver �APPENDIX D Loading, Unloading and Inventory Control Procedures \_,I �RECEIVING OF BUl_K CHEMICALS BY TANK, TRUCK, OR CAR 1. All receiving of bulk liquid chemicals will be done on days and a sample must be tested by the tannery lab before authorization to unload is given. 2. The tank truck is to be weighed in on hide house scales by the hide house foreman or receiving clerk; they are to decide if we have adequate capacity to store the delivered material. 3. The hide house for~man is ·ti direct the driver to the proper unloading site and to contact the plant superintendent and the :naintenonce department. 4. The hide house foreman must obtain a sample of the chemical from the truck by the. follovving means: (NOTE: Protective eye\>lear and rubber gloves and apron must be worn-:-JA. a. Non-pras~urized v~hicles The sample rnust ' be obtained through the top hatch of the tanker. Pressurized vehicles The sample may be drawn off from the sampling line. • The chemicals are to be tested 6gainst standard, by the tannery lab, by the prescribed procedure, in order to insure that the quality of th e sample is up to ·st-andard and that the bill of lading properly identifies the chemical to be received. I. 5. If all quality standards are met, the hide house foreman moy obtain the key to the lockout device from the plant superintendent . and remove the lock from the rec~iving line. The foreman and plant superintendent are to then sign ov~r authorization for unloading to the maintenance department. 6, The maintenance personnel are to supervise the unloading of the tank truck, in order to insure that the proper safety precautions for unloading are being observed. 7. When the unloading of the truck is completed, the maintenance personnel are to lock up the receiving line immediately and return the authorization slip to the maintenance foreman for prope r signature, The maintenance foreman then returns the authorization slip to the hide house foreman for signatur~; who then gives the slip to the plant superintendent. After all proper signatures are obtained, the authorization slip should be sent to the tannery lab. 8. The chemical truck i s then to be weighed and bill signed by the hide house foreman o r receiving clerk. �WOLVERINE WORL.D WIDE ..; LEATHER DIVISION l\UQjQRIZt\TION AN_D PROCEDURE SLIP FOR UNLOADING OF BULK LIQUID CHEMIC.~LS \.._..I This check 1 i'~t must be f i l h,d out cmd signed each time a deli very is made. 1, 2. Driver of delivery truck must report to the hie house foreman or receiving clerk for weigh-in. A. Maintenance must then be notified. B. Plant superintQnderit must be notified. Verification of Liquid Chemical is to be made by Tannery Lab using both certified bill of lading o~d testing procedures. DATE: VISUAL CHECK: ------------------ PHYSICAL TESTS: . "--../ Viscosity --------- pH: ------------- 3. Permission to unlock receiving line must be given by plant supt. 4. Verbal notification to department foreman using the product. 5. Proper signs to be placed at valve sites to indicate unlociding of liquid chemicals prior to. unl-oading procedure. ---------------- 6. ·Maintmriance Signature: Removal of lockout system -0nd unloading. 7. Removal of signs and the replacement of the lockout system is to be done by maintenance employee. Maintenance Signature: Foreman's Signature: 8. ------------ Tirne: -----------'--- Time: ---AM/PM ----- .t\M/PM Verbal notification tc, the depar-trnent using those products that th .;i unloading procedure has been completed. I/we the undersigned hQve used the above procedures fo~ unloading liquid chemicals at our tannery operation. - -·- - - - - - - , - - , - - - - , 0 - - - - - ~ - - - - Receiving Supervisor - · ---~· -··--- ·---Maintenance Employeo Maintenance Supervisor - - - - - - - - - - -- '-....../ I · • >GI ..... - - - - - -- - - - - - �APPENDIX E Inspection Report Form �APPENDIX E. Inspection Report Form '-._./ Item Sat. Un sat. Remarks Corrective Action Date and Initials of Inspection Evidence of tank leakage Adequate amounts of absorbents and neutralizing agents on hand Evidence of pump, piping, ~or valve leakage Materials stored in designated storage areas Integrity of all containment and drainage :5ystB11S ' .'-.___/ Comments Spill Prevention Supervisor Signed - - - - - - - - ' - - - - - Date ---------'------ �'-.....,/ APPENDIX F Site Plan, Storage Areas and Major Use Areas ~ �Artifact 33 ��Artifact 34 �POLLUTION INCIDENT PREVENTION PLAN FOR WOLVERINE WORLD WIDE, INC . Project No. 81846/94-2 October; 1981 Prepared by: Fishbeck, Thompson, Carr & Huber, Inc . 1500 East Beltline, S.E. Grand Rapids, Michigan 49506 �9/ 20/90 \ ....1 MSDS Sheet !?age 148 MSDS Date: 2/89 04-187 SCOTCHGARD FC 228 Cat: SOLVENT Sup/Manuf: 3M 14 Targ:SKIN Haz/Non-Haz:H Depts: Personal Health Code: B Indexes-> Health: 2 Fire: 3 Rea<=;.t ,ivity: o:· Experimental?: Y SARA III?: EPA: CAS Number Threshold Hazardous Ingrediant . . . . . . . . . . . End of # 04-187 MSDS Date: 7 / 87 04-292 SCOTCHGARD FC 229 Cat: SOLVENT Sup/Manuf: 3M 14 Targ: Haz/Non-Haz:H Depts: Personal Health Code: B Indexes- > Health: 2 Fire: 2 Reactivity: 1 Experimental?: Y SARA III?: EPA: CAS Number Threshold Hazardous Ingrediant 000112-34-5 35 PPM 1 DIETHYLENE GLYCOL MONOBUTYL ETHER NE 2 FLUOROCHEMICAL URETHANE . . . . . . . . . . End of# 04-292 19-483 SCOTCHGARD FC 233 B MSDS Date: 12/89 Sup/Manuf: 3M Cat: SOLVENT Haz/Non-Haz:H Depts: 14 19 Targ:EYE, LUNG, SKIN,INGEST Personal Health Code: E Indexes-> Health: 2 Fire: 4 Reactivity: 1 SARA III?: Y EPA: 1 4 Experimental ?: N CAS Number Threshold Hazardous Ingrediant 108-10-1 50 PPM 1 MIBK (17t) 6'1-64-1 750 PPM 2 ACETONE ( 1 t } 107-21-1 50 PPM 3 ETHYLENE GLYCOL ( 8%) 9005-65-6 NE SORBITAN,MONO-9-OCTADECENOATE DERIV . 4 38006-74-5 NE 5 1-PROPANAMINIUM DERIV . . . . . . . . . . . End of# 19-483 MSDS Date : 4/89 19-349 SCOTCHGARD FC 236 A Cat: SOLVENT Sup/Manuf: 3M Targ:EYE, LUNG, SK!N,INGEST Haz/Non-Haz:H Depts: 14 19 Personal Health Code: J Indexes-> Health: 3 Fire: 4 Reactivity: 0 SARA III?: Y EPA: 1 2 4 Experimental ?: N Hazardous Ingrediant CAS Number Threshold 1 IPA (60%) 67-63-0 400 PPM 2 FLUOROCHEMICAL CR+3 CPD (2-30t) 68891-970.5 MG/M3 3 TRIVALENT CHROMIUM CONTENT {1.5t) 7440-47-3 0.5 MG/M3 4 HEXAVALENT CHROMIUM CONTENT (<0.1t) 7440-47-3 0.5 MG/M3 . . . . . . . . . . . End of# 19-349 21 -351 SCOTCHGARD FC 905 MSDS Date: 6/89 Sup / Manuf: 3 M Cat: SOLVENT Haz/Non-Haz:H Depts: 21 Targ:EYE, LUNG, SKIN.INGEST Fersonal Health Code: J Indexes-> Health: 3 Fire: 1 Reactivity: 0 SARA III?: Y EPA: 1 Experimental?: N Hazardous Ingrediant CAS Number Threshold 1 1 ,1,1-TRICHLOROETHANE {90t) 71-55-6 350 PPM . . . . . . . . . . End of II 2 1 - 3 5 1 19 -350 SCOTCHGARD FC-236B MSDS Date: 4/89 Sup/Manuf: 3 M C~t: MILD ACID Haz/Non-Haz:H Oepts: 14 19 Targ:EYE, LUNG, SKIN,INGEST Personal Health Code: B Indexes- > Hea l th: 2 Fire: 3 Reactivity: 1 SARA III?: 'i EPA.: 1 Experimenta l?: Y Hazardous Ingrediant CAS Number Threshold 1 FLUOROALKYL URETHANE NE 108 - 10-1 2 MIBK (7-t) 50 PPM 101-21-1 50 PPM 3 ETHYLENE GLYCOL ( 8t) . . . . . . . . . End ·of # 1 9 - 3 5 0 �MSDS Sheet Page 149 04-361 SCOTCHGARD FX 3564 MSDS Date: 11/88 Cat: SOLVENT Sup/Hanuf: 3M 14 Targ:EYE, SKIN Ha z / Non-Haz:H Depts: Fire: 2 Reactivity :_ Pe rsonal He~lth Code: B Indexes- > Health: Experimental ?: Y SARA III?: Y EPA: Hazardous Ingrediant CAS Number Th'res'ho'ld 2-(2-BOTOXYETHOXY)-ETHANOL (20 %) 112-34-5 335 PPM . . . . . . . . . . End of# 0 4 - 351 2 1-215 SD 182 MSDS Date : 3/36 Sup/Manuf: STAHL FINISH Cat: SOLVENT Targ: Haz / Non-Haz:H Depts: 21 ?ersonal Health Code: B Indexes- , Hea l th: 2 Fire: 3 Reactivity: 0 SARA III?: EPA: Exper 1mental ?: N CAS Number Threshold Hazardous Ingr ediant NE COMPONENT C COMPONENT B 25 PPM 3 DENATURED ALCOHOL 955 PPM . . . . End of II 21-215 Z1-216 SD 183 MSDS Date: 1/86 Sup/Manuf: STAHL FINISH Cat: SOLVLENT Haz/ Non-Haz:H Depts: 21 Targ: Personal Health Code: 8 Indexes-· Hea :th : 2 Fire: 3 Reactivity : 0 SARA III?: EPA: Exper i men t a l ?: N Hazardous Ingred1ant CAS Number Threshold COMPONENT C NE DENATURED ALCOHOL 955 PPM 3 COMPONENT B 25 PPM . . . . . . . . . . End of# 21 - 216 21 -217 SD 186 MSDS Date : 6/ 8 1 Sup/Manuf: STAHL FINISH Cat: SOLVENT Haz/Non-Haz : H Depts : Targ: 21 Personal Health Code: 8 Indexes- > Health: 2 Fire: 3 Reactivity : O SARA III?: EPA: Experimen t a l ?: N Hazardous Ingrediant '.:AS Number Threshold DENATURED ALCOHOL 1000 !?PM ., COMPONENT B 25 PPM . . . . . 0 4-528 .. . . . . . . End of # 2 1 - 2 1 : SELLA FAST BROWN DGR MSDS Date: 7/8~ Sup/Manuf: CIBA-GEIGY CORP. Cat: DYESTUFF Haz / Non-Haz:N Depts: 14 Targ:N / A Personal Health Code: E Indexes- > Hea l th: ' fire: 0 Reactivit y: 0 Experimenta : ? : Y SARA III?: N EPA: Hazardous Ingrediant CAS Number Thresho ld NONE . . . End of# 0 4-528 1S-270 SELLACRON BLUER MSDS Date: 1 _1 8 4 Sup/Manuf: CIBA-GEIGY CORP. Cat: DYESTUFF Eaz/Non-Haz:H Depts : 14 19 Targ: Persona l Health Code: E Indexes- :. Health: 1 Fire : O Reactivity: SAR~ III?: EPA: Exper1men:a l ?: Y Hazardous Ingrediant CAS Number Thres hol::l. CHROMIUM 0.5 MG / M3 . . . . . . . . . . End of # 19- 27C 19 -27 1 SELLACRON BROWN CL MSDS Date: 7 /80 Sup/Manuf : CIBA-GEIGY CORP. Cat : NON - HAZ DYESTUFF Haz / Non-Haz:N Depts: 19 Targ: Personal Health Code: E Indexes- i Hea lth: 1 Fire : 0 Reactivity: ~ SARA III?; N EPA: Exper 1menta ~ ?; N Haz ardous Ingred iant C:AS Number Threshold NONE �CN rn, c.~/J er--· - L---=~~ """'Fi"...•. tl.. - WOLVERINE Leather.. 123 NORTH MAIN STREET ROCKFORD, MJCHIGAN 49351 USA TELEPHONE 616-866-562.3 April 20, 2005 FAX 616-866.-3680 .-, p;; !-\ • r-. ('r, /J •1 ?(1· oi::· :.. '- • •J LEATHER FINISHING NESHAP: , INITIAL NOTIFICATION OF COMPLIANCE STATUS Am :\:_;;.1:.i:~ ,_.,_-_.:•,.,.•;" ~- :B1't, ·•:£;rhP\~:_•. •. ·r ~ l•~. r This initial notification of compliance status is being submitted in accordance with the applicable provisions of the National Emission Standard for Hazardous Air Pollutants ("NESHAP") for Leather Finishing Operations (40 C.F.R. § 63 Subpart TTTT) and the NESHAP General Provisions ( 40 C.F.R. § 63 Subpart A). NOTIFICATION OF COMPLIANCE STATUS 1. (40 C.F.R. § 63.5415(0) The name and address of the owner or operator. (40 C.F.R. § 63.5415(/)(1)) Wolverine World Wide, Inc. 9341 Courtland Drive Rockford, Michigan 493 51 USA Phone: (616) 866-5500 The physical address oftlte leather finishi1tg operation. (40 C.F.R. § 63.5415(/)(2)) Corporate Office: 2. Facility: 3. Wolverine World Wide Tannery 181 North Main Street Rockford, Michigan 49351 USA Each type of leather product process operation performed during the previous 12 months (from February 27, 2004 through February 28, 2005). (40 C.F.R. § 63.5415(1)(3)) Spray Line 1: Spray Line 1 is used to make color corrections to the leather and meets Product Process Operation classification #4, "non-water resistant leather" with an applicable emission limit of3.7 lbs HAP per 1,000 sq. ft. of leather finished. Spray Line 3: Spray Line 2 is used to add water-resistant finishes to leather and meets Product Process Operation classification #3, "water resistant leather" with an applicable emission limit of 5.6 lbs HAP per 1,000 sq. ft. of leather finished. CmTently there are no HAP materials used in this operation. Material usage is monitored by the Lab Manager and the use of any HAP containing materials would be handled accordingly. . s,vAB: SWAB is used to apply finishes that meet Product Process Operation classification #3 "specialty leather" with an emission limit of 5 .6 lbs HAP per 1.000 sq. ft. ofleather fini shed. 4. Each HAP identified under§ 63.5390 in.finishes applied during the 12-month period used/or the initial compliance determination. (40 C.F.R. § 63.5415(/)(4)) According to information provided by the suppliers and/or manufacturers, the HAPs used in the s applied from February 27, 2004 to February 28, 2005 are as follows: Butyl Carbitol (N230 Glycol Ether) Triethyl amine Chromium Compounds Cobalt Compounds Fine Mineral Fiber (Silica and Talc) , ... J �Wolverine Leathers - Initial Notification April 20, 2005 Page 2 of2 5. Compliance status certification indicating whether the source complied with all of the·· • requirements of this subpart throughout the 12-month period used for the initial source compliance determination. (40 C.F.R. § 63.5415(/)(5)) (i) The plan for demonstrating compliance, as described in§ 63.5325, is complete and available on site for inspection. (40 C.F.R. § 63.5415(/)(5)(i)) (ii) Wolverine Leathers is following the procedures described in the plan for demonstrating compliance. (40 C.F.R. § 63.5415(/)(S)(ii)) (iii) The compliance ratio value was determined to be less than 1.00 for each operation for the periodfrom February 27, 2004 to February 28, 2005. (40 C.F.R. § 63.5415(/)(S)(iii)) I certify that, based on information and belief formed after reasonable inquiry, the statements and information in this notification are true, accurate and complete Paul K. Lloyd, Vice President 0 (Responsible Official) April 20, 2005 Date �- -- - - - - - - - - - - - -- - -- -- REPORT OF FINDINGS REGARDING RESEARCH OF CHEMICAL USAGE AT WOLVERINE TANNERY: ·---- Recent e-mail from Janice Tomkins to Rick Rediske and Lynn McIntosh On page 17 and 18 of the Citizen Response to Wolverine's response to the US EPA 104e I talk about Wolverine having various forms of Scotchguard stored outside without containment at their site. This is based on a 1981 Pollution Incident Prevention Plan for Wolverine World Wide, Inc. dated Oct 1981 and prepared by Fishbeck, Thomson, Carr and Huber, Inc. I found this plan in the City of Grand Rapids IPP Program files. A copy is found in Appendix 18 of my response. The scotchguard references are found in Appendix A of this 1981 report. Appendix A "includes all the bulk stored materials, tank volumes, construction material and containment information where applicable. Also included in this list are the major non-bulk storage and major use areas in reference to the labeled site plan found in Appendix F of this report. OUTDOOR CHEMICAL STORAGE The following chemicals are presently stored in Area 15: #13 Busan 30, #18 Chemol 21, #24 D-terge X 348 #27 Emulsan 20W #51 Scotchguard FC-236A, FC-2368, FC-152 (More chemicals are list for Area 15) The following chemicals are presently stored in Area 17: # Busan 30 #51 Scotchguard FC236A, FC-2368, FC152 (More chemicals are listed for this area.) Also found in Appendix B where is has said it is not a Hazardous compound. The Appendix F of this report has a site plan that shows were area 15 and 17 are and that there is no containment there. I have no documentation that there was a spill of the Scotchguard material. Only that they had it on site and it was stored outside. �Artifact 35 �POLLUTION INCIDENT PREVENTION PLAN FOR WOLVERINE WORLD WIDE, INC. Project No. 81846/94-2 October, 1981 Prepared by: Fishbeck, Thompson, Carr & Huber, Inc . • 1500 East Beltline, S.E. Grand Rapids; Michigan 49506 �OUTDOOR CHEMICAL STORAGE The followinq chemicals are presently stored in area 14: # 1 Ace t i c Ac id #38 Muriatic (Hydrochloric) Acid The following chemicals are presently stored in area 15: #80 Busan 30 Chemol 21 D-Terge X 348 Emulsan 20W Scotchguard FC-236A, FC- 236B, FC-152 Texol - C Mardo l 55 Oil and 930 Oi l Surfonfc J - 4 #88 Mite □ #13 #18 #24 #27 #51 #65 #74 A - 5 - 2 The following chemicals are presently stored in area 17: #13 #51 #89 #90 Busan 30 Scotchguard FC- 236A, FC-236B, FC-152 Silicone LS - 1644 - R M.I.B .K . The following ch em ica1s are presently being stored in area 18: #33 #77 #34 Isopropyl A1cohol Eastern 930 Oil Linea Levelin L �fI .,. ) 11 ,. I I STORAGE TANKS AND AREAS I I ~! II! ti lI 'I, DSA* - Stored Material Location Elevation Volume Tank Construct WW Plant Screen inq Channel Sub 6,700 gal Concrete W W Pl ant Wet Well Sub 7,900 qa·1 Concrete W \tJ Pl ant s. Clarifier Elev 286,300 gal Concrete D. ~~as tewa ter W W Pl ant Transfer Wel 1 Sub 19,200 gal Concrete E. Wastewater \tJ W Pl ant Elev 864,000 gal Steel A. Wastewater ' ~I Containment Dimensions Containment Volume none Containment Construction none none 680 gal Concrete ~I I B. Wastewater 11! II' ill Iii C. \✓as t ev,a ter lil I" /fl ii ii I',I ii Aeration Tank i ! F. Wastewater W W Pl ant N. Clarifier Elev 286,300 gal Concrete G. Sludge W W Pl ant Sl udqe Thickener Elev 176,000 gal Concrete H. Sludge W W Pl ant S1 udqe Cond Ta.nk Elev 1,000 gal Steel Fiberglass Coating I. Lime W vJ Pl ant Lime Storage Bin Elev 1,900 Ft Steel I!, i l il .':1• J. Lime s·1 urry W W Pl ant Lime Slurry Tank Elev 680 Gal Fiberglass :/, *Designated Storage Area - These areas are denoted on the enclosed site plan. II I 't [! II I ii l I 1I !/· 1J 111 'I lit J 17 1 xl6 1 x0.33 1 with drain �·=-··----·--•---,---- ~ ., ---,.,,.....,,.."'"'"''"""""'" __,.,.,.,..., ., '0 I ~ STORAGE TANKS AND AREAS (continued) DSA Stored Material Locat ·ion E·Ievation Volume Tank Construct Containment Dimensions Conta·i nment Volume Containment Construction K Ferrous Chloride WW Plant Ferrous Chloride Tank Elev 10,350 gal Fiberglass 30'xl4'x4' with drain 9200 gal Concrete L. Alum W W Pl ant Alum Storo.ge Tank Elev 10,350 gal Fiberglass 30 1 xl4'x4 1 with drain 9200 gal Concrete M. Polymer ~~ W Pl ant Polymer Mixing Tank Elev 80 qa l Fiberglass 17 1 xl6 1 x0.33 1 with drain 680 ga 1 Concrete 1. Grease Hide house Air Flotation Unit Elev 5800 gal Steel drain 2. Grease Hi de house Fat Settling Co 1umn Elev 350 gal Steel drain 3. Grease Hi de house Cooker Elev 2 @ 2500 gal Wood drain 4. Fat Hide house Fat Storage Tank Elev 4000 gal Steel drain 5. Grease Color Depart. Grease St oraqe Tank Elev 20,000 ga 1 Steel drain 6. Sulfide Hi de house Sulfide surge Tank Elev 12,000 gal Concrete drain �..AND AREAS; (continued) DSA Stored M;aterial 7. •S.ulf i de Tank . Con.struct • Hide.. house .. SHlf"iEle re- Elev Containment Dimensjons 6 Fiberglass 28 1 11 ;33 1 6"x3' with. ump 21,400 gal Fiberglass 12'x26 1 x4 1 7800 gal covery Tanks 8. Sodi un • Hydr.oXi de ,- Jlicie house ..· Causfi c Tanks 9. • Chrome Tanyard Chrome Recovery :Tan~,s 10. Chrome Tanya . Chrorne •. Star.age Tanks · Elev 11 . . Formic Acid Elev )~. Chrome .El ec 8,100 gal with drain Lime . Shed Ne·ar RR )ra cks < .' 5,000 gal Elev ~ 14. See listing Outside Lime Sh,ed. 15. See 1istin.g East of . Urne Shed 16 . Sur fo n i c J- 4 0uts i de. Co 1or Dept. Adjacent to Sou th Shipping Dock E1ev . 11,000 gal Steel none J �STORAGE TANKS AND AREAS (continued) DSA Stored . Material Location Elevat·ion Volume Tank Construct Containment Dimensions 1 7. Se e l i s t i ng We s t of Warehouse 18. See listing SW Corner of Po1t1er Pl ant 19. 930 Oil & 55 Oi 1 Col or Dept. Elev 11,000 gal Steel none 20. Sulfuric Above Pasting Department Elev 9,600 gal St ee 1. none 21. Leukanol Tanyard Elev 11,000 qal Fiberglass none 22. #6 Fuel Oi 1 Underqround Near Pov,er Pl ant Sub gr a.de 11,000 gal Steel none 23. Dyes Warehouse 24. Finishes & Warehouse Acid (2 Tanks) Lacquers 25. Empty Drum Storage Westside of Tannery Outside 26. Hide house 27. Warehouse loading dock loading dock 28. Hydraulic Oil Tin Shed none Containment Volu~e Containment Construction �Artifact 36 ��Artifact 37 �Wolverine kept PFAS outdoors at polluted tannery Posted Jun 17, 2018 66 Gallery: The Wolverine Worldwide tannery in Rockford 0 shares By Garret Ellison | gellison@mlive.com ROCKFORD, MI -- Historical records show that Wolverine World Wide once stored toxic chemicals that are polluting the Rogue River in an unpaved area outdoors at the footwear company's former leather tannery complex in downtown Rockford. A pollution prevention plan from 1981 shows that drums of per- and polyfluoroalkyl substances, or PFAS, were kept outside at the tannery near locations where recent testing has found extremely high levels of the chemistry in the soil and groundwater. The 1981 document, obtained though the Freedom of Information Act, may not have been provided to either the state or federal governments in response to mandatory record seeking related to an ongoing pollution investigation in Kent County. Neither the Michigan Department of Environmental Quality nor the U.S. Environmental Protection Agency would definitively say whether Wolverine provided the document in response to a state subpoena and a federal request for information. Other records obtained through FOIA show that regulators were unhappy with Wolverine's chemical storage at the time, but attempts to cajole changes at Wolverine were rebuffed. Records show that Scotchgard storage was eventually moved indoors. Academic experts who have independently analyzed records related to Wolverine use of PFASladen 3M Scotchgard fabric protector say the outdoor chemical storage could help explain the high contamination levels at the site, which is undergoing extensive pollutant testing this summer under EPA supervision. "Any spill that occurred in the storage area would certainly go into the groundwater," said Richard Rediske, a Grand Valley State University chemistry professor who first alerted the DEQ last year to Wolverine's historic PFAS usage. Wolverine tannery back in EPA crosshairs 5 years later �Arsenic, chromium, lead and PFAS befoul toxic site. According to the 1981 Pollution Incident Prevention Plan (PIPP), Wolverine kept several varieties of Scotchgard outside near a warehouse at the south end of the manufacturing complex where tanned pigskin hides became iconic shoe brands like Hush Puppies. Today, the soil and groundwater under the demolished complex and the adjacent river are highly polluted with PFAS, a class of chemicals which gave Scotchgard its waterproofing abilities. Human studies have shown probable links between PFAS exposure and kidney cancer, thyroid disease, pregnancy complications and other illnesses. Documents show Wolverine Worldwide once stored PFAS chemicals outdoors at its former tannery in Rockford. Testing confirms PFAS in sediment in the Rogue River and Rum Creek, a tributary that flowed directly underneath the tannery and Hide House buildings where records show that Wolverine stored Scotchgard chemicals indoors. There is a PFOS fish consumption advisory in the river nearby and recent testing found extremely elevated PFAS levels in surface water foam at the Rockford Dam. The Rogue River was formerly the drinking water source for the city of Rockford, which switched to groundwater supply wells in 2000. Experts say the former surface water treatment plant downstream of the tannery would not have removed PFAS. �Rockford may have been drinking contaminated water before 2000 Experts say the city's old river treatment plant would not have removed PFAS. Wolverine's own data shows the highest concentration of PFAS in the tannery groundwater is along the southwest corner of the property along the White Pine Trail, near a historic low area where upland drainage entered the river near a pump house that Wolverine formerly used to source water for tannery operations. According to the 2017 testing, the groundwater in that spot is contaminated with 532,000 parts per trillion (ppt) total PFAS -- about 330,000-ppt of which is PFOS, a highly bioaccumulative toxicant that was Scotchgard's key ingredient for decades. "Everything seemed to drain into that particular spot," said Rediske. Wolverine blamed the 100-year manufacturing history at the tannery grounds when asked to speculate why there are such high PFAS levels at the site. "Over decades of operations, and not unlike many other industrial operations, it appears some of the materials migrated into the soil," Wolverine said in a statement. The 1981 pollution prevention plan was obtained by the Concerned Citizens for Responsible Remediation (CCRR) in Rockford, a local watchdog group that petitioned the EPA in 2011 to investigate the tannery. The document is on file with the city of Grand Rapids, which accepted pre-treated Wolverine industrial wastewater at the city's sewage treatment plant on the Grand River until 2008. The Oct. 21, 1981 document was authored by the Grand Rapids-based engineering firm Fishbeck, Thompson, Carr and Huber, or FTCH. An MLive review of records provided under FOIA did not locate a copy of the 1981 plan in the thousands of pages Wolverine submitted to the DEQ as part of a subpoena for evidence in a pending federal case between Wolverine, the DEQ and Plainfield and Algoma townships. �The 1981 plan was also not found in records provided to the EPA as part of an investigative information request known as a 104(e) issued in early December. It was also not provided to EPA in response to a similar request in 2012. The DEQ declined to comment on whether the plan is something investigators would expect to receive as part of state record-seeking. Wolverine would not confirm it gave DEQ and EPA the 1981 plan, stating that "the PIPP is a document that was continually updated as facts developed at the tannery site." "Wolverine produced more recent versions of the PIPP to EPA, including in 2012," the company said in a statement, noting that it "continues to supplement its response to those information request as additional documents are located." The 1981 plan shows other chemicals stored in drums outside with Scotchgard included acetic and muriatic acids, fungicides, machinery cleaners, surfactants, textile lubricants, tanning oils, silicone and volatile organic solvents like methyl isobutyl ketone (MIBK). The outdoor storage caught the attention of regulators at the time, who expressed concern with keeping hazardous chemicals in areas without pollution containment. In a Sept. 14, 1982 letter to Wolverine environmental manager Harold Bailey, Michigan DNR water quality specialist John Bantjes wrote that Wolverine should store all "drummed liquids" inside and only keep clean, empty drums outdoors. Bantjes, who had inspected the tannery a few weeks prior, also noted that a tin machinery shed near the warehouse should not also house chemicals, because "drum puncture is a likely event during machinery movement!" "Lack of secondary containment at that site will result in runoff of spilled material to the ground," Bantjes wrote. Wolverine responded a couple weeks later by refusing to significantly modify pollution containment at the tannery unless the work happened in conjunction with an expansion project that was stalled by a "depressed market conditions for leather goods." Until the "present economic climate changes," wrote hired engineer Carl Huber, "no major reconstruction projects are being undertaken by Wolverine World Wide." The outdoor chemical storage was noted about a decade later in a 1994 Environmental Site Assessment by the DNR, which was considering an easement swap with Wolverine for a railroad right-of-way that crossed lengthwise through the tannery. The deal resulted in construction of the White Pine Trail segment along the river. Chemical storage had moved inside by 1993, the DNR noted. Subsequent year pollution prevention plans show Scotchgard was stored on the third floor of the tannery building and the Hide House. �EPA records show that Scotchgard was delivered to the tannery monthly by truck and, according to pollution plan updates in 1990, 1994 and 1996, the chemicals were stored in areas designed to drain spills to the tannery wastewater treatment plant. The records show Wolverine bought numerous products from 3M over the years, including reflective inks and color dyes as well PFAS products like Scotchgard. The company also used products containing various amounts of fluorochemicals from other sources. A 2000 tannery hazardous air pollutant summary shows that 16,590 pounds of Scotchgard FC3573 and 64,409 pounds of Scotchgard FX-3573 were kept on hand. In the early 2000s, 3M reformulated Scotchgard to remove PFOS after EPA determined the chemistry was toxic to humans, magnifies up the food chain and persists in the environment. Wolverine and 3M met to discuss the matter in 1999. 3M document shows Wolverine knew about PFAS in 1999 Wolverine has said it didn't know Scotchgard contained toxicant until 2016. The new version, Scotchgard PM-4700, was stored in plastic and metal totes at the tannery. The reformulated version's key ingredient is PFBS, a PFOS replacement chemical for which federal health regulators are currently drafting a toxicity risk assessment. High PFBS levels are also found in tannery site groundwater. Rediske, who analyzed Wolverine's patented process for treating pigskin leather hides with Scotchgard as part of his initial memo alerting DEQ to the company's usage, said the leather was dipped in Scotchgard at the tannery before drying. Scotchgard application occurred toward the end of treatment, he said. Rediske said it's not known how Scotchgard was stored at the tannery prior to 1981. Wolverine began using Scotchgard in Rockford in 1958. "The plant was there a long time," he said. "Lines and valves break." �Artifact 38 �- . . . Table tb. Targeted Monitoring Locations on the Rogue River and Rum Creek. Macroinvertebrab _.. . . .. Site • Water County ·Latitude Longitude Habitat Evaluation Community Body ID Rogue 2 Acceptable 161 43.13277 • -85.55710 Excellent Kent 1 River Rum -6 Poor 109 Good 43.12360 -85.56139 Kent 2 Creek /" · Rogue 43.12307 -85.56208 Kent 3 River Rogue Kent . 43.12094 -85.56142 4 - Ri"~r .. ~ 0~ Nofe: ,----- " StTE t I) 3 ~ 4 ~hoW n o ,.es:ult-s. becau.re. -Ht~ !PL.re u:Jn.,n ~ l ()ea,f-/::,./1 ~ . n o n - ~ ~ •· Ntk onlL/ artL ..fl,z.e.~ ~ loca.fi<fnS wa.Jafo~ ~f>lR ,',,, Lalt./>.C"-' ~ Qrtl..G:i" . .5~1/ot.v., 5 canot la(,J.) $,- rn;:;;:t l3ecau.ce t:,{2 COhU,/11.J... for.~' C..... ~ J --/1,./S- ~ - . f - OffJrfu,,·, ~ ~ J J 1'te_ Q n, I ' ! ; ~ /.,.n, J6o:l ck,/z,, . • �Artifact 39 �___., . Rogue River Rockford Dam Pond Kent County Hg Analysis: N (All) Overall Min Length Legal Min (Inches) 10 10.8 14 Range of Years Used Earliest Most Recent 2013 2013 Datasets available: 2013 Sample Size Chemical (All) Mercury 10 Mean Cone. (ppm) 0.33 Linear Regression Exponential Regression R2 R2 0.503 0.519 Chemical Mercury Min. Cone. (ppm) 0.19 Range of Legal Sized Samples Min Max 13.5 15.4 Max Cone. (ppm) 0.51 95%UCL (ppm) 0.411 Meal Category 2 Organics Analysis: N (All) Overall Min Length Legal Min (Inches) 10 10.8 14 Range of Years Used Earliest Most Recent 2013 2013 Datasets available: 2013 Sample Size Chemical (All) PCB 10 DDT 10 Chlordane 10 Toxaphene 10 PFOS 10 Mean Cone. (ppm) 0.001 0.009 ND ND 32.2 ppb Chemical Linear Regression Exponential Regression R2 PCB R2 0.232 0.385 0.232 0.628 0.0379 0.006 DDT Chlordane Toxaphene PFOS I Range of Legal Sized Samples Min Max 13.5 15.4 Min. Cone. (ppm) 0.001 0.001 Max Cone. (ppm) 0.004 0.06 95%UCL (ppm) 0.002 0.02 Meal Category 16 16 5.6 ppb 95.8 ppb 52.3 ppb 2 Final meal category based on UCL: n ''2 Current Advice: Rogue River largemouth and smallmouth bass are covered by the Statewide Guidelines. No one should eat more than 2 meals per month of fish under 18 inches and no one should eat more than 1 meal per month of fish over 18 inches. Recommendation: No change. Insufficient numbers of legal size bass (3) were collected, but results indicate that PCBs and DDT are not likely to be a cause of advisories. Mercury and PFOS would cause advisories. �Kent, Rogue River, Rockford lmpoundment, Largemouth Bass 0.07 • 0.06 E -"' - 0.05 0. 0. 0.04 (I) ~ 0 .a ns 0.03 Cl) :i IC C 0.02 • 0.01 • 0 I 10 11 12 • •••• 13 • 16 15 14 Length (inches) Kent, Rogue Riverl.,,Rockford lmpoundment, Largemouth Bass 120 • • ♦ ♦ 40 ♦ 20 •• 0 10 11 • 12 • 13 • 14 Length (inches) ~ 15 16 �Kent, Rogue River, u/s Rockford Dam, White Sucker 0.035 ♦ 0.03 - ~ E 0.025 C. C. tn .3~ 0.02 G) ~ 0 .a cu 0.015 Cl) :E IC C 0.01 ♦ ♦ ♦ 0.005 ♦ ♦ 0 ♦ ♦ ♦ I 14 15 16 17 18 ' 19 20 Length (inches) /4! - ;5;;; Kent, Rogue River, u/s Rockford Dam, White Sucker 35 ~ ♦ 30 .a ♦ ♦ 25 C. C. U) 0 u. a.. ♦ ♦ 20 ♦ 15 ♦ ♦ 10 ♦ 5 ♦ 0 14 15 16 17 18 19 20 ,,.---..._ ~ Length (inches) �Artifact 40 �F + F F I F F t t---..,1,...-1·--.. . ,-~-- ,. ._-.,j,... F _, ---JF__,-- F .-- F F I F F - -._ F I F F ,OH II 0 Michigan's Contaminant Induced -Human Health Crisis Addressing Michigan's Future By . 11 Facing the Challenge of the Evolvi.hg Nature of Environmental Contamination· Prepared for the Director of the Michigan Department of Environmental Quality By Robert Delaney & Dr. Richard DeGrandchamp �Introduction/Executive Sum'ihary Michigan's Human Health Crisis Addressing Michigan's Future By {. Facing the Challenges of the Evolving Nature of Environmental Contamination By Robert Delaney The State of Michigan and the United States (U.S) as a whole are in the midst of a human health crisis. The rates of various neurologic disorders (such as attention deficit hyperactivity disorder, autism , and schizophrenia) , and autoimmune diseases (such as diabetes and multiple sclerosis) have been rapidly increasing across the nation . These diseases have tragic consequences for individuals and their families. These diseases place a great burden on the medical system, render the overall population less productive as individuals, and take primary care givers away from other productive pursuits. There is an ever increasing amount of evidence that these impacts to our health as a state and nation are the result of contaminants in our food , water, homes, air, and the general environment. \.: Currently, the U.S. Environmental Protection Agency has approximately 85,000 chemicals listed as in commercial use with 1,000 to 3,000 new chemicals coming in to use in the ~conomy each year. Virtually nothing is known about the toxicity and environmentai'fate and transport of these chemicals . There are approximately 400 hazardous chemicals that ·have been detected in human umbilical cord blood; exposing the most chemically sensitive portions of our population to unknown risks. We are essentially running a large toxicity study and using the human ' population as the guinea pigs. • ' ,. To explore this topic, this write up consists offive different issue papers. Three issue papers : consist of an analysis of perfluoroalkyl chemicals (PFCs). The first paper consists of an overview of the nature and extent of PFC contamination in Michigan's environment. The second paper consists of a summation of the toxicological information that is available on PF Cs. The second issue paper discusses the epidemiological studies on PFCs, and the evidence of health effects on human populations from PFCs. The fourth paper provides a summation of the epidemiological evidence of dramatic increases in neurologic and autoimmune diseases observed in the U.S. human population. It also provides 'a couple of examples of ubiquitous contaminants that have been linked to population-wide; negative health effects. The fifth and final paper consists of some recommendation on what the Michigan Department of Environmental Quality and Michigan State government should do in response to these rising epidemics. The fifth paper is essentially a "brain storming" exercise to point out that there are things that can be accomplished if we choose to do something to address our problems. The reader is advised to start with the fourth white paper on the epidemiological evidence of the widespread increases in the rates of neurologic and autoimmune diseases in the general U.S. population (and abroad) , if the reader is unfamiliar with the topic. That is the starting point for considering whether what we are doing is effective in protecting our citizens . Finally, very little is said about the impact of contaminants on the biota in these issue papers. However, the chemicals negatively impacting humans are also damaging the environment. �Michigan's Contaminant lnduce'ti'Health Crisis Addressing Michigan's 'future By '" Facing the Challenge of the Evolving Nature of Environmental Contamination Prepared f<;>r the Di rector of the Michigan Department of Environmental Quality Prepared By Robert Delaney and Dr. Richard DeGrandchamp Table of Contents Introduction/Executive Summary Issue Paper 1 Distribution of Perfluoroalkyl Chemicals In Michigan 's En vironment Issue Paper 2 Exposure and Toxicity in Perfluorochemicals -i- Issue Paper 3 , Recent Epidemiology Studies Confirm Link Between PFC Exposure and Illness and Disease Issue Papei 4 Increased Disease Prevalence in the U.S. Population Is Linked to Environmental Chemical Exposure Issue Paper 5 Recommendations � https://digitalcollections.library.gvsu.edu/files/original/16f076de246a0da34b46c9b767f71dcb.pdf 9b49ed180dafe6f44d45bf2bf60e03b8 PDF Text Text Artifact 41 �ISSUE PAPER 1 ~· ,. DISTRIBUTION OF PERFLUOijOALKYL CHEMICALS IN MICHIGAN'S ENVJRONMENT .. By Robert Delaney Issue The environment and the human population of Michigan have been exposed to widespread perfluoralkyl chen1ical (PFC) contamination. The sources, nature, and extent of this contamination, as well as, the impacts on biota and humans in Michigan, can only be described in extremely general terms because of a severe lack of data from across the state. Risks to the ,. general population and the environment are unknown. Background PFCs were created in the 1940s and have been increasing in use ever since that date. The forms of PFCs that are most familiar to the general public are Scotchguard® and Teflon®. However, PFCs are found in thousands of products and processes used in industr,y and are contained in countless consumer products. PF Cs were thought to b~ biologically inactive and completely safe until recently when it was discovered that PFC contamination was increasing in biota and human populations a·round the globe (including highly isolated biota such as the mammals of the arctic). Subsequent toxicity testing of lab animals indicated that at least some of these PF Cs were highly toxic everi in small doses. PFCs bioaccumulate s3,nd biomagnify .in various animal species, such as reptiles, mammals, fish and birds, and are also taken up in plants. Humans, at the top of the food web, can bioaccumulate high levels of various forms of PFCs. : Studies of exposed human populations have already shown diverse negative health effects (See, Recent Epidemiology Studied Confirm Link Between PFC Exposure and Illness and Disease (attached) Issue Paper 3). These negative health effects have been shown even at background levels of human blood serum contamination; levels that can be expected in the bloOd serum of the typical Michigan resident. The toxicity of PFCs will be covered in detail in a separate briefing memo. ., P~Cs have some unique characteristics that make them particularly difficult to deal with in the environment. Unlike most environmental contaminants, they cannot be broken down (as far: as is known) through the normal biotic and abiotic processes that breakdown most contaminants. These chemicals do not photodegrade or biodegrade, are not oxidized, nor 'do they disassociate in water or other solvents. They are stable over a very large temperature range and are only destroyed by high temperature incineration. At this point, t.here is no known natural process that destroys PFCs in the environment. Thus, even if manufacturing of these chemicals is • completely stopped, they will continue to be present in the environment and in human populations for the foreseeable future. Of the approximately 400 PF Cs, only perfluorooctane sulfonate (PFOS); the main PFC in the old formulation of Scotchguard®, and perfluorooctanoic acid (PFOA), the main PFC associated with Teflon®, have been the subjects of much toxicity testing. However, many of the 400 PFCs are in the environm_ent, in biota and humans. ) �Issue Paper Distribution Of Perfluoroalkyl Chemicals In Michigan's Environment \ •. Page 2 These chemicals are considered a significant threat to the ~nvironment and human health. The __ European Union has banned almost all uses of the longer chI ain PFCs (eightor mere carbons in the PFC molecular backbone) . In the United States (U.S.), the nine major producers of PFCs also agreed to voluntarily stop generating the longer chain PFCs. However, PFCs continue to be manufactured in other countries such as China and Brazil and are still used in many consumer products and manufacturing processes in the U.S. There is relatively little data on PFC contamination in Michigan and the Great Lakes; however, some of the earliest studies were completed in Michigan. PFC contamination has been detected in each of the Great Lakes. In Lake Superior, PF Cs were found throughout the water column, including the deepest portions of the lake. PFOA was consistently fou·nd to have the · highest concentrations of the PFCs analyzed, and were generally 1.5 to 2 fold greater in concentration than PFOS. PFOA concentrations in Lake Superior water ranged from 0.07 to 1.2 parts per trillion (ppt). The two major sources of PFC contamination to the lake were air deposition and contamination eritering from tributaries, with tributaries estimated to contribute over 55 percent of PFOA and PFOS (Scott, 2010). Boulanger et al., 2004, reported contamination in Lakes Erie and Ontario surface waters from 16 sampling locations. Concentrations ranged from 21 to 70 ppt for PFOS and 27 to 50 ppt for PFOA. T,tiese numbers are very significant given the volume of surface water in these two wflter bodies and the fact that it is possible that the groundwater/surface water criteria could b~-as low as 15 ppt for PFOS. The levels of PFOS also approach or exceed the tentative <;ftinking water criteria being developed by the Michigan Department of Environmental Quality, Remediation Division. Current PFOA criteria is promulgated under Part 31, Water Resources Protection, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended . Aithough the current PFOA criteria for surface water used as a drinking water source is 420 ppt, the surface water.j,n these two bodies of water were approximately only one order of magnitude lower in concentration than the criteria (and higher than New Jersey's standard of 40 ppt). A mass balance study of the concentrations of eight PF Cs in Lake Ontario revealed that the main sources of PFC contamination came from tributaries and inflow from Lake Erie. Air deposition of PFCs was not a main contributor to PFC concentrations (Boulanger et al., 2005). There are at least three things that are critical to understand about these findings. First, given the dilution effects due to the enormous volumes of water in Lakes Erie and Ontario, these are , very high concentrations of contamination . Secondly, there must be highly contaminated sources that are adding PFCs to the watersheds of these two lakes. Finally, it can be expected that with only 16 samples taken across two such large water bodies, there must be high concentration, localized contamination in the lakes, such as areas impacted by parts of the watersheds that are heavily industrialized. Ecological and human exposure. in some areas might be exceedingly high in relation to tentative criteria. Screening level sediment sampling was done from 2001 to 2005 on tributaries to the four Great Lakes that border Canada (map attached) (Anon., 2009). Sediment contamination was highest in tributaries that passed through highly urbanized areas. No sediment data is available for the Michigan portions of the watersheds of the Great Lakes, although, it is noteworthy that the highest levels of sediment contamination were found in the Detroit River. Impacted sediments will act as a continuing sink of PFC contamination to surface water into the future, even after discontinuation of PFC discharge to surface water. It also represents a pathway of continuing contamination to the food web of the Great Lakes. �Issue Paper Distribution Of Perfluoroalkyl Chemicals In Michigan's Environment Page 3 t I, Several studies have shown PFC contamination throughout the food web of the Great Lake~ region. PFCs have been found in benthic algae, amphipods, zebra muscles, round gobies, • Chinook salmon, lake trout, whitefish, small mouth bass, ca~. mink, eagles, frogs; and snapping turtles (Kannan et al., 2005, attached). Kannan's studies (2002) demonstrated extremely high concentrations of PFCs in mink from the Kalamazoo River watershed. The attached article by Kannan (2005) gives a good overview of the widespread impact of PF Cs on Michigan's ecosystem. Another important study of PFC contamination in Great Lakes' biota was published in 2011 on the 20 year trends of PFC concentrations in herring gull eggs from seven herring gull colonies (Gebbink, 2009). The concentrations of PFCs (PFOA and PFOS) that major U.S. producers had agreed to terminate manufacturing in the U.S were found to decrease in herring gull eggs over time; while the concentrations of analyzed F?FCs still in production were found to increase. Finally, Wurtsmith Air Force Base, located in Oscoda is the only point source of PFCs that has been documented in Michigan. Very high level contamination has been found at numerous locations on the base, and groundwater has been impacted over an area of approximately 5. 7 square miles. Approximately 2.08 square miles of swamp and marsh, 9.37 miles _o f the Au Sable River, 2.89 miles of Van Ettan Creek, and 3.06 miles of Van Ettan Lake have been ,,, contaminated with PFCs from the base (map attached). l~ In 2011, wild fish tissue samples (fillets) were collected from a marsl;l just south ofthe base, and analyzed for 13 different PFCs. Seven different PFCs were detected in the fish. PFOS was the • most frequently detected PFC and the PFC with the highest concentrations. The PFOS concentrations ranged from 334 to 9,580 nanograms per gram (344,000 to ~,580,000 ppt) wet weight in fish fillets. The levels of contamination in these fish averaged almost an order of magnitude higher than anything documented in the literature to date. At the moment, Michigan holds the dubious honor of having the most PFC contaminated fish reported in the literature • from around the globe. The PFC levels in these fish fillets were deemed to be so much higher than provisional heathbased reference values issued by the U.S. Environmental Protection Agency arid the Minnesota Department of Health that an immediate "Do Not Eat the Fish" advisory was issued for the marsh and the Au Sable River south of the base. Those who hav_e been eating fish out of Clarks Marsh, depending on their levels of consumption, likely have had extremely high levels of exposure to PFCs, and may have experienced those levels for more than a decade. Given the long half-lives of PF Cs in humans (as long as eight years to eliminate half of the PFC from the body), some residents of Oscoda are likely to have very dangerous levels of PFCs in their blood. At this time, no known human PFCs exposure data for Michigan r~sidents has been published in the literature. However, the PFOA estimated median serum levels for the U.S. population is 4 parts per billion (ppb), and the estimated median serum level for PFOS is 21 ppb (Steenland, 2009). Michigan median serum levels can be expected to be siniilar to the national estimated levels for PFCs. Analysis In conclusion, contaminc:1tion of the Great Lakes' waters and the extensive contamination of biota across Michigan indicate widespread contamination of the waters of the state by PF Cs. Source contributions and human and ecological exposure cannot be characterized other than in �Issue Paper Distribution Of Perfluoroalkyl Chemicals In Michigan's Environment Page 4 ., ·~- ,. the most general terms because of a lack of monitoring across the state and in the human ', . . -· •• • population. ,. Recommendations Recommendations are provided in a separate document. Prepared by: Robert Delaney, Environmental Specialist Geology and Defense Site Management Unit Superfund Section/Remediation Division Michigan Department of Environmental Quality June 18, 2012 Attachment �, Issue Paper Distribution Of Perfluoroalkyl Chemicals In Michigan's Environment Page 5 / Attached References Anonymous, "Binational framework for identifying substances of potential threat to the great lakes basin, test case: perfluorooctane sulfonate (PFOS), its salts and its precursors, (larger class: perfluorinated alkyl (PFA))," http://www.epa.gov /bns/reports/march2009/PFOS-PFOA0309.pdf, March 25, 2009. K Kannan et al.,"Perfluorinated compounds in aquatic organisms at various trophic levels in a Great Lakes food chain," Arch. Environ. Contam. Toxicol., Vol. 48, 2005, pp. 559-566. Cited References B Boulanger et al., "Detection of perfluorooctane surfactants in Great Lakes water," Environ. Sci. Technol., Vol. 38, No. 15, 2004, pp. 4064-4070. B Boulanger et al., "Mass budget of perfluorooctane surfactants in Lake Ontario," Environ. Sci. Techno!., Vol. 39, No. 1, 2005, pp. 74-79. , / WA Gebbink, CE Hebert, and RJ Letcher, "Perfluorinated carboxyla\es and sulfonates and precursor compounds in herring gull eggs from colonies sparci'ning the Laurentian Great Lakes of North America," Environ. Sci. Technol., Vol. 43, Nd. 19, 2009, pp. 7443-7449. K Kannan et al., "Perfluorooctane sulfonate and.related fluorinated hydrocarbons in mink and river otters from the United States," Environ. Sci. Technol., VoL 36, ,No. 12, 2002, pp. 2566-2571. BF Scott et al., "Perfluoroalkyl Acids in Lake Superior Water: Trends and Sources," Journal of Great Lakes Research, Vol. 36, No. 2, 2010, pp. 277-284. K Steenland, T Fletcher, and DA Savitz, "Epidemiologic evidence on the health effects of perfluorooctanoic acid (PFOA)," Environ. Health Perspec;t., Vol. 118, No. 8, 2010, pp. 1100-1108. I Additional References VI Furdui ~t al., "Spatial distribution of perfluoroalkyl contaminants in lake trout from the Great Lakes," Environ. Sci. Techno!., Vol. 41, No. 5, 2007, pp. 1554-1559. JP Giesy and K Kannan, "Global distribution of perfluorooctane sulfonate in wildlife," Environ. Sci. Techno!., Vol. 35, No. 7, 2001, pp. 1339-1342. CA Moody et al., "Occurrence and persistence of perfluorooctane sulfonate and other perfluorinated surfactants in groundwater at a fire-training area at Wurtsmith Air Force Base, Michigan, USA," J. Environ. Monit., Vol. 5, No. 2, 2003, pp. 341-345. �"'CJ O ui" ru -· (/) CQ CD 0) ~ C ::::! . CD g~ "'CJ ru 0 -0 :::i CD 0...., Levels of PFOS in Surticial Sediments of Canadian Tributaries to the GreatLakes, 2001-2005 -,., "'CJ CD :::i, C 0 ., 0 ru ?\ '< 0 ~ CD 3 0 ru (/) :::i ~ 0 ~ ca· ru :::i (/)~ m :::i :5. ~- a . •- :::i 3 CD :::i ...... "-' -r PFOS, ~ _e. Source: GLBTS 2006 Annual Progress Report • <0.6 pglg_(Deteelicn timltentered -as 0)- 0 <100pglg • • 100:9S9 pg/Ill • :,,.1)!)9p,lill9 'Y ��Artifact 42 �To: John Pawloski, Michigan Department of Environmental Quality From: Richard R. Rediske, Ph.D. Professor of Water Resources. Grand Valley State University Re: Scotchguard (PFOS) usage at the Wolverine Worldwide Rockford, Ml Tannery. I have reviewed historical records from the Wolverine World Wide (WWW) Rockford, Ml Tannery concerning the use of Scotchguard in the production of Hush Puppy shoes. In the early 1950s, 3M developed a group of waterproofing chemical called perfluorooctanoic acid (PFOA) and perfluorooctane sulfonate (PFOS) that were incorporated into the commercial product called Scotchguard (Hekster et al. 2003). Due to environmental and human health concerns, Scotchguard waterproofing formulations containing PFOS and PFOA were discontinued in 2002 (Buck et al. 2011). In consideration of readily available information from the Wolverine Worldwide Web site, newspaper articles, and process patents and trade publications, it is well established that WWW used Scotchguard in Rockford during the time it was known to contain PFOS. 1. 2. 3. 4. 5. 6. 7. "Availability of pigskin opened the door to a range of possibilities in shoemaking. The introduction of Scotchgard Protector for Leather, made the company's leather the first performance leather on the market. The year was 1958 and it was when the Hush Puppies brand was born. This leather featured the breathability, durability, water, oil and stain repellency, and easy care maintenance that is still the company' s platform." (http://www.wolveri neleathers.com/aboutus. php Accessed 1/24/17) "The company (WWW) was the first to add Scotchgard, water-resistant chemical to the suede, to make it easy to clean and maintain, according to the younger Krause, the grandson of Victor Krause." (http:ljblog.mlive.com/grpress/2008/03/hush puppies mark 50 starstudd.html. Accessed 1/24/2017) https://www.google.com/patents/US20060288493 (WWW Process For Producing Leather Footwear Lining) https:ljwww.google.com/patents/US20060288494. (WWW Process for producing leather) Victor (Krause) designed a casual pair of men's shoes using the new material. He treated the pigskin with Scotchguard to protect the material.... Released in 1958, this was the first Hush Puppy. Feet and Footwear: A Cultural Encyclopedia 2009. M. DeMello. Greenwood Press ISBN10: 0313357145. The 1991 Spill Plan authored by Fishbeck, Thompson, Carr, and Huber lists Scotchguard related materials being stored on site. Scotchguard was fund to bel listed on MSDS sheets reviewed by the Citizen's Group. Based on this information, it is likely that the Wolverine World Wide Tannery in Rockford Michigan manufactured Hush Puppy shoes using PFOS containing Scotchguard from 1958 until it was banned in 2002. Moreover, industrial wastes, scrap leather, wastewater, and process streams produced in Rockford during this time all may have contained PFOS residuals for at least 44 years. Wastes disposed on site, residuals from spills, production wastes disposed of offsite in landfills, local groundwater, and scrap leather buried onsite all have the potential to contain PFOS. In a recent meeting on 8/22/16 at West Michigan Environmental Action Council, both Michael Robinson (attorney for WWW) and Mark Westra (consultant, Rose and Westra) stated that there was no evidence that PFOS was ever used at the Rockford Tannery site. This statement contradicts all the above information. �In 2013, the MDEQ completed a study of fish in the Rockford lmpoundment downstream for the WWW Tannery and found elevated levels of PFOS in small mouth bass and white sucker. These levels were sufficient to result in the issuance of a fish consumption advisory for PFOS. Based on the presence of elevated levels of PFOS in area fish and t he overwhelming likelihood of significant PFOS usage at the site, it is imperative that soils, groundwater and scrap leather deposits be analyzed for this chemical before closure plans move forward. There are many deposits of scrap leather that are exposed to overland runoff and t hat can easily enter Rum Creek and the Rogue River. If PFOS is found, offsite disposal areas need to evaluated for soil and groundwater levels of PFOS. This potential problem will not go away with neglect and denial by WWW. An investigation of PFOS at the former WWW Rockford Tannery needs to be undertaken as a matter of environmental and public health. Buck, R. C., Franklin, J., Berger, U., Conder, J.M., Cousins, I. T., De Voogt, P., .... & van Leeuwen, S. 2011. Perfluoroalkyl and polyfluoroalkyl substances in the environment: terminology, classification, and origins. Integrated environmental assessment and management. 7(4): 513-541. Hekster, Floris M., Remi WPM Laane, and Pim de Voogt. 2003. Environmental and toxicity effects of perfluoroalkylated substances. Reviews of Environmental Contamination and Toxicology. 179: 9-121 . .J �Artifact 43 �~ ,-..,+" PFO. . . . . ~ Slvt.1-1,J. Wteo,,,..-t:+ -(-k&. D F, (~ I. h~ CJ s~I r:::i ~ . • w~l-k • "'Nt,, □ 3. _,l~IMV o Lf . Pt",~f,,c~ □ S.Msb~~ o_ G-. PtPP Cl 7. □ 8. ~,s,:., ECo •. S1AW1wtc7 ~~rrl" d.t+r �Artifact 44 �&"9 ~ REPUBLIC SERVICES If waste is asbestos waste, complete Sections I, II, Ill and IV If wa&te Is .HQ! asbe$los waste, complete Sections I, II and Ill 127442 '---' ·,,__,. NON-HAZARDOUS· SPECIAL WASTE & ASBESTOS MANIFEST GENERATOR (Generator completes la-r) a. Generator's US EPA ID Number b. Manifest Document Number MIT 270012925 d . ~ 'WflJld~l · e. Generator's Mailing Address: Adm. Bldg/Tamer, 123 North Mail St. Rockftird, MI 49341 616/863-3997 f. Phone: If owner of the generating facility differs from the generator, provide: ·., .. g. Phone: i. Owner's Phone No.: I. Waste Shipplng Name and Desc • tion h. Owner's Name: J. Waste Profile # · c. Page t of. ·k. Exp. Date 40421018161 o. Unit WWol Non RCRA/tx)T RE9,llall!d 1 · cm Soil,... ID GENERATOR'S CE~TIRCATION: I hereby certify that the above named material is not a hazatdous waste as defined by 40 CFR 261 or any applicable . state law, has been properly descrlt?e~. classified and packaged, and Is in proper con~'}f9rtransportatlon according to appll<;able regulations; AND, If this waste Is a treatment residlle of a previously r8$1rk:ted hazardous waste subject to the La!~-Olsposal Restrictions. I certify and warrant lhat the waste has. been treated in accordance with the re uirements of 40 CFR 268 and Is no Ion er a ha itdous waste as defined by 40 CFR 261. . a. T"W5PQtter's)'ame c,1nd'Adyntss: . Vane, City Emiunmautal Senaca . 1040 Miwk,;t A.e 5W . Rapids. Mi 49503 HI. ~16 23S-150D DESTINATION (Generator complete llla-c and Destination Site completes llld-g) a. Disposal Facility and Site Address: c. US EPA Number ottawa ~ Farms Land611 d. Discrepancy lndicalion.Space: MID 985582097 th 15550 fi8 AN - b.---··•-, ... - - - - ~ ';. - ·-·-· • -- - - - - · - - - -- ·-· ·--·-- ----- - - - - - ~ - - - - - - - - - · --·-......,;a.-·~•--:..,__ c. Responsible Agency Name and Address: a. Operator's Name and Address: .. b. Phone: e. Special Handling Instructions and Additional Information: • d. Phone: •J f. □ Friable % Friable % Non-Friable □ Non-Friable 0 Both OPERATOR'S CERTIFICATION: I hereby declare that the contents of this ~ignrnent are fully and accurately described above by proper shipping name and are classified, packed, marked and labeled and ar:s in all respects in proper condition for transport by highway according to applicable intematlonal and .:,..-•li:>nal govemmental reaulatlons. • '-___.. I ' '. ..-. I .. I I. Date I h. Slonature a. ODAN1tor's Name and Title tPrinD •operator refers to the company which owns, leases, operates, controls, or supervises the facility being demolished or renovated, o r ~ or renovation ooaratlon or both . . · • . _ REV 11/09 RETURN TO GENERATOR RS-F11A �Artifact 45 �ABSTRACT WWW TANNERY DEMOLITION A Citizen’s Perspective on the Adequacy of Wolverine World Wide’s Response to the U.S. EPA 104e Information Request This is a critical review of Wolverine World Wide’s (Wolverine or WWW) Response to the 104e Information Request issued by the United States Environmental Protection Agency (EPA) on March 21, 2012. The 104(e) request was issued regarding Wolverine’s demolished tannery site in Rockford, Michigan. This document highlights many omissions and incomplete and/or misleading responses made by Wolverine to the EPA. Janice L. Tompkins �Overview This summary is my review of a March 21, 2012 U.S. EPA 104e information Request to Wolverine World Wide Inc. (Wolverine/WWW)), which related to the demolition of their 100+ year old Tannery in Rockford, Michigan. A 104(e) request is an important tool utilized by the United States Environmental Protection Agency (EPA), roughly equivalent to a judicial subpoena, but in an environmental context. The EPA issued eight detailed requests for information in the form of questions. Wolverine was questioned regarding historic practices at the Site prior to the demolition and regarding practices that occurred during demolition (August 31, 2010 to August 31, 2011). Many of these questions were directed to Wolverine in response to environmental concerns noted and documented by local concerned citizens It appears that Wolverine’s response to the 104 (e) included significant omissions and misleading statements regarding demolition activities at the tannery site. However, the information omissions related to historical operations are especially troubling. Had critical information been disclosed regarding usage and disposal practices related to PFAS, for example, hundreds of families in northern Kent County might have spared five additional years of exposure to this toxic chemical in their drinking water supplies. Throughout the 104(e) response Wolverine claimed--repeatedly-- that the information being requested was “beyond its knowledge” or that they were unable to “produce documents or information not within its possession, custody, and control.” Why was I then, a citizen, able to secure detailed responsive information by simply making a few inquiries to relevant information sources? Why is a profitable international company like Wolverine World Wide allowed to dismiss/omit material information with the boilerplate response of it being too cumbersome or burdensome? Possible accountability for the demolition if Wolverine accepts MEDC grant money Incredibly, prior to the demolition of Wolverine’s 100 + year-old tannery in Rockford, MI, Wolverine’s legal representatives claimed, in response to a question on an Act 381 Work Plan to Conduct Eligible Michigan Economic and Development Corporation (MEDC) Non-Environmental Activities(June 16, 2010), that the site contained no contamination—at least on the property. After reading this reply, the MEDC in partnership with the Michigan Department of Environmental Quality (DEQ) added some conditions to their grant that included a financial incentive to get Wolverine to test their site for environmental contamination. “Just to follow up, at the meeting with MEDC on Tuesday this week, they agreed to give WWW/Rockford the conditions we provided to them, and we’ll see what they say. The concern is that they will decide they don’t need MEDC money after all. The hope is that since they are saying they want to be good corporate citizens that they will do the phase I/phase II.” -- Interoffice DEQ e-mail from Susan Erickson to Bob Wagner. 1 �Wolverine declined the money as summarized in the following e-mail. From: Sygo, Jim (ONRE) To: Creal, William (DNRE); Marolf, Lynelle (DNRE); Shekter Smith, Liane (DNRE) Sent: Thu Sep 02 16:43:28 2010 Subject:: Wolverine Tann.el"i' http://www.rockfordindepenoenl.com/main.asp?SectionlD=11 &SubSeclion1 D= 11 &Article! 0=3252 Bill and Lynelle, I had a call on this demolition proposal that suggested significant stormwater Issues and likely soil contamination. I suspect that if staff had any details that they may have done something about this but its my understanding that John Byl told Wolverine to forgo the mega credits and do this under their own dime so they wouldn't have to characterize the area. You ever see a tannery (ha( wasn'( contaminated. Jim Sygo Deputy Director 517-241-7394 Wolverine’s premise for the avoidance of environmental testing at the site: “There is no known contamination on the property.” (Appendix 1) This premise appears to have formed the basis for a decision on the Company’s part to perform neither a Phase 1 nor Phase II Environmental Site Assessment of the Site prior to demolition. Wolverine also used this premise when seeking DEQ permits for all the work activities related to the demolition. DEQ accepting this premise, in spite of concerns, allowed the demolition to proceed with little or no sampling. Yet even a cursory review of documents, and evidence in the field, clearly indicated that extensive sampling and characterization testing should have occurred prior to, and during demolition. Execution of the Work Plan In Wolverine’s written responses, only limited information appears to have been submitted to historically describe and document work practices and changes made to existing structures on the Site. This allowed Wolverine to avoid having to meet stricter requirements related to environmental protection and public safety. Some Information Provided Wolverine did submit some pertinent piece of information to the EPA regarding this topic of historical practices: Brief description of the Site and of the tanning practices, maps of the site showing storage areas with containment, and a list of chemicals used at the tannery from what appears to be from 1987 2 �to the start of demolition. However, as indicated below, critical information was omitted which might have allowed response and removal actions, protective of human health and the environment, years ago. Information It Seems Wolverine Did Not Provide Maps. It does not appear as if Wolverine supplied maps prior to 1987 and the City of Grand Rapids Consent Ordered 1988 plant expansion. Importantly, a 1981 Pollution Incident Prevention Plan (PIPP) map (Appendix 18) (Citizen obtained through City of Grand Rapids, June 5. 2013 FOIA) and a Historic Sanborn map shows no outside containment around the Wolverine buildings, even when they apparently stored chemicals outside. Material Safety Data Sheets (MSDS). Nor did Wolverine reference the 1990 MSDSs found in their submitted CD (Citizen obtained through EPA FOIA), that showed they used products that when listed, contained 360 hazardous ingredients. Some of these hazardous ingredients were found in the soil, surficial soils, groundwater and sediment samples taken as part of the 2012 CERCLA Preliminary Assessment (PA) and the XRF Screening. Perhaps the most glaring omission of all is Wolverine’s failure to acknowledge, in any of their written responses to the 104e request, that the company used 3M Scotchguard from 1958-2001 as part of their production process. They did submit 1990 MSDSs for the 3M Scotchguard, but buried them in their CD. Wolverine said that they did not know PFAS (PFCs) was in Scotchguard until the fall of 2017. This statement is incredible given general media reports regarding Scotchguard toxicity, and 3M’s own efforts to notify users of health and safety concerns (both concurrent with and subsequent to pulling the chemical from market). Recently, 3M has gone on record that they met with Wolverine in January 10, 1999 in the City of Rockford to share the PFAS (PFCs) public health and safety concerns and why they were reformulating the product to remove them. 3M recently shared with the a local NBC media affiliate, a copy of the January 15, 1999 follow up letter to Rick DeBlasio, former Executive Vice President of Wolverine, summarizing the key points of the January 10th meeting regarding the PFAS (PFCs) public health and safety concerns. Wolverine is now admitting that they have known about the PFAS (PFCs) public health and safety concerns since January 1999. Yet Wolverine failed to notify DEQ or Kent County Health Department (KCHD) that they used Scotchguard containing PFAS at their tannery site and their tannery wastes containing PFAS were dumped into gravel pits, loaded into landfills, poured into trenches on local farmland, and thrown into ravines. It took CCRR to bring this issue to DEQ’s attention in January 2017. These practices have come at great cost, resulting in groundwater contamination of both municipal and private wells throughout northern Kent County. Human health is at risk and has been at risk for decades. Why didn’t Wolverine point out this important health information with the EPA back in May 2012? Hazardous Materials Survey. Wolverine’s demolition plan (Citizen obtained through City of Rockford FOIA) did not include a Hazardous Materials Survey of the buildings, pavement and wastewater treatment plant (WWTP) structures; and soils on Site were not tested prior to, or during demolition to determine potential hazard risks. In fact, it does not appear that any waste stream surveys, waste characteristic tests were done prior to, or during demolition, even though the buildings and WWTP concrete were heavily stained. The 2012 CERCLA PA report has since verified the existence of contaminated soils on site (Citizen obtained through EPA FOIA). However, no records appear to have 3 �been submitted by Wolverine that showed they tested or found any hazardous materials related to the buildings and WWTP materials, or the soil at this 100 plus year-old tannery. Valley City power washed the buildings, and did a wipe test; however, however EPA Standard Methods seem to indicate that this is an inappropriate test for this situation. Incredibly, only a single manifest appears to have been submitted for the whole demolition, relating to a non-regulated 10 yards of soil load being taken to a type II landfill. I assume this is the contaminated soil found at the WWTP clarifier given the quantity listed in the manifest. In contrast, the City of Whitehall required Whitehall Leather Co to do the Hazardous Materials Survey, waste stream surveys, waste characterization tests prior and during their demolition. The tests showed that the building materials were impacted. The concrete was highly contaminated. There was a lot of toxic build up in the materials. Given staining and worker accounts, demolition debris at this Wolverine site could have been as, or even more contaminated than the Whitehall facility and if improperly disposed of could be creating a new site of release of hazardous substances to the environment. Demolition Debris. In spite of innumerable truckloads of potentially impacted debris being taken offsite, no other official records appear to have been submitted documenting where the demolition debris went. Wolverine, in response to the 104e Information Request, listed sites where the tannery demolition debris was going to be taken. However, photos were taken documenting several trucks leaving the tannery, loaded with soil and broken concrete from the WWPT area, and going to Rusche Pit (a sand and gravel mining operation located in Algoma Township). Rusche Pit was not listed in either the demolition plan or in Wolverine’s 104e Information Request Response. The soils in these could have contained PFAS (PFCs) and the concrete could have been ground up and redistributed as fill or cover throughout the community. • Picture of demolition debris, stained concrete, at the tannery site “The Pit”. Wolverine told DEQ staff in February 2011 that they did not find contamination in the “pit” area. It was several months later when Wolverine reported to DEQ that they did find contaminated soils in the pit area. However, by this time, the soils had been removed and the area backfilled with clean fill. As such, it is difficult to understand how Wolverine could report that they found no contamination only a few months earlier. Especially for an area where past usage indicates this would be a heavily impacted area. In addition, for the next year Wolverine stated in public meetings and in reports, including their April 12, 2012, Part I 104e Response to EPA, that they found only two contaminated soil areas. It is only in the May 18, 2012 Part II 104e Response, that they first report that they had also found another “minor” contaminated soil area by the former abandoned underground storage tank (UST). It is not clear whether the soil was removed or not. Both the 1994 ESA and previous employee interviews refer to other buried USTs in this area. Given the widespread contamination found both at the former tannery and disposal sites all over Kent County, the failure to either adequately investigate the site at accepted professional standards or to knowingly downplay the evidence of high level, high volume contamination has resulted in a significant delay of addressing a very serious human health threat. 4 �Summary of Overview US EPA 104e Request states that Wolverine is required to respond completely and truthfully. It appears that Wolverine provided in their written responses only the information that backed up their unsupported premise that “there is no known contamination on the property.” The documents and citizen accounts found in this response package show that in doing this, Wolverine appears to have misrepresented and downplayed the potential environmental and public health risk at that site and to the Rogue River. Wolverine failed to acknowledge in any of their written responses to the 104e request that they used Scotchguard containing PFAS (PFCs) from 1958 until 2001 and dumped their PFAS (PFCs) containing waste in local dumps, and allowed it to be spread on farmland throughout Rockford area. These practices have put people’s lives at risk. I believe that Wolverine may have broken laws related to the tannery demolition and also in their failure in their responses to the 104e Request to accurately disclose and characterize the contamination at the tannery and disposal areas related to the PFAS (PFCs). There is also a serious question of how regulatory oversight could have failed so completely to recognize inadequate reporting of a very serious, and very widespread contaminant problem. The system of regulation and reporting is specifically designed to prevent and/or correct such a disaster. Yet, no agency took actions that would have prevented human exposure at this site since 1999 when EPA first realized that PFOS was a very serious environmental concern. Even in more recent years, it seems increasingly inexcusable that regulatory agencies could ignore this problem and the inaccuracies in Wolverines 104e responses. Document Format: The following format will be used throughout the document. EPA REQUEST: First, one of the 8 requests for information will be cited in full, or a portion of a request. WOLVERINE RESPONSE: Secondly, Wolverine’s response to the EPA request will be cited in full. AUTHOR COMMENT: Finally, I will present my analysis of Wolverine’s response (to the EPA) by raising questions, by noting possible omissions, by challenging inconsistencies, and/or by providing documentation from my own research as to how these requests could have been more fully answered. Please note: All documentation, whether written or photographic, has been acquired through Freedom of Information Act (FOIA) requests made to the EPA, the DEQ, the City of Rockford, Algoma Township and the City of Rockford, or by informal request to Concerned Citizens for Responsible Remediation (CCRR). The majority of information included in this analysis is mine and acquired through my own research. In the event that I refer to Wolverine-provided information within my “Author Comment,” it will be marked using this green type-face. (?) Wolverine’s response to the EPA was itself burdensome. Historical data that conflicted with their written responses was buried deep within a submitted CD. It was not made clear if or how the data supported the answers to questions previously cited. In a way this was misleading; the reader was led to believe that historical data did not exist when, in fact, it did—sometimes. 5 �EPA REQUEST #1: Identify all persons consulted in the preparation of the answers to this Information Request and the questions herein. Wolverine’s Response: 1: Part II page 2-4 Wolverine objects to this request as unduly burdensome and unreasonable. Many people were consulted in the preparation of these responses, but only a small number were consulted in a material capacity. The following persons were consulted in a material capacity in the preparations of these Responses: Michael Robinson, Warner Norcross & Judd LLP; Scott M. Watson, Warner Norcross & Judd LLP; Bryon Rose, President; John O’Brien, Director of Facility; David Huey, Engineer Maintenance Manager; David Latching, Associate General Counsel; Jim Harrison, Director of US Leather Operations; Bob Debusschere, Wet End Superintendent; Charlotte DeVries, paralegal I; and Scott French, Facilities Engineering Manager. THE FOLLOWING IS CITIZEN PROVIDED AND COULD NOT BE FOUND ON WWW’S CD Author Comment How could identifying those who were consulted be unduly burdensome or unreasonable? Of those listed that Wolverine consulted, none appear to be environmental professionals. Interestingly, even James Blue, Wolverine’s Environmental and Safety Manager at the time of pre-demolition and possibly during the start of the demolition activities, was not included on this list? In reviewing the above list of persons included in Wolverine’s response to the U.S. EPA, the omission of Mr. James Blue, Wolverine’s Environmental and Safety Manager, is noteworthy. See Jim Blue’s resume which describes responsibilities of Wolverine’s Environment and Safety Manager (Appendix 3). A. EPA REQUEST # 3(b): all information relating to the historic solid waste handling EPA REQUEST # 3(b): Any and all information relating to the historic solid waste handling and disposal practices at the site, including waste liquids, semi-liquids and sludges. Please include data from the period antedating the construction of the facility’s wastewater treatment plant and include information regarding any analysis and cleanup of chemical spills at the site. Wolverine’s Response: 3 (b), Part I. Page 2 & 3. April 12, 2012. “Wolverine objects to this request as unduly burdensome and unreasonable to the extent that it asks Wolverine to respond to matters beyond its knowledge or to produce documents or information not 6 �within its possession, custody, and control. Subject to its general objections, Wolverine produces in response to this Request (3a-f) the documents in folder numbers 3 and 3-4 on the enclosed compact disc.” I want to highlight that the following pertinent records are included in Wolverine’s 104e response: 1987- 1994 Pollution Incident Prevention Plans (PIPP) , and an updated in 2007 PIPP were submitted by Wolverine in response to the 104e EPA Information Request and are on the CD, Folder 2 000000451513, Subfolder 2, 01 PDF and 04 PDF. THE FOLLOWING INFORMATION IS CITIZEN PROVIDED AND COULD NOT BE FOUND ON WWW’S CD UNLESS NOTED Author Comment Clearly the documents referenced by Wolverine in their 104e CD revealed only a small fraction of information available, and significantly omitted a number of waste handling and disposal practices that likely had a material impact on human health and the environment. In fact, the following publically available documents, not produced by Wolverine, give some insight into Wolverine’s historical solid and liquid waste handling at the Rockford Tannery site. Historically, there seems to be consistent practices that allowed hazardous substances, including PFAS (PFCs,) used in their manufacturing to come in contact with the building infrastructure, the soil and waterways. Wolverine does not appear to have kept records indicating that waste surveys, waste characterizations, and site assessments were ever done or that clean closure ever occurred. (I saw one 1982 Waste Characterization Report referenced in a 1994 Environmental Assessment (ESA) which was not provided by Wolverine.) Yet sloppy housekeeping was documented at times in documents listed below. The documents below seem to indicate that one of the greatest risks of exposure of hazardous substances reaching the environment at the tannery site, may have been the in-plant sewer system that carried the manufacturing waste from the manufacturing buildings to the wastewater treatment plant (WWTP). Statements in documents listed below were bolded to call this out. These statements are sourced in the documents and in the interviews of some of the Wolverine’s previous employees. CITIZEN OBTAINED DOCUMENT: 1994 Phase 1 Environmental Site Assessment (ESA) on the western portion of the Wolverine’s Rockford Tannery site, prepared by Fishbeck, Thompson, Carr &Huber (FTC&H), for Real Estate Division, Department of Natural Resources when Wolverine and Michigan Department of Transportation (MDOT) traded easements to facilitate the establishment of the White Pine State Park Trail. Some of the information has been highlighted below. See Appendix 4 for the 1994 ESA. (Citizen obtained through DEQ informal request). Of note, see the Agency Review (pages 3-5). 7 �WASTE MANAGEMENT DIVISION • A January 1984 Resource Conservation and Recovery Act Inspection revealed this facility used IPS, MIBK, Butyl Acetate, Mineral Spirits and EP solvent. A reported maximum of one to two drums of hazardous waste was generated per month • 1982 Waste Characterization Report states that sampled wastes contained lead, zinc, cadmium, chromium, and acetone. The plant has a wastewater treatment facility for tannery effluent. The treatment facility generated chromium-bearing sludge. • Spill Potential: Pollution Incident Prevention Plans (PIPPs) on file for Wolverine state that flammable materials including MIBK and IPA were being stored outside, west and north of the warehouse, which is the southernmost Wolverine building. Information in the file indicates that the chemical storage area was later moved inside the warehouse, which had containment. • Spill Potential: 1983 – an inspection report shows that wastes were being stored in a building with no roof that was attached to the shoe plant. ENVIRONMENTAL RESPONSE DIVISION • Contaminated Soils: Oct. 1992 closure of 3 additional gasoline underground storage tanks (USTs) was begun. Soils were stained and had a petroleum odor during closure activities. Elevated levels of lead were discovered in the soils near one of the UST’s, the one closest to the WWTP, near the river. A soil lead concentration of 1400 ppm was detected in soils approximately 20’ to 30’ east of the site and 100’ south of Rum Creek, exceeding the direct contact criteria for lead of 400 ppm. Soil excavation was recommended for the southern end of the site, due to elevated levels detected in borings made 4/-6’bgl, 20’ to 30’ west of the site and 200’ south of Rum Creek. • Lack of Records: 1988 –Three USTs were removed, a 12,000-gallon UST, a 2000-gallon UST, and a 900-gallon diesel UST. There is no evidence that a site assessment or soil removal was done at the time nor were the locations of these USTs to be found in any files. Only a letter from Wolverine to the Michigan Department Natural Resources (MDNR) stating that no leakage had occurred has been found, contrary to the heavy staining and odors reported above. • Spill resulting in soil contamination: January 1980, foam from the WWTP aerator overflowed. Affected soil was reportedly hauled to a landfill. SURFACE WATER DIVISION • Surface Water Violation: September 1981, a complaint was received regarding a discharge of sludge to Rum Creek during dewatering activities for construction. The MDNR instructed the company to pump the dewatering water through the treatment system. 8 �• Surface Water Violation: In November 1982, approximately 2000 gallons of tannery waste were released to Rum Creek due to a plugged transfer line. No harmful effects were noted by the MDNR at the time of inspection. CONCLUSION SECTION (Page 8) Concerns not previously mentioned. • Potential Contamination Risk to soil and groundwater: Cinders and slag-like material observed along the path of the railroad may have leached contaminants, such as heavy metals and polynuclear aromatic hydrocarbons, to the soil or groundwater under the site. • Soil Spill: Staining was observed onsite adjacent to an unidentified Wolverine dumpster. The staining appeared in color to that observed beneath the hide storage trailer. CITIZEN FOIA OBTAINED DOCUMENT: Department Environmental Quality (DEQ) Urgent Violation dated December 13, 1999 for a Hydraulic Oil Release into the surface waters of the Rum Creek and Rogue River. Appendix 5 (Citizen obtained through DEQ FOIA) CITIZEN FOIA OBTAINED DOCUMENT: Wolverine letter dated November 11, 1994 to Dale DeKracker, Waste Management Division (WMD), DEQ, regarding implementation of the contingency plan during an isocyanides reaction. The letter was a written as a follow-up to the telephone notification of the hazardous waste incident with occurred on November 3, 1994. Wolverine reported no injuries occurred and no impact to the environment. Appendix 6 (Citizen obtained through MDEQ FOIA). CITIZEN FOIA OBTAINED DOCUMENT: 2004 National Pollutant Discharge Elimination System (NPDES) inspection report regarding renewal of COC#: MIS510423 cited numerous ways in which Wolverine was not in compliance with NPDES requirements. See Water Division files, DEQ, Grand Rapids District Office. (Citizen obtained through DEQ FOIA) CITIZEN FOIA OBTAINED DOCUMENT: December 15, 2008 received a Violation Notice (VN-003785) from the DEQ for non-compliance with NPDES practices (COC#MIS510423). The permit was never renewed by the DEQ. Appendix 7 (Citizen obtained through MDEQ FOIA). CHROMIUM VIOLATIONS (Note in regard to the following two entries that Wolverine submitted in response to the 104e, Kara Lab Reports that reflect only a portion of these Chromium violations. They are found on the CD, in folder 2 000000451513, Subfolder 1, PDFs Part 1-5.8) CITIZEN FOIA OBTAINED DOCUMENT: City of Grand Rapids Industrial Pretreatment Program (IPP) Report on Permitted Wolverine Leather, Summary of Violations from January 5, 1996 to December 31, 2007. This report was generated based 9 �on a citizen FOIA request. The report identifies 734 total Chromium violations and 1 PH violation during that time frame. In February 29, 2000 Wolverine entered into a Consent Order with the City of Grand Rapids to upgrade their WWTP to address the chromium violations. In 2000 Wolverine had 271 total Chromium violations while they were trying to upgrade their WWTP. Prior to 1996, permitted user violations were not entered into a database by the City of Grand Rapids. There were Wolverine monitoring reports and the City of Grand Rapids’ Notice of violations that showed prior chromium violations as well. The exact numbers were not easily determined. There was an April 5, 1988 Consent Order between the City of Grand Rapids and Wolverine Leather requiring an earlier upgrade as well. This upgrade appeared to address the need to treat their sulfide stream and chemical storage and containment which was accomplished in September 30, 1989. See Appendix 8 (Citizen obtained through City of Grand Rapids March 12, 2013 FOIA) CITIZEN FOIA OBTAINED DOCUMENT: Operating & Housekeeping concerns leading to potential soil contamination. DEQ Inter-office e-mail: Ryan Grant June 29, 2010 e-mail to Susan Erickson: “…they [Wolverine] did have a NPDES Industrial Storm Water Permit that I oversaw and they tried to terminate the permit spring/summer of 2009. I denied the request because at the time the WWPT was still operating and the housekeeping around the WWTP was bad. To this date there has been no request to terminate the permit. I was given the tour of the site and had some concerns that I talked to Gerry Heyt about last year. There is a tributary to the Rogue River that flows underneath the tannery building and the flooring in much of the tannery building is the original brick and mortar, lacking the mortar. I expressed my concern to The Wolverine World Wide EHS manager and Gerry Heyt that there may be significant soil contamination at this site given my observation.” See Appendix 9, (Gerry Heyt, Remediation and Redevelopment Grand Rapids District Supervisor (RRD), DEQ) (Citizen obtained through DEQ FOIA). • CRACKS IN FLOORING PHOTO 1 AND 2 10 �CITIZEN FOIA OBTAINED DOCUMENT: Seeming Lack of good records and knowledge DEQ E-MAIL TO WOLVERINE: Ryan Grant, WD, DEQ, Industrial Storm Water Program to Jim Blue, Wolverine Environmental and Safety Manager, dated June 30, 2009. See Appendix 10 (Citizen obtained through DEQ FOIA). “….. In addition to the future storm water management concerns, I noticed that some of the flooring in the plant consisted of the original brick and mortar material. The location in particular was the areas beneath the large tanning drums. It appeared that underneath the brick flooring was soil. If there were breaches in the flooring, what was preventing the tanning process fluids from entering the soil and subsequent groundwater, thus possibly venting to the surface waters?” • Jim Blue’s Response, dated June 30th, 2009: “The floor underneath the brick and mortar may be concrete, but the building is relatively old, and we do not know for sure.” CITIZEN OBTAINED DOCUMENT: Interviews of 8 previous Wolverine employees by Concerned Citizens for Responsible Redevelopment (CCRR) between July 28, 2010 and March 20, 2011. See Appendix 11. Wolverine could have easily contacted retired employees to determine the nature and scope of prior waste handling and disposal practices. Some Key Comments Taken from Interviews: In-line sewer system plugging, breaking, and sewage backing up 1. On May 25, 1976 two tannery workers died from hydrogen sulfide gas when they were told to go down and unclog hazardous waste in the sewage pipes in the WWTP. They were not provided breathing apparatus. (Interviewees #1 & #7.) It was reported in the Rockford Register, dated June 1, 1976, that “According to company officials, the operation which the men were performing at the time of their deaths was a routine flushing of a clogged pipeline”. See Appendix 12. 2. The Ditch by loading dock – lots of spills and sewage backups from the WWTP. The ditch was not cleaned out well. The ditch was later known as “The Pit” when they built the maintenance building in the tan yard right over it. (Interviewees #1 & #4). Concrete from this Pit appears to have been disposed of as construction waste during demolition. 3. Drains backing up (Interviewee #3) 11 �4. Hide House: Sewage pipes were always plugging up and overflowing. Pipes underground were always cracking and had to be fixed. (Interviewee #4) 5. In the Pit area debris from the tan mills and color mills were always getting stuck in the sewer drains and pipes. That crawl space/ditch area under the maintenance building of the tannery would get flooded up sometimes and all that stuff would overflow unto the floors of the tannery and even out onto the soils around it. It was a large area and it was a dirt floor (Interviewee #6 & 8) Spills/Housekeeping 1. In the Hide House, spills occurred landing on the cracks in the floor. Barrels of ammonia were always leaking and spilling and dripping all over the place. They would pump pasting slime right up and out on the floors. Stored chrome leather out in back parking lot and some never came back in. (Interviewee #4) 2. The aeration tank use to overflow. White foam would go all over the place. Sometimes it looked like it had snowed. It even reached the parking lots. (Interviewee #8) (11/2017 update: At Wurtsmith Air Force Base, another PFC contamination site, PFOS (PFCs) are being found in high concentrations in foam on the water.) Solid Waste Disposal They would take bales of leather trimmings (packed together in 4’ by 4’ bundles) and dump them by the river. Sometimes they covered up the bales with gravel and asphalt so you couldn’t see them (Interviewee #8) 12 �l r Hot Spots (11/2017 update) Grand Rapids Press, Amy Biolchini, November 12, 2017, Latest chemical find spurs fish study in river. “The data released Thursday showed samples taken from monitoring wells at the tannery site, which was demolished in 2010, ranges in concentration from 12,700 to 490,000-ppt. FOIA OBTAINED DOCUMENTS: Storm Water Prevention Plan and Application for Wastewater Discharge The following documents were prepared for the governmental agencies. In contrast to other documents herein, these depict a Tannery implementing best management practices, having procedures in place to prevent spills and having all the proper containment. See Appendix 1315 (Citizen obtained through EPA FOIA). 13 �1. Storm Water Prevention Plan 2009 was obtained from DEQ, Water Division (WD) through the FOIA process. The City of Grand Rapids Wastewater Survey for NonDomestic Establishments 2. Application for Wastewater Discharge for the Rockford Tannery, 1995- 2001 (Citizen obtained through City of Grand Rapids FOIA.) Author Summary Comment Based on the review of the documents you have one tannery, but there exists two very different accounts of the waste handling and disposal practices at that facility. The 1994 ESA findings, Wolverine chromium violations with the City of Grand Rapids, the June 30, 2009 e-mail between Ryan Grant and Jim Blue, and high PFAS (PFCs) findings at the tannery site seem to validate that there were times when the previous Tannery employees’ perspectives were true, despite the plans in place. Wolverine either knew, or should have known, of most or all of these historical practices. It appears the Wolverine 104e reporting does not meet even minimal professional standards of research and environmental regulatory required reporting. Any lending institution would not accept such poor reporting for a redevelopment project, so why regulators allowed this level of incompetent reporting is difficult to understand. THE SECTION ABOVE IS CITIZEN PROVIDED AND COULD NOT BE FOUND ON WWW’S CD, UNLESS NOTED B. EPA REQUEST # 3(C): Removal of Wastes EPA REQUEST # 3(c): Any and all information relating to the removal of wastes (both characterized and uncharacterized), including quantities, analyses and disposal destinations, during the demolition of the tannery. WOLVERINE RESPONSE: 3(c), Page 3 “Wolverine objects to this request as unduly burdensome and unreasonable to the extent that it asks Wolverine to respond to matters beyond its knowledge or to produce documents or information not within its possession, custody, and control. Subject to its general objections, Wolverine produces in response to this Request (3a-f) the documents in folder numbers 3 and 3-4 on the enclosed compact disc. THE SECTION BELOW IS CITIZEN PROVIDED AND COULD NOT BE FOUND ON WWW’S CD, UNLESS NOTED 14 �Author Comment 1 Under the Resource Conservation and Recovery Act (RCRA) Wolverine started as a Large-Quantity Generator (LQG). In August of 1996 Wolverine became a Small Quantity Generator (SQG). Reed Sneller, DEQ, Hazardous Waste Program, said in a phone conversation on 5/22/2013 that WWW became a Conditional Exempt Small Quantity Generator (CESQG) on December 31, 2007. In light of their generator status over the years it is interesting that no historical waste surveys or characterization reports appear to have been submitted by Wolverine in response to 104e Information Request. Also, no waste surveys or waste characterization reports related to the demolition appear to have been submitted by Wolverine in response to the 104e Information Request. DOCUMENT: ---RCRA A generator of hazardous waste shall compile and maintain information and records regarding the quantities of hazardous waste generated, characteristics and composition of the hazardous waste, and the disposition of hazardous waste generated. MCL 324.1118 (1) (c) The generator of hazardous waste shall keep all records readily available for review and inspection the MDEQ, State Police, a peace officer, or USEPA. MCL 324.11138(1) (f) DOCUMENT: ‘What Type of Wastes DO I Generate?” power point presentation by Christine Grossman, given at the Michigan Environmental Compliance Conference, April/May 2012: Demolition is shown as needing a waste survey. Appendix 16 (Presentation available on line, DEQ) DOCUMENT: Rose & Westra Report, September 19, 2011 Post Demolition Environmental Investigation. Valley City characterized and removed remaining process chemicals and waste for off- site disposal. These materials included waste in the former chromium and sulfide reclamation tanks which were located above ground and inside the tannery building.” Appendix 17 CCRR DOCUMENT: Previous Tannery Employee Interviewee #1: “When Wolverine was re-doing parts of the tannery, there were these two huge cement tanks about 25 ft. by 20 ft. and 18 ft. high. They were pillars that used to hold up the tanning drums. But they also were storage tanks. One tank was filled with chromium and the other tank was filled with sulfides. Wolverine wanted to be able to re-use these chemicals and not waste them. That was pure chrome in one of them. But the engineering project turned out to be a nightmare, yes it was very poor engineering, as a result Wolverine decided to just build the new area around these tanks. Yes, they just kept them there. No, they were never emptied out. Yes, they are above ground…. Yes, the tanks just became part of the building structure.” Appendix 11, Author Comment 2 The expansion that the tannery worker referred to is believed to be the 1988-1989 expansion. Those chemicals were left in these tanks as part of the building structures for approximately 21 years. 15 �DOCUMENT: NREPA Part 121 of ACT 451 _ Liquid Industrial Wastes (LIW) Generator must characterize LIW in accordance with hazardous waste regulations 324.12103(1) (a). Generator must keep LIW records for three years and have them available for review and inspection. Author Comment 3 It appears that not only was Valley City required to characterize the waste, but Wolverine as a Generator was required to characterize the waste. Where is either characterization document? WOLVERINE DOCUMENT: Warner Norcross & Judd Letter dated April 1, 2012 signed by Michael Robinson. Part 1 of Wolverine World Wide’s Response to the U.S.EPA’s Request for Information: “During demolition, in the event that Wolverine noticed a soil condition that appeared out of the ordinary, Wolverine characterized the soil based on available data. This occurred in two locations. One location was the space under the tannery maintenance area where waste line to the wastewater treatment plant had broken. The broken line was identified as the source of contamination. Accordingly, the soil was characterized as the same waste that had historically been treated at the wastewater treatment plant. It was disposed of as such by Valley City Environmental. The other location was directly under the primary clarifier tank at the wastewater treatment plant. In that location, there was a small amount of discolored soil that had the appearance and odor of tannery waste. This was characterized as tannery waste that may have leaked through a crack in the base of the clarifier.” (Citizen obtained EPA FOIA) CITIZEN FOIA OBTAINED DOCUMENT: Pollution Incident Prevention Plans: 1981, Section IV, D, page 4: The floor drains, in-plant sewer system and WWTP serve as secondary containment. Section V, Spill Cleanup Procedure, Other Spills: “A major spill would result should the main sewer line break. Should this occur, the disposal plant would be notified immediately and the entire plant operation would be shut down to cease the wastewater flow as soon as possible. Appropriate repair procedures would be undertaken to place the sewer line back in service.” Appendix 18 (Citizen obtained through City of Grand Rapids, June 5, 2013 FOIA) CCRR DOCUMENT: Previous Tannery Employee Interviewee #1: “Those sewers were full of all kinds of stuff: sulfides, chrome… Every chemical from the color dye department and the tannery went right through those pipes: chrome, spilled chemicals, sewage, sulfites, formic acid, sylph hydrides, format, ammonia sulfate, lime. These are just some of them.” Appendix 11 Author Comment 4 All the production waste chemicals and spills were sent to the WWTP via those in-plant sewer lines. The in-plant sewers were written up as being part of the secondary containment. The 1981 PIPP said that major spill would occur if there was a break to a main sewer line. Yet Wolverine identifies such a break in the sewer line as a source of contamination, characterizing it as the same waste that had historically been treated at the wastewater treatment plant. Wolverine says it was disposed of as such by Valley City Environmental. They never tested it to determine if it was hazardous. (11/2017 update: Given that Wolverine used Scotchgard containing PFAS (PFCs) until 2001, they were likely released as well.) 16 �• INFRACSTRUCTURE PHOTOS REMOVED CITIZEN FOIA OBTAINED DOCUMENT: According to the Rose and Westra Report, September 19¸2011 (Post Demolition Environmental Investigation), Wolverine reports to have characterized materials based on available data. page 3 “In addition, during demolition, continuous observations were performed to identify areas of contamination based on visual observations, the presence of or lack of odors, stained soils, deteriorated floors, and knowledge. …. These observations resulted in the identification of the two areas from which soil was removed.” page 2: The soils in these areas was excavated and transported to an off-site licensed landfill. The excavation in the maintenance area was approximately 50 feet square and 6 to 7 feet deep. The soil from the former primary clarifier area that was removed constituted approximately 10 cubic yards.” Appendix 17 (Citizen obtained through EPA FOIA) CITIZEN FOIA OBTAINED DOCUMENT: Rose & Westra (R&W) letter to Mr. David Latchana, WWW, dated February 6, 2012: Page 6: “The investigation did not find any physical or chemical evidence of buried waste, wastewater treatment plant sludge, or other industrial waste on site, along the riverbank, or on the bottom of the Rogue River.” (Citizen obtained through EPA FIOA) Page 6&7: “The MDEQ’s XRF Screening sporadically found both cobalt and molybdenum in soil samples from the Site along the Rogue River bank above the generic soil criteria for protection of the GSI pathway. These elements were found in background locations along riverbank. Neither R&W nor Wolverine found any documentation indicating these elements were present at the site.” Appendix 19 (Citizen obtained through EPA FOIA) 17 �DOCUMENT: Michigan Solid Waste Management Rules. 1. 2. R 299.4118 Inert material includes excavated soil, except if the materials are R 299.4114(3). Contaminated by hazardous substances in concentrations sufficient to cause environmental contamination. 3. R 299.4114(3). Low-hazard industrial waste tested and meeting the inertness criteria in R 299.4115 and approved by the MDEQ is considered an inert material. 4. R 299.4118 R 299.4115 To determine if a material is contaminated by hazardous substances in concentrations sufficient to cause environmental contamination a person may (I) test the material as required by R 299.4118 (material is not contaminated if the concentration of hazardous material is less than the concentration listed for inert materials in R 299.4115), or (ii) apply knowledge of the material. Author Comment 5 Standard practice in the industry is to prove that the soil is inert. The rules do say test or apply knowledge. Wolverine chose to apply knowledge rather than test. Yet those who might actually have possessed the relevant knowledge do not appear to have been consulted. In the absence of such knowledge, testing is critical . . . yet little or no testing was conducted. Who made these decisions? What expertise related to contaminated soils did these decision makers have? How long had the decision makers worked at the Tannery? Jim Blue, Wolverine’s Environmental and Safety Manager in a June 30, 2010 e-mail to Ryan Grant, DEQ, responded that Wolverine did not know for sure if there was a cement floor under the brick and mortar in the tannery. Did these decision makers have historical knowledge of previous findings listed under Citizen Comment for 3(b), such as the 1994 ESA? The most northern sampling locations done during the 2012 CERCLA PA went as far as the Wolverine Sole Plant which historically, is believed to have used hazardous chemicals in their processing. If that is true, then there were no true background samples collected. Wolverine’s 104e CD Folder 2 000000451513, Subfolder 2, 01 PDF, contains a FTC&H Pollution Prevention Plan 1987-1994(update). As part of this document there are scanned 1990 Material Safety Data Sheets (MSDSs) for chemicals used at the Wolverine Leather Tannery. In the 1990 MSDSs listed as hazardous ingredients are Cobalt (1%) (Dye molecule), (5%) Dye molecule, (9%) dye molecule; Cobalt + 2; Cobalt Complex; Cobalt Compound (30%), (70%), (100%); Cobalt complex dye (47%). These 1990 MSDSs, found on Wolverine’s CD, listing cobalt seem to contradict Wolverine and Rose and Westra’s statement that they never found any documentation that cobalt was present at the site. Appendix 20 (Only even numbered MSDS were found for pages 1-90 while pages 91-177 were in sequence. Why were the odd numbered MSDS from 1-90 not scanned and submitted?) (Citizen obtained through EPA FOIA) Wolverine in a Leather Finishing NESHAP: Initial Notification of Compliance Status dated April 20, 2005, list Cobalt Compounds as a HAP they used in finishes in their manufacturing from February 27, 2004 – February 28, 2005. Appendix 21 (Citizen obtained through DEQ FOIA). This is a rather current document that also seems to contradict Wolverine and Rose and Westra’s statement that they never found any documentation that cobalt was present at the site. 18 �Also, in the Wolverine 104e CD, Folder 3, PDF: NMCEO320111004092630 is a Republic Services Non-Hazardous Special Waste & Asbestos Manifest. Wolverine is listed as the generator. Waste Profile # is 40421018161. Waste Shipping Name and Description is Non RCRA/DOT Regulated Soil…. Total quantity was listed as 10 yards. It was dated 11/23/2010. The transporter is Valley City Environmental Services. The destination is Ottawa County Farms Landfill. Appendix 22 (Citizen obtained through EPA FOIA) Is this the manifest for the soil from the former primary clarifier area that was removed that constituted approximately 10 cubic yards? The 1990 MSDSs listed 360 hazardous ingredients used at the Tannery. If yes, then Wolverine is claiming without testing, based only on knowledge, sight and smell, they could discern that this soil was contaminated and at what concentration to determine it was not hazardous, therefore, not regulated under RCRA/DOT. (Highlighted in green is all about CD related information) CITIZEN FOIA OBTAINED DOCUMENT: Hazard Communication Program, Pitsch Companies, Grand Rapids, Michigan Employee training included the following: information on chemicals and their hazards, how to read and interpret labels and MSDSs and where to locate MSDSs. Pitsch would give information to their employees about the hazards involved when working in hazardous areas. Shouldn’t Pitch have provided MSDSs, which Wolverine by law was required to provide, to their employees prior to working at the tannery demolition site? Importantly, Wolverine DID NOT supply all historical and current MSDSs on their CD to EPA. Appendix 23 (Citizen obtained through City of Rockford FOIA) WOLVERINE DOCUMENT (NOT Produced in 104e Response): Pitsch Demolition Plan/Contract with WWW, dated August 2010. 1. 1.3 Hazard Recognition “Based on the nature of historical use of the property the potential environmental concerns include the following: a) asbestos- containing materials in the building; b) heavy metals with the paint on certain surfaces within some of the buildings; c) Mercury-containing switches and fluorescent lights; and d) Equipment containing polychlorinated Biphenyls (PCBs) 2. 2.0 Work Tasks: Number one on the list was a pre-demolition survey. 3. 2.3 Asbestos/Abatement “If present, Pitsch will remove asbestos-containing materials (ACM) from the buildings prior to demolition as required under current State and Federal regulations. The types and quantities of ACM will be determined as a result of the Pre-demolition Asbestos Survey. The results of the survey will be provided to Rockford Construction Company and Wolverine Worldwide.” 4. 2.6 Demolition of Buildings and Structures “Materials will be sorted based on recycling potential.” Further down… “The concrete, brick, and block will be transported off site and crushed for re-use” 19 �5. 2.7 Air Monitoring “…….The Cassettes will be analyzed for lead, cadmium, and chromium (trivalent and hexavalent). 6. 3.3 Staging of Impacted Concrete If present, excavated concrete suspected of being impacted will be placed on polyethylene plastic sheeting and covered with the sheeting at the end of each day. 7. 3.9 Certified Scales The licensed landfills and scrap dealers listed above have certified scales that will be used as evidence of disposal. The scales may be used for loads not associated with manifesting disposal of regulated materials. We will notify the Site Representative of any additions to the locations listed. Tickets for all weighed loads will be tabulated and submitted to the Owner at the end of the project. Appendix 24 Author Comment 6 The Pitsch’s Demolition Work Plan was approved in August 2010 prior to September 1, 2010 start of demolition. Why were impacted soils and concrete not considered potential environmental concerns, especially prior to testing and characterization? Local concerned citizens never saw any impacted concrete being separated out from the recycle waste stream. To the best of our knowledge, all of the impacted concrete was disposed of as construction waste at a facility not disclosed by Wolverine or its contractors. Most disturbing, this potentially impacted waste might then have been distributed throughout the community as fill or surface cover. In Wolverine’s 104e Part I, page 4: “an asbestos survey was performed in advance of demolition. Asbestos removal took place prior to demolition, as well as during demolition when asbestos was identified.” Why did Wolverine not submit the pre-demolition survey and the Pre-demolition Asbestos Survey that were required as a part of the approved Pitsch Work Plan? According to Wolverine in the 104e Part I Response, the asbestos survey was done. In an e-mail from Chris Kestner, Materials Testing Consultants (MTC) (City of Rockford’s consulting firm) to Michael Young, Rockford’s City Manager, asks the following: “I would like to see the Chromium results broken down between trivalent and hexavalent.” “I have not seen any asbestos sampling results from the demolition. Are you going to receive any?” I did not find any air quality test results on Wolverine’s 104e CD that showed chromium results broken down between trivalent and hexavalent, nor were any asbestos sampling results found. Both were required by the work plan and asked for by MTC. Appendix 25 (Citizen obtained through City of Rockford FOIA) It does not appear there were any surveys, characterizations, test results, and manifests submitted documenting hazardous materials. Are we to assume there were none done on a 100 plus year old tannery site? It is as if Wolverine and their contractors had already determined prior to any testing or characterization that this site would contain no hazardous materials. 20 �Even if there were absolutely no hazardous materials identified on the site, as indicated on Wolverine’s submitted documentation received through FOIAs, Wolverine still should have the tickets submitted from Pitsch for all weighed loads. At the minimum, this information would have verified the locations to which the demolition material was transported. Yet these tickets were not found on the Wolverine’s CD or Wolverine’s responses Part I or Part II. THE SECTION ABOVE IS CITIZEN PROVIDED AND COULD NOT BE FOUND ON WWW’S CD, UNLESS NOTED C. EPA REQUEST #4: Chemicals Historically Used EPA REQUEST #4: Identify the chemicals historically used at the site. Wolverine’s Response: #4, Part I, Page 3 Wolverine objects to this request as unduly burdensome and unreasonable to the extent that it ask Wolverine to respond to matters beyond its knowledge or to produce documents or information not within its possession, custody, and control. Subject to its general objections, Wolverine Produces in response to this request the documents in folder 3-4 on the enclosed compact disc. Author Comment 1: Contents of Wolverine CD Based on accounts from former workers and review of documents, it is unlikely that the documents provided by Wolverine constitute a complete, or even a best effort, attempt to identify historical chemicals used at the facility. (11/2017 update: Most importantly, Wolverine failed to identify PFAS (PFCs) found in Scotchgard that they used in their manufacturing process when they knew since January 10, 1999 it posed public health and safety threat.) This comment provides a list of pertinent documents to this information request that are on Wolverine’s CD: Based on the author created Table of Contents for the Wolverine 104e CD, Wolverine provided lists of chemicals used at the tannery which can be found in several different folders on the CD. From the Author Generated CD Table of Contents. (Appendix 0. The complete Table of Content) Folder 1 000000434865 Year 2005 and 2006 Chemical inventory Year 2005 and 2006 Dye Inventory. Folder 2 000000451513 21 �Sub-Folder 2, 01 PDF: FTC&H Pollution Incident Prevention Plan 1987-1994 (update) attachment 1990 MSDS (pages 2-177) Sub-folder 2, 04 PDF Pollution Prevention Plan 2007 Sub-folder 3, PDF 1, 64499350 1 WWW Tannery – List of Chemicals, Excel 6499350 – 1, WWW Tannery List of Chemicals Sub-folder 3, PDF 2, Document 1: Uniform Hazardous Waste Manifests Folder 3 000000451514 Sub-folder 2 (2/3): Repeat of Folder 2 000000451513 Subfolder 2, 01: FTC&H Pollution Incident Prevention Plan 1987-1994 (Update) Sub-folder 2 (2/3): Repeat of Folder 2 000000451513 Subfolder 2, 04: FTC&H Pollution Prevention Plan 2007 Folder 7 DOJ Index D. EPA REQUEST #5: Use, Generate, etc., any hazardous substances, etc. EPA REQUEST #5: Did you ever use, generate, store, treat, dispose, or otherwise handle at the Site any hazardous substances, wastes, or other materials? If the answer to the preceding question is anything but an unqualified "no," for each such hazardous substance, waste or other material, describe in detail the nature and volume of the hazardous substance, waste or other material, and how it was used, generated, stored, treated, disposed or otherwise handled at the Site. First Wolverine’s Response: #5, Part II, page 4-7 Wolverine objects to this request as unduly burdensome and unreasonable to the extent that it asks Wolverine to respond to matters beyond Wolverine's knowledge or to produce documents or information not within its possession, custody, and control. Wolverine further objects to this Request to the extent that it asks Wolverine to make a present legal determination with respect to terms of art such as "generate," "store," "treat," "dispose," "hazardous substance," and "hazardous waste." On the enclosed compact disc Wolverine is providing documents that list materials used in tannery operations. The lists, which are broken down by period in Microsoft Excel spread sheets, include the quantity (in pounds), item number, product name, and price per unit (pounds) of materials used at the Site during the period from 2005 to 2006. To Wolverine's knowledge, the information in the documents on the enclosed compact disc is representative of materials used at the Site during periods 22 �of high-volume operation. To Wolverine's knowledge, materials used during other time periods of tannery operation would have been substantially similar with respect to the nature of materials used, but would have differed with respect to volumes used. Other years of tannery operations generally would have used lower volumes of materials than the volumes used during the 2005-2006 period, which was a relatively high-volume year for production. Each of the listed materials was used in Site tannery operations. Those operations involved four main processes: tanning, coloring, finishing, and disposal at the wastewater treatment plant. NOTE: See Appendix 26 for further detail regarding Wolverine’s general response regarding the tanning process. THE SECTION BELOW IS CITIZEN PROVIDED AND COULD NOT BE FOUND ON WWW’S CD, UNLESS NOTED Author Comment 1 A review of the Wolverine CD documents and documents found in the public domain revealed a more comprehensive list of chemicals, especially related to their hazardous ingredients, than found in 2005 and 2006 chemical and dye lists Wolverine referenced on their CD as “representative.” In other words, Wolverine’s own documents conflict with the chemical use and handling practices referenced in their 104e written response. Earlier documents indicate that there were more hazardous ingredients listed for the chemicals that were used in the manufacturing process. Scotchguard was listed as hazardous on the 1990 MSDS sheets in the CD. (11/ 2017 update: Wolverine never mentions the PFAS (PFCs) contained in Scotchguard, that they knew since January 10, 1999, was a public health and safety threat.) Complicating the identification of chemical ingredients, Wolverine’s more recent documents give just the brand names for most of chemicals, and the ingredients of most of those chemicals are often considered “proprietary” and are not otherwise accessible in the public domain of information. Therefore, I wasn’t able to identify any hazardous chemicals found in the more recent brand names of chemicals that Wolverine listed. WOLVERINE’S 104e CD (Citizen obtained through EPA FOIA) 1. 2005 and 2006 Chemical Inventory and Dye Inventory (Wolverine 104e CD, in folder 1 000000434865. Where are the Material Safety Data Sheets (MSDS) that will identify the hazardous ingredients for these chemicals and dyes? 2. Wolverine Tannery list of chemicals, both in a Word document and an excel spread sheet: Wolverine 104e CD, Folder 2, Subfolder 3, PDF 1 6499350. No hazardous ingredients were identified. No MSDSs included. 3. Maps of storage locations for chemicals (Wolverine 104e CD, Folder 7, PDF Tannery First Floor 2012, PDF Tannery 3rd floor 2013). The demolition of the tannery was completed in August 2011. Therefore, I am not sure what the 2012 floor and 2013 floor refer to. There appears to be no other dates that show the time frame for the storage lay out shown on these maps. Based on review of other Pollution Incident Prevention Plans this layout appears to be the result of the 1988-89 or later treatment plant upgrade. 23 �4. 1987-1994 Updated Wolverine Pollution Incident Prevention Plan (PIPP), prepared by FTC&H. PIPP contains the 1990 MSDSs for the chemicals used on site (Wolverine 104e CD, folder 2 000000451513, subfolder2, 01). There are 360 different hazardous ingredients listed on the MSDSs. Citizen generated list of Hazardous Ingredients found in a 1990 MSDSs. Appendix 20 5. Uniform Hazardous Waste Manifests, (Wolverine 104e CD, Folder 2, sub-folder 3, PDF 2 Document 1). There are 24 state manifests listed with approximately 50 hazardous materials listed. The materials names on some of the manifests were illegible so an exact number could not be determined. See citizen generated list, Appendix 27 CITIZEN FOIA OBTAINED DOCUMENT: 1981 Wolverine PIPP, prepared by FTC&H, and found in the City of Grand Rapids Industrial Pretreatment Program’s files. (Citizen obtained through City of Grand Rapids FOIA, 6/5/2013) The document has a section related to where materials were stored. Appendix B gives chemical name, properties, and characteristics, hazard potential, and unit volume of storage. There is a section on Storage Areas and Tanks. Appendix A gives dimensions, volume, construction material. Tank locations are shown on a map. All major storage tanks have an overflow pipe back to the in-plant sewer system where a spill can be handled in the appropriate manner for the substance involved. The following information (emphasis added) was readily available to Wolverine: “Section III, B Storage Areas: The main storage area for all drums and bags of chemicals was in the main warehouse. Here the chemicals were stored in designated areas until needed for leather processing. They were then transported to the appropriate area of the tannery for use. To prevent possible interactions of the wet and dry materials, they were separated on opposite sides of the warehouse. The liquids chemicals and powered dyes were stored in the same general warehouse area; however, the floor surface was sloped towards a floor drain which drains to the waste disposal plant.” “Tin Shed Storage: 55-gallon drums of hydraulic oil were stored in a tin shed separate from the plant. The floor area was compacted soil and there were no floor drains.” Outside Open Storage: Several chemicals were presently being stored outside the main plant. These were listed in Appendix B and shown on the site plan. It was FTC&H’s understanding that when the present expansion of the tannery was complete, these chemicals would be moved to an appropriate indoor storage area furnished with proper drainage. The chemicals stored outside are the following: Acetic Acid and Muriatic (Hydrochloric) Acid were stored in Area 14. Busan 30, Chemol 21, D-Terge X 348, Emusan 20W, Scotchguard FC-236A, FC-236B, Fc-152, Texol-C, Mardol 55 Oil and 930 Oil, Surfonic J-4, Mitco A-5-2 were stored in Area 15. Busan 30, Scotchguard FC-236A, FC-236B, FC-152, Silicone, LS1644-R, M.I.B.K. were stored on Area 17. Isopropyl Alcohol Eastern 930 Oil, Linco Levelin L were stored in Area 18. “Containment: The entire plant including the hide house, tan yard, warehouse, and wastewater plant was paved with concrete. The concrete paving was sloped such that surface drainage is directed by gravity into the in-plant sewer system. Pavement serves as the primary containment. The floor drains, inplant sewer system and WWTP serve as secondary containment.” 24 �Recommendations: These are a few of the recommendations that were found in the 1981 PIPP. 1. “It is recommended that all outside storage be moved to a properly drained or contained area to prevent any spills to the environment. Proper drainage or containment by curbing of the plant yard should be provided to handle surface runoff from the yard. This would minimize the potential to hazardous materials being carried by the runoff to the nearby water course. 2. Accurate inventory records and weekly oil level measurements should be made to detect possible leaks in the underground fuel oil tank. 3. Containment and/or appropriate drainage should be provided for the empty drum storage area (area 25) to prevent any leakage from being carried away by runoff. 4. All oil stored in the tin shed (area 28) should be moved to a properly drained or contained storage area. 5. This spill plan should be updated as soon as the plant expansion is completed. “ Appendix 18 Author Comment 2 • • • It is misleading when the information provided by Wolverine on the 104e CD reveals a much more complete picture of the type and number of chemicals they used, and where they were stored on site, than what was reflected in their e-mails, letters, written 104e Part I& II Responses and the Rose & Westra’s reports related to the demolition and justification to limit areas to sample in response to the 2012 CERLA PA. No MSDS sheets, except the 1990 list were found on the CD submitted. At the very least, Wolverine should have had more recent MSDS sheets, since Wolverine indicated that they made their characterization of possible contamination during demolition based on current “knowledge.” Having both historical and current MSDSs would have been foundational to such an informed decision, yet Wolverine either made its decision in the absence of such key information, or chose not to produce it to EPA. In the 104e written response and in other correspondence to EPA, Wolverine appears to describe the chemical storage locations and containment structures based on what the building site, and infrastructure were after the consent ordered plant expansions, and upgrades, completed in 1989 and 2001. For example, the 11/28/11 R&W map, copied below, titled Former Storm Water Drainage Patterns, seemingly ignores the fact that, historically, Wolverine stored some chemicals outside—with no containment. 25 �• Rose & Westra stated that due to Wolverine’s containment which included inside chemical storage and in-line storm water sewer system that discharges to the WWTP, no sampling was needed to be done in the sub-catchments areas south of the tannery, retail area, warehouse and power house. Yet readily available historical information, some of which was raised to Wolverine through regulators, indicates a much different facility configuration in earlier years. And those earlier years likely included significant releases and disposal activities. For example, the 1981 PIPP and maps shows chemicals being stored outside with no containment, with storm water runoff heading in the direction of the river. R&W’s own map appears to be labeled incorrectly. The hide house was located north of Rum Creek and the building labeled retail, historically, was used for shoe manufacturing. Also, the catchment adjacent to the north side of the Rum Creek states storm water drainage area drains to WWTP. Yet the storm water inlets appeared to be tied in to a sewer line that is discharging to Rum Creek. Also, the catchment to the north of this one also has storm water inlets tied to this same sewer line and this catchment is labeled storm water drainage drains to Rum Creek. • Scotchguard FC-236A, FC-236B, which contained PFAS (PFCs), were stored outside with limited or no containment indicated on the 1981 PIPP map. No one in 1981 realized the public health threat PFOS (One of the PFAS in Scotchguard) posed. (11/2017 update: We now know that Wolverine was notified by 3M with the concerns over PFAS (PFCs) and its related public health and safety threats through a January 10, 1999 meeting at Wolverine headquarters and a follow up letter dated Jan 15, 1999 to 26 �Wolverine‘s former Vice President, Rick DeBlasio. Yet they still failed to disclose this to EPA and DEQ. Instead they repeatedly said, “There is no known contamination on site.” In fact, until 3M disclosed this letter in Nov 2017, Wolverine had been saying they didn’t know about the PFAS (PFCs) until the fall of 2016. The January 15, 1999 letter contradicts the concept that Wolverine did not know about the PFAS problem until 2016. Also, the statement that they were unaware of any known contamination at the site can only refer to the knowledge of authors of the 104e Wolverine Response as there was a great deal of evidence available to Wolverine staff (especially the environmental officer) and regulators that oversaw the site, that there was contamination on site. To have been unaware of the contamination would speak to an inexcusable level of incompetence, especially when one sees how large the contaminant problem is that regulators are now discovering at the plant and around the county. - 0 - -- ··--- (11/2017 update: Based on latest information foam should be added to the list that should be tested for PFAS (PFCs). Fish were tested in the Rogue River impoundment in 2013 and found to contain PFAS (PFCs) at significantly elevated levels prompting a 2015 consumption advisory from the Michigan Department of Health and Human Services.) 27 �• The 1981 PIPP documents the potential for spills that could lead to both environmental and public health and safety impacts. The 1994 ESA documents spills, discharges to the waters of the state and contamination of the soils that did occur between 1980 and 1994. CITIZEN OBTAINED DOCUMENT: Toxic Release Inventory (TRI) – Names and Amount of Chemical Released to the Environment by Year. WWW.EPA.Gov, My Environment: Rockford MI, Wolverine Leathers CITIZEN FOIA OBTAINED DOCUMENT: Wolverine’s Storm Water Pollution Plan, January 2009, Appendix 13 (Citizen obtained through DEQ FOIA) THE SECTION ABOVE IS CITIZEN PROVIDED AND COULD NOT BE FOUND ON WWW’S CD, UNLESS NOTED SECOND Wolverine’s Response: #5, Part II, page 7 “As explained in previous submissions, all liquid wastes at the Site, including wastes generated from the above processes, as well as storm water and any waste from floor drains, were conveyed via process piping to a wastewater treatment plant. Such wastewater was treated in the wastewater treatment plant; treated wastewater was discharged to the municipal sanitary sewer system; and pressed sludge cakes from the onsite wastewater treatment plant were disposed of at an approved offsite landfill.” “Other wastes generated at the Site were generated in relatively minimal quantities. These Non-liquid wastes included the following: general office refuse (collected for disposal by general Waste contractor, Waste Management); scrap steel, washed plastic drums, and shrink wrap (sent as scrap for recycling to Padnos Iron & Metal); waste oils, including hydraulic oil (collection and disposal company not known); cardboard (collected for recycling by general waste contractor, Waste Management); and dust-collector waste (collected for disposal by general waste contractor, Waste Management).” THE SECTION BELOW IS CITIZEN PROVIDED AND COULD NOT BE FOUND ON WWW’S CD, UNLESS NOTED Author Comment 3 Citizens are aware of at least three documented situations, all in the public record, in which Wolverine’s past waste disposal practices were found to be causing potential adverse impacts to public health. Each of these three situations is described below. 28 �“In 1997, the United States Environmental Protection Agency (EPA) informed Wolverine that EPA was investigating possible contamination at the Butterworth site. As a result of the EPA investigation, Wolverine participated in an allocation mediation process with other potentially responsible parties to determine allocation of fault. Ultimately, Wolverine was deemed to have been liable for 1.306% of the fault. Although Wolverine did not agree with the mediator’s findings, it decided not to contest the findings. Wolverine incurred $1,224,550.84 in remediation costs, its allocation of liability.” “Wolverine World Wide, Inc. v. Liberty Mutual Ins. Co., No. 260330 ( Mich. St. App. March 8, 2007) Liberty Mutual, the insurer, issued two umbrella policies to Wolverine World Wide (Wolverine), a footwear manufacturer, covering the years 1966 to 1972. Wolverine produced a toxic sludge as a result of its tannery operations, which it disposed at two sites: Butterworth Landfill, between 1965 and 1973 and the Northeast Gravel site from 1970 to 1979. In 1991, the Michigan Department of Natural Resources (DNR) informed Wolverine that it was investigating contamination at the Northwest Gravel site and warned Wolverine of its potential liability. The investigation confirmed that Wolverine’s tannery sludge was not responsible for the contamination; however Northwest Gravel sued Wolverine. Wolverine spent $199,339.20 to resolve the matter. (Mass Tort/Environmental—Michigan Court of Applies “Time-on-the risk” Allocation to umbrella Insurer in Pollution Damages Case. March 15, 2007. Clarence Y. Lee).” There is no indication that the investigations included PFAS/Scotchguard investigation. Plainfield Township Parks and Recreation Master Plan 2005-2009, Page 29. ”At the northwest corner of US-131 and House St., Wolverine Boot Company once maintained a dump for their tannery waste operations. Tanning processes result in a number of harmful by-products, some of which may have been dumped here. Once again, although the extent of the contamination is not known, the impact does not appear significant.” (This information clearly conflicts with the Wolverine’s representation that sludge was only disposed of at an “approved offsite landfill.”) (11/2017 update) The Grand Rapids Press, November 16, 2017, Garret Ellison, Water testing moves to new neighborhood, “Brown said the DEQ has heard about sludge applied to farmland as fertilizer in numerous neighborhoods around the Kent County amid the agency’s investigation into groundwater contamination connected to Wolverine waste sites. Plainfield Township Board meeting minutes from1980 contain references to Wolverine spreading sludge on farmland. “We’re just automatically considering that could be a strong possibility at all these locations now,” she said. The list of sites, or “source areas”, the DEQ is investigating has grown to 75, about 26 of which the agency has referred to Wolverine for follow-up testing, she said.” 29 �Author Comment 4 I could not find any of this information regarding such past practices in Wolverine’s response to the U.S. EPA 104e. Furthermore, since Plainfield Township has not investigated the extent of the contamination, how extensive might it be? At the very least, it seems that Wolverine should have knowledge of the existence of this dump site. It is recorded in a very recent public document. Public record shows that Wolverine owns the land. (11/ 2017 update: As of November 16, 2017 Wolverine is currently investigating 26 sites for additional water testing of which none of these sites are approved off-site landfills. Channel 13, an ABC affiliate, 11/19, 2017 Sunday Morning Show, stated that of the 413 Wolverine well monitoring results that are in, 173 homes show well water with PFAS. There are 28 homes with wells showing PFAS greater than 70 ppt and 145 homes with wells showing PFAS 0-70 ppt. Importantly, Wolverine’s direct misrepresentation to EPA regarding improper disposal of treatment plant sludge, containing PFAS (PFCs), has resulted in years of additional injury and exposure to residents consuming water impacted by such sludges and other Wolverine waste. Scotchgard: (11/ 2017 update: CCRR met with DEQ on January 24, 2017. They wanted to share their concerns that Wolverine had used Scotchgard that contained PFAS (PFCs) in their tanning process. Also, based on an interview conducted by this author with Mr. Earl Tefft, Wolverine had disposed of their waste in the mid 60’s at their dump site located off House St. as well as at a dump site at 3 Mile and East Beltline and a dumpsite just west of the White Pine Trail where it crosses 12 Mile. Mr. Tefft was an employee of Bell’s Trash Pickup who contracted with Wolverine to transport their waste to Wolverine’s designated disposal areas. CCRR was concerned that private wells in these areas could be contaminated with PFAS (PFCs). DEQ eventually notified Wolverine who began testing private wells in the House Street area in the spring of 2017. However, DEQ at the time had indicated that it lacks the funds to address such contamination.) THE SECTION ABOVE IS CITIZEN PROVIDED AND COULD NOT BE FOUND ON WWW’S CD, UNLESS NOTED E. EPA REQUEST #6: Describe Wolverine’s waste management practices EPA REQUEST #6: Describe Wolverine’s waste management practices at the site, including the period antedating the construction of the wastewater treatment plant. In your response, identify any practices or incidents in which liquid waste, off- specification liquid process materials or sludges were spilled, disposed of, buried, placed, or stored upon the land at the site, and identify the locations of any such areas of spillage, placement or storage. 30 �Wolverine’s Response: #6, Part II, page 8. • “Wolverine objects to this request as unduly burdensome and unreasonable to the extent that it asks Wolverine to respond to matters beyond its knowledge or to produce documents or information not within its possession, custody, and control. • As explained in Response 5, Wolverine’s waste management practice with respect to liquid waste was to convey all such waste to the onsite wastewater treatment plant. Wolverine currently has no knowledge of Site practices antedating the construction of the wastewater treatment plant. With respect to other wastes, Wolverine’s practice was to dispose of them as described in Response 5 on Page 5. Such wastewater treated in the wastewater treatment plant; treated wastewater was discharged to the municipal sanitary sewer system; and pressed cakes from the onsite wastewater treatment plant were disposed at an approved offsite landfill.” • “Wolverine is not aware of any practices or incidents in which liquid waste, off-specification process material or sludge was spilled, disposed of, buried, placed or stored upon the land at the Site. Wolverine is aware of only one spill in the tannery building. A 2007 malfunction of a sulfuric acid tank resulted in a spill of sulfuric acid into a barrier enclosing the tank. The barrier completely contained the spill such that the acid was not directed through the floor drains to the wastewater treatment plant. Valley City Disposal collected the spilled acid and transported it to Envirite in Canton, Ohio, for recycling.” - THE SECTION BELOW IS CITIZEN PROVIDED AND COULD NOT BE FOUND ON WWW’S CD, UNLESS NOTED Author Comment 1 Given the large of amount of leather and other wastes being found at the tannery, it is not possible for Wolverine Corporation as a whole to be unaware of any practices at the tannery that could have led to contamination at the site. Only the authors of the response could say this, but they cannot be speaking on behalf of the entire corporation as many that worked at the tannery would have been aware of the burial practices and spills. This appears that proper due diligence was not applied by the authors who represented Wolverine in the response to the 104e request. In other words, it seems impossible to believe that authors of the 104e response could be aware of only a single spill at their 100 plus year old tannery. A spill that was fully contained and resulted from a sulfuric acid tank malfunction. Previous tannery employees that were interviewed by CCRR, identified a large number of spills and buried tanks, and waste by-products that were buried. The 31 �1994 ESA mentioned in response to EPA Request 3(b) also listed documented spills, stained and contaminated soils, leaking underground storage tanks, hides and other wastes stored outside on site, and violations notices for surfaces water discharges. A 2009 e-mail from a DEQ staff to Jim Blue, Environmental and Safety Manager, stating he had concerns about the sloppy housekeeping he observed around the WWTP and due to the deteriorated condition of the flooring in the plant, especially underneath the tanning drums, that there was the potential risk of process fluids reaching the soil, groundwater, and surface water. Further, the authors of the Wolverine 104e response to have narrowly and improperly interpreted EPA’s request for site disposal information as applying only to hazardous materials disposed of on-site. To the extent that off-site waste management processes were utilized by Wolverine, including improper off-site dumping, these practices should also have been identified. They were not. It is clear that the authors of the Wolverine response failed to conduct even cursory investigation that might have ensured an accurate and informative response to EPA, for example by failing to make inquiries to proper employees and available records. From the response of the authors of the Wolverine response, there is a question of whether Wolverine ever informed waste haulers of the potential RCRA liability they were incurring for improper disposal of hazardous wastes, if the wastes were improperly being characterized? CITIZEN DOCUMENT: Tannery Worker Interviews CCRR conducted interviews of 8 former Wolverine Tannery workers. The oldest interviewee had worked at Wolverine for 40 years. Workers were eye witnesses to a variety of spills, many of which were not contained. Listed below are four quotes from different workers regarding type of and frequency of spills. Appendix 11 Interviewee # 4: • “There were hundreds of chemical spills in the tannery and hide house. There were cracks in the floor all over the Hide house. All the sewage pipes were always plugging up with scraps of leather and were overflowing. I mostly remember the chrome and sulfides. Sometimes a door on a tanning drum would break with no warning, and chrome and other stuff like sulfides would just come splashing out of the drums.” BRICK PHOTOS REMOVED Interviewee #5: • “There were two other railroad car tankers that were placed in a small building just off the SW corner of the tannery, at the back of the building. One tanker was filled with 930 oil and the other one filled with Mardol. The two were stacked right on top of each other. There was dirt floor in there. I am quite sure the oil was leaking, because when I went in that building to 32 �check on those tanks, I would stand up to me knees sometimes in mud and oil. In the 1998 a strong storm blew the top off the little building. So, they removed the two tanks and got some new ones that they put in the second floor of the tannery. Again, they just filled in that area where the tankers were with sand and covered it up with asphalt. Interviewee #8: • The aeration tank use to overflow. White foam would go all over the place. Sometimes it looked like it had snowed. It even reached the parking lots. • “They would take bales of leather trimmings (packed together in 4’ by 4’ bundles) and dump them by the river. Sometimes they covered up the bales with gravel and asphalt so you couldn’t see them.” Interviewee #2: • “We carried formic acid around in buckets, also muriatic acid. It would slosh around and spill on the floors.” WOLVERINE DOCUMENT (NOT Produced in 104e Response): Phase I ESA of a portion of the Wolverine’s Tannery Site done in 1994 by FTC&H. Wolverine did not produce this important document to EPA. It seems unlikely that Wolverine did not receive a copy of the 1994 ESA. At a minimum, they should have had knowledge of the statements below. Appendix 4 “STORED HIDES AND WASTES Hides and or Wastes stored onsite north of Rum Creek may have leached contaminants, such as heavy metals, to the soil or groundwater beneath the site. l HIDE STORAGE, IMI.IEOIAn:LY ~ST Of WINERY ll'J,IES,l~S,, r SOIL STAINING Staining was observed onsite adjacent to the unidentified WWW dumpster. The staining appeared similar in color to that observed beneath a hide storage trailer. 33 �ELEVATED LEAD LEVELS Elevated lead levels were detected in soils east and west of the former railroad tracks in the vicinity of the former WWW USTs. The concentrations were greater than background levels of MDNR Type A cleanup criteria. LEAKING UST(s) 1988 - Three other UST’s were removed, a 12,000-gallon UST, a 2000 Gallon UST, and a 900-gallon diesel UST. A letter from WWW to the MDNR states that no evidence of leakage was noted during removal of the USTs. It does not appear that a site assessment was conducted and locations for these USTs were not discovered in the file. SOIL EXCAVATION RECOMMENDED 1992 – Closure of 3 additional gasoline USTs was begun. Soils were stained and had a petroleum odor during closure activities. Elevated levels of lead were discovered in the soils near one of the USTs, the one closest to the WWTP, near the river. A soil lead concentration of 1400 ppm was detected in soils approximately 20’ to 30‘east of the (UST) site and 100’ south of Rum Creek, exceeding the direct contact criteria for lead of 400 ppm. Soil excavation was recommended for the southern end of the site, due to elevated levels of lead detected in borings made 4/-6’ bgl, 20’ to 30 ‘west of the site and 200 ‘ south of Rum Creek.” CITIZEN FOIA OBTAINED DOCUMENT: URGENT VIOLATION NOTICE: National Response Center Incident Report HYDRAULIC OIL RELEASE TO RUM CREEK Urgent Violation Notice: On December 13, 1999 WWW received an urgent violation notice for a Hydraulic Oil Release into the surface waters of Rum Creek and Rogue River. Appendix 5: December 13, 1999 Wolverine Incident Report. (Citizen obtained through DEQ FOIA) CITIZEN FOIA OBTAINED DOCUMENT: NPDES PERMIT DENIED BY DEQ: HOUSEKEEPING IN WWTP AREA BAD Concern for significant soil contamination: DEQ INTER-OFFICE E-MAIL. Ryan Grant June 29, 2010 e-mail to Susan Erickson: …“They (Wolverine) did have a NPDES Industrial Storm Water Permit that I oversaw and they tried to terminate the permit spring/summer of 2009. I denied the request because at the time the WWPT was still operating and the housekeeping around the WWTP was bad. To this date there has been no request to terminate the permit. I was given the tour of the site and had some concerns that I talked to Gerry Heyt about last year. There is a tributary to the Rogue River that flows underneath the tannery building and the flooring in much of the tannery building is the original brick and mortar lacking the mortar. I expressed my concern to The Wolverine World 34 �Wide EHS manager and Gerry Heyt that there may be significant soil contamination at this site given my observation.” Appendix 9 (Citizen obtained through DEQ FOIA) Author Comment 2 These documents record a number of on-site disposal and releases, which run directly contrary to those represented in Wolverine’s 104e Part II response. The authors of the 104e II response do not appear to have consulted with those who worked at the tannery given that they (the authors) did not uncover simple things like communications from the DEQ to the Environmental and Safety Manager at the plant about observed evidence of widespread release of contaminants at the site... THE SECTION ABOVE IS CITIZEN PROVIDED AND COULD NOT BE FOUND ON WWW’S CD, UNLESS NOTED Wolverine’s Response # 6 (CONTINUED) “As explained in Part 1 of its Response, during tannery demolition Wolverine identified two locations of soil contamination at the Site. One location was the space under the tannery maintenance area where the waste line to the wastewater treatment plant had broken. The broken line was identified as the source of any soil contamination and materials in the so-called “pit”. Accordingly, the soil and materials were characterized-as the same waste that had historically been treated at the wastewater treatment plant. They were completely removed down to the water table and disposed of offsite by Valley City Environmental at Ottawa County Farms Landfill in Coopersville, Michigan. The other location was directly under the primary clarifier tank at the wastewater treatment plant. In that location, there was a small amount of discolored soil that had the appearance and odor of tannery waste. This was characterized as tannery waste that may have leaked through a crack in the base of the clarifier. The discolored soil and material were removed and disposed of offsite by Valley City Environmental at Ottawa County Farms Landfill.” THE SECTION BELOW IS CITIZEN PROVIDED AND COULD NOT BE FOUND ON WWW’S CD, UNLESS NOTED Author Comment 3 The definition of characterization used by the authors of Wolverine 104e response, does not seem to be consistent with the EPA definition of characterization. It seems from the response that Wolverine removal response failed to determine the boundaries of contamination and the extent of contamination to be removed by sight and smells or by encountering the water table during excavation... Wolverine further appeared to fail to have a working knowledge of the chemicals it was utilizing, their concentrations, and whether they were hazardous or not. Wolverine may have removed all the soils down to the water table under the maintenance building, but without testing, Wolverine simply could not have determined the width and length of the contaminated 35 �soils area, in order to ensure all contaminated soils in this area was removed. An aerial map shows they removed only about half of the soil in the pit area. Yet sampling does not appear to have been completed in the area where no removal activities have occurred. ·-- . NOTE: Soils not rem in Southern half of PIT. • • w of site Aerial v1et demolition 2012: Pos (11/2017 update: Previous Wolverine employees interviewed by CCRR stated that the pit area was considered by them to be one of the hot spots for possible contamination at the tannery site. If this is true, then there would have been Scotchgard releases containing PFOS (PFCs) in the pit area. Since Scotchgard was listed by Wolverine’s 1990 MSDS sheets as a hazardous chemical, shouldn’t Wolverine have had the knowledge to know to require an appropriate characterization test?) How could Wolverine determine the length and width of the contaminated area under the primary clarifier without testing? It is our understanding that sight and smell provide a starting point, but characterization through testing identifies the chemicals, concentrations, boundaries and whether they are hazardous or not. See the following documents. 36 �WOLVERINE DOCUMENT (NOT Produced in 104e Response): Rose and Westra Report September 19, 2011. “In addition, during demolition, continuous observations were performed to identify areas of contamination based on visual observations, the presence of or lack of odors, stained soils, deteriorated floors, and knowledge. …. These observations resulted in the identification of the two areas from which soil was removed.” page 3. “The soils in these areas was excavated and transported to an off-site licensed landfill. The excavation in the maintenance area was approximately 50 feet square and 6 to 7 feet deep. The soil from the former primary clarifier area that was removed constituted approximately 10 cubic yards. Page 2. Appendix 17 (Citizen obtained through EPA FOIA) CCRR DOCUMENT: Public Meeting: DVD AUDIO OF MEETING: At the September 21, 2011 WWW Public meeting, Ken Grady said that they characterized the soil based on sight and smell. Listen to DVD Audio. DOCUMENT U.S. EPA Definition of Characterization: (from U.S. EPA List of Terminology) • • Characterization: The identification of chemical and microbiological constituents of a waste material. Hazard Identification: Determining if a chemical or microbe can cause adverse health effects in humans and what those effects might be. THE SECTION ABOVE IS CITIZEN PROVIDED AND COULD NOT BE FOUND ON WWW’S CD, UNLESS NOTED Wolverine’s Response, Part II, Number 6 (continued) “In additional, during tannery demolition Wolverine’s site investigation in the vicinity of a former boiler also identified a former UST area with minor soil contamination several feet deep with no relevant exposure pathway.” THE SECTION BELOW IS CITIZEN PROVIDED AND COULD NOT BE FOUND ON WWW’S CD, UNLESS NOTED Author Comment 4 In the R&W Report, Wolverine states that they determined 2 areas of soil contamination and the soils were excavated. Wolverine stated there were 2 areas of soil contamination in their 104e Part I Response as well. However, in the 104e Part II response, #6, second to the last sentence they add a sentence about identifying a former UST area with minor soil contamination several feet deep with no relevant exposure pathway. Why is this the first time Wolverine is mentioning that they found a third site of soil contamination during the demolition? Also, this is one of the sites identified in the 2012 CERCLA PA 37 �Report. However, the 2012 CERCLA PA Report doesn’t draw the same conclusion that there are no relevant exposure pathways. Wolverine says it is in a former UST area while the 2012 CERCLA PA Report states it is around an abandoned UST. Since Wolverine never documented waste contaminant concentrations nor did confirmation samples, it would be impossible to confirm if all contamination was excavated. Confirmation sampling should have been performed and a report written. Does such a report exist? There is only one manifest found for 10 cubic yards going to Ottawa Farms landfill which the author assumes is the 10 cubic yards of contaminated soil at the primary clarifier/wastewater treatment plant area. Was the waste properly characterized for disposal? Is the Ottawa Farms Landfill the appropriate type of landfill for the waste that was disposed of from the excavation? Where are the documents to verify where the other contaminated soils went to? Was there a due care obligation to inform anyone in the DEQ about these soils at the time of discovery? If yes, did they notify DEQ? Wouldn’t a Clean Closure have been required if Wolverine had notified the appropriate authorities? 250 cubic yards of contaminated soil removed frory_ N. half of PIT in _, December 2010. _. ~ , 'Soils in S, Half of Pit , have not been removed, or characterized . .. 10 tubics yardp/ contaminated soil.was removed near tank in Noveml.er .iofo. ., ~ \ APRIL2011 DOCUMENT: 2012 CERCLA Preliminary Assessment Report for Wolverine World Wide Former Tannery, June 14, 2012. Appendix 28 “There are four known source areas on the Site. These include a former abandoned underground storage tank (UST), the “pit” area, soils in the former wastewater treatment area and soils on the western portion of the Site along the river.” page 9. 38 �CITIZEN FOIA OBTAINED DOCUMENT: MDEQ letter to the EPA, dated June 14, 2012, states the following: “The company has demolished most of the plant buildings and has reported that they have removed some wastes from the Site. The waste contaminant concentrations however were never documented and confirmation samples were never collected after the removal of the wastes.- There are four known source areas that are relatively small, but the full extent of these areas has not been determined. (Daria W. Devantier, DEQ, Chief, Site Assessment and Site Management Unit, Superfund Section, Remediation Division). Appendix 29 (Citizen obtained through DEQ FOIA) Author Comment 5 The authors of the Wolverine 104e report, begin by talking about two known source areas and then over time refer to three known source areas. However, in the 2012 CERCLA PA, DEQ refers to a known source area that is located on the western side of the site along the river. DEQ states that the four areas are relatively small but Wolverine never determined the full extent of these areas. THE SECTION ABOVE IS CITIZEN PROVIDED AND COULD NOT BE FOUND ON WWW’S CD, UNLESS NOTED F. EPA REQUEST # 7: Identify the locations of drum storage EPA REQUEST # 7: Identify the locations of any drum storage areas at the site, and wastes that were stored in such areas. Wolverine’s Response: #7, Part I, page 3. “Wolverine objects to this request as unduly burdensome and unreasonable to the extent that it asks Wolverine to respond to matters beyond its knowledge or to produce documents or information not within its possession, custody and control. Subject to its general objections, Wolverine produces in response to this request the documents in folder numbers 7 and 3-4 on the enclosed compact disc. By way of further answer, to Wolverine’s knowledge the drum storage area at the site was used to store raw materials, not wastes. Waste was discharges to the wastewater treatment plant. Pressed Sludge cakes from the wastewater treatment plant were disposed of at an approved offsite landfill.” THE SECTION BELOW IS CITIZEN PROVIDED AND COULD NOT BE FOUND ON WWW’S CD, UNLESS NOTED Author Comment No date was found on the map diagrams in folder 7 on Wolverine’s CD. These map diagrams were similar to those found in the 1990s and 2000s PIPPs and Storm Water Pollution Prevention Plans (SWPPS). However, Wolverine did not submit any map diagrams of storage areas prior to the 198839 �1989 plant expansion. In the 1994 ESA quoted on page 5 in this document state “Spill Potential: 1983 – an inspection report shows that wastes were being stored in a building with no roof that was attached to the shoe plant. This historical document seems to contradict the authors of Wolverine’s 104e responses that all waste went to wastewater treatment plant, and should have provided clear indication to Wolverine that earlier maps and related information should have been consulted. At the very least, this was sufficient information to render Wolverine’s 104e response to EPA inaccurate. THE SECTION ABOVE IS CITIZEN PROVIDED AND COULD NOT BE FOUND ON WWW’S CD, UNLESS NOTED G. EPA Request 8: Identify the protocols that were followed EPA Request 8: Identify the protocols that were followed during the tannery’s demolition to characterize soils, demolition materials and any wastes discovered on site during the demolition, and identify the locations to which soils, demolitions and waste materials were sent. Wolverine’s Response: #8, Part I, page 3 & 4.) “Wolverine objects to this request as unduly burdensome and unreasonable to the extent that it asks Wolverine to respond to matters beyond its knowledge or to produce documents or information not within its possession, custody and control. Subject to its general objections, Wolverine produces in response to this Request the documents in folder number 3 on the enclosed compact disc. By way of further answer, Wolverine disturbed soils as little as possible during demolition. During demolition, in the event that Wolverine noticed a soil condition that appeared out of the ordinary, Wolverine characterized the soil based on available data. This occurred in two locations. One location was the space under the tannery maintenance area where waste line to the wastewater treatment plant had broken. The broken line was identified as the source of contamination. Accordingly, the soil was characterized as the same waste that had historically been treated at the wastewater treatment plant. It was disposed of as such by Valley City Environmental. The other location was directly under the primary clarifier tank at the wastewater treatment plant. In that location, there was a small amount of discolored soil that had the appearance and odor of tannery waste. This was characterized as tannery waste that may have leaked through a crack in the base of the clarifier. It was disposed of accordingly by Valley City Environmental. An asbestos survey was performed in advance of demolition. Asbestos removal took place prior to demolition, as well as during demolition when asbestos was identified. All chemicals and process piping were removed and/or cleaned prior to demolition by Valley City Environmental. Valley City Environmental washed, rinsed, and wiped tested containers, walls, floors, and other surfaces that came into contact with chemicals during the tanning process. Wolverine sent demolition waste materials to the following locations: • Richmond Transfer Station, 675 Richmond, Grand Rapids, MI (Salvage material, demo debris and ferrous and non-ferrous recyclables) 40 �• • • • • • • Pitsch Landfill, 7905 Johnson road, Grand Rapids, MI (Non-hazardous demolition debris) Pitsch, 200 North Park, Grand Rapids, MI (Concrete) Padnos (Turner Facility), 2125 Turner, Grand Rapids, MI (Steel) Lanco, 665 10 Mile, Sparta, MI (Electrical Equipment) Woodland Paving, 3566 Mill Creek, Comstock Park, MI (Asphalt) Superior Asphalt, Century, Grand Rapids, MI (Asphalt) Valley City (PCB containing light ballasts) THE SECTION BELOW IS CITIZEN PROVIDED AND COULD NOT BE FOUND ON WWW’S CD, UNLESS NOTED CITIZEN FOIA OBTAINED DOCUMENT: Pitsch Work Plan, Demolition and Site Plan Restoration, Wolverine World Wide, Rockford, Michigan, dated 2010. Appendix 24 (Citizen obtained through City of Rockford FOIA) 1.3 Hazard Recognition, last sentence: “No soils will be transported off site and excavation work is to be kept to a minimum.” Wolverine World Wide Response Part I, page 3. “By way of further answer, Wolverine disturbed soils as little as possible during demolition.” Author Comment 1 Site Disturbance Protocols 1. Wolverine opened up and significantly disturbed soils over the entire portion of the site that encompassed both the buildings, pavement and the river bed and bank at the site of the pump house. This allowed the exposed soil for the entire site to be vulnerable to runoff into the Rogue River during rain events. 41 �Rockford Tannery Demolition Soils excavated at levels far deeper than 18 inches. Soils greatly disturbed below foundation of bu ildings. 42 �2. Truckloads of soil mixed with broken concrete left the site. -'UGUST 26, 2011 MOR£ SOIL REMOVED 43 �CITIZEN OBTAINED DOCUMENT: Michigan Department of Natural Resources and Environment (DNRE) Flood Plain Permit dated June 10, 2011: “Permitted Activity: Place 110 cubic years of fill and cut 1879 cubic yards, all within the 100-year floodplain of the Rogue River for the demolition and removal of several commercial buildings. All work must be completed in accordance with the attached plans.” Author Comment 2 During the demolition Wolverine decided they wanted to remove the pipes that were in the bank and in streambed that came from the pump house. They installed a largely ineffective silt curtain. Then they brought in a backhoe and dug out the pipes in the bank and stream bed. A large and potentially contaminated silt plume occurred and extended far beyond the silt curtain. The disturbed and potentially contaminated silt and soil continued to be released into the Rogue River for a couple days. This activity was not part of the permit and the work was below the ordinary high-water mark. Since Wolverine did not indicated they were going to excavate below the ordinary high-water mark on their flood plain permit application, a Part 301 Inland Lakes and Streams Act review was not done. Wolverine did not call DNRE (DEQ), prior to excavating the pipes out, to receive a verbal okay to do the work. A citizen called in a complaint while they were doing the work. DNRE (DEQ) was not able to respond until after the activity was done. DNRE (DEQ) had Wolverine later amended the permit to include stream bank restoration. Another example of doing work and the DNRE (DEQ) getting involved after the work is done. Also, some unmeasured levels contaminants were likely released in the resulting silt plume. (11/ 2017: PFAS (PFCs) tied to all that soil was probably released into the river.) 44 �45 �CHARACTERIZATION PROTOCOLS WOLVERINE DOCUMENT (NOT Produced in 104e Response): According to the Rose and Westra Report September 19¸2011 (Post Demolition Environmental Investigation), Wolverine determines in 2 areas soil should be removed as part of the demolition. Appendix 17 (Citizen obtained through EPA FOIA) Page 2: During demolition, Rockford Construction and WWW Representatives discovered two areas where WWW determined that soil should be removed as part of the demolition. The first area was located under the former maintenance area near the northwestern corner of the former tannery building. The second area was under the bottom of the former primary clarifier and sludge holding tank in the wastewater treatment plant. The soils in these areas was excavated and transported to an off-site licensed landfill. The excavation in the maintenance area was approximately 50 feet square and 6 to 7 feet deep. The soil from the former primary clarifier area that was removed constituted approximately 10 cubic yards.” Page 3 “In addition, during demolition, continuous observations were performed to identify areas of contamination based on visual observations, the presence of or lack of odors, stained soils, deteriorated floors, and knowledge. …. These observations resulted in the identification of the two areas from which soil was removed.” Author Comment 3 Wolverine’s 104 (e) Response to the U.S. EPA on April 12, 2012 admitted that they removed soil from this “area” because it was visually contaminated and smelled like tannery sludge/waste. Rose & Westra September 19, 2011 Report stated they found an area underneath the former maintenance area contaminated. (The area underneath the former maintenance area was later called the pit area.) However, Wolverine told a DEQ official in February 2011 that crews did not find any soil contamination as part of the work in the pit area. This was a result of a December 16, 2010 phone call and follow up email of a concerned citizen to David Monet (see below) regarding the soil removal creating what looked like a crater from what you could see from the neighborhood. This crater area would later be called the “Pit” area. 46 �,,,. . 4.., DECEMBER82019 Work actfolfly near Pit area of the Site. • 47 �THE PIT AREA, FENaD IN AFTER DEMOUTION. CAMERA FACES SOUTH TOWARD DOWNTOWN, FURTHER SOUTH: DARK, DISTURBED SONS t1IA1' WERE 'NOTED' DURING IIUQl' ll!MOVEO. 48 �CITIZEN EMAIL DOCUMENT: E-mail Response from David Monet, DEQ to concern citizen, February 22, 2011. “I have to apologize for not getting back to you sooner. I was finally able to talk with Wolverine World Wide last week, in essence, inquiring about the deep “crater” excavation referenced in your 12/16 e-mail. Per WWW, the crews were removing the subgrade concrete from a basement installed in the working area. They indicated that they did not find any soil contamination as part of that work. If they did/do discover contamination, per section 20114 of PART 201 of P.A. 4451, they have an affirmative obligation to diligently pursue necessary response activities.” Appendix 28 Did Wolverine fulfill their affirmative obligation to diligently pursue necessary response activities? It appears as though Wolverine representatives misrepresented or made false statements to DEQ regarding contamination of the pit area. (Contrary to requirements set forth in Part 201,324.20139) See e-mail exchanges between concerned neighbor and DEQ regarding the crater in the pit area. Appendix 30 CITIZEN FOIA OBTAINED DOCUMENT: E-mail exchange between Michael Robison, Wolverine’s Attorney and Partap Lall, EPA, dated November 17, 2011. Subject was EPA instructions on where Wolverine should sample in the pit area in the context of the Preliminary Assessment. “In the 7th bullet reference to PIT area—it is for soils around where the PIT was. We do not want you to sample the clean fill material that was placed in the area, but surrounding soils in order to understand if the removal was complete or if there has been migration outside the PIT.” Appendix 31 (Citizen obtained through EPA FOIA) The aerial map of the pit and WWTP and Figure 3 Soil Sample Locations in the CERCLA PA Report shows that soil removed and refilled was approximately half of the pit area and the sample appears to have been taken within the fill area. Appendix 28 49 �WOLVERINE DOCUMENT (NOT Produced in 104e Response): According to the Rose and Westra Report September 19¸2011 (Post Demolition Environmental Investigation), reports to have characterized materials based on available data. Page 3 “In addition, during demolition, continuous observations were performed to identify areas of contamination based on visual observations, the presence of or lack of odors, stained soils, deteriorated floors, and knowledge. …. These observations resulted in the identification of the two areas from which soil was removed.” Appendix 17 (Citizen obtained through EPA FOIA) WOLVERINE DOCUMENT: WWW’s 104 (e) response to the U.S. EPA on April 12, 2012 admits that “Wolverine characterized the soil based on available data”. CCRR RECORDING - PUBLIC MEETING: DVD AUDIO At the September 21, 2011 Wolverine Public meeting, Ken Grady said that characterized the soil based on sight and smell. CITIZEN DOCUMENT: Ken Grady of Wolverine includes the following statement in a letter written to a Rockford citizen who had raised concerns regarding waste characterization. (September 21, 2010). "While there are no known hazardous chemicals located on the premises, the Work Plan specifies that if Pitsch encounters any hazardous materials, work will be stopped immediately, notification will be made, and the proper procedures will be followed to analyze, test and handle the materials in accordance with all applicable environmental laws. Appendix 32 (Citizen obtained document) CITIZEN FOIA OBTAINED DOCUMENT E-MAIL Dated August 11, 2010: Chris Kestner (MTC) to Michael Young, Rockford City Manager: “What will happen if stained (contaminated) soil is encountered? 50 �Will it be reported or documented? Will the City of Rockford see this documentation?” Appendix 33 (Citizen obtained through City of Rockford FOIA) DOCUMENT: U.S. EPA Definition of Characterization: (from U.S. EPA List of Terminology) Characterization: The identification of chemical and microbiological constituents of a waste material. Hazard Identification: Determining if a chemical or microbe can cause adverse health effects in humans and what those effects might be. Author Comment 4 What available data did Wolverine base their characterization on? Where are the Pitsch Pre-demolition Survey and the Pre-demolition Asbestos Survey that were required as part of the Pitsch signed Work Plan? Wolverine’s definition of characterization appears to be based exclusively on “knowledge,” sight and smell, which does not seem to be consistent with the EPA definition of characterization. How do you determine the boundaries of contamination based on sight and smell? How do you know what chemicals you are dealing with, the concentrations, whether they are hazardous or not? How does this follow through with Ken Grady’s statement to a local citizen that proper procedures will be followed to analyze, test and handle materials in accordance with applicable environmental laws? DEQ or WWW should produce the asbestos and excavation reports and data from sampling to demonstrate compliance with all applicable laws. If such a document does not exists what are the liabilities for WWW for improper disposal and reporting? What are the liabilities for DEQ having not required such documentation? CCRR DOCUMENT: Letter from Michael Young, Rockford City Manager, to a concerned citizen, dated August 25, 2010. Appendix 34 #2 “My understanding is that no soil will be taken out with other materials that are being disposed of.” 51 �Author Comment 5 During demolition crushed building material and soil were combined and loaded on trucks to be disposed. #8 “Mr. Gutting, a professional engineer, will be responsible for hazardous chemical recognition.” (Mr. Gutting works for Pitsch Demolition) Author Comment 6 Does this include contaminated soil recognition? It appears unlikely that Mr. Gutting was on site to personally observe when contaminated soils were detected in the Pit area and the area beneath the final clarifier tank of the WWTP. It is similarly unlikely that he had historical knowledge such as the 1990 MSDSs as well as current MSDSs. Was he given only the latest chemical and storage information? Was he contacted by phone, if he was not on site? Did he determine that the soils were non-hazardous and if yes, how? Who, with an environmental background and appropriate expertise, determined that the soils in the former UTS area should not be removed? In the same letter Mr. Young stated that Pitsch is trained in hazardous recognition and that Pitsch would notify Wolverine who in turn would notify City of Rockford if hazardous chemicals were discovered. Does this include contaminated soils? Was the City of Rockford notified of the contaminated soils and when? Was Wolverine’s current Environmental and Safety Manager, on site for any of the determinations of possible contamination, especially since Wolverine was the generator of the waste? No notification by Pitsch was found in the City of Rockford’s FOIA requests. WOLVERINE DOCUMENT (NOT Produced in the 104e Response): Rose and Westra Report. (September 19, 2011). Report states that soils were characterized in two locations; the tannery maintenance area (“Pit” is located underneath it”) and directly under the primary clarifier in the WWTP. Appendix 17 (Citizen obtained through EPA FOIA) CITIZEN FOIA OBTAINED DOCUMENT: Michael Robinson states in 12/01/2011, in an e-mail to Nuria Muniz, U.S. EPA that: “250 cubic yards of material was removed from the Pit Area and 10 cubic 52 �yards of dark stained soil was removed from the former final clarifier. This contamination waste was disposed of by Valley City Environmental.” (Citizen obtained through EPA FOIA) Author Comment 7 • Where is the manifest for the 250 yards of material removed from the pit area showing it went to Ottawa Farms Landfill? • Were any of Wolverine’s 1990 list of hazardous ingredients detected in the 2012 CERCLA PA and/or the XRF screening? See the answer to this in author comment 8 and tables 1-4. Author Comment 8 • The following chemical compounds were found both in the Wolverine 1990 MSDS and the 2012 CERCLA PA samples (Table 1-4): Acetone, Ammonia, Barium, Bis(2Ethylhexyl)phthalate, Calcium, Chromium, Hexavalent Chromium, Copper, Ethyl benzene, Lead, Magnesium, Mercury, Naphthalene, Phenol, Potassium, Sulfur, Toluene, Xylene. This means that these identified chemicals used at the Tannery and were also detected in at least one type if not more of the environmental media tested: the deep soil samples, surficial soils samples, groundwater samples, and sediment samples. Some exceed criteria limits. See Tables 1-4. • The following chemical compounds found in the WWW 1990 MSDS and the XRF screening: Barium, Calcium, Chromium, Cobalt, Copper, Iron, Lead, Magnesium, Manganese, Mercury, Potassium, Sulfur, and Zirconium. Some of these chemicals were found to exceed criteria. See the following Table (5). In addition, Bis (2-ethylhexyl) Phthalate, Chromium, Copper, Lead, Naphthalene, Phenols, Toluene and Zinc were found in the WWW Application Surveys (1995, 1997, 1999, and 2001) for Waste Discharge Permits for the City of Grand Rapids and in Tables 14 of the Preliminary Assessment. • Chromium, Copper, Lead and Zinc were also found both the WWW Application Surveys (WWWAS) and the XRF Screening Samples. See Table 6: Summary of Priority Pollutants in WWW Application Surveys. See Table 7: Summary of Chemicals in WWWAS, PA, XRF Screenings. • Given that knowledge was one of the criteria Wolverine used to determine contamination and given the types of chemicals use at the tannery, characterizing the soil by sight and smell is not appropriate or adequate for a clean closure. To fail to properly characterize the extent of contamination that needed be excavated would be a violation of Due Care obligations under the law. Were soils left in place above direct contact? Would these soils leach to groundwater or erode into surface water above applicable standards? Was the characterization of the wastes sufficient to identify the proper disposal facility? Was unknown liability incurred by those who transported and disposed of the wastes? Were new sites of uncontrolled hazardous chemical contamination under either RCRA or Part 201 created by inappropriate disposal of tannery soils and demolition materials? 53 �Table 1. Deep Soil Sample Data and 1990 Wolverine MSDS Overlap Analyte/Compound Preliminary Assessment # of detects # of Samples Exceeding Criteria MSDS Sheet 0 0 yes yes WWW collected samples Ethylbenzene yes Toluene yes 1 1 Xylenes yes 1 0 yes Naphthalene yes 1 0 yes Phenol yes 1 0 yes yes yes 12 12 12 0 yes yes yes yes 11 8 1 8 Yes yes yes 7 7 yes Acetone yes 3 0 yes Toluene Xylenes yes yes 7 3 0 0 yes yes Bis(2-ethylhexyl)phthalate Naphthalene Inorganics Yes yes 4 8 0 0 yes yes Chromium (Total) Yes 11 11 yes Copper Yes 11 0 yes Lead yes yes yes 11 11 11 0 7 11 yes yes yes SVOA Inorganics Chromium (Total) Cooper Lead Mercury(total) Ammonia EPA Split samples VOA SVOA Mercury(total) Ammonia 54 �Table 2. Surficial Soil Sample Data and 1990 Wolverine MSDS Overlap Preliminary Assessment # of detects # of Samples Exceeding Criteria MSDS Sheet Chromium (Total) yes 4 4 yes Copper yes 4 0 yes Lead yes 4 0 yes Mercury(total) yes 3 3 yes Toluene yes 3 0 yes Xylenes yes 1 0 yes SVOA yes 1 0 yes Bis(2ethylhexyl)phthalate yes 2 0 yes Naphthalene yes 4 0 yes Chromium (Total) yes 4 4 yes Copper yes 4 0 yes Lead yes 4 0 Yes Mercury(total) yes 4 3 yes Ammonia yes 4 4 yes Analyte/Compound WWW collected samples Inorganics EPA Split Samples VOA Inorganics 55 �Table 3. Groundwater Sample Data and 1990 Wolverine MSDS Overlap Preliminar y # of # of Samples Analyte/Compound Assessmen detects Exceeding Criteria t MSDS Sheet WWW collected samples SVOA yes 1 0 yes Chromium (Total) yes 2 2 yes Copper yes 2 0 yes Iron yes 3 3 yes Ammonia yes 9 9 yes Phenol Inorganics Table 4. Rogue River Impoundment Sediment and 1990 Wolverine MSDS Sheets Preliminary Assessment # of detects # of Samples Exceeding Criteria MSDS Sheet Chromium (Total) yes 12 10 yes Copper yes Lead yes Mercury yes 12 12 9 4 7 6 yes yes yes Chromium (Total) yes 12 7 yes Copper yes 12 3 yes Lead yes 12 5 yes Mercury (Total) yes 12 7 yes Chromium (Total) yes 10 3 yes Copper yes 10 0 yes Lead yes yes 10 6 0 6 yes yes Analyte/Compound WWW collected samples Inorganics EPA Split Samples DEQ Collected Samples Mercury 56 �Table 5 XRF Summary of Metals showing Detected and Exceedances Soil # of Soil # of Exceedance Exceedance DCC GSIP Surficial # of detects Surficial # of exceedance DCC 4 4 Surficial # of exceedance GSIP Analyte/Compound Soil # of detects Arsenic 8 Cobalt 3 3 5 5 Copper 26 6 26 1 Zinc 21 5 27 2 Lead 21 1 27 Chromium 26 1 27 8 3 Barium Selenium 1 1 Strontium 26 27 Zirconium 26 27 Rubidium 26 27 Mercury 26 27 Iron 26 27 Calcium 26 27 Potassium 26 27 Manganese 22 24 Scandium 20 22 Vanadium 6 10 Molybdenum 3 8 Thorium 4 1 Uranium 2 2 Sulfur 2 1 Silver 1 1 57 1 1 �Table 6 Chemical Compounds Found in WWW Application Surveys (1995, 1997, 1999, 2001) for Wastewater Discharge Permits Priority Pollutants Information Chemical Compound WWW GR Application Surveys 1995 1997 1999 2001 Bis(2-ethyhexyl) Phthalate present present present present Chromium present present present present Copper present present present present Mercury present present present present Lead Present present present present Naphthalene present present present present Phenols present present present present Toluene present present present present Zinc Present present present present Chloro benzene Present Present Dichloromethane Present Present Present Trichloromethane Present Present Present Trichlorofluoromethane Present Present No longer on survey form No longer on survey form Di-n-butyl Phthalate Present Present Present Present Di-n-octyl Phthalate Present Present Present Present p-chloro-m-cresol Present Acrylonitrile Present 58 �Table 7 Chemical Compounds Found in the Wolverine World Wide Application Surveys (1995, 1997, 1999, 2001) for Wastewater Discharge Permits, the 2012 CERCLA Preliminary Assessment and/or XRF Screening Chemical Compound WWW GR Application Surveys Preliminary Assessment Tables 1-4 Bis(2-ethyhexyl) Phthalate yes Chromium yes yes Copper yes yes Lead yes yes Mercury yes yes Naphthalene yes Phenols yes Toluene Yes Zinc yes 59 XRF Screening yes �Author Comment 9 Was there a due care obligation to inform anyone in the DEQ prior to the removal of these soils? Wouldn’t a Clean Closure have been required if Wolverine had notified the appropriate authorities. As it is, a letter from the MDEQ to the EPA dated June 14, 2012 states the following: “The company has demolished most of the plant buildings and has reported that they have removed some wastes from the Site. The waste contaminant concentrations however were never documented and confirmation samples were never collected after the removal of the wastes. There are four known source areas that are relatively small, but the full extent of these areas has not been determined.” (Daria W. Devantier, DEQ Chief, Site Assessment and Site Management Unit, Superfund Section, Remediation Division). Appendix 29 (DEQ FOIA) Author Comment 10 Wolverine claims that there were two locations from which contaminated soils were removed during demolition of the Tannery site: The “Pit” and soils beneath the final clarifier. Were there more than 2 areas where contaminated soils were removed? It appears that some removal activity may have occurred in the Hide House area on the site, December 8, 2010. rO(ltHllkltl p!WS Was impacted soil or liquid waste being removed? 60 �Author Comment 11 The 2012 CERCLA PA report documents contaminated soils located south of the Pit. Was Mr. Gutting or Wolverine’s Environmental and Safety Manager contacted or informed of this area? Author Comment 12 Various site ponds and large puddles were observed and photo documented in the WWTP area of the tannery site. The water in some of these ponds and puddles appeared to be discolored, some had sheens and others foamy. The previous tannery employees dubbed this area the #1 Hot Spot for chemical contamination. This is the same area where monitoring wells have been installed as well as where the 2012 CERCLA PA report substantiates contamination. Were these site ponds and puddles tested? How, when and where was this liquid in these site ponds and large puddles disposed of? It appears that the authors of the 104e response never interviewed site workers or the site environmental manager in order to prepare their responses. Site pond removed 61 �SITE PONDS REMOVED WOLVERINE DOCUMENT (NOT Produced in 104e Response): Rose and Westra, INC. Report, September 19, 2011 Appendix 17 (Citizen obtained through EPA FOIA) • Page 1: “Prior to the demolition, Wolverine retained Valley City Environmental (Valley City; Grand Rapids, Michigan) to clean the process portions of the tannery buildings. Simultaneously, Wolverine retained R&W to operate the Wastewater pre-treatment plant to treat and dispose of water generated during the cleaning process. Valley City characterized and removed remaining process chemicals and waste for off-site disposal. • These materials included waste in the former chromium and sulfide tanks which were located above ground and inside the tannery building. After removing these materials, Valley City power-washed the walls and floors in the process areas of the former tannery building. The resulting water was treated at the on-site wastewater plant and discharged to the City of Rockford sewer system in accordance with the pre-treatment permit.” THE SECTION ABOVE IS CITIZEN PROVIDED AND COULD NOT BE FOUND ON WWW’S CD, UNLESS NOTED 62 �Wolverine’s Response, Part 1, #8, page 4: Valley City Environmental washed, rinsed, and wiped tested containers, walls, floors, and other surfaces that came into contact with chemicals during the tanning process. THE SECTION BELOW IS CITIZEN PROVIDED AND COULD NOT BE FOUND ON WWW’S CD, UNLESS NOTED Author Comment 1 • Wipe sampling is only addressed in SW-846 in the context of laboratory safety concerns relative to dioxins and furans. EPA does not recommend that the procedure there be extended to other analytes or other situations, such as porous concrete saturated by liquid waste over a period of decades. Wolverine and Valley City Environmental Services appear to have used a test method not appropriate for a tannery demolition and the results are probably useless for the characterization of hazard risk and proper disposal of soils and demolition debris disposal. Disposal sites should be investigated as secondary source of contamination. See EPA document below. DOCUMENT: EPA website (www.epa.gov/osw/hazrd/testmenthods/faq/faqs_sample.htm) • • “Question: Where can I find wipe sampling methods in SW-846? Answer: Wipe sampling is only addressed in SW-846 in the context of laboratory safety concerns relative to dioxins and furans, and a very limited discussion of wipe sampling techniques appears in Appendix A to Method 8290A. However, EPA does not recommend that the procedure there be extended to other analytes or other situations.” “While wipe sampling has been described in the open literature, one of the biggest problems is that it is very difficult to interpret the results. By its very nature, the analysis of whatever material is used to wipe a surface (often filter paper wet with a solvent) yields the mass of the analyte(s), for example nomograms of dioxin or micrograms of another analyte. However, there is no straightforward way in which to convert that mass into a concentration per unit area, nor any effective way in which to compare results from different wipes, except to say that one wipe picked up more material than another. If the surfaces that are wiped have different characteristics, for example a smooth metal surface versus a rough concrete block, there is no way to judge the efficiency of the wiping process itself. Therefore, use caution in interpreting the results of wipe samples.” Appendix 35 Author Comment 2 • There were 360 hazardous ingredients identified in the Wolverine 1990 MSDS (Wolverine CD), Folder 2 000000451513, sub-folder 2, 01 PDF, FTC&H Pollution Prevention Plan, 19871994(update). Included in that list were the following F005 chemicals: 2-ethoxyethanol, Isobutanol, Methyl Ethyl Ketone (MEK), Toluene, and Methylisobutylketone (MIBK). Also 63 �included on the list were the following D001 chemicals: Napatha (Naptha solvent, Naptha Petroleum Lt. Arom), Petroleum Solvents, Petroleum Distillate, Isopropanol, and Kerosene. See Appendix 20 (EPA FOIA) • Wolverine CD also contained Uniform Hazardous Waste Manifests (CD folder 2000000451513, Subfolder 3, PDF, Document 1. The following F005 materials were listed: Toluene hexane, and MEK rags. The following D001 materials were listed: Xylene; Toluene (solvent mixture); Ethyl 3-ethoxy propionate (EEP Solvent); Isopropyl alcohol (tricholor/Scotchgard); Waste Aerosols; Isocynate Hardener; Hexane, Acetonetrile; Waste Adhesives; Hexane Aceton*; Waste Paint. See Appendix 27 • D001 and especially F005 chemicals quickly absorb into any material it touches such a concrete ( D001 and F005 chemicals found in Wolverine’s CD) • Wolverine previous employee, Interviewee #2 stated that historically the concrete used back when the tannery was build had a low R Factor- more porous and not water tight. • Citizens in August 2010 spoke with Ann Couture and Tanya Cabala regarding their involvement in the Whitehall Leather Co. demolition and their recommendations. Ms. Couture, as the City of Whitehall’s environmental consultant, stated that the building materials at the Whitehall Leathers Tannery were impacted. The concrete was really contaminated. There was a lot of toxic build-up in the materials. Similar impacts might be expected at the Wolverine site, but were ignored. • Given that the Wolverine Rockford site was a tannery that historically used 360 identified hazardous ingredients in its manufacturing process that included FOO5 and D001 chemicals, doing a wipe test as your characterization method appears to be totally inappropriate and inadequate. Should Wolverine have done a Toxicity Characteristic Leaching Procedure, Test Method 1311 in “Test methods for Evaluating Solid Waste, Physical/Chemical Methods,” EPA Publication SW-846; Appendix 36 DOCUMENT: Michigan Solid Waste Management Rules (R 299.401 to R 299.4922) • Inert material includes excavated soils, except if the materials are contaminated by hazardous substances in concentrations sufficient to cause environmental contamination. R 299.4114(2)(c) and R 299.4113 (3) • Construction brick, masonry, pavement, and broken concrete used for fill, riprap, slope stabilization, or other construction are considered inert materials if they are not otherwise in violation of Parts 301 of NREPA, MCL 324.30101 et seq. or Part 303 of NREPA, MCL324.30301 et seq., and are also not contaminated by hazardous substances in concentrations sufficient to cause environmental contamination. R 299.4114 (2)(d) and 299.4114(3) 64 �• A site that accepts more than 1000 cubic yards of construction brick, masonry, pavement or broken concrete must notify the director of DEQ on a form provided by DEQ. R 299.4114 (2) (d) (iii). CITIZEN FOIA OBTAINED DOCUMENT: Wolverine World Wide Tannery Complex; Demolition Permit Conditions; City of Rockford Permit NO. 2010-1, Page 2, #6:”Demolition of the WWTP and associated infrastructure and the existing retail store will not begin until an environmental survey of the facilities is completed which will be provided to the City and covered under a separate demolition permit.” Appendix 37 (Citizen obtained through City of Rockford FOIA) Author Comment 3 Despite repeated requests, citizens have not been able to verify if an environmental survey of the WWTP and associated infrastructure was done. Citizens were also unable to verify if the environmental survey was meant to be a Hazardous Material Survey. If a Hazardous Materials Survey had been done, would it have helped determine and document whether the construction brick, masonry, pavement, and broken concrete was inert or possibly hazardous. This was done at the Whitehall Leathers Tannery demolition, which did confirm that the concrete was heavily impacted (Ann Couture, City of Whitehall environmental consultant). Note: Pitsch was the main contractor in charge of the demolition and also owners of the facilities that Wolverine listed as taking the supposedly nonhazardous demolition debris and concrete. In Wolverine’s 104e response, page 4, states that Valley City Environmental washed, rinsed, wipe tested containers, walls, floors, and other surfaces that came into contact with chemicals during the tanning process. Rose and Westra’s Post Demolition Environmental Investigation Report on page 1 states the Valley City did this prior to demolition. The report also refers to the “former chromium and sulfide reclamation tanks which were located above ground and inside the tannery.” The Report suggests that Valley City removed these materials, but no clarification is given as to whether the concrete tanks had been tested, power- washed or how its content was properly characterized. One previous tannery employee said the following: “When Wolverine was upgrading parts of the tannery (1988/1989), they decided to not empty two storage tanks, one held pure chromium and the other one, sulfides, due to engineering difficulties. Instead, the tanks were not emptied and built into the actual structure of the upgraded tannery.” How could Valley City have cleaned the tanks before they were made accessible via the demolition? In another tannery worker interview, the person said that the aeration tank overflowed all the time leaving “white foam all over the place.” There is no mention of the WWTP concrete being tested. The EPA 2012 CERCLA PA report substantiates soil contamination in this area. 65 �Soils, demolition and waste materials disposal locations protocols In the Pitsch Demolition Plan, page 8, 3.3 includes a section on staging of impacted concrete. In the August 28, 2010 staff report, Reed Sneller, DEQ, tells Jim Blue, Wolverine’s Environmental and Safety Manager, that contaminated concrete needs to go to a licensed solid waste landfill and not to concrete recycling/crushing operation. Yet, incredibly, none of the stained concrete was observed being tested or separated from the recycle waste stream. Appendix 24: Pitsch Demolition Plan; Appendix 38: Reed Sneller’s August 28, 2010 staff report. (Citizen obtained through DEQ FOIA) • STAINED CONCRETE PHOTO REMOVED In an August 25, 2010 letter from Michael Young, Rockford City Manager, to a member of Concerned Citizens for Responsible Redevelopment(CCRR) states in pt. 2 that his understanding that no soils will be 66 �taken out with other materials that are being disposed of. Yet concerned citizens observed and photo documented that soils and crushed concrete were being dumped together into trucks to be hauled away. Appendix 39. The waste haulers and disposal facilities listed on the Pitsch demolition work plan are somewhat different than those listed in Wolverine’s 104e Response. These are locations listed in the Pitsch demolition Work Plan. Appendix 24 (Citizen obtained through City of Rockford FOIA) 1. Belding Sanitary Landfill, Belding, Michigan - Demolition debris 2. Valley City, Grand Rapids, MI – Non-hazardous PCB, Hazardous Liquid Disposal, and Mercury switches 3. Liquid Industrial Waste Services. - Zeeland, MI – Non- Hazardous Liquids 4. Northern A-! Disposal, Muskegon, MI – Hazardous Liquid Disposal 5. Padnos Iron and Steel, Grand Rapids, MI – Scrap Metal 67 �No mention is made in the Demolition Work Plan of concrete going the following sites listed in the 104e Wolverine response: Pitsch, 200 North Park or of asphalt going to Superior Asphalt, Century, Grand Rapids, or LANC0, 665 10 Mile in Sparta, Michigan. Also, Pitsch Landfill, 7905 Johnson Road, is located in Belding, MI, not in Grand Rapids, Michigan as stated in the 104-E. This is likely a typo. MOST IMPORTANTLY: Neither document specifies that any waste of any kind would be hauled to RUSCHE PIT during the month of August 2011. A concerned citizen time stamped photo documented the occurrence of trucks leaving the tannery site and driving directly to RUSCHE PIT and entering with uncovered trucks full of soils and concrete from the Waste Water Treatment Plant area of the site. Close-up shots verify both soil and concrete being loaded into these trucks. Later that same day, another concerned citizen called Rusche Pit after seeing the pictures of the trucks entering their site. When asked if they were taking demolition material from Wolverine Tannery Site they said “no,” directly conflicting with the eye witness account and photographic evidence. Importantly, the transport and disposal of this possibly contaminated concrete appears to be completely undocumented. Rusche Pit sends Algoma Township records of what they take in and the sand and gravel they send out. The Algoma Township records from Rusche Pit, for materials that they received, do not show that they took in any demolition material in the month of August 2011. (Citizen obtained through Algoma Township FOIA) This this activity could be considered illegal dumping, commonly called midnight dumping. Power Point: Trucks from Tannery Site to Rusche Pit (Time stamped); Appendix 40. Kent County Geospatial Service, Rusche Pit at 12056 Algoma Ave. NE, to be owned by the Pitsch Agnes L. Trust, PPN 410610100003. See Appendix 43. Did Pitsch notify Wolverine and the City of Rockford that they were going to have the Tannery broken concrete taken to Rusche Pit and not follow their demolition Plan? Did Pitsch charge Wolverine landfill prices instead of sand and gravel mining prices? (11/2017 update: Since soil was mixed in with the demolition material, this site now may contain PFAS (PFCs).) 68 �Copyright ® 2009 - 2013 County of K•f\l., Michigan. All rtghff r•-rv•d Kent Coun~ Geo•patlal Service DISCLAIMER: Thia. mep does not repre5ent • lea•• document t<ent co..,nty Mlchlgen m•k•• no warrantv, exprfl~Sed O<' IMphe<:I • .-.,g11u·o1ng •cc... recv. complat•n••• OI" u••'"'"••• of ln formotlot1 pr••••lta<:I. Use.-. of this 1nh>rmatJon ••sum• aH liab,1,tv for Its rrtn. .• for• 0<1rtlcular use THE SECTION ABOVE IS CITIZEN PROVIDED AND COULD NOT BE FOUND ON WWW’S CD, UNLESS NOTED SELECTED INDEX relating to Scotchgard, PFAS, PFOS, PFOA, PFCs PFCs, 2, 7, 14, 18, 27, 29, 34 PFOA, 5 PFOS, 5, 27 Scotchgard, 2, 5, 7, 18, 26, 27, 29, 34, 53 Overview This review is my analysis of a March 21, 2012 U.S. EPA 104e information Request issued to Wolverine World Wide Inc. (Wolverine/WWW) related to the demolition of their 100+ year old Tannery in Rockford, Michigan. . A 104(e) request is an important tool utilized by the United States Environmental Protection Agency (EPA), roughly equivalent to a judicial subpoena, but in an environmental context. The EPA issued eight detailed requests for information in the form of questions. Wolverine was questioned regarding historic practices at the Site prior to the demolition and regarding practices that occurred during demolition (August 31, 2010 to August 31, 2011). Many of these questions were 69 �directed to Wolverine in response to environmental concerns noted and documented by local concerned citizens It appears that Wolverine’s response to the 104 (e) included significant omissions and misleading statements regarding demolition activities at the tannery site. However, the information omissions related to historical operations are especially troubling. Had critical information been disclosed regarding usage and disposal practices related to PFOS, for example, hundreds of families in northern Kent County might have spared five additional years of exposure to this toxic chemical in their drinking water supplies. Throughout the 104(e) response Wolverine claimed--repeatedly-- that the information being requested was “beyond its knowledge” or that they were unable to “produce documents or information not within its possession, custody, and control.” Why was I then, a citizen, able to secure detailed responsive information by simply making a few inquiries to relevant information sources? Why is a profitable international company like Wolverine World Wide allowed to dismiss/omit material information with the boilerplate response of it being too cumbersome or burdensome? The USA EPA 104e Request stated, repeatedly, that Wolverine was required to respond completely and truthfully to the eight requests for information. However, in their written responses, it appears that Wolverine only provided information relevant to the unsupported claim that “there is no known contamination on the property.” In doing this, Wolverine appears to have both misrepresented and downplayed the potential environmental and public health risk at the tannery site and the adjacent Rogue River. I have provided numerous documents in this Abstract which show the incompleteness of Wolverine’s responses to the EPA. One would assume that if these documents were readily available to me that the company could have produced them with ease. It is yet to be determined whether Wolverine has broken any laws regarding the demolition of the Rockford tannery and in their failure to accurately disclose key information to the EPA. Other questions remain: Was tannery demolition debris adequately tested (characterized) before it was disposed of off Site? Do records exist showing where the waste was disposed? In the light of the PFAS debacle, clear precise answers are undeniably important. Finally, how is it that a profitable company could respond so inadequately to an ‘environmental subpoena’ and not have been held accountable? The system of regulation and reporting is specifically designed to prevent and/or correct such a disaster as now faces citizens living in northern Kent County. Yet, business went on as usual with minimal regulatory oversight of a 100 year-old tannery while the company made money and bought time. The cost of this inexcusable outcome is being paid, every day, by citizens and their families. The claim that a ‘good corporate citizen’ wants people to be ‘comfortable with their water’ after sitting on key health information for over 20 years, is meaningless. Actions have already spoken. MAPS AND VISUALS 70 �For easy reference, and to better understand the scope of this document, I have included five key maps: 1. Map of Current/Historical Site Features 2. Aerial View of Historical Site Feature 3. MAP of seven Hot Spots: Submitted by citizens to U.S. EPA on April 2, 2012 during the PA process 4. AERIAL View of the Tannery Site post-demolition: April 2012 71 �Need a date and title 72 �Figure 2 Historical/Current Site Features Legend = V\tllte Pine Trail Site Boundary C',qntplltdby. leNStet181·ZGNnder w.e o•c:75:::11•1.:50 = = =300=-••-~eel s .k.lM2012 So;1tce: )klii!',YI Olklj,'lr9pllic O.XO \Jl)(ary rogue keepers 73 �I Wo1vcrinc World Wide I Hydraulic OJiR.clc11te on Dcttmbor8 and 9, 199$) Date: Deetmbtr IS, 1999 l J./, B1v,u t,,..s-rs ,.,,__ tt'c!<tS ;JrouM. f'H-1u s 'P'lJ.mf Hvc,M ;5ou,//-,\,I/(? ~ Wosfe. A-,w- C.Ov(l,. _;Jck_,- Tma~t- 74 PIM' /Wet-or& B 0 1t- �.' . .- . ~--._ J 1 : ~ : I •• ' ' \ \ \ 75 �Artifact 46 �ASSESSMENT OBSERVATIONS The property inspection was conducted on December 7, 1993, and consisted of a walk along the length of the site, with adjacent properties being viewed from the subject site. The inspection focused on potential environmental release points and visual observation for the presence of any evidence of onsite contamination. This section is based upon information provided by the visual inspection and a personal interview with Dick Anderson of the MDOT Real Estate Division. Mr. Anderson manages the railroad rights-of-way for MDOT and has been familiar with the site since it was purchased by MDOT in 1984. Chemical Materials Mr. Anderson was unaware of any chemical storage or spillage occurring onsite. Piles of blue hides were observed in the railroad right-of-way approximately 50' north of Rum Creek (see Appendix 6, Site Photographs and Appendix 4, Site Map). Plastic sheeting that covered the hides was tom or missing on several of the piles. Additional hide piles were observed approximately 300' north of Rum Creek. Brown, odorous, organic wastes which appeared to contain animal hair were observed immediately east of the south hide pile and also approximately 500' north of Rum Creek (see Appendix 4, Site Map). WWW tannery wastes have contained lead, zinc, nickel, .cadmium, chromium, and acetone. A portion of a wooden trailer containing hides was located onsite approximately 550' north of Rum Creek (see Appendix 4, Site Map). Yellow-brown staining was observed beneath the south end of the trailer, which appears to be approximately 10' west of the site (see Appendix 6, Site Photographs). A dumpster was observed on WWW property immediately east of the subject site, opposite the WWTP. A yellow-brown stain was observed on soil beneath the dumpster that appeared to extend onto the subject site. The stained area was approximately l' x 3'. The interior of the dumpster could not be viewed. A worker at WWW stated that he believed the dumpster was used to store metal but was uncertain. An area of limited soil staining (approximately 4' x 2.5') was observed in the gravel parking area between the WWTP and the tannery in the southern portion of the site (see Appendix 6, Site 01/10/94 -7- �Photographs). The stain did not appear to penetrate more than approximately 2" into the soil (i.e., no soil staining or odors were noted below_ 2 "). Patches of black soil were observed in the parking/drive area near the south end of the site and onsite near the north end of the tannery building (see Appendix 6, Site Photographs). The soil was darker than surrounding soils. A petroleum odor was not detected in this material. Peat-like soils are reported less than 10' below ground level (bgl) in the area. PCB Inspection PCBs were used as a coolant/dielectric fluid in transformers and capacitors from 1929 to 1977. No electrical transformers were observed on the subject site. Three elevated, electrical transformers were observed along the west side of WWW, immediately south of Rum Creek. According to a 1987 WWW Pollution Incident Prevention Plan, one of the transformers has a PCB concentration between 162 and 362 ppm. Two other PCB-containing transformers are located at the WWW power house, also east of the site. No evidence of leaks or release of any insulating oil was observed during the site inspection or discovered in review of MDNR files. Solid Waste Broken concrete, brick, scrap wood, and metal were observed onsite, along the riverbank, from approximately 50' to 700' north of the wooden trailer (see Appendix 4, Site Map). Cinder and slag-like materials were observed piled along the railroad bed in two locations approximately 1400'-1700' north of Rum Creek (see Appendix 4, Site Map). Most of the ground in the area was covered with leaves and was not easily visible at the time of the inspection. An open-top 55-gallon drum was observed onsite approximately 75'-100' south of the northern property boundary, near the eastern edge of the site. Another drum, wooden pallets, and scrap metal were observed in the area, northeast of the site, on property formerly operated by American Oil Company (see Appendix 4, Site Map). It appears that surface water runoff from this area northeast of the site flows to the southwest and ponds onsite, east of the railroad tracks. No obvious soil staining, petroleum odors, or surface water sheen were noted in the area during the site inspection. 01/10/94 -8- �Storage Tanks Mr. Anderson was unaware of any present or former ASTs or USTs located on the property. An unidentified vertical, orange pipe and an empty 55-gallon drum were observed at the eastern edge of the railroad right-of-way immediately south of Rum Creek (see Appendix 6, Site Photographs). Mr. Anderson did not know the origin or purpose of the pipe or drum. They are in the vicinity of a monitor well installed as part of an UST investigation at WWW and appear to simply mark the location of the flush-mount monitor well. The pipe was loose and did not appear to be connected to anything. Wastewater No evidence of onsite disposal of wastewater was observed during the site inspection. Tannery effluent generated at the adjacent WWW is pretreated in the WWTP immediately west of the site. Treatment consists of primary clarification with extended aeration; a chemical treatment with lime, alum, sodium hydroxide, and polyelectrolytes; a final clarification; and sludge dewatering. The wastewater is then discharged to the municipal sanitary sewer system. 01/10/94 -9- '½ro~& ll~~.lli �REGULATORY REVIEW FTC&H. requested a review of files located at the Grand Rapids Office of the MDNR for the Environmental Response, Surface Water Quality, Waste Management, and Air Quality Divisions. Files were also requested from the Kent County Health Department, Grand Rapids, Michigan, and the Michigan State Police Fire Marshal Division, Lansing, Michigan. In addition to the site itself, FTC&H requested a file search for: 1. Wolverine World Wide, Courtland and Main Streets 2. Michigan Northern Railroad/Penn Central Railroad 3. Porter's Quarters Gifts, 31 Courtland Street 4. S&J Petroleum Corporation, 66 East Bridge Street (LUST site) 5. City of Rockford Department of Public Works, 200 Industrial Drive Agency Review 1. The Kent County Health Department had no information on any of the listed sites. 2. The MDNR had infonnation on the following sites. a: Wolverine World Wide, 123 Main Street: Waste Management Division: A January 1984 Resource Conservation and Recovery Act inspection revealed this facility used IPA, MIBK, butyl acetate, mineral spirits, and EP solvent (a blend from Spartan). A maximum of one to two drums of hazardous waste was generated per month. A 1982 waste characterization report states that sampled wastes contained lead, zinc, nickel, cadmium, chromium, and acetone. The plant has a wastewater treatment facility for tannery effluent. The treatment facility generates chromium-bearing sludge. Pollution Incident Prevention Plans on file for WWW state that flammable materials, including MIBK and IPA, were being stored outside, west and north of the warehouse, which is the southernmost WWW building (see Appendix 4, Site Map). The exact locations were not determined. Infonnation in the file indicates the chemical storage area was later moved inside the warehouse, which has containment. 01/10/94 - 10 - oo!.n: �A tin storage shed north of Rum Creek and west of the railroad site had a compacted earthen floor and was used to store hydraulic oil (see Appendix 4, Site Map). MDNR notes indicate no evidence of leakage was observed outside the tin shed. A February 1983 inspection revealed wastes were being stored in a building with no roof that was attached to the shoe plant, located northeast of the site, approximately 500'. Environmental Response Division: Closure of three gasoline USTs began at the WWW site in October 1992. There were two 1000-gallon USTs and one 4000-gallon UST. One of the 1000-gallon USTs was located on the west side of the facility, near the wastewater treatment plant, approximately 200' south of Rum Creek and approximately 20'-30' east of the subject site: The other two USTs were south of the power house approximately 100' -150' east of the subject site (see Appendix 4, Site Map). Soils were stained and had a petroleum odor during closure activities. No BTEX was discovered in the western excavation above Type B cleanup criteria. The BTEX contamination did not extend to the groundwater. Groundwater was 5'9 .5' bgl and flowed from northeast to southwest, toward the river. Elevated levels of lead were discovered in the soils in the vicinity of the western excavation. Lead at 23 ppm was detected in soils approximately 5' bgl at the eastern edge of the subject site, 75' south of Rum Creek. The default Type A soil cleanup criteria is 21 ppm. A soil-lead concentration of 1400 ppm was detected approximately 20'-30' east of the site and approximately 100' south of Rum Creek. This level exceeds the direct contact criteria for lead of 400 ppm. A lead level of 130 ppm was detected at 4'-6' bgl in a boring approximately 200' south of Rum Creek and 20'-30' west of _the· site. In the southern excavation, the concentration of ~TEX in the groundwater was below Type B criteria. Soil excavation was recommended for the southern area. An April 1993 report by FTC&H, Hydro geologic Investigation Repon and Proposed CAP, was submitted to the MDNR. Three other USTs were removed from WWW in 1988. They included a 12,000-gallon gasoline UST, a 2,000-gallon diesel UST, and a 900-gallon diesel UST. A letter from WWW to the MDNR states that no evidence of leakage was noted during removal of the USTs. It does not appear that a site assessment was conducted and locations for these USTs were not discovered in the file. 01/10/94 - 11 - �In January 1980, foam from the WWTP aerator overflowed. Affected soil was hauled to a landfill. Surface Water Quality Division: In September 1981, a complaint was received regarding a discharge of sludge to Rum Creek during dewatering activities for construction. The MDNR instructed the company to pump the dewatering water through the treatment system. No further action was required. In November 1982, approximately 2000 gallons of tannery waste were released to Rum Creek due to a plugged transfer line. No harmful effects were noted by the MDNR representative. In 1991, WWW requested a withdrawal of a groundwater discharge permit because the facility connected to the sanitary ~ewer system. Air Quality Division: In September 1991, the MDNR registered a complaint regarding "misting" of an outdoor opening to the sludge press at the WWTP building with bleach to control odor. The MDNR inspector noted potential soil contamination in a localized area. No further response was undertaken. That same month, the MDNR issued a letter to WWW r·egarding a problem with visible emissions from a scrubber stack and spray booth on a leather coating line. b. Rockford Parking Area (Act 307 site), approximately 800' south of the site. Hydrocarbon contamination was dis~vered at this site during installation of a drainage line. A hydrocarbon bulk storage facility previously operated at this location. An August 1992 Hydrogeological Investigation conducted by FTC&H indicates that soil and groundwater contamination has not migrated offsite. Groundwater flow direction in this area appears to be to the west-southwest, toward the Rogue River. FTC&H recommended that a Corrective Action Plan be prepared for the site. No. additional work has been conducted at the site. c. City of Rockford Department of Public Works, 200 Industrial Drive, approximately 900'1000' northeast of the site (LUST site). According to Mike Chesher, Rockford City Public Services Director, soil and groundwater was contaminated due to leaking gasoline tanks. The contamination has not migrated offsite. He stated that a proposal for groundwater treatment has been submitted to the MDNR and that contaminated soils have been remediated. 01/10/94 - 12 - �3. The Fire Marshal Division had no information on any of the listed sites. Data Base Review FTC&H also reviewed the following data bases of sites compiled by the federal and state government. Federal 1. The National Priorities List of CERCLA (Superfund) Sites was reviewed for known sites of contamination located within approximately one mile of the subject site. No sites were located. 2. The Comprehensive Environmental Response, Compensation, and Liability Information System List was checked for sites within a 1/2-mile radius of the subject site. No sites were found. 3. The Emergency Response Notification System List was reviewed for the presence of the subject property; the subject site was not recorded. State 1. The June 1993 Michigan List of Hazardous Waste Generators was reviewed for the site and . adjacent properties. The only site listed was Wolverine World Wide Inc., 123 Main Street and 9341 Courtland Street. 2. The November 1993 Proposed List of Michigan Sites of Environmental Contamination (MDNR Act 307 List) was checked for known sites of contamination within approximately one mile of the subject site. The following sites· were found. a. Rockford Paper Mills, 41-08N-11W-02DD, approximately one mile southwest on the opposite side of the Rogue River. Aluminum and sodium were released to the environment. Evaluation and interim response are privately funded. b. Rockford Parking Area, 41-09N-11W~36, approximately 800' south of the site. Benzo(a)anthrene was released to the environment. Evaluation and interim response are privately funded (refer to Agency Review paragraph 2.b.). 01/10/94 - 13 - �3. The Fiscal Year 1993 Fourth Quarterly Report of Leaking UST Sites in Michigan was reviewed for known sites of contamination within approximately 1/2-rnile of the subject site. The following sites were located. a. J&J Petroleum Corporation, 66 East Bridge Street, approximately 550' southeast of the site. This site appears to be in a downgr_adient groundwater flow direction from the subject site and thus contamination is not likely to affect the subject site. b. Wolverine Leathers, 123 North Main Street, adjacent to the site (refer to Agency Review paragraph 2.a.). c .. City of Rockford Department of Public Works, 200 Industrial Drive, approximately 900'1000' northeast of the site (refer to Agency Review paragraph 2.c.). 4. The September 1993 List of Registered USTs in Michigan was reviewed for the presence of registered USTs onsite and on adjacent properties. The only site listed was Wolverine Leathers, 123 North Main Street. The list indicates that three gasoline USTs (two 2000-gallon and one 4000gallon) are temporarily closed (refer to Agency Review paragraph 2.a.). 5. The March 1993 MDNR List of Active Solid Waste Facilities, Transfer Stations, and Inactive Solid Waste Facilities was checked for known disposal sites within a 1/2-mile radius of the subject site. No sites were iocated. 6. The Michigan List of Hazardous Waste Treatment, Storage, and Disposal Facilities was checked for sites within a 1-mile radius of the subject site. No sites were found. 01/10/94 • - 14 - �CONCLUSIONS There are three known s~tes with leaking USTs located within a 1/2-mile radius of the subject site and two Act 307 sit.es of contamination located within a 1-mile radius. From the information reviewed, it does not appear likely that contamination from any of these sites has the potential to impact the subject property. After reviewing the information provided by a 50-year title search; reviewing MDNR, local health department, and Fire Marshal Division files; conducting a visual site inspection; interviewing the current owner/operator; reviewing state and federal lists of contaminated sites; and reviewing adjacent properties; FTC&E; personnel, with the information available, have identified the following as areas of potential environmental contamination: 1. Cinders and slag-like material observed along the path of the railroad may have leached contaminants, such as hea~ metals and polynuclear aromatic hydrocarbons, to the soil or groundwater beneath the site. 2. Hides and/or wastes stored onsite north of Rum Creek may have leached contaminants, such as heavy metals, to the soil or groundwater beneath the site. 3. Staining was observed onsite adjacent to an unidentified_ WWW dumpster. The staining appeared similar in color to that observed beneath a hide storage trailer. 4. Elevated lead levels were detected in soils east and west of the former railroad tracks in the vicinity of the former ·www USTs. The concentrations were greater than background levels of MDNR Type A cleanup criteria. Elevated lead levels may exist onsite in this area. 5. Assessor records indicate that American Oil Company formerly operated immediately north of the site. Surface water drainage and probable groundwater flow direction is toward the subject site. No visual evidence of environmental contamination was found. 6. Chemical materials have been stored outside at the adjacent WWW warehouse building east of the site. Tuer~ is no ·available evidence to indicate that environmental contamination has resulted from this storage. 01/10/94 - 15 - �Soil staining in· the parking area between _WWW and the WWTP appears to be confined to the upper few inches of soil. 01/10/94 - 16 - �Artifact 47 �3M document shows Wolverine knew about PFAS in 1999 (al mlive.com/news/grand-rapids/2017 /11 /3m _ scotchgard_wolverine_pfas.html https://www.facebook.com/garret.ellison November 4, 2017 1/6 �Rockford PFAS investigation at former Wolverine World Wide tannery By Garret Ellison j_gellison@mlive.com ROCKFORD, Ml -- Wolverine World Wide has claimed it first learned last fall that the Scotchgard waterproofing agent it used to make Hush Puppies shoes for decades contained a toxic chemical which has subsequently golluted the Rogue River in Rockford and goisoned drinking water sugglies in Plainfield Township. 3M, the Minnesota giant which manufactures Scotchgard, has undercut Wolverine's claim by disclosing an 18-year-old document showing Wolverine was specifically advised that the former Scotchgard chemistry was being discontinued and the key compound was a threat to environmental health. The two companies met in Rockford to discuss the chemical on Jan. 10, 1999, according to a 3M letter sent five days later to former Wolverine vice president Rick DeBlasio. 3M attorneys disclosed the letter on Friday, Nov. 3. "3M bears no responsibility for the environmental practices of Wolverine," wrote 3M attorney William A. Brewer Ill. "We are surprised to see that Wolverine claims it was unaware of the fact that PFOS was used at its former tannery and, apparently, that it was unaware of 3M's voluntary decision to phase out of the chemistries in question," Brewer wrote. "The record reflects otherwise." 3M letter to .@WolverineWW in 1999 blows up claim that WWW didn't know #PFOS was in Scotchgard until last year: httgs://t.co/7ufBldA5D7 gic. twitter.com/PZOAU63WP6 - Garret M. Ellison (@garretellison) November 4, 2017 "Beyond the fact that 3M's phaseout decision and leadership on this issue made national headlines, 3M personally met with Wolverine long before and during the time of the phaseout announcement in May 2000," Brewer wrote. "These meetings were to discuss PFOS, share information about the compound, and advise of 3M's voluntary efforts to phase out of the chemistries." According to the letter, Wolverine was advised that PFOS "has the potential to accumulate in the body with repeated exposures and resist degradation in the environment." 3/6 �"This information was reported to your company previously in an updated Material Safety Data Sheet as recently as late 1998," the letter reads. The letter notes 3M monitored employees for over 20 years and found PFOS at various concentrations in their bodies, and that "exposure could occur from manufacturing process of 3M and its downstream users, as well as from product use and disposal." The letter is dated prior to the reformulation of Scotchgard under wessure from the Environmental Protection Agency, which said in 2000 it would have taken steps to have Scotchgard removed from the market had 3M not voluntarily phased out PFOS production. 3M later developed a new version of Scotchgard that relies on perfluorobutane sulfonate, or PFBS, as its key ingredient. The Michigan Department of Environmental Quality says it's reviewing the 3M disclosure and plans to bring up the matter with Wolverine. "The DEQ takes the issue of full transparency of historical information very seriously as this is very important information in our site investigations," DEQ spokesperson Melanie Brown said in a statement. "The department is reviewing the newly obtained 3M correspondence and is looking forward to discussing with WWW how this new information correlates to the background information they previously have provided to us. In mid-August, Wolverine sent Mlive a statement through the public relations firm Lambert, Edwards & Associates claiming it didn't know didn't know perfluoroctanesulfonic acid, or PFOS, was used in Scotchgard at the tannery until last year. PFOS is one of numerous per- and polyfluoroalkyl substances collectively called PFAS, (also PFCs), found in the Rogue River near the Rockford dam and in residential drinking water wells near Wolverine's long forgotten landfill on House Street NE in Belmont. Wolverine began using Scotchgard at the tannery in 1958. "In fall 2016, Wolverine first learned that PFOS may have been present in compounds used at its former tannery in Rockford," the Aug. 18 statement read. "Following this, Wolverine developed and submitted to the DEQ a proposed plan to voluntarily sample this site for not only PFOS, but also for PFOA and other PFAS compounds." The statement was issued in response to a question about an allegation that Wolverine attorney Michael Robinson and consultant Mark Westra claimed there was "no evidence that PFOS was ever used at the Rockford Tannery site" during a Aug. 22, 2016 meeting with the Concerned Citizens for Responsible Redevelopment group of Rockford held at the West Michigan Environmental Action Council. 4/6 �The allegation was in a Jan. 24 memo to the DEQ by Richard Rediske, an environmental chemist at Grand Valley State University's Annis Water Resources Institute, who warned that scrap leather on the riverbanks, waste buried on site and tannery wastewater may have contained PFOS for 44 years. Rediske specifically warned that a new tannery site inspection was needed as well as scrutiny of old local disposal sites that might have accepted tannery waste. Months after Rediske's memo, PFAS was discovered in wells near Wolverine's House Street NE landfill, where tannery sludge was dumped into unlined trenches in the 1960s. The subsequent DEQ investigation into that PFAS plume spread has moq2hed into a widespread search for other old Wolverine dump sites around northern Kent County. The investigation has also sparked a county cancer study_. On Saturday evening, Nov. 4, Wolverine responded to 3M's disclosure with a statement seemingly at odds with its previous assertion. "Wolverine has known and it was widely publicized that 3M's Scotchgard contained PFAS and we relied on 3M's representations to us, the EPA, and the public that it had no adverse effects on the environment or human health," the company stated. "We've never intended to infer anything to the contrary. "Wolverine used 3M's Scotchgard product (which contained PFAS) from about 1960 through 2002 when the product was reformulated. 3M has always assured Wolverine (as it does in its letter), the EPA and the public that the chemical is safe for the environment and human health. Wolverine acted in good faith based on that information and always complied with EPA and state regulations." Since the PFAS investigation began in earnest, Wolverine has made repeated reference to 3M's responsibility for the chemical. 3M first sold Scotchgard in 1956. It protected fabric, furniture and carpets from water and stains for decades. It was reformulated in the early 2000s after the EPA determined the chemistry was toxic to humans, magnifies up the food chain and persists in the environment. On its website, Wolverine wrote that "3M are experts at PFAS." "They created and sold the product and we now understand that they have a number of environmental sites involving PFAS that they are involved in around the United States (including Alabama and Minnesota) and the world." 5/6 �"We have reached out to 3M to get their expert advice because they have state of the art research on PFAS and their possible impact on humans and the environment - Wolverine has not yet had access to this research," Wolverine wrote. "We have asked 3M to step up and partner with us, the community and the various regulatory agencies to help address the issues in our community related to the products that they manufactured and sold ." Wolverine's says it began using the reformulated version in 2002 and "we now know that Scotchgard contained PFOA/PFOS until 3M changed the formula around 2002." When asked Sept. 12 how Wolverine could not have known PFOS was in Scotchgard until last year, vice president Chris Hufnagel called it an "emerging issue." "This PFAS is, I think we would all agree, it is an emerging issue," Hufnagel said . "There is not a lot known about it. We're learning more, honestly, on a daily basis." 6/6 �Artifact 48 �01/ ~8 '99 07:50 ID :311 PCP 223-6$-04 FAX:6517361587 ' JM l ",:1\la SI, l~u.d. MN ~~l ,l,t . llNX} hi! 71_1 11111 3NI January IS, 1999 VIA fACSIMlLE Rick DeBluio Executive Vice President Corporate Operationa GrO\lp Wolverine Worldwide, lnc. Nonh Maln Office 123 North Main Street Roclcford, Ml 493S1 Dear Mr. DeBluio: This lencr is in follow-up to a meeting held at Wolverine Worldwide, lnc. on January 10, 1999. Thank you for agreeing lo meet with 3M'a representative&. Although l waa not able to artcnd that meeting. I would like 10 retpe>nd lo your request for a written summary of the key point&. which ara u foUows: • There is 1. growing interest in understanding the effects of chemicals on huma.n health and tha c.nvi.ronment.. Jn this regard, 3M hu a comprehensive initiative underway that ia helping ua to advance the undcratanding of fluorochcmicala. One example is the fluorochemical perfluorooctane aulfonate (PFOS). 3M has manufacwred PFOS and rewed molecule■ since 1948. • PFOS is an e.u mplc of an "organic" fluorine molecule. Huma.n scrum has been known to contain oraanic fluorine molecule, for over thiny yean, u reported in the published scientific literature. • 3M'• improvement in the application of analytical techniques hu allowed for rapid analysis of 1pecific organic fluorine molecule, at extremely low limits of detection. • 3M' a state of the art analytical techniqu.es have led IO the recent discovery of PPOS at tens of pans per billion (ppb) levels in scrum samples of nonoccup•tionally exposed people. 2 �01/ 18 '99 07:50 . ID:311 PCP 223-6$-04 FAX :6Sl7361587 January 15, 1999 Pagc2 • f1uorcx:hemicals such as PFOS arc stable molecu.les and therefore pc<sistent. As such, PFOS has the potential 10 M.C1Jmulate in the body with repeated exposures and to resist degradation in the environment. This information wu ~orted to your company previously in an updated Maierial Safety Data Sheet as n:cenlly u late I 998. • 3M has conducted medical surveillance among employees occupationally expoaed to PFOS for over twenty years. These empl.oyees have PPOS serum levels 1hat range from one pan per million (ppm) up to 12 ppm. No adverse health effec:t wociatcd with PFOS exposure hu been found in 3M employees, who,e measured level i, about 100 times . hiiher than levels seen in the serum of people wiiut oecupatlonal exposure. • Further. the currently available evidence doea not suaaest any human health eff'ect wocla.led with the lcvcla of PrOS found In aerum samples of people without occupational exposure. • Exposure could occur li'om manufacturing proceasa of 3M and ii.I downstrwn users, u well as from product use and disposal. The relative contribution of the$e various sources to population exposure and the routes of exposure 11e currently under study. 3M has undertaken a wide range of stewardship initiatives in response to these recent finding,. These stewardship activities arc outlined below: 3M is actively developing further human health and toxicological • information to advanu our acien1ific undersunding. We are working with a number of leading independent researchers and scien1isu to help with this effon. • An eKpansive environmental testing program ia underway to advance our understanding of exposure routes to these materials outside as well as wi1hin the occupational setling. • 3M has initiated discussions with regulatory agencies globally, including the U.S. EPA and FDA. to advise them of our findings and to seek their input and assistanu with our tating and stewardship initiatives • In spite oflhe absence of known human health effects 11 the levels obSCNcd, 3M is commiued to reducing source., of exposure to PFOS. In that regard, we are actively reducing fluorochemical residual! in our 3 �Artifact 49 �I ENCLOSURE 1 QUESTIONS 1) Identify all persons consulted in the preparation of the answers to this Information Request and the questions herein. 2) Identify aJI documents consulted, examined, or referred to in the preparation of the answers to this InfoI1Dation Request, and provide copies of all such documents. 3) Produce correct and complete copies of the following: a) All available environmental data, including, but not limited to, all soil, sediment and groundwater sample collection data and analyses; all groundwater and surface water elevation data used to determine groundwater flow direction; and any other environmental sample collection data and analyses from the site; b) Any and all information relating to the historic solid waste handling and disposaJ practices at the site, including waste liquids, semi-liquids, and sludges. Please include data from the period antedating the construction of the facility's wastewater treatment plant, and include information regarding any analysis and cleanup of chemical spills at the site; c) Any and all information relating to the removal of wastes (both characterized and uncharacterized), including quantities, analyses and disposal destinations, during the demolition of the tannery; d) Any and all data regarding chemical storage during site operations, including the location and capacity of above- and below-ground storage tanks, vats, drums and containers; e) Any and all data regarding media known to be contaminated with hazardous substances, pollutants or contaminants, including soils, solid wastes and any process residues left on site or aJong the adjacent river banks during decommissioning and demolition activities; and f) All records of any air monitoring conducted during decommissioning and demolition of the site_ 4) Identify the chemicals historically used at the site. 4 �•5) Did you ever use, generate; store, treat, dispos:e; or otherwise handle at tb,e Site any hazardous substances, wastes or other materials? If the answer to the preceding question is anything but an unqualified ''.no;"Sor each such hazardous substance, waste or othennaterial, descn."be in detail the nature and volume of the hazardous &tJ.bstance, waste or other material, and how it was us(;;(}., generated, stored, treated, disposed or otherwise handled at the Site. 6) Describe Wolverine's waste management practices at the site., including the period antedating the construction.of the wastewater treatment plant. In your response, identify any practices or incide:nts in which liquid wastes, off-specification liquid process materials or sludges were spilled, diswsed of, buried, placed or sto.red upon the land at the site, and identify the location of any such areas of spillage, placement or storage. 7) Identify the location of any chum storage areas at the site, and identify any wastes that were stored in such areas. · 8) Identify the protocols that were followed during the tannery's demolition to characterize soils, demolition materials and any wastes di$COVered on site during the demolition, and identify the locations to which soils, demolitions and waste materials were gent. 5 �Artifact 50 �M.!CHAEL l. ROBINSON 616-752-2128 FAX 616-222-2128 mrobinson@wnj.com April 12, 2012 Via Federal Express G. Marie Watts Environmental Protection Specialist U.S. Environmental Protection Agency Superfund Division (SC-5J) 77 West Jackson Boulevard Chicago. Illinois 60604-3590 Re: PART I of Wolverine World Wide's Response to U.S. EPA' Request for Information Pursuant to Section 104 of CERCLA for Woherine World Wide's Former Tannery Site (SSID: C593) in Rockford, Michigan Dear Ms. Watts: I write on behalf of Wolverine World Wide in response to the above-referenced request for information and documents (the "Request"). Enclosed with this letter are Wolverine's objections and responses to the Request and a compact disc containing electronic copies of all non-privileged documents in Wolverine's possession, custody, or control that ,vcre identified during review of Wolverine's documents as responsive to one or more items in the Request. As agreed with Mr. Tom Williams, this submittal is Part I of Wolverine's response to the Request. It includes responses to Request items 3, 1 4, 7, and 8. As agreed, Wolverine will respond to the remaining Request items (items 5 and 6) in Part II of its response, which will be provided no later than May 21, 2012. If you have any questions about this response, please contact me. Thank you. Very truly yours. ... mson 8242310 1 Our agreement with Mr. Williams was to submit items 3(a). (c), (c). (t) by April 13, 2012. hut this submittal includes Wolverine's response to every subpart of item 3. WARNER NORCR05S & Juoo LLP ATTORNEYS •T LAW 900 FIFTH THIRD (ENTER• 111 LYON STREET, N W. GRAND RAPIDS. MICHIGAN 49503-2487 • WWW.WNJ.COM �----~------------------------ -------• Wolverine World Wide's Response to U.S. EPA's Request for Information Pursuant to Section 104 of CERCLA for Wolverine's Former Tannery Site (SSID C593) in Rockford, Michigan PART I As agreed with Mr. Tom Williams, this Response is Part I of Wolverine's response to the Request. It includes responses to Request items 3, 4, 7, and 8. As agreed, Wolverine will respond to the remaining Request items in Part II of its response, which will be provided no later than May 21, 2012. GENERAL OBJECTIONS In responding to the Request, Wolverine has undertaken a diligent and good-faith search for and review of information and documents in its possession, custody, and control. That said, Wolverine does not represent or warrant that all responsive documents have been identified during this review, and Wolverine reserves the right to voluntarily supplement its responses at any time should additional information become available. Wolverine asserts the following general privileges, protections, and objections with respect to the Request. 1. Wolverine asserts all available privileges and protections, including the attorney-client privilege, the attorney work-product doctrine, all privileges and protections related to malerials generated in anticipation of litigation, the settlement communication protection, the confidential business information ("CBI") and trade secret protections, the joint defense privilege, and any other privilege or protection available to it under law. Wolverine is not providing privileged documents. In the event that a privileged or protected document has been inadvertently included among the documents produced in response to the Request, Wolverine asks that any such document be returned to Wolverine immediately. 2. Wolverine objects to Instruction 3 to the extent it seeks to require Wolverine to seek out responsive information from former employees and agents. Wolverine is providing information within its possession, custody, and control. 3. Wolverine objects to Instruction 5. Wolverine is responding to this Request with information within its possession, cust<?dy, and control, and Wolverine will similarly comply with any lawful future requests that are within EPA' s authority. Wolverine reserves the right to voluntarily supplement its responses at any time should additional information become available. 4. Wolverine objects to Instruction 8. Requiring the certification specified in that instruction is beyond the EPA's 104(e) authority. Wolverine has undertaken a diligent and goodfaith search for and review of information and documents in its possession, custody, and control. Subject to these objections, it is submitting all known, responsive, non-privileged information within its possession, custody, and control and is not knowingly submitting any false information. Wolverine reserves the right to supplement its responses at any time should additional information become available. �5. Wolverine objects to Instruction 9 and the Request's definition of "documents." Wolverine disclaims any responsibility to search for, locate, or provide EPA with copies of any documents "known [by Wolverine] to exist," or to identify documents that "have been transferred to others or have otherwise been disposed of' without Wolverine's knowledge. Further, Wolverine objects to the definition of "documents" as overly broad and unduly burder.some. Wolverine is providing known, responsive, non-privileged information and documents within its possession. custody, and control. 6. Wolverine objects to the Request to the extent that it asks Wolverine to describe certain items in detail and to separately provide infom1ation that is contained in documents furnished to or already in the possession of the EPA. Documents that were previously provided to the EPA are provided again as a courtesy as part of this Response. But information sought by EPA that is set forth only in those documents is not separately stated in detail this Response. In those circumstances, to the extent that a more complete answer to such requests can be determined by examining the provided documents, the burden of that examination is the same for Wolverine and EPA. Requiring Wolverine to separately provide a detailed answer, rather than referring to the provided documents, would be unduly burdensome. OBJECTIONS AND RESPONSES 3. Produce correct and complete copies of the following: a) All available environmental data, including, but not limited to, all soil, sediment and groundwater sample collection data and analyses; all groundwater and surface water elevation data used to determine groundwater flow direction; and any other environmental sample collection data and analyses from the site; b) Any and all information relating to the historic solid waste handling and disposal practices at the site, including waste liquids, semi-liquids, and sludges. Please include data from the period antedating the construction of the facility's wastewater treatment plant, and include information regarding any analysis and cleanup of chemical spills at the site; c) Any and all information relating to the removal of wastes (both characterized and uncharacterized), including quantities, analyses and disposal destinations, during the demolition of the tannery; d) Any and all data regarding chemical storage during site operations, including the location and capacity of above- and below-ground storage tanks, vats, drums and containers; e) Any and all data regarding media known to be contaminated with hazardous substances, pollutants or contaminants, including soils, solid wastes and any process residues left on site or along the adjacent river banks during decommissioning and demolition activities; and 2 �f) All records of any air monitoring conducted during decommissioning and demolition of the site Wolverine objects to this request as unduly burdensome and unreasonable to the extent that it asks Wolverine to respond to matters beyond its knowledge or to produce documents or information not within its possession, custody, and control. Subject to its general objections, Wolverine produces in response to this Request (Ja-f) the documents in folder numbers 3 and 34 on the enclosed compact disc. 4. Identify the chemicals historically used at the site. Wolverine objects to this request as unduly burdensome and unreasonable to the extent that it asks Wolverine to respond to matters beyond its knowledge or to produce documents or information not within its possession, custody, and control. Subject to its general objections, Wolverine produces in response to this Request the documents in folder number 3-4 on the enclosed compact disc. 7. Identify the location of any drum storage area at the site, and identify any wastes that were stored in such areas. Wolverine objects to this request as unduly burdensome and unreasonable to the extent that it asks Wolverine to respond to matters beyond its knowledge or to produce documents or information not within its possession, custody, and control. Subject to its general objections, Wolverine produces in response to this Request the documents in folder numbers 7 and 3--4 on the enclosed compact disc. By way of further answer, to Wolverine's knowledge the drum storage area at the site was used to store raw materials, not wastes. Waste was discharged through process piping to the wastewater treatment plant. Pressed sludge cakes from the wastewater treatment plant were disposed of at an approved offsite landfill. 8. Identify the protocols that were followed during the tannery's demolition to characterize soils, demolition materials and any wastes discovered on site during the demolition, and identify the locations to which soils, demolitions and waste materials were sent. Wolverine objects to this request as unduly burdensome and unreasonable to the extent that it asks Wolverine to respond to matters beyond its knowledge or to produce documents or information not within its possession, custody, and control. Subject to its general objections, Wolverine produces in response to this Request the documents in folder number 3 on the enclosed compact disc. By way of further answer, Wolverine disturbed soils as little as possible during demolition. During demolition, in the event that Wolverine noticed a soil condition that appeared out of the ordinary, Wolverine characterized the soil based on available data. This occurred in two locations. One location was the space under tannery maintenance area where the waste line to the wastewater treatment plant had broken. The broken line was identified as the source of any soil contamination. Accordingly, the soil was characterized as the same waste that had historically been treated at the wastewater treatment plant. It was disposed of as such by Valley City Environmental. The other location was directly under the primary clarifier tank at the wastewater treatment plant. In that location, there was a small amount of discolored soil that 3 �had the appearance and odor of tannery waste. This was characterized as tannery waste that may have leaked through a crack in the base of the clarifier. It was disposed of accordingly by Valley City Environmental. An asbestos survey was performed in advance of demolition. Asbestos removal took place prior to demolition, as well as during demolition when asbestos was identified. All chemicals and process piping were removed and/or cleaned prior to demolition by Va11ey City Environmental. Valley City Environmental washed, rinsed, and wipe tested containers, walls, floors, and other surfaces that came into contact with chemicals during the tanning process. Wolverine sent demolition waste materials to the following locations: • Richmond Transfer Station, 675 Richmond, Grand Rapids, MI (Salvage material, demo debris and ferrous and non-ferrous recyclables) • Pitsch Landfill, 7905 Johnson Road, Grand Rapids, MI (Non-haz.ardous demolition debris). • Pitsch, 200 North Park, Grand Rapids, Ml (Concrete). • Pad.nos (Turner Facility), 2125 Turner Grand Rapids, MI (Steel). • LANCO, 665 10 Mile, Sparta MI (Electrical Equipment). • Woodland Paving, 3566 Mill Creek Comstock Park, MI (Asphalt). • Superior Asphalt, Century, Grand Rapids, MI (Asphalt). • Valley City (PCB containing light ballasts). I certify under penalty of law that I have examined and am familiar with the information submitted in responding to the Request. To the best of my knowledge the information submitted is true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment. Signature: Name: Date: 8241440 4 z.:~ ="' c:;~14,J --/~~~---e..____ �Artifact 51 �UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 77 WEST JACKSON BOULEVARD CHICAGO, IL 60604-3590 REPLY TO TH E ATTENTION OF : SR-6J . BY CERTIFIED MAIL RETURN RECEIPT REQUESTED Christopher Hufnagel, Senior Vice-President Wolverine Worldwide, Inc. 9341 Courtland Drive N. E. Rockford, Michigan 49351 Re: Request for Information Pursuant to Section 104 of CERCLA for Wolverine Worldwide Waste Disposal Areas in and around Kent County Michigan Dear Mr. Hufnagel: This letter seeks Wolverine Worldwide, Inc.' s (hereafter, "Wolverine's," or "your") coop~:-:ltion in providing information and documents relating to the generation of hazardous substances, pollutants and contaminants, and the disposal of such hazardous substances, pollutants or contaminants at certain disposal areas in and around the City of Rockford and Kent County, Michigan, including, but not limited to, the disposal area adjacent to House Street in Belmont, Michigan, and the former Wolverine tannery at 123 Main Street and surrounding areas in Rockford, Michigan (hereafter the "Wolverine Disposal Sites" or "Sites," unless a specific question or request is by its terms directed to a specific disposal site). We encourage you to give this matter your immediate attention and request that you provide a complete and truthful response to this Information Request and attached questions (Attachment B) within twenty (20) days of your receipt of this letter. The United States Environmental Protection Agency (" EPA" or "the Agency") is investigating the release or threat ofrelease of hazardous substances, pollutants, or contaminants at and from the Wolverine Disposal Sites. EPA is seeking to obtain information con~eming the generation, storage, treatment, transportation, and methods used to dispose of such substances that have been, or threaten to be, released from the Sites. EPA reserves its authority to study the effects of these substances on the environment and public health. In addition, EPA reserves its authority to identify activities, materials, and parties that contributed to contamination at the Sites. EPA believes that you have information that may assist the Agency in its investigation of the Sites. Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 1 00% Recycled Paper (100% Post-Consumer) �EPA performed a Site Assessment at the former Wolverine tannery at 123 N. Main Street, Rockford, Michigan (the "Tannery Site") during 2011-2012. At that time, EPA observed the presence of what appeared to be scrap leather in and on soils adjacent to the Tannery Site and along the Rogue River. EPA also issued a request for information under CERCLA Section 104(e) to Wolverine in March, 2012, regarding, among other things, past waste disposal practices at the Tannery Site. Upon issuing the Site Assessment report, EPA transferred the Tannery Site to the Michigan Department of Environmental Quality for the exercise of other cleanup authority. In 2017, EPA became aware that the chemical compound perfluorooctane sulfonic acid ("PFOS") or related compounds had been discovered in well water at an area adjacent to a closed waste disposal location in Belmont, Michigan and that Wolverine Worldwide or its predecessor had used this location for disposal of process wastes. EPA has also become aware that Wolverine may have disposed of process wastes at other locations. Description of Legal Authority The federal "Superfund" law (the Comprehensive Environmental Response, Compensation, and Liability Act, 42 U.S.C. § 9601 , et seq., commonly referred to as "CERCLA" and "Superfund") gives EPA the authority to, among other things: (1) assess contaminated sites, (2) determine the threats to human health and the environment posed by each site, and (3) clean up those sites in the order of the relative threats posed by each. Information Request tfnder Section 104(e)(2) ofCERCLA, 42 U.S.C. § 9604(e)(2), U.S. EPA has broad information gathering authority which allows U.S. EPA to require persons to furnish information or documents relating to: (A) The identification, nature, and quantity of materials which have been or are generated, treated, stored, or disposed of at a vessel or facility, or transported to a vessel or facility. (B) The nature or extent of a release or threatened release of a hazardous substance or pollutant or contaminant at or from a vessel or facility. (C) Information relating to the ability of a person to pay for or to perform a cleanup. While EPA seeks your cooperation in this investigation, compliance with the Information Request is required by law. Please note that false, fictitious, or fraudulent statements or representations may subject you to civil or criminal penalties under federal law. Section 104 of CERCLA, 42 U.S.C. § 9604, authorizes EPA to pursue penalties for failure to comply with that section or for failure to respond adequately to requests for submissions of required information. Your responses to EPA's March 2012 Information Request require follow-up. In issuing this information request, U.S. EPA expressly reserves its authority to seek complete and accurate 2 �responses to the March 2012 Information Request, and to exercise its authority to request civil penalties as appropriate. Some of the information EPA is requesting may be considered by you to be confidential. Please be aware that you may not withhold the information upon that basis. If you wish EPA to treat the information confidentially, you must advise . EPA of that fact by following the procedures outlined in Attachment A, including the requirement for supporting your claim for confidentiality. • If you have information about other parties who may have information which may assist the Agency in its investigation of the Site or may be responsible for the contamination at the Site, that information should be submitted within the time frame noted above. This Information Request is not subject to the approval requirements of the Paperwork Reduction Act of 1995, 44 U.S.C. § 3501 et seq. Instructions on how to respond to the questions in Attachment B to this document are described in Attachment A. Your response to this Information Request should be mailed to: U.S. Environmental Protection Agency Valerie Mullins, Enforcement Specialist Emergency Enforcement & Support Section, SE-SJ 77 West Jackson Boulevard Chicago, Illinois 60604-3590 If you have additional questions about the history of the Site, the nature of the environmental conditions at the Site, or the status of cleanup activities, please contact Michael Berkoff, Regional Program Manager at (312) 353 8983. However, if you have specific questions about the Information Request, please contact Valerie Mullins, Enforcement Specialist at (312) 3530324. Legal questions may be addressed to Thomas Williams, Regional Counsel at (312) 8860814. We appreciate and look forward to your prompt response to this Information Request. Sincerely, Joan Tanaka, Chief Remedial Response Branch# 1 Enclosures 3 �cc: John Byl, Esq. Warner, Norcross & Judd LLP 900 Fifth Third Center 111 Lyon Street N. W. Grand Rapids, Michigan 49503 Kathleen Shirey, Acting Director MDEQRRD P.O. Box 30426 Lansing, MI 48909-7926 Susan Leeming MDEQRRD P.O. Box 30426 Lansing, MI 48909-7926 4 �Attachment A Information Request to Wolverine \Vorldwide, Inc. Instructions 1. Answer Every Question Completely. A separate response must be made to each of the questions set forth in this Information Request. For each question contained in this letter, if infom1ation responsive to this Inf01mation Request is not in your possession, custody, or control, please identify the person(s) from whom such infonnation may be obtained. 2. Number Each Answer. Precede each answer with the corresponding number of the question and the subpart to which it responds. 3. Provide the Best Information Available. Provide responses to the best of Respondent's ability, even if the information sought was never put down in writing or if the written documents are no longer available. You should seek out responsive information from current and former employees/agents. Submission of cursory responses when other responsive information is . available to the Respondent will be considered non-compliance with this Information Request. 4. Identify Sources of Answer. For each question, identify (see Definitions) all the persons and documents that you relied on in producing your answer. 5. Continuing Obligation to Provide/Correct Information. If additional information or documents responsive to this Request become known or available to you after you respond to this Request, EPA hereby requests pursuant to Section 104(e) of CERCLA that you supplement your response to EPA. 6. Confidential Information. The information requested herein must be provided even though you may contend that it includes confidential infom1ation or trade secrets. You may assert a confidentiality claim covering part or all of the infom1ation requested, pursuant to Sections 104(e)(7)(E) and (F) of CERCLA, 42.U.S.C. i i 9604(e)(7)(E) and (F), and Section 3007(b) of the Resource Conservation and Recovery Act (RCRA), 42 U.S.C. i 6927(b), and 40 C.F.R. i 2.203(b). If you make a claim of confidentiality for any of the information you submit to EPA, you must prove that claim. For each document or response you claim confidential, you must separately address the following points: A- 1 �1. the portions of the information alleged to be entitied to confidential treatment; 2. the period ohime for which confidential treatment is desired (e.g., until a certain date, until the occurrence of a specific event, or permanently); 3. measures taken by you to guard against the undesired disclosure of the information to others; 4. the extent to which the information has been disclosed to others; and the precautions taken in connection therewith; 5. pertinent confidentiality determinations, if any, by EPA or other federal agencies, and a copy of any such determinations or reference to them, if available; and 6. whether you assert that disclosure of the information would likely result in substantial harmful effects on your business' competitive position, and if so, what those hannful effects would be, why they should be viewed as substantial, and an explanation of the causal relationship between disclosure and such harmful effects. To make a confidentiality claim, please stamp or type "confidential" on all confidential responses and any related confidential documents. Confidential portions of otherwise non-confidential documents should be clearly identified. You should indicate a date, if any, after which the information need no longer be treated as confidential. Please submit your response so that all non-confidential information, including any redacted versions of documents, is in one envelope and all materials for which you desire confidential treatment are in another envelope. All confidentiality claims are subject to EPA verification. It is important that you satisfactorily show that you have taken reasonable measures to protect the confidentiality of the information and that you intend to continue to do so, and that it is not and has not been obtainable by legitimate means without your consent. Information covered by such claim will be disclosed by EPA only to the extent permitted by Section 104(e) of CERCLA. If no such claim accompanies the information when it is received by EPA, then it may be made available to the public by EPA without further notice to you. 7. Disclosure to EPA Contractor. EPA may disclose any infonnation that you submit in response to this Information Request to authorized representatives of the United States, pursuant to 40 C.F.R. i 2.3 l0(h), even if you assert that all or part of it is confidential business infom1ation. Please be advised that EPA may disclose all responses to this Info1mation Request to one or more of its private contractors for the purpose of organizing and/or analyzing the information contained in the responses to thi s Information Request. If you are submitting information that you assert is entitled to treatment as confidential business information, you may A-2 �comment on thi s intended disclosure within fourteen (14) days of receiving this Infonnation Request. 8. Personal Privacy Information. Personnel and medical files, and similar files , the disclosure of which to the general public may constitute an invasion of privacy, should be segregated from your responses, included on separate sheet(s), and marked as "Personal Privacy Information." 9. Objections to Questions. If you have objections to some or all the questions within the Information Request letter, you are still required to respond to each of the questions. Definitions The following definitions shall apply to the following words as they appear in this Information Request. 1. The te1m "arrangement" means every separate contract or other agreement between two or more persons, whether written or oral. 2. The term "documents" includes any written, recorded, computer-generated, or visually or aurally reproduced material of any kind in any medium in your possession, custody, or control, or known by you to exist, including originals, all prior drafts, and all non-identical copies. 3. The te1m "hazardous substance" shall have the same definition a:s that contained in Section 101(14) ofCERCLA, and includes any mixtures of such hazardous substances with any other substances, including mixtures of hazardous substances with petroleum products or other nonhazardous substances, or pollutants or contaminants. 4. The term "identify" means, with respect to a natural person, to set forth: (a) the person's full name; (b) present or last known business and home addresses and telephone numbers; (c) present or last known employer (include full name and address) with title, position or business. 5. With respect to a corporation, partnership, or other business entity (including a sole proprietorship), the term "identify" means to provide its full name, address, and affiliation with the individual and/or company to whom/which this request is addressed. 6. The term "material" or "materials" shall mean any and all objects, goods, substances, or matter of any kind, including but not limited to wastes. A-3 �7. The tem1 "person" shall include any individual, firn1, unincorporated association, partnership, corporation, trust, or other entity. 8. The term "pollutant or contaminant" shall include, but not be limited to, any element, substance, compound, or mixture, including disease-causing agents, which after release into the environment will or may reasonably be anticipated to cause death, disease, behavioral abnormalities, cancer, genetic mutation, physiological malfunctions (including malfunctions in reproduction) or physical deformations; except that the term "pollutant or contaminant" shall not include petroleum. The tem1 "pollutant or contaminant" shall include that family of chemical compounds commonly known as per- and polyfluor alkyl substances or "PF AS," including perfluorooctane sulfonic acid or "PFOS," and waste Scotchgard.™ 9. The term "real estate" shall mean and include, but not be limited to the following: land, buildings. a house, dwelling place, condominium, cooperative apartment, office or commercial building, including those located outside the United States. 10. The term "release" shall mean any spilling, leaking, pumpiug, pouring, emitting, emptying, discharging, injecting, escaping, leaching, dumping, or disposing into the environment, including the abandonment or discharging of barrels, containers, and other closed receptacles containing any hazardous substance or pollutant or contaminant. 11. The term "House Street Site" shall mean the former waste disposal area located at and adjacent to 1855 House Street, Belmont, Michigan. 12. The term "Tannery Site" shall mean the former Wolverine tannery located at 123 N. Main Street, Rockford, Michigan, and adjacent areas at which waste leather from Wolverine' s processes was placed. 13. The tenn "waste" or "wastes" shall mean and include trash, garbage, refuse, by-products, discarded off-specification products and raw materials, solid waste, hazardous waste, hazardous substances, and pollutants or contaminants, whether solid, liquid, or sludge, including but not limited to containers for temporary or permanent holding of such wastes. 14. The term "you" or "Respondent" shall mean Wolverine Worldwide, Inc., the company to whom this information request is addressed. A-4 �Attachment B Wolverine Worldwide, Inc. Requests A. General Requests 1. Identify all persons consulted in the preparation of the answers to these Information Requests. 2. Identify all documents consulted, examined, or referred to in the preparation of the answers to these Requests, and provide copies of all such documents. 3. If you have reason to believe that there may be persons able to provide a more detailed or complete response to any Information Request or who may be able to provide additional responsive documents, identify such persons. 4. List all EPA Identification Numbers of the Respondent and EPA or state identification numbers of any areas Respondent used for waste storage or waste disposal in Rockford, Michigan, and within a 70-mile radius of Rockford, Michigan. If there are no identification numbers for such areas, provide their addresses. 5. Identify the acts or omissions of any persons, other than your employees, contractors, or agents, that may have caused the release or threat of release of hazardous substances, pollutants, or contaminants, and damages resulting therefrom in Rockford, Michigan, and within a 70-mile radius of Rockford, Michigan. 6. Identify all persons having knowledge or information about the generation, transportation, treatment, disposal, or other handling of hazardous substances, pollutants or contaminants by you, your contractors, or by prior owners and/operators in Rockford, Michigan, and within a 70-mile radius of Rockford, Michigan. 7. Provide the correct name and addresses of your domestic (i.e., in United States) plants, facilities, and other buildings or structures where Respondent carried out its manufacturing, waste treatment, and waste accumulation and waste disposaVoperations prior to January 1, 2012 (excluding locations where ONLY administrative and clerical or office work was performed). 8. If available, provide a schematic diagram or flow chart that fully describes and/or illustrates the Respondent's operations at its facilities located in Rockford, Michigan and within a 70-mile radius of Rockford, Michigan. 9. Provide all Resource Conservation and Recovery Act (RCRA) Identification Numbers with associated site addresses issued to Respondent by EPA or a state for Respondent's operations. �10. Provide copies of any National Pollutant Discharge Elimination System (NPDES) pem1its issued for facilities owned and/or operated by Respondent for the last ten years the facilities were in operation. 11. Provide all sampling analytical results for the media identified in this request, in Microsoft Excel® fonnat where possible, including the location from which the sample was taken, the media of the sample, the date the sample was taken, the date the sample was analyzed, the analytical method used, the laboratory that performed the analysis, and the resulting constituent concentrations. Please also provide all laboratory reports for these samples in searchable portable digital format (pdf). B. Questions Regarding the Operations and Waste Practices at the Facility Located at 181 North Main Street, Rockford, Michigan (Tannery Site) 12. Provide a description of Respondent's operations at the Tannery Site, including: a. the dates such-operations commenced and concluded; and b. the types of work performed at each location on the premises at the Tannery Site, including but not limited to the industrial, chemical, or institutional processes undertaken at each location. Include in your response the tanning, coloring and finishing activities identified in your May 2012 Information Request Response to EPA. 13. Identify and describe the points in your manufacturing process at which Scotchgard™, or water proofing, or stain resistant, or other Per/Polyfluoroalkyl Substances (PF AS)containing coatings was or were applied to animal hides, or leather, or synthetic materials, or finished products (for example, whether coating was applied to raw leather or hides or synthetic materials before such material was cut for creating products such as shoes and boots, or after products were created). If the point of application changed over time, please provide dates of such changes and what changes were made. 14. Describe the process or method by which Scotchgard™, or water proofing, or stain resistant, or other PFAS-containing coatings was or were applied to animal hides or leather, or synthetic materials or finished products, e.g., by roller, spray applicator, etc. If the process or method of application changed over time, please provide dates of such changes and what changes were made. 15. List the types of raw materials and coatings used in Respondent's former operations at the Tannery Site, including the products and/or materials manufactured, recycled, recovered, treated, or otherwise processed in these operations. 16. Provide copies of Material Safety Data Sheets (MSDS) for materials used in Respondent's operations at the Tannery Site that were not provided in your May 2012 Information Request Response to EPA. 2 �17. For each type of waste (including by-products) from Respondent's operations at the Tannery Site, including but not limited to all liquids, sludges, and solids, provide the following infonnation: a. b. c. d. e. f. its physical state; its nature and chemical composition; its color; its odor; the approximate monthly and annual volumes of each type of waste (using such measurements as gallons, cubic yards, pounds, etc.); and the dates (beginning and ending) during which each type of waste was produced by Respondent's operations. 18. Provide any waste characterization determinations, including any analytical information documented, for any waste stream generated from Respondent's operations at the Tannery Site identified your response to question 15, above. 19. Identify which part of Respondent's operations at the Tannery Site generated each type of waste, including but not limited to wastes resulting from spills of liquid materials and wastes generated by cleaning and maintenance of equipment, inventory cleanout, offspecification determined wastes, and machinery. 20. Describe how process wastes generated at the Tannery Site, including non-liquid wastes, scrap leather and animal hide, scrap synthetic materials, off-specification product, byproducts, floor sweepings, scrap metal, waste dyes, degreasers, parts cleaners, sludges (including waste water treatment and air pollution control sludges), rags and wipes, used oil, and any waste streams that were generated by and received from any off-site source, were gathered, stored and treated pending disposal. Include in your response: a. any practices, if any, for segregating Scotchgard™, or water proofing, or stain resistant, or other PF AS-containing coatings from all other wastes; b. for the period beginning with the operation of the wastewater treatment plant, a description of how all process wastes were conveyed to that plant; and c. information regarding waste gathering, storing and treatment practices that pre-date installation of the wastewater treatment plant. 21. With respect to the placement of scrap leather, or animal hide scrap synthetic material, or off-specification product on or in soils and sediments at and adjac_ent to the Tannery Site, provide the following information: a. during what period(s) of operations at the Tannery Site did such placement occur, and b. had any such scrap leather, animal hide, or scrap synthetic material or offspecification product been treated with or received application of Scotchgard™, or water proofing, or stain resistant, or other PF AS-containing coatings before such placement? 3 �22. Describe the methods used to clean up spills of liquid or solid materials during Respondent's operations at the Tannery Site, including but not limited to: a. b. c. d. the types of materials spilled in Respondent's operations; the materials used to clean up those spills; the methods used to clean up those spills; and where the materials used to clean up those spills were disposed of. 23. Describe the cleaning and maintenance of the equipment and machinery involved in your operations, including but not limited to: a. b. c. d. the types of materials used to clean and maintain this equipment/machinery, the monthly or annual quantity of each such material used, the disposition of those materials used in cleaning equipment, and where the materials are/were disposed of. 24. For the period predating and following the construction and operation of the wastewater treatment plant, describe how each type of waste generated at the Tannery Site was accumulated prior to disposal, recycling, sale or off-site transport, including: a. the type of container in which each type of waste was placed and/ or stored; and b. where each type of waste was accumulated or stored. 25. Was there ever a spill, leak, release or discharge of hazardous materials, hazardous substances, pollutants or contaminants into any subsurface disposal system or floor drain inside or under the building(s) at the Tannery Site? If the answer to the preceding question is anything but an unqualified "no," identify: a. b. c. d. e. f. g. where the disposal system or floor drains were located; when the disposal system or floor drains were installed; whether the disposal system or floor drains were connected to pipes; where such pipes were located and emptied; when such pipes were installed; how and when such pipes were replaced, or repaired; and whether such pipes ever leaked or in any way released hazardous substances, pollutants or contaminants into the environment. 26. Did any leaks, spills, pumping, dumping, pouring, injecting, emptying, disposing or releases of hazardous materials, hazardous substances, pollutants or contaminants occur on the Tairnery Site when such materials were being: a. b. c. d. delivered by a vendor; stored; treated; or transferred to an agent or contractor for disposal. 4 �Include with your response copies of any documents that you have that provide information regarding such releases, and persons' names and last known addresses who may have knowledge of such information. 27. Provide any release reports that you have made pursuant to Section 103(a) of CERCLA and Section 304 of the Emergency Planning and Community Right-to-Know Act (EPCRA) to any local, state or federal agency for releases of hazardous materials, hazardous substances, pollutants or contaminants at the Tannery Site. 28. Was a state or federal Clean Air Act installation or operation permit issued for any area or source at the Tannery Site? If so, please provide a copy of the most recent one. 29. Identify: a. any air pollution controls attached to each process at the Tannery Site, including the date the control started operating; common name of the equipment; the size of the equipment (for example CFM of a baghouse); the control efficiency; and the manufacturer of the equipment; and b. all points in the Tannery Site's production process that potentially created air emissions of Scotchgard™, or water proofing, or stain resistant, or other PFAScontaining coatings, and the specific air pollution control associated with them, if any. 30. Provide copies of the following air reports, pertaining to operations of the Tannery Site, for the last ten years the Tannery Site was in operation: a. excess emissions reports; b. emissions inventory reports; c. variances from permit limits or regulatory requirements, or permit exemptions issued by a regulatory agency; and d. any other reports submitted for air pollution compliance purposes. 31. Identify all individuals who had responsibility for Respondent's environmental matters at the Tannery Site, e.g. , responsibility for the disposal, treatment, storage, recycling, or sale of Respondent's wastes, and for each such individual, provide his/her: a. b. c. d. e. f. job title; duties; period he/she performed those duties; his/her supervisor(s); his/her current position or the date of resignation; and the nature of the information he/she possesses or possessed regarding Respondent's waste management practices at the Tannery Site. 5 �32. Describe the containers used to take each type of waste from the Tannery Site operation, including but not limited to: a. the type of container (e.g. 55-gallon drum, roll-off box, etc.); b. the colors of the containers or other identifying feature such as any distinctive stripes or other markings on them; c. any labels or writing on those containers (including the content of those labels); d. whether those containers were new or used; and e. if those containers had previously been used, a description of that prior use. 33. For each type of waste from the Tannery Site, describe Respondent's contracts, agreements, or other anangements for its disposal, treatment, or recycling, and provide a copy of such contracts and other documents reflecting such agreements or arrangements. 34. Identify all entities and individuals who picked up waste from the Tannery Site or who otherwise transported the waste away from Respondent's operations at the Tannery Site. Include any individuals who were Respondent's employees and the names of any entities who were agents or contractors, and provide any documents that provide information regarding the dates, volumes, the nature of the materials and any location for disposal or treatment of those materials that were arranged for or transported for disposal from the Tannery Site. 35. Apart from the Tannery Site buildings' demolition in 2009-2010, has soil ever been excavated and stored at or removed from the Site? Unless the answer to the preceding question is anything besides an unequivocal "no," identify: a. b. c. d. e. f. g. h. 1. amount of soil excavated; the location of excavation; manner and place storage of excavated soil; dates of soil excavation; identities of persons or entities who excavated soil; reasons for soil excavation; all results of analysis of samples of soils excavated; whether soils contained hazardous substances, pollutants or contaminants; and results of analysis of post-excavation samples taken from area that was excavated. C. Questions Regarding Other Rockford, Michigan Operations and Waste Practices 36. For any facilities in addition to the Tannery Site are also located in Rockford or Kent County, Michigan, describe any manufacturing, processing, and product finishing activities at each such facility, but do not include in your response any locations used solely for office, clerical and other business administrative activities, or for storage of finished products pending sale. 37. Did any manufacturing, processing or finishing activities at such facility or facilities 6 �identified in your response to the proceeding request involve the generation, treatment, accumulation or storage pending disposal, of wastes that contained or may have contained ScotchgardTM, or water proofing, or stain resistant or other PF AS-containing coatings? 38. If your answer to the preceding question is affinnative, then identify: a. when and where in the process the Scotchgard™, or water proofing, or stain resistant or other PFAS-containing coatings were applied; b. a description of all the waste streams, \Vhether or not they included Scotchgard™, or water proofing, or stain resistant or other PF AS-containing coatings; c. how such waste streams were treated, stored, accumulated and disposed of; d. if disposed of off-site, where such disposal occurred; and e. whether disposal ever occurred at the same locations at which Respondent disposed of, or arranged for the disposal of, wastes from the Tannery Site. 39. Provide copies of the most recent state or federal Clean Air Act installation or operation permits issued for any area or source at any facility owned and/or operated by Respondent in the vicinity of Rockford, Michigan. In addition, identify: a. any air pollution controls attached to each process at each facility for which a Clean Air Act permit was issued, including the date the control started operating; common name of the equipment; the size of the equipment (for example CFM of a baghouse); the control efficiency; and the manufacturer of the equipment; and b. •all points in production process at each facility for which a Clean Air Act permit was issued that potentially created air emissions of Scotchgard™, or water proofing, or stain resistant, or other PF AS-containing coatings, and the specific air pollution control associated with them, if any. D. Questions Regarding the House Street Site 40. Describe the nature of your activities or business at the House Street Site, with respect to, processing, storing, treating, disposing, or otherwise handling hazardous substances, pollutants or contaminants. 41. State the dates during which you owned, operated, and/or leased the House Street Site, and provide copies of all documents evidencing or relating to such ownership, operation, or lease arrangement (e.g., deeds, leases, etc.). 42. Provide information about the House Street Site, including but not limited to the following: a. b. c. d. Prope1iy boundaries, including a written legal description; Location of underground utilities (telephone, electrical, sewer, water main, etc.); Surface structures (e.g., buildings, tanks, etc.); Ground water wells, including drilling logs; 7 �e. Storm water drainage system, and sanitary sewer system, past and present, including septic tank(s), subsurface disposal fie ld(s), and other underground structures; and where, when and how such systems are emptied; f. any and all additions, demolitions, or changes of any kind on, under, or about the Site, to its physical structures, or to the property itself (e.g., excavation work); and any planned additions, demolitions, or other changes to the House Street Site; and g. All maps and drawings of the Site in your possession. 43. Identify all past and present solid waste units (e.g., waste piles, landfills, surface impoundments, waste lagoons, waste ponds or pits, tanks, container storage areas, etc.) on the House Street Site. For each such solid waste unit identified, provide the following information: a. The unit's boundaries and the location of all known solid waste units whether currently in operation or not; b. The type of unit (e.g., storage area, landfill , waste pile, etc.), and the dimensions of the unit; c. The dates that the unit was in use; d. The purpose and past usage (e.g., storage, spill containment, etc.); e. The quantity and types of materials (hazardous substances, pollutants, contaminants and/or any other chemicals) located in each unit; f. Any data resulting from sampling of the materials in the unit; and g. The construction (materials, composition), volume, size, dates of cleaning, and condition of each unit. h. If the unit is no longer in use, how was such unit closed and what actions if any were taken to prevent or address potential or actual releases of waste constituents from the unit. 1. If any media were sampled during closure, provide all data collected relating to materials in that unit. J. If material was ever removed from a unit, what is the disposition of that material? Was it transported or moved to a different unit at the House Street Site or to a unit at another location? 44. Identify the House Street Site' s current owner and that entity's or individual's relationship to Respondent, if a~y. 45. Provide any information indicating in any way that a hazardous substance, pollutant, or contaminant, was released or threatened to be released at the House Street Site during the period prior to which Respondent owned, operated and/or leased the House Street Site. a. If an actual release occurred, please describe any and all response activities initiated to address the release. 46. Provide any information indicating in any way that hazardous substances, pollutants or contaminants were placed at the House Street Site followin g the date upon which 8 �Respondent, its agents or contractors ceased placing or disposing wastes at the House Street Site. 4 7. Provide copies of all local, state, and federal permits ever grarited for waste treatment, storage or disposal at the House Street Site or any part thereof (e.g., RCRA permits, NPDES permits, etc.). 48. Did the House Street Site ever have "interim status" under RCRA? 49. Did the Respondent ever file a notification of hazardous waste activity regarding the House Street Site under RCRA? If so, provide a copy of such notification. E. Questions Regarding Wolverine Disposal Sites other than the House Street Site 50. In addition to the House Street Site, identify all locations, by address and owner, where Respondent disposed of wastes that contained Scotchgard™ or other PF AS-related compounds, regardless of date. Include in your answer the results of any analyses you or your contractors or agents performed or arranged to have performed on groundwater, drinking water, surface water, soils and sediments at all such locations. F. Questions Regarding Respondent's Current Response Actions in Rockford, Michigan 51. Provide all reports, information, sample analysis, laboratory results, or data related to soil, sediment, sludges, water (ground and surface), drinking water, air quality and geology/hydrogeology prepared by you or at your direction regarding the House Street Site. Include all documents containing analysis or interpretation of such data, and any past and current aerial photographs of the House Street Site. 52. Provide a copy of all workplans prepared by you or at your direction that identify sampling and analytical procedures to be observed or employed by your contractors, including laboratories, for sampling of any medium (soil, groundwater, etc.) taken or to be taken at or in the vicinity of Rockford, Michigan. 53. Provide a copy of all figures or maps prepared by you or at your direction that show the locations for samples collected or to be collected at the House Street Site and areas in the vicinity of Rockford, Michigan by you or your contractors. Additionally, explain how these sampling locations have been selected. 54. Provide a copy of all figures or maps prepared by you or at your direction that show the locations or addresses at which owners or tenants or property in the vicinity of Rockford, Michigan have been provided bottled water, or have had water filters installed, or have received any other form of alternate drinking water. 55. Identify the constituents for which you have performed or arranged for the performance of sample analysis for samples taken from the House Street Site and sampling locations in its vicinity in each of the following media: 9 �a. Drinking water b. Groundwater C. Surface water d. Soil e. Sediments f. Sludges 56. Describe any community engagement activities you have conducted regarding contamination at in the vicinity of Rockford, Michigan. Provide copies of documents or correspondence provided to residents regarding contamination at the House Street Site and/or PF AS drinking water contamination in the vicinity of Rockford, Michigan. 57. Identify any areas or specific locations in addition to the House Street Site and its vicinity at which you or your contractors are sampling and testing residential drinking water. Include a map in your response that shows these areas, and indicate in your response how these areas or locations were or are being selected (e.g., whether they are adjacent to or near other waste disposal areas, are in the vicinity of air deposition fall out, etc.). 58. Identify all public water systems as defined in 40 CFR § 141.2 (community water systems, non-community water systems, etc.) in the vicinity of the House Street Site, the Tannery Site, other manufacturing facilities, or other locations in Kent County, Michigan that you have sampled for Scotchgard™ or other PF AS-related compounds. Indicate in your response: a. which ones were tested and the results of sampling analysis; b. whether any public water systems declined to allow such sampling. 59. Indicate whether the laboratory or laboratories conducting the analyses on water samples is (are) using EPA Method 53 7 or a modified version thereof. If the latter, indicate what modifications have been made to EPA Method 537, and identify how these changes affect data quality. 60. Indicate whether you are performing or arranging for perfom1ance ofre-testing or confirmation sampling for residential well water where analytical results show PFASrelated compounds, singly or in combination, in concentrations at or near 70 parts per trillion (ppt) and, if so, the concentration that is being used for determining whether to collect re-testing or confirmation samples. 61. With respect to water filters you or entities or persons acting at your direction have installed in residences or public water supplies identify: a. The filters ' designer, and whether that person or entity has a professional engineer's license issued by the State of Michigan; b. The identities of persons or entities that are installing the filters, and whether they have engineer's license issued by the State of Michigan or other qualifications; 10 �c. The methods by which the persons or entities installing the filters do this \Vork, including whether there is sampling before and after installation and if so, the analytical parameters, evaluation of water pressure, water flow in piping, gathering information about water usage; d. Whether anything is provided or installed in addition to the filter (e.g., treatment media such as chlorine); e. Whether residences given filters are given contact infonnation to report issues or pose questions; f. Any releases or other documents residence occupants are given to review and/or sign; and g. A description of how such filters are to be maintained, and who performs such maintenance. 11 �Artifact 52 �UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 77 W. JACKSON BLVD CHICAGO, IL 60604 MEMORANDUM Subject: Enforcement Action Memorandum - Determination of Threat to Public Health and the Environment at the Wolverine Worldwide Tannery and House Street Disposal Site, Rockford and Plainfield Township, Kent County, Michigan (Site ID # C593) From: Jeffrey W. Kimble, On-Scene Coordinator Emergency Response Branch 1 Emergency Response Section 2 Through: Jason H. El-Zein, Chief Emergency Response Branch 1 To: Robert A. Kaplan, Acting Director Superfund Division I. PURPOSE The purpose of this Action Memorandum is to document the detennination of an imminent and substantial threat to public health and the environment posed by hazardous waste and substances, and to authorize expenditures up to $940,139, at the Wolverine Worldwide Tannery and House Street Disposal Site in the City of Rockford and Plainfield Township, Kent County, Michigan (Site). The Site is not on the National Priorities List (NPL), but a CERCLA Preliminary Assessment was conducted in 2012 (SEMS 434898) and the Site scored high enough to be listed. Subsequently, the State of Michigan (State) asked that it not be listed and that instead, authority for the Site be transferred to Michigan for action under the State's "other cleanup authority." II. SITE CONDITIONS AND BACKGROUND Name: Wolverine Worldwide Tannery and House Street Disposal Superfund Site ID C593 CERCLIS ID: MIN000510613 Site Location: 123 North Main Street, Rockford, 49341, and 1855 House Street, Plainfield Township, 49306, Kent County, Michigan Lat/Long: 43.1216003, -85.5595355 and 43.107618, -85.619421 RCRAID: NIA State ID: None Potentially Responsible Parties (PRPs): Wolverine Worldwide, Inc. �NPL Status: Non NPL Category: CERCLA Time-Critical A. Site Description 1. Removal site evaluation Operations on the Wolverine Worldwide, Inc. (Wolverine) former Tannery property (Tannery Property) in Rockford, Kent County, Michigan, began in approximately 1903 when G.A. Krause and his sons built a shoe factory on the northern portion of the property. The Tannery Property operations began on the southern portion of the property in approximately 1908 when Mr. Krause and his sons built the tannery to supply their shoe factory with leather. The Tannery Prope1ty used chromium as a means to tan its hides. Operations at the Tannery Prope1ty included the tanning and coloring of hides for use mainly in shoes. Waste disposal practices in the early years of the tannery's operation are not known. Wolverine constructed a wastewater treatment plant (WWTP) at the Tannery Property sometime between 1950 and 1960. Some sludge from plant operations is known to have been disposed of in a gravel pit located several miles south of the Tannery Property. Anecdotal reports from former company workers indicate that some sludge may have been spread on at least two separate farms in the area as fertilizer. Wolverine operated a disposal site at 1855 House Street N.E. in nearby Plainfield Township (House Street Disposal Area), at which WWTP sludge and, potentially, other tannery wastes were disposed. In 2017, additional dump areas on State-owned property next to the House Street Disposal Area and another area at the intersection of House Street N .E. and Imperial Pine Drive were discovered and have been shown to have tannery scraps, drums and other waste present. Tannery operations ceased in approximately 2009 and the buildings on the Tannery Property were demolished in 2010 and 2011. The main plant on the Tannery Property historically encompassed an area of approximately 15 acres. The Tannery Property historically consisted of the former tannery operations including: tannery buildings, the on-site WWTP, warehouse and storage buildings, and an office building. In 2012, the Michigan Department of Environmental Quality (MDEQ) and EPA completed a CERCLA Pre-Assessment Report (SEMS 434898) for the Tannery Property. 2. Physical location The Site consists of two locations: The Tannery Property, located at 123 North Main Street in Rockford, Michigan 49341, and the House Street Disposal Area, located at 1885 House Street N.E. in Plainfield Township, Michigan 49306 (Attachment 3). The Tannery Property is located at 123 North Main Street on the north end of the downtown district of the City of Rockford, Kent County, Michigan (T.9N., R.11 W., section 36, Attachment 3). The location coordinates for the former main tannery building are latitude 43.123056° and longitude -085.560278°. The main plant site historically encompassed an area of approximately 15 acres. Commercial businesses are located to the south of the Tannery Property, residences are located to the east and north, and the Rogue River and residences are located to the west. A �recreational trail, the White Pine Trail, runs through the western portion of the Tannery Property along the bauk of the Rogue River (SEMS 434898). The former tannery operations included: tannery buildings, an on-site WWTP, warehouse and storage buildings, and an office building. The company constructed the WWTP sometime between 1950 and 1960. Some sludge from plant operations is known to have been disposed of in a gravel pit located several miles south of the Tannery Property. Tannery operations ceased in 2009 and the buildings on the Tannery Property were demolished in 2010 and 2011 (SEMS 434898). Reportedly, Wolverine historically disposed of byproducts from its leather tanning operations at the House Street Disposal Area portion of the Site, specifically the area located at 1855 House Street N.E. in Plainfield Township, which was a licensed disposal facility authorized by the State of Michigan. This disposal area is in an area of mixed rural and residential land use. Two additional dump areas, historically part of the House Street Disposal Area, are located adjacent to the House Street Disposal Area and are currently undergoing a voluntary removal action by Wolverine at the request of MDEQ. Sampling at the two additional areas adjacent to the current House Street Disposal Area has identified hazardous substances and likely hazardous waste identified as material historically dumped by Wolverine (SEMS 937808). An Environmental Justice (EJ) analysis for the Site was conducted. Screening of the surrounding area used Region S's EJ Screen Tool, which applies the interim version of the national EJ Strategic Enforcement Assessment Tool (EJSEAT). Region 5 has reviewed environmental and demographic data for the area surrounding the Site and has determined there is a low potential for EJ concerns at this location. 3. Site Characteristics The Tannery Property consists of an approximately 15-acre property in a mixed residential/commercial area. The Tannery Property is situated on the north end of the commercial downtown area of the City of Rockford. Commercial businesses are located to the south of the Tannery Property, residences are located to the east and north, and the Rogue River and residences are located to the west. A recreational trail, the White Pine Trail, runs through the western portion of the Tannery Property along the bank of the Rogue River. Rum Creek also flows through the property. The Rogue and Grand Rivers are used quite extensively for recreation and fishing. The City has a canoe/kayak launch on the east bank of the river just downstream of the Tannery Property. The City also just completed construction of a boardwalk with fishing platforms on the western bank of the river opposite the Tannery Property. Numerous environmentally sensitive resources are located in close proximity to the Tannery Property. The Tannery Property is only partially fenced, allowing public access to certain areas. The near-surface geology in the area of the Tannery Property consists of glacial outwash sand and gravel deposits and end moraine complexes. These deposits occur as fluvial terraces along the Rogue River with the end moraine complexes flanking the river and underlying the terrace deposits. The terrace deposits range in thickness from approximately 10 to 60 feet while the moraine deposits can exceed 300 feet in thickness. The bedrock geology of the area consists of �the Red Beds and Grand River Formation. The depth to bedrock in the Tannery Property area ranges from approximately 215 to over 320 feet. 4. Release or threatened release into the environment of a hazardous substance, or pollutant or contaminant Tannery Property: During the 2010 and 2011 demolition activities on the Tannery Property, some environmental concerns were noted, and Wolverine initiated an environmental investigation to assess three areas of concern and evaluate conditions compared to requirements in Pait 201, Environmental Remediation, of the Michigan Natural Resources and Environmental Protection Act, 1994 PA 451, as amended (Part 201). Wolverine installed and sampled three wells and installed five piezometers as part of this work. After reviewing findings from the initial investigation, additional samples were collected from the property and from the Rogue River. This work was done in consultation with the EPA and the MDEQ. In 2011, after consideration of a citizen petition, BPA and MDEQ conducted a CERCLA Preliminary Assessment (PA) of the Tannery Property. PA work was subsequently initiated by MDEQ and occurred concurrently with the Wolverine assessment work. EPA evaluated the data from these assessments. The analytical results were compared to the list of CERCLA hazardous substances at 40 CFR Part 302. Listed hazardous substances (particularly semivolatile organic compounds (SVOC) (referred to as semivolatile organic analytes (SVOA)) and inorganic compounds) were detected at levels above typical background concentrations, and at levels that exceeded applicable State action levels in all soil, groundwater and surface water sediment samples. Assessment results are summarized below by media type. The full CERCLA PA Report is included in the Administrative Record for this action. As a result of the investigations, numerous CERCLA hazardous substances (including VOCsNOAs, SVOCs/SVOAs, and inorganics) (listed per 40 CFR Part 302) were identified in the samples, as detailed below. Soil: Levels detected were compared to Part 201 Non-residential Direct Contact Criteria (NRDCC) and Groundwater Surface Water Interface Protection Criteria (GSIPC). Arsenic (360,000 micrograms per kilogram [ug/kg]), chromium (total) (49,000,000 ug/kg), and lead (930,000 ug/kg) were detected in deep soils at concentrations exceeding NRDCC. Several hazardous substances and/or contaminants were detected in both the deep and surficial soil samples at concentrations exceeding the GSIPC. These include: 1,2-dichlorobenzene (2,300 ug/kg); 1,4-dichlorobenzene (390 ug/kg); fluoranthene (13,000 ug/kg); phenanthrene (11,000 ug/kg); arsenic (360,000 ug/kg); barium (650,000 ug/kg); cadmium (17,000 ug/kg); chromium (total) (49,000,000 ug/kg); hexavalent chromium (17,000 ug/kg); lead (930,000 ug/kg); mercury �(total) (640 ug/kg); selenium (2,200 ug/kg); silver (450 ug/kg); zinc (1,000,000 ug/kg); ammonia (556,000 ug/kg); and cyanide (550 ug/kg) in the deep soils. GSIPC exceedances in the surficial soil samples include: fluoranthene (5,800 ug/kg); phenanthrene (3,600 ug/kg); arsenic (11,000 ug/kg); chromium (total) (180,000 ug/kg); mercury (total) (340 ug/kg); selenium (1,200 ug/kg); silver (150 ug/kg); zinc (210,000 ug/kg); ammonia (316,000 ug/kg); and cyanide (410 ug/kg) The data generated by the soil sampling indicate that there have been releases of contaminants to the soil on the Tannery Property. This is evidenced by contaminant concentrations above sample quantitation limits being more than three times background concentrations. Soil samples collected from the Tannery Property in three known source areas have been shown to be contaminated with elevated levels of several organic and inorganic contaminants. These soils are located at relatively shallow depths but are all in the demolished main plant area, are covered with topsoil, and are partly surrounded by a fence. However, some soils sampled from locations along the recreational trail that were once part of the Tannery Property operational area show elevated levels of organic and inorganic contaminants at or near the surface. This area is not fenced and is accessible to the-general public. The fence is designed to restrict access to the Tannery Property, but because of the shallow groundwater, it does not provide a barrier to waste migration from the Tannery Property. The potential exists for soil contamination in other portions of the main plant area of the Tannery Property based on the former tanning processes at the Property. A complete extent of contamination survey of the former tannery needs to be conducted. Area residents are potentially at risk of direct contact to contaminated soils at the Site. Elevated levels of organic and inorganic contaminants have been detected in the surficial soils along the western side of the Tannery Property along the recreational trail and the bank of the Rogue River. The majority of the Tannery Property where the main plant buildings were located is fenced and has been covered with topsoil. The area along the trail on the western side of the Tannery Property is accessible, and the trail is used regularly by walkers and bikers. Groundwater: Contaminant concentrations of groundwater sample analysis results were compared to Part 201 Residential Drinking Water Criteria (RDWC) and Groundwater Surface Water Interface Criteria (GSIC). Groundwater contaminants that exceed one or both of these criteria, along with their maximum concentrations, are noted below. Samples collected from the three initial wells in 2011 showed arsenic (37 micrograms per liter [ug/1]) and ammonia (20,000 ug/l) at levels elevated above RDWC and GSIC. Additional monitoring wells were installed and sampled by Wolverine as part of a follow up investigation. Exceedances were as follows: Arsenic (30 micrograms per liter [ug/1]), boron (770 ug/1), iron (9,800 ug/1), vanadium �(10 ug/1 ), ammonia (46,000 ug/1 ), chloride (480,000 ug/1 ), and sulfates (500,000 ug/1) were detected at concentrations that exceeded the RDWC. In addition, 4-chloro-3-methylphenol (3 ug/1), arsenic (30 ug/1), chromium (total) (54 ug/1), hexavalent chromium (85 ug/1), ammonia (46,000 ug/1), and cyanide (16 ug/1) were detected at concentrations exceeding GSIC. These results indicate a release of contaminants to the groundwater on the Tannery Property, based on the fact that contaminants likely associated with'tannery process wastes are present in the groundwater samples. No background samples have been collected to date since no background monitoring wells have been installed, but given that these contaminants can be associated with tannery wastes, and the fact that the samples were collected from wells just downgradient of source areas, there is a high likelihood that these contaminants in the groundwater are the result of releases from source areas on the Tannery Property. There is also a likelihood that contaminants from historic operations on the Tannery Property may also be located in other areas of the property that have not been investigated to date. The groundwater in the area of the Tannery Property is vulnerable to contamination from the land surface due to the highly permeable sand and gravel soils that are present. Analysis of groundwater samples collected from the Tannery Property monitoring wells have shown elevated levels of contaminants associated with tannery wastes. Groundwater is used for drinking water within a 4-mile radius of the Tannery Property (the 4-Mile Target Distance Limit (TDL)). Surface Water and Sediment: Sediment contaminant concentrations are also compared to the range of Part 201 Sediment Screening Levels in the table. Sediment contaminants that exceeded at least one of these screening levels are noted in the following paragraph along with their maximum concentration. Contaminants. having a maximum concentration that exceeded all screening levels include: chromium (total) (520,000 ug/kg) and mercury (total) (5,100 ug/kg). Contaminants that had concentrations that exceeded at least one screening level include: fluoranthene (620 ug/kg); pyrene (550 ug/kg); arsenic (16,000 ug/kg); cadmium (1,300 ug/kg); copper (66,000 ug/kg); lead (130,000 ug/kg); and zinc (290,000 ug/kg). The sediment data indicate a release of contaminants above background levels to the surface water pathway. Sediments in the Rogue River have been impacted from contaminants associated with the Tannery Prope1ty. Total chromium, hexavalent chromium, and mercury have been detected in sediment samples at levels elevated above background concentrations. Contaminants from the Tannery Property can migrate to the Rogue River directly; or through Rum Creek as it passes through the Tannery Property; along the western Tannery Property boundary; or through groundwater from the Tannery Property that discharges to the river. The 15-mile TDL includes Rum Creek through the Tannery Property, approximately seven miles of the Rogue River downstream of the Tannery Property, and eight miles of the Grand River downstream of its confluence with the Rogue River. These rivers are used for recreation and fishing. Based on citizen reports to EPA, the area directly next to the tannery on the Rogue River is a known spot for residents to launch boats for recreation, fishing, and an area that children �routinely swim in during summer months. Approximately 14.45 miles of wetlands frontage are also present along the 15-mile TDL along with several documented occmTences of state and federal threatened and endangered species. The Grand River eventually discharges into Lake Michigan outside of the 15-mile TDL. The surface water pathway is a major exposure pathway of concern for this Tannery Property. Surface drainage in the area of the Tannery Property flows either directly into Rum Creek or the Rogue River. The Rogue River eventually discharges into the Grand River approximately seven miles downstream of the Tannery Property. See Figure 7 for the 15-Mile Target Distance Limit Map. Analysis sediment samples collected from the Rogue River adjacent to the Tannery Property showed some elevated levels of inorganic analytes including: arsenic; total chromium; • hexavalent chromium; copper; lead; mercury; and zinc. The Probable Point of Entry (PPE) of contaminants into the surface water pathway is all along Rum Creek as it passes through the Tannery Property and all along the eastern bank of the Rogue River on the west side of the Tannery Property. The furthest downstream PPE is at the southwest corner of the Tannery Property on the bank of the Rogue River. There are no known surface water intakes along the 15-Mile TDL, but the City of Rockford historically operated an intake on the Rogue River downstream of the Tannery Property. Sensitive environmental resources along the 15-mile TDL include: six state threatened species, seven state endangered species, and two federal threatened species. These are all located downstream of the PPE and downstream of where sediment samples were collected. No Human Health or Environmental Health Consult has yet been conducted. After the review of this data, the City of Rockford asked the State of Michigan and EPA to discontinue CERCLA investigations and allow the State to work with Wolverine on a voluntary cleanup plan for the site (SEMS 936833 and 434863). Based on the discussions at the time, EPA and MDEQ agreed to this approach but provided for the process to be reopened as needed (SEMS 434900). House Street Disposal Area: In 2017, waste linked to Tannery Property operations was found at two locations directly adjacent to and historically part of the House Street Disposal Area. According to MDEQ, both of these properties were part of the larger property once used as the House Street Disposal Area, most likely around the l 95Os. One of these properties is now owned by the State of Michigan, Department of Transportation ("MDOT") (the "MDOT Property"). The other property is at the intersection of House Street and Imperial Pine Drive (the "Imperial Pine Drive Property"). Initial investigations on these additional properties identified wastes likely to have been dumped on it from the Tannery Property. Initial surveys revealed that dumping from the Tannery Property occurred along an old service road and next to a ravine that was likely part of the historical footprint of the House Street Disposal Area. The House Street Disposal Area is also adjacent to locations where the highest yet detected per- and polyfluoroalkyl substances (PFAS) compounds have been detected in residential drinking water (SEMS 937808). �MOOT Property: Wolverine's consultant (Rose & Westra/GZA) and a consultant (FTC&H) for a private law firm representing concerned citizens, with staff from MDEQ observing, conducted sampling in October 2017 at the MDOT Prope1ty. During the sampling event at the MDOT Property, FTC&H, accompanied by MDEQ, observed topography and ground conditions that could be consistent with a historic access road extending from the south side of the House Street Disposal Area to an area on the MDOT Property. The observations potentially indicate the past use of the area for trench/buried waste dumping or dumping of solid or liquid waste. These observations have not yet been investigated. Observations identified waste materials, including drums, soils, leather, bricks, glass, and other materials exposed in a ravine on the MDOT Property, on the ravine floor, and buried in the subsurface soils. Trees were observed growing on top of waste materials. By counting the annual growth rings, one tree that was cut down recently was estimated to be approximately 64 years old. A roughly 5-foot thick sequence ofleather waste and soils appearing to be "ash like 11 was observed below the roots of the tree. A clay layer was observed in a ravine side wall at some locations. Drum, waste, and soil removal was conducted by a removal contractor hired by Wolverine. Prior to conducting observations, FTC&H requested chemistry data for waste materials expected to be present at the MDOT Property to assist in preparing a Health and Safety Plan for use by FTCH staff while conducting observation and assessment activities. Rose & Westra/GZA did not provide any existing chemistry data to support FTC&H planned activities at the MDOT Property (SEMS 937808). Based on chemistry data for water samples that were reported for some residential wells in the area, the compounds of concern were interpreted by FTC&H to be Michigan 10 metals, VOCs, and PFAS compounds. FTC&H collected three soil/waste samples from the MDOT Property to provide a general representation of materials present. • • • Sample SS-01 consisted ofred-brown leather shavings that were removed from the side hill excavation. Sample SS-02 consisted of an ash-like material containing some gray silty-sand, some white silty-sand, and some leather fibers that were removed from the side hill excavation. Sample SS-03 consisted of layered tan and brown hard sludge-like or dried-adhesive material that was largely contained within a highly degraded rusted steel drum. Arsenic Samples SS-01, SS-02, and SS-03 contained arsenic at a concentration that exceeded the Part 201 limits for the Statewide Default Background Level (SDBL), the Drinking Water Protection Criteria (DWPC), the Groundwater-Surface Water Interface Protection Criteria (GSIPC), and the Direct Contact Criteria (DCC). Based on these exceedances for arsenic, the soil samples may represent contaminated material that could impact groundwater, surface water, and may cause unacceptable exposure to humans through direct contact with the waste/soil material. Health impacts of unacceptable human exposure to arsenic at the detected concentrations can include increased cancer risk. �Chromium Samples SS-01, SS-02, and SS-03 exceeded the Pati 201 limits for total chromium, when compared to the hexavalent chromium Part 201 criteria, including the SDBL, the DWPC, the GSIPC, and the DCC. The individual samples have not yet been analyzed to determine the actual hexavalent chromium concentrations. The samples have been resubmitted to the laboratory for analysis to determine the hexavalent chromium concentrations. As of the time of this writing, the results have not been received. Given the soil sampling effort conducted as part of this scope of work, it is possible that materials containing higher concentrations of metals than those identified from SS-01 through SS-03 may be or have been present in the waste material at the MDOT Property. Mercury Sample SS-02 exceeded the Part 201 general residential cleanup criteria (GRCC) for mercury including the SDBL, the DWPC, and the GSIPC. Additionally, samples SS-01 and SS-03 exceeded the Part 201 GRCC for the GSIP. Based on these exceedances for mercury, the soil samples may represent contaminated material that could cause impact to groundwater and surface water, at concentrations that may harm humans or aquatic organism through ingestion and direct contact with potentially impacted water, or through bioaccumulation. Also detected in the sample results were: • 1,2,4-Trichlorobenzene, • 1,2,4-Trimethylbenzene, • Acetone, • n-Buytylbenzene, • t-Arnyl methyl ether (TAME), • Toluene, • Xylenes, •PFAS Concentrations of metals, and potentially VOCs, in the soil/waste at the MOOT Property exceed applicable GRCC and represent concerns for human health and the environment. Part 201 exposure limits based on the DWPC, the GSI protection criteria, the DCC, and the Proposed Vapor Intrusion Tier I Screening Levels were exceeded. Additionally, the total chromium concentration observed in SS-02 exceeded the EPA 20x TCLP screening criteria and may represent a hazardous waste by the characteristic of toxicity (SEMS 937808). MDOT Property and Imperial Pine Drive Property Removal: Wolverine's contractor Rose & Westra/GZA collected composite samples from the waste at the MDOT Property and the Imperial Pine Drive Property for disposal profile analysis of the materials prior to off-site disposal at Republic Waste's Ottawa County Farms Landfill (SEMS 937642). Although the waste was classified "non-hazardous" for disposal purposes, there was �Toxicity Characteristic Leaching Procedure (TCLP) Lead was identified at 3 mg/L (3,000 ug/L) in one sample from the Imperial Pine Drive Property. The samples submitted for analysis were composites of at Least 4 (and likely more) different media contained within the areas being excavated and included soil, metal, leather, debris and other materials. This means that preexcavation, any one of these individual components of the composite could have exceeded TCLP Lead for Hazardous Waste in situ if in fact the level of TCLP lead were not ubiquitous throughout all materials. House Street Disposal Area Summary: All future investigations of suspect areas must consider each type of waste independently to determine risk to the public, and not simply collect composite samples for disposal profiling. Site Summarv: Due to the continued presence of hazardous substances at the Tannery Property, and the need for significant further testing at the House Street Disposal Area at which the contaminants present are likely both hazardous wastes and hazardous substances, EPA has determined that the CERCLA Assessment process should be reopened at the Tannery Property, that the House Street Disposal Area be fully assessed, and that appropriate removal and/or remedial actions be initiated at the Site. The Proposed Actions section of this Action Memorandum will discuss the next steps and work to be performed as directed by EPA. 5. NPL status The Site is not on the NPL, but a CERCLA Preliminary Assessment was conducted at the Tannery Property, and EPA notes that based on that assessment, the Site scores high enough to be listed on the NPL. 6. Maps, pictures and other graphic representations Attachment 3 shows the location of the Site, Site features and some previous sample locations. B. Other Actions to Date 1. Previous actions In 2011 and 2012, EPA, MDEQ and Wolverine conducted sampling efforts and a CERCLA Preliminary Assessment was conducted. From 2012 to the present, Wolverine has been conducting voluntary actions and informing MDEQ of its progress in these actions. In 2017, Wolverine and MDEQ undertook extensive work into investigating and remcdiating PF AS contamination in numerous locations, including the Tannery Property, the House Street �Disposal Area, and other locations where Wolverine purportedly dumped or otherwise disposed of waste in the past. 2. Current actions The most current action at the Site has been to address the potentially widespread PFAS contamination in drinking water in the areas associated with waste from the former tannery. This Action Memorandum focuses on CERCLA hazardous substances and develops a comprehensive plan to address the CERCLA hazardous substance and hazardous waste (if and when such wastes are identified) issues at the Wolverine Worldwide Tannery Prope1ty and House Street Disposal Area Site. State and Local Authorities' Roles 1. State and local actions to date MDEQ has been working with Wolverine since 2012 in a Voluntary Action. The Kent County Health Department has been working with MDEQ and Wolverine in the assessment of PFAS contamination in drinking water. 2. Potential for continued State/local response Given the exigency of the situation, the scope of the potential investigations, the discovery of hazardous substances and likely hazardous waste in the MDOT Property and Imperial Pine Drive Property, which are adjacent to and are believed to have been historically part of the House Street Disposal Area, and wastes currently migrating from the Tannery Property to Rum Creek and the Rogue River, neither the state nor the local governments have the resources to conduct a removal action at the Site in a time critical manner. HI. THREATS TO PUBLIC HEALTH OR THE ENVIRONMENT, AND STATUTORY AND REGULATORY AUTHORITIES The conditions remaining at the Site present a substantial threat to the public health or welfare, and the environment, and meet the crite1ia for a time-critical removal action, pursuant to the NCP at 40 C.F.R. § 300.415(b)(2). These criteria include, but are not limited to, the following: Actual or potential exposure to nearby human populations, animals, or the food chain from hazardous substances or pollutants or contaminants. Area residents near the Tannery Property are potentially at risk of direct contact to contaminated soils at that portion of the Site. Slightly elevated levels of organic and inorganic contaminants have been detected in the surficial soils along the w estern side �of the Tannery Property along the recreational trail and the bank of the Rogue River. A portion of the Tannery Property where the main plant buildings were located is fenced and has been covered with topsoil, but rainwater and surface water runoff have been observed leaving this area and entering the creek and river. The area along the trail on the western side of the Tannery Property is accessible and rnnoff has impacted these areas, yet additional sample data is lacking. The trail is used regularly by walkers and bikers. Additionally, the area is purportedly also used by children as a swimming hole in summer months. Sediment and water contamination has been documented in this area. The Tannery Property is contaminated with lead, arsenic, copper, PFAS, hexavalent chrome, ammonia and other hazardous substances. The extent of hazardous substances and waste at this portion of the Site is not properly identified, but contamination exists in the soil and groundwater at this portion of the Site. Groundwater migration of hazardous substances has been documented on site, yet the pathway of groundwater flow between the Tannery Property and the municipal wellfield has not been properly assessed. Storm water may create releases of hazardous substances (or waste if identified) from the Site, as it migrates off-site. Potential exposure through each of these migration pathways could cause imminent endangerment to human health, welfare, or the environment. These pathways need to be fully assessed. The House Street Disposal Area, and adjacent MDOT Property and Imperial Pine Drive Property locations, likely have the same type of hazardous substances and/or wastes from the Tannery Property operations. Trespassers or residents in these areas may have unrestricted access and potentially direct contact with wastes, and potential exposure to human populations and impact threats to the environment exist. The health effects of lead are detailed by the Agency for Toxic Substance and Disease Registry as follows: The effects of lead are the same whether it enters the body through breathing or swallowing. Lead can affect almost every organ and system in the body. The main target for lead toxicity is the nervous system, both in adults and children. Long-term exposure of adults can result in decreased performance in some tests that measure functions of the nervous system. It may also cause weakness in fingers, wrists, or ankles. Lead exposure also causes small increases in blood pressure, particularly in middle-aged and older people and can cause anemia. Exposure to high lead levels can severely damage the brain and kidneys in adults or children and ultimately cause death. In pregnant women, high levels of exposure to lead may cause miscarriage. High level exposure in men can damage the organs responsible for sperm production. The health effects of arsenic are detailed by the Agency for Toxic Substance and Disease Registry as follows: Breathing high levels of inorganic arsenic can cause sore throat or irritated lungs. Ingesting very high levels of arsenic can result in death. Exposure to lower levels can cause nausea �and vomiting, decreased production of red and white blood cells, abnonnal heart rhythm, damage to blood vessels, and a sensation of "pins and needles" in hands and feet. Ingesting or breathing low levels of inorganic arsenic for a long time can cause a darkening of the skin and the appearance of small "corns" or "warts" on the palms, soles, and torso. Skin contact with inorganic arsenic may cause redness and swelling. The heaith effects of copper are detailed by the Agency for Toxic Substance and Disease Registry. as follows: High levels of copper can be harmful. Breathing high levels of copper can cause irritation of the nose and throat. Ingesting high levels of copper can cause nausea, vomiting, and diarrhea. Very-high doses of copper can'cause damage to th~ liver and kidneys, and can even cause death. The health effects of chromium are detailed by the Agency for Toxic Substance and Disease Registry as follows: . The International Agency for Research on Cancer (IARC) has determined that chrornium(VI) compounds are carcinogenic to humans. The National Toxicology Program 11th Report on Carcinogens classifies chromium(VI) compounds as known to be human carcinogens. In workers, inhalation of chrornium(VI) has been shown to cause lung cancer. Mixed results have been found in studies of populations living in areas with high levels of chromium(Vl) in the drinking water. In laboratory animals, chromium(Vl) compounds have been shown to cause tumors to the stomach, intestinal tract, and lung (https://www.atsdr.cdc.gov/toxprofiles/tp7.pdf). The health effects of ammonia are detailed by the Agency for Toxic Substance and Disease Registry as follows: Ammonia is a corrosive substance and the main toxic effects are restricted to the sites of direct contact with ammonia (i.e., skin, eyes, respiratory tract, mouth, and digestive tract). For example, if you spilled a bottle of concentrated ammonia on the floor, you would smell a strong ammonia odor; you might cough, and your eyes might water because of irritation. If you were exposed to very high levels of ammonia, you would experience more harmful effects. For example, if you walked into a dense cloud of ammonia or if your skin comes in contact with concentrated ammonia, yoUr skin, eyes, throat, or lungs may be severely burned. These bums might be serious enough to cause permanent blindness, lung disease, or death. Likewise, if you accidentally ate or drank concentrated ammonia, you might experience bums in your mouth, throat, and stomach (https://www.atsdr.cdc.gov/toxprofiles/tp126.pdf). Weather conditions that may cause hazardous substances or pollutants or contaminants to migrate or be released. Migration of hazardous substances in groundwater due to the nature of soils at the Site has been well documented. With every rainfall, migration through the groundwater pathway exists. Many residents in the area of the House Street Disposal Area of the Site rely on well water for drinking �water, and the municipal water supply for the City of Rockford lies in the general path of the groundwater flow from the Tannery Property, approximately one mile away from that part of the Site. Rainfall also causes storm water runoff at the Tannery Property and off-site releases have been documented. Hazardous substances have migrated to adjacent land via groundwater, and have impacted the water and sediments of Rum Creek and the Rogue River. Actual or potential contamination of drinking water supplies or sensitive ecosystems. All area residents within the 4-Mile TDL utilize groundwater wells for obtaining their drinking water. Residents of the City of Rockford are served by a municipal system that utilizes wells located approximately one mile southeast of the Tannery Property part of the Site. Approximately 5,484 residents are served by this system. The remainder of the residents located within the 4-Mile TDL utilize private drinking water wells. The approximate residential population served by private wells by radius ring is listed in the table below: Estimated population served by residential wells Distance from Site Mile 0 ¼-1/:zMile ½- 1 Mile 1 - 2 Mile Mile 0 269 3,079 7,591 Mile 8,433 Total 19,372 Heavy metals (lead, copper) and PFAS have been found in groundwater monitoring wells near the former Tannery Property and in some drinking water wells near the House Street Disposal Area. Sediments in the Rogue River have been shown to be impacted from contaminants associated with the Tannery Property. Total chromium, hexavalent chromium, and mercury have been detected in sediment samples at levels above background concentrations. The PPE of contaminants to the river is along Rum Creek as it passes �through the Tannery Property, along its western boundary and potentially where groundwater from the Tanne1y Property discharges to the river. The 15-mile TDL includes Rum Creek through the Tannery Property, approximately seven miles of the Rogue River downstream of the Tannery Property, and eight miles of the Grand River downstream of its confluence with the Rogue River. These rivers are used for recreation and fishing. Approximately 14.45 miles of wetlands frontage are also present along the 15-mile TDL along with several documented occurrences of state and federal threatened and endangered species. There are no known surface water intakes along the 15-Mile TDL, but the City of Rockford historically operated an intake on the Rogue River downstream of the Tannery Property. The Rogue and Gr.and Rivers are used quite extensively for recreation and fishing. The City has a canoe/kayak launch on the east bank of the river just downstream of the Site. The City also just completed construction of a boardwalk with fishing platforms on the western bank of the river opposite the Tannery Property. Approximately 14.45 miles of wetland frontage have been documented along the 15Mile TDL. Sensitive environmental resources along the 15-rnile TDL include: six state threatened species, seven state endangered species, and two federal threatened species. These are all located downstream of the PPE and downstream of where sediment samples were collected. High levels of hazardous substances or pollutants or contaminants in soils largely at or near the surface that may migrate Hazardous substances have been identified and documented in the surface soils of the Tannery Property as well as in samples from the House Street Disposal Area. Arsenic, chrome, lead and other hazardous substances have already been documented in drinking water samples from residences surrounding both areas. Sediments in the Rogue River are already noted to be contaminated by migrating hazardous substances from the Tannery Property. Failure to address the continued migration of hazardous substances in each of the locations could further contaminate drinking water and the environment. The availability of other appropriate federal or state response mechanisms to respond to the release. No other federal or state response mechanism is available to respond in a timely manner given the exigencies of the situation. IV. ENDANGERMENT DETERMINATION Given the conditions at the Site, the nature of the lmown and suspected hazardous substances on Site, and the potential exposure pathways described in Sections II and III above, actual or threatened releases of hazardous substances from the Site, if not addressed by implementing the �response actions selected in this Action Memorandum, may present an imminent and substantial endangerment to public health, or welfare, or the environment. V. PROPOSED ACTIONS A. Proposed Actions 1. Proposed action description The response actions described in this memorandum directly address actual or potential releases of hazardous substances on the Site, which may pose an imminent and substantial endangerment to public health, or welfare, or the environment. Removal activities on site will include: a) Develop and implement a site health and safety plan to protect workers during the cleanup; b) Develop and implement Extent of Contamination Study plans to comprehensively study the former Tannery Property (including sediments in the Rogue River and Rum Creek adjacent to the Site) and House Street Disposal Area locations and to determine the amount and location of hazardous substances and/or waste in soil, sediment, groundwater and surface water as may be present in each location; c) Develop and implement a work plan for offsite disposal of any hazardous waste or hazardous substances that pose an Imminent and Substantial Endangerment to Human Health and the Environment as determined by the EPA On Scene Coordinator and identified during the Extent of Contamination Studies. The work plan shall include specific site controls to prevent accidental releases during removal activities and to eliminate additional off-site migration of hazardous substances; d) Develop and implement a work plan to conduct soil gas sampling and an initial Vapor Intrusion study for residential and commercial properties near the Site based on reported historic use ofTCE at the Tannery Property as a hide degreaser (SEMS 407293); e) Develop and implement a work plan to eliminate or adequately restrict off site migration of hazardous substances via surface run off, air deposition, or groundwater flow, which exceed State contact or other appropriate criteria; f) Place warning signs and, where not already present, fencing to limit public access to the Site; g) Conduct personal and perimeter air monitoring and sampling during the cleanup; and �h) Ensure that all hazardous substances, pollutants or contaminants sent off-site are treated, stored, and/or disposed of in accordance with the EPA Off-Site Rule, 40 C.F.R. § 300.440. The removal action will be conducted in a manner not inconsistent with the NCP. The On-Scene Coordinator (OSC) has initiated planning for provisions of post-removal site control consistent with the provisions of 40 C.F.R. § 300.415(1). The response actions described in this memorandum directly address actual or threatened releases of hazardous substances, pollutants or contaminants at the facilities comprising the Site which may pose an imminent and substantial endangerment to public health and safety, and to the environment. These response actions do not impose a burden on the affected property disproportionate to the extent to which that property contributes to the conditions being addressed. 2. Contribution to remedial performance The proposed removal action at the site will not impede future actions based on available information. 3. Engineering Evaluation/Cost Analysis (EE/CA) Not Applicable 4. Applicable or relevant and appropriate requirements (ARARs) All applicable, relevant and appropriate requirements (ARARs) of federal and State law will be complied with, to the extent practicable, considering the exigencies of the circumstances. On December 27, 2017, EPA sent a letter to Abigail Hendershott of the MDEQ to request Michigan ARARs. Any ARARs identified in a timely manner will be followed to the extent practicable. 5. Project Schedule The estimated on site working days to complete the Extent of Contamination Study at each site is a total of20 on site working days. Work to be performed based on the results of this study will be addressed in an amendment to this Action Memorandum. Estimated Costs The estimated costs for this site are for the Extent of Contamination Studies to be performed. Time Critical Removal Action costs for any proposed work that comes from this assessment work will be captured in an Amendment to this Action Memorandum if necessary. See Attachment 4 for an Independent Government Cost Analysis. REMOVAL ACTION PROJECT CEILING ESTIMATE Extramural Costs: I �Regional Removal Allowance Costs: Total Cleanup Contractor Costs (This cost category includes estimates for ERRS, subcontractors, Notices to Proceed, and Interagency Agreements with Other Federal Agencies. Includes a 15% contingency) TBD Other Extramural Costs Not Funded from the Regional Allowance: Total START Labor Total START Analytical Total START Other Direct Costs CRL or other Regional Labs Subtotal Extramural Costs $98,240 $501,672 $154,760 $100,000 Extramural Costs Contingency (10% of Subtotal, Extramural Costs rounded to nearest thousand) $854,672 TOTAL REMOVAL ACTION PROJECT CEILING $85,467 $940,139 VI. EXPECTED CHANGE IN THE SITUATION SHOULD ACTION BE DELAYED OR NOT TAKEN Given the conditions at the Site, the nature of the known and suspected hazardous substances onsite, and the potential exposure pathways described in Sections II and III above, actual or threatened releases of hazardous substances from this Site, if not addressed by implementing the response actions selected in this memorandum, may present an imminent and substantial endangerment to public health, or welfare, or the environment. VII. OUTSTANDING POLICY ISSUES None. VIII. ENFORCEMENT For administrative purposes, information concerning the enforcement strategy for this site is contained in the Enforcement Confidential Addendum1. 1 Neither the lack of a total cost estimate nor deviation of actual total costs from this estimate will affect the United States' right to cost recovery. �The total EPA costs for this removal action based on full-cost accounting practices that will be eligible for cost recovery ate estimated to be $1,524,8942. ($940,139 f $22,000) + (58.49% X $962,139) = $1,524,894 IX. RECOMMENDATION This decision document represents the selected removal action for the Wolverine Woddwide Tannery and House Street Di.sposal Site i11 Rockford and Plainfield Township, Kent County, Michigan, developed in accordance with CERCLA, as amended, and is not inconsistent with the NCP. This decision is based on the administrative recotd forthe Site (Attachment l). Conditions at the Site meet the NCP criteria at 40 C.F.R. § 300.415(b) for a removal action, and I recommend your approval ofthe removal action proposed in this Action Memorandum. This Action Memorandum is being developed to support an Administrative Settlement Agreement and Order on Consent issued under CERCLA aµthorities, and it is anticipated that Wolverine will conduct the work outlined in this document. You may indicate your approval by signing below. Approve: ~A-~L //,0/1% Acting Director, Superfufid ' Division Date Acting Director, Superfund Division Date Disapprove: Enforcement Addendum Attachments: 1. 2. 3. 4. Administrative Record Index Region 5 EJ Analysis Site Location and Layout Maps Independent Government Cost Analysis 2 Direct Cost.s include dfrect ext1:amural costs and direct intramurl\1 costs. Indirect costs .are calcµlatqd based On an estimated indirect cost tale expressed as a percentage of Site specific direct costs, consistent with the full cost accounting methodology effective October 2, 2000, Tlwse estimates Qo n9t irn:Iude pre-judgme!lt interest, do not take into account other enforcement costs, including Department of Justice costs, and may be adjusted dudng the course of a.rem9val action. The estimates are for illustrl\tive purposes only and their use is not intended to create any rights for responsible parties. Neither the lack of a total qist estimate nor deviation of actua1total costs from this estimate will affect the United States right to cost recovery. �cc: B. Schlieger, EPA HQ (Schliegcr.brian@Epa.gov) L. Nelson, U.S. DOI, w/o Enf. Addendum, ( Lindy_Nelson@ios.doi.gov) Keith Creagh, Director, MDEQ, w/o Enf. Addendum (creaghk@michigan.gov) Bill Schuette, Michigan AG, w/o Enf. Addendum (SchuetteB@michigan.gov) J. Walczak, MDEQ, w/o Enf. Addendum (walczakj@michigan.gov) bee: J. Glover, MSS-12J, w/o Enf. Addendum M. Johnson, ATSDR-4J, w/o Enf. Addendum A. Lippert, Public Affairs, P-19J, w/o Enf. Addendum T Harrison, Contracting Officer, MCC-1 OJ, w/o Enf. Addendum D. McGary, Contracting Officer, MCC-l0J, w/o Enf. Addendum J. Maritote, SE-SJ w/o Enf. Addendum J. El-Zein, SE-SJ D. Gray, SE-SJ T. Johnson, SE-GI C. Norman, Delivery Order File, SA-SJ S. Chummar, Delivery Order File, SA-SJ T. Quesada, Record Center, SMR-7J C. Ropski, SE-SJ C. Bohlen, SE-5J S. Borries, SE-SJ J. El-Zein, SE-SJ B. Kelly, SE-GI J. Clark, C-14J T. Williams, C-14J �ATTACHMENT 1 U.S. ENVIRONMENTAL PROTECTION AGENCY REMOVAL ACTION ADMINISTRATIVE RECORD FOR THE WOLVERINE WORLDWIDE FORMER TANNERY SITE . ROCKFORD, KENT COUNTY, MICHIGAN ORIGINAL JANUARY, 2018 NO. SEMSID DATE AUTHOR RECIPIENT TITLE/DESCRIPTION 434863 4/19/12 Young, M., Rockford, City of Walczak, J., MI Dept. of Environmental Quality Letter re: Request that USEPA and MDEQ Terminate CERCLARelated Activities 2 936833 4/19/12 Young, M., Rockford, City of Williams, T., U.S. Letter re: Site Activities EPA 2 3 434900 6/14/12 Devantier, D., Ml Dept of Environmental Quality Muniz, N., U.S. EPA Letter re: Preliminary Assessment Recommendation 2 4 434898 6/15/12 File File CERCLA Preliminary Assessment 150 5 937642 10/25/ 17 Powers, L., GZA Vorce, K., Ml Geoenvironrnental Dept. of Environmental Quality Email re: MOOT & Imperial Pine - Solid Waste 20 6 937808 11/16/17 FTC&H File FTC&H Technical Memorandum Varnum LLP Soil Analytical Results 89 7 938081 12/27/17 Kimble, J., U.S. EPA Hendershott, A., MI Dept. of Environmental Quality Letter re: Request that the Michigan Department of Environmental Quality (MDEQ) Identify all Applicable, Relevant, and Appropriate Requirements (ARARS) PAGES 2 �NO. SEMSID DATE AUTHOR RECIPIENT TITLE/DESCRIPTION 8 938079 12/28/17 File File Michigan's Chemical, Action and Location Specific Response Actions Summary - ARAR Table (Revision: December 28, 2017) 13 9 938080 12/28/17 Hendershott, A., MI Dept. of Environmental Quality Kimble, J., U.S. EPA Letter re: Applicable, Relevant, and Appropriate Requirements (ARAR) 2 Kimble, J., U.S. EPA Kaplan, R., U.S. EPA Action Memorandum re: Request for a Time-Critical Removal Action at the Wolverine Worldwide Former Tannery Site 10 (PENDING) PAGES �ATTACHMENT 2 EJ ANALYSIS Wolverine Worldwide Tannery and House Street Disposal Site Rockford and Plainfield Township, Michigan EJSCREEN Rep art (Version 2017) 1he User Specified Area, MCHIGAH, EPA Region 5 Approxin-.te Population: 21,869 Input Area (sq, niles): 33,21 Wolverine WorldlNide Selected Variables EJlndeaes EJ Index for PM2.5 EJ Index for Ozone EJ Index for NATA" Diesel PM EJ Index for NATA. AirToxics cancer Risk EJ Index for NATA. Respiratory Haiard Index EJ Index for Traffic Proximity and V olume EJ Index for Lead Paint Indicator EJ Index for Superfund Proximity EJ Index for RMP Proximity EJ Index for Haiardous Waste Proximity EJ Index for Wastewater Discharee Indicator I State ~rcentile EPA lqion USA Percentile Percentile 6 11 6 5 8 6 20 8 29 20 13 10 18 12 15 19 14 12 23 26 15 g 7 5 38 50 35 34 42 33 18 29 17 �E.J. ll'\lft!x- for the Selected Area Compared to All People's B!ockgr;ups in the State/Rl'!\]lofl/US 100 l"l 1~ il ~c ,, 0 "'<• 9-·,.i';\- state Percentile Re,;:ic;nal Percenti'e ■ USP.. ;?eccerHi le n, ~ re i:ort3how:st he~ luo fore1Hiro n~ntal a n::t dern:-sraphic indicato r.. ;a rd EJSCREEN indexes. ltshowsen•, ironme nul and dcmo&ra pi~ raw data i:=; ., t he etinvted concentr.t» n of oz:one in the a ir), a nd ilko ~Mw:. w h:at p:n:entile s c h raw d ata -all.le represent:. The ~ p:rcent iles provi::1-e p:r:;po:th'e o n howthC!i Y-lectlSI bbck510upor biffen r,ea rornpilN:S to the-ent ire state, EF>\ rcsb n,or nat~n. for elQmp~ Sh gN'en ba tion is nthe 95th p:rcentH: n:at~nwi::fe, t h is rneoans that o ntrS p::r, ~t,:r,f t he US po pub t~n has a hi;her bbck 6~ llp'iillue than the a·,era~ p::r:on In the locatio-n bei rt; a na l),:e:f . Theym rs -b r whi.: h the drt:3 are a'r.11 i~ ~e., and the method:. u:5ie:d, <n ri,'acrom th,:;e indi:nor.. , l rnp:ntilntcavc:,ns and unccrtaint~n pptrto this 2:r~ nin;-bcl i nfo rrna1»n,. so it i=: c:.e ntG I to u nde ~ti nd 1hc lirnitatio ns o n a pproprGte inte. rpret:atio ns and a pplCa t io ns of the~ ind-=:ato r:: . Ple::asc ~e fJSCRf fN doc u men·t:ation ford is, 1r.sK),n of thee issue. bdore us i'lj rc~rts. Oeoortber 22, 201 �EJSCREEN Report (Version 2017) the User Specified Area, MICHIGAN, EPA Region 5 Approximt1e Population: 21,869 Input Area (sq. rriles): 33.21 Wolverine Wol1dwlde Selected Viriables Value State Alig. "'ilein State EPA Regbn '!Hein EPA Av•. Re•ion USA Avg, "'ilein USA mvironmental lndica tors Particulate Matter (PM 2.5 i. 1411,;) Q.22 Q.14 35 10.1 16 9.14 43 Ozone (ppb) 402 38.1 SQ 37.6 94 38.4 76 0.392 0.726 31 31 0.932 <&>th 0.938 <50th 36 34 <&>th 40 <50th 0 NATA Dies el PM (1411m>) NATA" Cana,r Risk (lifotimeriskpermillio•) 28 1.1 1.3 35 1.7 <&>th 1.8 <50th 180 570 153 370 64 500 to Lead Paint Indicator (!lPre·l960Housin~I 0.14 0.3Q 25 0.39 26 0.2Q 42 Superfund Proxrmity (sioo counl/kmdiltonce) 0.12 0.14 73 0.13 75 0.13 71 NATA· Respiratory Hazard Index Traffic Proximity and Volume~• ifrti;lfi: ,o ..11dirla """ to ooad) RMP Proximilv !fuilitv,o•nllkmdiltoncel 0.069 0.51 12 0.81 5 0 .73 8 Hazardous Waste Proximitv (fa,ilihl counl/km dim•"" I Wastewater 0isch1111:e Indicator 0.014 0.072 17 0091 9 0.093 11 b.00045 0.16 67 4.2 52 30 63 11% 3)% 14 29% 17 36% 10 5-.6 24-.6 22 25-. 25 38% 12 215 (tox~~ci1htm ,on,cntration/mdStance) Demogl"illpnic ln111cators Demographic Index Minoritv Population 17-.6 35% 23 33% 27 34% Linguistical~ Is alated Population o-. 2% 61 2-.6 58 5% 44 Population With less Than Hil!:hSchool Education 4-.6 10'.4 21 11% 24 13% 21 law Income Popul ation of ■ge 7% 6% 69 6'.4 65 6% 63 Population over 64vean; of•• 12% 15% 40 14% 44 14% 43 Population UnderS ye ■n; The: Na t~nal-Sc::.a ~AirTo)(i.:::.:A:zcc-zrncnt (HATA) k EPA~ on;oin;, compr« hens io,c er.a luattOn oh ir Wxii::s in t he United State::.:. EPAdc•te:bp:d t he NATA 1o priorrt:Ee airtoxic ,. cmizion !iOUrce~.. ;nd k>c;t~rs of inte:rertfor furthe: r!!;tudy. It G import.a nt W rc~rnberthat NATA provi::ld broad estimates,:,f he;tth ri~b overge:»r;~phi.:; N:515 of the country, notdefinitN'e rGb:'to sqz crfi: ind;, i::lualsor bcations. Mo re. information on t~ NATA a nil 'rsG ,an be: found 1 a t : http:s :1tw,11w..e.pa ~v/ntiona hir-tioxic:s•as!ll!~m: nt. �EJSCREEN Report (Version 2017) t h e User Sp ecifie d A r ea, MIC HIGAN, EPA Region 5 Approximate Population: 21 ,869 Input Area (sq. miles): 33.21 Wolver-ineWorldwide ~i. 1. Mt-11;.:ai,,p! ~.. 11.... Ct,.ce~h• U - 1 ~1~ tl•J*j?'-1Fli;l~•Jo'Jt' ,.u J.4-1} ~ '" 2:,~ 1 ; ,. I ,_,.. .....,,.J.,, ...., ~ t,,J ......-~--.Mt--•-.r. ,,~._ - · ·:iw::~~•~"':11, - - · \Jlt•. Q, :;•# _I _ .......~ ,.:;~ C'✓A: '1-WL<qJ:;:-11"\ _.,~<t. ~sl: - -•J..,.'t'\~ •• �ATTACHMENT 3 SITE LOCATION AND LAYOUT MAPS V<h•,enr-,, V1b-1t1Wl-'.lr. Ferner lirml:f¥ \-.....__.,. • I Legend I C !,It:< &,w,.t.1-•, nc.1<1c. ,-~Jl• t\:icti:1 N w@@, ' f\~ , - -ir:;:=::m____ ,,,lt!~ ��Histoncal/Curront Site 1-eatures 7 Leuen<I ·~· .. ,,,,~ lrr. fir.:, l:¼:ll.rl'.l.!JI'; �,.. SoJ S~'T'lplo L<lwil o-i~I ' ~ �,, Jav-·, Mon110~ 111'1!11 l ~lillfii f'.1 & fiP •:l1 Pi~..:il~let,'Rl•"3rr-:lnx::me'ler LOCllUCfl!! �''!I....,.. ..... "" Sedlrnenl Sam le l ocahons I cgend $~ moni S .il'llllo M..s:cl' 2012 J ~ :hl1~r1 &!me e Decertior 7:t 1I - - -- ---- --- <:<>u µ li,j h 1 .~rl S lUl ff l rtt>f.Jfl .~ .... ~:.1.-: t-·1,.,. Wr:hi;., ~ o , ,or Cl , l '-''"'f t. :~•!> i: ... �ATTACHMENT 4 Independent Government Cost Analysis Wolverine Worldwide Tannery and House Street Disposal Site Rockford and Plainfield Township, Michigan January 2018 Government Independent Cost Analysis Back&olll1t1 and Planning iJ:>rojectT'v1anage01ent !Lead START lLabClr Tannery Site [Pr<JJ~~~j.d~11::ige01cl1t • :Lead START !Labor ••• • \ch;~~t/QAQc . Total . $?,0.8-0 ... $:±,QOO $! 2 ,900 . $18,080 Cost $130 hr $100 hr $75 Total Amount 16 hours 40 hours 160 hours $130hr $100 hr $75 .$100 100 hours $2,Q8-0 . $<J,QQO .$30,000 $<l,QOO .. $6,880 . . $J?2 a day !Lodging . 4 :x;io ttays • jriq~~ent rental lot $8-,00Q. ... ... $8-PQO $35,000 .. lot $3\900 .. j~~~c.()ntr::t<::t(g.:ote~h). Analytical. ..$<'i?,}<'i9 , .... }soil samples per bore i ... $!,!?? p(Jr ~arnplCJ . i?O soil bo~ . $43,360 ?w~t;~s~~pies !)Clf~()T(J , $1,084 persatnpl.: 5 soil smr1plt:s per in~tajl I $ I ,!?fp(Jr samplt: ~28,~Q9 .. $16,260 3 \Vater ~ainpl(J~per instaU ... $1 ,084per sa111pli: , $55,488 48 .J... $1J?<'ipet~atnpl.: ....• . l~(Jtlilllt:l1! S111!lpl.:~ 16 $1,084persainpl(J Jl]1}<J4 . is~fc1<::CJ water sample~ f House Street Site ' .JJ:>~()jt:~!T'v1<111::ig.:11:1.:flt ................. \LeadST~I . .. ,!:,c1~9.r. jChemist/QAQC 16 hours 40 hours 400 hours 100 hours Tannery Total $320,672 $130 hr $100 hr......... ............................. $75 $100 $2,080 · · ······ ······ ··············• ••• .. , E,OOQ .. $30,000 .. ... .... $4,000 .....i!::?tl,gitl!;!; $l 72 ::i .ttc1y . . !Eqllipment rental 1.. . . ... ... ,$8,000 T~ub?on~::i~i (s()nic rig) • lot . ...$~0,000 . . [Analytica.1- .. . . . . . .. ... . . .. . . .. ........... . . ..... . ..............••• lQdeep soil boring;, 5 soil samples per bore i. $1,156 per~atnple , ... 5 \V::t~t~ample~perb()rt: , $l,08<Jp(Jt~<1ippl.: L ge()p~()be lo<::<1!i()11S l 5 soil S111!lplc:sper ·• . $l,l?<'ipt:tsc1ipple ~ \Vclter satnplCJ~ per J $1,084 p(Jr sample ! ! fao House St Total CRL or other EPA labs EPA direct costs= 400 hours X $55 = $22,000 Total J6,880. $8p00 .l?Q,OQO $57,800 $?i,200. . $115,600 . $ 4},360 $415,920 � Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Living with PFAS Interviews Creator An entity primarily responsible for making the resource Devasto, Danielle Description An account of the resource Beginning in 2021, the Living with PFAS interviews were recorded to gather the personal stories of individuals impacted by PFAS contamination. PFAS, or per- and polyflourinated substances, are a large group of human-made chemicals used widely since the 1940s to make coatings and products resistant to heat, oil, stains, grease, and water. They can be found in countless household items, including food packaging, non-stick cookware, stain-resistant furniture, and water-resistant clothing. These chemicals are often called “forever chemicals” because they do not break down easily, can move through soils and contaminate drinking water sources, and build up in animals, plants, and people. PFAS have been linked to increased incidences of various cancers, increased cholesterol, decreased fertility, birth defects, kidney and liver disease, and immune system suppression, and thyroid dysfunction. It is estimated that PFAS are in the drinking water of more than 200 million Americans (Andrews & Naidenko, 2020). In Michigan alone, over 280 sites have PFAS contamination exceeding maximum contamination levels for groundwater (MPART, 2024). Date A point or period of time associated with an event in the lifecycle of the resource 2021 Source A related resource from which the described resource is derived Living with PFAS (project) Rights Information about rights held in and over the resource In copyright Subject The topic of the resource Oral history Personal narrative PFAs (Perfluorinated chemicals) Groundwater--Pollution Publisher An entity responsible for making the resource available Grand Valley State University. University Libraries. Special Collections & University Archives Identifier An unambiguous reference to the resource within a given context DC-11 Format The file format, physical medium, or dimensions of the resource video/mp4 application/pdf audio/mp3 Type The nature or genre of the resource Motion Picture Text Sound Language A language of the resource eng Oral History A resource containing historical information obtained in interviews with persons having firsthand knowledge. Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Identifier An unambiguous reference to the resource within a given context PFAS0024audio Creator An entity primarily responsible for making the resource McIntosh, Lynn Date A point or period of time associated with an event in the lifecycle of the resource 2021-08-11 Title A name given to the resource Lynn McIntosh, 2021 (Interview audio and transcript with additional artifacts) Description An account of the resource Lynn McIntosh grew up on the east coast but has lived in Rockford, Michigan for about 30 years. This interview documents the maps, photographs, reports, and firsthand testimony that Lynn McIntosh and CCRR assembled to uncover PFAS contamination linked to Wolverine Worldwide. Key artifacts included FOIA-obtained site maps, demolition photographs, worker interviews identifying buried tanks and disposal practices, regulatory records showing gaps and inconsistencies in testing and reporting, and documents proving Wolverine’s use and storage of Scotchgard. Together, these materials formed the evidentiary foundation that challenged official claims, demonstrated widespread contamination, and helped prompt renewed EPA investigation and cleanup action. Please note, in addition to the audio interview and transcript document, the supplemental artifact documents include the visual and textual artifacts referenced throughout the interview and transcript, including items labeled from "Artifact 1" to "Artifact 52." Contributor An entity responsible for making contributions to the resource DeVasto, Danielle (interviewer) Subject The topic of the resource Oral history Personal narrative PFAs (Perfluorinated chemicals) Groundwater--Pollution Source A related resource from which the described resource is derived Living with PFAS (project) Publisher An entity responsible for making the resource available Grand Valley State University. University Libraries. Lemmen Library and Archives Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/page/InC/1.0/?language=en">In copyright</a> Type The nature or genre of the resource Sound Text Format The file format, physical medium, or dimensions of the resource audio/mp3 application/pdf Language A language of the resource eng https://digitalcollections.library.gvsu.edu/files/original/af091e183b8d79f3b279d2a060f0978e.mp4 59548fabb9c650345ca905e08eed95e3 https://digitalcollections.library.gvsu.edu/files/original/f73ad65e14a5a052e7e8993e8ffa7520.pdf a3d497b07f3a092de2d2004b76fe5cdc PDF Text Text Living with PFAS Interviewee: Michael McIntosh Interviewer: Dani DeVasto Date: September 9, 2025 Dani DeVasto (DD) (00:03): Okay. I'm Dani DeVasto, and today, September 9th, 2025. I have the pleasure of chatting with Michael McIntosh. Hi Michael. Michael McIntosh (MM) (00:13): Hi, Dani. DD (00:15): Can you tell me about where you're from and where you currently live? MM (00:19): Yes. Um, I'm, I'm from Michigan. I grew up mainly in Jackson, Michigan, which is south of Lansing. Uh, I've lived out east for a while in Connecticut. Um, and since 1991, my family and I lived here in Rockford, Michigan. DD (00:37): All right. You already anticipated my next question, <laugh>, which is, how long have you lived there? MM (00:43): <laugh>. DD (00:46): Oh, all right. So, Michael, can you tell me a story about your experience with PFAS or with PFAS in your community? MM (00:54): Yeah. I, I, I'll go back to my start, really. And, um, in particular, it was the, uh, Wolverine Worldwide, um, demolishing their tannery. And, um, when they did that, before they did that, they said there's no known contamination on the site. Um, but from when it started, we had a group of neighbors who kept track of it. Um, we had, uh, I had set up kind of a walking routine so that various times of the day someone would walk and take pictures if needed, um, particularly of, um, dust or, or, uh, you know, contamination in the air, those events. Um, and we, about that time, we started a small nonprofit, um, CCRR, um, concerned Citizens for Responsible Remediation. And it was mainly my wife, Lynn and me, and, um, quite a few neighbors that cared. And, um, we had hired AJ Birkbeck at that time as our environmental lawyer, um, and we were showing up at city council meetings and raising concerns. MM (02:13): The city kind of blew us off. Um, that wasn't our first taste of, of not being taken seriously, but that's what starts this. Um, and we, um, we tried to keep track. We, we asked where the air quality monitors were. Um, we were, we were getting, um, requesting data. We ended up having to FOIA stuff because �the city was making it difficult for us to get information. Um, and it was at that time that I, I took on a few different roles, um, when I was off in the organizer of meetings. Um, and I would often facilitate them. I wouldn't necessarily lead them, um, because we had various people who were involved that needed to speak, um, particularly Lynn, my wife. Um, and then I would follow up with meeting notes and, um, and, uh, things like that. And, uh, I remember one experience when, um, we met we and raised our concerns, and we, um, we shared, we shared it with each other, and we, um, everybody's email was in plain sight. MM (03:31): We, we either shared it with the city, I don't remember, or someone in our group kind of surreptitiously shared it. And then the city manager stole our <laugh>, stole our distribution list, and used it to, um, try to, to, um, dismiss us as, you know, discontented citizens. Um, and that was our first lesson in communications and using, uh, blind carbon copies on our emails, um, that sort of thing. Um, it was a learning curve, things like that. Um, so I was, I was helping keep us on track from, uh, sometimes we were meeting weekly, sometimes we met next door at our neighbor's, uh, porch once a week. Um, and it was a time when, first, first time when the neighborhood really came together on something because we were with the Westerly winds. Um, we were in particular, um, um, you know, subject to any air pollution that was coming our way. MM (04:39): Uh, that was one of, one of the things that's, that's kind of an early thing. Our group got smaller over time. People after the tannery was demolished and things were set and done there. Um, we, um, a lot of people slipped away. Understandably, there wasn't a lot to do. Um, and I'll just fast forward to 2017 when, um, our small group at that point, CCRR, we were probably about, if we were 10 people, that was a lot. And by then, I think, uh, Dr. Rick Ky joined us, um, in 2013. He was persuaded that we were, um, that we were legit. Um, and, um, it was our group that was the whistleblower to the EPA. And it was also at the time that we, um, we were able to persuade Garrett Ellison of M Life that again, that we were legit, that we had a legitimate environmental concern. MM (05:43): And he started writing. Um, and then, um, it, that was when, again, I was doing quite a bit of organizing, quite a bit of communications. Um, <laugh>, I was, let's see, in 2017, what was that, eight years ago, I was 62. And we had millennials in our group. And so one time I said, well, well, who wants to get a, get us on Facebook so we can communicate that way? And I was so shocked that nobody, particularly the millennials, nobody, nobody stepped up. And I, I'm not shy about asking people and, and by name and saying, Hey, would you, would you think about it, Nick, what about you? Um, no takers. And I said, okay, I'll do it for eight weeks, and then I'm gonna hand it over to someone. I'll get it going. Well, that eight week deadline came and went. MM (06:42): And so I continued with that. And it's probably not a lot these days, but over the course of, um, probably about six or eight months, we got up to 1100 regional followers. Um, and a lot of them were people who were affected by the contamination at House Street. Um, we were in close communication with them. Um, we were showing up at town hall meetings when, when Wolverine was saying that, you know, that, that we really care about the community, and you want, we want you to be comfortable with your water. Um, it was a lot of BS from their pr, um, and particularly their lawyers. Uh, and that was, that was �particularly a very intense time. Um, I helped organize, one of the things, I reached out, one of the groups I reached out to was Clean Water Action. And I, I don't know if he's still there. I think he is, he may direct the Michigan, Sean McBrady. Um, but we did, um, we arranged a press conference, uh, in the Capitol, and I went, and three people who were affected by the, um, the House Street dumping went. And we, um, you know, we had, we had various, uh, various networks show up. Um, and, uh, we also went to try to talk to a couple of our legislators. We tried to, to find Pete McGregor to talk to him. Unfortunately, he, he was very much for business, and he had been persuaded by the city that we were kind of just a ragtag group that was full of complainers. And so, unfortunately, he never took us seriously or gave us the time of day. Um, and I'm not shy about naming names because we, this was all done in public, so I'm not, I'm not trying to throw anybody under the bus, but I'm just saying at the time, that's how things were going down. MM (08:51): Um, and so, um, it was the, one of, one of the things that I want to share for the sake of, I'm really doing this, not just for the history, but for all the generations younger than me. Um, you know, the millennials, which my kids are involved with, that Gen Z, the alphas, the, the Gen X. Um, because, um, it was incredibly hard work. Um, I was keeping a down a, a full-time job at a corporation. Fortunately for me, I didn't work at a small place because the city manager would often call those small places and complain about their employees. And a good friend of ours lost her job at LGROW because of, she gave up her job because her boss, after talking to the city manager, Michael Young at the time, said, um, well, you can either support this CCRR group or you can, uh, work at LGROW. MM (09:55): And she was bold enough to say, you know what? I don't need this job. She was a key member. That was Janice Tompkins. She was a key member of CCRR. Still is. Um, but it, it's, you know, the, um, the four of us that went to the EPA, not including, I didn't go, but Lynn and Janice Tompkins, AJ Beck and Rick Rediske went, uh, the science did an article on them. And the article title is quite telling, because it's, they persisted because the group persisted for seven years. Um, and now it's 15 years because CCRR still is a going concern. We were really low tech. Um, we didn't have a website, um, there, we didn't publish a lot. We used email and we tried to communicate kind of low key so that we stayed kind of below the radar of things. Um, but it can be hard on relationships, and it was hard on Lynn's and my marriage because we were both in the middle of it, and we were both working hard at it, often into the evening. MM (11:13): Um, and I, I finally got to the point, I think it was towards the end of 2018 when I said, you know, I'm gonna burn out here. I, I need to step back for a little bit. And so I, I, um, reduced my involvement with CCRR. And at that time, I took on something much more life giving. I started on the board at Plain Song Farm, which when you listen to this, whoever listens to this, I hope, Plain Song Farm on 12 Mile in Rockford is still a going concern. Uh, it's a small nonprofit and if, um, a young nonprofit, but I'll just throw that out. 'cause they're, they care about the environment and the, the, um, they care about, very much about the watershed. They're very involved with the community, and they care about PFAS. They had their water tested for PFAS, um, their wells at one point. MM (12:08): Um, so I spent more time with them. Lynn stayed involved. I would show up at CCR meetings and help communicate and make sure people were gonna make it and that sort of thing. Um, so, um, fast forward �to now, my involvement is with the Wolverine Community Advisory Group that's been going, I you may have that date, I think since 2018 or 2019. Um, I just joined in September of 2024 because, um, you know, Lynn and I agreed, we got to the point where we realized that, um, our marriage was the most important thing, and we were putting that ahead of everything else we would privilege our marriage and our relationship. So when I, um, she was ready to go off, um, the CAG, the Wolverine CAG, I was stepping down from Plain Song and I thought, okay, I think it's time for me to step into this. MM (13:11): And, um, I'd like to use my gifts there, encourage people that are still involved. Such, again, Rick Rediske is one of the, uh, he, he's on a three person leadership team member along with Sandy Wynn Stelt, and Tom Konecsni. And, um, I'm on the, I'm one of the ad hoc, not the ad hoc, one of the subcommittees is communication. So I'm back in the game working on communications, and we hope in the next six to 12 months to really, really up our game on communications. And in particular, I mean, we're, we're pretty much an older group. We have some younger people that have joined. Um, uh, professor Dr. Dani McBride from Calvin University has joined. Um, she's a breath of fresh air. Um, we have, um, one of the co-directors, I won't mention her because I don't don't know if she's going to join. She's come to a meeting and, and may join, um, the, when I say young people, anybody under 40, I consider young. Anybody under 45. I'm, I'm 70, the truth told. So anybody younger than me, I feel younger than. And I, I, I have a burden that, um, it's just recently I've been aware of it from my reading, but it's just recently that I've become more aware of the burden that younger people, younger than me feel for the climate change, for things like PFAS for those environmental concerns. And they're not only, perhaps discouraged, but, uh, incredibly disappointed or very despairing. Um, and I just feel for them. And so I hope anything I say could be used as encouragement and encouragement to stick with it, um, because it's worth it. Um, it's amazing the relationships you develop with people who care. And, um, I don't know, people talk enough about affection or love, but you come to have a deep affection or love for the people, for the water systems, for creation. MM (15:30): Um, I say to my tree sometime in the yard that, um, you know, you don't belong to me. I belong to you. Um, and I just know that, that the environment's gonna continue to be a, uh, an issue. So that's why I'm stay involved with what I'm doing. Um, that's frankly, the, the big reason. Well, I really believe in the book that you're writing, and, um, I really believe in the idea of the, of making a public library of all these interviews for future generations. So, and you're way younger than I am, too. So I care about you, <laugh> and your family. Thank you, DD (16:12): <laugh>. Thank you. Would you say that, I mean, it seems like, especially with your work with Plainsong Farms and now with the CAG, and even before that, would you say that like caring about the environment was something that was central to you, one of your concerns always? Or has this kind of MM (16:30): Yeah, the first Earth Day was, was in, uh, was April 22nd, 1970. I was a ninth grader in junior high. We got word before homeroom, a handful of us. We went to the principal's office and said we wanted to join the junior college in their five mile walk from the community, from the junior college to Jackson and picking up trash and so on. And you wouldn't believe it. They said, yes, if our parents approved, I bet that wouldn't happen today. So we called our parents, we got approval, and I don't know if there were �six or eight or 10 of us junior high kids went out. And when you're in ninth grade, uh, you know, freshmen and sophomore and juniors are you, you know, junior college, you're pretty, pretty mature. And you get kind of geeked by that. And that was just a, that was a conversion moment for me. Um, it was that, that school year that, um, the very first environmental biology class was offered at my, uh, at my high school. And I took that. And, uh, even though I became a history major, not a biology or botanist or zoologist or something, um, I've always, I've always had a deep, deep concern for the environment. And my family took us camping. You know, we loved the, the best days were days that you spent outdoors, you know, all the whole day outdoors. And still true for me. DD (18:04): You, um, you mentioned before about using your gifts with the, with the CAG, kind of bringing your gifts back. And I noticed that a couple times it, in your, in your story, it sounds like you got the role of communications. So I'm just curious, what do you consider your gifts are that you're bringing to the cag? MM (18:26): Well, first of all, I, I mean, first I'm thinking back to my college education. I, I majored in, uh, in history and minored in religion and ancient languages. And, um, so I always have a concern for the past. And so whether the past is 10 years ago or 2000 years ago, um, the past influences things. And so it's important to keep that alive. And, um, and I taught, I taught junior high and high school for five years, and then, um, just for a lot of reasons, um, transitioned to corporate it. And I was in that, I was in corporate IT for 37 years. And my favorite work, I, I was a developer. And then at one point I transitioned to a role of project manager. Um, and that's, that's where I re really felt like most of my gifts came alive in terms of, um, team building, bringing people in, helping them feel like what they have to contribute is important because they have something unique to contribute. And as it, it is important. Um, I joke sometimes and say that my core competency is scheduling meetings, <laugh>. So <laugh>, that's the thing I do best. <laugh> MM (19:52): Anything else just comes along with that. So, you know, I, I'm always trying to figure out, well, what works? What's the best time? Let's keep it short if we can. Um, I try to have at least a simple agenda if I'm facilitating. And, um, I just, after 37 years, I was just driven to come up with minutes, you know, to record particularly the decisions that you made and the tasks, because it's easy, particularly with volunteers, you know, volunteers, they're doing it for free and they're doing it for love, and they have a life outside this. And, um, people will commit and then they'll forget. Mm-hmm <affirmative>. And I get that. I need reminders all the time. Um, I've just become shy and not reminding people, you know, I try to do it graciously, but you know, I'm, I just will say, you know, you were thinking about that, I think, do you, are you thinking about that still? Or whatever. So, um, and it's, and most people are very gracious about it, and they'll say, you know, I don't have the bandwidth now, or, you know, oh yeah, I'll get to that. And then we get stuff done, which everybody feels good about. So, um, I guess that's it in a nutshell. I mm-hmm <affirmative>. I, yeah, I like people. Yeah. I like learning about them. I like to find out what they're about and what, what they enjoy, what makes them tick. It's a, it's a joy. DD (21:21): Yeah. I can definitely see how a group of volunteers has a lot of energy and passion, but also needs to be like, channeled and, and like mm-hmm <affirmative>. Somebody has to be able to help, like, break it down and have tasks and things so that the energy moves forward, �MM (21:37): Right? Yep. Yep. We all need that focus. DD (21:41): We all do. Um, you, I also noticed that you mentioned a couple times when you were talking about how, um, how CCRR was portrayed or described to others. I think, you know, you said like they didn't like the ragtag group and things like that. I was wondering if you, um, if you wanna say anything more about that, or like the perception amongst your neighbors in the city. It sounds like at least from the city, the group was not well perceived. MM (22:13): No, no, it was not. No. Um, yeah. I'll mention one thing that is just a sample. Um, but the city, along with the, um, downtown development authority, which is some of the city, some of the, um, uh, whatever city counselors were on it, as well as volunteers, volunteers, business, they gathered together and they write a, wrote a letter to Blake Kruger, who was CEO at the time of Wolverine. This was maybe 2012. And they wrote a letter, and it was published in the local newspaper, the Rockford Squire. They wrote a letter in which they, um, affirmed their supportive wolverine, thanked them for all that they had done for the community, and threw us under the bus slung mud at us about this small group of disgruntled residents, not citizens, residents, um, who were causing trouble. Um, that was one example. There was a lot of give and take in the Rockford Squire. MM (23:28): Um, I just, you know, I got to the point where, and, and maybe you do, and for a while, you know, you, me, I, I can over care what people think of me. I got to the point where I didn't care, you know, know <laugh>. I didn't care what they thought I was gonna do, what was right. I wasn't gonna think what I saw is right. You know, we've been wrong. I'm not saying that I don't wanna be self-righteous because, um, but they threw us under the bus. We, I tried being a collaborator. I tried multiple times with the city manager, uh, to collaborate, to meet, to meet. And it was kind of like, it was his way or the highway. And we never had it. And there were a couple times when he said he'd do it, and I said, we'll, be glad to meet if you do this. MM (24:18): And he waited and waited and waited and never did. And I pulled the plug on the meeting, and then we, we caught flack for that, that we weren't willing to meet. Um, so it was a lot of game playing and a lot of, um, just, they weren't used to there being another center of authority in the city of Rockford. And there were, there were, I mean, we talked to people that a number of people, even before this time, even before 2010, who'd been hurt by the city's high handedness. Um, it's much better now. I'll just, I'll just say that we've got a new administration in, we've got really good city counselors in. Um, they don't do everything I want 'em to do, but <laugh>, you know, they're politicians and they're good politicians and, um, and they're good people. Um, so I don't want to say a lot has changed since 2010, uh, in the last 15 years, and I'm really grateful for that. DD (25:25): Do you think that change is related to all of the issues with PFAS and Wolverine? Or do you think it's just... �MM (25:34): Um, well, the, um, well the, the big thing probably was in the midst of all this, maybe 2014 or 2015, the city manager died unexpectedly. He was only 48. And then, um, we had the police chief came to power, and that was, that was a disaster. And then the city really looked hard for another city manager. Um, that was one of the big turning points, but a lot of people came forward to care about who the city chose as city manager. So that was, that was part of the turning point. We were, Lynn and I, because of our networks were involved with, um, and a lot of people were involved supporting who we thought were good, good candidates for city council. Um, and so Gail Mansit was a city counselor. She was in CCR, she was a city counselor for one term. Um, so yeah, I think it was a lot of small things. The big thing was that that former city manager leaving, unfortunately, you know, unfortunately left a wife and two high school kids behind. That's, it's always unfortunate. Um, uh, but we got, we got some better, some better people in. DD (27:02): Yeah. MM (27:03): Um, someone, someone once said, <laugh>, I never, you know, I debated at times wanting to run for city council because Oh, someone who really, yeah, yeah, yeah. Someone who, but I would die on the vine. I think <laugh>. Um, but someone, someone who worked in the Whitehall area when they did their cleanup, um, her advice, Lynn talked to her and talked to her for a while, and, and this woman said, I wish I remembered her name. You don't have, you don't wanna get the right city council members on. You want to be the city council <laugh>, so run for city council. DD (27:46): Oh boy. MM (27:46): I don't know that I could have gotten, frankly, I don't know if I would've been voted in, maybe I would today, if I wanted to run 10 years ago, I don't think I would've made it. Lynn. Lynn definitely couldn't have been a city council member. It just, her gifts are so different than what, what a city council member needs to have. DD (28:06): <laugh>. MM (28:08): You can appreciate that. DD (28:10): <laugh>. Um, I've, I, one small question is CCRR, would you consider that group still active today? MM (28:22): Um, truth be told, we, um, we haven't done too much about it, but anytime Rick Rediske is on the Wolverine CAG, Gail Menowitz is on the Wolverine CAG, I'm on the Wolverine CAG. Typically, we go �down around briefly every month and introduce ourselves, and each of us will say, and I am a member of CCRR, so if we needed to get together and get more serious on another issue, you know, we would do that, we would do that. So we haven't said, we haven't, we haven't said, shuttered it and said, well, this is, you know, we're still there. We're under the radar. It's a great place to be. DD (29:12): You're reminding me of like superheroes and like, they, they go back to their regular lives for a little bit until they get a call <laugh>. MM (29:21): Sure. Well, my super, my superpower is scheduling meetings I've already talked about. Mr. Calendar comes to the rescue <laugh>. DD (29:34): Um, now that you're getting, I, I mean, I, I think it's really, um, admirable that you recognized that you were going to be burning out and so that you stepped away. I think that's something that could be really difficult to do. Um, and it's certainly something that we hear people talking about more just in general, like more awareness these days of burning out and Yes. Um, and, and how to manage it. I guess I'm curious, now that you're back kind of in the game on the CAG, um, what are your, like <laugh>, what are your, are you, are you concerned about burnout again? Are you, like, do you have strategies in place for managing that? Because I think, you know, even anyone who's interested in this kind of work advocacy, volunteer work, like those are important things to think about. MM (30:25): Yep. Yeah. One thing I'd say, there's a book out that, um, I haven't read, but I don't need to because I know what the title is and it's rest is resistance. Rest is resistance that says it all to me. I don't need to read her book. You know, maybe if she wrote an article 20 years ago, I could read that and that would be enough <laugh>, but it is really important, um, because no, it doesn't, nobody a favor. If you burn out because you get cynical, you can, you can affect other people. It's not good for your own health, obviously. Um, so, you know, I stay physically active. That's important. Again, I, I love to be outside. I love to garden. Uh, I love to bicycle in the winter. I love to bi, you know, cross country ski or snowshoe, things like that are important. Keeping up with friends. MM (31:20): Um, my involvement with, uh, my local church really is a good thing. I'm trying to get them to care more about the environment. Um, that's, that's a little bit of a, of a lift, but I think there's some people who are listening, some people younger than me that are listening, which is great. Um, but yeah. And, and Lynn and I remind ourselves that we, you know, she is, she is writing a book that she's away for a few days to work on a book as far as her story about PFAS. And some of the stories will be funny because she had some really funny experiences, and some of them will be more sober or serious. And she said, you know, I'm trying to, to weigh that. I don't know if I don't know how I'm feeling about doing this, particularly some of the darker stuff. MM (32:12): And I said to her, you know, I don't know if I'm ready for you to do it either. Hmm. So it kind of came back and that we left it there for now. We just, we know we need to have that conversation. Um, we �wrapped it, we put a wrap on it by saying the same thing I've shared. She'd be doing it for future generations or current generations to, to hear the story. Um, so in that sense, I'm absolutely behind her. Um, some of the stuff it may bring up. Yeah. I'm not looking forward to waiting through back some of that, you know, kind of having it in the house, but mm-hmm <affirmative>. We'll figure it out. We're a lot different than we were 15 years ago, and we have, we're more quickly honest with each other. And, you know, so there's good things that come out of this sort of thing. The hard things can, can produce good characteristics. Um, it's, you know, it's hard on our relationship and it's been good for our relationship. So, um, yeah, it's a mixed blessing, like so many things. DD (33:22): Mm-hmm <affirmative>. Yeah. Are there any other impacts that come to mind for you after tangling with PFAS and the tannery and all that? Any other ways that you see that change impacting your life now? MM (33:37): Um, well, yeah, I think I spoke about that at the beginning. The burden that I feel. Um, because I, I think that PFAS is the tip of the iceberg. Um, we don't have the sort of regulations for development of chemicals that we need. Um, there needs, those need to be what we've got, need to be dumped and just start restarted from the ground up because it doesn't, the, the regulations, we have to not protect the public health. Um, that's true at the state level. That's true at the federal level. Um, I have great concerns regarding the Trump administration and, um, them trying to kill off science and, um, um, dismembered the, the EPA as well as, uh, you know, the, um, the NIH, the National Institution of Health. You know, once, once you've been in this stuff and seen the consequence in people's lives, we know people who, who's been affected, whose lives have been affected by the well water that they drank, that's been contaminated. MM (35:00): It's, it's something that, that they live with. It's in their blood system. It doesn't go away. Um, who knows what all the health impacts are gonna be as the ears go on or the decades go on. Um, so you know that there's gonna be more of that. And we need people that are, can get involved in a good way with the politics. Um, you know, I know there's a story that we know about of the, the English, um, reformer for slavery, William Wilberforce, and he, he fought in parliament for 30, 30 years before the slave trade was banned. And then another 30 years before slavery was banned in the British Empire. He was at it for 60 years. You know, and he's not that, that's just one great story I know of. Um, we need people who are willing, who, you know, we need people who go beyond passion. MM (36:01): Um, because passion won't carry you, passion burns out. Um, one of my favorite novelists is Marilyn Robinson. And, um, I had the pleasure of attending a lecture that she had at a local university, and someone asked a great question, how do you, how do you decide what to write about? And she didn't use the word passion. She said, I consider the things that I think are interesting and important, and to me to think about what's interesting and important, what's interesting speaks to our gifts, you know, where we think we, we can have something and something that's important grounds us in a way that keeps us focused and coming back and important not in the way, not something that's important just for the next week, but maybe important for the next 10 years. Um, so that answer is one of the things that guides me and helps, keeps me grounded. �MM (37:08): What is interesting and important. And I think what the work of the, the Wolverine CAG is doing, trying to hold Wolverine to the, um, the descent consent decree holding their feet to the fire there. And I hope someday to be in a point of collaboration with them. That's my hope and desire that we can work as partners. Um, but it's important, it's really important because guess what, I believe there are other places they dumped that they are not telling us about, and they're in North Kent County, and those will come out someday. And there are other places in the river where the, um, you know, where the groundwater is hitting the Rogue and polluting, and it's going into the Rogue and going into the, um, the Grand River and going into Lake Michigan, and then all the way down to the Atlantic. Um, and that's just, that's in my, in the harder days, that's just incredibly disheartening because we're, we're concerned particularly about human health. One of the things I think is interesting, but I haven't done much about is what are we doing to the more than human creatures? You know, we study fish for, to make fish advisories for humans who fish and eat the fish. I'm not sure how much we're studying the impact of PFAS on the fish or on the other, you know, the grizzly bear that eat the salmon or whatever DD (38:44): Mm-hmm <affirmative>. MM (38:46): So, yeah. Did an that answer your question? I forgot your question, <laugh>. DD (38:51): That's okay. I think you sort of started answering my next question, which is, well, you kind of did both, so yay for you, <laugh>. But the next question was kind of about what concerns you have about PFAS contamination moving forward. So I think you sort of mentioned a couple things in your, in your response, but I don't know if you have other thoughts. MM (39:14): Yeah. Could we just pause for one moment? DD (39:18): Absolutely. [RECORDING PAUSED] So, do you have any concerns about PFAS contamination moving forward? I know you sort of touched on a little bit of that just before. MM (39:29): Yeah, yeah. I don't think we found all the sources. Um, as I mentioned, certainly in Northern Kent County, I don't think, um, for a while Michigan was the head of the game ahead of the game, you know, in a, in a dark way in knowing PFAS contamination. Um, then other states and, and early on after 2017, there were internationally people were coming to, um, talk with us about, uh, our experience with it because it's a worldwide problem. Um, I think, uh, I want to go back to, um, that we want to elect good officials, and we need, we need scientists as well as other citizens to care enough to work with, uh, to, to build some sort of groundswell or legislation for better requirements for companies that are, um, that are creating new things that, um, it's really hard to know how it's gonna affect people and, uh, all the other creatures that are on this beautiful broken planet. Um, I, it, my concern for regulations, I haven't �done much about it, I'll be honest at this point, but it was, um, I can't remember her last name, epidemiologist at MSU, Dr. Courtney DD (40:59): Carigan. MM (40:59): Carigan, okay. Yeah. You know, she, who, who just opened my eyes to that, that, that whole issue. Um, so, and the other thing is, is, um, we as a culture need to be willing to pay more for product that's been tested because companies should clean up as they go. It shouldn't be the, the cleanup we're paying anyway with our tax dollars for cleanups. And so how much better to address those things upfront to be really forward thinking, um, to think past the quarterly, um, the quarterly, uh, what do I wanna say, report or the annual report for a company, um, and think about really what, what are we making? Can we go more slowly? Um, that's a hard thing. We're a very competitive society. The world's very competitive. People are pressed to get things first to market and that sort of thing. And sometimes that is very harmful to the world, and it's not right. It's just not right. Um, I guess that's pretty idealistic. I understand. Um, but the more we can get people to care, um, about these things, we'll be in a better place. DD (42:40): Yeah. Is regulatory advocacy part of the CAG's purview or not? MM (42:48): You know, thank you. I will ask that question at the next meeting. Okay. I do not know. Great question. Yeah. I'll let you know what I find out. DD (43:00): Okay. That sounds good. Um, before we wrap up today, is there anything else that you want to add that we haven't touched on or anything you wanna go back to, to say more about? MM (43:14): I just wanna thank you for doing this, Dani. You're providing such a great service, um, to our region and to the world. Um, and I, I hope and pray that it will be helpful for people. So thank you. You're a great listener. You asked really good questions. Um, if you don't have any other questions, I think I'm good now. Maybe, maybe like we talked about before we got on, I'll think of 20 other things after we, we, uh, close this off. But I think what I've said is enough. DD (43:46): Thank you, Michael. MM (43:48): Thank you. Take care. � Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Living with PFAS Interviews Creator An entity primarily responsible for making the resource Devasto, Danielle Description An account of the resource Beginning in 2021, the Living with PFAS interviews were recorded to gather the personal stories of individuals impacted by PFAS contamination. PFAS, or per- and polyflourinated substances, are a large group of human-made chemicals used widely since the 1940s to make coatings and products resistant to heat, oil, stains, grease, and water. They can be found in countless household items, including food packaging, non-stick cookware, stain-resistant furniture, and water-resistant clothing. These chemicals are often called “forever chemicals” because they do not break down easily, can move through soils and contaminate drinking water sources, and build up in animals, plants, and people. PFAS have been linked to increased incidences of various cancers, increased cholesterol, decreased fertility, birth defects, kidney and liver disease, and immune system suppression, and thyroid dysfunction. It is estimated that PFAS are in the drinking water of more than 200 million Americans (Andrews & Naidenko, 2020). In Michigan alone, over 280 sites have PFAS contamination exceeding maximum contamination levels for groundwater (MPART, 2024). Date A point or period of time associated with an event in the lifecycle of the resource 2021 Source A related resource from which the described resource is derived Living with PFAS (project) Rights Information about rights held in and over the resource In copyright Subject The topic of the resource Oral history Personal narrative PFAs (Perfluorinated chemicals) Groundwater--Pollution Publisher An entity responsible for making the resource available Grand Valley State University. University Libraries. Special Collections & University Archives Identifier An unambiguous reference to the resource within a given context DC-11 Format The file format, physical medium, or dimensions of the resource video/mp4 application/pdf audio/mp3 Type The nature or genre of the resource Motion Picture Text Sound Language A language of the resource eng Oral History A resource containing historical information obtained in interviews with persons having firsthand knowledge. Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Identifier An unambiguous reference to the resource within a given context PFAS0041 Creator An entity primarily responsible for making the resource McIntosh, Michael Date A point or period of time associated with an event in the lifecycle of the resource 2025-09-09 Title A name given to the resource Michael McIntosh, 2025 (Interview video and transcript) Description An account of the resource Michael McIntosh shares his experiences organizing community action around PFAS contamination in Rockford, Michigan, from grassroots advocacy to ongoing work with the Wolverine Community Advisory Group. Contributor An entity responsible for making contributions to the resource DeVasto, Danielle (interviewer) Subject The topic of the resource Oral history Personal narrative PFAs (Perfluorinated chemicals) Groundwater--Pollution Source A related resource from which the described resource is derived Living with PFAS (project) Publisher An entity responsible for making the resource available Grand Valley State University. University Libraries. Lemmen Library and Archives Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/page/InC/1.0/?language=en">In copyright</a> Type The nature or genre of the resource Moving Image Text Format The file format, physical medium, or dimensions of the resource video/mp4 application/pdf Language A language of the resource eng https://digitalcollections.library.gvsu.edu/files/original/e3a5648f27266025fea75f33c55dfb4f.mp4 03281c02f51ed3740b55ddbc4f15cf5b https://digitalcollections.library.gvsu.edu/files/original/c8f1071931490e7dd8e604d147edb3f1.pdf 95e5f3400ed2c2c722c44062507b0fbd PDF Text Text Grand Valley State University Veterans History Project Name of Interviewee: Thomas McIntire Name of War: Vietnam War Era Interview Length (00:12:15) Pre-Enlistment    Graduated from high school, but the draft was still in effect (1:00) Figured that enlisting would be easier than getting drafted (1:15) Enlisted in the Army in June of 1965 (4:20) Training         Was not in good shape for boot camp, struggled with it (1:40) Had a drill sergeant that chewed tobacco all the time, but was a pretty nice guy (2:20) Did what he was supposed to do to pass boot camp (2:30) Wasn’t too hard (2:45) Basic training was eight weeks long at Fort Knox, KY (3:10) Came home on leave for several weeks, but went back to Fort Knox for truck mechanic school for another 6-8 weeks (3:15) Was sent to Germany after that (3:25) Went out to learn how to drive trucks one day, but he had never driven a manual truck before. It was a quick learning process (5:00) Enlistment            Discharged as a Specialist, 4th Class (0:20) Was a truck mechanic in Germany (0:30) Enjoyed the scenery in Germany (3:35) Went to the motor pool every day to work on whichever trucks needed fixing (4:00) Stayed in touch with family by writing letters, also took pictures (5:50) Never came home while in Germany (6:20) Food was nothing exciting, but got used to it because there was nothing better (6:35) There was a nightclub on base (7:00) Also had a car, so he could travel through Germany (7:20) Always had pranks going on in the motor pool (8:10) Was discharged from the Army in June of 1968 in Fort Dix, New Jersey (9:30) Post-Enlistment      Hung around his house after discharge (9:45) Got bored quickly and looked for a job (10:00) Made a few friends, but doesn’t talk to any of them anymore (10:15) Got a job, but also went back to school (10:45) Was a tool and die maker (11:00) � Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Veterans History Project Creator An entity primarily responsible for making the resource Grand Valley State University. History Department Description An account of the resource The Library of Congress established the Veterans History Project in 2001 to collect memories, accounts, and documents of U.S. war veterans from World War II and the Korean War, Vietnam War, and conflicts in the Middle East and elsewhere, and to preserve these stories for future generations. The GVSU History Department interviews are part of this work-in-progress, and may contain videos and audio recordings, transcripts and interview outlines, and related documents and photographs. Coverage The spatial or temporal topic of the resource, the spatial applicability of the resource, or the jurisdiction under which the resource is relevant 1914- Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/page/InC/1.0/?language=en">In Copyright</a> Subject The topic of the resource Afghan War, 2001--Personal narratives, American Iran Hostage Crisis, 1979-1981--Personal narratives, American Korean War, 1950-1953--Personal narratives, American Michigan--History, Military Oral history Persian Gulf War, 1991--Personal narratives, American United States--History, Military United States. Air Force United States. Army United States. Navy Veterans Video recordings Vietnam War, 1961-1975--Personal narratives, American World War, 1939-1945--Personal narratives, American Publisher An entity responsible for making the resource available Grand Valley State University. University Libraries. Special Collections & University Archives Contributor An entity responsible for making contributions to the resource Smither, James Boring, Frank Relation A related resource Veterans History Project (U.S.) Identifier An unambiguous reference to the resource within a given context RHC-27 Language A language of the resource eng Source A related resource from which the described resource is derived <a href="https://gvsu.lyrasistechnology.org/repositories/2/resources/455">Veterans History Project interviews (RHC-27)</a> Oral History A resource containing historical information obtained in interviews with persons having firsthand knowledge. Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Identifier An unambiguous reference to the resource within a given context McIntyreT Title A name given to the resource McIntyre, Thomas V. (Interview outline and video), 2005 Creator An entity primarily responsible for making the resource McIntyre, Thomas V. Description An account of the resource Thomas McIntire enlisted in the US Army three days after his graduation from high school. He was sent to Fort Knox, Kentucky for boot camp, and later for truck mechanic school. The Army sent Thomas to Germany, where he worked in the motor pool on a base there. Thomas was discharged in June of 1968, and came back to Michigan to become a tool and die maker. Contributor An entity responsible for making contributions to the resource Velting, Stacy (Interviewer) Subject The topic of the resource Oral history Veterans History Project (U.S.) United States--History, Military Michigan--History, Military Veterans Video recordings Vietnam War, 1961-1975--Personal narratives, American United States. Army Language A language of the resource eng Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/page/InC/1.0/?language=en">In Copyright</a> Type The nature or genre of the resource Moving Image Text Relation A related resource Veterans History Project (U.S.) Date A point or period of time associated with an event in the lifecycle of the resource 2005-05-26 Source A related resource from which the described resource is derived <a href="https://gvsu.lyrasistechnology.org/repositories/2/resources/455">Veterans History Project Collection, (RHC-27)</a> Format The file format, physical medium, or dimensions of the resource application/pdf video/mp4 Publisher An entity responsible for making the resource available Grand Valley State University. University Libraries. Lemmen Library and Archives https://digitalcollections.library.gvsu.edu/files/original/ce546f465a84a130a87cf548957b207e.pdf a2b4ec253cfbd33cfb12b3cf5b3f1179 PDF Text Text L L L ,: . ->•• ··. '. L R PLAN FLAT ROCK ■ ■· ■ �MASTER PLAN City of Flat Rock Wayne County, Michigan r ; Prepared by: I I I ~ McKenna Associates, Incorporated Farmington Hills, Michigan r I· January, 1990 [ ! �ACKNOWLEDGEMENTS MAYOR r- Richard C. Jones CITY COUNCIL Cynthia Marion, Mayor Pro Tern Terry Byrd Paul Gagne Timothy Nightingale Sarah Jane Olbrich Kenneth Wrobel I I. \... PLANNING COMMISSION Dennis Mowbray, Chairman Janet Baggett Norvell Barnes Lee Bobcean Daniel Swisz Steven Tallman James Vajen Terry Byrd (former member) L CITY STAFF Larry Dishaw, Director of Building and Safety 1· l_ l. �TABLE OF CONTENTS Table of Contents List of Tables iii List of Maps iii List of Figures iii MASTER PLAN GOALS Introduction POPULATION ANALYSIS General Development Trends Population Characteristics Future Population Growth Population Projections I ! l 1 1 8 8 9 14 17 EXISTING LAND USE Overview Residential Land Use Commercial and Office Land Use Industrial Land Use Public and Semi-Public Uses Transportation Landfi 11 s Vacant Land 24 24 24 24 REGIONAL LAND USE RELATIONSHIPS Overview Planning Relationships to Surrounding Communities Additional Regional Issues 25 25 25 27 HOUSING REVIEW AND ANALYSIS Introduction Age and Condition of Housing Housing Size and Density Value of Housing Projected Housing Demand 29 29 29 19 19 20 20 23 31 32 33 �TABLE OF CONTENTS (Continued) PAGE I l. [ I. I I.. ECONOMIC ANALYSIS Existing Economic Base Industrial Sector Commercial/Office Sector Market Profile Commercial Land Needs Commercial District Profiles Economic Development Trends Conclusions: Potential for Future Growth Fiscal Impact of Economic Growth 34 34 34 34 CIRCULATION ANALYSIS Overview Jurisdiction of Roads Road Classifications Circulation System Deficiencies Opportunities for Improvement Pedestrian Movement 50 50 50 51 53 COMMUNITY AND RECREATION FACILITIES City Administration and Services Public Utilities School Facilities Recreation Facilities 59 59 FUTURE LAND USE Introduction Future Land Use Map Single Family Residential Mobile Home Park Multiple Family Residential Commercial and Office Uses Planned Mixed Use Development Industrial and Railroad Use Parks and Recreation Public Facilities Road Network 72 72 35 36 37 39 42 44 56 58 63 64 65 73 74 76 76 77 78 79 80 81 81 ii �. LIST OF TABLES 1. IL. 2. 3. ' 4. 5. f - i I - 6. 7. 8. 9. 10 . 11. 12. 13. 14. 15. !1. 16. 17. 18. Total Population Population Age Structure Future Age Structure Composition of Labor Force Annual Household Income Educational Attainment Population and Household Projections Land Use Acreage Age of Housing Size of Housing Units• Value of Housing Property Value Trends Value of Classes of Property (1988) Budget History Municipal Facilities Parks and Recreation Facilities Property Inventory Comparison to Standards -- Recommended Parkland Recommended Recreation Facility Standards 8 10 11 13 13 14 18 21 30 31 33 44 46 47 61 65 68 70 LIST OF MAPS I I_ 1. 2. 3. 4. 5. 6. i. '. L Property Value History Budget and Property Tax History i ii . 22 52 54 57 60 83 LIST OF FIGURES 1. 2. !f Existing Land Use Functional Classification of Roads State, County & Local Road Classification Comprehensive Circulation Pl~n Community and Recreation Facilities Future Land Use Map 45 48 �[ MASTER PLAN GOALS l. I I I ' . Introduction This chapter sets forth goals for the Flat Rock Master Plan. These goals resulted from discussion with the Planning Commission, City Council, and department heads. They address the genera 1 deve 1opment of the City, 1and use, housing, the environment, economic development, transportation, community facilities, and recreation. General Goals 1. Neighborhoods: Foster strong, vital neighborhoods to ensure that Flat Rock continues to be recognized as a stable community where families and individuals reside, work, and shop. 2. Master Physical Planning: Maintain complementary land use relationships which promote a harmonious, attractive community; preserve natural resources; promote a sound tax base; and provide for manageable traffic volumes. 3. Property Maintenance: Recognize that the City and its physical resources are dynamic, and aggressively encourage property maintenance and reinvestment. 4. Fiscal Stability: Promote the development of a financially secure community which can continue to provide all necessary services to its residents and businesses in an efficient manner. 5. Land Use: Promote efficient use of the land and encourage assembly and orderly redevelopment if appropriate land use plans are presented for: underdeveloped areas; areas isolated among more intensive uses; or areas which are declining or negatively impacted by nonresidential traffic or incompatible land uses. 6. Planning Innovation and Flexibility: Encourage innovation in land use planning (e.g., Planned Unit Development), where innovation would: more effectively implement the goals set forth in the Master Plan, achieve a higher quality of development than would be possible under conventional regulations, result in better use of 1and in accordance with its character and adaptability, - 1 - �, . result in development that is compatible with surrounding uses, and produce recognizable and substantial benefits for the community. Residential Goals 1. Housing Balance: Strive for a housing balance that enhances the City's image as a high quality single-family residential community, recognizing that most of the City's residences are designed and built for single-family homeowners with children. · Avoid concentrations of other types of housing that would upset this desired balance. 2. Single-Family Neighborhoods: Retain single-family residential areas as secluded and quiet neighborhoods through the promotion of safe and efficient internal pedestrian and vehicular circulation systems, maintenance of citywide public services, and protection from nonresidential encroachment. 3. Housing Choice: I_ I' I !: Seek a balanced housing stock consisting of a range of housing types and price ranges, and particularly encourage the development of lowdensity, high-quality, upscale single-family housing in conventional subdivisions, for which there is an existing need. Provide a sufficient supply of affordable housing alternatives for elderly residents which will encourage them to remain in the community, balancing and diversifying the population. I [_· [ 1· I I I I. 4. Density Relationships: High- and medium-density residential developments should be separated from lower-density developments. Exceptions to this policy would be .where a higher-density residential development serves as a transition between commercial development and lower-density residential development, or where housing of varying densities is contained within a planned development. 5. Multiple-Family Development: Provide for new multiple-family housing primarily as a transitional use to separate non-residential uses from single family development. High- and medium-density housing should be located only where there is access to major thoroughfares, and only where it can be adequately served by public and private services without unreasonable disruption to the level of services enjoyed by other residents. Future multiple-family housing should be constructed of the highest quality materials. Buildings and other improvements should be placed on the site with sensitivity to natural features and the need to create a stable and secure living environment. Maintain the quality of existing multiple-family developments through strict enforcement of City ordinances, security, housing inspections, and beautification promotion. - 2 - �• 6. Housing Maintenance: Encourage housing rehabilitation and require a high standard of property maintenance to perpetuate a high quality of housing among residents. I L. • Economic Development 1. Economic Development Initiatives: Continue to develop and apply economic development tools (such as formation of the DOA, tax increment financing, tax abatements, sharing in the cost of utilities, and special assessment districts) in a prudent and efficient fashion to enhance and maintain a ba 1anced, heal thy mixture of business and industry, provided that such programs are consistent with the overall development and financial goals of the City. 2. Economic Development Incentives: Economic development incentives should be used chiefly to promote development of light manufacturing, research firms, and other types of development which: 1) are compatible with the City's goals concerning protection of residential areas and the environment and, 2) generate new employment opportunities, particularly for residents, and 3) increase the tax base. Commercial Development Goals 1. Central Business District: Recognize the Central Business District as the focus of office, specialty retail activity, and housing in a mixed use setting. 2. Telegraph Road: . Recognize that Telegraph Road north of the railroad tracks is the center of retail activity in the City. Recognize also that Telegraph Road north of the tracks, and particularly north of Vreeland Road is the center of service-type businesses in Flat Rock. 3. Gateway Commerce Center: Develop the Gateway Commerce Center as a regional convention/business center consisting of business, industry, lodging, and other regional-oriented commercial uses. Regional commercial facilities should be located near the freeway and isolated from .nearby residential areas. [ 4. . l Gibraltar Road: -Aside from Gateway Commerce Center, restrict future retail development along Gibraltar Road, but permit office and professional uses to locate along the corridor. 5. Neighborhood Commercial Districts: Restrict future commercial development within neighborhoods, since designated commercial areas on major thoroughfares will be able to supply the convenience shopping needs of all residents. 6. Revitalization of Aging Convnercial Districts: and redevelop aging business structures deteriorating conditions and the aging cycle. I 1. . - 3 - Maintain, upgrade, expand, and sites, anticipating · �,-- ! 7. Planned Deve1opment vs. Li near Shopping Districts: The deve 1opment of planned multi-tenant shopping centers or office buildings should be encouraged a1ong commerci a1 corridors, instead of unp 1anned strip development where one use is located on each parcel. Consolidation of individual uses on separate parcels should be encouraged. 8. Appearance: The design of commercial uses in Flat Rock should reflect thorough and careful analysis of the site and a sincere effort to improve the aesthetic experience. Architecture should be clean and uncluttered, and excessively large or garish signs should be prohibited. Loading and storage areas should be screened, preferably with landscaped screening or a combination or landscaping and walls. Parking areas should be landscaped to provide visual relief to large paved areas. Landscaping and setbacks should generally convey a sense of spaciousness and compatibility with the underlying natural features. Lighting should enhance the appearance of the commercial district. Lighting fixtures should be designed to complement the design of adjoining buildings. Glaring high-intensity lights should not be used in areas where pedestrian activity is desired. 9. Office Development: Provide desirable sites in the downtown area, Gateway Commerce Center,- and along Gibraltar Road for both large and smaller scale office uses which will enhance the City's tax base, be attractively developed, and create employment. Industrial Development Goals 1. Industrial Diversity: Continue to promote diversity in the City's industrial base through recruitment of high-tech, research, light manufacturing, and warehouse uses. 2. Industrial Design Standards. Promote the location of new high technology, research and 1ight industrial parks in attractive settings which will coexist harmoniously with the rest of the community. Future industrial development within planned industrial parks should be encouraged. Planned industrial parks should include an internal circulation system, needed supporting facilities, and adequate land use transitions to other parts of the City. 3. Allocation of Industrial Land. Confine future industrial to designated areas on the east side of the City, where an industrial base has already been established. Since most industries are oriented toward metropolitan Detroit or Toledo, industrial development on the east would minimize the impact on the rest of the City. The only exception to this policy would be where expansion of an existing industry in another part of the City (such ii- - 4 - �,--- I . I ' ,- • 1 as in proximity to Telegraph Road) would provide recognizable benefits, such as new employment opportunities and increased tax base, but would not have a detrimental impact on nearby residential or commercial areas or on the natural environment. I 4. f": [ ["''. Utilities and Public Services: Future industrial development should be permitted only in accordance with the ability to provide required utilities and public services, including public water and sewer services, adequate road construction and maintenance, police and fire protection, and general municipal administrative and regulatory services. The ongoing costs of providing such services should be considered, as well as the costs related to initial construction. Phase out older industrial uses in the center of the City which are incompatible with surrounding uses and the development goals for the area. 5. Obsolete Industrial Uses: Environmental Goals 1. l_ Huron River: Recognize the Huron River as the most significant natural feature in Fl at Rock. Promote development that wi 11: 1) preserve the natural riverfront environment, and 2) maximize visual and physical access to the river for all residents. 2. Protection of Natural Features: Promote the preservation of significant wooded areas, wetlands, and floodplains through the review of development plans, public acquisition of floodplain and other sensitive lands, and utilization of environmentally sensitive areas for storm water control and low intensity uses (such as recreation uses), recognizing a balance must be • achieved between natural resource goals and other planning and development goals. 3. Pollution Control: Continue to encourage land planning, development patterns and effluent treatment techniques which promote energy conservation and minimize noise and pollution of the air, soil, and water. 4. Toxic Waste Sites: Work with the Department of Natural Resources and other appropriate agencies to determine feasible uses for toxic waste sites identified in Flat Rock. Transportation 1. l. [ [: r. ~ .. Transportation Planning: Promote transportation improvements consistent with efficient access to community goods and services, public safety and convenience, and consider the capability of the transportation system to accommodate increased traffic produced by development. 2. The Need for New Roads: Identify locations and work toward installation of new roads where needed to make vacant land accessible for development in accordance with the Future Land Use Plan. - 5 - �3. Right-of-Way Widths: Limit development within the existing or planned rights-of-way as indicated on the Master Thoroughfare Plan. However, recognize that it could be several years before certain rights-of-way are acquired. Therefore, develop flexible guidelines to restrict development within such "long-range" rights-of-way where the estimated implementation is more than 10 to 15 years in the future. 4. Road Hierarchy: Develop a road system that provides access to all parts of the City, yet restricts the use of neighborhood streets by trucks or extraneous through traffic. 5. Roadway Aesthetics: Roadways should be visually pleasing to motorists, pedestrians, and persons who view the roads from adjoining land. Frontage along roads should be amply landscaped. The construction of boulevards or parkways should be encouraged. 6. Pedestrian/Bicycle Transportation: Sidewalks should be required in conjunction with all new construction, following the standard established in the older neighborhoods. Sidewalks should link residential areas with schools, recreation areas, commercial districts, and other attractions throughout the City. Community Facilities 1. Municipal Services: Develop a system of quality municipal services which are responsive and necessary to maintaining the attractiveness and vitality of the City's residential, business, and industrial districts. 2. Maintenance and- Replacement: Provide for system completion, ongoing maintenance, and replacement programs based on a continually updated capital improvement program for roads, street lights, sewers, water mains, and other infrastructure elements. Recreation Goals 1. Level of Service: Provide the maximum level of neighborhood and communityoriented recreation facilities feasible and programs to meet the needs of all residents, within the physical and financial capabilities of the City. r I_ 2. Multiple-Use Concept: Develop the City's recreation system in accordance with the multiple-use concept, whereby the City's two main parks provide a total recreation experience for the entire family. Under this concept, each community park serves a large section of the City with facilities for active and passive recreation, competitive sports, facilities for children and adolescents, and picnic and nature study. 3. Neighborhood Parks: Assure that, as the City develops, adequate land is set aside throughout the City for recreational purposes . As new residential subdivisions are built in the outlying areas of the City, the use of Cityowned properties and school properties as neighborhood parks should be encouraged. - 6 - �r-- i r- I~ [ [ r-· I.~ ~ • . 4. Activities Center: Construct a multi-purpose, community-wide activities center within the City, which would contain indoor recreation facilities, meeting room space, and central programming offices. 5. River Access: Increase public access to the Huron River through acquisition and enhancement of riverfront properties. · 6. Park Design and Landscaping: Enhance the design and aesthetic quality of all local parks, recognizing the significance of parkland to the overall character and public image of the City. 7. Coordination with Other Agencies: Continue to cooperate with ot er public and private organizations, such as the school district and Huron-Clinton Metropolitan Authority, in providing recreation services and facilities to avoid unnecessary duplication. 8. Privately-Owned Recreation Facilities: Encourage privately owned and commercial recreation facilities to locate in the City, provided the type and location of such facilities is consistent with the City's recreation goals. 9. Recreation Facilities Outside the City: Provide expanded access to important recreation resources outside of the City to increase recreation opportunities for City residents. I. 1· 1- I r· [ f [ l-: 1- - 7 - �POPULATION ANALYSIS General Demographic Trends Population growth in Flat Rock generally has followed regional trends over the past four decades. The end of World War II initiated a housing construction boom and subsequent population growth in Flat Rock. Steady growth in population continued into the 1970's, when the pace of housing construction slowed and population growth came to an abrupt halt. As indicated in Table 1, the largest numerical increase in population was recorded in the decade beginning in 1950, resulting in the addition of 2,765 residents, an increase of over 140 percent for the decade. The population continued to increase by over 20 percent in each of the next two decades beginning in 1960 and 1970, reaching a peak of 6,853. Recent population estimates indicate that the population declined by almost five percent between 1980 and 1984. TABLE 1 TOTAL POPULATION I_ I l[__ Year Numerical Change 1,231 1940 1,467 + 236 + 19.2% 1950 1,931 + 464 + 31.6% 1960 4,696 + 2,765 + 143.2% 1970 5,643 + 947 + 20.2% 1980 6,853 + 1,210 + 21.4% 1984 6,522 331 4.8% Bureau of Census, U.S. Department of Commerce. 1984 Estimate: 1984 Population and 1983 Per Capita Income Estimates for Counties and Incorporated Pl aces, Current Population Reports, Local Population Estimates, Series P-26, U.S. Department of Commerce. [ [ Percent Change 1930 Source: [ Total - 8 - �Evidence indicates that residential development and population growth in Flat Rock have been affected by two key factors: economic cycles in the Downriver area and the availability of public utilities. According to Census data, during the relatively strong economy in the 1970's almost 800 housing units were constructed in Flat Rock. In contrast, during the recession in the early 1980's an average of less than four housing units were constructed each year. In recent years, as the regional economy gained strength, a modest increase in new housing construction has been recorded. Population growth has been closely related to the level and cycles of new housing construction. The availability of public utilities has also affected new housing construction and population growth in Flat Rock. In particular, the capacity of sanitary sewer treatment facilities has limited new housing construction. The recent construction of the South Huron Valley Wastewater Treatment Plant in Brownstown Township is expected to expand the capacity of the sanitary sewer system serving Flat Rock, thereby creating new development opportunities. Population trends in Fl at Rock para 11 el the trends recorded in other nearby communities. Brownstown Township, Huron Township, and Rockwood recorded population growth through 1980. Census estimates reveal that the number of residents has begun to decline in each of these communities since 1980. Population Characteristics A review of the age composition reveals that, as a whole, the Flat Rock population is younger than the populations of other communities in Downriver and Wayne County. The 1980 census indicated that the median age of residents in the north part of the City (Tract 5990) was 30.1 years, and the median age of residents in the south part (Tract 5991) was 26.0 years. The median age for the population as a whole was 27.31 years. In comparison, the median age of the entire Downriver population was 29.7 years, and the median age of the population of Wayne County was 29.3 years. In the five closest Downriver communities the median age ranged between 24.8 and 28.7 years. l ii i__-· I_ : Closer review of age statistics reveals that four age groups increased in total number and as a percent of total population between 1970 and 1980 (see Table 2) The 20 to 34 year age group recorded the largest increase, amounting to 962 persons. An increase in the number of children under five years of age was also recorded between 1970 and 1980. The increase in these two age categories reflects the level of new household formation during the 1970's. An increase in residents was al so recorded in the two oldest age categories between 1970 and 1980. The number of residents 45 years of age or older increased by 330 persons, an increase of 24 percent. Residents in this age group account for about a quarter of the total population in the City. The number of school-age children (between the ages of 5 and 19) decreased in total number and as a percent of total population between 1970 and 1980. Whereas this age group accounted for 35.4 percent of the total population in 1970, they - 9 - �~ TABLE 2 I~ POPULATION AGE STRUCTURE r- · I [ [ l· Total Under 5 years 1970 Percent Total 1980 Percent 8.3% 637 9.3% 469 Change 1970-1980 +168 5 to 14 years 1,350 23.9 1,211 17.7 -139 15 to 19 years 651 11.5 606 8.8 - 45 20 to 34 years 1,034 18.3 1,996 29.1 +962 35 to 44 years 772 13.7 706 10.3 - 66 45 to 64 years 1,012 17.9 1,283 18.7 +271 355 6.3 414 6.0 + 59 ! i' .. 65 and older Source: I [_ I. 1· l: t_ Bureau of the Census, U.S. Department of Commerce. constituted only 26.5 percent of the population in 1980, reflecting a decline of 184 persons. A decrease was also recorded in the number of residents between the ages of 35 and 44 years. The decrease in these two age groups reflects a decline in the number of mature families with children in Flat Rock. School enrollment figures indicate little change in the number of school-age children since 1980. The number of children enrolled in the Flat Rock School District has ranged between 1,538 and 1,669 in the 1980's, a variation of only 131 students. Enrollment for the 1987-88 school year is 1,659; enrollment is expected to remain about the same for the 1988-89 school year. Estimates prepared by the Southeast Michigan Council of Governments (SEMCOG) indicate that, as a proportion of total population, the most substantial future increases are expected in the older age categories (see Table 3). By the year 2005, residents between the ages of 45 and 64 are expected to account for 24 percent of the total population, and residents 65 years and older are expected to account for 9.8 percent of the total population. Residents in the 20 to 34 age group are expected to decrease in total number as a percent of total population, from 29.1 percent in 1980 to only 20.7 percent in 2005. To summarize, the SEMCOG estimates forecast a general aging of the population, although in-migration and general population growth is expected to maintain the younger age groups at stable levels. Household Size and Composition. Broad changes in household composition have been observed in Flat Rock in recent years. Of greatest significance is the change in household size, from an average size of 3.6 persons in 1970 to 2.96 in 1980. According to the SEMCOG Small Area Forecast, average household size is expected to decrease to 2.31 persons by 2005. - 10 - �I. TABLE 3 [ FUTURE AGE STRUCTURE 1-· 1980 Under 5 years [I •. I I I L Percent 637 9.3% 774 8.1% Change 1980-2005 +137 5 to 14 years 1,211 17.7 1,423 15.0 +212 15 to 19 years 606 8.8 709 7.5 +103 20 to 34 years 1,996 29.1 1,968 20.7 - 28 35 to 44 years 706 10.3 1,404 14.8 +698 45 to 64 years 1,283 18.7 2,275 24.0 +992 414 6.0 930 9.8 +516 65 and older Source: i Total 2005 Percent Total Bureau of the Census, U.S. Department of Commerce. 2005 Estimate: Southeast Michigan Council of Governments Small Area Forecast, Version 84 The decrease in household size is attributed in part to the trend among married couples to delay or avoid having children. The aging of the population has also affected household size. The proportion of one and two-person "empty-nester" households composed of elderly residents has increased. I I__ II , i I- The type of housing constructed in Flat Rock is another determinant of household size. Approximately half of the almost 800 housing units constructed between 1970 and 1980 were multiple-family units according to Census statistics. As the number of multiple-family units increased, the number of rental units increased accordingly. The 1980 Census reported 757 occupied rental units in the City, or about 32 percent of all occupied units. Most multiple-family housing is designed to accommodate small households. In Flat Rock, the median number of persons per renter-occupied housing unit is about 2.1 persons. The combination of lower birth rates, an aging population, and smaller housing units produced the 22 percent decrease in household size between 1970 and 1980. The decrease in household size has had a substantial impact on total population. If not ·for the influx of residents due to new construction, the decrease in household size between 1970 and 1980 would have resulted in a population loss of 1,015 persons. If the SEMCOG estimates prove accurate and household size - 11 - �decreases to 2.31 persons by 2005, the resulting population loss may be as high as 1,655, based on the current number of households. Migration. The 1980 Census revealed a high rate of population migration in Flat Rock. According to the Census, over 55 percent of the City's households had moved in within the previous five years. In comparison, the Census reported that only about 42 percent of the households in Wayne County as a whole had moved in within the previous five years. r -· l- I The mobility of residents is related to several factors, including the rate of new housing construction, upward mobility, new employment opportunities, and the movement of empty-nester households into smaller homes. Regardless of the causes, the mobility of residents has the effect of accelerating population change. Population migration has had a minor impact on racial composition. In 1970, the Census reported that only four residents out of a total population of 5,683 were black. In 1980, the Census reported 82 black residents in the City, accounting for 1.2 percent of the total population. Employment and Income. The percentage increase in the size of Fl at Rock's resident labor force was much greater than the increase in population between 1970 and 1980, suggesting that a number of households have more than one wage earner. The total resident labor force in 1980 was 3,154 persons, an increase of about 40 percent over the 1970 figure. I The increase in the size of the labor force was accompanied by substantial changes in composition (see Table 4). The percentage of workers employed in precision production, crafts, and repair work decreased from 28 percent to 18.2 percent. During the same period the percentage of workers employed in managerial, professional, technical positions increased to 21. 8 percent, and the percentage of workers employed in sales increased to 7.8 percent. In spite of the shifts in labor force composition, operators, fabricators, and laborers still constitute the largest occupational category, accounting for 25.6 percent of the total resident labor force. On the whole, household and family income has continued to increase over the years, resulting in a substantial increase in middle and .upper-middle income categories. Between 1969 and 1979 the proportion of households making more than $25,000 per year increased from 5.6 percent to almost 35 percent (see Table 5). The proportion of residents in lower income categories decreased accordingly, although there appears to be a core of lower income residents. In both 1970 and 1980, the Census revealed that slightly over eight percent of all households had an annual income of less than $5,000. The percentage of households in the $5,000 to $14,999 income category decreased from over 57 percent to only about 20 percent of all households. At any rate, the continued increase in income of most households has widened the income gap between the most and least affluent households over the years. - 12 - �I TABLE 4 COMPOSITION OF LABOR FORCE Occu12ation Number Managerial, professional, technical Sales 1970 1980 Percent Number 382 17.7% 590 21.8% 109 5.0 211 7.8 !. Administrative support 300 13.9 385 4.3 f Service 235 10.8 304 11.3 Precision production, craft, repair Operators, fabricators, l_aborers 605 28.0 491 18.2 529 24 . 4 690 25.6 4 0.2 28 1.0 1-1 Other I TOTAL Source: 2,164 Percent 2,699 Bureau of the Census, U.S. Department of Commerce. TABLE 5 ANNUAL HOUSEHOLD INCOME Wayne Count~ Flat Rock Number f, Percent Number 1979 1979 Percent Percent 8.4% 14.5% Less than $5,000 116 $ 5,000 to $14,999 815 57 . 1 462 19.7 26.5 $15,000 to $24,999 415 29.1 653 27.8 24.3 $25,000 to $49,999 76 5.3 940 40.1 29.6 5 0.3 93 4.0 U.S. Department of Commerce, Bureau of the Census. 5.1 I I .· 1969 $50,000 or more Source: 8.1% - 13 - 198 �l . Education. The educational status of Flat Rock residents substantially improved between 1970 and 1980, according to the Census (see Table 6}. The percentage of residents over the age of 25 who completed high school increased from just 56.2 percent in 1970 to 73.2 percent in 1980. Based on high school completion, the educational attainment of Flat Rock residents exceeds that of residents in the County as a whole or the region. TABLE 6 EDUCATIONAL ATTAINMENT (Residents Over 25 Years of Age} Wayne County Flat Rocle Years of School Completed Number Percent Number Percent Percent Elementary School 2,401 86.1% 3,552 95.7% 89.6% High School 1,567 56.2 2,715 73.2 61.4 397 167 14.2 6.0 1,015 406 27.3 26.1 10.9 11.1 College 1 to 3 years 4 years Source: 1970 1980 1980 U.S. Department of Commerce, Bureau of the Census. Residents of Flat Rock also improved their college-level educational status in recent years. The percentage of residents who completed one to three years of college education increased from 14.2 percent in 1970 to 27.3 percent in 1980. The 1980 Census further reported that 10.9 percent of Flat Rock residents had completed four years of college. In comparison, 11.1 percent of all residents in Wayne County had completed four years of college. l I[_ Future Population Growth The level of growth of Flat Rock's population will be determined chiefly by four sets of variables: 1. Physical Parameters. Several physical variables will affect future population growth in Flat Rock, including the amount of vacant land available for residential development, the zoning restrictions placed on such land, the capacity of the sanitary sewer system, and the type of housing that is constructed in the future. - 14 - �~ 1- I [ l " • 2. Regional Economy. The economic health of the region is the most significant external variable that affects population growth in all Detroit metropolitan communities. · 3. Characteristics of the Existing Population. Characteristics of the population, such as the age structure and propensity to move will affect population growth in Flat Rock. 4. Preferences of Residents. Existing and prospective residents' preferences in terms of a living environment will have an impact on population growth. The type and affordability of housing, characteristics of the environment, and availability of public facilities and services affect people's desire to live in a community. Each of these sets of vari ab 1es are discussed in detail in the fo 11 owing paragraphs. Physical Parameters. Vacant land area on which new housing units can be constructed is a key variable that determines the absolute maximum population, or holding capacity, of the City. An existing land use survey completed by SEMCOG in 1980 indicated that 1,150 acres of vacant developable land remains in the City. In addition, there are 1,726 acres of land used for agricultural purposes. A comparison between the existing land use and future land use maps reveals that approximately 850 acres of the vacant land are designated for single-family development, and approximately 300 acres are designated for multiple-family development. Currently, there are 2,369 housing units which occupy 631 acres of residential land in Flat Rock. Therefore, on the average, each housing unit occupies 11,602 square feet of land. If the remaining single-family acreage is developed at the same density as existing residential development, then another 3,191 single-family units could be built in the City. It is likely that multiple-family development will occur at a higher density. At a relatively low density of eight multiplefamily units per acre, a total of 2,400 additional multiple-family units could be constructed of the remaining vacant land. I Based on an average of 2. 96 persons per househo 1d from the 1980 Census, the maximum population of Flat Rock if all residential lands are eventually developed is calculated to be about 23,400 persons. This estimate does not account for possible rezoning of single-family residential land to permit higher density development. Such rezoning would increase the holding capacity of the City. Equally important, these estimates do not take into account the capacity of the sanitary sewer system. This is a major physical parameter that could substantially reduce the City's holding capacity. Regional Economy. The regional economy is largely beyond the control of the City and its individual residents, but it has a tremendous impact on population growth. The general state of the economy and regional patterns of growth and development are related external variables that work in conjunction to affect population growth. - 15 - �f"" I Cycles in the economy have been cited as one of the key determinants of population change in Michigan, because of the effect of the economy on migration patterns. In general, a lackluster economy results in a reduction in the number of families that purchase new homes or relocate. Thus, a poor economy tends to preserve the status quo or, as observed in certain Downriver communities in recent years, may result in a reduction in population. During times when the economy is strong, regional patterns of growth determine the population growth of individual communities. Although most analysts believe that the regional center of growth and development is farther to the north in metropolitan Detroit, the Downriver economy has grown substantially stronger since 1984. Recent newspaper reports have documented a "new surge in residential development tied chiefly to the economic revival." 1 Demand fueled by the Mazda plant plus $1.7 billion invested in other major industrial developments in Downriver in recent years are cited as key reasons for the upswing in new housing construction. If the economy continues to rebound, it is likely that Flat Rock will eventually experience demand for new housing, provided that public utilities have the capacity to serve such development. Characteristics of the Population. The earlier review of SEMCOG forecasts revealed that the number of mature households is projected to increase over the next twenty years. However, in-migration and general population growth is expected to maintain the younger age groups at stable levels. The increase in residents over the age of 45 portends smaller household size, which is an important consideration with regards to future population growth. A fr act i ona 1 increase or decrease in househo 1d size can make a difference of hundreds in total population. SEMCOG projections for the year 2005 call for an average household size of 2.31 persons in Flat Rock, compared to an average size of 2.96 persons in 1980. As noted earlier, if the SEMCOG projections prove accurate, the effect of household size alone could range between 1,655 and 2,270 persons by the year 2005 depending on the total number of households. I. Residents' Preferences and Perceptions. Variables related to people's preferences in terms of housing and the environment in which they live will affect population growth. Residents have been drawn to Fl at Rock by a variety of features, including the availability of nearby employment, the character of the community, well-maintained public facilities, proximity to the Lake Erie and other recreation opportunities, and the convenience of being located along 1-75. L The ability of the City to maintain these qualities will affect the stability of neighborhoods, and accordingly, the growth in population. Maintaining quality housing, good public services, and other qualities of the community becomes increasingly difficult as neighborhoods and housing ages. Continued investment in maintenance and replacement by the City and individual property owners will be required. [ 1 Jack A. Seamonds, "Downriver ripples with new housing plans," The Detroit Free Press, March 20, 1987, sec. J, p. 1. - 16 - f .. L �I I . l. . ' [ . People's preferences in terms of type of housing will also affect future population growth. Single-family detached housing is predominant in Flat Rock at the present time. However, the successful development of multiple-family housing in the 1970's revealed a latent demand for a greater variety of housing types. The construction of additional multiple-family housing would increase the total number of housing units that could be built in the City. However, as noted earlier, households occupying multiple-family homes are typically much smaller than those occupying single-family homes. Population Projections Current population statistics indicate that the rate of population growth in Flat Rock has levelled off. According to Bureau of the Census estimates, the population may have actually declined between 1980 and 1984. The information presented on the previous pages reveals a number of events that could generate add it ion al population growth in future years. These events include continued growth of the local economy and increased capacity of the sanitary sewer system. It is not likely that large scale housing development will occur in Flat Rock in the near future. In spite of the successful economic development initiatives taken in recent years, statistics reveal that the overall direction of growth in the region is not toward the Downriver area. While many communities in Oakland, Macomb, and Washtenaw Counties have gained population in recent years, 1984 Census estimates reveal that all except two Downriver communities lost population since the 1980 Census. It would be reasonable to expect that recent economic development initiatives will sustain a modest level of population growth in Downriver. The most precise population projections for Flat Rock and other communities in the region have been prepared by SEMCOG as a part of its Version 84 Small Area Forecast. The small area forecast is based on local land use plans and policies, modified to account for sewer service, protection of environmentally sensitive lands, planned transportation improvements, and similar considerations. The SEMCOG projections indicate a 38.4 percent increase resulting in a total population of 9,486 for Flat Rock by the year 2005 (see Table 7). This increase is projected even though the number of persons per househo 1d is expected to decline from 2.96 to 2.31. Thus, the net increase of 2,633 residents must be attributed to the projected increase of 1,792 households. Review of these projections reveals the importance of accurate estimates of household size. If household size were to remain steady instead of decrease, the population could exceed 12,000 persons by the year 2005, assuming that the number of households increases as projected. The SEMCOG estimates are based on a healthier rate of growth than in the recent past. Between 1970 and 1980, an average of 77. 8 housing uni ts per year were constructed in Flat Rock. The pace of construction slowed to about 3.4 units per year in the 1980's. Over the 18-year period beginning in 1970 an average of [ L. - 17 - �r ·- l. . 44.7 housing units per year were constructed each year. In contrast, the SEMCOG estimates call for construction of an average of 86.8 units per year over the next twenty years. TABLE 7 POPULATION AND HOUSEHOLD PROJECTIONS Percent Change 1980 - 2005 1980 1990 2005 Population 6,853 7,661 9,486 +38.4% Households 2,314 2,731 4,106 +77 .4 2.96 2.81 2.31 -22.0 Persons per Household Source: Southeast Michigan Council of Governments Small Area Forecast Version 84. [ - 18 - �EXISTING LAND USE Overview [. l. I' · Early development in Flat Rock was oriented in relation to three primary transportation axes: Telegraph Road, Gibraltar Road, and Huron River Drive. At one time, Telegraph Road (US-24) was the major north-south transportation route in southeast Michigan, linking Detroit and communities farther to the north with Toledo. The heavy volume of traffic on Telegraph Road provided a healthy market for an assortment of retail and services businesses that were developed in a random pattern along the corridor. In Flat Rock, Telegraph Road near the Huron River became the "main street" of the central business district (CBD). The CBD eventually expanded to encompass about 12 to 15 blocks, generally east of Telegraph Road. Telegraph Road consisted of primarily retail uses, whereas the rest of the CBD contained a mixture of service, institutional and residential uses. Some of the oldest housing in the City is interspersed with the commercial and inst itut i ona 1 uses in the CBD. A sma 11 neighborhood of older single family homes also exists adjacent to and east of the CBD. Patterns of additional early residential growth were prescribed by the other two primary axes noted above, Gibraltar Road and Huron River Drive. The largest single family neighborhood in the City developed in a large triangular area bounded by Gibraltar Road on the north and Huron River Drive on the south. Huron River Drive was developed by residents who desired more substantial custom-built homes on large lots in a semi-rural setting. A second concentration of early residential growth occurred northwest of the CBD along Huron River Drive. In addition to the large lot development facing onto Huron River Drive, a small riverfront subdivision was developed north of the CBD. A fourth major transportation axis -- the railroad -- also affected the early development and general form of the City. The general pattern of commercial and residential development was split diagonally by the railroad line, demarcating the north boundary of the CBD. The northwest part of the City developed at a slower rate than the rest of the City, possibly because the tracks "cut off" the northwest from the businesses and institutions in and near the CBD. : I... r I The basic pattern of development described in the previous paragraphs was in place in 1970, when the previous master plan was completed. In more recent times, the development of the City has been affected most significantly by access to I-75 , the major north-south corridor in Michigan and the United States. The Gibraltar Road interchange created opportunities for regional-oriented development on the east side of the City. Mazda is the most prominent example of such development. Concurrently, Telegraph Road's role as a regional transportation corridor declined. Accordingly, much of the recent commercial development along Telegraph Road has been oriented toward a local market, rather than toward travellers. Some o1der businesses have become obsolete because of the reori en tat ion of the Telegraph Road market. - 19 - ,. L �,. Aside from the I-75 access and reorientation of the Telegraph Road commercial district, in recent years Flat Rock's land use profile has changed because of the construction of new types of housing. The City's predominantly single family housing stock has been diversified with the construction of mobiles homes and apartments during the 1970's. Although the City recorded a few major developments in the 1970's and 1980's, almost half of the land in Flat Rock remains vacant. Thus, the opportunity still exists to shape the City to the form desired by residents and community leaders. A more detailed review of each type of land use follows. Residential Land Use The amount of land used for residential purposes increased by about 130 acres, or about 21 percent, between 1970 and 1988 {see Map 1 and Table 8). Currently, about 754 acres, or approximately 17.5 percent of the total land area, is used for residential purposes. Much recent residential development has consisted of multiple family and mobile home construction. Multiple family complexes occupy over fifty acres of land, most of which is on the south side of Gibraltar Road, west of Cahill Road. The huge Deerfield Estates mobile home park occupies over 120 acres of land east of Telegraph Road, at the northern entrance to the City. I_ The most recent large scale single family development occurred in the southeast part of the City off of Olmstead Road, where a 280-lot subdivision was constructed in the 1970's. Scattered large lot single family development also occurred recently along various roads, such as Huron River Drive, Arsenal Road, and Cahill Road. The continued development of scattered large lot single family homes indicates the demand for such housing still exists. Development of single family subdivisions has been hindered because of, among other reasons, the lack of sewer capacity and insufficient access to vacant lands. Three broad areas are suitable for single family development but are not currently accessible via public. road: in the center of the City, north of Gibraltar Road; in the southcentral part of the City; and, in the northwest corner of the City. Commercial and Office Land Use The amount of land allocated for commercial and office use increased by over 50 acres between 1970 and 1988, an increase of almost 82 percent. The 1988 land use survey revealed that about 112 acres of land are currently used for commercial purposes. - 20 - �I • • TABLE 8 LAND USE ACREAGE Acres 1970 Change 1970-1988 Acres Percent Acres 623.7 14.7 754.0 580.3 51.8 122.0 17.5 13.5 1.2 2.8 +130.3 + 20.9 Commercial Retail Office 61.4 1.4 111.7108.9 2.8 2.7 2.6 0.1 + 50.3 + 81.9 Industrial 56.0 1.2 410.3 9.6 +354.3 +632.7 Public and Semi-Public Schools, Municipal Buildings, Religious Institutions Parks and Recreation Utilities 256.0 6.0 207.8 4.8 - 48.2 - 18 . 8 153.9 52.2 1.8 3.6 1.2 0.04 Transportation Street Rights-of-Way Railroad 482.1 11.3 530.1 323.5 206.6 - 48.0 -10.0 2,789.7 65.4 2,110.2 -679.7 -24.4 Residential Single Family Multiple Family Mobile Home Park Vacant Landfi 11 s . 1988 Percent Percent Sources: 163.8 12.3 7.5 4.8 49.3 3.8 (1) November 1988 Land Use Survey by McKenna Associates, Incorporated. (2) Comprehensive Community Plan, City of Flat Rock (March 1970) The most substantial commercial development in recent years occurred along Telegraph Road, north of the railroad tracks. With the construction of Kmart shopping center and various other nationally-recognized businesses, the north Telegraph business district has become the center of retail activity in the City. The central business district is a secondary node of specialty retail and office activity. Based on recent development patterns, continued business development on the remaining Telegraph Road frontage and redevelopment of obsolete businesses can be expected. Gibraltar Road also has the potential of developing into a commercial node, benefitting from access to 1-75. Strict adherence to adopted planning policies will be required to prevent strip commercial development that is common adjacent to many freeway interchanges. - 21 - �" / ,. ' _/ ;;::::- 1:..··., \"~? / /j ;:_.: r-7) 0 - ~ ~~~ ~ '\ ·,,<<h ·7__ . Wl .l,__\e_ CAl'IL[TOH ,, ,, " ,,,, . ,,,,--- ----L___ If---_ - 'I ., ,, ,: \1 1' I '1 ,,,, ,, 1, \' ' .... . ,,. H~W~tRG ,,,, \\ ,, 'I LEGEND □ SINGLE FAMILY RESIDENTIAL MULTIPLE FAMILY RESIDENTIAL B MOBILE HOME PARK ~ RAILROAD COMMERCIAL UTILITIES OFFICE PUBLIC & SEMI-PUBLIC INDUSTRIAL PARKS & RECREATION LANDFILL ■ VACANT EXISTING LAND · USE ■ ■ ■ ■ ■ CITY OF FLAT ROCK ■ ■ ■ WAYNE COUNTY ■ . MICHIGAN ■ ■ ■ ■ m north ,c,lo ...~~-~-I:.:::!._. . .:l: :~ ~i: I MAP 1 M!eKenna Associates, Incorporated Community Planning • Urban Design Farmington Hills, Michigan �r. : ' L. Industrial Land Use ! ~ Industrial land use recorded the largest percentage increase of any land use since 1970. The allocation of an additional 354 acres of land for industrial use represented a 633 percent increase over the 1970 industrial land use figure. The 1988 land use survey revealed that about 10 acres of land are currently used for industrial purposes. The most significant industrial construction during the past two decades was the Mazda manufacturing facility (formerly a Ford plant). The construction of this facility marked a reorientation of industry in Flat Rock, toward 1-75 instead of Telegraph Road. The facility also set a new standard for industrial design in the City. Little growth was recorded in Flat Rock's older industrial district near the City center during the past two decades. Older industries along the railroad and Telegraph Road were developed at a time when environmental planning issues were of minor importance in industrial districts. Consequently, inadequate parking, buffering, and screening of outside storage areas are common problems. The size and configuration of the sites themselves do not meet the needs of modern Industry. Based on recent development patterns, continued decline of the older industrial district can be expected. The opportunity exists to develop new light manufacturing, research, and warehousing uses on the east side of the City, where there is convenient access to 1-75. Light industrial development is proposed in the Gateway Commerce Center. Also, planned industrial park development would be an appropriate transitional use to buffer existing and new single family development from the railroad and Mazda. Public and Semi-Public Uses I I I The amount of land allocated for public and semi-public uses decreased by about 48 acres between 1970 and 1988, a decrease of almost 19 percent. The 1988 land use survey revealed that about 208 acres of land are currently used for public and semi-public purposes. The overall decrease is attributed chiefly to a decrease in the amount of land owned by the Huron-Clinton Metropolitan Authority (HCMA) The 1970 survey indicated the about 147 acres were owned by HCMA. I. l 1· i I IL '\ _ The amount of land occupied by schools, municipal buildings, and religious institutions actually increased over the past two decades . New buildings constructed during this period include the Flat Rock municipal building, several churches located along Gibraltar Road and Huron River Ori ve, and the senior citizens building in the central business district. The most significant transition in the public and semi-public land use category over the past two decades involved the general movement of such uses out of the CBD to larger sites elsewhere in the City. - 23 - �Transportation The amount of land allocated for transportation uses decreased by about 48 acres between 1970 and 1988, a decrease of about 10 percent. The 1988 land use survey revealed that about 530 acres of land are currently used for transportation purposes, including street rights-of-way and the railroad. The overall decrease is due to loss of the airport, which occupied about 57 acres according to the 1970 land use survey. The amount of land occupied by street rights-of-way increased by a small amount, reflecting the construction of new subdivision streets and the widening of certain rights-of-way. Landfills The 1988 land use survey revealed that 164 acres, or almost four percent of the City's total land area is occupied by land that was formerly used as landfill. There are two such landfill sites in the City: The former Ford Motor Company landfill on the east side of Hall Road, between Vreeland and Gibraltar Roads, and The landfill site located on the west side of Arsenal Road at the City's northern boundary. The land occupied by these former landfills apparently cannot be used in the foreseeable future. Of far greater significance is the impact these landfills have on development of adjacent lands. Vacant Land The 1988 land use survey revealed that 2,110 acres, or about 49 percent of the City's total land area remains undeveloped. There are . four broad undeveloped areas in the City: in the northwest corner, between Inkster and Arsenal Roads, in the central part of the City, north of Gibraltar Road and west of Cahill Road, in the southcentral part of the City, south of Gibraltar Road extending to Huron River Drive, and in the southeast corner of the City, in the southwest quadrant of the I75/Gibraltar Road interchange. In addition, opportunities for development exist on vacant lands along the river, and on scattered vacant sites fronting on various thoroughfares. - 24 - �-' I' ' ,--- I •. • REGIONAL LAND USE RELATIONSHIPS Overview Flat Rock is a part of the sub-region known as "Downriver." This sub-region extends approximately seventeen miles along the Detroit River, from Detroit to Huron River. Downriver contains some of the most intensively developed industrial land in southeast Mi chi gan. A recent SEMCOG report characterized the northernmost Downriver communities as follows: From north to south, the corridor is a series of blast furnaces, coke ovens, oil tanks, chemical plants, and similar industrial structures, alternating with such extensive land uses as coal piles, slag heaps, and chemical waste ponds. The overall image of the Downriver area as an intensively developed industrial region is not stt:ictly applicable to southernmost communities, such as Flat Rock. Although Flat Rock has large scale industrial development, such as the Mazda plant and the Grand Trunk rail classification yard, the City also has hundreds of acres of land that are vacant or used for agriculture. These vast undeveloped areas provide Flat Rock and other southern Downriver communities with the opportunity to implement a new land use pattern that redefines the Downriver image. Indeed, the master plans for the southern Downriver commun it i e.s propose a range of complementary land uses, with an uncustomary emphasis on housing, commercial facilities, recreation, as well as the traditional industrial uses. Although most of the City has been subject to the intensive industrial development that characterizes the northern Downriver communities, the City has not been completely insulated from the impact of industrial development in the region. A recent report identified four sites in Flat Rock that are contaminated with toxic industrial wastes. These site include the Michigan Environmental Services Company waste oil transport, treatment, and recycling facility; Huron Quarry Sanitary Landfill; Mand P Landfill; and, Erving and Vivian Brown Landfill. Planning Relationships to Surrounding Communities [_ l .. The City of Fl at Rock is surrounded by seven communities: Huron Township, Brownstown Township, Woodhaven, Rockwood, South Rockwood, Berlin Township, and Ash Township. Following review of the land use and adopted master plans of surrounding communities, two general observations can be made: 1. The past and expected future pattern of land use in Flat Rock should not deter adjoining communities from achieving their 1and use objectives. Furthermore, the proposed pattern of development in surrounding communities - 25 - i . �,· '; ' .,_ [-- . does not appear to be in conflict with desired land use development in Flat Rock. iI L_ 2. Coordination of future development in adjoining communities would achieve benefits in terms of urban design and the efficient use of public utilities. [ . The -following analysis explores the land use relationships with adjoining communities in greater detail. [ The Northern Border. Brownstown Township and Woodhaven adjoin Flat Rock on the north. Brownstown Township's master plan calls for single-family development between Inkster and Arsenal Roads, and a combination of multiple-family and mobile home park uses between Arsenal and Peters Roads. This pattern of development is compatible with the adjoining land use and zoning in Fr at Rock, which indicates a combination of single- and multiple-family land use west of Telegraph Road, and mobile home park use east of Telegraph Road. [ I_ Woodhaven's master plan specifies light and heavy industrial use between Peters Road and I-75, north of Vreeland Road. This pattern of development is compatible with the adjoining General Manufacturing and Railroad Industrial zoning classifications, which accommodate the Mazda plant and Grand Trunk rail classification yard in Flat Rock. The Eastern Border. I-75 provides a substantial buffer between Flat Rock and Brownstown Township, the adjoining community to the east. The master plan for Brownstown Township specifies single- and multiple-family uses south of Vreeland Road. Commercial development is proposed for the intersection of I -75 and Gibraltar Road. Planned unit development and light industrial use is indicated for land south of Gibraltar Road. i I_ L. The evolving land use pattern in Flat Rock is consistent with Brownstown Township's master plan in that land around the interchange is proposed for intensive, planned mixed use development in both communities. Consequently, the opportunity exists to create a full-service commercial/office/lodging district to meet the needs of travellers along I-75 as well as residents in surrounding communities. Because· of the physical separation provided by I-75, the compatibility of adjoining land use is of less importance north and south of the Gibraltar Road interchange. The Southern Border. Flat Rock is bordered by four communities on the south: Rockwood, plus three communities across the Huron River in Monroe County. The river itself and the heavy vegetation along its banks provides a buffer between Flat Rock and communities to south. Nevertheless, the single-family development pattern in the south portion of Flat Rock is consistent with a similar adjoining pattern of development in communities to the south. The Western Border. Huron Township adjoins Flat Rock on the west. The master plan for Huron Township specifies park use south of the Huron River, and singlefamily development north of the river. - 26 - �'·· <. r-- • This pattern of development is consistent with the adjoining pattern of existing and zoned development in Flat Rock. The zoning map indicates single-family and industrial use south of the river along the western boundary. In spite of the existing zoning, ownership patterns indicate that industrial-zoned land adjacent to Huron Township will eventually be developed as parkland by the Huron-Clinton Metropolitan Authority. Single-family development is the predominant land use north of the river in Flat Rock. Additional Regional Issues In addition to the immediate impact from land use in adjoining communities, there are a number of planning issues which relate to the broader metropolitan area. These issues are analyzed in the following pages. Regional Patterns of Growth. The strength of the regional economy and the patterns of regional development will affect the pace of future development in Flat Rock. Housing construction trends provide one measure of the impact of the patterns of regional growth on local communities. New housing construction occurred at a steady pace in most communities in southern Downriver during the 197O's. The recession in the early 198O's brought housing construction to a virtual halt. As the economy rebounded, housing construction resumed, but at a modest pace compared to construction in other parts of the region. Statistics indicate that the overall current direction of growth in the region is not toward the Downriver area, but is focused more toward communities to the north and west. Evidence indicates that steady growth of the Downriver economy is continuing, however. For example, Downriver housing sales in 1987 outpaced housing sales in the state as a whole, increasing by 8.7 percent over 1986 sales levels. Other reports have documented over $1.9 billion in industrial investment since 1984. Should this pattern of economic growth continue, Flat Rock is wellpositioned to benefit. A recent report prepared by the Downriver Planning Group 2 made the following observation: "It is clear that Downriver development is moving in a westward direction; consequently, development south of Pennsylvania is now centered somewhat west of 1-75." Proximity to 1-75. Flat Rock has direct access to 1-75, which has been described as the state's most important industrial corridor. 1-75 provides Flat Rock with access to industrial and commercial centers in southeastern Michigan and Ohio. Furthermore, the direct freeway access provides industries in Flat Rock with transportation savings, an expanded labor market, and an expanded market area in general. The large volume of traffic along I-75 also represents a potential market for Flat Rock retail businesses. Traffic counts taken in 1986 indicate that about 43,800 vehicles travel on 1-75 in the vicinity of Gibraltar Road during an average 24-hour period. 1 Downriver Planning Group, Analysis of Regional Projects and Development Opportunities, 1988. - 27 - �r· Regional Utility Systems. The South Huron Valley Waste Control System is a major regional utility which has had a substantial impact on growth in the southernmost Downriver communities. Prior to construction of a $34 million wastewater treatment plant which was completed in early 1988, development was held up because of inadequate capacity of the sanitary sewer system. With completion of the treatment pl ant, development is expected to resume, in particular to address the latent demand for housing in Flat Rock, and the nearby communities of Gibraltar, Woodhaven, Brownstown Township, Huron Township, Van Buren Township, and South Rockwood. Regional regional because regional Activity Centers. Certain activity centers in Flat Rock have a imp act, because of the market served, the level of employment, or of the services provided. The three principal existing or roposed activity centers in Flat Rock are as follows: - Mazda Vehicle Assembly Plant. The Mazda plant contains 2,700,000 square feet of floor area and provides employment for approximately 3,500 persons. The Mazda plant is credited with being the catalyst for a additional industrial development in Downriver, as well as creating demand for housing in nearby communities. I - Gateway Commerce Center. The Gateway Commerce Center is a planned mixed used development located south of the Mazda Assembly Plant, adjacent to I-75. If implemented as planned, this 300-acre development will be a regional center of economic activity. Retail and restaurant uses are planned near to Gibraltar Road, research and office uses farther south, and industrial uses in the southernmost portions. - Grand Trunk Railroad Classification Yard. Because of its function, the Grand Trunk rail classification yard has a regional impact. The classification yard is an important infrastructure requirement for large-scale manufacturing facilities which receive and deliver shipments throughout the country by rail. Metropark Development. Although no d·eve loped Metropark land is actua 11 y 1ocated in Flat Rock, the Oakwood and Willows Metroparks in Huron Township have the potential of creating a regional impact. In 1987, over 185,000 vehicles entered these two parks. Plans call for continued development of the parks, including the provision of winter sports, pedal boats, put-in-take fishing, additional golf course development, picnic areas, and campgrounds. Employment would increase to 25 full-time and 135 part-time employees. Upon completion of these improvements in 10 to 15 years, the two parks are expected to generate over 400,000 vehicle trips per year. This level of activity is likely to have a spillover impact on adjoining communities, generating increased traffic on access roads and possibly expanding the market for retail businesses. - 28 - �HOUSING REVIEW AND ANALYSIS I • Introduction I Even though Flat Rock is a relatively small community, it contains a broad variety of housing types: - Older, wood-frame housing is located near the City center, primarily east of Telegraph Road. - Newer conventional single family neighborhoods are located south of Gibraltar Road, east of the City center. - Large lot single-family development in rural-like settings is located along Huron River Drive, Arsenal Road, Cahill Road, and other roads which extend into the sparsely-developed portions of Flat Rock . - Cottage-type dwellings are located along certain segments of Huron River Drive, providing residents with the recreational benefits of living on the riverfront. - Higher density multiple-family housing is located in various locations, generally in proximity to the major roads, such as Gibraltar and Telegraph Roads. I l. - Mobile home development is located in the north end of the City, east of Telegraph Road. According to the 1980 Census and more recent SEMCOG building permit statistics, there are approximately 2,390 housing units in the City. There are 763 occupied rental units, or about 32 percent of all occupied units. In comparison, about 33.5 percent of all occupied housing units in Wayne County as a whole are rental units. Housing construction during the 1970' s increased the proportion of rental housing in the City. Approximately half of the almost 800 housing units constructed between 1970 and 1980 were multiple-family units according to Census statistics. In contrast, although there has been very little housing development in the 1980's, single-family development has been predominant. Almost 80 percent of the housing units for which building permits have been issued in the 1980's have been single-family units. Age and Condition of Housing L: Housing age statistics reveal that the period of greatest growth in Flat Rock was over thirty years ago (see Table 9). More homes were constructed in the 1950's -- over 700 units -- than any other decade in Flat Rock's history. Furthermore , over 60 percent of all housing units were constructed prior to 1960. The pace of housing construction remained steady in the 1960' s and - 29 - �1970's. The units constructed during these two decades account for about 39 percent of all housing units in the City. L TABLE 9 l AGE OF HOUSING Construction Period Cit~ of Flat Rock Percent No. of Units 1.1% Wayne County Percent 2.1% 1980 - 1987 27 1975 - 1980 304 12.7 3.9 1970 - 1974 354 14.8 5.9 1960 - 1969 267 11. 2 11.6 1950 - 1959 705 29.5 22.7 1940 - 1949 289 12.0 22.2 1939 or earlier 445 18.6 31.5 I I L 2,391 I Source: Bureau of the Census, Department of Commerce. 1980-1987 Figures: Southeast Michigan Council of Governments. l I. r I. A combination of two factors -- the recessionary economy and inadequate sewer capacity -- dampened the pace of housing construction in the 1980's. Building permits for only 27 housing units have been issued during the past seven years. These 27 units account for about 1.1 percent of all housing units in the City. Although Flat Rock has a high proportion of older housing units, the housing stock in Wayne County as a whole is even older. Over 76 percent of all housing units in Wayne County were built prior to 1960. However, the rebound in housing construction in the 1980's has been stronger in Wayne County than for Flat Rock. Units built during the past seven years account for 2.1 percent of all housing units in Wayne County as a whole. In spite of its age, housing in Flat Rock is in generally good condition. The need for repair and rehabilitation is evident in the older neighborhood surrounding the City center. Conditions which contribute to the deterioration of housing in this area include the age of the housing, the impact from encroaching non-residential uses, and the conversion of some homes originally designed for single-family use into multiple-family dwellings or commercial uses - 30 - �! L .. Housing deterioration is also evident along certain roads where large lot single-family development has occurred in a somewhat discontinuous pattern. Development in these fringe areas consists of a variety of housing designs and styles, constructed at different periods of time in accordance with different construction standards. Homes, outbuildings, and yards on some of the parcels in these areas have not been consistently well-maintained. Generally, housing in most other neighborhoods in Flat Rock is in good condition. However, the majority of the housing stock exceeds thirty years of age. Typically, this is the age at which the need for major repairs and replacement become apparent. Thus, maintenance of the housing stock will be increasingly important in future years. Housing Size and Density Housing size in Flat Rock is about average for Wayne County. The median size of owner-occupied housing is 5.8 rooms in Flat Rock, compared to 5.7 rooms for the County as a whole. The median size of renter-occupied housing is 4.0 rooms in Flat Rock and 4.3 rooms in Wayne County. As indicated in Table 10, almost half of the housing units in Flat Rock have five or six rooms. In comparison, about 54 percent of the housing units in Wayne County as a whole have five or six housing units. TABLE 10 SIZE OF HOUSING UNITS No. of Rooms l. I.. I I•• 1 2. 3 4 5 6 7 8 or more Source: Cit~ of Flat Rock No. of Units Percent 32 29 163 464 663 489 358 165 1.3% 1.2 6.9 19.6 28.1 20.7 15.2 7.0 Wavne County Percent Oakland Count~ Percent 1.4% 2.7 8.6 13.6 29.6 24.3 10.8 9.0 0.6% 1.8 7.9 15 .1 22.4 20.5 13.2 18.5 Bureau of the Census, U.S. Department of Commerce (1980 Data) Although Flat Rock compares favorably with the rest of the County in terms of housing size, homes are somewhat larger in the developing northern portion of southeast Michigan. In Oakland County, for example, the median size of owneroccupied housing is 6.2 rooms. Almost a third of all housing units in Oakland County have seven or more rooms. - 31 - �The highest density of single-family residential development in Flat Rock is in the conventional subdivisions near the City center and south of Gibraltar Road. The gross density of development in the subdivision located south of Gibraltar Road and east of Evergreen Road is about 4.2 units per acre. The gross density is about 3.5 units per acre in the single-family neighborhood east of Telegraph near the City center, and in the subdivision located east of Olmstead and south of Gibraltar heed. Aside from the scattered residential development on agricultural lands, the lowest density of single-family development is along such roads as Huron River Drive, Arsenal, Vreeland, Cahill, and Woodruff. Lots in some linear subdivisions along these roads typically range between one-half and one acre in size. Most parcels along these roads are not within platted subdivisions, and consequently they range in size from less than an acre to five or more acres in size. It appears that land along these roads may have once been divided for use as narrow strip farms. Along Huron River Drive, though, it appears the land has been divided to maximize the number of parcels with access to the riverfront. Higher density multiple-family development has occurred in a few locations along major roads in Flat Rock, for example, on the south side of Gibraltar Road, Vreeland Road near Telegraph, Olmstead Road in the south part of the City, and off of Telegraph Road. Multiple-family development consists of predominantly two-story apartments and townhouses, constructed at an average density of 15 units or less per acre. Value of Housing According to the 1980 Census, a majority of homes in Flat Rock have a value of between $40,000 and $59,999 {see Table 11). About 28 percent of the homes have a value of less than $40,000, and about 18 percent have a value of $60,000 or more. This assessment is based on the values specified by homeowners themselves. The housing values reported on the 1980 Census may be outdated, based on recent reports. A recent newspaper report on the Downriver housing market stated: "Nowadays, buyers are snatching up homes as fast as sellers can pack their dishes in boxes. In fact, Downriver recorded the biggest sales gain of any Michigan region during the first half of 1987 ... "3 I L The report further indicated that the increased demand for homes has produced a substantial increase in average sales price. The average sales price in the Downriver area was $42,422 in 1982. The average sales price reported for 1987 had increased to $54,083. Real estate analysts further report that a higherpriced homes constitute a larger share of the total sales. 3 r- Joe Hoshaw Jr., "Home buyers set rapid pace," The News Herald Newspapers, September 9, 1987, sec. p. 1. L - 32 - �l. . TABLE 11 VALUE OF HOUSING 1980 Value Range r· City of Flat Rock No. of Units Percent 23.6% 14.4% 25.1 37.2 31.9 777 54.4 22.0 25.8 $60,000 - $99,999 236 16.5 13.8 20.9 $100,000 or more 17 1.2 3.3 7.0 Less than $20,000 40 $20,000 - $39,999 359 $40,000 - $59,999 2.8% Wavne Count~ SMSA Percent Percent Source: Bureau of the Census, U.S. Department of Commerce (as reported by homeowners on the 1980 Census) Projected Housing Demand The projections set forth in the Population Analysis indicate that the population of Flat Rock is expected to increase by 2,663 residents to 9,486 by the year 2005. At the same time, the average househo 1d size is expected to decrease to 2.31 persons. To accommodate a net population increase of residents, an additional 1,792 housing units would have to be constructed by the year 2005. If the existing proportions of renter and owner-occupied housing is maintained in the future, then 573 of the projected 1,792 housing units will be rental units, and 1,219 will be owner-occupied units. Required residential land area can be computed using average densities of 15 units per gross acre for rental units and 3.5 units per gross acre for owner-occupied housing. Accordingly, a total Jand area of 386 acres is needed to accommodate the projected demand for housing by the year 2005. Sufficient land area exists in various locations throughout the City to accommodate this need for residential housing. For example, vacant developable acreage exists north of Gibraltar Road and west of Cahill Road, west of Arsenal Road on the west side of the City, and north and south of Woodruff Road in the southeast part of the City. The land in these areas is appropriately zoned for residential use. - 33 - L.,. �ECONOMIC ANALYSIS Existing Economic Base l. l_ The economic base in Flat Rock consists of chiefly two components: the industrial sector and the commercial/service sector. The industrial sector serves a regional market, and draws employment from throughout southeast Michigan. In contrast, the commercial/service district serves principally local residents and trave 11 ers a1ong Telegraph Road. Characteristics of these two components of the economic base are described in the following paragraphs. Industrial Sector I_ I· l. I_ r· I Based on total employment, volume of production, and similar criteria, the industrial base in Flat Rock is dominated by the Mazda Motor Manufacturing (USA) Corporation, which is located at the I-75/Gibraltar Road interchange. The Mazda plant contains about 2.7 million square feet of floor space, and employs about 3,500 people when at full production. Full production capability of the Mazda plant is 240,000 vehicles. Flat Rock contains a variety of other, smaller industrial-type concerns, many of which have been in operation for several years. These include Flat Rock Metals, Scheel Concrete, AAA Sign Company, Flat Rock Bagging Company, and Astro Oil. Most of these industrial facilities are located on the west side of the City, in proximity to the Telegraph Road corridor. The Grand Trunk rail classification yard is also a major industrial/transportation facility. This classification yard serves industry throughout southeast Michigan. The classification yard is located on the north side of Vreeland Road, just over a half mile west of I-75. Commercial/Service SectorThe commercial/service sector in Flat Rock consists of three districts: the downtown area; the linear commercial district along Telegraph Road, north of the railroad tracks; and, the linear commercial district along Gibraltar Road, extending from I-75 to downtown. The businesses in these three districts provide basic necessities. However, residents must shop outside of the City for certain goods and services, particularly if they desire a broader selection of comparison goods. Also, certain specialized services, such as the services of a stockbroker or medical specialist, must be acquired outside of the City. Numerically, service-type businesses and retail businesses are predominant in Flat Rock's commercial/service sector. About 40 out of a total of 149 existing businesses provide some type of service. Service businesses include beauty and barber shops, dry cleaning establishments, car washes, video rental, vehicle repair shops, heating and air conditioning service establishments, and similar uses. i_ - 34 - �Retail stores account for 36 of the businesses in Flat Rock. Convenience retail uses are predominant, accounting for almost half of all retail uses. Convenience goods are those that are consumed on a daily basis, such as groceries, drugs, and hardware items. About thirty percent of a11 retail businesses of fer comparison or "shopper" goods. Comparison goods are purchased less frequently and usually only after people have compared prices and quality of competing stores. Examples of comparison goods businesses in Flat Rock include the auto dealerships, the lumber company, the floor covering store, and the paint store. Flat Rock also contains seven specialty retail establishments, accounting for about twenty percent of all retail uses. Specialty retail establishments include gift shops, a tack shop, bait and tackle shops, and a mobile home supply business. In addition to service and retail businesses, other major categories of business in Flat Rock include offices and restaurant-type uses. A total of 26 office uses are located in the Flat Rock commercial/service districts. Most offices are occupied by banks, insurance agents, attorneys, and medical practitioners. i. Restaurant-types uses include full-service restaurants, fast food establishments, and bars. There are 19 restaurant-type uses located in Flat Rock. Other types of businesses located in the commercial/service sector of Flat Rock include hotels/motels (4 establishments), equipment rental businesses (2), public uses (1), and recreation uses (2). Ten vacant commercial buildings or storefronts are presently located in Flat Rock. Market Profile According to data compiled by Urban Decisions Systems, the retail market located within a five-mile radius contains 25,411 households with a total population of 73,957. 4 The median annual household income is estimated at $36,731. I_ _ l By 199~, the number of households in the market area is projected to increase to 26,741 and the population is expected to increase to 75,717. The median annual household income is expected to increase substantially, reaching .$46,166 in 1992. These projections indicate that, although the number of households and total population is expected increase by a modest amount, the purchasing power of residents is expected to increase substant i a1ly. Thus, based on income projections alone, there is strong potential for expansion of the retail sector in Flat Rock. 4 Source of market data: Urban Decisions Systems, Inc., as reported in Gateway Convnerce Center, a market study prepared by Rainmaker Holdings, Inc., January 1988. - 35 - �I I ' I. I • · The market study for the Gateway Commerce Center revealed that t~ere is market support for specific types of retail stores in the trade area. These conclusions are based on a random survey of residents in the trade area that was conducted as a part of the market study. I.. · The survey found that, due to the limited range of shopping facilities in the trade area, a majority of residents shop at malls or shopping.centers outside of the trade area for non-grocery items. Southland Mall in Southgate is the most popular shopping center, frequented by 43 percent of residents in the trade area. l. The market survey found that many residents would be willing to change their shopping habits in favor of new retail facilities that offer better selection, better services, or more competitive prices. In particular, the survey found that development opportunities are best for certain services (such as tax preparers, cleaners, and eye care), clothing stores, general merchandise stores, a large hardware store, a department store, recreation services (such as a movie theater or bowling establishment), and full-service restaurants. Commercial Land Needs The income data presented above can be used to calculate the purchasing power of residents and the amount of retail space needed to serve the trade area population. Data collected by the U.S. Census indicates that about 39 percent of all personal income is spent on retail goods, with about ten percent spent on durab 1e goods and about 29 percent on nondurable and convenience goods. Accordingly, the potential retail sales volume generated by residents in the trade area is estimated as follows: Durable Goods: Nondurable Goods: $123,016,620 356,748,200 Total Potential Retail Sales Volume: $ 479,764,820 Retail floor area requirements are calculated by dividing the sales volume estimates by sales per square foot information for existing businesses. Information concerning sales per square foot are provided by the Urban Land Institute in its annual publication Dollars and Cents of Shopping Centers, the U.S. Census, and various local economic development publications. Based on these sources the average sales per square foot is estimated to be about $125 for comparison goods and about $225 for convenience goods businesses. Based on these averages, the retail floor space needed to serve the 1992 trade area population is estimated to be 10,278,722 square feet. I.. A general standard for retail uses is that the total site area should be about four times the gross building area. Based on this ratio, the land area needed to accommodate the future commercial needs of residents in the trade area is about 240 acres. Since only about 112 acres of land are allocated for commercial use in Flat Rock, according to the 1988 land use survey, the opportunities for future growth of the commercial sector appear strong. This trade area need, however, will be addressed partially by commercial facilities in surrounding communities. - 36 - �. Commercial District Profiles North Telegraph Road Business District. Analysis of the distribution of businesses reveals that the City's three commercial/service districts serve different functions and markets. The linear commercial district along Telegraph Road north of the railroad tracks appears to be the primary focus of retail activity in the City. Retail, service, and restaurant uses are predominant in this district. The quality, character, and size is as important as the actual number of businesses in this district. North Telegraph Road is Flat Rock' s newest commercial/service district, containing regional and nationally-recognized businesses located in modern-looking buildings on spacious sites. The combination of generally attractive surroundings and modern marketing techniques increase the appeal of this district. Of the three commercial/office districts 1ocated in the City, north Telegraph Road generates the greatest amount of economic activity. Downtown Flat Rock. Compared to the north Telegraph Road district, downtown Flat Rock contains almost twice as many businesses, including almost twice as many retail and service uses. However, the level of economic activity in the downtown area does not match the level of activity along north Telegraph Road, for the following reasons: I- I. !I - l... - The downtown business district was developed several decades ago. Many buildings and businesses have not been modernized or updated in recent years. - The downtown area was initially planned intensively-developed, compact district. buildings are small. Modern standards call street parking, and much larger buildings merchandise. with the intent of creating an Lots are shallow and narrow, and for spacious lots with ample offto contain a greater variety of - The economic impact of the downtown area is dispersed among several streets, including Huron River Drive; Gibraltar Road, between Division Street and Tel~graph Road; Seneca Street; and Telegraph Road, between the river and the ra i1 road tracks. The economic imp act of downtown businesses is further dispersed by _the presence of non-commercial uses, including homes and churches, in the business district. A report completed in 1976 cited these and similar concerns about the central business district. 5 Among the conclusions stated in CBD Report are the following: 5 Norman L. Dietrich Associates, P. C. , City of Flat Rock CBD Report, April, 1976. - 37 - �There is no smooth continuous east/west through traffic flow in the study area. - The number of streets and alleyways that segment the CBD are a deterrent to sound commercial growth. - There is no separation of through traffic, local traffic, and shopper traffic. - The Huron River has been neglected as an important resource and focal point in the central business district. - The center of gravity for commercial growth in the central business district is along Telegraph Road with a small nucleus at Telegraph and Huron River Drive. - The Telegraph Road frontage has many of the problems associated with typical strip development, such as excessive signage, fragmented facades, and lack of any real identity or sense of place. - The mixed use area has within it the basic framework for sound development. - Where possible, more intensive residential developments should occur within or on the fringe of the central business district. Many of the concerns cited in the CBD report have been addressed in the intervening· years~ The visual appearance and pedestrian environment were improved through implementation of a streetscape program. Construction is nearly complete on a new senior citizens housing complex on Telegraph Road in the heart of the central business district. Nevertheless, because of certain inherent constraints, downtown Flat Rock accommodates many comparatively small specialty retail and service businesses which do not depend on a steady or large volume of customers or sales for their livelihood. For example, several businesses in the downtown area operate on an appointment-only basis, and some service businesses have little or no walk-in trade at all. 1.- The downtown does stand apart from the City's other commercial/service districts because of the number of office uses. Twenty office uses are located in the downtown area, many of which are located in redesigned homes. Offices for attorneys, medical practitioners, insurance agents, and real estate agents are well-suited for downtown Flat Rock, because these businesses do not create a severe traffic or parking demand. In summary, the evolving development pattern suggests that the economic health of downtown Fl at Rock depends on a mixture of reta i1 , service, office, and residential uses. Gibraltar Road Business District. The third commercial/service district, along Gibraltar Road between 1-75 and downtown, consists of mostly service-type businesses, such as service stations, vehicle repair, video rental, and a selfservice auto wash. - 38 - i. i . L., �Businesses along Gibraltar Road are dispersed over a two-mile distance. The commercial uses are widely separated by the more predominant residential and institutional uses and vacant land along Gibraltar Road. The quality of commercial development along Gibraltar Road varies considerably. A gasoline service station and a Ford auto dealership--both well-maintained, viable operations -- anchor the district at the east end. New development proposed for the Gateway Commerce Center is expected to generate additional high quality, regional-oriented development near 1-75. I I- Elsewhere along corridor, businesses appear to be less viable, and the buildings and grounds are rundown in appearance. The only shopping center along this section of Gibraltar Road is dated in appearance, lacks adequate landscaping, and exhibits signs of inadequate maintenance. Economic Development Trends Various local, regional, and national trends affect current and future growth of the commercial and industrial sectors in Flat Rock. The potential impact of major economic trends is described in the following paragraphs: 1. General Growth Patterns in Downriver. The general direction of growth in Downriver indicates that the opportunities for economic growth in Flat Rock will be strong. A recent analysis of regional projects and development opportunities found that a significant band of development is taking shape in the central third of the Downriver area, generally along the 1-75 corridor. 6 A recent newspaper report further noted that "The Downriver is growing to the south and west, thanks largely to affluent families looking to build new homes instead of buying existing ones." 7 As the leading edge of development in the region continues to expan_d to the west and south, proposals for new development can be expected in Flat Rock. i-i 2. Growth in the Trade Area. Aside from regional growth patterns, the projections cited earlier in this chapter indicate there is inherent growth in the Flat Rock trade area. Modest increases in the number of residents and households are projected, but a substant i a1 increase in the average hous.ehold income is expected. This inherent growth in the trade area creates the opportunity for steady expansion of the local economy. ,1 I i t__ 6 Downriver East-West Trunkline Studv, vol. 1987. 7 Curt Smith, "Burgeoning Communities Record Housing Bonanza," The News-Herald, December 28, 1988, p. 10-A. - 39 - 2 - Data Inventory, November 20, �'· r· L 3. Changes in the Methods of Reta i 1i ng. Methods of reta i 1i ng have changed dramatically since the time when downtown and many isolated businesses were constructed. Modern retailing standards call for much larger inventory than in the past, spacious sites with off-street parking, and high-visibility. These changes in retailing affect the viability of older businesses and business districts, particularly the central business district, which is now better-suited as a specialty retail and office district. Even older businesses along Telegraph Road north of the railroad tracks are experiencing intense competition from the newer businesses. Consequently, continued redevelopment of i so 1ated obsolete reta i 1 businesses can be expected along Telegraph Road. 4. Changes in Industrial Processes and Industrial Development Standards. Industrial operations have changed substantially in the past two decades, creating growth opportunities and rendering certain industrial operations obsolete. Small industrial plants on cramped sites in the heart of the City fail to meet the standards of modern industries. In terms of function, most small and medium-size industries no longer rely on rail transportation. Modern industries are concerned about image, availability of space for loading/unloading, availability of space for expansion, and isolation from incompatible residential or commercial uses. Most new industrial development occurs in planned industrial parks. Studies have shown that Downriver has failed to keep up with the needs of modern industry, as reflected in the fact that Downriver contains only 12 percent of all industrial parks in southeast Michigan. This development void provides an opportunity in Flat Rock to develop industrial park facilities that meet the needs of modern industries. ; l ·- 5. Growth in the Service Sector. Increasingly, industrial commodities are being replaced by knowledge-based and information-based services as the most critical components in the national economy. The result of this trend is the growth of the service sector, including such businesses as information processing, transportation, communications, insurance, financial services, accounting, l ega 1 counseling, management consulting, advertising, design services, real estate, marketing, and so forth. The growth of the service sector creates opportunities for development of office-oriented businesses, which are not currently well-represented in the local economy or Downriver as a whole. 6. Computerized Technology. The widespread introduction of computerized technology is creating new operating procedures for business organizations. The most apparent impact of computer technology is to automate low-skilled work. Computer technology also permits remote management, so that the production of services need not take place where the services are consumed or used. As a result, certain clerical and other functions normally associated with management need not be located in the same high-rent office district as the administrative offices. The relatively low cost of land in Fl at Rock could meet the requirements for such computer-1 inked office functions. r· Ii - 40 - �' L. 7. Proximity analyzing center at following to Metro Airport, Detroit, and Toledo. In recent market studies the potential demand for a suite hotel and executive conference the Gateway Commerce Center, Pannell, Kerr and Forster cited the locational factors in favor of such facilities: - Proximity to Detroit Metropolitan Airport, Accessibility to the entire Detroit metropolitan area via I-75 or I-275, - Accessibility to Monroe, Toledo, and locations farther south. These same 1ocat i ona l factors favor the deve 1opment of other types of commercial, service, and industrial facilities in Flat Rock. For example, retailers are beginning to realize that by locating their warehouse near the I-75/I-275 interchange they have direct access to all parts of the metropolitan area. Similarly, industrial suppliers located in the Flat Rock area can serve industries in both Detroit and Toledo. I. I !' . In recent years, the lack of adequate sanitary sewer 8. Sewer Capacity. capacity has hindered economic growth in Flat Rock and surrounding communities. This constraint was removed with the completion of the South Huron Valley Wastewater Control System, also called the "minisewer," which serves Flat Rock, Brownstown Township, Gibraltar, Huron Township, Woodhaven, and South Rockwood. 9. Free-Trade Agreement. According to economic analysts, the recently approved Free-Trade Agreement (FTA) between the United States and Canada offers the potential for substantial economic growth in southeast Michigan, including the Downriver area. According to one report, 10,000 jobs could be created in southeast Michigan as a result of the FTA. The report further stated that "proximity to Canada, and cost of land will make the I-75 corridor attractive to businesses that want to capitalize on the FTA. The Gateway Commerce Center, in particular, could benefit from the FTA if the impact is as widespread as predicted. 10. Spin-off Effect of Mazda. Flat Rock has yet to realize the full spin-off effect from Mazda, resulting from the construction of small manufacturing facilities by suppliers. The benefits of Mazda's presence has been felt by several surrounding communities, such as Rockwood, where Mazda suppliers have located. The potential for additional spin-off benefit from Mazda exists in Flat Rock, provided that industrial park facilities are available to accommodate the manufacturing concerns. [[ [ r I,_ 11. Catalyst Effect from the Senior Citizens Building. Completion of the senior citizens residence could be a catalyst that generates new growth in downtown Flat Rock, in contrast to the longstanding pattern of development in the outlying areas of the City. Besides providing a market for some types of retail stores and service businesses, the building provides a new, modern image for downtown. Frequently, a development of such magnitude induces other property owners and businesses to update their facilities or operations. - 41 - �Conclusions: I Potential for Future Growth Potential for Future Commercial and Office Development. The analysis presented in this chapter indicates that strong potential for future commercial and office development exists in Flat Rock, as the population, number of households, and total income in the trade area continues to increase. Research cited herein reveals that the Flat Rock trade area is currently underserved in terms of retail facilities, based on comparison with other communities. The potential for further commercial growth is also reflected by survey research, which revealed that residents of the trade area travel several miles to major shopping centers to do much of their shopping. Many residents indicated they would be willing to change their shopping patterns if competitive, quality retail facilities were constructed nearby. In summary, it appears that the strongest need is for community-oriented shopping centers and services. As such development occurs, it is expected that the particular function, or market niche, of each commercial district will become better defined. North Telegraph Road is expected to retain its status as the primary retail and service district in the City. The downtown area is expected to develop as a mixed use center of office development and specialty retail. The function of the Gateway Commerce Center is 1east we 11-defi ned at the present time, a1though the potent i a1 exists for regionally-oriented retail, office, lodging, and light industrial development. As one of the main entranceways to the City, the Gibraltar Road frontage west of Olmstead Road would be best-suited for low-intensity office development. Offices would be compatible with adjacent institutional uses that have been developed in recent years, and would provide a good buffer between the road and existing or future residential development on the interior. Potential for Future Industrial Development. Prior to construction of the Ford plant, industrial development in Flat Rock was limited to a variety of small operations located near the center of the City, generally adjacent to the railroad tracks. The construction of the Ford plant and then Mazda dramatically altered the industrial profile of the City. The attributes that attracted Ford and Ma~da to locate in Flat Rock would be equally attractive to other industries. Industrial developers cite five major consideration which determine suitable industrial locations: transportation, labor supply, energy and other utilities, availability of land, and public policy. Additional considerations that are relevant when selecting a specific site include the topography and soil conditions, the direction and composition of population growth, and the types of industries that are expanding or moving into the area. The following analysis reveals that, when measured in terms of these considerations, certain portion of the City are well-suited for industrial development. - Access to Transportation. The primary industrial location determinant is convenient access to freeway transportation. Research has shown that over three-quarters of all land developed for industry is located within 2.5 miles of an interstate freeway interchange. A freeway location provides industries - 42 - �with substantial transportation savings, access to In expanded labor market, and an expanded trade area. Immediate access to 1-75, which has been described as the state's most important industrial corridor, was clearly one the major locational determinant for Ford and Mazda. Heavy industries in the City also benefit from the Grand Trunk railroad facilities. [ I - Labor Supply. The availability of a trained labor force is an industrial need that can be met by the Downriver labor force. According to the 1980 Census, a greater proportion of people in Downriver are employed in manufacturing-about 37 percent-than in any other sub-region in southeast Michigan. In addition, industries in Flat Rock have access to the trained labor markets in more urbanized communities nearer to Detroit and Toledo. - Energy and Utilities. Industry requires a reliable supply of energy and adequate utility services, including water supply and sanitary sewer service. Detroit Edison provides electrical service to the City, and natural gas is supplied by Michigan Consolidated Gas. As noted earlier, the limitations caused by inadequate sewer capacity were resolved with the completion .of the South Huron Valley Wastewater Control System, also called the "minisewer." The City of Detroit water system currently serves the City. - Ava i 1abi 1i ty of Land. The need for 1arge amounts of 1and, both for the initial construction and for later expansion, has been cited as one of the key reasons that industries have moved out of urban core areas. Large industrial sites are needed that are suitable for construction and free from drainage problems. Several hundred acres of vacant land on the easterly side of the City could potentially be used for industrial development in Flat Rock. Three genera 1 areas have been identified as being particularly well-suited for industrial development: I. Another manufacturing/heavy industrial use would be appropriate for the former Ford Motor Company industrial plant on Gibraltar Road at I-75. 2. Light industrial, research, and warehousing uses would be appropriate in the Gateway Commerce Center industrial park. 3. Light industrial, research, and warehousing uses would also be appropriate as a buffer along Hall Road and Vreeland Road, to separate future residential development from Mazda and the Grand Trunk railroad yard. - Public Policies. Research in recent years has documented the relationship between public policies and the ability to successfully operate a business or industry. Public policies with the greatest impact on industry in Flat Rock are reflected in the adopted planning and zoning standards. Review of these documents reveals that the City has set aside sufficient land to accommodate industrial growth. Further evidence of favorable public policies include the City's actions to allow Mazda to locate into the City, and creation of a Planned Unit Development ordinance and tax increment financing authority to facilitate establishment of the Gateway Commerce Center. I. ! I I. - 43 - �r-- I . 1 .• 1··I l,·, . This analysis indicates that conditions are conducive for industrial growth in Flat Rock. Vacant lands on the east side of the City are best-suited to the locational requirements of industry because of the immediate access to 1-75. Reuse of the vacant Ford Motor Company p1ant for heavy industry would be appropriate, but other industrial lands would be better-suited for light industrial, research, and warehousing uses. t Fiscal Impact of Economic Growth Property values pro vi de one of the best measures of economic growth. As indicated in Table 12, Flat Rock experienced rather substantial decline in property values from 1982 through 1986. Total State Equalized Value (SEV) dropped from a high of $152.4 million in 1982 to $79.2 million in 1986, a decline of about 48 percent. TABLE 12 PROPERTY VALUE TRENDS Year ,i .. ($000,000) Percent Change 1989 $84.9 1988 81.8 + 2.3 1987 79.9 + 0.9 1986 79.2 -11. 3 1985 89.3 -10.7 1984 100.0 -32.6 1983 132.7 -12.9 1982 152.4 + 5.5 1981 144.5 Source: - 3.8% 1988 Annual Report, City of Flat Rock. As indicated in Figure 1, the decline in the total value of property parallels the decline in the value of industrial property during the same period. Most of the decrease in value of industrial property can be attributed to the shutdown of the Ford Motor Company plant. Because of tax abatements, the construction of Mazda did not restore property levels to their former level . - 44 I I l. �;---- ~ 140 110 ililllllllii::11111:::1i 100 90 0 ::) ....J < > 80 • ·1:1 ■!l~ll!ill!~Ji!!III~~ 111:11111111111~ Hlil!il iilillii!ilili!ll!Hiii!!iii!j:iiM 1 70 @ 60 en en w en en < / 1 0 ~ w . ·•·•·•·•·'.-'.i;:ft._ 120 0 - --- ~I iiiiil lil ilil!l!l l!II i iili!I ill 130 -g - r-~-- 50 40 30 20 10 11 1:11 :i;::r ::;I !II l!'-1!1!1.1!1111111111111~ Ii I JI::;;;:: 1 .; ti !lilil iilillillllll!i II ll•l~\IIIH:111 Iii :11111.l i I iH!ilil li:·11:li i H ;:1:1: 111111111 ::1 illHi 1:111:: 1 1 1 HI 11 :i ;: il!ilil !il i :111:1 i : ilili Ii iIilJH I IIll!! II1: -liliilllilliiilil!i!lilllll ili!IJl;liilllllll■Hllil i lil il . ,;;:. ;•::: :::;:; liiiililll ii lliiiil i i ::::.::~:::::::w !/i~i!; N ·········· .....•.·· :•:•:•:•.•:•:•:•:•:•.•···· •.·.·.•,:.·.·······•:•:•:• •:•:•:•:•: ···············• •:•:•:•:•:•:•:•:•:•:•:•:• 0 TOTAL ASSESSED VALUE ••••••••••••••••••••• •••••••••• ••••••••••••••••••••••••• •••••••••••••••••••••••••• 1980 1981 1982 1983 1984 . . • --~ . . 1985 :• ::::::::: ; ; :•'❖"❖'❖ '❖'•·············· ············· ·················· :::::••.•••• •.!.•-•'• •••• ••'• ••••••••••• •' ·:::• .:....::: 1986 COMMERCIAL ASSESSED VALUE INDUSTRIAL ASSESSED VALUE ················ UTILITY ASSESSED VALUE 1987 1988 PROPERTY VALUE HISTORY CITY OF FLAT ROCK RESIDENTIAL ASSESSED VALUE Figure 1 Source: City Assessment Record �rI.. , r- ~ • ! I,_ The slopes of the lines in Figure 1 depicting total assessed value and industrial assessed value are very similar, reflecting the impact of industry on the economic well-being of the City. During the nine-year period covered in Figure 1, the assessed value of residential, commercial, and utility properties remained nearly level. · [-_ l_- The impact of various classes of property on total land value is indicated in Table 13. Residential real property accounts for greatest proportion of the total equalized value, about 57 percent. According to the 1988 land use survey, residential land uses occupy 17.5 percent of the total land area in the City. A large proportion of the vacant lands in the City, however, are also considered residential properties for the purposes of tax assessment. TABLE 13 VALUE OF CLASSES OF PROPERTY (1988) r Equalized Value of Real and Personal Property ($000) I I- Commercial Industrial Residential Utility Source: $18,717 8,739 40,409 3,049 Class Value as a Percent of Total SEV 26.4% 12.3 57.0 4.3 Records of the City Assessor Commercial real and personal property accounts for the next highest proportion of the total equalized value, about 26.4 percent. Commercial land uses occupy about 2.7 percent of the total land area. Thus, commercial uses provide a fairly high return in comparison to the amount of land occupied. i ' l·-· [__ [ : The return is not nearly as great for industrial uses, which account for 12.3 percent of the total equalized value.· Even though industrial uses currently account for about half as much of the state equalized value as commercial uses, industrial uses occupy almost four times as much land area. Given current conditions, the figures in Table 13 indicate that industrial land use is the least cost-efficient use of land in the City. This assessment does not take into account other benefits from industry, though, such as job creation and state generated funds. The decline in property values and tax revenues has forced the City to reduce expenditures and limit the expansion of public services. Table 14 and Figure 2 indicate the irregular year-to-year changes in the general fund budget, a result of the adjustments made necessary because of declining property tax revenues. The largest percentage decrease in the general fund budget, a decrease of 17.1 percent, was recorded in 1983. The budget declined in every year except - 46 - �one between 1983 and 1987. a 10.4 percent increase. This decreasing pattern was reversed in 1988 with TABLE 14 BUDGET HISTORY Year General Fund Budget Percent Change 1989* $2,500,575 + 2.2% 1988 2,445,910 +10.4 1987 2,215,498 - 2.9 1986 2,280,531 - 1.3 1985 2,309,476 - 1. 2 1984 2,282,014 + 2.8 1983 2,218,856 -17.1 1982 2,676,665 +18.7 1981 2,254,5~4 - 1. 7 1980 2,293,228 Source: Treasurer, City of Flat Rock * 1989 Estimate by Williams, Herbert &Jocks l l [ r 1, I In summary, largely due to the decline in industrial property values there was a subsequent substant1al decrease in tax revenue. The loss in revenue imposed severe constraints on the normal operations of the City, caused by cutbacks in the budgets~ The pattern of decreasing tax revenues and budgets was finally reversed in 1988. The analysis presented in this chapter indicates that opportunities for continued economic growth exist, particularly in the following areas: - Commercial growth is expected to occur in three locations: along Telegraph Road, downtown, and in the Gateway Commerce Center. Telegraph Road north of the railroad tracks will continue to develop as the primary retail and service district in the City. A mixture of specialty retail, office, and service uses, as we 11 as resident i a1 deve 1opment is expected downtown. Because of its location adjacent to I-75, regionally-oriented planned mixed use development is most appropriate for Gateway Commerce Center. - 47 - �r -·} r~ I ·1 ,- -- ·---, ,--·--; !7 --i ~ .. . •,~i ,. r-- .-,. i , ::-~---1 2,800 - - - - - - ~ 2,600 2,400 "'11.:111111::1•1111111 2,200 : i: 2,000 1,800 _ 0 0 0 fh 1,600 1,400 • i I• 1•:1 •11:11•: :1• 1!!•• !II!! ! 1:1 •: I 1 •:1 ll!il 1■1~1111111111111! 1J!Ji!l l lil !il !lil <C _J _J •.iH•.•··••1~;;1 1••1!•1;~·T· r· 1·r·· 1· 1 '' 1,200 11 •n mrnm 11• 1•11111:1 !I•11• il!l!I!! 11 •1111,::r Ii 111 !l!lllll!il!llll!IJ•liiw 0 0 :11 .1Biilllllilllillil!illi11!1il•!l!ll!l!l•!!llllll■ll!l-llli•l1illl ( /) a: :: 11•:Hli:lll!l !I! 1,000 800 600 400 200 0 1980 1981 1982 1983 1984 1985 1986 1987 1988 1'989 BUDGET AND PROPERTY TAX HISTORY e ·1TY OF FLAT ROCK Figure 2 Source: City Treasurer �- In addition to downtown, which serves as the current office center for Flat Rock, office development would be appropriate in the Gateway Commerce Center and along Gibraltar Road, west of Olmstead Road. The development of welldesigned and lands caped office uses along Gibraltar Road would create a pleasing entranceway to the City. From a land use perspective, office uses would be more compatible with surrounding residential and institutional uses than strip commercial development. - Future industrial development would be suitable in three general locations. Because of the design and location of the building, the former Ford Motor company industrial plant on Gibraltar Road at I-75 is the single most prominent opportunity for manufacturing/heavy industrial development. Light industrial, research, and warehousing uses would be appropriate in the Gateway Commerce Center i ndust rial park and al so as a buffer along Ha 11 Road and Vreeland Road, to separate future residential development from Mazda and the Grand Trunk railroad yard. I l [ I ' . l- ,. l.· [ [ r-l. r· - 49 - �CIRCULATION ANALYSIS I- Overview The local network of streets and thoroughfares is of vital importance for the overall well-being of the City and its residents. The most basic function of local streets is to provide a circulation system by which people and goods can move within and through the City. Roads and road rights-of-way also provide locations for public utilities, such as water, sewer, gas, electric, and telephone lines. Roads provide the means by which emergency and public services are delivered to residents. Road rightsof-way provide locations for landscaping and parking along commercial strips. Most important, the road system establishes the basic form and character of the City. As described in the Existing Land Use component of this plan, the development of the City has been shaped by the location or, in some cases, the absence of transportation corridors. The impact of Telegraph Road on commercial development is particularly evident. While early commercial development was concentrated in a central business district near the riverfront, commercial development in more recent times has occurred in strips along the full length of Telegraph Road. At the same time, the absence of roads in the central and northwestern portions of the City has resulted in little or no development in these areas. In summary, because the local road network serves many functions, this network has a significant impact on the local economy, character, environmental quality, development, and the overall well-being of the City. It is important, therefore, to identify and understand deficiencies in the circulation system, and to prepare alternatives to address those deficiencies. Jurisdiction of Roads The roads within the City of Flat Rock are under the jurisdiction of three agencies: the Michigan Department of Transportation (MOOT), the Wayne County Office of Public Services, and the City of Flat Rock. State Trunkline System. The state trunkline system serves as the regional road network for the City and County. MOOT has jurisdiction over this system, which in Flat Rock consists of I-75 and US-24 (Telegraph Road). Although MOOT oversees planning and major improvements to the trunkline system, it contracts with the County for general maintenance services. A more complete description of this regional network follows: - I-75 is the primary north-south freeway through the region, providing a link to the Detroit and Toledo metropolitan areas as well as locations farther north and south. This highway has been described as the state's most important industrial corridor. In Flat Rock, an interchange with I-75 is located at Gibraltar Road. - 50 - �- US-24 (Telegraph Road) provides an alternate north-south route to the Detroit and Toledo metropolitan areas. Telegraph Road serves dual purposes as a carrier of through traffic as well as providing access to abutting commercial properties. - I-275 . intersects with Will-Carleton Road approximately four miles west of Flat Rock city limits. This freeway provides direct access to expanding markets and employment opportunities in the western suburbs of Detroit and in Washtenaw County. Overall, the state trunkl ine system provides excellent north-south transportation for City residents. The north-south orientation of regional circulation system has affected business, employment, shopping patterns, and the local economy in general. The circulation system facilitates interaction with businesses in the Detroit or Toledo metropolitan areas, rather than with businesses to the west. The east-west regional transportation network is less than adequate. The closest east-west freeway routes are I-94 to the north and M-50 in Monroe County. County and City Roads. A network of county and city roads provides for local circulation within the City of Flat Rock. Gibraltar Road, Huron River Drive, Will-Carleton Road, and Inkster Road are under the jurisdiction of the County. All other roads are under the jurisdiction of the City. In general, the local circulation system radiates out from the original central business district (CBD), which is located in the southwestern portion of the City. In the eastern and northern portions of the City, the road network takes the form of a grid pattern which is typical of the county road system. In these outer areas of the City, the road network is sparse, and there are large tracts of undeveloped land. Transportation to the west of the CBD is limited to a single crossing over the Huron River at Telegraph Road. I. I The Grand Trunk Rail road runs from northeast to southwest through the City, connecting with a large rail classification yard in the northeast part of the City. This railroad is a formidable barrier to the construction of new roads across the central portions of the City. Road Classifications The purpose served by each road or highway in the circulation system is best described through classification of the roads. Road classifications identify the type and volume of traffic that is- appropriate for each segment of the road network. The classifications establish expectations among residents, City officials, and transportation engineers concerning the operational characteristics of each road. For the purpose of future transportation planning in Flat Rock, a functional classification of roads has been developed. This system includes the following road classes (see Map 2): - 51 - �[ I I .. V~'I ,, ,. ,, ,; ,, ,: ",,,, ~---: :____. -T ;, r·~7 ::I I I i I 'I ::,; I !•··.I! ; : ,.; I I ;i II :: '·:: ' I LEGEND •~'.--...........,/ ~ ---FREEWAY I -- \?', ; I ' ~ ~--~~> ' ,' - - - PRINCIPAL ARTERIAL I :.;; , /I/. - - - - - - MINOR ARTERIAL .fl t ., I it.Lr\,_ ===LOCAL I FUNCTIONAL CLASSIFICATION OF ROADS ~ MAP 2 ■ ■ CITY OF FLAT ROCK ■ ■ MICHIGAN ■ ■ WAYNE COUNTY m ■ nortn I. .80__.0l_,eo . .......ol _3_r.~?.....l _ _::._.~:i scale ··--··-· c.,- ....... - M~K.eMa Associates, Incorporated Comniunity Pleming • Urban Desion Farmington Hills, M1chioan _-_--..... �. •' - Freeways. Freeways are designed to handle large volumes of traffic moving at high speeds over long distances or between urban areas. As noted, the principal freeway serving the City of Flat Rock is I-75, which, in the vicinity of the City, carries about 44,000 vehicles per day. Principal arterials. Principal arterial roads and highways serve the major centers of activity. With the exception of freeways, principal arterials provide for the highest traffic volumes and the longest trips. Principal arterials allow for major traffic movement within the City and region. The City of Flat Rock has four principal arterial roads: Telegraph Road (average daily traffic (ADT): 22,200 vehicles), Gibraltar Road, Will Carleton Road, and Vreeland Road. II. - Mi nor arterials. Mi nor arteri a1 roads interconnect with the pri nc i pa 1 arterial system and provide trips of moderate length and a lower level of traffic mobility. Minor arterial roads place more emphasis on land access than principal arterials. Minor arterials in Flat Rock include Huron River Drive, Hall Road, Olmstead Road, Arsenal Road, Inkster Road, and Garden Boulevard. - Local roads. Local roads primarily provide direct access to abutting land and to collector and arterial streets. Movement of through traffic is usually discouraged on local roads. Local roads in Flat Rock include minor roads in the central business district and local subdivision roads. Public Act 51 Classification System. Wayne County utilizes a road classification system to establish funding priorities in accordance with Michigan Public Act 51 of 1951 (see Map 3). Under the Act 51 classification system, principal and minor arterials are generally classified as State Trunklines, County Primary Roads or Major City Streets,- depending on agency jurisdiction over the road. The remaining roads are generally classified as Local City Streets, with the exception of streets in the CBD. Streets within the CBD qualify for Act 51 funding, and therefore, receive the classification of Major City Streets. Circulation System Deficiencies l. Ir__ The status of the local road system has important consequences in terms of the future land use plan. An inadequate road system can impact on whether the City achieves its development objectives. For example, the lack of good access to some areas of the City has prevented desired residential, commercial, and industrial development. In other areas, continued development without necessary road improvements will result in increasing congestion and traffic conflict on local streets. Described below are circulation system deficiencies within the City: Telegraph Road. Telegraph Road is an example of a road which is experiencing increasing congestion and traffic conflict. Strip commercial development has occurred along the road, generating local business traffic. At the same time, Telegraph Road is utilized as a regional thoroughfare for longer through trips - 53 - �I- I_ ,----- ...... ;: ,, --- ~~=-- LEGEND - - - STATE TRUNKLINE • • - • - • - COUNTY PRIMARY n,1111111111_ COUNTY LOCAL I~ - - - MAJOR CITY STREET l === LOCAL CITY STREET - - - ADJOINING CITY STREET f i I . I· ST A TE COUNTY & LOCAL ROAD CLASSIFICATION* *Based on Michigan Public Act 51 of 1851 ■ ■ MAP 3 ■ CITY OF FLAT ROCK ■ ■ MICHIGAN ■ WAYNE COUNTY ■ m no<lh scale 800 1600 3200 feet one mile M!tKeMa Associates. tncorporated Convnurvty Plal'Y"ling • Urban Des,gn Farmington Hills, Michigan �I • L by vehicular and truck traffic. As a result, conflicts have arisen between local business traffic which generates many turning movements, high-speed through traffic, and relatively slower and cumbersome truck traffic. These conflicts will intensify as the commercial district along Telegraph Road continues to expand. Circulation in the CBD. A key transportation deficiency in the Central Business District is the lack of a direct link between Gibraltar Road and Telegraph Road. Following Gibraltar Road all the way through the CBD to Telegraph Road might seem a logical route. However, there are no directional signs along the route, nor is there a traffic signal at the Gibraltar/Telegraph intersection to facilitate turning movements onto Telegraph. I. Need for Access Roads. There are several large tracts of vacant land in Flat Rock which are suitable for new development, particularly for high-quality single family homes, but which are inaccessible from the existing road network. These areas include a large tract of land located between Cahill Road and the CBD, an area south of the Cahill/Gibraltar intersection, and land areas both east and west of Arsenal Road. Need for Collector Roads. As new residential development occurs in the City, a residential street system wi 11 develop to pro vi de access for these areas. Subsequently, there will be a need for new "collector roads" to channel traffic from the local residential streets to arterial roads. Collector roads are generally wider than other residential roads. Efforts are made, where possible, to discourage direct residential access onto collector roads, since the added curb cuts increase traffic conflicts and congestion. Homes which do front on collector roads should be set back an ample distance from the roadway. I. I l. Grand Trunk Railroad. A constraint to the development of new roads in Flat Rock is the presence of the Grand Trunk Railroad classification yard. The rail road is a physical barrier that makes it very difficult to provide east-west road connections between the central and western portion of the City. - Improvements to the railroad crossings at Vreeland Road will be very important in order to facilitate better traffic flow along the only east-west road in the northern portions of the City. Pavement of Roads. Not only is there a need to provide access roads to underdeveloped areas of the City, but there is a need to pave certain existing roads. Unpaved roads in the City include Woodruff Road, Cahill Road, Meadows Avenue, Seneca Avenue, Peters and several roads in residential subdivisions. l[ Delivery of Community Services. Currently deficiencies in the City's existing overall road system frustrate the delivery of community services. For -example, the presence of unpaved roads and lack of collector streets has made it difficult for local officials to identify safe and appropriate school bus routes and student transfer stations. In the future, as City road network is improved, special effort must be made to accommodate school buses, fire trucks, trash collection truck, ambulances and other service vehicles. [:. - 55 - �Opportunities for Improvement Following are possible solutions to road system deficiencies in the City of Flat Rock (refer to Map 4): Access Roads for Residential Development. The opportunity exists to provide road access to vacant areas east and west of Arsenal Road by extending Vreeland Road west to Inkster Road. Other undeveloped areas of the City may be accessed by extending Seneca east to Cahill, extending Cahill south to Woodruff, and connecting Meadows Avenue east and west from 01 mstead to Tamarack. These road extensions could become future collector roads as residential development in the vicinity expands. The exact location of these road extensions could vary depending on topography, location of drains and wetlands, the need to align new roads with existing roads, proposals for new development, and similar conditions. r· I !~ - Downtown Circulation. Traffic circulation in the CBD may be improved by designating Gibraltar Road as the primary route for through traffic, connecting traffic from the east to Telegraph Road. Traffic- flow along Gibraltar could be facilitated by installing a traffic signal at the Telegraph/Gibraltar intersection, and by making adjustments at the Gibraltar/Garden Boulevard intersection which would allow non-stop traffic movement along Gibraltar. Telegraph Road Commercial Area. To reduce congestion and traffic conflict, the site plan review process should be used to control the number of curb cuts onto Telegraph Road. Developers should be encouraged to construct secondary access drives to serve a11 of the properties, thereby reducing turning movements on Telegraph Road. For example, traffic safety on Telegraph Road could be improved by constructing a secondary service drive behind the existing -business along the east side of Telegraph Road, thereby providing an alternate access off of Vreeland Road for patrons of Kmart and adjoining businesses. iI • Truck Routes. Conflicts between truck and vehicular traffic could be reduced by encouraging trucks to use Hall Road as the primary north-south truck route, and Vreeland Road as the primary east-west truck route. For non-industrial traffic, Cahill should become the primary north-south roµte, and Gibraltar Road should become the primary east-west route. L - Pavement of Roads. As the City grows, developers should be required to pave all proposed roads. In addition, there are existing roads which may never be paved without public funds, which the City could pave to provide a catalyst for development. The following roads should receive priority for paving with public funds: Cahill Road, Seneca Road, Woodruff Drive, and Meadows Avenue east of Tamarack. - [_· f - I Improved Access to School. After Woodruff Drive is paved and Meadows Avenue is connected east to Olmstead, improved access to the Flat Rock elementary and middle schools should be developed. Tamarack Street should be phased out as the primary access to the schools, and a direct route which does not cut through a residential neighborhood should be developed. I ·"' - 56 - �I. ,1 I LEGEND .' I :- -'_5~: FREEWAY , .j ,.,. . ',._ _j:_ :·_: /- - - - • PRINCIPAL ARTERIAL ~ L=.- - • • - • - • • PROPOSED PRINCIPAL ARTERIAL 0 - - - MINOR ARTERIAL 1111,n111111111111111n1111 === -$-- FUTURE COLLECTOR STREET '\ 1-\,,t/, "'-------.. TRAFFIC SIGNAL • - - - - - SERVICE DRIVE ~ POSSIBLE TRAFFIC W LOCAL STREET □ - - - PROPOSED TRUCK ROUTES -""' ~c....- -·\_ INTERSECTION IMPROVEMENTS SIGNAL (Long-term) ~ STREET CLOSING RAILROAD CROSSING IMPROVEMENTS 11iiilliiiiilihiiiihiiiiiii0 PRIORITY ROAD PAVING (Future Collector Street) COMPREHENSIVE CIRCULATION PLAN MAP 4 ■ ■ I I l: CITY OF FLAT ROCK ■ ■ ■ WAYNE COUNTY MICHIGAN ■ ■ m north scale 800 1800 320 0 feet one mile MS:Kenna Associates, lncor0orated Community Planning • Urba n De sign Farmington Hills. M1chtgan �Improved transportation patterns are also required at Currently, school bus loading and unloading blocks access and hinders the flow traffic on other streets. Ideally, an area for buses should be developed, possibly making it school to acquire more property. the high to certain off-street necessary school. streets staging for the Improved Access to Cook Road Industrial Area. Industries located along Cook Road do not have direct access to Telegraph Road. Consequently, trucks serving this industrial district must travel through residential areas. An alternate means of access to this area is required. Two alternatives are possible: I) Construction of a new road to Telegraph Road, or 2) Construction of an access road along the railroad tracks to Vreeland Road. I I Pedestrian Movement As the City continues to deve 1op, the need to accommodate pedestrians wi 11 increase in importance. A pedestrian orientation was established in the older portions of the City through construction of sidewalks along most streets. This pattern should be continued in newly developed areas, using a two-fold approach, as follows: First, developers should be required to install sidewalks along all road rightsof-way in conjunction with all new construction. Second, the City should become directly involved in the installation of sidewalks if the following circumstances exist. - Pedestrian/vehicle conflicts are prevalent. It would be beneficial to provide access to key centers of community activity, such as to parks or libraries. It is necessary to complete the missing links in an area where much of the pathway system has been installed. 1· Priorities for installation of new sidewalks in Flat Rock should include the following: missing links along Telegraph Road, missing links in the downtown {particularly in the vicinity of the new senior housing complex), a new sidewalk along Woodruff Drive from Olmstead to Huron River Drive, and sidewalks along both sides of Gibraltar Road between the CBD and Gateway Commerce Park. [. [_ - 58 - �[ COMMUNITY AND RECREATION FACILITIES The responsibility for providing public services to the residents of Flat Rock is shared by several public entities, including the City itself, various Wayne County departments, various state agencies, the Fl at Rock Community School District and other organizations. These services play an important role in determining the quality of life within the City. During the coming years, as vacant land areas within the City are developed and the number of residents in the City increases, the demand for public services will also increase. This chapter of the Master Plan examines the public facilities and services within the City and looks at ways to expand these resources to meet the needs of a growing City. City Administration and Services Following is a description of existing municipal facilities (see Table 15 and Map 5): City Hall r· ! I City Hall represents a major focal point within the City of Flat Rock, occupying a five acre site located on Gibraltar Road near Evergreen Street. The facility contains a number of civic and governmental activities including the general City offices, council chambers, and police, fire, and public works departments. Built in 1975, the building itself is an impressive two-story structure, containing a total of 45,500 square feet of floor space. It is anticipated that the existing structure will provide adequate capacity for City administrative needs for the foreseeable future. The only drawback of the building is that it is not energy efficient; measures to mitigate this deficiency are required. The site on which City Hall is located is highly visible, centrally situated within the community, and surrounded on two sides by Flat Rock Community Park. These characteristics, coupled with adequate space on the site for additional construction, presents the opportunity to develop the site as the civic center for the community. As additional library space, meeting rooms, and other facilities become necessary within the City (such needs are described below), these facilities should be constructed adjacent to City Hall. This will allow for the integration of local civic activities, and enhance City Hall as a focal point of the City. Senior Center/ Public Works Garage The City owns and maintains a Senior Citizen Center, which is housed in the old Public Works Building on West Huron River Drive north of Arsenal Road. Built in 1926, the building is approximately 1,200 square feet in size and is in fair condition. The building contains meeting room space and kitchen facilities which are utilized for senior activities. The City continues to improve the facility each year, rehabilitating the structure itself and remodeling its interior. Window restoration and energy efficiency measures are currently needed. - 59 - �I I I '. ~ - · .- Municipal Facilities 1. CITY HALL 2. SENIOR CENTER/PUBLIC WORKS BUILDING 3. YOUTH CENTER 4. LIBRARY 5. ABANDONED WATER TREATMENT PLANT 6. ABANDONED SEWAGE TREATMENT PLANT (OWned by County) 0 Municipal Recreation 7. HU ROC PARK 8. FLAT ROCK COMMUNITY PARK 9. PEBBLE BROOK PARK 10. POTENTIAL RECREATION 0 ·1 Public School Facilities 11. FLAT ROCK HIGH 12. BOBCEAN ELEMENTARY 13. UNDEVELOPED PROPERTY 14. SIMPSON JUNIOR HIGH 15. BARNES ELEMENTARY 16. SCHOOL-OWNED PLAYGROUND □ ■ 'I LJ./\ '\.._..,,,..,._ Regional Recreation 17. OAKWOODS METROPARK 18. POTENTIAL RECREATION COMMUNITY & RECREATION FACILITIES ■ ..r .,f' ~ l ·/;". W ~;,. MAP 5 ■ CITY OF FLAT ROCK ■ ■ MICHIGAN ■ WAYNE COUNTY ■ north scale I L ~ J.-_____3r_:_....~l ___:1.r. . .l W ~--s-:....t_-so.... ~enna Aasoclatea. Incorporated Conm.nty Pia,...,,,_ • Urban Design Farmington Hills, Michigan �TABLE 15 MUNICIPAL FACILITIES City Hall Complex, 25500 Gibraltar Road, 5 Acres City Administration, Police, Fire and Public Works Department; 45,500 sq. ft.; built in 1975; good condition, although modifications are required to make it more energy-efficient. I Library, 26336 East Huron Drive, 0.2 Acres I . City-leased facility for ·library services, 5,600 sq. ft., built in 1978, maintained in good condition. I. Senior Citizen Center/ Public Works Building, 26643 West Huron Drive, 0.3 Acres Senior Citizen Center, 1,200 sq. ft., built in 1926, fair condition (requires window restoration, energy efficiency measures, and remodeling). Public Works Building, 3,200 sq. ft., built in 1954, good condition. Sewage Treatment Plant, East Huron River Drive, 1.21 Acres Sewage Treatment Plant, closed -- to be demolished. I Youth Center, located at Hu Roe Park i I I. I i il I. Youth Center Building, 1,500 sq. ft., built in 1957; average condition (requires new roof, boiler, general modernization). The new senior housing complex, located on Telegraph Road in the central business district, contains a meeting room for senior activities. While this facility will bolster programs available to senior citizens within the City, it will not replace existing programs. The City should continue to improve and maintain the existing Senior Citizen Center on East Huron River Drive as a site for ongoing senior programs. The Senior Citizen Center shares the same site with the City Public Works Garage, which houses mechanic facilities for repair of city vehicles. This building is 3,200 square feet in size and is in good condition. r ! L - 61 - �Youth Center The City owns and maintains a Youth Center located on Atwater Street in Hu Roe Park. The Youth Center contains a meeting room, kitchen facilities, and storage space. It is utilized by local youth groups, such as the boy scouts and girl scouts, and by community groups which are youth-oriented. Built in 1957, the Youth Center is in average condition. Currently, the building needs a new roof and boiler and general modernization. The kitchen cannot be used for cooking, because as it does not meet County Health Department standards. Eventually, when new community meeting facilities are constructed behind City Ha 11, the Youth Center wi 11 cease to be a primary meeting space for the community. The City may continue to maintain the Youth Center as secondary meeting facilities, or remove the Youth Center to enhance the natural setting of Hu Roe Park. Library The local Library is centrally located at 26336 East Huron Drive in downtown Flat · Rock. The building itself, which is leased by the City, contains 5,600 square feet of floor space, and is maintained in good condition. The City of Flat Rock is a member of the Wayne/Oakland Federation, a cooperative in southeast Michigan consisting of approximately 60 libraries. The library located in Flat Rock is financed by Flat Rock, Gibraltar, Rockwood, Brownstown Township, and Huron Township. The hiring of personnel is handled by Wayne County. According to library officials, the existing library is adequate for the current needs of the community. In the long-term, the City hopes that a new 1ibrary facility will be built behind the City Hall, as part of the City's civic center. 11 I- f- I Police The City Police Department operates out of the City Hall. The department has a 19-person force, including the chief, 12 uniformed road officers, 2 detectives, a narcotics officer, and 3 shift commanders. While the department has ample space in City Hall for its operations, there is a need for additional office support in terms of equipment and personnel. The department has a fleet of 4 marked and 2 unmarked police vehicles, which is adequate to service the City. The City has 911 dialing service for emergencies, but does not have the capacity to automatically identify the number and location of emergency calls. The Michigan State Police maintains a post within the City of Flat Rock, located at the intersection of Will Carleton Drive and Telegraph Road. This is a central location for state patrol of the 1-275 and 1-75 Freeways. There has been some consideration given to moving this post to a new location north of Flat Rock; however, at this time, State funds have not been appropriated for such a move. l . .• Fire Department The City has a voluntary Fire Department which operates out of City Hall. Fire trucks are stationed at City Hall and at the Public Works Garage on West Huron River Drive. The City Fire Department provides fire protection and ambulance service for all City residents (seven minute maximum response time). When - 62 - �requested, the Department has a mutual agreement to provide services to surrounding communities. The department's equipment is in generally good condition; the City has recently purchased two new fire trucks. The department is, however, in need of an aerial bucket. Currently, there are 37 volunteers on the Flat Rock Fire Squad. Public Utilities Public Water Service The City of Flat Rock owns and maintains the local public water distribution system which services all developed areas within the City. Water is supplied from the City of Detroit. Major water mains into the City lie along G"braltar, Vreeland, and Woodruff Roads. The system is in generally good condition. There is a need to replace some undersized lines within the older central portion of the City, and to replace lines within the system which are subject to breakage (ie. along Huron River Drive, Arsenal Road, Moses Road). Additional improvements are needed to allow system looping in some areas of the City, which would improve water pressure. · l '-· According to City officials, the water system has adequate capacity to meet the needs of future development on the City's remaining vacant land. The system is also adequate for the purposes of fire protection throughout the City. Sanitary Sewer Service Flat Rock also owns and maintains the sanitary sewers in the City. Sewage is treated at the South Huron Valley Wastewater Control System located in the Township of Brownstown. · The treatment facility is operated by Wayne County, but is owned by seven communities, each of which is allocated a portion of the total treatment capacity of the plant. The City of Flat Rock itself owns the capacity to treat 2.77 million gallons per day. l- Currently, the City sends approximately 2 million gallons of sewage to the treatment plant each day. The remaining available treatment capacity owned by the City could serve approximately 600 additional homes. The City, therefore, does not own the capacity to provide sanitary sewer service a population of 9,486 persons, which is the projected population for Flat Rock in the Year 2005. If the City Master Plan is to be implemented, the City must seek additional sewage treatment capacity. At this time, there are no plans to expand the treatment plant in Brownstown, and there appears to be little possibility that Flat Rock will be able to purchase existing capacity from another municipality. The City's old sewage treatment plant (which is owned by Wayne County) is located on East Huron River Drive in the vicinity of Van Riper Street. This plant was closed in 1988 because of obsolescence. The abandoned plant will be demolished. Storm Sewers The City of Flat Rock contains enclosed storm drains scattered throughout the City. All combined storm/sanitary sewers, which once existed in the older central portions of the City, were separated during the l960's and 1970's. All - 63 - �•. r-. ' I ' - r-· enclosed storm water and surface water ronoff from City land areas discharges into the Huron River, either directly or via open drains. Improved drainage is required on some of the vacant lands that have been identified as suitable for residential development. It is recommended that the City undertake a system-wide stormwater study, possibly in cooperation with surrounding communities, to determine solutions to the stormwater drainage problems. School Facilities [._ r- il The Flat Rock Community School District operates four schools within the City of Flat Rock. Flat Rock High School is located on a 5.4 acre site north of the Gibraltar Road/Garden Boulevard intersection. Simpson Junior High (33.4 acre~) and Barnes Elementary (9.7 acres) are located north and south of Carter Street respectively, east of Tamarack Road. Bobcean Elementary is located north of Seneca, west of Evergreen. The School District also owns a 55.8 acre site north of the City Hall which is now vacant, and a 0.8 acre site near Dover Street (in the southeast portion of the City) which is used as a neighborhood park. The District's administration building is located on the same site as the High School. According to school officials, K-12 enrollment in Flat Rock has fluctuated during recent years. At this time, local school facilities are operating a full capacity. If enrollment grows appreciably over the next few years, the construction of additions to the two existing elementary school buildings will be needed. Currently, there is ample land at both elementary schools for such additions. School officials hope to eventually construct a new high school and library/resource center on the school-owned property behind City Hall. From the standpoint of city-wide planning, this is an excellent proposal; for it would reinforce the City Hall and surrounding properties as the center for civic activities in Flat Rock. Adequate space could be provided at the new high school for vehicular parking and the transfer of students between buses, which would alleviate some of the traffic problems now occurring at the existing high school site. The existing high school building could be converted into a vocational/special education center. Parks and Recreation Inventory of Existing Facilities As listed in Table 16, the City owns and maintains three parks, comprising a total of 38.3 acres of parkland. r I I The largest City park is Hu Roe Park (27.4 acres) which is located along the Huron River south of the Grand Truck Railroad. A large portion of the park is, in fact, located on an island, and access is provided via a footbridge. Hu Roe L. - 64 ,-- �TABLE 16 PARKS AND RECREATION FACILITIES PROPERTY INVENTORY Site Size (Acres) Hu Roe Park 27.4 Footbridge, picnic areas, benches, fishing. Flat Rock Community Park 10.7 Two (2) lighted softball fields, two (2) tennis courts, playground equipment, picnic areas with grills, pavilion, restrooms, storage shed, water fountain, caboose. Pebble Brook Park I. 0.2 Tot lot, benches. 5.4 One (1) baseball diamond, football field, soccer field, gymnasium, weight room. Public Schools Flat Rock High School 33.4 Two (2) baseball/softball diamonds, running track, soccer field, six (6) tennis courts, sledding hills, indoor pool, gymnasium. Barnes Elementary 9.7 One (1) softball diamond, soccer field, play equipment, gymnasium. Bobcean Elementary 9.1 Two (2) baseball/softball diamonds, play equipment, gymnasium. Playground near Dover Street 9.8 Ball diamond. Simpson Junior High School I . Facilities City Parks I Huron-Clinton Metro Authority r; 1· Oakwoods Metropark 35.5 Natural area (portion of larger park). Property north of Will Carleton Drive 31.0 Undeveloped, leased by the City. -. [ · - 65 - �r - ' Park contains picnic areas and benches along the river. The park is used extensively for fishing and other forms of passive recreation. The park is also the site of the City's annual July 4th celebration and other community events. Located adjacent to City Hall on a 10.7 acre site is Flat Rock Community Park. This park contains two lighted softball diamonds, tennis courts, playground equipment, picnic areas, a pavilion, and restrooms. It is used extensively by City residents for active recreation. Pebble Brook Park is a 0.2 acre site located at the end of Todd Street in the southeast portion of the City. Pebble Brook Park contains a tot lot and benches. The Flat Rock Community School District is also a major provider of recreation services within the City. The District owns 57.6 acres of land at four school sites. Recreation facilities located on these sites include 5 ball diamonds, 6 tennis courts, 4 gymnasiums, a soccer field, running track, play equipment, and an indoor pool. Although these facilities are designed to meet the needs of school children, the facilities are made available to all residents when not being used for school purposes. The School District and the City of Flat Rock together employ a full-time director for local adult education and recreation programs. The director coordinates a full range of recreation programs for all age groups including organized baseball, softball, track, basketball, soccer and "safety-town" (for children). The director also coordinates adult education programs and many of the Senior Citizen activities. Over 1,000 people participated in these programs during the 1988/89 year; the age of participants ranged from 2 to 85 years. The southern 35 acres of the Oakwoods Metropark 1i es within Fl at Rock City limits, located west of the Huron River and north of the Grand Trunk Railroad. This park is owned and operated by the Huron-Clinton Metropolitan Authority (HCMA). Recreation facilities available at the park (although not located within City limits) include picnicking, fishing, hiking, canoeing, and cross-country skiing. The portion of Oakwoods Metropark which lies within the City is a designated nature study area. II. I I_ The HCMA owns an additional 31 acre site within the City of Flat Rock which is undeveloped. The site is located immediately west of the Huron River, south of the Grand Trunk Railroad, with access to Will Carleton Road. The City currently leases this property from HCMA and is considering developing the property as a campground. A footbridge over the Huron River to the City's Hu Roe Park could be provided. There are three other metroparks located within 10 miles of the City of Flat Rock, which are managed by the HCMA. These parks offer swimming, boating, golfing, camping, and ice skating facilities. Throughout the entire southeast Michigan metropolitan area, there are a total of 13 metroparks operated by HCMA. Each metropark offers a variety of recreation opportunities, and all are located within a one-hour drive from Flat Rock. The Mi chi gan Department of Natura 1 Resources (MDNR) operates Sterling State Park, approximately 20 miles south of Flat Rock, on the shore of Lake Erie near the - 66 - �1-75/Dixie Highway interchange. This 1,000-acre park is one of the most frequently visited state parks in Michigan. Park Classification For planning and management purposes, parks can be classified based on the type of facility and expected use. The parks in Flat Rock may be classified as follows: - Mini-Parks. Mini-parks are small, specialized parks, usually less than an acre in size, that serve the needs of residents in the surrounding neighborhood. A mini-park may contain a children's playlot, serve as a greenbelt, or provide a sitting area for senior citizens. The retommended service area for mini-parks is a 1/4 mile radius. In Flat Rock, Pebble Brook Park meets the criteria for classification as a mini-park. - Neighborhood Parks. Neighborhood parks are typically multi-purpose facilities which serve as the focus of recreation activity for an entire neighborhood. Neighborhood parks are generally 3 to 10 acres in size and should be easily accessible to the neighborhood population, with safe walking and bike access. The recommended service area is a 1/2 mile radius. These parks typically contain areas for active recreation, such as ballfields, playlots, and tennis courts, as well as areas for quiet recreation activity, such as walking, sitting, or picnicking. The two elementary schools and the high school function as neighborhood parks in the City of Flat Rock. I. [ - Community Parks. Community parks typically contain a wide variety of recreation facilities to meet the diverse needs of residents from several neighborhoods. Community parks are generally 10 acres or more in size with a 2 mile service radius. These parks typically contain areas for active and quiet recreation, pl us other facilities not commonly found in neighborhood parks, such as nature trails, fishing areas, a band shell or pavilion. Such parks generally have access to major streets and are centrally located within the community. Community parks in Flat Rock include Hu Roe Park, Flat Rock Community Park, and the Simpson Junior High School recreation facilities. - Regional Parks. Regional parks are typically located on . sites with unique natural qualities which are particularly suitable for outdoor recreation, such as picnicking, boating, fishing, swimming, camping, and trail uses. Such parks generally exceed 200 acres in size. Regional parks typically serve several communities, although most users are within 1/2 hour driving time. The four HCMA parks, including Oakwood Metropark which is located partially within Flat Rock City limits, are regional parks which provide regional recreational opportunities for Flat Rock residents. Evaluation of Existing Recreation Space and Facility Needs One determination of recreation space adequacy is comparison to nationally accepted standards of acreage per 1,000 persons. Once these genera 1 space requirements are identified, it is necessary to determine if there are any specific recreational deficiencies based on existing development, proposed development and the desires and needs of the service area residents. - 67 - �In terms of overall recreational standards for land, City-owned parks alone fall short of national standards. The National Parks and Recreation Association recommends 6.5 acres per 1,000 people. Based on this standard, the City should have 42.8 acres of parkland for its present population and 59.3 acres of parkland by the year 2005. Currently, the City owns and maintains only 38.3 acres of parkland. However by combining all City, School, and HCMA owned park properties located within Flat Rock, there is a total of 141.2 acres of developed parkland available to local residents. This figure exceeds parkland needs for both the City's current and projected (year 2005) population. Table 17 compares the acreage of park types within the City to national standards. These figures indicate that the City has adequate neighborhood and community park acreage for both its current and projected population, but is deficient in mini-parks and regional parks. The deficiency in mini-parks is partially mitigated by the excess of parkland in other categories. The deficiency in regional parkland is mitigated by the HCMA park system, which provides adequate regional park facilities within a 1/2 hour drive from Flat Rock. TABLE 17 COMPARISON TO RECOMMENDED PARKLAND STANDARDS* I. MiniParks Neighborhood Parks Convnunity Parks Regional Parks Recommended Minimum Acres per 1000 Population 0.25 2.0 5.0 10.0 Estimated Existing Acreage** 0.2 34.0 71.5 35.5 Acres Needed for Existing Population (6,853) 1. 7 13.7 34.3 68.3 Acres Needed for Projected Population in 2005 (9,486) 1. 9 18.0 47.4 94.9 I. I. I. *Based on National Parks and Recreation Standards. **Includes City, School, and HCMA properties. - 68 - �• Based on national standards, the City of Flat Rock appears to have adequate park acreage for its current and projected population. However, the existing parks and school sites are located predominately in the central portions of the City. Because Hu Roe Park and Flat Rock Community Park are classified as community parks, which have a 2 mile radius service area, these parks are adequately located to service the entire City. · I. l Neighborhood-type recreation facilities, however, have a service radius of only 1/2 mile and, therefore, should be more evenly distributed throughout the City. As the City develops, there will be a need to identify sites for neighborhood parks in the outlying portions of the City. For example, facilities at the school-owned playground near Dover Street could be expanded to provide for neighborhood recreation for residents in the southeast portion of the City. Evaluation of park acreage alone does not assess the type of facilities located at each park. Table 18 details standards for recreation facilities and compares actual facilities available to projected need in the year 2005. The table indicates that additional court facilities (hardball, basketball, and volleyball}, a soccer field, golf course, indoor ice rink, trail, archery range, and campsites will be needed by the year 2005. Some of these facilities are available at nearby regional parks, including trails, golf course, and campsites. Summary and Recommendations. Based on the preceding evaluation, the immediate emphasis for parks and recreation improvements in Flat Rock should be on the development of facilities and general site enhancement at existing parks, rather than the acquisition of new park properties. However, in the l anger term, as new residential subdivisions are developed in the outlying portion of Flat Rock, the City should assure that adequate property is set aside for neighborhood parks to service their subdivisions. 1. Hu Roe Park and Flat Rock Community Park should continue to be developed as community-wide parks and as important focal points within the City. Emphasis should be placed on enhancing the natural amenities at Hu Roe Park for passive recreation. This park should be incorporated as part of the downtown area. Flat Rock Community Park should continue to be developed for active recreation. 2. As outlying portions of the City are developed, mini-parks and neighborhood parks should be · incorporated into new residential subdivisions. Specifically, parks will be needed in the following areas: 1} the northwest portion of City in the vicinity of Arsenal Road, 2} in the central part of the City, south of Vree 1and and west of Cah i 11 Road, and 3} south of Gibraltar Road and west of Cahill Road. 3. i- The City should continue to explore the possibility of leasing the HCMA owned property (located east of the Huron River and north of Will Carleton Road} for campground facilities. - 69 - �. r-· TABLE 18 . RECOMMENDED RECREATION FACILITY STANDARDS r I - r I. I- Facility Reconunended Facilities per 1,000 Population Existing Facilities Facilities Needed For Projected Population of (9,484) Projected Deficiency Softball Fields 1/5,000 3 2 Adequate Baseball Fields 1/5,000 5 2 Adequate Picnic Areas None 2 Continued Improvement Required 1 Continued Improvement Required Published Picnic Shelters None Published Playgrounds 1/3,000 5 3 Adequate Tennis Courts 1/2,000 8 5 Adequate Basketball Courts - Outdoor 1/5,000 0 2 2 Courts Soccer Fields 1/10,000 2 2 Adequate Golf Course 1/ 25,000 0 1 Adequate Community Center 1/25,000 1 1 Adequate Senior Center 1/30,000 1 1 Adequate Handball 1/20,000 0 1 or 2 1 Court Swimming Pool - Indoor 1/20,000 1 1 Adequate l. Indoor Ice Rinks 1/50,000 0 1 1 Rink ll:_ Campsites 1/150 0 63 63 Sites Volleyball 1/5,000 0 2 2 Courts l. ' [ Trails I/Community 0 1 1 Trail Archery Range 1/50,000 0 1 1 Archery Range Source: Based on standards published by the National Parks and Recreation and the Michigan Department of Natural Resources - 70 - �I 1- • 4. The City should continue to maintain and enhance all existing parks and recreation facilities. The design of local parks is very important, and should take into account annual maintenance requirements and aesthetic enhancement. Good landscaping of local park facilities wi 11 add to the overall character and image of the City. 5. The City should prepare a master recreation plan to provide overall direction and phasing for the development of recreation facilities within the community. It is recommended that the pl an be prepared to meet the guidelines set forth by the Michigan Department of Natural Resources (MDNR), so that the City may qualify for MDNR grant programs. 6. The City and the Flat Rock Community School District should continue to work together to enhance and support their existing recreation and adult education programs. These programs currently provide excellent recreational opportunities for the residents of Flat Rock. I' I.. - 71 - �r•-... I • L_ [ r·_ [_- FUTURE LAND USE Introduction Early development in Flat Rock was oriented in relation to three primary transportation axis: Telegraph Road, Gibraltar Road, and Huron River Drive. Telegraph Road near the Huron River became the "main street" of the central business district. Eventually, the central business district expanded to encompass about 12 to 15 blocks, generally east of Telegraph Road. The Telegraph Road frontage consisted of primarily retail uses, whereas the rest of the CBD contained a mixture of service, institutional, and residential uses. Patterns of early residential growth were prescribed by the other two primary axes, Gibraltar Road and Huron River Drive. The largest single family neighborhood in the City developed in a large triangular area bounded by Gibraltar Road on the north and Huron River Ori ve on the south. A second concentration of early residential growth occurred northwest of the CBD along Huron River Drive. The fourth major transportation axis -- the railroad -- also affected the early development and general form of the City. The general pattern of commercial and residential development was split diagonally by the railroad line, demarcating the north boundary of the CBD. This basic pattern of development was in place in 1970 when the previous master plan was completed. In more recent times, the development of the City has been affected most signifi.cantly by access to I-75. The Gibraltar Road interchange created opportunities for regional-oriented development on the east side of the City. Concurrently, Telegraph Road's role as a regional transportation corridor declined. As a result, much of the recent commercial development along Telegraph Road has been oriented toward a local market, rather than toward travellers. Other changes in the commercial sector have occurred in the . two decades since the last master plan was prepared. The level of economic activity in the CBD has continued to decline. The commercial district along Telegraph Road north of the railroad tracks is now the primary retail district in the City. It is important to examine Flat Rock's current development pattern in the context of time. For most of its history, Flat Rock's development has been concentrated in a very small part of the City. The City had been in existence for several decades in 1970, but still only one-third of City's land area had been developed upon. The interchange at Gibraltar Road opened a new frontier. If looked at in the context of the City's entire history, the "exploration" and development of this frontier is in the very early stages. Gradual, steady growth in the eastern part of the . City would not be out of character with the pace of development experienced over the past several decades throughout the City. [. : f. I I i.. - 72 - �Although the City recorded a few major developments in the 1970's and 1980's, almost half of the land in Flat Rock remains vacant. Thus, the opportunity still exists to shape the City to the form desired by residents and community leaders. Planning Goals. Early in the planning process, the Planning Commission and City Council reviewed and approved a series of goals to help sort out some of the difficult decisions that are addressed by the Master Plan. Primary goals agreed upon by the City leaders include the following: Neighborhoods: Foster strong, vital neighborhoods to ensure that Flat Rock continues to be recognized as a stable community where families and individuals reside, work, and shop. - Master Physical Planning: Maintain complementary land use relationships which promote a harmonious, attractive community; preserve natural resources; promote a sound tax base; and provide for manageable traffic volumes. - Property Maintenance: Recognize that the City and its physical resources are dynamic, and aggressively encourage property maintenance and reinvestment. - Fiscal Stability: Promote the development of a financially secure community which can continue to provide all necessary services to its residents and businesses in an efficient manner. - Land Use: Promote efficient use of the land and encourage assembly and orderly redevelopment if appropriate land use pl ans are presented for underdeveloped areas, areas isolated among more intensive uses, or areas which are declining or negatively impacted by nonresidential traffic or incompatible land uses. I l l. - Planning Innovation and Fl exi bi l i ty: Encourage innovation in land use planning (e.g., Planned Unit Development) where innovation would achieve a higher quality of development than would be possible under conventional regulations. In addition to these general goals, the Planning Commission and City Council reviewed and approved more detailed goals concerning land use, housing, the environment, economic development, transportation, community facilities, and recreation. These goals have been thoroughly examined during the planning process in light of data, analysis, and recommendations produced during the course of preparing the Master Plan. Future Land Use Map The Future Land Use Map (Map 6) sets forth recommendations for continued use, new development, and reuse of land in the City over the next two decades. The Future Land Use Map is a link between what exists and what City leaders and citizens would like to have . - 73 - i. �Together, the Master Plan and Future Land Use Map provide a flexible guide to promote informed public and private decision-making for the betterment of the community. The land use designations on the map are generalized; they are not intended to be site specific or to follow specific property lines. Although the Master Plan and Future Land Use Map form the basis for the Zoning Ordinance and other rigid legal controls, the Plan and Map are intended to be flexible policy documents and decision-making guides. General Form of the City. The Future Land Use Map builds upon past growth and prevailing development patterns. According to the map, intensive development is generally limited to two areas: along the Telegraph Road corridor and on the east side of the City, in proximity to I-75. Commercial and service uses are concentrated along Telegraph Road. New commercial development is expected, particularly north of the railroad tracks. Specialized retail, office, and residential development is expected to occur south of the railroad tracks in the downtown. Two types of intensive development are slated for the east side of the City. Industrial development is indicated on the Future Land Use Map north of Gibraltar Road. A mixed use pattern is indicated on the map for the land on the south side of Gibraltar Road near I-75. I I I L Residential development is specified for most of the remaining land in the City. Single family residential development is the most predominant residential land use classification. Multiple family development is called for in several locations, to serve as a transition zone between the single family areas and more intensive land uses. Interspersed within the residential areas are various public uses, such as parks and schools. Recommendations for each of the land uses identified on the Future Land Use Map are reviewed in the next several pages. Single Family Residential The Population Analysis revealed that the rate of population growth levelled off in the 1980's after five decades of continued growth. However, the analysis also found several events that are expected to generate additional population growth in future years. These events include economic expansion and increase capacity of the sanitary sewer system. SEMCOG projections indicate that the population of the Clty will increase by 38.4 percent by the year 2005, resulting in a total population of 9,486. At the same time the average household size is expected to decrease to 2.31 persons. To accommodate the projected population increase an additional 1,792 housing units would have to be constructed by the year 2005. To accommodate this level of growth, about 386 acres of land must be turned over for residential development during the next two decades. - 74 - �The ba 1ance of housing types is an important concern with regard to future residential development. Almost one-third of all existing housing units are rental units. About half of the units constructed between 1970 and 1980 were multiple-family units. The housing balance must be shifted in the future, toward a greater proportion of single family units. This shift is needed to address a latent need for higher quality single family housing and to reinforce the City's neighborhoods. The following standards should be used to guide future residential development: - Ideally, new residential development should occur in planned settings, such as subdivisions or condominium developments, rather than at random along thoroughfares. - Residential development should be coordinated with the availability of sewers, public water supply, and public roads. - The creation of "neighborhoods" should be a primary residential development objective. There is a need to coordinate housing construction with the development of schools, parks, community services, and neighborhood shopping. The Future Land Use Map identifies five areas where new single family development is appropriate: - South of Gibraltar Road. New development must be coordinated with land use patterns in existing neighborhoods. The opportunity exists to create some of the most attractive homesites in the City through subdivision design that is sensitive to the natural features, particularly the woodlands, which exist in this part of the City. Northwest part of the City. Roads must be developed to provide access to large vacant landlocked parcels which are suitable for residential development. The extension of Vreeland Road to Inkster Road would facilitate development in the northwest part of the City. L i L Central part of the City. The central part of the City, north of Gibraltar Road and west of Cahill Road, is viewed by many City leaders as the best location for high quality single family development. Housing in this area would be located close to the City's primary commercial district, public facilities, and schools. Access roads are needed in this area to unlock the development potential. - Northcentral part of the City. The opportunity exists for additional single family development north of Vreeland Road and south of the mobile home park. The layout of any future residential development in this area must be sensitive to the potential impact of more intensive uses to the north, east, and west. - City Center. The opportunity for new residential development exists in downtown Flat Rock. A ·variety of housing types could be developed in the downtown area, including townhouse, mid-rise, or single-family housing. Ne~ - 75 - �.. I : '' '- I I_- housing should be integrated into an overall mixed use development plan for the downtown. Mobile Home Park The land use survey completed in 1988 revealed that 2.8 percent of the City's land area is occupied by a mobile home park which is located at the north end of the City, between Telegraph and Peters Roads. One objective of the Master Plan is to seek a more balanced range of housing, yet provide opportunities for construction of various types of housing to meet the needs of residents. Also, it is the intent of the Master Plan to minimize additional demands on public services and minimize any deterrent impact on future low density single family development elsewhere in the City. Accordingly, the Future Land Use Map does not designate any additional lands for mobile home park development. If the housing balance improves in the future such that additional single family homes are constructed, then future mobile home park development may be appropriate. Under such circumstances, expansion of the existing mobile home park to the south would be appropriate. Multiple Family Residential It is intended that areas designated for multiple family use be developed with attached housing at a density of between seven and ten units per acre. The nmultiple familyn classification may include single family attached townhouses, apartments, or mid-rise housing. Multiple family areas are generally located on the Future Land Use Map where they can serve as a transitional zone between commercial or industrial development and lower density sing~e family housing. Multiple family areas are also located where they would have direct access onto major thoroughfares so as to minimize the impact of increased traffic on the road system and on nearby land uses. i I The Future Land Use Map identifies five general areas where multiple family housing is appropriate: l On the south side of Gibraltar Road, in the vicinity of existing multiple family complexes. Vacant land between the existing complexes provides the opportunity for limited expansion. I. !. - On the east side of Cahill Road, between Vreeland and Gibraltar Roads. Multiple family development in this area would serve as a transition zone between the single family area to the west and the industrial area to the east. - Along Arsenal Road, north of Huron River Drive. Multiple family dev~lopment in this area would serve as a transition zone between the developing single family area to the north and the intensive development along the railroad and on Huron River Drive. I I I L - 76 - �- On the west side of Telegraph Road at the north end of the City. The location of this parcel, its shape, the character of land use to the north, and other site constraints make this parcel of land suitable for multiple family. - On the south side of Vreeland Road, between Cahill and Telegraph Roads. Multiple family development in this area would serve as a transition zone between the proposed single family area to the south and the industrial/ railroad area to the north. Commercial and Office Uses The economic analysis revealed that there is a strong potential for commercial and office development in Flat Rock, as the population, number of households, and total income in the trade area continues to increase. Research presented earlier in the Master Plan indicated that the Flat Rock trade area is currently underserved in terms of retail facilities, based on comparison with other communities. As such deve 1opment occurs, it is expected that the particular function, or market niche, of each commercial district will become better defined. North Telegraph Road is expected to retain its status as the primary retail and service district in the City. The downtown area is expected to develop as a mixed use center of office and specialty retail. The Gateway planned mixed use area is expected to contain regionally-oriented retail development, office, and lodging, among other uses. I. A more complete description of the commercial and office areas designated on the Future Land Use Map follows: North Telegraph Road Business District. Over the next twenty years, the Telegraph Road business corridor, north of the railroad tracks, is expected to retain its status as the main retail/service district in the City. To accommodate the projected growth in the commercial sector, the Future Land Use Map calls for Commercial/Retail development along almost the entire length of the north Telegraph Road corridor. Furthermore, the Future Land Use Map provides for greater depth for the commercial frontage wherever feasible. The greater depth will allow for limited expansion as well as improved site design on existing inadequately-sized sites. Downtown Flat Rock. In accordance with the mixed use pattern proposed for downtown Flat Rock, limited retail, office, and service uses would be appropriate. Three factors should be considered when evaluating commercial development proposals for downtown: 1) the intensity of any such development must be compatible with existing and future residential development that is 1ocated in the downtown area, 2) the intensity of deve 1opment must be appropriate for the size and configuration of the site on which it is located, and 3) emphasis should be placed on upgrading existing facilities and quality building design. - 77 - �". ,I l f. l f. - Neighborhood Commercial Development. The Future Land Use Map identifies two locations where neighborhood commercial development is appropriate: the "Big Lots" shopping center on the south side of Gibraltar Road, east of City Hall, and at the intersection of Huron River Drive and Sheek Boulevard. Future development in these areas should consist of low-intensity convenience commercial uses that are compatible with the surrounding residential development. - Gateway Planned Mixed Use Area. Retail development would be appropriate in the Gateway Commerce Center area, as a part of the mixed use development plan anticipated for the area. A broad range of commercial uses would be appropriate in the Gateway area which, because of its location, would serve an automobile-oriented market. Office Development. In addition to the downtown area, the Future Land Use Map identifies one other location where substantial office development would be appropriate: along Gibraltar Road. Office development along this corridor would serve three purposes: I • ! 1. Amply landscaped office development would provide an attractive entrance to the City. 2. Office uses would provide a buffer between residential development to the north and south and the traffic on Gibraltar Road. 3. Offices would be compatible with the existing churches along Gibraltar Road. Planned Mixed Use Development As noted previously, "Planned Mixed Use Development" is designated in two areas on the Future Land Use Map: Gateway Planned Mixed Use Area. The conceptual plans that have been considered by the City in the past provide a general indication of the range of uses that might be appropriate in the Gateway area, including retail, office, research, lodging, and light industrial uses. There are three principles that will determine the success of a mixed-use development proposal in this area: 1) the timing of the proposed development, 2) the ability of the proposa 1 ( based on the mix of uses) to create a focus of activity that will draw a new regional market to Flat Rock, and 3) the quality of the overall plan, which must integrate several different uses into a single functioning unit. - Downtown Flat Rock. The new senior citizens building was a major project that upgraded the image of downtown. Additional "major projects" are required to reverse the gradual decline that has been evident. The Future Land Use Map provides for a mixed land use pattern in the downtown that includes office uses, retail, and housing uses. Replacement of existing uses and buildings may eventually be necessary or, based on the future I. I : - 78 - �development plans, it may be possible to combine existing and new uses. Detailed plans for the downtown are being prepared by the Downtown Development Authority. New housing is viewed a key component for the revitalization of downtown, since it would provide market support for the retail uses. Townhouses (68 units per acres) or garden apartments (10-15 units per acre) would provide the required population concentration. Such housing should be designed to be compatible with existing single family housing in the vicinity. Any development proposals for the downtown must be sensitive to the fact that this is the oldest part of the City. Although new development is necessary, structures which have historic value should be preserved and renovated. Because the downtown was developed several decades ago, the size of the parcels and the configuration of land uses favor pedestrian movement. It is necessary to adapt the downtown to higher level of vehicle movement in order to meet needs of modern business, but the pedestrian environment must still be retained. Industrial and Railroad Use The Economic Analysis revealed that conditions are conducive for industrial growth in Flat Rock. The City's industrial attributes include access to freeway transportation, availability of vacant land, and access to rail facilities. Vacant lands on the east side of the City are best-suited to the locational requirements of industry because of the immediate access to I-75. Accordingly, "General Industrial" ·use is indicated on the Future Land Use Map for the Mazda parcel, plus land adjacent to the Grand Trunk classification yard north of Vreeland Road. An objective of the plan is to maintain heavy industrial uses on the east side of the City to minimize the effect from trucks, noise, fumes, and other impacts on the rest of the City. Planned light industrial and warehousing is proposed in three locations: - As a transitional use along Hall Road. In this location, the light i ndustri a1 development wi 11 pro vi de a buffer between the more intensive industrial development to the east and the residential development to the west. Ideally, new light industrial development should be contained in planned industrial parks or a similar planned setting. [ - Along Cook Road near the railroad tracks. The uses in this district have adapted to unusual site conditions that would not be suitable for most other uses. The Future Land Use Map provides for the continued operation of this existing industrial district, provided that the intensity of development does not increase. However, efforts should be made to upgrade the appearance of these facilities and to provide a more direct outlet onto Telegraph Road. [ I I L... - 79 - �- North of the railroad tracks, on the west side of the City. The Future Land Use Map provides for continued use of 1and which has been used for industrial purposes for several decades, beginning with the a Ford Motor Company operation. The site is currently occupied by Flat Rock Metals. Any increase in the intensity of the industrial use would not be appropriate in this part of the City. As noted earlier, light industrial use in a planned setting would also be appropriate in the Gateway planned mixed use area. Existing lands currently being used for industrial use in the vicinity of Arsenal Road near the railroad tracks are not designated for industrial use on the Future Land Use Map. The existing industrial uses in this area have been in a state of decline for several years. The sites are too small to accommodate most modern industrial operations. Commercial uses would be more viable on these sites in the long run. Furthermore, commercial development would be more compatible with the existing and future residential uses in the vicinity. 1.. The Grand Trunk rail classification yard is an established industrial/ transportation use which provides significant economic benefits for the City. The Future Land Use Map anticipates the continued operation of the classification yard within its existing boundaries. Parks and Recreation The Community and Recreation Facilities chapter indicated that the immediate emphasis in terms of parks and recreation planning should be on the development of facilities in existing parks, rather than acquisition. However, the analysis recognized that as new residential subdivisions are developed additional neighborhood park land will be needed. [ I (. l_ .• Based on this assessment, the Future Land Use Map identifies two existing Cityowned parks, Hu Roe Park and Flat Rock Community Park (adjacent to City Hall). Emphasis should be placed on enhancing the natural amenities at Hu Roe Park for passive recreation use. Flat Rock Community Park should continue to be developed for active recreation. Lands located on the west side of the City which are owned by the Huron-Clinton Metropark Authority are also identified as "Parks and Recreation" on the Future Land Use Map, even though these lands are not currently open to the public. This land would be suitable for campground use or nature study. The Future Land Use Map also identifies four "Proposed Park Sites" in locations where neighborhood parks will be needed after residential development occurs. The proposed park site designations are intended to be generalized; they are not intended to be site specific or to follow specific property lines. Additional information concerning proposed parks and recreation improvements are set forth in the City's Recreation Plan. - 80 - �Finally, the Future Land Use Map identifies riverfront park sites which are still under study. Two such sites are publicly-owned lands which could be developed to provide limited river access. Two other riverfront properties, on Arsenal Road south of Hu Roe Park and south of the Telegraph Road bridge, are privately owned. Public Facilities The Future Land Use Map identifies City facilities, schools and school owned properties, and cemeteries. Key public facilities are identified below: - City Hall Complex. City Hall is a modern, spacious building which is located in a highly visible, centrally situated site on Gibraltar Road. As indicated in the Community and Recreation Facilities chapter, the opportunity exists to develop the site into a true civic center by incorporating other public facilities (such as the library) and by continuing the expansion of the adjacent Community Park. The civic center function would be further enhanced if the high school is moved to the large vacant school-owned parcel directly north of City Hall. - Schools. Parcels occupied by four schools are identified on the Future Land Use Map: I. 1. Flat Rock High School is located on 5.4-acre site on Division Street. Current published standards indicate that Flat Rock is in need of a more modern high school facility on .a larger site. The vacant property north of City Hall would be an excellent location for a new high school. 2. Barnes Elementary and Simpson Junior High are located adjacent to each other on Meadows Street. These sites are adequate in size, but a direct means of access is required. 3. Bobcean Elementary Schoo 1 is 1ocated on Evergreen., north of Gibraltar Road. The school district owns one other large parcel of land in the City, on the east side of Arsenal Road, south of Matilda. New school construction on this parcel is not anticipated in the near future. Single family development would be appropriate in the event that the school district relinquishes ownership of the parcel. Road Network [ The Circulation Analysis identified several circulation system deficiencies including: - Increasing traffic congestion and traffic conflict on Telegraph Road. r- - Lack of a direct link between Gibraltar Road and Telegraph Road . - 81 - �r -r; .... '\. - The need for access roads to serve vacant lands and schools. I, - The need for collector roads to complete the road •network.• r. - The need to pave roads to facilitate development in underdeveloped parts of the City. Recommendations to address many of these deficiencies are set forth in the Circulation Analysis and on the Comprehensive Circulation Plan Map (Map 4). The Future Land Use Map i dent i fies access roads needed to serve vacant 1ands, including: extension of Vreeland Road west to Inkster Road, extension of Seneca east to Cahill, extension of Cahill south to Woodruff, and connection of Meadows and Carter Streets to provide a link between Tamarack and Olmstead. The exact location of these road extensions could vary depending on topography, location of drains and wetlands, the need to align new roads with existing roads, proposals for new development, and similar considerations. I, /_ r 1-- I II_, - 82 - �·~ _____. /' ,:::,1.-·.~·-. ~~~ ~i) ·\ >:\1'.: ~1~~ -L cu1,,po111 ,, ,,,,"" 11 III :,,! ,.,--- '--; ~ // '-.._____ ·... ,, I' I' ·, // 1' ,1 1' ,1 11 ,, ,,' !\ ' .:·..... , \ , ~[WB!flll ",,,, ,, =----= \\k~o•u•===cY-=-- I' LEGEND □ SINGLE FAMILY RESIDENTIAL PUBLIC (CITY HALL , SCHOOLS, MUNICIPAL BUILDINGS & CEMETERIES) ~!i!iili!/!l/lli/;I lt f MULTIPLE FAMILY RESIDENTIAL OFFICE MOBILE HOME PARK ~ COMMERCIAL/RETAIL -=- ,~t.!.~~1x..e~1~~~'?.oM!~~f.lJJSE DEVELOPMENT CBD PLANNED MIXED USE DEVELOPMENT (RETAIL, OFFICE & HOUSING) E] ~ GENERAL INDUSTRIAL PLANNED LIGHT INDUSTRIAL & WAREHOUSING R . PARKS & RECREATION RAILROAD [l PROPOSED PARK SITE POTENTIAL RIVERFRONT ~ ACCESS sn,ov) X , PROPOSED ROAD WNOER LAND USE ■ ■ ■ CITY OF FLAT ROCK ■ ■ WAYNE COUNTY MICHIGAN ■ ■ ■ ■ ■ ■ FUTURE - scale 800(1600 ■ ■ north 3200 feet . . . . Mtp • SOIH'U! Ci1y ol ,1,1 Aocll, Michigan one mile CD MAP 6 MS:KeMa Associates, Incorporated Community PlaMlng • Urban Design Farmington Hills, Michigan F .,. � Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Wyckoff Planning and Zoning Collection Creator An entity primarily responsible for making the resource Planning & Zoning Center (Lansing, Mich.) (Organization) Wyckoff, Mark A. Description An account of the resource Municipal master plans and zoning ordinances from across the state of Michigan, spanning from the 1960s to the early 2020s. The bulk of the collection was compiled by urban planner Mark Wyckoff over the course of his career as the founder and principal planner of the Planning and Zoning Center in Lansing, Michigan. Some additions have been made to the collection by municipalities since it was transferred to Grand Valley State University. Coverage The spatial or temporal topic of the resource, the spatial applicability of the resource, or the jurisdiction under which the resource is relevant Michigan Date A point or period of time associated with an event in the lifecycle of the resource 1960/2023 Source A related resource from which the described resource is derived <a href="https://gvsu.lyrasistechnology.org/repositories/2/resources/870">Planning and Zoning Center Collection (RHC-240)</a> Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/vocab/NoC-US/1.0/">No Copyright - United States</a> Subject The topic of the resource Michigan Comprehensive plan publications Master plan reports Zoning--Michigan Zoning--Maps Maps Land use--planning Publisher An entity responsible for making the resource available Grand Valley State University. University Libraries. Special Collections & University Archives Identifier An unambiguous reference to the resource within a given context RHC-240 Format The file format, physical medium, or dimensions of the resource application/pdf Type The nature or genre of the resource Text Language A language of the resource eng Text A resource consisting primarily of words for reading. Examples include books, letters, dissertations, poems, newspapers, articles, archives of mailing lists. Note that facsimiles or images of texts are still of the genre Text. Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Identifier An unambiguous reference to the resource within a given context Flat-Rock_Master-Plan_1990 Creator An entity primarily responsible for making the resource McKenna Associates, Incorporated Date A point or period of time associated with an event in the lifecycle of the resource 1990-01 Title A name given to the resource Master Plan Description An account of the resource The Master Plan for the City of Flat Rock was prepared by McKenna Associates, Incorporated In January 1990. Subject The topic of the resource Master plan reports Flat Rock (Mich.) Wayne County (Mich.) Source A related resource from which the described resource is derived <a href="https://gvsu.lyrasistechnology.org/repositories/2/resources/870">Planning and Zoning Center Collection (RHC-240)</a> Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/vocab/NoC-US/1.0/">No Copyright - United States</a> Type The nature or genre of the resource Text Format The file format, physical medium, or dimensions of the resource application/pdf Language A language of the resource eng Publisher An entity responsible for making the resource available Grand Valley State University. University Libraries. Lemmen Library and Archives https://digitalcollections.library.gvsu.edu/files/original/f8a3271ee0471c154224d9beab958a8f.pdf 5d7f0b302301489ffbc3afacb3dcb3a6 PDF Text Text �MASI~r~ City of ~-.bj~ Wail_~, Oakland ciill"lty; ~a~e ich~an n I l. ., Prepared by: McKenna Associates, Incorporated Farmington Hills, ·chigan Transportation Analysis Prepared by: Ann Arbor Planning Associates in consultation with McNamee, Porter & Seeley Ann Arbor, Michigan l , Date of Public Hearing and Adoption by the Planning Commission: April 10.1 1990 . . \.1 ~ Reproduced on recycled paper. �""' ''.';. •. , ACKNOWLEDGEMENTS MAYOR William T. Roberts CITV COUNCIL James D. Clifton, Mayor Pro-Tern Linda S. Ackley Wil 1i am I. Burke Diane Cartter Heather F. M. Hill Rebecca Williamson I , , . ,--.. . _ ,..._ PLANNING COMMISSION Helen Foss, Chairperson William Compton, Vice-Chairperson Thomas Bailey Peter Lalic Bruce Lloyd David Ridley Lillian Spencer Wil 1i am Teri an Kenneth Tucker ADMINISTRATH>N J. Michael Dornan, City Manager-Treasurer Ruby Lewandowski, City Clerk Kurt L. Fenske, Building Official Julie Fritz, Planning Commission Secretary �TABLE -OF CONTENTS Tit1e Page Acknowledgements Table of Contents List of Tables Li st of Figures List of Maps iii iv iv MASTER PLAN GOALS Introduction 1 1 POPULATION ANALYSIS General Demographic Trends Population Characteristics Summary of Major Trends Future Population Growth Population Projections 7 7 10 EXISTING LAND USE General Overview Residential Land Use Commercial and Office land Use Industrial land Use Public and Semi-Public Land Use Rights-of-Way Vacant Land 22 22 24 14 15 19 26 27 28 28 28 ECONOMIC ANALYSIS Existing Commercial Facilities Commercial Development Potential Existing Industrial Facilities Industrial Development Potential Fiscal Impact of Economic Growth 29 29 35 41 44 46 TRAFFIC AND TRANSPORTATION STUDY INVENTORY AND ASSESSMENT OF EXISTING CONDITIONS Introduction Existing Road Conditions Existing Intersection Conditions Traffic Volumes and Turning Movements Accidents Levels of Service Planned Transportation Improvements Summary of Findings RECREATION ANALYSIS Description of Planning Process Administrative Organization Inventory of Existing Facilities Parks Classifications 50 50 50 53 55 60 64 68 73 76 76 76 77 82 - i - �I , I~ r ! ,,--.- ', rI ! ( - r ~ l - :::::::----. Table of Contents Cont. PAGE RECREATION ANALYSIS (Continued) RecreaDion Deficiencies Residents' Preferences and Ne~ds Long-Range Goals Parks and Recreation Objectiyes Five-Year Action Program COMMUNITY FACILITIES ANALYSIS City Administrative Services Utilities 83 87 89 90 91 95 95 98 TRAFFIC ANO TRANSPORTATION STUDY EVALUATION AND RECOMMENDATIONS Summary of Transportation Problems Proposed Alternative Actions Overview Recommendations to Improve Traffic Flow Evaluation Methodology Overview The Computer Model The Network Model Application of Model to Walled Lake The Walled Lake Network Imputs Assignment Calibration Model Results for the Proposed Actions Overview Impacts of the Separate Actions Impacts of Combined Actions Conclusions and Recommendations Overview High Priority Road Improvements Second Priority Road Improvements Control Access and Future Development Summary FUTURE LAND USE Introduction Future Land Use Map Residential Land Uses Commercial and Office Uses Industrial Land Uses Parks and Recreation Public and Semi-Public Land Uses Road Network ~ - ii - 102 102 103 103 103 105 105 106 106 110 110 111 114 115 115 115 116 122 124 124 128 129 130 132 134 134 135 136 139 141 142 143 144 �.,,_ I\ LIST OF TABLES I' PAGE I l. i NUMBER f7 1 , ' 2 3 4 5 6 7 8 9 10 11 12 13 \ , 14 15 !' . l , l • 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 TITLE Total Population Population Age Structure Future Age Structure Composition of the Labor Force Annual Household Income Residential Acreage (1989) Population and Household Projections Land Use Acreage Number of Commercial Uses by Type Types of Businesses within Each Commercial Area Location of Various Types of Commercial Uses Projected Growth within the Potential Trade Area Projected Growth in Household Income within the Potential Trade Area Property Value History - Walled Lake and Neighboring Communities Value of Classes of Property Value of Classes of Property (1989) Existing Road Conditions Existing Intersections Traffic Volumes Access Points onto Pontiac Trail Level of Service and Delay at Signalized Intersections Level of Service and Delay at Unsignalized Intersections Level of Service at Intersection During P.M. Peak Period Haggerty Road Connector Estimated Traffic Volumes for 1987, 1995 and 2010 at Crossroads with Haggerty Road Parks and Recreation Facilities Comparison to Published Recreation Standards Recommended Recreation Facility Standards Trip Purpose Distributions by Time-of-Day Average Daily Traffic in the Haggerty Road Corridor Impacts of Proposed Actions - Base Year Impacts of Proposed Actions - 2010 Impacts of Proposed Actions - Base Year (Combined Actions) Impacts of Proposed Actions - 2010 (Combined Actions) - iii - 8 10 11 13 14 16 20 23 31 32 32 36 37 47 47 49 52 54 56 62 65 65 66 70 81 85 86 112 114 117 118 123 125 �LIST OF FIGURES i__ r-, I ,_, ' NUMBER Population Trends in Nearby Communities Population Projections Property Value History Parks and Recreation Program Organizational Structure 1 2 3 4 -- TITLE ,- LIST OF MAPS L, NUMBER 1 2 3 4 ' - : C - 9 21 48 78 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 PAGE TITLE Existing Land Use Existing Commercial Areas Existing Industrial Areas Average Daily Traffic Increase in Traffic Volumes Intersection Traffic Volumes During P.M. Peak Mid-Block Traffic Accidents Intersection Traffic Accidents Levels of Service During P.M. Peak Regional Parks and Recreation Facilities Parks and Recreation Facilities Proposed Parks and Recreation Facilities Sidewalk and Safety Path Plan Transportation Zones Traffic Impact Analysis Screen Display of the Network Base Year ADT with the Maple Road Connector Base Year ADT Upon Closure of E. Walled Lake Drive ADT in 2010 with No Changes to the Road System ADT in 2010 upon Implementation of All Recommended Actions Future Land Use APPENDICES A. B. Haggerty Road Connector Alternatives Parameters and Ratios Used in Transportation Model - iv - 25 30 43 57 58 59 61 63 67 79 80 94 101 107 108 109 119 121 126 127 146 �MASTER PLAN GOALS Introduction, This chapter sets forth goals which provide the overall direction for the Walled Lake Master Plan. These goals resulted from discussion with the Planning Commission and department heads early in the planning process~ They address the general development of the City, land use, housing, the environment, economic development, transportation, community facilities, and recreation. General Goals I. Neighborhoods: Foster strong, vital neighborhoods to ensure that Walled Lake continues to be recognized as a stable community where families and individuals reside, work, and shop. 2. Master Physical Planning: Maintain complementary land use relationships which promote a harmonious, attractive community; preserve natural resources; promote a sound tax base; and provide for manageable traffic volumes. 3. Roads and Transportation: Develop an orderly program for improvement, maintenance, and expansion of the road system in order to meet increasing traffic demands, provide smooth traffic flow, and provide proper access to all property within the City . 4. Property Maintenance: Recognize that the City and its physical resources are dynamic, and aggressively encourage property maintenance and reinvestment. 5. Fiscal Stability: Promote the development of a financially secure community which can continue to provide all necessary services to its residents and businesses in an efficient manner. 6. Land Use: Promote efficient use of the land and encourage assembly and orderly redevelopment if appropriate land use plans are presented for: new development .on vacant lands; underdeveloped areas; areas isolated among more intensive uses; or areas which are declining or negatively impacted by nonresidential traffic or incompatible land uses. 7. Urban Design: Promote development that is consistent with the urban design concept that is defined and described in the Master Plan. - 1 - �8. Planning Innovation: innovation would: Permit innovation in land use planning where more effectively implement the goals set forth in the Master Plan, achieve a higher quality of development than would be possible under conventional regulations, result in better use of land in accordance with its intrinsic character, result in development that is compatible with surrounding uses, and produce recognizable and substantial benefits for the community that would not otherwise be achieved. \ L, Residential Goals r· 1. Single-Family Neighborhoods: Retain single-family residential areas as secluded and quiet neighborhoods through the promotion of safe and efficient internal pedestrian and vehicular circulation systems, maintenance of citywide public services, and protection from nonresidential encroachment. 2. Multiple-Family Development: I Recognize that multiple family housing satisfies the needs and lifestyle of many · residents. Accordingly, seek a balance of housing types and densities that can be adequately accommodated by the road system, recreation facilities, schools, and other public facilities. l. High- and medium-density housing should be located only where there is access to major thoroughfares, and only where it can be adequately served by public and private services without unreasonable disruption to the level of services enjoyed by other residents. f. Future multiple-family housing should be constructed of the highest quality materials. Buildings and other improvements should be placed on the site with sensitivity to natural features and the need to create a stable and secure living environment. Maintain the quality of existing multiple-family developments through strict enforcement of City ordinances, security, housing inspections, and beautification promotion. L 3. Density Relationships: High- and medium-density residential developments should be separated from lower-density developments. Exceptions to this policy would be where a higher-density residential development serves as a transition between commercial development and lower-density residential development, or where housing of varying densities is contained within a planned development. 4. Housing and the Environment: Consider the impacts of various types and densities of housing on the environment, taking into consideration the need - 2 - �to protect sensitive wetlands and woodlands, the potential impact on the lake, and the impact on transportation. ,--I iL:' 5. Housing for Elderly Residents: Provide a sufficient supply of affordable housing • alternatives for elderly residents which will encourage them to remain in the community, balancing and diversifying the population . 6. Housing Maintenance: Encourage housing rehabilitation and require a high standard of property maintenance to perpetuate a high quality of housing among residents. Recognize that, in order to maintain high quality housing, some deteriorated homes or residential areas may need to be redeveloped. .-,1 Economic Development 1. Economic Development Initiatives: Continue to develop and apply economic development tools (such as formation of the DOA, tax increment financing, tax abatements, sharing in the cost of utilities, and special assessment districts) in a prudent and efficient fashion to enhance and maintain a balanced, healthy mixture of business and industry, provided that such programs are consistent with the overall development and financial goals of the City. 2. Criteria for Offering Incentives: Economic development incentives should be used chiefly to promote development of light manufacturing, research firms, and other types of development which: 1) are compatible with the City's goals concerning protection of residential areas and the environment 2) generate new employment opportunities, particularly for residents, and 3) increase the tax base. I. Commercial Development Goals 1. Lakeshore Business District: Recognize the lakeshore business district -- the original downtown -as the focus of specialty retail, restaurant, entertainment, and office activity, in a mixed use setting. Work toward improving the function and appearance of the l akeshore business district, using the 1982 Downtown Improvement Program as the primary guide. · Recognize that improvement to the downtown must be a shared responsibility involving the City and business/property owners. l., 2. Pontiac Trail and E. West Maple Road: Recognize that the center of retail and service activity in the City -- the new downtown -- is along Pontiac Trail and E. West Maple Road. Promote development that will improve the diversity and quality of business activity along these corridors. Furthermore, work with the business community to improve the appearance and function of the commercial districts. 3. Neighborhood Commercial Districts: Provide convenience commercial services within planned shopping centers in accessible locations at intersections of major roads throughout the City. - 3 - �I • 11 i 4. Planned Deve 1opment vs. Li near Shopping Districts: The deve 1opment of planned multi-tenant shopping centers or office buildings should be encouraged along commercial corridors, instead of unplanned strip deve 1opment where one use is 1ocated on each parce 1 . Con so 1i dat ion of individual uses on separate parcels should be encouraged. 5. Revitalization of Aging Conunercial Districts: and redevelop aging business structures deteriorating conditions and the aging cycle. 6. Appearance: The design of commercial uses in Walled Lake should reflect thorough and careful analysis of the site and a sincere effort to improve aesthetics, consistent with the urban design guidelines set forth in the Master Plan. · f~ I' ., Maintain, upgrade, expand, and sites, anti ci pat i ng I I • r . L r-· Architecture should be clean and uncluttered, and excessively large or garish signs should be prohibited. Loading and storage areas should be screened, preferably with landscaped screening or a combination of landscaping and walls. Parking areas should be landscaped to provide visual relief to large paved areas. Landscaping and setbacks should generally convey a sense of spaciousness and compatibility with the underlying natural features. 7. Office Development: Provide sites primarily in the downtown area and along Pontiac Trail for both large and sma 11 er seal e office uses which wi 11 enhance the City's tax base, be attractively developed, and create employment. Industrial Development Goals 1. r. Promote the location of new high technology, research and light industrial parks in attractive settings, recognizing that the City's industrial districts are centrally located and must co-exist harmoniously with the rest of the community. 1 L ..J I ' Industrial Design Standards: Future industrial development within planned industrial parks should be encouraged. Planned industrial parks should include an internal circulation system, needed supporting facilities, and adequate land use transitions to other parts of the City. - 2. Industrial Diversity: Continue to promote diversity in the City's industrial base through recruitment of high-tech, research, light manufacturing, and warehouse uses. - 4 - �3. Utilities and Public Services: Future industrial development should be permitted only in accordance with the ability to provide required utilities and public services, including public water and sewer services, adequate road construction and maintenance, police and fire protection, and general municipal administrative and regulatory services. The ongoing costs of providing such services should be considered, as well as the costs related to initial construction. Environmental Goals 1. Walled Lake: Recognize that the lake is the City's most significant natural 2. Protection of Natural Features: Promote the preservation of significant wooded areas, wetlands, and floodplains through the review of development plans and utilization of environmentally sensitive areas for storm water control and low intensity uses (such as recreation uses), recognizing that a balance must be achieved between natural resource goals and other planning and development goals. 3. Pollution Control: Continue to encourage land planning, development patterns and effluent treatment techniques which promote energy conservation and minimize noise and pollution of the air, soil, and water. rH feature. Promote development that will: 1) preserve the natural lakefront environment, and 2) maximize visual and physical access to the lake for all residents. l. I' I I Transportation I 1. Transportation Planning: Promote transportation improvements consistent with· efficient access to community goods and services, public safety and convenience, and consider the capability of the transportation system to accommodate increased traffic produced by development. 2. The Need for New Roads: Identify locations and work toward installation of new roads where needed, such as the extension of E. West Maple Road, to make vacant land accessible for development in accordance with the Future Land Use Plan and to alleviate traffic congestion. 3. Limit development within the existing or planned rights-of-way as indicated on the Master Thoroughfare Plan, anticipating the eventual upgrading of the entire road system within these rights-ofway. 4. Road Hierarchy: 5. Roadway Aesthetics: •4· i !I '- Right-of-Way Widths: Develop a road system that provides access to all parts of the City, yet restricts the use of neighborhood streets by trucks or extraneous through traffic. Roadways should be visually pleasing to motorists, pedestrians, and persons who view the roads from adjoining land. Frontage along roads should be amply landscaped. The construction of boulevards or parkways should be encouraged. - 5 - �6. n Pedestrian/Bicycle Transportation: Safety pathways should be required in conjunction with all new construction. Safety pathways should link residential areas with schools, recreation areas, commercial districts, and other attractions throughout the City. LI Corranunity Facilities f ., 1. Municipal Services: Develop a system of quality municipal services which is responsive and necessary to maintaining the attractiveness and vitality of the City's residential, business, and industrial population. 2. Maintenance and Replacement: Provide for system completion, ongoing maintenance, and replacement programs based on a continua 11 y updated capital improvement program for roads, streetlights, sewers, water mains, and other infrastructure elements. Recreation Goals 1. Level of Service: Provide the maximum level of neighborhood and communityoriented recreation facilities feasible to meet the needs of all residents, within the physical and financial capabilities of the City. 2. Enhancement of Existing Facilities: Consider enhancement of existing recreation facilities as a higher priority than acquisition of new properties. Accordingly, develop the City's recreation system based on the multiple-use concept, whereby each community park serves a large section of the City with facilities for active and passive recreation, competitive sports, facilities for children and adolescents, and picnic and nature study, providing a total recreation experience. 3. Coordination with Other Agencies: Continue to cooperate with other public and private organizations, such as the school district, Oakland County Parks, and the Huron-Clinton Metropolitan Authority, in providing recreation services and facilities to avoid unnecessary duplication. 4. Privately-Owned Recreation Facilities: Encourage privately owned and commercial recreation facilities to locate in the City, provided the type and location of such facilities is consistent with the City's recreation goals. 5. Recreation Facilities Outside the City: Provide expanded access to important recreation resources outside of the City to increase recreation opportunities for City residents. 6. Lake-Oriented Recreation: enjoy the lake. I • L, Work to enhance opportunities for resident to - 6 - �\ J POPULATION ANALYSIS General Demographic Trends The first census in which Walled Lake's population was recorded -- 1960 -revealed that the City had 3,550 residents. Almost thirty years later, in 1987, Oakland County estimates indicated that the population was 5,703, an increase of over sixty percent (see Table 1). [ \ l. The most substantial growth over the past three decades occurred since 1970. Between 1970 and 1980 the population increased by 989 residents, an average annual increase of 2.36 percent per year. The population has increased at an even faster rate since 1980, with an average annual increase of 2.65 percent per year. Evidence indicates that residential development Lake has been affected by five key factors: residential environment, economic opportunity, housing construction. Each of these factors paragraphs. and population growth in Walled regional growth patterns, the improved public services, and is examined in the fo 11 owing Regional Growth Patterns. Regional patterns of growth have affected population growth in Walled Lake over the past three decades. The population boom following World War II launched a period of continued growth in Oakland County. In the first two decades fo 11 owing the war modest growth was recorded in the area surrounding Walled Lake. By 1970, the Walled Lake area was at the leading edge of development in southeast Michigan, and residential construction and population growth surged. Figure I clearly illustrates this pattern of regional population growth, as reflected in the population figures for Walled Lake and surrounding communities over the past several decades. Figure 1 illustrates that, in comparison to surrounding communities, Walled Lake's population has grown at a steady rate. In contrast, the growth surge in the region since 1970 is dramatically reflected by the population figures of two neighboring communities, Commerce Township and Novi. l_ . Quality of the Residential Environment. The desirability of the residential environment has affected population growth in Walled Lake. The early settlement of Walled Lake in the early 1800's was related to the desirability of living and working near the lake. In essence, the lake was looked upon as a vital economic resource. Recreational and residential benefits of the lake replaced economic benefits in the 1900's, and Walled Lake came to be recognized as a choice summer rec re at ion area. Over the years, seasona 1 homes have been converted into permanent residences and new housing has been built to accommodate people's desire for greater enjoyment of the lakes. Concurrently, over the past several decades, the City has gone through a transition from a summer recreation-oriented community to a permanent year-round residential community. - 7 - �TABLE 1 TOTAL POPULATION Year Population 1960 1970 1980 1986 1987 3,550 3,759 4,748 4,850 5,703 Numerical Change Percent Change '. ,-- \ i Sources: +209 +989 +102 +853 +5.9% +26.3% +2.1% +17.6% Bureau of the Census, U.S. Department of Commerce. 1986 Estimate Reported in East North Central 1986 Population and 1985 Per Capita Income Estimates for Counties and Incorporated Places, Bureau of the Census, 1988. 1987 Estimate from the Oakland County Planning Division, Based on Census Conducted by the City of Walled Lake. r, 'L, r - l I I • '-· Economic Opportunity. New economic opportunities have attracted residents to the Walled Lake area in recent years. It is no longer a certainty that living in western Oakland County requires a long commute to work or to shop. Over the past five years, Farmington Hills, Novi, and West Bloomfield Township have been among the leading communities in Oakland County in terms of commercial and office growth. Consequently, residents of the Walled Lake area now have a broader range of shopping and services available nearby. With the growth in employment in the area, people have migrated to the Walled Lake area to live closer to their place of work. Improved Public Services. A fourth factor affecting population growth is the improvement in public services, which has made it feasible to permanently settle and enjoy the community. The completion of 1-96 and other improvements to the road system have made it possible for residents to live in a secluded residential environment, yet have access to the work opportunities and other amenities available in more populated parts of the region. Other public service improvements have been implemented in recent years, including expansion of the sewer and water systems, betterment of the school system, and advancement of the governmental system. With these and other ongoing public service improvements, the City has gradually upgraded the quality of life in the community. Housing Construction. Housing construction is the final key factor in the City's population scenario. Since 1970, the number of housing units has more than doubled, largely as a result of multiple family housing construction. There were 1,101 year-round housing units in the City in 1970, of which 283 were renteroccupied units. By 1987, the number of housing units increased to 2,347, of which 1,216 were renter-occupied units. Thus, renter-occupied units increased from about 26 percent to almost 52 percent of the total housing stock. - 8 - �c--i ~ :. -7 _! NOVI 30,000_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _........_ _ _ _ _ _ _ _ _ _ _ _ ___,...___ 2 5 , 0 0 0 , - t - t - - - - - - - - J - - - - - - + - - - - - - - + - - - - - - - + - - J { __ _.!--_J COMMERCE TOWNSHIP 20,000 I I I I I / I :;,....c: I I 15,000_._-1----------'--------.f---------+--...,,C.---#-----.f--------+----1 10,000 I I I✓ I V I I I WIXOM z W1LLED LAKE 5,000 WOLVERINE LAKE 0 t- c{ _J ::> ~-~ ~-•:~:• _::::::l: { 1 Cl. 0 Cl. 1940 19·50 '::::::::::/=::.:_:_:_:_·_;! ':~_ul1:1_:8!=::::::::::::::::::::::: ·::·:~--- __________ _::::::::::I::::::::::: : : : ~=-= ~---~ 1970 1960 1980 19"87 f990 (Est.) FIGURE 1 POPULATION TRENDS IN NEARBY COMMUNITIES Source: Bureau of the Census, U.S. Departr.icnt of Cor,11,1 erce Walled Lake Master Pl an �', .' f' Population Characteristics ' Age Composition. Although the median age of Walled Lake residents increased from 22.2 years in 1970 to 27.4 years in 1980, the population is still relatively young, compared to the population of certain surrounding communities and the County as a ~hole. For example, the median age of residents in Commerce Township is 28.4 years; the median age in Novi is 29.4 years. The median age for Oakland County is 30.3 years. Among surrounding communities, the lowest median age in 1980 was recorded in Wixom, at 25.7 years. Ir ' , I ; IL.' Between 1970 and 1980, numerical increases in population were recorded in every age group except the youngest age groups (under 15 years). As indicated in Table Z, the most substantial increases were recorded among young adults and the elderly. The number of residents between 25 and 34 years of age increased by 416, an increase of almost 78 percent. The number of residents 65 years or older increased by 225 residents, an increase of over 136 percent. TABLE 2 POPULATION AGE STRUCTURE Age Category 1980 Number Percent Numerical Change 1970-1980 427 11.4% 389 8.2% -38 5 to 14 years 888 23.6% 787 16.6% -101 15 to 24 years 690 18.4% 919 19.4% +229 25 to 34 years 535 14.2% 951 20.0% +416 35 to 44 years 464 12.3% 513 10.8% +49 45 to 54 years 398 10.6% 418 8.8% +20 55 to 64 years 192 5.1% 381 8.0% +189 65 and older 165 4.4% 390 8.2% +225 Under 5 years l 1970 Number Percent J l .. Source: Bureau of the Census, U.S. Department of Commerce. The population age structure is in part a reflection of the type of housing that has been constructed in the City. Typically, multiple family units appeal to oneand two-person households consisting of either young adults or elderly residents. The SEMCOG Small Area Forecast Version 84 indicates that the most substantial growth over the next twenty years will be in the age categories over the age of - 10 - �,-, 35 years (see Table 3). The SEMCOG forecast appears to be based on the natural aging of the existing relatively young population. The projections in Table 3 indicate that residents over the age of 35 will comprise over half of the total population by the year 2005. The median age of the population is projected to increase to 36.3 years. TABLE 3 FUTURE AGE STRUCTURE ,-I i ' L·._; r., I I I Age Category 1980 Number Percent 2005 Number Percent L. r- Numerical Change 1980-2005 389 8.2% 427 7 .1% +38 5 to 14 years 787 16.6% 850 14.2% +63 15 to 19 years 394 8.3% 436 7.3% +42 20 to 34 years 1,476 31.1% 1,150 19.2% -326 35 to 44 years 513 10.8% 931 15.6% +418 45 to 64 years 799 16.8% 1,521 25.5% +722 65 and older 390 8.2% 656 11.0% +266 Under 5 years Source: SEMCOG Small Area Forecast Version 84 There are two factors that could affect this forecast of continued aging of the population. First, the potential for new housing construction could result in an influx of younger families into the City. Second, because of the abundance of multiple family housing in the City the population is likely to be more mobile. Residents in multiple family housing are less likely to remain in the City for their entire lifetime. Household Size and Composition. Broad changes in household composition have been observed in Walled Lake in recent years. Of greatest significance is the change in household size, from an average of 3.72 persons in 1970 to 2.63 persons in 1980. According to the SEMCOG Small Area Forecast, average household size is expected to decrease to 2.34 persons by 2005. The decrease in household size can be attributed to the following three factors: 1. The Trend Toward Smaller Families. The trend toward smaller families is reflected in Census data for Walled Lake. In 1970, the average family in Walled Lake was composed of 4.09 persons. By 1980 the average family size had decreased to 3.24 persons. - 11 - �2. ~· I The Aging of the Population. The increase in the proportion of one and two-person "empty-nester" households composed of elderly residents has had the impact of lowering the average household size for the City as a whole. i I • 3. The TyP.e of Housing Constructed. The type of housing constructed over the past two decades is another determinant of household size. As indicated earlier, the number of rental units in the City more than tripled between 1970 and 1987. Most rental housing is in the form of multiple family units designed to accommodate small households. In 1980, the average multiple family unit in Walled Lake had 2.18 persons per household, compared to an average household size of 2.97 persons for single family units. In summary, the combination of smaller family size, the aging of the population, and sma 11 er housing uni ts produced a 29 percent decrease in household size between 1970 and 1980. The decrease in household size has had a substantial impact on total population. If not for the influx of residents due to new construction, the decrease in household size between 1970 and 1987 would have resulted in a population loss of about 1,200 persons. If SEMCOG estimates prove accurate and household size decreases to 2.34 persons, the impact on total population could range as high as 740 persons by the year 2005. 1 i ~. I t - l.. I J J ' '- Employment. Between 1970 and 1980, the labor force in Walled Lake grew by 771 persons, increasing from 1,422 to 2,193. Furthermore, the size of the labor force grew as a proportion of the total population, from 37.8 percent in 1970 to 46.2 percent in 1980, suggesting that a number of households have more than one wage earner. Similar increases in the size of the libor force have been recorded in other Oakland County communities. For example, among surrounding communities, residents in the labor force comprise 50.2 percent of the total population in Novi, and 57.3 percent of the total population in Wixom. Managerial, professional, and technical workers comprise the largest segment of the labor force, accounting for 26.8 percent of all resident employment in 1980 (see Table 4). The next largest segments of the labor force consist of operators, fabricators, and 1aborers ( 17. 5 percent of a11 emp 1oyment) and administrative support (15.0 percent). In general, the employment data show a trend toward a greater proportion of employees in "white collar" occupations, such as managerial, technical, sales, and clerical positions. Employment in these occupations more than doubled between 1970 and 1980 and constituted over eighty percent of the growth in the labor force as a whole. These occupations now constitute over 53 percent of the total resident labor force. Income. On the whole, the incomes of Walled Lake residents have continued to increase over the years. Per capita income, for example, increased by over 56 percent between 1979 and 1985, reaching a high of $12,385 per person. However, the per capita income for Walled Lake residents is somewhat less than the per capita average for the County as a whole, which was $15,485 in 1985. - 12 - �TABLE 4 COMPOSITION OF LABOR FORCE 1970 Number Percent Number Percent Mangerial, professional, technical 280 19.7% 588 26.8% 79 5.6% 251 11.4% Administrative support 191 13.4% 330 15.0% Service 130 9.1% 312 14.2% Precision production, craft, repair 285 20.0% 315 14.4% Operators, fabricators, laborers 438 30.8% 384 17.5% li 1.3% 11 0.6% Sales L I I • Other 1,422 Source: r. 1980 Occupation 2,193 Bureau of the Census, U.S. Department of Commerce Although the incomes of Walled lake residents have increased over the years, income levels are still lower than most surrounding communities. For example, the 1979 median family income for Walled Lake and surrounding communities (Commerce Township, Novi, Wolverine Lake, and Wixom) ranged from $19,902 to $30,289. Among these five communities, Walled lake recorded the second lowest median family income, $20,159. Walled lake has a greater proportion of households in the lower income brackets than the County as a whole (see Table 5). In 1979, 36.8 percent of all Walled Lake households had an annual income of less than $15,000, compared to 25.3 percent for the County. The incomes of 7.6 percent of all Walled Lake families placed them below the po~erty level. Walled lake's comparatively low ranking on the income scale can be attributed to three factors: 1. In comparison to most surrounding communities, Walled lake has fewer residents employed in managerial, professional and similar high paying occupations. 2. Walled lake has a higher proportion of elderly residents, many of whom are on fixed incomes. - 13 - �TABLE 5 r I ANNUAL HOUSEHOLD INCOME < i ., Oak.land County Walled Lak.e Number l: 1970 Percent Number 1980 Percent 1979 Percent less than $5,000 66 7.3% 192 10.8% 6.6% $5,000 to $14,999 594 65.3% 462 25.9% 18.8% $15,000 to $24,999 222 24.4% 494 27.8% 23.9% $25,000 to $49,999 22 2.4% 596 33.5% 38.2% 6 0.6% 36 2.0% 12.6% r. $50,000 or more Source: Bureau of the Census, U.S. Department of Commerce 3. Walled Lake has a relatively high proportion of rental housing units. People who are in their prime income earning years typically own their homes, rather than rent. · Although the rate of income growth in Walled Lake has lagged behind the rate of income growth in surrounding communities, in recent years the rate of income growth has outpaced the rate of inflation, as measured by the Consumer Price Index. Between 1979 and 1985, per capita income increased at average annual rate of 7.7 percent in Walled Lake. During the same period, the Consumer Price Index increased at an average annual rate of about 3.5 percent. L. I. I Education. The 1980 Census revealed than 67.6 percent of Walled Lake residents 25 years of age and older had completed four years of high school, and 32.l percent had some college education. Thus, 32.4 percent of the City's residents had not completed high school. In comparison, the educational attainment of residents of the County as a whole was higher than for Walled Lake. For example, 77.8 percent of all residents 25 years of age or older in the County had completed four years of high school, according to the 1980 Census. Almost 43 percent of the County residents had completed some college. Summary of Major Trends This analysis has shown that Walled Lake's population has grown at a generally steady rate since World War II, although the most substantial growth occurred since 1970. Population growth in Walled Lake is attributed to five key factors, - 14 - �including regional growth patterns, the quality of the residential environment, new economic opportunities being created in western Oakland County, improvements to public services, and the availability of new housing. The median ~ge of the population has increased in recent years, reaching 27.4 years in 1980. Compared to surrounding communities, though, the population of Walled Lake is relatively young. Nevertheless, substantial change in the age structure is projected over the next two decades, resulting in a much older population. SEMCOG estimates indicate the median age will increase to 36.3 years by the year 2005. This estimate could be affected by in- and out-migration, as well as new housing construction in the City. I" t. I l ., The decrease in household size is one of the most significant trends affecting Walled Lake's population in recent years. Household size decreased by 29 percent between 1970 and 1980, resulting in an average household size of 2.63 persons. Continued decrease in household size is projected through the year 2005. The changes in age composition and household size are due in part to national and regional trends related to marriage and family characteristics. Also, the types of housing being constructed in the City has had a partial impact on population characteristics; apartments typically appeal to smaller households, young adults, and elderly. The employment data show a trend toward a greater proportion of Walled Lake residents in "white collar" occupations, such as managerial, technical, sales, and clerical positions. However, compared to the surrounding region, a smaller proportion of Walled Lake's residents are employed in these occupations. Income levels of Walled Lake residents have increased at a steady rate over the past three decades, although the data reveal that the average family income in Walled Lake falls below the average incomes for surrounding communities. Nevertheless, in recent years income levels have increased at about twice the rate of inflation. Future Population Growth The level of growth of Walled Lake's population will be determined chiefly by four sets of variables: 1. Physical Parameters. Several physical variables will affect future population growth in Walled Lake, including the amount of vacant land available for residential development, the zoning restrictions placed on such land, the capacity of the sanitary sewer treatment facilities, the capacity of the road system, and the type of housing that is constructed in the future. 2. External Variables. The economic health of the region is the most significant external variable that affects population growth. - 15 - �f7 r 3. Characteristics of the Population. Characteristics of the population, such a age structure, household size, and propensity to move will affect population growth in Walled Lake. 4. Preferences of Residents. Existing and prospective residents' preference in terms of a living environment will have an impact on population growth. The type and affordability of housing, characteristics of the environment, and availability of public facilities and services affect people's desire to live in a community. n f Each of these sets of variables are discussed in detail in the following pages. ( " I i I I I • Physical Variables. Vacant land on which new housing units can be constructed is a key variable that determines the absolute maximum population, or "holding capacity" of the City. A land use survey completed in the spring of 1989 revealed that 36.4 percent of the City's land area is currently occupied by residential development. A total of 369 acres, or about 25 percent of the City's land area is still vacant. Of this total, 265.5 acres are zoned for residential use. A summary of the occupied and vacant residential acreage is provided in Table 6. TABLE 6 ' - I / :'. ,· RESIDENTIAL ACREAGE (1989) Development Vacant Total Single Family R-IA Zone R-1B Zone 422.2 acres 127.7 acres 105.4 22.3 549.9 acres Multiple Family RM-I Zone R-3 Zone MH Zone RD Zone 120.2 Total 542.4 acres 137.8 110.4 91.3 19.4 258.0 42.8 56.5 36.6 1.9 265.5 acres Vacant Buildable Acreage* 103 . 6 32.9 52.4 16.4 1.9 807.9 acres 214.0 * Vacant Buildable Acreage i$ vacant residentially-zoned land not located in wetlands. Source: February 1989 Land Use Survey by McKenna Associates, Incorporated. The development potential on the vacant and buildable residentially-zoned land can be computed based on the density standards set forth in the Zoning Ordinance for each zoning district. These computations reveal that the opportunity exists to develop another 2,270 housing units in the City. The RM-3 zoned property west - 16 ,- �of Pontiac Trail could accommodate up to 1,575 housing units, according to current density standards. Thus, the opportunity exists to almost double the 2,347 housing units currently existing in the City. Based on current household size levels, the construction of 2,270 new housing units would' add approximately 5,300 residents. Under this development scenario, the total population of the City would almost double to 11,000. These estimates do not account for recommended changes in the density of development that may be set forth in the future land use component of this master plan. Rezoning of land to R-lA or R-18 to facilitate new single family development would decrease the holding capacity of the City. I . I , t, ' i . I . I . ! •, ' These estimates also do not take into account possible limitations on holding capacity, such as the capacity of the wastewater treatment facilities. Development has been held up in recent years because the lack of capacity at the existing treatment facility. In early 1989 the cities of Walled Lake and Novi joined together on a two-year project to expand the treatment plant. This expansion is expected to create additional capacity for the entire City. The capacity of the transportation system could also limit residential development opportunities in the City. Certain roads, such as Pontiac Trail, already operate at an unacceptable level of service because of excessive traffic. Planning studies are underway to identify solutions that wi 11 a11 evi ate the traffic congestion, but implementation of any major improvements--such as the extension of West Maple Road -- is several years distant~ In the interim, the congested road network could be a deterrent to new residential development in the City. External Varfables. Certain variables are largely beyond the control of the City and its individual residents, yet these variables have a tremendous impact on population growth. The general state of the economy and regional patterns of growth and development are related external variables that work in conjunction to affect population growth. Cycles in the economy have been cited as one of the key determinants of population change in Michigan, because of the effect of the economy on migration patterns. In general, a lackluster economy results in a reduction in the number of families that purchase new homes or relocate. Thus, a poor economy tends to preserve the status quo · or, in certain communities, results in reduction in population. r . ' The impact of the recovery of the regional economy in recent years is most evident in western Oakland County, including the Walled Lake area. Resurgent growth pushed the leading edge of urbanization well beyond the boundary that seemed so permanent in the recession years in the early 1980's. If the economy continues to expand, it is likely that housing demand in Walled Lake will increase, resulting in new construction and possibly even redevelopment. Characteri sties of the Population. The earlier review of SEMCOG forecasts revealed that substantial increases are expected in the number of residents 35 years of age and older. The expected increase in this segment of the population - 17 - �is due largely to natural aging of the existing population, and to a lesser extent, due to inmigration of older families . The increase in the number of residents in the older age groups foretells an increase in the number of one and two-person households, including "empty-nester" households consisting of parents whose children have grown. i i f7 i • I. ;·- \L.., Migration patterns may alter the age structure projections. Because apartment dwellers tend to be more mobile than homeowners, it is likely that many residents will move before they reach an elderly age. The age structure projections could be further altered by the extent to which regional population trends affect Walled Lake. The demand for new housing in many surrounding communities is being created by young families. This trend is reflected in the Walled Lake School District enrollment projections, which indicate that enrollment will increase to a fifteen year high in the 1992-93 school year. lnmigration of new residents, in'cluding young families, is needed to offset the projected decrease in household size. As noted earlier, SEMC0G projections for the year 2005 ca 11 for an average household size of 2. 34 persons. If this projection proves accurate, the impact on total population could range as high as 740 persons by the year 2005. I[· l . 'f . Preferences of Residents. Variables related to people's preferences in terms of housing and the environment in which they live will affect population growth. Residents have been drawn to Walled Lake by a variety of features, including the following: - proximity to the 1ake, - the "small town" environment, - the quality of the school system, availability of housing and building sites at relatively low cost, - stable neighborhoods, - nearby employment opportunities, - nearby shopping and service facilities, and - well-maintained public services. The ability of the City to maintain these qualities will affect the stability of neighborhoods, and accordingly, the growth in population. Maintaining quality housing, good public services, and other qualities of the community becomes increasingly difficult as neighborhoods and housing ages. Continued investment in maintenance and replacement by the City and individual property owners will be required. Implementation of workable solutions to the transportation problem will have a substantial impact on people's perception of the quality of life in Walled Lake . - 18 - �Population Projections Current population statistics indicate that Walled Lake's population continues to grow at a steady rate. The information presented on the previous pages reveals a ~umber of events that are expected to generate additional population growth in future years. These events include continued economic expansion in western Oakland County, new housing development facilitated by expansion of the sanitary sewer treatment plant, the desire to live near the lake, and the general appeal of the community and its neighborhoods. One of the most precise population project i ans for Wa 11 ed Lake and other communities in the region have been prepared by SEMCOG as a part of its Version 84 Small Area Forecast. The Small Area Forecast is based on local land use plans and policies, modified to account for sewer service, protection of environmentally sensitive lands, planned transportation improvements, and similar considerations. I~ l '. I • I t.; SEMCOG projections indicate that the number of households in Walled Lake will increase to 2,555 by the year 2005. The SEMCOG projections further indicate a 26 percent increase in population, resulting in a total population of 5,975 by the year 2005 (see Table 7 and Figure 2). This increase is projected even though the number of persons per household is expected to decline from 2.63 to 2.34 persons. Thus, the net increase of 749 persons must be attributed largely to the projected increase in the number of households. Review of these projections reveals the importance of accurate estimates of household size. If household size were to remain steady instead of decreasing, the population could reach 6,720 by the year 2005, assuming that the number of households increases as projected. The SEMCOG estimates are based on a slower rate of growth than in the recent past. Between 1980 and 1988, an average of 60 units were added per year to the housing stock in Walled Lake. In contrast, the SEMCOG estimates call for construction of an average of 13 units per year over the next sixteen years. Data concerning growth in population in past years can be used to derive an alternate projection of future population. This statistical method of forecasting is called linear regression and involves fitting a straight line to a series of data points. The linear regression formula indicates that, based on past growth, the population of the City will reach 6,908 by the year 2005. l i l . I • A third method of projecting future population is to assume that the current rate of growth will continue. Based on the current rate of growth, 2.65 percent, the population of Walled Lake is projected to reach 9,132 by the year 2005. All three projections indicate that the population of Walled Lake in the year 2005 will fall short of the estimated holding capacity of 11,000. The SEMCOG projection of 5,975 residents probably will be reached earlier than the year 2005. SEMCOG's conservative estimate appears to have not taken into account the impact of the rebounding regional economy on growth in western Oakland County. - 19 - �TABLE 7 POPULATION AND HOUSEHOLD PROJECTIONS Percent Change I 1980 1990 2005 1980-2005 Population SEMCOG Linear Regression Current Growth Rate 4,748 4,748 4,748 5,743 5,704 6,169 5,975 6,908 9,132 +25.8% +45.5% +92.3% Household 1,806 2,150 2,555 +41.5% Persons Per Household 2.63 2.67 2.34 -11.0% • ,) l. . Sources: Southeast Michigan Council of Governments (SEMC0G) Small Area Forecast, Version 84 Computations by McKenna Associates, Incorporated I i i , I At the other end of the spectrum, it is likely that the estimate based on the current rate of growth is too optimistic. In the development of a City, the parcels of land that are easiest to develop are generally built upon first. The lands that remain vacant commonly have features which limit or deter development. For example, many vacant parcels in Walled Lake have wetlands on them. As the pool of vacant parcels diminishes, the pace of development slows because of the need to address unique circumstances on the remaining parcels. Thus, it is unlikely that the current rate of growth could be maintained far into the future. To conclude, the linear regression formula appears to provide the best estimate of future population in Walled Lake. The linear regression formula projects an increase of 1,205 persons over the next sixteen years, resulting in a total population of 6,908 by the year 2005. In comparison, over the past seventeen years the population of the City has increased by 955 persons. I L t - - 20 ; . �i r·--·. ' - _ _, J • ,. J l j --.... -·-· PROJECTION BASED ON CURRENT GROWTH RA TE 10,000 9,000 8,000 LINEAR' REGRESSION PROJECTION 7,000 6,000 6,000 SEMCOG PROJECTION 4,000 3,000 z 0 .,_ <( ...J ::> 2,000 1,000 0.. 0 0.. 1960 1970 1980 1990 2000 2005 FIGURE 2 Sources: 1960-1980 u.s. Census POPULATION PROJECTION SEl1C0G, Small Area Forecc1st, Version 1904 Walled Lake Master Plan Linear Regression Analysis �EXISTING LAND USE General Overview (" I I ' f~ I I The general pattern of development in Walled Lake has been influenced by three key parameters: the lake, major thoroughfares, and the railroad. The lake was the dominant focus of most early development. The original downtown was developed near the intersection of Pontiac Trail and Walled Lake Drive, facing directly onto the lake. Although the original downtown is no longer the primary center of business activity in the City, a few retail and service businesses still occupy buildings which date from the turn of the century. The original downtown eventually expanded to encompass about 10 to 12 blocks north of the lake. Whereas retail uses concentrated close to the lake, the northerly part of the downtown contained primarily institutional uses (such as churches and schools) and residential uses. A few historic structures still exist in this part of the City, including the "Stonecrest" school building, which was constructed in 1860. Some of the oldest housing in the City was constructed on land surrounding the original downtown and east and west along the lake. The construction or improvement of thoroughfares led to growth away from the 1ake. Pontiac Tra i 1, a state terri tori a1 road that was constructed in the 1830's, became the primary axis of development north of the lake. The City's business center eventually moved to the intersection of Pontiac Trail and E. West Maple Road, which is the City's major east-west thoroughfare. The City's most intensive commercial and service development is now located along E. West Maple Road. '-- ( . A third major transportation axis -- the railroad -- also affected the early development and general form of the City. The Michigan Airline Railroad, now known as Coe Ra i1 , was constructed in 1883, separating the north and south portions of City. Over the years most of the City's industrial growth occurred along the railroad, resulting in two distinct industrial districts on opposite sides of the City. As described in the previous paragraphs, the most intensive development in the City occurred near the lake and along the major transportation corridors. In general, the remainder of the City has been reserved for various types of residential deve 1opment. Aside from the l akefront resident i a1 deve 1opment, there are three distinct residential districts in the City: north of the railroad, east of Pontiac Trail, and west of the lake. Although growth has been recorded in every decade since Walled Lake was first settled in the early 1800's, almost a quarter of the land remains vacant. Thus, the opportunity still exists to shape the City to the form desired by residents and community leaders. A more detailed review of each type of land use follows. - 22 ' . �i~ I TABLE 8 i I LAND USE ACREAGE 1976 Acres Percent ' I t .r ·, ,. I ~ 1989 Acres Percent Change 1976-1989 Acres Percent Residential Single Family Multiple Family 377 .o 25.3% 542.4 422.2 120.2 36.4% 28.3 8. l +165.4 +43.9% Commercial Retail, Service Office 60.0 4.0 87.2 72.3 14.9 5.8 4.8 1.0 + 27.2 +45.3 Industrial 61.0 4.1 77. 7 5.2 + 16. 7. +27.4 75.0 53.5 21.5 5.0 3.6 1.4 90.l 58.3 26.l 5.7 6.0 3.9 I. 7 0.4 + 15.7 +20.l 143.2 9.6 161.4 10.8 + 18.2 +12.7 10.6 0.7 10.8 0.7 + 0.2 +l.9 147.8 9.9 151.6 10.2 + 3.8 +2.6 615.4 41.4 368.8 24.8 -246.6 -40.l 1490.0 100.0 1490.0 100.0 Public and Semi-Public Public Semi -Pub 1ic Ut i1 ities Street Rights-of-Way Railroad Rights-of-Way Water Vacant Total Source: (l} (2} February 1989 Land Use Survey by McKenna Associates, Incorporated. 1982 Master Plan for the City of Walled Lake. - 23 - �Residential Land Use The amount of land used for residential purposes increased by about 165 acres, or about 44 percent, between 1976 and 1989 (see Existing Land Use Map and Table 8). Currently, about 542 acres, or approximately 36.4 percent of the total land area is occupied by housing. ,·'! I_ _: Much of the residential development in recent years has consisted of multiple family housing. Multiple family complexes occupy over 120 acres of land, or about eight percent of the City's total land area. There are four large concentrations of multiple family development: along Pontiac Trail in the southwest corner of the City (Walled Lake Villa); at the intersection of Decker Road and Fourteen Mile Road in the southeast corner of the City (Lake Village); west of Decker Road north of the railroad (Dover Hill); and, at the intersection of S. Commerce and Decker Roads in the north end (Walnut Ridge Apartments, Hidden Meadows, and Place on the Park). The most recent large-scale single family development occurred on the east side of the City off of Decker Road, where the 98-lot Lakeland Hills Estates No. 2 subdivision was developed in the mid-1980's. Scattered single family development occurred in various locations throughout the City in recent years, such as along Pontiac Trail near the western boundary of the City, and in the vicinity of Arvida and Leon Streets near the lake. t - The predominance of multiple family construction in recent years is reflected by building permit data collected by the Southeast Michigan Council of Governments (SEMCOG). As indicated in the chart which follows, SEMCOG records for the decade between 1979 and 1988 indicate that permits for construction of 576 residential units were issued. Three-quarters of the units constructed during this period were multiple family units, and only about 19 percent were single family units. Housing Construction, 1979-1988 Units Percent Single Family Two Family Multiple Family 112 32 432 19.4% 5.6% 75.0% Total 576 100.0% The opportunity for substantial new residential development still exists in the City. The most extensive development opportunity exists on the land commonly referred to as the "Foster Farm" parcel, located west of Pontiac Trail and north of the railroad. Over 55 acres of land in this area is currently zoned for intensive multiple family development, of which approximately 52 acres are buildable. - 24 - �) ) . T - I., i •.>., l=t===.1!•••11.•W.HL:•===: 0 • 0 . ~ 4 J ., .... '.: ··7 .~: .. / VILLAOf o, WOLV(tllllNl L Alll ~ ____, ~ ~ ~ ~ ~ - l ' b!.\...\ \\ '0 WALLEO LAKE I ly ' I I i]! I CITY f',vilUl@:1 Of NOVI - ---, ■ □ SlN<li: FAMILY RESIDENTIAL ■ k?J E~~ i tv'U_TlPLE FAMILY RESIOENTIAL ::JM~ . PlBUC ~.;rz:,.·1 UTILITIES COMMERCIAL ~ ~ VACANT OFFICE SEMI-PUBLIC RAIL~OAD ~ INDUSTRIAL MAP 1 EXISTING LAND USE LAKE CITY OF WALLED MICHIGAN OAKLAND COUNTY ■ M£Kenna Associates. Incorporated Community Planning • Urban Design Farmington Hills, Michigan north scale 3001 60· 120011760 feet 1/3 mile �Large scale residential development opportunities exist in two other areas: [""' I ' l. In the center of the City, east of Pontiac Trial and south of E. West Maple Road. A plan for construction of 128 condominium units (Winwood) has already been ap~roved for 22 acres of land, but additional vacant land that is zoned for single and multiple family use exists in this part of the City. Between W. West Maple Road and Pontiac Trail in the southwest corner of the City. Vacant land in this area is zoned for single family use. The following chart indicates the amount of vacant residentially-zoned land in the City. Some of these vacant lands are occupied by wetlands. Vacant Residentially-Zoned Land Buildable Vacant Acreage Zoning Classification Vacant Acreage Single Family Multiple Family Low Density High Density Mobile Home 127.7 110.4 42.8 56.5 32.9 52.4 16.4 36.6 Commercial and Office Land Use The amount of land allocated for commercial and office use increased by about 27 acres between 1976 and 1989, an increase of about 45 percent. The 1989 land use survey revealed that about 87 acres of land are used for commercial purposes. Most of the commercial acreage -- about 72 acres -- is occupied by retail uses. Office uses occupy only about 15 acres of land. The general boundaries of the commercial district have not expanded significantly in recent years. Most of the increase in commercial acreage is a result of infill in the existing commercial district, conversion of buildings on Maple Road that were previously used by industry, and new construction on vacant lands at the edges of existing commercial districts. Most new commercial development has had the effect of solidifying E. West Maple Road's status as the center of business activity in the City. One other area where new commercial construction took p1ace in recent years was near the intersection of Pontiac Trail and S. Commerce Road. Significant loss of commercial activity was recorded in one location, at the intersection of E. West Maple Road and Pontiac Trail, were a supermarket ceased operation and was eventually torn down. - 26 - �The opportunity for new commercial development exists in various locations on the City's major thoroughfares: Commercial redevelopment is likely to eventually occur on the parcel vacated by the supermarket at the intersection of E. West Maple Road and Pontiac Trail. This is an important site in terms of the overall character and function of the City's primary commercial district. Commercial redevelopment is also likely to occur on the four-acre parcel of land located adjacent to the City Hall, which is currently occupied by a vacant, rundown commercial structure. ,. .. The opportunity for new commercial development exists on the west side of Pontiac Trail , north of the rail road, on vacant land that is zoned for commercial use. J ' The potential for development in these areas provides the opportunity to change the profile and function of the commercial district so that it better serves the needs of residents. Currently, the commercial district is heavily oriented toward service-type uses. A need exists for more community-oriented retail businesses and office uses. Industrial Land Use Industrial land uses occupy about 78 acres, or about five percent of the City's total land area, according to the 1989 land use survey. The amount of land occupied by industrial use increased by almost 17 acres between 1976 and 1989, amounting to a 27 percent increase. There are two distinct industrial districts in the City, both of located adjacent to the railroad. The east side industrial district on both sides of Decker Road. Among the industries in this area Fabricating, Hughes Manufacturing, V-Line Precision Products, Hansen C. F. Long, and Armalay Sponge Company. which are is located are S & H Marketing, The west side industrial district is located on both sides of Ladd Road and on the north side of W. West Maple Road. Among the industries in this area are Textron, Dedoes Industries, Ebinger Manufacturing, McCord Heat Transfer, Lawson Manufacturing, and American Plastic Toys. Vacant industrial-zoned land provides the opportunity for new industrial growth in the City, particularly in the center of the City on land located north of the railroad and east of Pontiac Trail. Lack of direct access to this industrial property is a key consideration, however. Properties located adjacent to the railroad are landlocked, and the only access is across commercial or residential property. A few vacant industrial-zoned parcels are located in the City's two existing industrial districts. However, wetlands occupy much of the vacant industrial - 27 - �acreage on the west side. Also, several vacant industrial parcels along W. West Maple Road and Ladd Road are partially in Commerce Township. Only a few vacant industrial parcels remain in the existing industrial district on the east side. Within the timeframe of this plan, redevelopment of existing aging industrial sites can be expected. Public and Semi-Public Uses Public and semi-public uses occupy approximately 90 acres of land, or about six percent of the City's total land area. Of this total, uses classified as "public", such as public schools, the City Hall complex, parks, and cemeteries, occupy about 58 acres. Uses classified as "semi-public", s_uch as parochial schools and churches, occupy about 26 acres. The amount of land allocated for public and semi-public uses increased by almost 16 acres between 1976 and 1989, amounting to a twenty percent increase. Rights-of-Way The continued development of vacant lands resulted in construction of new roads throughout the City. Genera 11 y, about twenty percent of the 1and area in developed urban areas is occupied by street right-of-way. The land use survey revealed that street rights-of-way now occupy about 161 acres of land, or about 10.8 percent of the City's total land area. The amount of land occupied by street rights-of-way increased by about 18 acres between 1976 and 1989, amounting to approximately a 13 percent increase. The amount of land occupied by the railroad right-of-way remained essentially unchanged since 1976. Vacant Land A decrease was recorded on only one land use category between 1976 and 1989: the vacant land category. Forty percent of the land that was vacant in 1976 had been developed upon by 1989. Currently, almost 369 acres of land remain vacant, amounting to about 25 percent of the City's total land area. About 68 acres of vacant land are occupied by wetlands, leaving about 300 acres (20.2 percent of the total land area) that can eventually be built upon. - 28 - �ECONOMIC ANALYSIS One of the p~rposes of the Master Plan is to accommodate desired economic growth that will create employment, shopping, and income-producing opportunities for residents. To achieve this objective, it is first necessary to become knowledgeable about the income and employment characteristics of residents, and to achieve a thorough understanding of business and industrial development patterns in the City. r: The growth and development of Walled Lake's commercial and industrial base is influenced by a number of factors including the City's location in the region and the extent to which this setting has affected economic development. Other factors influencing commercial and industrial development patterns include transportation systems, the availability of land, and the characteristics of the City's population, including the number of households and their income levels. This chapter of the Master Plan evaluates the commercial and industrial characteristics of the City. By offering a composite picture of the City's economy, this analysis will help identify opportunities and constraints relative to future commercial and industrial development opportunities and as such, can he 1p provide the foundation upon which a comprehensive economic development strategy can be based. Existing Commercial Facilities Most commercial facilities in Walled Lake are concentrated in seven (7) locations (see Map 2): 1) in the waterfront district along Walled Lake Drive; 2) along E. West Maple Road, from Pontiac Trail to the east City boundary; 3) along Pontiac Trail, from Northport Road to S. Commerce Road; 4) at the intersection of S. Commerce Road and Pontiac Trail; 5) at the intersection of S. Commerce Road and Decker Road; 6) a1ong Ladd Road, between W. Wa 11 ed Lake Road and Pontiac Trail; and 7) along Pontiac Trail, from Decker Road to the east City boundary. Other commercial facilities servicing Walled Lake residents are located along Pontiac Trail west of Walled Lake Villa in the City of Novi. I - ' . As reflected in Table 9, the City's commercial areas contain five (5) major types of commercial uses. · Convenience - Convenience goods are those that are consumed or used on a daily basis such as groceries, drugs and hardware items. Comparison - Comparison goods are those that are purchased less frequently than convenience goods and usually only after people have compared prices and quality of competing stores. Comparison goods include clothing, appliances, jewelry, furniture and similar items. Office - Office uses include medical, legal, financial, professional services. - 29 - and other �,......, 27 L ,-lfE 'f!A PERCENTAGE OF LOCATION/DESCRIPTION l!i1 l!I .m ~ Iii mm B ~ ~ COMMERCIAL TYPES E. WEST MAPLE ROAD CONVENIENC PONTIAC TRAIL S. COMMERCE ROAD at PONTIAC TRAIL COMPARISON S. COMMERCE ROAD at DECKER ROAD LADD ROAD PONTIAC TRAIL EAST - - - • AREAS ZONED COMMERCIAL OR OFFICE PONTIAC TRAIL WEST (CITY OF NOVI) EXISTING COMMERCIAL AREAS CITY OAKLAND ------- SERVICE OF WALLED COUNTY • MAP 2 LAKE MICHIGAN �i ,-= I Service - Service uses are commercial uses that provide a specialized or unique service, such as repair shops, hair care facilities and dry cleaners •. • Specialty Retail - Specialty retail uses offer a specific type of product or unique goods not commonly found in a majority of stores and shops. Specialty retail uses include gift shops, craft shops, art dealers, coin dealers, and antique shops. ,....,. I TABLE 9 l.: NUMBER OF COMMERCIAL USES BY TYPE I _, I Convenience i. No. _L 49 29.9 Comparison No. 18 Office i No. i 10.9 47 28.7 Service Specialty Retai 1 No. _L No. _L No. % 39 23.8 11 6. 7 164 100 Total Of the total number of commercial businesses in Walled Lake, approximately 29.9 percent are convenience uses, while 28.7 percent are office uses. A much smaller percentage of the City's businesses -- 10.9 percent -- market comparison commercial or "shopper" goods. Service and specialty retail uses represent 23.8 and 6.7 percent of all commercial uses, respectively. f • The convenience retail and office businesses in Walled Lake serve primarily the local market. In contrast, the comparison goods, service, and specialty retail businesses serve both the local and a regional market. ! I l The Walled Lake commercial sector is distinguished by a high proportion of service and specialty retail businesses, and a small number of comparison retail stores. The number of convenience and office uses is consistent with the size of the community. J A detailed review of each commercial district follows: Waterfront District - Area #1. The waterfront district is located along Walled Lake Drive at the north end of the lake. This district includes the original downtown, located at the intersection of Pontiac Trail and Walled Lake Drive. Many of the older commercial structures in the City, some of which were constructed before the turn of the century, are located in this district and are still occupied by commercial uses. Convenience commercial uses are the most prevalent types of businesses in the waterfront business district (see Table 10). Of the 26 businesses located in the waterfront district, 42.3 percent are convenience goods businesses, including gas stations, restaurants, party stores and an ice cream shop. This district also contains 5 specialty retail businesses and 5 service uses. - 31 - �Approximately 46.0 percent of all specialty retail uses in the City are located in this district (see Table 10). This district contains only a few comparison goods and office-type businesses. There is no vacant commercial zoned land in this district. r-· I I TABLE 10 ' I 'I : r-, r-· ''I TYPES OF BUSINESSES WITHIN EACH COMMERCIAL AREA Convnercial Type Area #1 Area #2 Area #3 Area #4 Convenience 42.3 23.6 25.0 41.9 Comparison 11.5 16.4 7.5 Office 7.8 32.7 Service 19.2 Specialty Retail Area #5 Area #6 Area #7 Area #8 0.0 33.3 33.3 54.5 9.7 0.0 0.0 0.0 0.0 32.5 12.9 100.0 66.7 66.7 27.3 25.5 30.0 25.8 0.0 0.0 0.0 18.2 19.2 1.8 5.0 9.7 0.0 0. 0 0.0 0.0 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% l. r. I I ' TOTAL Source: McKenna Associates Inc. Survey, July 1989 TABLE 11 LOCATION OF VARIOUS TYPES OF COMMERCIAL USES ' ' Area No. Convenience Comparison Office Service Specialty Retail 12.0% ~§@ ~ l. 1 20.0% 17.6% 2 z~u. ::-:-:~--~;:;:::»;; 4.SHl. 33;g 3 18.0 24KO. :::::»:-:.;.:,c.:..-;A. 0.0 2.0 2.0 10.0 17.0 17.0 0.0 0.0 0.0 0.0 27.5 7.8 11.8 3.9 5.9 5. 9 100.0% 100.0% 100.0% 4 5 6 7 8 TOTAL Source: ·.-.•.w:-.•.-.❖.,_,. 3.9% .......... •. • ·:.t McKenna Associates Inc . Survey , July 1989 - 32 - 2119 29.0 20.0 0.0 0.0 0.0 5.0 9.0 18.0 27.0 0.0 0.0 0.0 0.0 100. 0"/4 100.0% �n ti E. West Maple Road District - Area #2. The E. West Maple Road business district contains the greatest number of commercial uses and the greatest variety of convenience, comparison, office and service businesses in Walled Lake. This district extends from Pontiac Trail to the east City boundary, and is interspersed with some industrial and public uses. This corridor has been the focus of new commercial development in recent years, resulting in the construction' of a new strip shopping center, several fast-food restaurants, and several offices. Compared to the other commercial areas in the City, this district contains a broad range of convenience, comparison, office and service uses. Almost half of the limited number of comparison commercial uses in the City are located along this corridor. t •• I I I. I • Even though the E. West Maple commercial area is the City's most diverse business district, it does not provide the full range of goods and services needed by residents. Noticeably absent are certain comparison goods businesses, such as a department store, furniture store, appliance store, clothing store or sporting goods store. Pontiac Trail District - Area #3. Businesses in this district extend along Pontiac Trail from Northport Road to S. Commerce Road. Commercial uses in the Pontiac Trail district are concentrated on both sides of Pontiac Trail but are separated by a variety of residential, public and semi-public uses, particularly along the west side of the road. Some of the residential uses that existed along this corridor have been removed or converted to commercial or office use. Convenience, office and service businesses are predominant along Pontiac ·Trail. This businesses corridor contains the second largest number of office and service uses in the City . Several businesses along this corridor, particularly the older uses, have poor accessibility and limited parking facilities. This may discourage some City residents from shopping at some of the businesses along this corridor. The development challenge in this district will be to encourage replacement of obsolete businesses on undersized lots with, at a minimum, businesses that can serve the basic needs of surrounding residents. Gradually, the residential uses in the Pontiac Trail business corridor are giving way to more appropriate retail or office uses, and variable development standards have been replaced with upto-date standards designed to assure quality development. ' ., \. A continued orderly transition of uses is required in this district in order to improve the districts economic viability, appearance, access, parking and traffic conditions. S. Conunerce Road/Pontiac Trail District - Area #4. This district includes businesses located at the intersection of S. Commerce Road and Pontiac Trail. Although this district does not cover as much area as the E. West Maple Road or Pontiac Trail corridors, it contains the same number of convenience commercial uses as the E. West Maple Road district. The intersection of two of the City's major thoroughfares and the proximity of this district to existing single family residential development to the north and east of this area, makes it an attractive location for convenience commercial uses. - 33 - - - --- - = - - �'·•· Over 41 percent of the businesses in this area are convenience commercial uses. Most of these businesses are located in the three shopping centers at the intersection of S. Commerce Road and Pontiac·Trail. f: j J i. I I ) ' . . r: 'I I Although the S. Commerce Road/Pontiac Trail district is a center of convenience commercial activity, the district does not contain a full range of convenience goods businesses. For example, the district does not contain a supermarket or drug store. The availability of vacant land in this area provides the opportunity to change the function of this commercial district so that it better serves the needs of residents. The opportunity for new commercial development exists to the east and west of this area along Pontiac Trail and to the south, on vacant land zoned for commercial use. Extension of Commerce Road to E. West Maple Road would make additional commercial land accessible for development. Vacant land to the west along Pontiac Trail provides the opportunity for commercial development at a larger scale. S. Convnerce Road/Decker Road - Area #5. Only office uses are located in this district. These include two real estate agencies, a travel agency, a dental clinic, a medical clinic and a gynecologist. All have attractive sites with good access, adequate parking, and site landscaping. l, I I. The majority of land in this district is developed. However, there is a limited amount of vacant land along S. Commerce Road zoned for office use that is suitable for development of neighborhood and professional offices. The development challenge in this district is to continue limited office use in scale with the existing office development. · Ladd Road District - Area #6. Businesses in this district are concentrated in the shopping center plaza located along Ladd Road, north of the intersection of Pontiac Trail. This district contains three commercial uses, a supermarket/food center, a Michigan Department of Social Serv~ces office, and a medical clinic. Although the number of commercial uses is limited, the supermarket/food center facility contains a broad range of additional convenience and service commercial uses including a restaurant, pharmacy, flower shop, convenience store, video rental store, and postal service. The location of these uses under one roof provides for a complete and convenient neighborhood commercial center for residents in this part of the City. Pontiac Trail, East of Decker Road District - Area #7. This district is located along the north side of Pontiac Trail, east of the intersection of Decker Road. The businesses in this district include a gas station located on the northeast corner of the intersection, a medical clinic, and a dental clinic. A site plan for a 16,500 square foot neighborhood shopping center has been approved for the northeast corner of the Decker Road/Pontiac Trail intersection. Future commercial development in this district will depend on the demand for additional neighborhood commercial goods and services or for small freestanding office buildings. A small amount of vacant commercially-zoned land exists along Pontiac Trail which could accommodate limited new development. - 34 - �l - Commercial Development Potential Projection of commercial development potential in the City of Walled Lake is a process involving the following steps: Step 1: Delineate the potential trade area. The potential trade area includes not only the City, but also portions of surrounding communities. Step 2: Determine the trade area sales potential. Step 3: Determine local allocation of total sales. The purpose of this step is to determine what portion of potential trade area actually is or could be served by City businesses. Step 4: Convert sales potential estimates into floor area requirements. p I I I i ., ,·. II l Step 5: Convert floor area estimates into land area requirements. Delineation of Trade Area. The first step in projecting the potential for future development involves delineation of the potential trade area from which customers are most likely to be drawn to Walled lake businesses. Distance is the most important determinant of trade area, since most people will generally travel to the nearest businesses that serve their needs. Other factors that affect trade area include travel times, quality, service, variety of merchandise, accessibility, and socioeconomic differences between neighborhoods or communities. The trade area for convenience goods is generally limited to the residential areas immediately surrounding the business districts. People generally will not travel great distances for groceries, drugs and other convenience goods that they purchase frequently. In built-up areas such as the City of Walled Lake, the trade area radius for convenience goods generally ranges from 4 to 8 blocks. However, because of the location of commercial districts, some residents of Walled lake must travel up 3/4 to one mile for convenience goods stores. l • t I • Comparison purchases are made relatively infrequently, and usually involve comparisons on the basis of quality, service, price, and variety of selection. Hence, people will travel great distances to make comparison goods purchases. In urban areas, the primary trade area for comparison goods ranges from 10 blocks for a clothing purchase to 3 miles for a department store purchase. Because of the limited number of comparison goods businesses within Walled Lake and the lack of a major department store, clothing store, furniture store and other comparison commercial uses,. the primary trade area for comparison goods could encompass an area within 25 to 30 minutes driving distance. This would include all of Commerce Township plus portions of all the surrounding communities including the City of Novi, which is the location of a number of comparison goods businesses including a major regional shopping mall complex. The secondary trade area for comparison goods could encompass an area within 60 minutes driving distance, which includes the remaining portions of the surrounding communities. - 35 - I -- - - -- �n I 1 I The trade are for service businesses is similar to the trade are for businesses that market comparison goods. In fact, residential growth in surrounding communities provides the best opportunity for expansion or new development of service businesses in Walled lake. Trade Area Sales Potential. Trade area sales potential is calculated using projections of change in the number of households, household income data, and data concerning household expenditure patterns. I' j ' ( ' j ' - I: I I; Retail sales are closely related to the number of households in a trade area. In the potential trade area for Walled lake, there were 18,250 households in 1980. According to SEMCOG projections, the number of households will increase to 30,613 by the year 2005, a 67.7 percent increase {see Table 12). Western Oakland County is a high-growth area and it is expected that the City of Walled Lake and surrounding communities will experience steady growth in the number of households. The new development is expected to be in the lake areas, near major transportation corridors, or on the outer fringes of existing suburban development. The population of the potential trade area is also expected to increase, from 51,180 to 73,804, a 44.2 percent increase. While number of households is useful for predicting retail sales and demand for certain services, total population is useful for projecting the need for certain professional services, such as doctors or dentists. TABLE 12 PROJECTED GROWTH WITHIN THE POTENTIAL TRADE AREA Population 1980 2005 City of Walled lake City of Novi Commerce Township Village of Wolverine lake TOTAL 4,748 22,675 18,789 4,968 51,180 5,975 38,092 24,731 5,006 1,806 8,705 6,163 1,576 2,555 16,472 9,626 1,960 73,804 18,250 (+67.7%) 30,613 (+44.2%) Source: I-• Households 1980 2005 1980 figures are based on U.S. Census data. 2005 figures are based on projections made by the Southeast Michigan Council of Governments {SEMCOG). Income estimates for communities in the trade area are set forth in Table 13. These estimates are expressed in 1985 dollars, based on 1985 U.S. Census figures and SEMCOG Household Data. Table 13 indicates that total annual household income will increase from an estimated $956 million in 1985 to $1.4 billion in 2005, an increase of 51.3 percent. - 36 - �n l ·' f7 ! 1 Data collected by the U.S. Census indicates that about 39 percent of all personal income is spent on retail goods, with about 10 percent spent on durable goods and about 29 percent on nondurable and convenience goods. Another 39 percent of personal income is spent on services, including medical care, auto repair, beauty or ba.rber services, and other personal, professional, and repair services. Local Allocation of Total Sales. From review of the types and variety of businesses in Walled Lake, it appears that residents are only able to make a portion of their purchases in the City. Residents of the trade area may take their business outside of the City for a number of reasons, including convenience, accessibility, price, quality, or variety of selection. The "capture rate" indicates the portion of total trade area sales actually captured by Walled Lake businesses. TABLE 13 PROJECTED GROWTH IN HOUSEHOLD INCOME WITHIN THE POTENTIAL TRADE AREA 1985 i I . City of Walled Lake City of Novi Commerce Township Village of Wolverine Lake TOTAL $ $ $ $ 60,066,243 462,763,587 351,577,212 81,101,502 $ 955,508,544 2005 $ $ $ $ 75,119,555 750,777,288 523,153,848 96,867,120 $ 1,445,917,811 (+51.3%) Source: I ' 1985 Figures are based U. S. Census Data. 2005 figures are based on projections made by the Southeast Michigan Council of Governments. The most reliable method of determining capture rate is to complete a shopper survey. In the absence of such a survey, the capture rate must be estimated by analyzing the specific types of businesses in the community and the competing businesses and commercia·l districts in surrounding communities. The capture rate for convenience goods businesses is usually close to 100 percent in neighborhoods near the businesses, but the rate declines sharply at a driving distance of only 10 to 15 minutes from the businesses. It is estimated that 90 percent of the convenience goods market within the City is captured by City businesses, with about 10 percent going to businesses in Novi, Wolverine Lake and Commerce Township. Alternately, it is estimated that Walled Lake businesses capture a portion ( up to ten percent) of the convenience goods market from surrounding communities. Convenience goods businesses derive additional market support from the volume of through traffic on Pontiac Trail and other thoroughfares. - 37 - �r; [ r....-.. l i ( ..' The capture rate for comparison goods businesses in the City is estimated to be only about 15 percent. Walled Lake contains only a few comparison goods businesses; these businesses do not provide sufficient variety to permit comparison of major purchase items. Consequently, it is estimated 85 percent of the compari9on market is captured by shopping districts or centers in surrounding communities, particularly Novi and Farmington Hills. A few Walled Lake comparison goods businesses draw market support from outside of the City. These businesses include a lumber company, boat sales, floor covering store, plant nursery, auto dealer, and hardware store. It is estimated that between 5 and 10 percent of the comparison goods market in surrounding communities is captured by Walled Lake businesses. .. ' Figures presented earlier revealed that services are an important part of the City's economic base, accounting for almost one quarter of all businesses. Service businesses in Walled Lake include repair services, heating and cooling installation, printing, furniture refinishing, landscaping installation and maintenance, and personal services. The capture rate for service businesses is not nearly as limited as for convenience and comparison retail businesses for two reasons: 1) The market for service businesses is expanding because of residential growth in surrounding communities, and 2) The amount of land allocated for use by certain types of service businesses in surrounding communities is severely limited. In short, the opportunity exists for Walled Lake businesses to capture a substantially greater proportion of the service market in surrounding communities. Based on the capture rates and househo 1d income figures cited earlier, the current and future potential retail sales volume in Walled Lake is estimated as follows: Potential Retail Sales Volume $51,500,567 $77,920,358 1985 2005 These estimates represent the market for retail goods only. Based on a conservative estimate, these figures should be increased by at least 30 percent to reflect the potential sales of service and specialty retail businesses. Thus, the total potential sales volume in 1985 is $66.9 million, increasing to $101.3 mill ion by 2005. Retail Floor Area Requirements. Retail floor area requirements can be determined by dividing the sales volume estimates calculated above by sales per square foot information for existing businesses. The Urban Land Institute provides information concerning sales per foot in its annual publication Dollars and Cents of Shopping Centers. In community shopping centers, the median sales volume per . square foot of gross leasable area ranges from under $60 for certain low sales volume businesses, such as laundries, arcades, cinemas, and bowling alleys, to over $200 per square foot for high sales volume tenants, such as supermarkets, jewelry stores, and liquor and wine shops. The average sales per square foot is $125.00 for comparison goods businesses and $225.00 for convenience goods - 38 - �businesses. Based on these averages of sales per square foot, the total retail floor area needed to serve the potent i a1 Wa 11 ed Lake market is estimated as follows: 1985: 263,933 square feet 2005: 399,330 square feet ,. i . These figures should also be increased to reflect the existing and continued presence of service and specialty retail businesses in Walled Lake. Based on the 30 percent figure used earlier, the total floor area needs are estimated at about 343,000 square feet in 1985, increasing to about 519,000 square feet in 2005. Office Floor Area Requirements. Office space requirements for professionals who provide services directly to residents are based on the average number of office workers or office professionals that can serve a population of a given size. Finance, insurance, and real estate operations typically provide one office worker per 63 people with an average of 160 square feet of office space per worker. Medical and dental standards call for one physician per 565 people and one dentist per 1,778 people with an average office size of 1,300 square feet. Legal office standards call for one attorney per 473 people with an average of 800 square feet of office space per attorney. Mi see 11 aneous office services include engineers, architects, bookkeeping services, business education, and similar services. Typically, two square feet of miscellaneous office space are provided per person in the service area. These office space requirements do not take into account the needs of corporations or businesses where office workers do not provide a direct service to residents. Office needs related to operation of a corporation or business are included in the industrial base analysis which follows. Based on these standards, office space needs in Walled Lake are estimated as follows: 1985 2005 Finance, insurance, and real estate 26,916 sq. ft. 32,401 sq. ft. Medical, dent a1 32,134 38,683 Legal 17,925 21,578 Miscellaneous office services 21,196 25,516 Total 98,171 sq.ft. 118,178 sq. ft. These office floor area estimates include portions of the surrounding communities within the assumed service area. Consequently, the estimates are based on a service area population of 10,598 in 1985 and 12,758 in 2005. These estimates of office space needs do not reflect the potential demand created by the district court. A court building generates the need for various legal services, which often require nearby office space. - 39 - �l , .J r:.... I·.., Land Area Requirements for Retail and Office Development. A general standard for shopping centers is that the total site area should be about four times the gross building floor area. This floor area ratio would provide room for parking, open space, pedestrian and traffic circulation, and landscaping. Walled Lake's Zoning Ordinance does not contain maximum lot coverage standards for commercial development. Instead permitted lot coverage is based on compliance with other site and building standards. In practice, developments are usually provided with a larger site area than is required by the zoning ordinance. Certain high intensity uses, such as convenience stores, medical offices, and beauty shops require more parking and consequently more site area, than the average commercial uses. Consequently, for the purposes of computing a conservative estimate of retail land area needs, a reasonable floor area standard would be 6 to 1. __ Based on this floor area ratio, the total land area needs for retail and office uses are estimated as follows: Total 1985 2005 I L 49.9 acres 75.5 acres I ' These figures should be increased to account for service and specialty retail businesses in Walled Lake. Based on the 30 percent figure used earlier, the total land area needs are estimated at about 65 acres in 1985, increasing to about 98 acres in 2005. Currently, 87.2 acres of land are occupied by commercial and office uses in Walled Lake. Another 75.5 acres are vacant but zoned for commercial or office use. Thus, the existing commercially-zoned land should provide adequate area for the commercial development needs of the City through the year 2005. The excess commercially-zoned acreage provides alternative locations to meet the specific site requirements of new development. I. Sunvnary. This analysis revealed that the convenience goods market is particularly well-served by existing businesses in Walled Lake. The convenience goods businesses serve the local market, portions of surrounding communities, and through traffic on Pontiac Trail and E. West Maple Road. Opportunities still exist to fill certain niches in the convenience goods market. The Planning Commission identified the following business needs: a variety store, apparel stores, shoe stores, and mini-department store. ' . I ' This analysis further indicated that Walled Lake contains a reasonable number of office uses for a community of its size. Opportunities for new office development exist to provide higher quality office space for the professionals who serve Walled Lake residents. The presence of the district court presents additional office opportunities which developers have not yet acted upon. The Planning Commission also identified the need for more banks or financial institutions in the City. Several attractive sites are zoned for office use along Pontiac Trail, east of Commerce Road. - 40 - �,7 ' ; -· I . : . i ' -· I \. L Residents are clearly under-served by existing businesses in the comparison goods market. Few Walled Lake businesses sell "durable goods", such as furniture and appliances. The opportunity to address this deficiency with new development in Walled Lake is limited for two reasons: 1) Households in Walled Lake provide insufficient market support for many types of comparison goods businesses, and 2) Existing commercial districts in surrounding communities would provide strong competition for new comparison goods businesses in Walled Lake. The analysis revealed that Walled Lake's commercial sector is particularly strong in two areas: services and specialty goods. The presence of a large number of specialty goods businesses is associated with the lake environment and the historic downtown. An increase in the number of specialty goods businesses in the waterfront district may occur, but the market niche served by the waterfront district must first become better-defined. Also, certain functional problems must be resolved, particularly the parking deficiency, before any significant growth can occur in the waterfront district. The service sector represents a cl ear-cut opportunity for substantial new business development in Walled Lake. The analysis revealed that Walled Lake service businesses, such as repair and installation services, already serve residents in surrounding communities. The market base for service businesses is expanding continuously because of non-stop residential growth in these communities. Unlike the comparison goods market, surrounding communities have not made an effort t ,o deve 1op a strong service sector to compete with existing and future Walled Lake businesses. The viability of the commercial sector is not just related to the total number of each type of business. Of equal importance is the location of competing and complementary businesses, the appearance of the businesses, convenience of access, and similar issues. The existing commercial district does not function as well as it could. Retail businesses on Pontiac Trail or E. West Maple Road that would benefit from being located near each other are separated by unrelated residential, industrial, or service uses. In many instances, vehicular access and parking is poorly defined and pedestrian access is nonexistent. There is a need to bring together complementary business uses into planned shopping centers or districts. Redevelopment of a few old obsolete commercial buildings and sites is also needed. Existing Industrial Facilities An objective of the Master Plan is to provide for development that will generate emp 1oyment and strengthen the tax base. A balanced approach to meeting this objective includes industrial development, as well as commercial and office development. A regional perspective is required to determine the potential for industrial growth. Present-day standards for industrial development are very selective, calling for large amounts of land area, immediate access to highways and rail, - 41 - �I. availability of utilities, and other criteria. These rigorous standards limit the locations that could be considered appropriate for new industrial development. Consequently, new industrial development tends to be concentrated in just a few communities which serve the industrial needs of the entire region. According tb the 1989 land use survey, 78 acres or about five percent of the total City land area is occupied by industrial uses. As indicated on Map 3, most industries in Walled Lake are concentrated in two distinct industrial districts located adjacent to the railroad. r. i I._ East Industrial District. This district includes industrial uses on the east and west sides of Decker road, both north and south of the railroad. Approximately sixty percent of the industries in this district are of a light industrial nature and the remainder would be classified as heavy industrial. Among the industries in this area are the following: - I.., I {._ Armalay Sponge Company Hansen Marketing Hughes Manufacturing S & H Fabricating Wolverine Foundry Supply Company Leeman Oil Company Distribution Center Fastdecks Incorporated Davis Iron Works V-Line Precision Products C.F. Long & Sons Fisher Fuels It appears that this industrial district is older than the district on the west. Buildings show signs of wear and deterioration. Many of the sites do not comply with modern industrial design standards, which call for ample loading/unloading space, abundant landscaping, and so forth. A substantial amount of industrially-zoned vacant land exists in this district, along the railroad, west of the existing industrial development and south of the railroad, east of Decker Road. This vacant land provides the opportunity for new industrial growth. The challenge in this district will be to encourage development of new industries, particularly in the center of the City west of the existing industrial development and to encourage the redevelopment of existing aging industrial sites. However, lack of direct access to the vacant industrial-zoned property is a key consideration with regard to future industrial development. The extension of S. Commerce Road would provide access to this area. West Industrial District. This district is located on the east and west sides of Ladd Road north of W. West Maple Road. The industries in this district are light industrial uses and include: - Dedoes Industries - Ebinger Manufacturing - Steinberg Sales J & B Meter and Pump Service - 42 - �i ' r. AREA □ ■ ■ LOCATION/DESCRIPTION EAST AREA- DECKER ROAD WEST AREA- LADD & WEST MAPLE INDIVIDUAL INDUSTRIAL SITE LOCATION AREAS ZONED 1-1 LIMITED INDUSTRIAL DISTRICT EXISTING INDUSTRIAL AREAS CITY OAKLAND OF MAP 3 WALLED COUNTY ■ LAKE MICHIGAN r;, "·t::1 �n ' LJ - Digital Devices Incorporated American Plastic Toys Incorporated - Textron - Dedtru Grinding Incorporated - Lawsons Manufacturing McGord Heat Transfer - Nu-Way Supply Company - Pure-Pak, Inc. Most of the industrial uses in this district have limited outside storage, good access, and basically well maintained properties. Almost all of the industrially -zoned land in this district is developed with the exception of a few small vacant parcels along the railroad and along W. West Maple Road. The planning challenge in this district will be to engage in cooperative efforts with Commerce Township to facilitate expansion of existing industries and development of new facilities, to upgrade public facilities such as sewer, water, and roads, and to maintain the quality of existing industrial development. The proposed extension of Maple Road is currently planned to bisect this district and may result in redevelopment of some industrial sites. L r. Individual Industrial Site Locations. Within the City there are also a number of individual industrial site locations. These industries are located outside of the two primary industrial districts in Walled Lake on land currently zoned for commercial use. Individual industrial uses include Husky Envelope and Fisher Fuels Distribution Center located on E. West Maple Road, Erin Industries located on Pontiac Trail, and Specialty Cabinet and Furniture Manufacturing on Market Street. Industrial Development Potential I I i'\ I .I C Industrial developers cite five major considerations which determine suitable industrial locations: transportation, labor supply, energy and other utilities, availability of land, and public policy. Additional considerations that are relevant when selecting a specific site include topography and soil conditions, the direction and composition of population growth, and the types of industries that are expanding or moving into the area. The following analysis reveals that, when measured in terms of these considerations, certain portions of the City are suitable for certain types of industrial development . Access to Transportation. The primary industrial location determinant is convenient access to freeway transportation. Over three-quarters of all land developed for industry is within 2.5 miles of an interstate freeway interchange. A freeway location provides industries with substantial transportation savings, an expanded labor market, and an expanded market area. Direct and convenient access is not an asset that can be claimed by Walled Lake's industrial district. The nearest freeway which serves Walled Lake is 1-96, an east-west corridor, located 3 to 4 miles south of the City. Interchanges with 1-96 are located at Wixom Road, Beck Road, Novi Road, and at Grand River and 1275. 1-275 is a major north-south highway that connects 1-96 with 1-94, the state's most important industrial corridor. The planned Haggerty Road Connector, - 44 - �located east of the City boundary, will provide additional freeway access for the Walled Lake area and should help to improve the transportation system for City industries. The City is also served by the Coe Railroad. Most of Walled Lake's initial industrial growth occurred along the railroad, although existing industries are no longer dependent on the railroad for transportation. Wayne County Metropolitan Airport located in the City of Romulus and Willow Run Airport located in Van Buren Township are the nearest airports served by major carriers. These two airports are located on I-94 within two miles of I-275. Oakland-Pontiac Airport is the nearest airport. Although it is a tower-controlled public use airport, it is not served by major carriers. I - l. I I L_ i I '-· I • Although the existing transportation system appears to be adequate to serve the needs of existing industries, it is not the City's most important industrial location asset. The transportation system must be improved to attract new industrial development. Labor Supply. The availability of a trained labor force is an important need that is adequately met in Walled Lake. Over the years, employees have relocated in Walled Lake and nearby communities to live near the industries where they work. According to the 1980 Census, the City's labor force numbered 2,432 of which 702 were in manufacturing. Although the labor supply exceeds total employment in the City, the number of residents employed in manufacturing is less than the number of employment positions available in City-based manufacturing plants. The City's labor supply, will continue to grow somewhat as more people move into the City in future years. Energy and Utilities. Industry requires a reliable supply of energy and adequate utility services, including water supply and sanitary sewerage. The City receives electrical service from Detroit Edison. In the past, these energy services have been provided adequately without serious or prolonged interruption. Public water and sanitary sewer lines exist throughout the community and appear to adequately serve the needs of existing industry, although there currently is a moratorium on new sewer taps. A new sanitary sewer treatment pl ant currently under construction will provide additional capacity upon completion within two years. Availability of Land. The need for large amounts of land, both for the initial construction and for later expansion, has been one of the key reasons that industries have moved out of cities. Limited land area has been one of the most severe constraints faces· by existing industries that have proposed expansion in Wa 11 ed Lake. Walled Lake currently has 43.1 acres of vacant industrial-zoned land. Approximately one-third of that land is located in the west area industrial district on property owned by Textron, much of which is occupied by wetlands. Most of the remaining two-thirds is located in the center of the City, north of the railroad . Wetlands are only located on a small portion of this land, so that with proper storm water management , adequate drainage can be attained. However, accessibility problems to this area will have to be resolved prior to future industrial development. - 45 - �r I - l l@ r~-, ',_,; rr, i Public Policies. Research in recent years has documented the relationship between public policies and the ability to successfully operate a business or industry. Public policies with the greatest impact on industry in Walled Lake are reflected in adopted planning and zoning standards. Review of these documents reveals that the City ha.s made an effort to accommodate industrial growth. The City has retained several acres of vacant land in the center of the City to accommodate future industrial growth. Furthermore, the City has worked with existing industries to facilitate expansion plans, even where it was necessary to resolve zoning nonconformities. The preceding analysis revealed that conditions in Walled Lake are not conducive for large scale industrial growth, although the City can accommodate limited 1ight industrial development. There are two key constraints to industrial growth: 1. There is little vacant industrial land remaining in the City. Land assembly would be required, since much of the remaining land is divided into small parcels. Wetlands occupy some of the vacant industrial land. l. I ' . 2. The transportation system serving the industrial area is inadequate. The industrial district does not have convenient access to freeways, and severe congestion exists on surface roads, particularly during peak periods. Notwithstanding these constraints, the potential for new industrial development or expansion of existing industries does exist. To counterbalance its 1iabil ities, the City offers a central location within the fastest growing county in the state, proximity to attractive neighborhoods and residential communities, attractive industrial sites which are located near to other commercial services (unlike many newer isolated industrial parks), adequate public utilities, and receptive public officials. Industries that would benefit most from Walled Lake's assets include small manufacturing, design or fabricating shops, or research or administrative facilities. In contrast, heavy manufacturing concerns or industries that require frequent truck shipments would be inappropriate in Walled Lake. I l .• Fiscal Impact of Economic Growth t . Property values provide one of the best measures of economic growth. Oakland County has been heralded as the county that has led the economic revitalization of Michigan in the 1980's. Table 14 reveals that economic growth in the last five years produced a 52.7 percent increase in property values in the county. Walled Lake nearly kept pace with the county, with a 46.4 percent increase in property values over the five year period. The surrounding communities of Commerce Township and Novi produced more substantial increases, the result of development of vast amounts of previously vacant land. Table 15 and Figure 3 provide a more detailed look at property value trends in the City of Walled Lake. Figure 3 reveals that growth in State Equalized Value - 46 - �r--: - -7 7 rr-·\. ~ J .,-- ,l el -.. ~J TABLE 14 PROPERTY VALUE HISTORY1 WALLED LAKE AND NEIGHBORING COMMUNITIES % Change ___1985 -- _ ___1986 City of Novi s s Coomerce Township2 $ s s s Oakland County $15 , 319,946,55'2 COOIIUlfil __ City of ~alled Lake 60,853,700 478,852,000 311,742,450 1987 519,393,700 s s 377,576,800 $ 63,078,400 S16,513,811,361 _1982 1988 593,307,950 s s 401,728,700 $ 68,889,500 $18,372,321,924 1985-1989 82,529,350 s 89,059,700 +46.4 759,338,200 $ 909,829,100 +90.0 434,869,850 $ 532,525,100 +70.8 S23, 395,403, 757 +52.7 S20,834,957,169 1 Total State Equalized Value, Real and Personal Property 2 Includes Village of Wolverine Lake. TABLE 15 ~ -...J VALUE OF CLASSES OF PROPERTY1 X Ch~e Land...!!filL_ 198_1-1989 1981 1982 1983 1984 1985 1986 1987 1988 1989 Coomercfal S13,687,800 $12,378,700 $12,048,500 $12,494,100 $12,966,500 S13,044,000 S13,575,800 S15,016,300 $16,215,700 +18.5 Industrial S 4,388,700 S 4,761,400 S 4,951,900 S 5,286,500 S 6,056,700 S 6,045,900 S 6,088,000 $6,262,700 S 6,368,600 +45.1 Residential $25,302,900 $29,636,750 $30,857,700 S40,698,700 $51,420,800 $56,229,300 +122.2 s 272,800 s $ 95,300 S33,988,000 $ 95,300 S35,897,9QO Developmental $27,515,400 $ 90,600 s s s $ TOTAL $43,652,200 $44,746,100 $46,732,450 S48,n1,600 $53,106,500 $55,083,100 1 95,300 State Equalized Value, Real Property Source: Oakland County Equalization Division 95,300 94,700 S60,457,200 99,800 sn,799,600 99,500 +63.5 $78,913,100 +80.0 --, �---------- ---, • ··--- r··---, ' ' -·-, - -- l --~] ~ -·1 100 -. 90 - 70 0 0 0 0 0 0 fh w :::> 80 ~ A 60 _J 1 - ~ ~....,,:._.:.:::::::l < > +:>, 00 C 50 w N _J < ::, 0 w 40 30 20 TOTAL EQUALIZED VALUE r·:: : :·:·: : : : 1!~~li -- - ·- ,• : EQUALIZED VALUE·RESIDENTIAL REAL PROPERTY 1 :-·:: L>.:ti : :,:r:r~,::::;; :;1;::;::!:t:: ::::m<4 Ilt:i;;::;;; ' 1:1:: :: : 1:11: ::: :::::1 :!:!;::::: :::;;;1i\iHi1ll!l!!H!Hil!l!!ii!!I <•..·*.•••· . I B l!ll l !l l!l !l l l ll !l!l l l l l!l l!l ll!l!l l!l l l l!l!l!l!l ll l!l l!l!l!l!!!l!l!l !lll l!l!l!l!l!l l l l!l ll l l!l l l l l!l l!l l!i'! :i::j :::::;!:::;::: :::;::::::::::: ;::;:;;::;:;::: ;:;~;;:;:::::::; ::::;::;;:;;;:; § : ::: EauArzED VALUE-COMMERCIAL REAL PROPERTY 10 ::;:;:;:;::::::::::~::: :::1:1:1::;1;:;;;;;;;; ;;;;~;;;;;;;;:;:;:;;;;; ;;;;;;;;:;:;:;:;:;:;:n :;:;:;:;:;;;:;:;:;:;: ;;;;;;;;;;;;;;;;;;;;;;; ;;;;;;;;;;;;;;;;;;;;;;; ;;;;;;;;1;;;;;;;;;;;;; EQUA,IZED VALU E•INDUSTRIAL REAL PROPERTY 0 1981 1982 1983 1984 1985 1986 1987 1988 1989 Figure 3 ' PROPERTY VALUE HISTORY . CITY OF WALLED LAKE Source: Oakland County Equalization Divis ion �1.• parallels the increase in years. The slopes of the real property are al most commercial and industrial the value of residential property over the past nine lines depicting total equalized value and residential i dent i cal . On the other hand, the lines depicting real property are nearly level. In 1989, residential property accounted for about 63 percent of the total value of property in the City (see Table 16). Commercial real property accounted for about 26 percent, and industrial and utility property accounted for 10.8 percent of total SEV. In terms of land value per acre, commercial land is by far the most valuable, $142,174 per acre. Industrial and residential properties are almost equal at over $69,000 per acre. ( . L TABLE 16 r I VALUE OF CLASSES OF PROPERTY (1989) '' TOTAL SEV $23,145,900 26.0% 162.8 $142,174 Industrial Utilities 9,585,000 10.8% 137. 9 69,507 Residential 56,229,300 63.1% 804.5 69,893 Total 89,059,700 iI l ' ACREAGE AVERAGE (Vacant & SEV PER Developed) ACRE PERCENT OF TOTAL SEV Commercial & Source: Oakland County Equalization Division Land Use Survey by McKenna Associates, Inc. (1989) ' l ' - '. In summary, increases in residential land values accounted for most of the growth in SEV in Walled lake during the past decade. Accordingly, the residential sector was the primary source of increased property tax revenues which were used to maintain or increase public services during the past several years. In order to maintain the level of public services over the long term, increases in the value of commercial and industrial properties will be necessary during the next two decades. - 49 - J . -~-iiiiiiiiiiiiii~~iiiiii.ii.-;;;;;;;;;;;;;.~===:==~--=======---..:: �r . I, l p r I TRAFFIC AND TRANSPORTATION STUDY: INVENTORY AND ASSESSMENT OF EXISTING CONDITIONS n Introduction l, r, i Traffic and transportation are vital concerns of the City of Walled Lake. The ability to move goods and people throughout the City is necessary to assure the continued viability of the business district. People's perceptions of a City are affected by their ability to travel on its roads and highways. Traffic congestion, accidents, noise and air pollution created by traffic affect the City's image and have a direct impact on the economic health and quality of life in the City. Transportation improvements required to accommodate future traffic levels can be determined through appropriate land use and transportation planning. Based on factors such as projected changes in land use and trends in traffic patterns in the City and surrounding regions it is possible to forecast traffic volumes over the next two decades. Such information allows the City and other agencies to take appropriate actions, such as road construction or widening, or other measures to meet the transportation requirements of the future. I I I l - 'I i L~ I • il . The first step in transportation planning involves the analysis of the existing system of roads and patterns of traffic. This includes undertaking a field reconnaissance to determine existing roadway conditions, determining historical and existing traffic volumes, reviewing traffic accidents, analyzing intersection capacity and levels of service and developing a list of problem areas. The second step involves determining the effect of currently committed highway projects in the region on the traffic in Walled Lake. This includes collecting and compiling information about such projects and assessing their impacts on the traffic in City of Walled Lake. The next step includes the development of an initial list of roadway improvements based on the list of existing traffic problems. Traffic impacts of each are then evaluated in light of projected population growth and proposed land use in the City and surrounding areas. This report documents the first two steps in this process, i.e., the inventory and assessment of present conditions and the compilation and assessment of currently committed highway improvements in the area. ; ( - Existing Road Conditions Information about the existing conditions on the identify physical and institutional parameter which future transportation recommendations. Accordingly, of the existing conditions on each major roadway in - 50 - City's roadways helps to affect the feasibility of the following descriptors the City were compiled: �I : L_. t • - Roadway Designation Number of Traffic Lanes Pavement Widths Speed Limit Roadway Alignment and Geometry Adjacent Land Use Roadway Jurisdiction Right-of-way (existing and planned) This section describes the major roadways in the City of Walled Lake. Table 17 summarizes these parameters for the roadways. Decker Road - Decker Road is a two-lane arterial which provides a north/south route along the eastern border of the City. The City of Walled Lake has jurisdiction over Decker Road. The land use abutting Decker is in part residential. The alignment and geometry of Decker are for the most part straight and flat except at the northern end of Decker where it curves sharply before intersecting with South Commerce Road. South Commerce Road - South Commerce Road is a two-lane road under the jurisdiction of the Oakland County Road Commission. The east half of the road is located in the City and the west half is in Commerce Township. South Commerce changes direction several times, and has some sharp curves near Wolverine Lake. South Commerce serves both residential and commercial land uses. Ladd Road - Ladd Road is a two-lane road under the jurisdiction of the City of Walled Lake. Located at the western boundary of the City, Ladd provides a south/north connection between Pontiac Trail and Wolverine Lake. It eventually connects with Benstein Road and other roads which meander northward between the lakes to connect with M-59. Ladd Road is a collector with a straight alignment in flat terrain. E. West Maple - E. West Map 1e ,. east of Pontiac Trail is a County road which provides a west/east connection from the City of Walled Lake eastward. E. West Maple is a part of a major west/east arterial in the northern suburban area of Detroit, running from Kensington Metro Park in the west to St. Clair Shores in the east. The only physical discontinuity of this arterial is in the City of Wa 11 ed Lake. E. West Map 1e within the City 1i mits is a three- 1ane arterial located in a commercial W. West Maple - W. West Maple, west of Ladd is a two-lane City road which provides a westward connection from the City of Walled Lake to Kensington Metro Park. Only a small portion of W. West Maple is within the City. A larger portion of W. West Maple is in the City of Wixom and in Milford Township. The alignment is straight on a flat terrain. The existing right-of-way is 66 feet. Walled Lake - Walled Lake is a narrow curvilinear two-lane road on a 40 to 66 foot right-of-way, running along the northeastern shore of Walled Lake, and then westward to intersect with Ladd Road. Walled Lake, a City roadway, is the narrowest arterial in the area. It has a pavement width of only 20 feet. Walled - 51 - �., , .J ' .. ) I --.--- ... ' J t)I TABLE 17 EXISTING ROAD CONDITIONS ROADWAY n v DESIGNATION NUMBER OF LANES ROADWAY WIDTH SPEED LIMIT ROADWAY GEOMETRY ABUTTING LAND USE JURISDICTION Decker Arterial 2 22' 35 Straight Flat Residential City S. Commerce Arterial 2 22' 25-40 Some Changes In Direction Flat Residential Commercial County Ladd Collector 2 20' 35 Straight Flat Light Industrial City W. Maple {east part) Arterial 3 33' 35 Straight FJat Commercial County W. Maple {west part) Arterial 2 22' 25 Straight Flat Residential Undeveloped City Walled Lake Arterial 2 20' 25 Curvilinear Flat Residential City Recreational Pontiac Trail Arterial 2-4 22'-44' 30 Some Changes In Direction Flat Residential Commercial Sources: AAPA Field Study * Based on Zoning Ordinances of Walled Lake ** From Master Plan Right-of-way Plan of Oakland County County ROW WIDTH. . 66' 66-120' 66' 66-120' PLANNED ROW WIDTH 86'* 120'** 120'* 120'** 66' 86' 40' -60' 86'* 50-120' 120'** �.' I),--,- . :' 17 ' . r • l I l • !'-.. :l ' l, Lake abuts resident i a1 , rec re at i ona 1, and commerc i a1 1and uses. Much of the east/west movement along the southern edge of the City, between 14 Mile Road in the east and Pontiac Trail in the west moves along this narrow road, which is crossed by pedestrians and vehicles for recreational activities at the lake. Pontiac Trail - Pontiac Trail is the major and the most heavily used arterial in the City of Walled Lake. It carries the bulk of the through-traffic from north to south during the a.m. peak period and from south to north during the p.m. peak period. Traffic is heavy during the peak periods and tends to "backup" for several blocks. Pontiac Trail is a County road, running diagonally in the City from the southwest to the northeast corners. It is an old route through Oakland County which due to the County's growth now carries heavy volumes of through-traffic. In the City of Walled Lake, Pontiac Trail runs through both commercial and residential districts. The numbers of lanes on Pontiac Trail varies from 2 to 4 within the City. The pavement width changes from 22 to 44 feet and the right-of-way varies from 50 to 120 feet. Because Pontiac Trail runs diagonally, none of its intersections with the west/east arterials are at 90 degree angles, the preferred geometric-design configuration for intersections. Local Streets - A common characteristic of the local streets in the residential deve 1opments of Wa 11 ed Lake is the 1ack of connecting routes between the developments. Typically, there is only one, sometimes two access points from the development onto a major arterial. Thus, local vehicle trips within the City must use the major arterial roads to get from one point within the City to another. Existing Intersection Conditions A field reconnaissance was made to determine the conditions of the intersections in the study area. Intersection types are denoted by the number of legs and angles. For example, a "T" intersection is a three-legged, right angle intersection. "Y" denotes a three legged, non-right angle intersection and "X" denotes a four-legged intersection of any angle. The intersection type is a physical parameter which affects the feasibility of future recommendations. The type of traffic control, signal phasing 1 , and the number of turn lanes and approach 1anes affect the capacity of an intersection and can be re 1at i ve ly easily modified, if necessary. The following characteristics have been verified and noted: - Type of Intersection - T, X, or Y - Type of Traffic Control - Stop Sign or Signal - Signal Phasing (where applicable) - 2 or 3 Phase Turn Lanes and Intersection Approach Lanes Table 18 summarizes these characteristics for all intersections between arterials, and between arterials and collectors in the study area. 1 A signal cycle is divided into phases. Each phase accommodates a specific movement of traffic. Two phases are the minimum for a regular traffic signal, allowing traffic to flow along one street while stopping the cross street traffic. - 53 - �- ...._.. - l l - r ~--- -~ t))) J -·-- • _j - -- -- -- ... -·-, ., • .. ' J ~ - l TABLE 18 EXISTING INTERSECTIONS INTERSECTION TYPE JRAFEIC CONJROL TRAFFIC PHASING TURN LANES Signal 2 Phase Left-WB, NB Right-EB Left-EB,NB Right-WB Left-EB Right-WB,SB,NB Left-WB,SB Right-WB,NB Left-EB, SB Right-WB Left-NB,SB,EB,WB Right-EB APPROACH LANES NORTH/SOUTH EAST/WEST Pontiac Trail West Road y Ladd Road T Signal 2 Phase Wa 11 ed Lake X Signal 3 Phase y Signal 3 Signal 2 Phase Signal 2 Phase E. West Maple S. Commerce y Decker Road X Phase J1 ~ 2 2 2 2 2 2 2 2 2 2 2 2WB, 3-EB West Maple Road Ladd Road Decker Road T X 4-Way Stop Signal 2 Phase Left-NB,SB,EB,WB 2 2 Left-NB,SB,EB,WB 2 2 1 1 1 1 1 1 2 2 Walled Lake Road Ladd Road X Stop on Ladd Angle Road y 3-Way Stop 14 Mile Road T Stop on 14 Mile y Stop on Decker S. Commerce Decker Road Source: Ann Arbor Planning Associates Field Study Left-SB Right-EB,WB �Traffic Volumes and Turning Movements I ~ I Information on traffic volumes was obtained in several ways. Most of the recent and historical traffic volume information was obtained from the Oakland County Road Commi~sion (OCRC) records. Some volume information was obtained from the Southeast Michigan Council of Government's (SEMCOG) files. The traffic volume on Walled lake Road was counted by an Automatic Traffic Recorder by the OCRC during April, 1989 at the request of the City of Walled lake. The intersection turning movement counts were recorded by the Consultant on mid-week days in April and May, 1989 during the afternoon peak period (4:00 p.m. to 6:00 p.m.). Table 19 shows the most recent traffic volume information available for Walled lake. The heaviest flow of traffic in the City of Walled lake is on Pontiac Trail between South Commerce and Walled lake Roads. The highest traffic flow occurs on this segment of Pontiac Trail during the afternoon peak period (between 4 p.m. and 6 p.m.). Table 19 also shows that the afternoon peak period has higher traffic volumes than the morning peak period (7 a.m. to 9 a.m.). Map 4 portrays this traffic volume information graphically . I - 't J . Map 5 shows the changes in traffic volumes on Pontiac Trail and E. West Maple in the City of Walled lake and just east of the City between 1976-77 and 198687. During that decade the traffic volume on Pontiac Trail inside the City of Walled lake increased by an average of 31 percent, and by 11 percent on E. West Maple Road. Just east of the City the increases in traffic volumes were 64 percent on Pontiac Trail and 48 percent on E. West Maple Road. Map 6 shows the turning movements of traffic at the intersections in the study area during the afternoon peak period. Not surprisingly, heavy turning movements were observed at the Pontiac Trail and E. West Maple intersection. The pattern of turns indicates that the segment of Pontiac Trail between S. Commerce and Walled Lake Roads serves as a major link in the route of east/west throughtraffic in Walled Lake. l_ More than half of the north bound traffic on Pontiac Trail turns onto north bound S. Commerce during the p.m. peak period. This indicates that Pontiac Trail also serves as a major link in the north/south route of through-traffic in Walled lake. The turning movements at the Walled Lake Road and Pontiac Trail intersection, and the traffic count ·on Walled Lake Road at 14 Mile Road imply that a substantial number of vehicles turn right onto north bound Pontiac Trail from west bound Wa 11 ed lake Road by cutting through on Liberty or Withera 11 and Nicolet Streets. This was confirmed by field observations. Observation of turning movements at the W. West Maple, Ladd, and Angle Road intersection shows that a substantial number of vehicles enter W. West Maple from Angle and north bound Ladd Road. This indicates that W. West Maple is also used as an east/west route to the developments west of Walled lake. - 55 - �r----- -:-··-• - -- __...._,__ .--- - ---- -. r--, .J •. ; -~-;-: - ---, J J TABLE 19 TRAFFIC VOLUMES ROAD BETWEEN ADJ {BI-DIR) 1 YEAR 8-9 AH 5-6 PH E. West Maple Haggerty and Welch East of Decker EastJiLPont i ac Tr . 15226 11358 12658 1986 1985 1986 895 825 1148 1259 OCRC* 1038 OCRC 1016_~ OCRC Decker North of Pontiac Tr. South of Pontiac Tr. South oLE._ West Map 1e 7838 10896 14502 1987 1987 1987 498 713 1053_ 793 1044 1458 Pontiac Tr. East of Welch West of Welch East of S. Commerce West of S. Commerce South of E. West Maple South of Walled Lake 10166 11450 10015 19677 23565 14221 1987 1987 1987 1987 1987 1987 737 712 621 1010 1302 900 1011 1130 865 1633 1948 1230 __ OCRC OCRC OCRC OCRC OCRC JKRC Walled Lake Angle and Pontiac Tr. at 14 Mile 9139 10611 1987 1989 463 821 748 864 OCRC OCRC Lad{J South of Anql e 5383 1988 451 687 CRC S. Commerce Asher and Pontiac Tr. 10000 1987 840_ __ _ _8_40 __ _SEMCOG ~ 1 ADT (BI-DIR) - Average Daily Traffic (Bi-directional) Sources: * Oakland County Road Commission ** Southeast Michigan Council of Governments SOURCE OCRC OCRC OCRC ~, .. J �,---1 ' ~ -~ 1· I ,..J c::7 _,,.I ~ •· ·) t!!r!!&ix;;;,;,:;tfA c::::;~~ 11-------1 'lQ Oakland Coooty Road Conmisston Southeast Michigan Council of Goverrvnenu ~ AVERAGE DAILY TRAFFIC CITY OF WALLED LAKE pl.,.., llcKENll4 UIOCIUEI, INCOIIPOAU[D cOffltnUnfty wban dH lgn I.HNAIIIO",u"-',.OUSOQAT~ 1armanat011 _., An,tA, . . . . . c:HgM mlehlg.n t,aAtpo,••--.,,_, ... • OAKLAND COUNTY MAP 4 • MICHIGAN lfLfl n I -- - �t· - ·- - ""'""I ) , --,~---.. '• - -- ; -1 I LEGEND •t··· 00,000 (87) Average Dally Traffic In 1987 00,000 (77) --- Average Dally Traffic in 1977 +00% - --- percent increase c:::J~ ,, . . ......... . .... ..,27 _ _ ._J ~ n-~~nl~Q I 111' I 36 I ,," , I JI IIII , IC, I -~~ " , _ d j ~ , c ;•- - - - ~ . .r~ I 11 i . mNP.~-,-;· .. u ..., ' Source: INCREASE IN TRAFFIC VOLUMES CITY OF WALLED LAKE llcKENNA AISOCIATES, INCORPO~ATED CM'lfnuntt)' plf.lWng fwmlngton hM11 Wben dHlgn m~hlgan - ~N 4AIOJI ~ . i Q .UIOaATD Tr.-.•~•••on ,.,,..,11, M11A,..,II~ • OAKLAND COUNTY Oakland County Road Coomfufon MAP 5 • MICHIGAN m..nn �r--- ·-- l .... :- r ·- 7 ..... 'I - ' LEGEND ® ---------- Vehicles/Hour Turning Left Vehicles/Hour Through Vehicles/Hour Turning Right __.. INTERSECTION TRAFFIC VOLUMES DURING P.M. PEAK CITY OF WALLED LAKE ......,..,.Q AIIOCIAlD McKfNHA ASSOCIATES, ttCOIIPORATEO NfH AAM>A cotntnunit)' p14tn1a r~Of'lhlll Mf!IAfNfMcHglifl ..t,;an Cleatgn ,nkhfgatt T1 anepM ■■ -.~r.i• • OAKLAND COUNTY • MAP6 MICHIGAN lJlfl n .-- - �'I . Accidents Accident summaries for the City of Walled Lake were obtained from the Oakland County Road Commission for the years 1985 through 1987. Accident records for Walled Lake Road were obtained from the Traffic Improvement Association of Oakland County. The accidents were classified as either "intersection" or "midblock" accidents, depending on where they occurred. "Intersection" accidents include all accidents occurring on any intersection approach roadway within 200 feet of the middle of the intersection. All other accidents are considered to be "mid-block" accidents. Accident rates were calculated to permit comparison of accident experience at different locations. "Mid-block" accident experience is summarized by: Total number of accidents in three years (1985-87) Number of accidents with injuries (1985-87) Accident rate (accidents/year/mile) r, I !, r. I- "Intersection" accident experience is summarized by: Total number of accidents in three years (1985-87) Number of accidents with injuries (1985-87) Accident rate (accidents/million vehicles) The number of accidents with injuries is provided to denote the severity of accidents at a particular location. Injury accidents are those in which at least one person, but perhaps more, was injured or killed. Note that the accident rate for "mid-block" (accidents/year/mile) is different than the rate for "intersection." The latter does not involve distance, but is normalized by the number of vehicles traveling through the intersection. Map 7 shows the mid-block accident experience in the City of Walled Lake for the period between 1985 and 1987. In general, the road segment with the worst midblock accident record is Pontiac Trail between Walled Lake and Decker Roads. During 1985-87 this segment had 242 mid-block accidents. The second worst segment is Walled Lake Road between Pontiac Trail and 14 Mile Road, which had 66 accidents during the same period. In contrast there were no accidents on Decker Road from 1985 through 1987, and only 3 accidents on Ladd Road in the same time period. The accident rate (accidents/year/mile) takes into account the length of a road segment and provides a comparative measure. The worst rate, 72. 44 accidents/year/mile was on Pontiac Trail between Decker and South Commerce Roads. This road segment also had one of the worst records in Oakland County. The OCRC ranked it as the 13th worst segment, out of more than 1000 segments in the County. For comparison, Ladd Road, with rate of 1.07 accidents/year/mile was ranked 1081st. Pontiac Trail from South Commerce to Walled Lake Road had an accident rate of about 55 accidents/year/mile, and Walled Lake Road from Pontiac Trail to 14 Mile Road a rate of about 30 accidents/year/mile . The severity of the accidents on Pontiac Trail is greater than that on other roads in the City. On Pontiac Trail between Decker and S. Commerce , 46 of 113 accidents (40.7 percent) involved injuries, while on other roads within the City only a quarter to a third of the accidents involved injuries. - 60 - �j ;--1 . .J II'---~---+-- LEGEND ~ - All Accidents - Accidents with Injuries - Accidents/Year/Mile c::)~ d·1 r- ( 'ic'> , I I 'j Source: Oakland Cou,ty Road Conmissfoo ~ MID-BLOCK TRAFFIC ACCIDENTS CITY OF WALLED LAKE McKEHNA AISOCIATH, INCORPOIIATEO comMUNty ~ fwft'Wngton hilt nan dHlgn m'ch'91n AHN AAIOR PLANNMO AHOCIATH Ttanapot\lllon An1lpjt Ann NW, .. chlg,in • 1985-1987 OAKLAND COUNTY • MAP 7 MICHIGAN lJlJ7 - n .-- �r !: Two factors contribute to the accident experience on Pontiac Trail. The road carries a high volume of traffic and serves as an arterial for through traffic while also providing direct access to the abutting land, taking on the functions of both a collector and local street. Table 20 gives the number of access points (curb-cuts, 'driveways, and other access points, excluding streets) onto Pontiac Trail between Decker and Ladd Roads. TABLE 20 ACCESS POINTS ONTO PONTIAC TRAIL r . I ·, Section Decker - S. Commerce S. Commerce - Maple Maple - Walled Lake Walled Lake - Ladd Length (mile) .52 .27 .51 .40 South Side North Side 16 8* 17 10 28 13* 21 9+ * includes some long undefined access areas + includes lake access area i. , Source: Ann Arbor Planning Associates Field Study The conflict between merging traffic from the residences and businesses on Pontiac Trail and heavy through-traffic contributes to accidents. A contributing factor to the accidents on Walled Lake Road is the fact that the road serves through-traffic as well as providing access to the abutting recreational and residential land. Residents from nearby neighborhoods walk to the lake, generating a great deal of pedestrian traffic along Walled Lake Road. l, Map 8 summarizes accident experience at intersections in the City of Walled Lake for the years 1985 through 1987. The worst accident experience in the City was at the intersections of Pontiac Trail between Walled Lake Road and Decker Road. During the period 1985-87, there were 61, 70, and 65 accidents at the intersections of Pontiac Trail with S. Commerce, Maple, and Walled Lake respectively. The corresponding accident rates at these intersections were 2.79, 1.97, and 2.24 accidents per million vehicles. Another intersection with high accident rate was at Decker and 14 Mile, with a rate of 2.11 accidents per million vehicles. Of the 61 accidents at the intersection of Pontiac Trail with S. Commerce during 1985-87, 27 (44.3 percent) were severe with injuries. The rate of 2.79 accidents per million vehicles was 59th in Oakland County. For comparison, the intersection of Ladd and Maple with an accident rate of 0.12 accidents per million vehicles was ranked 592nd in the County. - 62 - �r-·-·· t r:7 J ! ~-:-- 1 LEGEND • Total Accidents - Accidents with Injuries - Rate (Accidents/Million Vehicles ~ Source: Oakland County Road Commission ~~ " -~~lll ] r :.J_ 3Q Source: ~ INTERSECTION TRAFFIC ACCIDENTS CITY OF WALLED LAKE McKENNA ASSOCIATIES, INCOAPORATED communn, ~ v wb•n d . . lgn fannlnglOfl twit mk:Ngan ANH ARBOR PLANNIHO ASSOCIATES y,...,.,_.-.,.,. .,,.,,_. ~""'-... ch'a-" • 19as-19a1 OAKLAND COUNTY • Oakland County Road Conmfufon MAP 8 MICHIGAN lJlJl .-- .. - n �The contributing factors to the accidents at these intersections include the volume of traffic, the skewness of the intersections, and the number of access points near the intersections. Angle parking near the intersections of Pontiac Trail at Walled Lake Road, and Pontiac Trail at E. West Maple are also undesirable .from a safety perspective . Levels of Service Levels of service (LOS) were determined for all study intersections and arterials for the p.m. peak hours using standard methodology documented in the 1985 Highway Capacity Manual 2 published by the Transportation Research Board. Existing traffic conditions and existing traffic volumes were used in this analysis. This methodology determines a Level of Service from A through F, with A providing the best service and F, the worst. The following is a description of the Levels of Service for arterial roadways and intersections. Definition of LOS on Arterial Roadways Il , i ' L i l . Level of Service A describes primarily free flow operations at average travel speeds usually about 90% of the free flow speed for the roadway class. Vehicles are completely unimpeded in their ability to maneuver in the traffic stream. Stopped delay at intersections is minimal. Level of Service B represents reasonably unimpeded operations at average travel speeds usually about 70 percent of the free flow speed for the roadway class. The ability to maneuver within the traffic stream is only slightly restricted and stopped delays are not bothersome. Drivers are not generally subjected to appreciable tension. Level of Service C represents stable operations. However, ability to maneuver and change lanes in mid-block locations may be more restricted than in LOS B, and longer queues and/or adverse signal conditions may contribute to lower average travel speeds of about 50 percent of the average free flow speed for the roadway class. Motorists will experience an appreciable tension while driving. f C Level of Service D borders on a range on which small increases in flow may cause substantial increases in approach delay and, hence, decreases in arterial speed. This may be due to adverse signal progression, inappropriate signal timing, high vo 1umes or some combination of these. Average trave 1 speeds are about 40 percent of free flow speed. Level of Service Eis characterized by significant approach delays and average travel speeds of one-third the free flow speed or lower. Such operations are caused by some combination of adverse progression, high signal density, extensive queuing at critical intersections, and inappropriate signal timing . 2 Highway Capacity Manual, (1985). Special Report 209, Transportation Research Board, Washington, DC. - 64 - �l..; Level of Service F characterizes arterial flow at extremely low speeds below onethird to one-quarter of the free flow speed. Intersection congestion is likely at critical signalized locations, with high approach delays resulting. Adverse progression is frequently a contributor to this condition . Definition •of LOS at Intersections The level of service at intersections is characterized by the delay experienced by vehicles going through the intersection. Table 21 describes the LOS at signalized intersections in terms of stopped delay per vehicle. TABLE 21 [ LEVEL OF SERVICE AND DELAY AT SIGNALIZED INTERSECTIONS Level of Service {LOS) Stopped Time Delay per Vehicle (seconds) less than 5.0 5.1 to 15.0 15.1 to 25.0 25.l to 40.0 40.l to 60.0 more than 60.l A B C ! D E F I i.,. Source: ,. 1985 Highway Capacity Manual Levels-of-service at unsignalized intersections are stated in somewhat more general terms. Table 22 gives the level-of-service at unsignalized intersections in terms of delay. I; TABLE 22 LEVEL OF SERVICE AND DELAY AT UNSIGNALIZED INTERSECTIONS r . I j l - Level of Service (LOS) A B C D E F Source: I ,_ Expected Delay to Minor Street Traffic Little or no delay Short traffic delays Average traffic delays Long traffic delays Very long delays Queues and extreme congestion 1985 Highway Capacity Manual - 65 - �L. Levels of Service E and Fon arterials and at intersections are considered to be unacceptable conditions. The level of service on the arterial segments during the p.m. peak period was calculated using the travel time along the segments and intersection delays to determine the LOS3 • Travel time along the corridors was determined in April 1989 using the floating car technique, (i.e. study vehicle maintains the travel flow without passing). The resulting LOS on the arterial segments are shown on Map 9. I_ I t - The existing LOS during the p.m. peak period for signalized and unsignalized intersections is presented in Table 23. These results are also shown on Map 9. TABLE 23 I ' I LEVEL OF SERVICE AT WALLED LAKE INTERSECTIONS DURING P.M. PEAK PERIOD SIGNALIZED INTERSECTIONS I-, I Pontiac Pontiac Pontiac Pontiac Pontiac Pontiac E. West Trail Trail Trail Trail Trail Trail Maple at at at at at at at LEVEL-OF-SERVICE West Road Ladd Road Walled Lake E. West Maple S. Commerce Decker Decker Rd. B B C D C B B UNSIGNALIZED INTERSECTIONS I W. West Maple at Ladd Rd. Walled lake Rd. at 14 Mile S. Commerce at Decker Rd. B B C L Source: Ann Arboi Planning Associates I, An unacceptable level-of-service (LOSE) was found on Pontiac Trail between E. West Maple and S. Commerce Roads. Furthermore, most of the rest of the Pontiac Trail corridor between Walled lake Road and S. Commerce including the intersection with E. West Maple, was at LOS D, the lowest acceptable LOS. With these conditions, small increases in traffic volume could deteriorate the level of service and push it into an unacceptable level. - 66 - �~ ·7 -- ~ J - i . -, LEGEND @ C Level of Service at Intersection Level of Service on Roadway ~~ l -nlnd I ~i'··(.l1 1 ; 11 i 1 11 1rfl / z~' >-----------< 36 ~I I I I I I 1111 I I l..[I 1111 11111 1 ''" "I"" ((iJ!'.:'<~ . ~~/ \\I LEVELS OF SERVICE DURING~, .~ :_ ~\~=-=::j P.M. PEAK CITY OF WALLED LAKE lkK£HHA Al80CtATES, INCORPORATED c.ommunNy ,lfMlne "rba,n lk•lgn lemwtvton hlk mlch!Qan ... IMH .UM>R ~ .. O Alac:JCIATD ,,_,,., ""...,_,~.,, AnnN..., .. d,lgM • OAKLAND COUNTY • MAP 9 MICHIGAN lIITTH ) J �-. t j r i . I It should be noted that the LOS was calculated for the afternoon peak period, which in Walled Lake is the time of day with the highest traffic volumes. At other times of day the level of service is better . • Planned Transportation Improvements This section describes plans for transportation improvement projects committed or planned by the Michigan Department of Transportation (MOOT) and Oakland County Road Commission (OCRC) in the vicinity of the City of Walled Lake. The magnitude of traffic impacts of these projects on the City of Walled Lake is assessed. I ' Michigan Department of Transportation J lt • ( ' I . Haggerty Road Connector: The MOOT project with the most direct impact on the City of Walled Lake is the Haggerty Road Connector (HRC), M-9. The HRC will provide a higher capacity south/north connector between the intersection of 1-696/1-96 and Pontiac Trail at Haggerty Road. The HRC project is committed, though the final decision concerning the alignment had not been reached at the time this chapter of the plan was completed. In July 1987, the MOOT proposed the following four alternative alignments for the HRC to be studied. - Alternative 1 - No action. - Alternative 2 - Improve Haggerty Road from 8 Mile Road north to Pontiac Trail with no additional access to the freeway system. Alternative 3 - Provide access to existing Haggerty Road from the I-96/ I696/1-275 interchange. The connection with Haggerty Road would be just north of the intersection of 13 Mile Road and Haggerty Road. This alternative would include improvements to the existing Haggerty Road from the point of connection north to the vicinity of Pontiac Trail. i (_ ' l .. - Alternative 4 - Provide a new road on a new alignment west of the existing Haggerty Road with freeway access provided at the I-96/1-696/1-275 interchange. Pontiac Trail would be the northern connector to Haggerty Road. Maps showing the alignments of alternatives 2, 3 and 4 are in the Appendix. The Draft Environmental Impact Statement (DEIS) 4 , which provides an assessment of the four alternatives, was released in May 1989. The process of selecting preferred alternative involved a series of public hearings, the last of which took place on June 7, 1989. It is expected that the decision on a final 4 Michigan Department of Transportation, and the Federal Highway Administration (1989), "Draft Environmental Impact Statement for the Haggerty Road Connector, Oakland County , Michigan," Prepared by Envirodyne Engineering Inc. - 68 - �' I.• • alignment will be made by the Fall of 1989. However, it is quite clear that either Alternative 3 (a new interchange and westerly alignment up to 13 Mile Road, plus improvements on Haggerty Road from 13 Mile Road northward), or Alternative 4 (a new interchange and a new facility in a westerly alignment) will be selected. , Alternative 1 (do nothing), and Alternative 2 (no additional interchange connection) have been found to be unacceptable in the analysis of the Draft Environmental Impact Statement. Alternative 4-A, one of two variations on Alternative 4, was recommended by the Technical Advisory Committee during their May 1989 meeting. Accordingly, this alternative, which calls for a new roadway west of the existing Haggerty Road, currently has the highest probability of being selected. ''· . Both Alternatives 3 and 4 propose a controlled access boulevard, with three or four lanes in each travel direction, separated by a median with a minimum width of 84 feet. The right-of-way will be 410 feet at minimum. Alternative 3 would have service roads in each direction, with the existing Haggerty Road serving as one of these service roads. The existing Haggerty Road would remain unchanged and function as a service road under Alternative 4. With both alternatives, the HRC would be connected to the Interstate system via a new interchange located at I-96, midway between Haggerty Road and Meadowbrook Road. The cross roads will be widened on the approach up to five lanes at the intersection. There are two variations to both Alternative 3 and 4, 3-A and 3-8, and 4-A and 4-B, respectively. Alternatives 3-8 and 4-B deviate slightly from the linear south/north alignment of 3-A or 4-A in the vicinity of Black Spruce Bog, midway between 13 Mile and 14 Mile Roads (see Appendix). Table 24 shows the Average Daily Traffic (ADT) and the Design Hour Volumes (DHV) for E. West Maple Road and Pontiac Trail for the current year (1987), for the year when construction ends (1995), and the design year (2010). These volumes are from the DEIS. I • The DHV is the hourly volume on which the design of a facility is based. Typically, for existing facilities the DHV is the thirtieth highest hour volume recorded in a year. In urban and suburban areas the thirtieth highest hour volume usually corresponds to that for a normal peak hour. The DEIS indicates that daily traffic volumes on E. West Maple Road and on Pontiac Trail in the vicinity of Haggerty Road are expected: 1. To grow by about 75 percent by the year 2010 if the HRC is not constructed (from 18,100 to 31,400 vehicles per day, and from 13,400 to 23,300 vehicles per day respectively, under Alternative 1). This traffic growth is attributed to future land-use developments in Oakland County. - 69 - �TABLE 24 HAGGERTY ROAD CONNECTOR ESTIMATED TRAFFIC VOLUMES FOR 1987, 1995 AND 2010 AT CROSSROADS WITH HAGGERTY ROAD Alternative Road f ' !. '-· 1987 DHV 18,100 13,400 1,620 1,210 ADT 1995 2010 DHV ADT na na na na 31,400 23,300 2,800 2,100 Alternative 3 E. West Maple Pontiac Trail 21,600 16,330 1,720 1,500 26,600 21,800 2,170 2,000 Alternative 4 E. West Maple Pontiac Trail 20,300 21,700 1,880 1,900 31,600 35,400 2,930 3,100 Alternative 1 E. West Maple Pontiac Trail ADT DHV r .., I f • ADT - Average Daily Traffic DHV - Design Hour Volume na - Not Available l. t <.., Source: Mi chi gan Department of Transportation, Draft Environmental Statement Haggerty Road Connector Im12act 2. To grow more moderately under Alternative 3 than under Alternative 4. ADT on E. West Maple near Haggerty in the year 2010 is estimated at 26,600 under Alternative 3, versus 31,600 under Alternative 4. ADT on Pontiac Trail at Haggerty is estimated at 21,800 under alternative 3, versus 35,400 under alternative 4. 3. To be lower by the year 2010 under Alternative 3, than under the "do nothing" alternative. ADT on E. West Maple at Haggerty under Alternative 3 is estimated at 26,600, versus 31,400 under Alternative 1. ADT on Pontiac Trail at Haggerty is estimated at 22,800 under Alternative 3, and at 23,300 under alternative 1. 4. To remain virtually at the same level on E. West Maple . at Haggerty in the year 2010 under Alternative 1 ("do nothing") and Alternative 4 ("construct a new roadway"). ADT for E; West Maple is estimated at 31,400 under Alternative 1 and at 31,600 under alternative 4. - 70 - �,...... 5. To increase on Pontiac Trail at Haggerty by about 165 percent in the year 2010 under alternative 4. AOT is estimated to increase on Pontiac Trail at Haggerty from 13,400 in 1987 to 35,400 in 2010. I • l" , Impacts on Walled Lake: It is important to note that these traffic volumes are bi-directional, and estimated east of the City of Walled Lake, at the intersection with Haggerty Road. In the p.m. peak period much of this traffic at the intersections of Pontiac Trail and Haggerty and E. West Maple and Haggerty will be coming from Haggerty and proceeding north or turning east. In the a.m. peak period most of the traffic will be coming from the north and east onto the HRC. In both cases most of the traffic is moving away from Walled Lake since the HRC as proposed by either Alternative 3 and 4 will provide a good south/north route, east of the City of Walled Lake. Without the HRC (or other changes) much of the future southwest/northeast traffic would attempt to travel through the City of Walled Lake. It should also be noted that the HRC will probably stimulate more development just west of Walled Lake. In that case, there will be an increase in east/west traffic from the HRC to the areas west of the City, probably via E. West Maple, Pontiac Trail, and then W. West Maple Roads. However, this traffic will be in the direction opposite of the present peak flows on these roads. Alternative 3 which is estimated to generate less growth in traffic on Pontiac Trail and W. Maple than Alternative 4, is the preferred alternative for the City of Walled Lake. I• Completion of 1-696: MOOT is expected to complete the last rema1n1ng section of 1-696 in southeast Oakland County, from Telegraph Road eastward to 1-75, in late 1989. This will provide a continuous east-west corridor along the southern tier of Oakland County, south of the City of Walled Lake. This project will provide better connectivity between the City of Walled Lake, western Oakland County, and Macomb County. However, it is not expected to affect traffic in the City itself. New Interchanges on I-96/I-696: MOOT will construct two new interchanges on I-96/I-696, one in the vicinity of Haggerty Road as part of the HRC, and the second at Inkster Road. Construction of another interchange in the vicinity of Drake Road is also being considered, but is less certain at this time. These improvements will provide better access to I-96/1-696 south of the City of Walled Lake. Only the interchange at the Haggerty Road Connector will have an impact on the City by diverting through traffic from Pontiac Trail/E. West Maple Roads onto the Haggerty Road Connector. Other New Interchanges: MOOT proposed constructing new interchanges on M-59 at Squirrel Road to serve the Oakland Technology Park and the new Chrysler headquarters, and at 1-75 and Featherstone Road. These interchanges are expected to have little direct impact on the City of Wa 11 ed Lake. However, the new "Oakland Technology Park" could generate additional southwest to northeast traffic, with a small portion of it, possibly, going through the City of Walled Lake. - 71 - �,-· i The Corridor of Opportunity: The •corridor of Opportunity• is part of a longterm MOOT study, and is still conceptual at this time. The corridor is envisioned as a location for •high-tech• and research industries along M-59 from 1-96 (near Howell) easterly to 1-94 (near Mount Clemens). If this idea becomes reality, it _will create new jobs north of the City of Walled lake, and could add to the through-traffic through the City. Proposed Oakland County Road Commission Improvements i I\.. .""' The Oakland County Road Commission (OCRC) prepared two policy statements~6 in 1988-1989 which provide guidance for road development in Oakland County from the County's viewpoint. There are no definite commitments of funds for these proposed projects. Proposed Trunklines: The "Draft Report on Proposed State Trunkline Additions• prepared in 1989, lists three categories of trunklines in the Oakland County: I. Existing or committed trunklines 2. Proposed new trunklines with specific proposed alignments I L 3. Proposed new trunklines with no specific proposed alignment (just general area). f, 1 1 l • '. ; I I t .. From the view-point of the City of Walled lake, the most important proposed state trunkline with a specific alignment is the improvement of E. West Maple Road from the eastern border of the City eastward and the reclassification of this segment to State Trunkline. The report proposes that this trunkline be connected to Northwestern Highway (M-10) which currently ends at 14 Mile Road. The report also proposed a north/south trunkline west of the City of Walled Lake aligned along Milford Road between 1-96 and M-59. This proposed trunkline, would most likely eliminate the possibility of constructing a north/south connector along Benstein Road, between M-59 and 1-96. The Benstein Road extension would be a more desirable alternative for the City of Walled lake. The report further proposed a north/south trunkline, with no specific alignment as yet, north of the City of Walled lake from Elizabeth Road at M-59 northward, connecting to a new east/west trunkl ine at the northern borders of Oakland County. This northern · trunkl ine would probably generate more residential development north of the City of Walled lake and more traffic through the City. 5 Oakland County Road Commission, Planning & Development Department (1989), "Draft Report on Proposed State Trunkline Additions: Future Trunkline Conversion Projects•. 6 Oakland County Road Commission, Planning & Development Department (1988), •Report of the Oakland County Roads Commission Strategic Planning Process: 1988•, Volume I, October 1988. - 72 - �The "Report on Proposed State Trunkl ine Additions" does not represent the official policy of the OCRC. The Commission reviewed the draft but decided not to adopt the report. Capacity Improvement and Construction Needs: As part of its strategic planning process, the OCRC summarized its future needs for capacity improvements, paving, and construction during the next decades, including a series of maps indicating the specific locations. ,·\ Both West Maple Road and Pontiac Trail in the City of Walled Lake are included as needing capacity improvements. Benstein Road from West Maple to Pontiac Trail, and the Maple Road extension are included as needing new road construction. I I - Summary of Findings The City of Walled Lake is experiencing several inter-related transportation problems, the symptoms of ,which are congestion and traffic accidents. The contributing factors to these problems have been identified by this study as: 1. Lack of Road Hierarchy The system of roads in City of Wa 11 ed Lake does not have an adequate hierarchy. A well developed road network includes several "layers" -- a categorical hierarchy of roads -- each of which serves a specific level of traffic - local, sub-regional, regional, state or interstate. The foremost distinction among categories of road is between local streets and through-traffic roads. This distinction is made because of the substantially different street design required to serve local and non-local traffic. To eliminate conflicts among levels of traffic carriers, it is desirable to separate them as much as possible. All categories of roadways should be carefully integrated into a balanced circulation plan for the system to function well. The following is a definitions of common roadway classifications: !: ''I , Local or Minor Street - These roadways provide access to adjacent land and make up a large percentage of the total street mileage of cities while carrying only a small portion of the overall vehicle miles traveled. Local streets should provide access to collector streets. Ashtan is an example of a local street in Walled Lake. Collector Streets - Collector streets provide access to local streets or directly to abutting properties. Their purpose is to collect vehicles from local subdivisions and distribute them to local destinations or to arterials. Collector streets can provide internal circulation and access to nonresidential areas such as industrial parks and major shopping centers. Ladd Road is an example of a collector street in Walled Lake. - 73 - �. \ I I !· I I ; Arterials - Arterial roadways provide continuity over long distances. Arterials carry traffic from collectors to major activity centers, freeways, and other townships and cities. These roads serve through traffic and may provide access to abutting properties and minor intersecting streets. Some access control is desired, e.g., minimizing curb cuts and providing parallel marginal access roads for strip commercial development. Arterials can be further classified into major arterials and minor arterials. Generally, major arterials carry over 10,000 vehicles per day, and minor arterials carry between 5,000 and 15,000 vehicles per day. Residential lots are generally not given direct access to arterials, even minor arterials. Pontiac Trail is an example of an arterial in Walled Lake. A basic problem in the City of Walled Lake is the lack of a hierarchy of roads and the inadequate separation of local traffic from through-traffic. The arterials through the City also function as residential/local streeti. This contributes to traffic accidents and to deterioration of the adjacent residential environment. ! L Walled Lake severely lacks the second tier of roads, namely the "collectors," which play an intermediary role between local streets and arterials. Solutions to this problem involve the development of a circulation plan for the City. This would include connectors between subdivisions and between subdivisions and arterials and would provide for an orderly and controlled movement between the major and secondary networks, while allowing flexibility of individual development proposals. 2. Through-Traffic Most of the traffic flow in the City of Walled Lake, particularly during the morning and afternoon peak periods is through-traffic, generated by residents of surrounding communities, who use the City streets in their daily work commutes. The lakes area north of the City of Walled Lake has been experiencing continuous residential growth. At the same time employment centers have been growing in the communities south, west and east of the City, along the 1-96, 1-696, 1-275, and M-14 corridors. This growth pattern leads to a south-bound morning commuting flow through the City, and north bound commuting flow during the afternoon peak period. L , r .. I I I , Because of the existence of lakes and wetlands in the area north of Walled Lake, the prominent grid pattern of arterials of southeast Oakland County changes to diagonal and meandering alignments in this part of the county. Without other alternatives, the north-south commuter route penetrates the City along Pontiac Trail, and along Walled Lake Road. The physical discontinuity of the West/East W. Maple Road in the City also contributes to through-traffic by adding some of the east/west traffic onto Pontiac Trail. The City of Walled Lake is located in the midst of a commute route. It is affected by the residential and commercial growth in surrounding areas, over which it has no control. - 74 - �3. Lack of Road Network r~ !I •\ A good road network minimizes the travel distance between any two points in the system. A grid pattern is suitable for a road network in flat terrain. Because .of the geographical constraints of the wetlands and lakes, described above, the road system in the vicinity of the City of Walled Lake has evolved into a shape of a funnel, rather than a network. The inefficiency of the funne 1 system is that a movement between two points requires a movement through the funnel, which in the case of Walled Lake is Pontiac Trail. Traffic from most arterials, and many local roads are channeled into this funnel. In order to relieve the pressure on Pontiac Trail, and to move toward a more efficient road network configuration, east/west and north/ south links should be added to the existing road system. This could be achieved by constructing the Maple Road Connector to allow for east-west movement, and by extending Benstein Road to Pontiac Trail to allow for a direct north-south movement. 4. Excessive Number of Access Points ..' Because the City of Walled lake lacks a road hierarchy, and in particular collector roads, residents and shoppers access the arterials almost at any point. There are a large number of access points (and strips} along the major arterials of the City. In contrast to other transportation problems over which the City has very limited control (i.e. through-traffic), solutions to this problem are within the City's jurisdiction and control. The City could reduce the number of access points through restrictive ordinances and through the development of a system of control points. Control points are points of entry and egress from different land areas (e.g., access to an industrial or commercial areas or groups of subdivisions). 5. Capacity on Pontiac Trail .L I' i The essence of the transportation problem in the City of Walled lake is Pontiac Trail. Pontiac Trail (within the City}, together with Walled lake Rd. ( a1ong the lake), and West Maple (east of Pontiac Trail} carry the largest traffic volumes, and exhibit lower levels of service and the highest accident rates. Historically, Pontiac Trail evolved from a non-motorized route into a major arterial required to carry large volumes of throughtraffic. Most of the through-traffic in Walled lake follows Pontiac Trail because of the lack of east/west and north/south network links. In order to reduce traffic problems in the City of Walled lake, and to make the transportation system more efficient, efforts should be focused on relieving pressure on Pontiac Trail. This could be achieved by increasing the capacity of Pontiac Trail itself, by creating a fully developed road network, which would divert some of traffic currently channeled onto Pontiac Trail, and by developing a good circulation system which would reduce the local traffic on Pontiac Trail. - 75 - �r, I i 1 RECREATION ANALYSIS I, ,...., l I ' I • .' . '. I Descriptio11 of Planning Process This analysis is the most recent of several planning documents pertaining to parks and recreation that have been prepared for the City of Walled Lake since the 1960's. The previous Master Recreation Plan was approved by the City Council and the Michigan Department of Natural Resources in 1978. This plan was subsequently updated in 1982, and again was re-submitted to the MDNR for approval . This analysis, which will be separated out as the 1990 Master Parks and Recreation Plan, was prepared by the City's Planning Commission in conjunction with preparation of an overall master plan for the City. The Planning Commission is responsible for planning the physical development of the City, including community and parks and recreation facilities. The plan was prepared with the assistance of McKenna Associates, a planning consulting firm, and with the active involvement of the City administration. Following initial review of the plan by the Planning Commission, the plan was submitted to the Parks and Recreation Commission and City Council for further review and refinement. Throughout the process, all meetings were open to the public. Notices were posted beforehand as required by the Open Meetings Act. Since 1982, the City has worked to complete several projects proposed in the earlier plan, including the following: I • I ·-· Project Year Source of Funds 1982-83 Installation of fitness trail at Sims Park. General Fund 1983-84 Installation of fitness trail work stations at Sims Park. General Fund 1986-87 Paving of Sims Park parking lot; installation of General Fund swimming area buoys and new signage at Mercer Beach; Installation of playground equipment and fencing at Marshall-Taylor and Pratt Parks. 1988-89 Installation of grills, picnic tables, and a swing set at Mercer Beach. I. l. General Fund Administrative Organization Parks and recreation services are provided by the city government and the Walled Lake Consolidated School District (see organization chart, Figure 4). The City owns and maintains a number of parks sites, and hires part-time staff in the summer to assist in recreation and special events programming. The School - 76 - �r i ! I District maintains three school sites in the City, and has a full-time staff in charge of community education and recreation. A Parks and Recreation Commission has been established by ordinance to act as an advisory • body to the City Council (Chapter 32 of the City Code). The Commission consists of seven members as follows: one member of the Planning Commission, one member recommended by the Wa 11 ed Lake Consoli dated School District, and five members who are residents of the City. The Parks and Recreation Commission meets one a month or as necessary. All meetings are open to the public with notice posted beforehand at City Hall. [ The Parks and Recreation Commission principally advises the City Council on matters re 1ated to parks facilities and operation and seasona 1 programming. The City Manager and Director of Public Works share the responsibility for implementing the parks and recreation program. The responsibility for recreation programming in the Walled Lake Consolidated School District rests with director of the Community Education Department. In addition to recreation and leisure activities, this department is responsible for community service programs, adult high school completion, special events programming, and other community education programs. Recreation facilities owned by the schools are maintained by school district maintenance staff and part-time seasonal employees. Inventory of Existing Facilities Overview There are currently five City-owned parks in Walled Lake: Sims Park, Pratt Park, Marshall-Taylor Park, Mercer Beach and Riley Field (see Maps 10 and 11). There are also indoor and outdoor recreation facilities located at Walled Lake Elementary and Decker Elementary Schools and Walled Lake Junior High School. Nearby regional facilities include Proud Lake State Recreation Area, Commerce Township Park, Highland State Recreation area, Kensington Metropolitan Park, and Bloomer State Park. Six golf courses, a campground and a number of lakes are also within close proximity to ' the City. Private and commercial recreation facilities within the area include two gun clubs, a roller skating rink, a batting cage facility and the Multi-Lakes Conservation Club. r 'I Municipal Facilities Municipal and public school recreation sites within the City of Walled Lake and their facilities are described in Table 25. In terms of total acreage, the City government is a minor provider of recreation facilities when compared to the local school district. The five municipal parks in Walled Lake range in size from O. 25 acres to over 15 acres. They include a community wide park, two neighborhood oriented parks, a little league ball field, and a beach with picnic areas and play equipment. The City parks are locally oriented and are designed to serve a variety of outdoor recreational needs for the residents of Walled Lake. - 77 - �Figure 4 r-. II ,I I CITY OF WALLED LAKE PARKS AND RECREATiON PROGRAM n ORGANIZATIONAL STRUCTURE r ., RESIDENTS OF WALLED LAKE [ ' ' ------- I MAYOR AND CITY COUNCIL WALLED LAKE SCHOOL BOARD I I· ! l_ PARKS AND RECREATION COMMISSION ._ ___ ■ CITY MANAGER SEASONAL RECREATION STAFF SUPERINTENDENT DEPARTMENT OF PUBLIC WORKS PARKS MAINTENANCE l __, - 78 - ' COMMUNITY EDUCATION DEPARTMENT LEISURE AND RECREATION PROGRAMING SCHOOL BUILDING AND GROUNDS MAINTENANCE �r-· i~ I♦ r-: I, HIGHLAND ' ., i : C04MERCE BLOOMER STATE 1----PARK NO. 1 4-<:ficf~Jl¥-i PROUD 1 LAKE STA~E RECREATION AREA . ,.._a,~;;~. ' . • ,,:,,.►o.~~ ~r.~~~:; · ,~ ~:k~ :-<: WI.VERINE l. rm ~"- r·• I < I .c .i FARMINGTON HILLS I - I , L LYON ' ..' L :r ; '~ l._. ~ REGIONAL RECREATION FACILITIES '. ~ REGIONAL P.ARKS & RECREATION FACILITIES CT) MAP 10 M~Kenna Associates, lncorpOfated Community P1aming • Urban Design F~rmington Hills. Michigan �,·- I • I l V . "........... _ _ _ __J - 21 L, i1.., I \' WALLED LAKE JUNIO RK -~=·=····-t - WALLED LAK ELEMENT AR I·• ! II ,. PARKS & RECREATION FACILITIES CITY OAKLAND Ml!iK.,._ Aqoc;.ialea, lncOl'POf&led ~ "'--g . t>~ °"91 Fwnwtg1:an ..._ Mocnoan OF MAP 11 WALLED COUNTY • LAKE MICHIGAN _,,, ~ �TABLE 25 PARKS AND RECREATION FACILITIES ,--, I ii Site Size (Acres} Type a. Sims Park 15.10 Community Park (3) Basketball Courts; (1) Tennis Court; (1) Ballfield; Fitness/ Jogging Course; Play Areas with Equipment; Picnic Areas with Grills; (1) Pavilion. b. Pratt Park 0.25 Mini-Park Play Area with Park Equipment; Picnic Area. c. Marshall-Taylor 1.30 Mini-Park (1) Ballfield; Park Play Area with Equipment; Picnic Area. d. Mercer Beach 0.08 Special Use Park Beach Area; Picnic Area with Grills; Play Area With Equipment. e. Riley Field 1.10 Special Use Park (1) Little League Baseball Field. a. Walled Lake Junior High School 14.90 Neighborhood Park (1) Football Junior High Field and Track School (lighted with bleachers); (1) Soccer Field; (1) Baseball Field; (1) Strengthening Gymnasium; Multi-Purpose Room. b. Walled Lake Elementary School 8.50 Neighborhood Park (2) Ballfields; Elementary (2) Basketball School Courts; Play Areas with Equipment; Gymnasium; Multi-Purpose Room. c. Decker Elementary School 7.60 Neighborhood Park (2) Ballfields; Elementary (2) Basketball School Courts; Play Areas with Equipment; Multi-Purpose Room. Park/Faci 1i t:t Facilities 1. City Owned Facilities i • L ! I i ( J . '' . 2. School Owned Facilities 1 i . L~ Source: City of Walled Lake Recreation Plan, 1982 and McKenna Associates, Inc . Survey, April 5, 1989. - 81 - �L School Facilities The three school facilities located in the City, Walled Lake and Decker Elementary Schools and Walled Lake Junior High School, range in size from 7.6 acres to almost 15 acres. These properties account for over 63 percent of the . total acreage of recreation facilities within the City. They mainly serve the residents of the neighborhoods in which they are located, although the facilities which are intended to serve the recreation needs of all residents of the Walled Lake Consolidated School District. I., Recreation Programs r, L ,..... (' I . '· I L - The Walled Lake Consolidated School District conducts a complete recreation program for all age groups. Individual programs include baseball, softball, basketball and volleyball leagues, organized activities for children including a youth summer day camp, golf and fishing tournaments, special programs such as trips to plays and sporting events, dance and swimming classes, and a variety of adult and senior citizens programs. These programs are available to all School District residents, with some registration and activity fees required. Recreation programs are provided by the school district's Community Education Department recreation programming staff. The school district maintains recreation facilities and conducts its programs at the two high schools, two junior high schools and five elementary schools within the district. The school facilities contain a variety of indoor and outdoor recreation facilities all of which are available to school ·district residents either for no charge or for a nominal fee. Use of these facilities is first available to school athletic teams and for scheduled programs and then open to the general public on a request basis. Private Facilities L, Several privately owned recreation facilities are also located in Walled Lake. Although use of these facilities is limited to those who can afford the fees, they do address certain recreation needs. Private recreation facilities include West Oakland Rollery, Detroit Gun Club, and the Batting Complex. There are also a number of private recreation facilities located within local condominium complexes and at common areas associated with a few residential subdivisions within the City. Private access to the lake and dock areas are also provided for several residential developments and complexes around the lake. Parks Classifications For planning and management purposes, recreation professionals classify park and recreation facilities based on the type of facility and expected usage. The following classifications are applicable in the City of Walled Lake: • Mini-Parks. Mini -parks are small, specialized parks, usually less than an acre in size, that serve the needs of residents in the surrounding neighborhood. A mini-park may contain a children's play lot, or serve as a - 82 - �greenbelt, or provide a sitting area for senior citizens. Marshall-Taylor Park function as mini-parks . ' _,' • Neighborhood Parks. Neighborhood parks are typically multi-purpose faciliti~s which serve as the focus of recreation activity for an entire neighborhood. Neighborhood parks are generally 15 acres or more in size, and typically contain areas for active recreation, such as ball fields, play lots, and tennis courts, as well as areas for quiet recreation activity, such as walking, sitting or picnicking. The junior high school and two (2) elementary schools within the City function like neighborhood parks, although they are deficient in terms of size. • Community Parks. Community parks typically contain a wide variety of recreation facilities to meet the diverse needs of residents from several neighborhoods. Community parks are generally 25 acres or more in size. These parks typically contain areas for active and quiet recreation, plus other facilities not commonly found in neighborhood parks, such as nature trails, gardens, or a nature interpretive center. Sims Park functions like a community park, although it is deficient in terms of size. • Regional Parks. Regional parks are typically located on sites with unique natural qualities which are particularly suitable for outdo·o r recreation such as picnicking, boating, fishing, swimming, camping and trail uses. Such parks generally exceed 200 acres in size. Regional parks typically serve several communities, although most users are within one hour driving time. There are no regional parks in Walled Lake, although Proud Lake State RecreatiQn Area is located in close proximity in Commerce Township . • Private and Special Use Facilities. Private or special use facilities are typically single-purpose recreation facilities, such as golf courses, nature centers, marinas, conservatories, ski areas, and facilities for the preservation or maintenance of the natural or cultural environment. Mercer Beach and Riley Field are both special use facilities in Walled Lake. Private recreation facilities in the City were identified earlier in this section. i , r-· I L, ' 1 I I L, ,. : ' I I ' ' - Pratt Park and Recreation Deficiencies Table 26 ' compares the City's park land acreage to recommended standards, based on current and projected population. Comparison of Walled Lake parks and recreation resources with the published standards reveals that certain aspects of the system could be improved. The figures indicate that if the school sites are counted in the park acreage figures, the City has adequate mini-park and neighborhood park acreage for the current and projected population. Continued residential growth will create the need for additional mini-park and community park facilities in the future. The system is deficient in the amount of acreage allocated for community parks. According to accepted standards, the City has about 15 acres of community park land; eventually community parks should occupy about 40 acres in the Citys. - 83 - �The City is also deficient in regional park acreage, but due to the limited size of the City, it would be impossible to develop a regional park of adequate size with the appropriate facilities within the City. Proud Lake State Recreation Area in adjacent Commerce Township is one of several nearby regional parks which serve City residents. The raw numbers do not address the quality of existing parks and recreation facilities. Upon closer examination, deficiencies or limitations are apparent because of the location, useability, level of development and individual size of existing park lands. These include: r~ i l.., r .. I 1. Limitations on Site Size. Most of the existing City parks are deficient in terms of size based on accepted standards. As the population increases, these parks could be subject to overuse because of their limited size. 2. Reliance on School Sites. The neighborhood parks within the City are all located at local schools sites. The cooperation between the City and School District provides for efficient use of the land. Nevertheless, there are limitations associated with having all of the neighborhood park facilities on school sites. 3. Closure of Walled Lake Junior High. Walled Lake Junior High School is scheduled to close in the fall of 1992. This action could possibly eliminate one of three neighborhood parks in the City and reduce the total acreage of parks in Walled Lake by 30 percent. f ' I l • I L- 4. Distribution of Park Sites. Park sites in Walled Lake are not evenly distributed throughout the City. Thus, accessibility to park facilities is not equal for all residents. 5. Types of Parks. Some areas of the City are not served by certain park types such as mini-parks and neighborhood parks, particularly in the east and southeast portions of the community. Continued growth in Walled Lake could eventually result in portions of the City being underserved. Table 27 addresses concerns about the quality of recreation facilities by comparing the actual facilities available to recommended standards, based on a projected population of 8,000. The table reveals that tennis courts and picnic facilities will be needed. The table further reveals that Walled Lake residents are not currently provided with various facilities, such as an outdoor community swimming pool, a fishing pier and nature or hiking trails. This evaluation, which is based on recommended standards, must be considered in relation to local conditions and needs. For example, many communities conform to the numerical standard for baseba 11 fields, but the fields are not in satisfactory condition for organized league play. The residents of each community express an exceptional interest in a few specific recreation activities, creating a greater need for certain recreation facilities than is specified by the recommended standards. - 84 - �TABLE 26 I ;~ COMPARISON TO PUBLISHED RECREATION STANDARDS MiniParks Neighborhood Parks Co11111unity Parks Private and Special Use Facilities Minimum Acres Per 1000 Population 0.25 2.0 5.0 Variable Estimated Existing Acreage 1.6 31.0 15.1 1.18** {: Acres Needed for Existing Population (5,703) 1.4 11.4 28.5 Existing Acreage as a Percent of Desired Minimum 114.3% 271. 9% 52.9% Acres Needed for Projected Population {8,000) 2.0 16.0 40.0 Existing Acreage as a Percent of Desired Minimum 80.0% 193.8% 37.8% [. ' (** Does not include acreage of private recreation facilities within the City). Based on National Parks and Recreation Standards - 85 - �TABLE 27 RECOMMENDED RECREATION FACILITY STANDARDS I I r" ! ! I Facility ,.. I I I ReCOll'l'llended Facilities per 1,000 Population Existing Facilities Facilities Needed For Projected Population of 8,000 Projected Deficiency Ball fields 1/5,000 9 2 Adequate Basketball Courts 1/5,000 7 2 Adequate Football Fields 1/30,000 1 1 Adequate Tennis Courts 1/2,000 1 4 3 Courts Soccer Fields 1/10,000 1 1 Adequate Volleyball · 1/10,000 3 1 Adequate Playgrounds 1/3,000 7 3 Adequate Fitness/Jogging 1/10,000 1 1 Adequate Beach 1/25,000 1 1 Adequate Picnic Areas None Published 5 Picnic Tables None Published 10 Outdoor Swimming Pools 1/40,000 0 Boat Launches (parking) 1/400 0 Fishing Piers 1/100,000 0 1 1 Pier Hiking/Nature Trails (miles} 1/5,000 0 2 2 Mil es of Trails ' Source: Adequate Continued Improvement Required 1 1 Pool Provide Parking When Required Based on standards published by the National Parks and Recreation Association and the Michigan Department of Natural Resources. - 86 - �Residents' Preferences and Needs r• I I . • l In order to assess local recreation needs, the Planning Commission was consulted to obtain their perception of the need for parks and recreation facilities. In general, the Commission indicated that existing recreation facilities are · generally adequate for the existing population but that new facilities must be developed to serve future population growth. While recognizing the recreation deficiencies that currently exist and those that are anticipated in the City due to population growth, the Planning Commission identified certain specific recreation needs as follows: r, - New parks are needed to service all areas and residents of Walled Lake, in particular the southeast s~ction of the City. l - Every new residential development in the City should provide park facilities, requirements of which should be provided for in the master plan and zoning ordinance. Residents in areas surrounding new residential development should be surveyed to determine if they want new parks and, if so, what type of facilities are desired. I' I l. The Planning Commission and City staff offered the following additional comments concerning City and school district recreation facilities: City-Owned Facilities r. a. ; I ,_ Mercer Beach 1. The beach is the most valuable and unique recreation resource within the City. Every effort should be made to make it more useable, convenient, and enjoyable for more residents of Walled Lake. 2. There is purchase purchase piece of 3. A concession stand and permanent restroom facilities are needed. These could be developed in conjunction with the additional parking. 4. There is a need to acquire and develop additional public beach property. ',I __ l., b. a need for additional parking. The City once attempted to a parcel for parking but could not reach an agreement to the property. It is still felt that the City should buy a property and develop it as additional parking for the beach. Sims Park 1. Alternative access is needed to the site. The current park design does not provide adequate access to the north end of the property. Alternative designs could include access off Decker Road and a culde-sac to the rear of the park. - 87 - �i. ' [~ n c. f'. 2. The construction of a comfort station at the park should be considered . 3. The existing ballfield has not been adequately maintained. It could possibly be upgraded for league play if redesigned. However, due to the close proximity of surrounding residences, any upgrading should not include the installation of lights. Riley Field 1. There is a need for a substantial number of additional parking spaces. 2. The ballfields needs to be re-graded, drainage should be installed, and the fields should be re-seeded. 3. The installation of permanent drinking fountains facilities should be considered. I , I d. and restroom Marshall-Taylor Parle 1. This park site could be better designed to serve as a safe play area for children. For example, and a crosswalk should be installed, and additional facilities constructed. 2. The obsolete well house on the site could be removed to provide for expansion of the park. Additional facilities that could be added include a tennis court and off-street parking. ,· I l e. Pratt Parle 1. Tennis courts are needed in the City and could be developed behind City Hall. Additional parking may be required. School-Owned Facilities I I'. Even though the three school sites in the City function like neighborhood parks, they are currently inadequate with regard to site size, types of equipment and facilities, and accessibility to some of the City's neighborhoods. Consideration should be given to development of these recreation sites with more neighborhood park type facilities such as picnic areas. As previously discussed, a key concern with regard to the continued provision of recreation facilities by the public schools is the impending closure of Walled Lake Junior High School. If the school is closed, the City will lose an important neighborhood park facility and will be deficient in terms of overall park space. Alternative plans for the development of a new neighborhood park to replace the junior high school facility should be considered. - 88 - �In order to obtain another perspective of recreation needs, a survey of City department heads was completed by McKenna Associates, Inc. in June, 1989. City staff indicated that the total number of park sites, indoor recreation facilities, and the majority of outdoor recreation facilities were adequate. The staff further indicated that most recreation needs not provided by the City · are address~d by the school district programs and facilities. The department heads did identify the need for additional mini-parks for residential neighborhoods and subdivisions, baseball fields, boat launches, fishing piers, and restrooms and a concession stand for Mercer Beach. r L ; In an effort to more thoroughly assess recreation needs of the citizens of Walled Lake, it is recommended that the City conduct a rec re at ion needs survey to determine the precise leisure interests and needs of residents. A survey conducted by the City would provide results that could be used to develop a locally-based set of recreation facility standards. The Planning Commission verified the need for such a survey, indicating that the needs may be changing as the population rapidly grows. Long-Range Goals ' (. I 1... Walled Lake is embarking on a new era in recreation planning, caused by continued residential growth, the possible closure of a major recreational facility in the City, and the need for additional parks and recreation sites to serve all residents. Based on the analysis of existing facilities and local recreation needs, the following long-range goals have been established for the City of Walled Lake (see Map 12): 1. Expand Recreation Opportunities. Increase recreation opportunities, particularly outdoor park facilities, that meet the needs of all segments of the population including youth and young adults, the elderly and the handicapped. 2. Address Residents' Preferences. Provide parks and recreation facilities and programs that are based on the preferences of residents in Walled Lake. 3. Maintain Fiscal Responsibility. Develop parks and recreation facilities and programs based on a sound fi seal po 1icy. Consider the use of volunteers, state and federal funding programs, and other funding sources. 4. Natural and Aesthetic Qualities of Parks. Provide parks and recreation facilities that not only satisfy recreation needs, but also complement the topography and natural terrain and contribute to the aesthetic quality of the City. 5. Cooperate with the School District. Cooperate with the Walled Lake Consolidated School District in the planning and programming of parks and recreation facilities. Written agreements of cooperation should be entered into when appropriate. l " l _, ,- - 89 - �...., i l .,......_ 6. Reduce Duplication of Services. Strive to reduce duplication in recreation services. Overall recreation planning should consider existing facilities and programs offered by the school district and other agencies . 7. Consider Maintenance Needs. Consider the cost of maintenance and operation in designing new recreation facilities. Projections of costs should be compared to future revenue projections for the life of the facilities. 8. Upgrade Existing Facilities. Maximize the use of parks and recreation facilities by upgrading existing facilities. 9. Improve Accessibility. Improve the accessibility to parks and recreation facilities and programs, particularly for youth, young adults, elderly and handicapped residents. 10. Continue the Planning Process. Maintain the ongoing parks and recreation planning process. The parks and recreation plan should be reviewed and updated annually. r" r ( : ,-'. i I ;- r Parks and Recreation Objectives Following are the City's objectives for the development of parks and recreation facilities in Walled Lake: I. Comunity Parks. Continue to develop Sims Parks as a community park. Emphasis should be on improving accessibility to the rear (north) portion of the park and installation of new facilities. The City should also explore opportunities to acquire a new site for a community park to replace the Junior High School Site. Possible locations that should be explored include the seven-acre fill site east of Pontiac Trail and north of the railroad, or wetland areas located west of Pontiac Trail and north of the railroad. 2. Neighborhood Parks. As the remaining vacant land in the City is developed make certain that adequate land is set aside for recreation use. Require developers to set aside a portion of each residential site that is developed for residential use. 3. Waterfront Development. Explore opportunities to acquire additional lakefront property for public beach use. Also, acquire adjacent land to expand Mercer Beach if the opportunity arises. 4. Additional Recreation Facilities. Expand the range of recreation facilities available to City residents. Facilities which are needed include tennis courts, picnic facilities, outdoor swimming pool, a fishing pier, exercise trails, and ball field improvements . Construction of adequate support facilities, such as restrooms, concession stands, offstreet parking, and barrier-free facilities, are also very important to make the best use of the parks. ( I 'L. !" i '' - 90 - �.. '' . I , 5. Optimize Park Use. Optimize the use of all parks and recreation facilities through multiple use of park space, adequate maintenance, and timely repair and replacement of facilities. 6. Recreation Programs. Continue to support and expand recreation programs in cooperation with the Walled lake Consolidated School District. 7. Acquisition and Expansion. Consider purchasing additional land for parks and recreation use before the price of land escalates to a level that would make acquisition infeasible. Land acquisition efforts should be guided by two principal objectives: the need for uniform geographic distribution of facilities and the need for adequately-sized parks. With respect to acquisition and expansion, consideration should be focused on the following: !'"' i l . ,-~ ... .'' , t I l a. Possible utilization of obsolete well sites and stormwater retention areas for recreation purposes. b. Possible acquisition of land in the southeast part of the City to serve the recreation needs of existing residents. c. Possible utilization of wetland areas for recreation purposes. (. 8. Needs Survey. A recreation needs survey should be completed within the next three years to determine with greater accuracy the recreation needs and desires of residents. 9. Parle Design and Landscaping. Enhance the appearance of a11 parks, recognizing the significance of parkland to the overall character and image of the City. A five-year landscaping/tree planting and lighting program should be developed for all parks. I '! t. Five-Year Action Program Specific projects under consideration included in a five-year plan include the following: 1. f - ! r· I . Improvements to Mercer Beach. This project would include construction of permanent restrooms, a concession stand, and acquisition of land for construction of a parking lot. Expansion of the park should be considered, should additional land become available for purchase. Timeframe: 1990-1991 Cost: $55,000 (Costs of possible acquisition of land for beach of parking to be determined.) Anticipated Sources of Funding: Quality of life recreation bond funds, LWCF, city general funds. - 91 - �2. Improvements to Sims Park. This project would include acquisition of land for a new access road, construction of an internal drive to provide vehicular access to the back portions of the site, construction of a comfort station, and installation of new recreation equipment . • Timeframe: 1990-1995 Cost: Anticipated Sources of Funding: Quality of life recreation bond funds, LWCF, city general funds. r--~ L, r·~ $185,000 3. L r~ ' Acquire Land for Replacement of Junior High School Site. This project wQuld include acquisition of land plus preparation of a design plan for the new park, grading and seeding, installation of recreation equipment, and installation of fencing and landscaping. Timeframe: To be undertaken when the Junior High School is vacated in 1992. The actua 1 construction would occur over severa 1 years, extending beyond 1995. Cost: $217,000 (plus land acquisition costs to be determined when a potential site is identified) Anticipated Sources of Funding: Quality of life recreation bond funds, city general fund. 4. Improvements to Riley Field. This project would include construction of additional parking, grading, drainage, and re-seeding of the ballfield, and construction of restroom facilities. Timeframe: Cost: 1993 $56,000 Anticipated Sources of Funding: Quality of life recreation bond funds, city general fund. 'l, 5. Improvements to Marshall-Taylor Park. This project would include installation of fencing around perimeter of site, construction of tennis courts and parking, and installation of a cross-walk. Timeframe: Cost: 1993 $91,000 Anticipated Sources of Funding: Quality of life recreation bond funds, city general fund. - 92 - �6. 1- L Prepare Design Plans for New Park at Former Well Site. Timeframe: 1990-1991 (Actual construction would occur over a period of several years, extending beyond 1995.) Cost: I I. .. $8,000 Anticipated Sources of Funding: r L., r-- 1 I \ ., i ( . I. l l . - 93 - City general fund. �27 \ I . ' · ~ LL E D L A KC ~ ] - IMPROVEMENTS TO EXISTING PARKS & RECREATION FACILITIES Ill- NEW PARKS & RECREATION FACILITIES PROPOSED PARKS & RECREATION FACILITIES CITY OAKLAND M!iK.,._ Aa.-oc.JM e a. lnco,oo,et.O C~ y P1air--o • Urban 0.--o,t F" arnw,gtOft..,.,frlillct-oa,n OF MAP 12 WALLED COUNTY • LAKE MICHIGAN _. ~ �ri - ' . t. COMMUNITY FACILITIES ANALYSIS r I • I L , ... i L. The responsibility for providing public services to residents of Walled Lake is shared by several public entities, including the City government itself, various Oakland County departments, various state offices, the Wa 11 ed Lake schoo 1 district, and other agencies. In recent years, the public service base has expanded in response to continued growth and demand for additional services. Anticipated future growth and residents' desires for improved quality of life are likely to create_additional future public facility needs. This chapter of the master plan addresses certain community facility needs which are provided in part or in full by the City. City Administrative Services City government provides essential services for the residents of Walled Lake. These include: fire and police protection; public services such as monitoring of public water facilities and maintenance of City facilities including parks, roads, buildings, and utilities; and the administration of these various functions. The following section describes the public services provided by the City of Walled Lake. City Hall. The City Hall is the center for administrative and legislative functions in Walled lake. The City Hall facility located at 1499 E. West Maple Road was put into use in 1966. The building has approximately 6,000 square feet of floor space on one level. The City Hall houses the City administrative offices including the Manager, Clerk, Treasurer, Building Department, and the City Police Department. The City Hall building shares a 6.54 acre site with a 4,200 square Department of Public Works building, a 2,000 square foot Volunteer Department Building, a 1,800 square foot library building attached to the Hall building on the west side, a small trailer currently used to house the Fire Department offices, and the 0.25 acre Pratt Park site. foot Fire City City Expansion of the City Hall building is required as a result of continued growth in Walled Lake. Space is currently needed for offices and storage areas and will be required for new employees and staff who will be needed to administer and support a larger population. In addition, space will be required to accommodate equipment, such as computers, terminals, and printers which will be needed to efficiently manage the City government. Additional file cabinets, print files, and other type~ of record storage will also be needed. ,_ It is important to look beyond short-term needs and consider possible building space needs in the next two to three decades. The City has outgrown its existing City Hall building after only about twenty years of use. Based on this past rate of growth, it is projected that expansion of the City administrative facilities will be required one or two times during the next twenty to thirty years. It is recommended that the City embark on an in-depth study of the functions of the City to precisely determine the future City Hall building and land area needs. - 95 - �('" i I ' I l' '- ' [ ' Police Department. The Walled Lake Police Department functions from the City Hall. The department maintains 24 hour coverage and currently includes a police chief, 4 sergeants, 1 corporal, 13 sworn officers, and 4 full-time civilian dispatchers .• All officers work on a full-time rotation basis. The Police Department has mutual aid agreements with pol ice departments of adjacent communities including Novi, Wixom, Wolverine Lake, and Commerce and West Bl oomfi el d Townships. Supplemental services including research laboratories, forensics, and marine patrol, are provided by the Michigan State Police, Oakland County Sheriff's Department, and the Michigan Department of Natural Resources. The police department, like other departments located in the City Hall facility, is also currently operating with a deficiency of space and is in need of additional office and storage area. Fire Department. Fire service in the City of Walled Lake is currently provided by the Walled Lake Fire Department and the Walled Lake Volunteer fire Department. The City Fire Department functions from the City Hall site in a trailer adjacent to the City Hall building. The department includes a part-time fire chief and 4 full-time fire fighters. The City Fire Department maintains a mutual aid agreement with adjacent communities similar to that which exists for the police department. The City Fire Department is currently operating with a deficiency of space and is in need of additional office area and storage facilities for firefighting equipment. Plans are currently under consideration by the City for construction of a new fire station to house the Fire Department. The new station is proposed to be located on the Civic Center Complex site west of the City Hall adjacent to Pratt Park. This new facility will provide much needed space for the department and a unified facility for fire department offices and storage of firefighting equipment. l l . The Walled Lake Volunteer Fire Department also functions from the Civic Center Complex site. The volunteer fire department is located in a 2,000 square foot building north of the City Hall building. The volunteer fire department includes 15 volunteer fire fighters and 2 firefighting trucks stored in the departments building. The Walled Lake Junior Volunteer Fire Department also functions from this building. The junior volunteers assist with traffic control at fire call sites, but primarily serve as a training group for the volunteer fire department. Department of Public Works. The physical environment of the City is often the most apparent gauge of the quality and effectiveness of the local government. Responsibility for maintenance of City property, facilities, and equipment is charged to the Department of Public Works (DPW). I L.; I I 1 ·, The Department of Public Works currently includes a full time director, 5 full time maintenance staff, 2 water division staff, and 1 clerical employee. The department is located in a 4,200 square foot building on the Civic Center Complex site west of the City Hall building. The DPW building contains department offices and storage area for City maintenance vehicles and equipment. The DPW currently maintains all City parks, ballfields, recreation facilities, and City properties including City Hall. The department also maintains the City library, cemetery, and services all City vehicles and equipment. All road and sidewalk maintenance, repair and construction, and snow removal for City roads - 96 - �is provided by the DPW. The DPW water division staff currently monitors the City's public water system including maintenance of all lines and water distribution facilities. The existing DPW facility is in need of additional office space and area for storage of materials and equipment. As the City continues to grow, the existing building wi1l have to be expanded or a new facility constructed to meet the increasing demand for services. Li brarY. The City of Wa 11 ed lake operates and maintains a public library ( 1 . ! L. . facility. The library is located at the Civic Center Complex attached to the south side of the City Hall building. The library facility was constructed as part of the City Hall building. An addition to the library building was completed in 1982. The library is currently available for use by residents of Walled Lake and Commerce Township. It is also available to members of the Wayne-Oakland Library Federation with a valid membership card. The library facility is maintained by the City DPW and is currently operating near capacity. Additional space will be required as the City continues to grow in order to maintain the present level of service. Post Office. The local post office serving the Walled Lake area is located along E. West Maple Road in the A&P shopping center, behind the First Federal Savings Bank. A post office facility has been in operation in the City of Walled lake since the mid-40's, and from its current location since the early-60's. An expansion of the post office was completed in 1984 which involved the redevelopment of an adjacent retail store for postal use. f I_ i The post office currently serves the residents and businesses of Walled Lake and parts of Novi, Wixom, Wolverine Lake, Commerce Township, and West Bloomfield Township. According to postal officials, the current post office facility is not adequate in size to accommodate the present and anticipated future postal service demand of area residents and businesses. There has been discussion between U.S. Postal and City officials regarding a new post office facility that may be constructed in the City in the future. Cemetery. There is currently one cemetery in the City Of Walled Lake. The cemetery is located on Pontiac Trail at Ladd Road. It is owned, operated and maintained by the City and contains approximately 7 acres. According to City officials, the cemetery is currently 75 percent full. Although there area some plots remaining, most have already been purchased. Cemetery plots are purchased through the City Clerk. I • Sununary. The foregoing analysis indicates that the City of Walled Lake administrative services are in need of additional office and storage space to adequately operate and serve the needs of City residents. Administrative and service functions located in the existing City Hall, Department of Public Works building, and library facility are currently operating at capacity. - 97 - �The City should strive to provide adequate, centrally located administrative facilities. Toward this end, the following recommendations are offered: 1. A professional architect should be retained to study the office, storage space and land area needs of the City government and to prepare an overall plan for expansion of existing or development of new facilities. 2. Retain all "people oriented" functions, such as governmental and legislative functions, police and fire services, and the library facility, at one location to provide for a centralized civic center complex to serve all residents. Storage and maintenance functions including the Department of Public Works facilities, need not be located at the civic center site. 3. Provide for the development of facilities that will not only satisfy office and storage space needs but that wi 11 promote the image of a modern, forward-thinking government and community. 4. Develop facilities that will provide adequate office, storage space and land area that will meet the long-term needs of the City and provide for expansion of those facilities, if necessary. l' l, Utilities Public Water. Walled Lake has contracted with the City of Detroit Water System since June of 1989 to provide public water for the entire City. The DPW maintains the water lines and distribution system within Walled Lake. No capacity, pressure or service problems currently exist and all areas of the City area adequately served. According to City officials, the capacity of the system is adequate to meet the needs of future development in the City. I.. Well Sites. Prior to contracting for water service with the City of Detroit, the City maintained two well sites that provided water for Walled Lake. In light of the recent switch to contracted water service, the former well sites have been abandoned and are no longer in use. City officials are currently considering alternatives for redevelopment of the former well sites including the dismantling and removal of all structures and apparatus and development of the sites for public use. The well equipment at Marshall-Taylor Park could be removed, graded and redeveloped to provide additional recreation facilities or much needed parking. The well site along Pontiac Trail could be redeveloped for residentail use in accordance with adjacent residential development. Storm Sewers. The City of Walled Lake contains both enclosed storm drains and open ditches. Storm water in the north part of the City discharges into Wolverine Lake. Storm water in the south part of the City ultimately drains into Walled Lake. The Department of Public Works is responsible for maintaining the storm sewer system, except for services along Pontiac Trail and E. West Maple Road which are maintained by Oakland County. - 98 - �,~ I I . I According to City officials, the existing storm water system is currently inadequate in meeting the needs of the City. The existing capacity of the system is deficient and improvement of storm sewer lines is needed community wide. Much of the syste~ dates back to the early-40's and as such, lines are now undersized and cannot accommodate the required flow from existing development. The DPW is continuously maintaining and cleaning the open swale ditches. Flooding problems also exist in the Gamma and Omega Street area, along Appleford Street, and along E. Lake Drive and Leeds Street due to the inadequate size of existing sewer lines. A storm water system ana 1ys is and pl an was recent 1y prepared which provided recommendations for development of future storm water facilities and storm water management, including use of the wetlands for stormwater detention. 1~ Sanitary Sewer Service. The entire City is served by sanitary sewers, although some older residential properties continue to utilize individual septic systems. Walled Lake is a partner with the City of Novi in the operation of the wastewater treatment plant located in Novi on West Road. According to City officials, the existing sanitary sewer system 1ines and treatment capacity are currently adequate to service existing development in the City of Walled Lake. However, the lack of additional sewage treatment capacity may prevent future expansion and additional development in the City from taking place. i I l • l '.J I ' . ' . ·• The City is currently involved in a joint project with the City of Novi for expansion of the existing wastewater treatment plant to provide additional treatment capacity. Expansion of the existing plant is intended to provide enough treatment capacity to accommodate the build-out of Walled Lake and the northern portion of Novi. Sidewalks. In order to provide a ci rcul at ion system that will accommodate pedestrians and bicyclists, the non-motorized modes of transportation, the City of Walled Lake contains a number of sidewalks and safety paths. Concrete sidewalks are located in road rights-of-way throughout the City, and range in size from 3 to 5 feet in width. Most of the sidewalks in Walled Lake are located along Pontiac Trail, W. Walled Lake Drive, E. West Maple Road, and in the downtown area. However, individual segments of sidewalk are scattered throughout the City. Asphalt safety paths within the City are also located in road rights-of-way and range in size from 3 to 5 feet in width. Typically, such pathways are provided in areas in lieu of concrete sidewalks chiefly for their safer construction and recreational benefits. Unlike sidewalks that are constructed in segments with expansion joints, safety paths are continuous and have no dividers. Safety paths in Walled Lake are located along W. Walled Lake Drive, E. Walled Lake Drive, and almost the entire length of Decker Road. The development of sidewalks and safety paths can provide pedestrian and bicycle access to key centers of community activity, such as a school, park, or the City Hall. The location of sidewalks and safety paths in areas where pedestrian, bicycle and vehicle conflicts are prevalent provides added protection for pedestrians and bicyclists. According to City officials, a new sidewalk is - 99 - �n i ,., planned for construction along E. Walled Lake Drive from Fourteen Mile Road to the downtown area. A safety path is proposed to be extended along Ladd Road from W. Walled Lake Drive to W. West Maple Road. Additional sidewalks are also currently being considered along Fourteen Mile Road and portions of Pontiac Trail. The existing safety path along Decker Road is currently under consideration for completion along the entire length of the Road. Sidewalks should be required in conjunction with all new development in the City. The City should consider establishing a program to construct missing segments so as to provide a continuous sidewalk/safety path system throughout the City and to replace sidewalks and safety paths in portions of the City where the existing system is deteriorated. Map 13 illustrates the recommended location for extension of the existing system and construction of new sidewalks and safety paths. In addition, this map identifies the proposed Oakland County recreation path planned along the existing railroad line. A system of recreation paths are planned along abandoned and inactive rail lines throughout Oakland County. I' ' I - i II ~ '·· i . I '. - 100 - �L V ............. _ _ _ __J 21 LL£D LAKE L EXISTING SIDEWALK EXISTING SAFETY PATH PROPOSED SIDEWALK 11111111111- PROPOSED SAFETY PATH ••••••••••• PROPOSED OAKLAND COUNTY RECREATION PATH MAP 13 SIDEWALK & SAFETY PATH PLAN CITY OAKLAND Mg(- OF WALLED COUNTY LAKE • MICHIGAN AhOc:lal.._ lncorp(Hled norffl ~ CooTnuwlyPIWWWIO•UrbMDHlo'I F ~ H i l l.. ~ , I 'J �• II II TRAFFIC AND TRANSPORTATION STUDY EVALUATION AND RECOMMENDATIONS , I f7 ' i r ·, · Summary of Transportation Problems in the City An earlier chapter in this Master Plan identified and documented the major factors contributing to transportation problems in the City of Walled Lake. To reiterate, the major problems are: 1. Lack of Road Hierarchy: There is inadequate separation of local traffic from through-traffic. All major streets serve as both arterials and residential streets. This is an undesirable . situation that deteriorates the adjacent residential environment, contributes to congestion and reduces traffic safety. 2. Through-Traffic on City Streets: A large portion of the traffic flow in the City of Walled Lake is generated by surrounding communities and not by City residents. The City is located in the path of a heavily traveled commuter route serving surrounding communities over which the City has no control. Lack of Road Network: The City's arterial system evolved into a shape of a funnel, rather than a more desirable grid network. Most trips within or through the City are funnelled onto Pontiac Trail. 3. ! . \, 4. Excessive Number of Access Points: Owing to lack of restrictive ordinances concerning driveways and access roads, residents and shoppers can enter the City's arterials almost at any point. This contributes to traffic conflicts, accidents, and congestion. 5. High Volumes of Traffic on Pontiac Trail: The essence of the transportation problem in the City of Walled Lake is Pontiac Trail, in particular its downtown section between E. West Maple and E. Walled Lake Road. This section of Pontiac Trail carries about twice as many vehicles as any other City arterials {about 23,500 vehicles per day in downtown). Much of this flow is through-traffic from surrounding communities. This traffic follows Pontiac Trail due to a lack of alternate east/west and north/south links in the road network. These transportation problems are interrelated. For example, lack of road safety as reflected by the large number of traffic accidents, is a result of a combination of these factors. Large traffic volumes generated outside the City are penetrating local streets and competing with local traffic. The City has no effective means to reduce this outside traffic. The lack of a developed road network forces even more traffic than would have been anticipated under network conditions onto collector streets, and "converts" them into arterials. There is no separation of local traffic from through-traffic on these roads. The problem is further aggravated by the lack of local control over access points (driveways) onto the road system which is dominated by through-traffic. - 102 - �• r' ' I I \ n !. r~ I I I. r -- j r I i, Proposed Alternative Actions Overview The transportation problems in the City of Walled Lake are in a large part due · to traffic generated outside the City, over which the City has no effective control. Changes in land use inside the City are expected to have only marginal impact on the overall traffic generation and traffic flow on the roads in the City. Thus, in order to improve traffic circulation and road safety conditions in the City of Walled Lake, the consulting team evaluated a set of alternatives which would improve the channeling of through-traffic. These actions, described below, introduce links into the road network which are intended to divert traffic from existing roadways, and allow for a more efficient traffic flow throughout the City. In addition, the development of a "collector" road system on currently undeve 1oped parce1s of land and the adoption of more restrictive driveway ordinances by the City would enhance the effectiveness of these alternatives. The expected impact of this set of alternatives was evaluated using a transportation network computer model (QRS-II} developed by the U.S. Department of Transportation. The impact _of more restrictive ordinances concerning driveways and collector road system cannot be modeled accurately. However, experience has shown that if adopted they would enhance traffic safety. Recommendations To Improve Traffic i - The following alternative actions were evaluated using a network computer model. These actions are not mutually exclusive. Each alternative was modeled and evaluated separately as well as in combination with other alternatives. 1. Construct a Maple Road Connector \ l_ r - ! -~ ,' ,_ In this alternative, a three lane Maple Road Connector between the intersection of E. West Maple Road and Pontiac Trail on the east, and the intersection of W. West Maple Road and Ladd Road on the west is proposed. The purpose of this Connector is to provide for a direct east/west link, and reduce the pressure of through-traffic on Pontiac Trail. The Connector will consist of one lane in each direction, with a middle turning lane. The Maple Road Connector will enhance the road network by providing a east/west link in the City. The only discontinuity of Maple (Fifteen Mile) Road, between Kensington Metro-Park in the west and St. Clair Shores in the east, is in the City of Walled Lake. - 103 - �, • 2. i This alternative calls for increasing capacity on the downtown portion of Pontiac Trail, between E. Walled Lake and Coe Railroad. It is proposed that t his section be widened to five lanes, from the current four lanes. The additional middle lane would be used as a turning lane. It is estimated that this arrangement could increase the capacity of this section by 15 to 18 percent. In addition, this turning lane is expected to improve traffic safety. I r Owing to regional historical travel patterns and existing land use, it is estimated that Pontiac Trail will continue to serve as the major arterial and focal point within the City in the future, even if some traffic could be redirected to other arterials. This portion of Pontiac Trail will continue to serve as the spine of Downtown Walled Lake. Frequent access and egress trips by local shoppers, general local traffic, and regional trough-traffic are expected to dominate this strip. I l ', ,.. !l , I Increase Capacity on Pontiac Trail ' The new turning lane would help to reduce conflicts between the through-traffic drivers, who wish to pass through quickly, and the local shoppers and residents, who need to make turns and stops. 3. I, I . i l l , Close E. Walled Lake Road to Through-Traffic E. Walled Lake Road surrounding the lake is a narrow road which- abuts residential, commercial, and recreational land. The City of Novi, which has jurisdiction over the southern portion of E. Walled Lake Road, between 14 Mile and 13 Mile Roads, is in the process of closing it to through-traffic within it's city limits. When Novi closes off its portion of the road, south/north traffic diverted from E. Walled Lake Road in Novi could enter E. Walled Lake Road in the City of Walled Lake, via Decker and 14 Mile Roads. Closing E. Walled Lake Road in the City of Walled Lake to through-traffic would be a complementary action. Furthermore, this action would also convert E. Walled Lake Road back to its original function as a collector roadway. Thus, this alternative calls for closing E. Walled Lake Road to through-traffic approximately at its intersection with 14 Mile Road. E. Walled Lake Road will be closed to north/south traffic at the boundaries of the City of Walled Lake with the City of Novi (at 14 Mile Road), and to east/west traffic at the intersection of Decker and 14 Mile Roads. It is expected that the south/north through-traffic that is currently using E. Walled Lake Road would be re-channeled to Decker Road. The east/west traffic will be diverted via Decker Road to E. West Maple Road and the proposed Maple Road Connector, onto W. West Maple Road. It is also expected that some of this through-traffic would be diverted onto the proposed Haggerty Road Connector east of the City of Walled Lake. - 104 - ' \, ii �, • 4. (: i I r --, Extend S. Commerce Road Southward to Intersect E. West Maple Road This action calls for extending S. Commerce Road southward past its intersection with Pontiac Trail to E. West Maple Road. The extension, like the rest of S. Commerce Road, would be two lanes. Currently, S. Commerce Road feeds and receives traffic from the Pontiac Trail funnel. This extension could distribute some of the traffic, which would otherwise use Pontiac Trail, onto E. West Maple Road. It would also help to build the desired road network by adding a north/south link. Furthermore, this link, connected to a new "collector" would open the triangular land parcel north of Coe Railroad, between Pontiac Trail and Decker Road for development. The new collector would facilitate the development of a road hierarchy in the City. I1 .., Evaluation Methodology Overview The four alternative actions to re-channel through-traffic in the City and provide for a more efficient circulation were evaluated with the aid of the QRS- II network-based computer program, deve 1oped by the U.S. Department of Transportation. With the aid of the QRS-II program, the consultant estimated the traffic volumes on the City's arterials resulting from each proposed action. The impacts were estimated in terms of Average Daily Traffic (ADT) separately for each proposed action, and for combinations of proposed actions for two time periods - the present or Base Year, and the future (2010). The input for the present or Base Year conditions was based on information provided by the City of Walled Lake and from the latest traffic counts available from the Oakland County Road Commission (OCRC). Most of these traffic counts were made between 1987 and 1989. Because no major changes occurred in the regional transportation system between 1987 and the present (1989), these data are considered a good approximation for present or Base Year conditions. The year 2010 was selected as a medium-range future point. Experience has shown that a 15 to 20 year time period is the maximum for which estimates could be made with reasonable degree of confidence. Also the year 2010 is the "design year" for the Haggerty Road Connector - the most important transportation improvement project in the vicinity of the City of Walled Lake, and the one with the most profound impact on traffic in the City. It is expected that by 2010 all of the recommended changes in land use in the City, and consequently changes in trip generation, would have been fully realized. On the following pages, estimates are presented in both tabular and in "width-band" graphical forms, and compared against the "bench-mark" of the Base Year daily traffic volumes. Then, the impacts and consequences of the estimated traffic volumes resulting from the proposed actions are discussed, and recommendations are made. - 105 - �, ■ r- t 1· The Computer Hodel The computer model used in this analysis is the Quick Response II (QRS II), prepared for the Federal Highway Administration (FHWA), U.S. Department of Transporta~ion, and distributed by AJH Associates of Milwaukee, Wisconsin. I' I' The QRS-11 is a micro-computer program for forecasting impacts of urban development on highway systems and of highway development on travel patterns. QRS-11 employs a state-of-the-art set of theories and models which are comparable, for the most part, to main frame computer programs such as the Urban Transportation Planning Systems {UTPS). QRS-11 uses the established modeling sequence consisting of Trip Generation (Trip Production and Attraction), Trip Distribution, Mode Split, Conversion of Person Trips to Vehicle Trips, and Traffic Assignment. l ..: The original QRS was first introduced in 1978 as a set of manual procedures to estimate impact of changes in land use on the highway system {and vice versa) in a National Cooperative Highway Research Program (NCHRP) Report by the Transportation Research Board of the National Research Council (NCHRP, 1978). In 1981 the FHWA released the first micro-computer version of QRS, the QRS-1, which simply adapted the manual calculations for micro-computers. f . I i QRS-11 is an entirely new and updated implementation of the original QRS. The main difference is that QRS-11 has become a network-based computer package with a General Network Editor {GNE). The GNE allows the user to draw a transportation network on a computer screen, add descriptive and numerical information to each node and link on the screen, and edit the data as necessary. The combination of the GNE with established modeling procedures makes the QRS-11 a powerful and convenient analytical forecasting tool. The "short-cuts" that QRS-11 uses {and hence the term "quick" response) are that it employs fixed matrices of production and attraction rates (based on national averages) for three trip purposes: Home-Based Work (HBW) trips, Non Home-Based Work (NHBW) trips, and Non-Home-Based (NHB) trips for four categories of population of metropolitan areas {<100,000, 100,000-250,000, 250,000-750,000, and >750,000). It also employs matrices of auto occupancy rates and distribution parameters for "trip-distribution" based on these three trip purposes and four sizes of metropolitan areas. The various rates used in this analysis are included in the Appendix. The Network Hodel: Zones, Nodes, Links, and External Stations L. I I J . ' L.. The QRS-11 is a zonal simulation model. The study area (i.e. The City of Walled Lake) is divided into sixteen transportation zones. Each zone is represented by a centroid, which is a profile of the average socio-economic characteristic of that zone, translated by QRS-11 into vehicle trip production and attraction rates. Traffic from outside the boundaries of the study area is generated by external stations (i.e. Haggerty and Maple Road). The model includes a transportation network consisting of major arterials in the city (i.e. Pontiac Trail, Maple Road, Decker, etc.) Each section of an arterial is bounded by two nodes, and is called a link. Centroids and external stations - 106 - �I ~ -I ---- :---J -7 i~-:·:7 - - 7 ,\ ' LEGEND Zone Boundary @ Zone Number 3Q _ i ! ~'-./,...,....- TRANS PO RT ATION ZONES CITY OF WALLED,._~~ LAKE ....,... ,,..,....,.__ ...,......._..._.,... cH,- McKENHA ASSOCIATES, IHCORPOAATt:D •"'"""""''""""'"" fwmtngton Nit llttoon .. ,19n tnk:hi8an • OAKLAND COUNTY • MAP 14 MICHIGAN m..nn ,- �Ill l ~ .:7 ,)) ~j .----""' .. J ---,..J • ,_7 ,--." ' j LEGEND link Centroid Connector ® - Zone Centroid External Node 119Qll - ,.@. . . . . . ........ ,,, ...... ,, . ; , .., 27 11>\.t.••··'J.tc,,.. , 1,1-at =~--LL.; :3 6 LL{O i IIII ,.....I,I....b:o t ~ . •"' I i Irun L~K{ ~-'J!J.: i ! ~ TRAFFIC IMPACT ANALYSIS CITY OF WALLED ..,...LAKE "·"'·•.._...... WcKE~A ASSOCIATES, IHCORPORATIED cOfflfflUnlly ~ urb.., dH~ ,.,-rNr\glon hlla mlcNgan ........ f,.,....-,,1.1_,. AftatrMe ,._. ......... cht."" • OAKLAND COUNTY • MAP 15 MICHIGAN lJlfl- n .-- - ·.1 �,. • co ,- r I I I I '· , ci ·. i . I • lL I • 0 >- <(~ _Ja: 350 OS zl- - ' I r r tr ... •-1 .- y ■ I • J • .. I I . • -.. I I. ww wZ a:w OJ: Cl)f- �, ■ ,i ' are connected to the network by a "simulated link" called centroid connector. If the network is built to scale, QRS-11 computes travel time on each link. l- r- COMPUTER MODEL INPUTS AND OUTPUTS 1 Required Inputs: Zones - (1) Household income, or (2) Auto ownership, (3) Retail Employees, (4) Non-Retail Employees, (5) Housing Units, and (6) Intrazonal Travel Time. External Stations - {l) HBW Production, (2) NHBW Production, (3) NHB Production, (4) HBW Attraction, (5) NHBW Attraction, and (6) NHB Attraction. Node - Type (real, imaginary, with or without penalty at intersection, centroid etc.). Link - Type (one-way, two-way, real, imaginary, etc.). Optional input includes speed, travel-times, and capacity (vehicles/hour/per direction). Outputs: r, The outputs of the QRS-II model include directional ~olumes on each link, turning movements, production and attraction volumes at each traffic zone, minimum paths, etc. The output sought in this analysis was daily traffic volumes on each link. For detailed information on QRS-II see NCHRP Report 187,(NCHRP, 1978) and the QRS-II Reference Manual, Version 2.3.l and GNE, Version 2.6 (AJH Associates, 1989). Application of Model to Walled Lake The Walled Lake Network The base QRS-II model of the transportation system in the City of Walled Lake Consists of: I !,_ ' . 16 8 88 74 Transportation Zones External Stations links Nodes The boundaries of the 16 transportation zones and the 8 external stations are shown on Map 14. An outline of the road system used in the model network is provided in Map 15, and a screen image of the network is shown in Map 16. The model was drawn to scale, at 96 pixel per mile, so the QRS-II could automatically compute travel time on each link. - 110 - �, • r. The definitions of traffic zones, centroids, and external stations remain identical under all of the alternatives that were evaluated. The number of links varies slightly from alternative to alternative, since connectors and extensions are modeled as links and their addition or exclusion changes the total number of links in a particular run of the model. As noted earlier, the model was used to evaluate impacts of the following actions: 1. 2. 3. 4. L. Construction of the Maple Road Connector Increased capacity on Pontiac Trail Closing E. Walled Lake to through-traffic Extension of S. Commerce Road to intersect with E. West Maple Road Also, the impacts of various combinations of these actions were evaluated. Traffic volumes resulting from these proposed actions were obtained for the Base Year and future (2010). Inputs 1. Zones Base Year. (1987): The following were the inputs sources for the base period Production/Attraction Rates. The model used rates based on national averages, for a city with population up to 50,000. These rates apply to trip production, attraction, car occupancy, and trip-distribution parameters. All rates and parameters used in this analysis are listed in the Appendix. Socio-Economic Characteristics ''· ' . Housing Units - The City of Walled Lake Building and Community Development personnel provided the consultant with estimates of the number of units in multiple housing projects (apartments and condominiums) by each traffic zone. The number of single family units in each zone was estimated by examination of the City zoning map. Employment (Retail and Non-Retail) - The City of Walled Lake Building and Community Development personnel provided the consultant with estimates of the number of retail and non-retail employees in each traffic zone. Income - Income per household, in 1980 dollars, was derived from the 1980 Census of Population, Block Statistics. Auto Ownership - QRS-11 estimated auto ownership internally, based on user-supplied household income. - 111 - �The Future - Year 2010. 2010: I The following changes were assumed for the year Hous i nq and Emo 1oyment. Changes were derived from estimates by McKenna Ass.ociates Inc. for the revised Master Plan. Overall change in intensity of housing and employment is expected to be relatively small. Employment and housing is estimated to remain the same for the year 2010 in 11 out of the 16 zones. • The more significant growth is expected to occur in zones 2, 6 (north of the Coe Railroad, between Ladd and Decker Roads), and in zone 7 (west of downtown, including expansion of Textron and the development of an industrial park). Otherwise, the situation will remain quite the same. 2. External Stations Base Year Average Daily Traffic (ADT) information was converted into daily trip productions and attractions, in vehicle-trips, for the three trip purposes: Home-Based Work (HBW), Non-Home-Based Work (NHBW), and Non-Home-Based (NHB). The ADT information was based on OCRC traffic counts, whenever possible, or derived from 1989 intersection turning counts collected by the consultant. Time-of-day distribution of trips (AM and PM peak, midday, and evening and night) was based on available hourly distributions from the OCRC traffic counts. Table 28 shows the time-of-day distribution by trip purpose. TABLE 28 TRIP PURPOSE DISTRIBUTIONS BY TIME-OF-DAY Time Period AM Peak PM Peak Base (midday) Evening/Night % HBW % HBNW % NHB 90 75 10 10 10 13 45 70 10 12 45 20 HBW = Home Based Work HBNW = Home Based Non-Work NHB = Non-Home Based - 112 - �The Future - Year 2010. Trip production and attraction of the external station for the base year were expanded to account for future growth in intensity of land-use, and consequently in traffic surrounding Oakland County ¼ommunities. ,.-- . ( ! ' l The growth rate was adopted from estimates developed by the Draft Environmental Impact Study (DEIS) for the Haggerty Road Connector (MOOT, 1989). It was assumed that the relative distribution of vehicle-trip production and attraction for the three trip purposes (HBW, HBNW, NHB) for each external station will remain unchanged. ... I At this time it is not clear whether the Michigan Department of Transportation will select the Haggerty Road Connector alternative which generally follows the existing alignment or which follows a new alignment west of the present Haggerty Road. (See previous Traffic and Transportation Inventory chapter for discussion of the Haggerty Road connector alternatives.) Therefore, the average of the growth rate estimates from these two alternatives has been used to estimate the increase in traffic on Pontiac Trail and E. West Maple Road. ,., I • I The estimated growth for Alternative 1 of the Haggerty Corridor Study, namely the "no change from the present" was used for the other extern a1 stations. This growth is attributed to increase in intensity of land use in the vicinity of the Haggerty Road corridor, and not to the improvement on Haggerty Road itself. I. Table 29 shows the estimated changes in ADT's, and the corresponding growth ratios, adopted from the DIES for Haggerty Road. 3. Links I • The road capacity of City links followed, in general, the Highway Capacity Manual (Transportation Research Board, 1985) guidelines for urban arterials at approximately Level of Service (LOS) "C." The consultant assumed these capacities: , a. 550 vehicles/hour/direction on a two-way two-lane street . b. 1100 vehicles/hour/direction on a two-way four-lane street (e.g. Pontiac Trail in downtown) c. 700 vehicles/hour/direction on a two-way, three-lane street (e.g. E. West Maple Road) d. 1300 vehicles/hour/direction on a two-way five-lane road (e.g. improved Pontiac Trail in downtown) In addition, the model assumed a system-wide average travel speed of 20 miles/hour, and a penalty of .25 minute for a left turn . - 113 - �TABLE 29 I ' AVERAGE DAILY TRAFFIC (ADT) IN . THE HAGGERTY ROAD CORRIDOR 1987 AND 2010 , . ' : t, 1987 2010 Growth Ratio AND MAPLE Maple (Alt 3)* Maple (Alt 4)** Maple (Ave. of Alt 3 & 4) 18,100 18,100 18,100 26,600 31,600 29,100 1.47 I. 74 1.61 Pontiac Trail (Alt 3) Pontiac Trail (A 1t 4) Pontiac Trail (Ave. of Alt 3 & 4) 13,400 13,400 13,400 21,800 35,400 28,600 1.62 2.64 2.13 NORTH/SOUTH ON HAGGERTY (ALT 1) 12 Mile to 15 Mile 15 Mile to Pontiac Trail Pontiac Trail to Richardson 26,100 24,400 22,400 41,700 37,900 35,800 1.60 1.58 1.60 CROSSROADS (ALT 1) 14 Mile 15 Mile Pontiac Trail 18,000 18,100 13,400 31,200 31,400 23,300 I. 73 1. 73 I. 73 PONTIAC E. West E. West E. West .. I * Alternative 3 - Haggerty Road follows existing alignment ** Alternative 4 - Haggerty Road follows new alignment, west of the existing road Source: DEIS Haggerty Road, Tables 1-1 to 1-4, pp 1-9 to 1-12. Assignment The traffic assignment module of the QRS-II assigns vehicles trips to each link. In simple terms, the objective of the assignment model is to load the trips onto the network in a way that will minimize the travel time of each trip in the system. The specific model used in this analysis is the "Iterating Capacity Restrained" version of the "Equilibrium Traffic Assignment." "Capacity Constraint" refers to the incorporation of congestion and road capacity into the model. When the system is in equilibrium, travel time between any two centroids on alternate routes is equal (and there is no apparent reason to prefer one route to the other). The equilibrium solution is obtained through an interactive procedure. A 10 iteration assignment process was used, and the capacity/volume parameter was set to a level which simulates congested conditions. - 114 - �Calibration The first step, prior to forecasting traffic volumes associated with each proposed action, involves the calibration of the model. The model was calibrated to match its output of average daily link-volumes with the base year . daily traffic volumes. The calibration allowed for a tolerance of up to 15 percent between the base year volumes and the model results. However, this difference in the final calibrated model was less than 10 percent on most links. In other words, the calibrated model replicates the base year traffic conditions to within 10 percent, which is a very reasonable model fit. Model Results for the Proposed Actions Overview The computer model provides Average Daily Traffic volume (ADT) estimates for the major arteria 1 1inks for each of the proposed actions and for their combinations for the Base Year and for 2010. Results for the separate actions for Base Year and 2010 are presented in Tables 30 and 31. Results for combinations of actions for the Base Year and 2010 are presented in Tables 32 and 33. The results of several alternatives are also presented graphically in "band width" maps. The impact of the alternative actions for the Base Year illustrate what the transportation system would be like if these improvement were in place right now. Results for the year 2010 illustrate what the impact of these improvements would be twenty years from now, after the transportation system adjusted to these and other changes in the region. The left column of Tables 30 through 33 lists the name of the link for which ADT's were estimated. The next column gives the Base Year traffic volumes derived from the latest actual traffic counts by the OCRC. These volumes are shown graphically on Map 4 and are set forth in Table 19, presented earlier in this document. These values of ADT provide the benchmark for comparison with the traffic volume estimates produced by the model. The subsequent columns in Tables 30 through 33 display the model results for the various alternatives. ' . The measure of comparison of the ADT for each link and its value for the Base Year conditions is given as the ratio of the estimated ADT to the "bench-mark" Base Year ADT. This ratio is shown in the second column of each table, and is labelled "Ratio to BY". An overall impression of the impact of an alternative action can be easily made by examining the "Ratio to BY" figures. A ratio of 1.00 implies no change compared to the present. A value above 1.00 indicates an increase in traffic over the Base Year conditions; the decimal places give the percent growth. A value below 1.00 indicates a corresponding decrease in traffic volume on the link. It should be noted that a change in the range of -10 percent to +10 percent could be attributed to modelling error, and not necessarily to real change. - 115 - �Impacts of the Separate Actions The impacts of the proposed actions on traffic volumes is summarized below. Details for each link are shown in Table 30 for the Base Year and in Table 31 for year 20l0. Maple Road Connector t ' '' I ' ' I. i ' ' The estimated ADT's upon construction of the Maple Road Connector for the Base Year are shown in Table 30 and Map 17. The most important change is that the Connector is estimated to carry 12,208 vehicles per day. Most of these trips will be diverted from Pontiac Trail between W. Maple Road and E. Walled Lake Roads. Traffic on this section of Pontiac Trail will be reduced by a third, from 32,565 to 15,760 ADT (ratio of 0.67). Other changes related to this improvement are: 1) a reduction of approaching traffic on Pontiac Trail, between S. Commerce Road and Maple Road, from 19,677 to 16,035 (ratio of 0.81); 2) reduction of traffic on W. Walled Lake, between Pontiac Trail and Angel Street from 9,139 to 6,951 (ratio of 0.76); and 3) a slight increase in traffic on E. West Map 1e Road, about 13 percent , between Decker Road and Pontiac Trail . Slightly more traffic will be attracted to E. West Maple Road because of the direct east/west route provided by the Connector. Pontiac Trail between S. Commerce Road and E. Walled Lake Road is the most critical segment according to the Base Year traffic volumes, accident reports, and Level-of-Service analysis. This section of Pontiac Trail had the lowest Level-of-Service in the City. Thus, reducing traffic volumes by 24 percent on Pontiac Trail between S. Commerce Road and Maple Road, and by 33 percent between Maple Road and E. Walled Lake Road, would be very beneficial. This would reduce congestion, and improve the Level-of-Service and highway safety. Table 31 shows that by the year 2010, without the Maple Road Connector or any other road improvement, traffic on Pontiac Trail from E. West Maple Road to E. Walled Lake Road will increase by 38 percent. In contrast, if the Connector is constructed, the traffic on the same segment of Pontiac Tra i 1 wi 11 remain virtually at the present level . This indicates that Maple Road Connector is highly desirable. Widen Pontiac Trail in Downtown to Five Lanes Widening Pontiac Trail between E. Walled Lake Road and Coe Railroad would increase the capacity of the road by 18 percent. Including this change in the model yielded only slight variations from the ndo nothing" alternatives for both the Base Year and the year 2010. The reason for this is that the model is not very sensitive to small changes in capacity constraints. The ADT results are almost the same as for the Base Year conditions and the do-nothing conditions in 2010, and are not shown in the tables. Nevertheless, the extra turning lane is highly desirable for reducing congestion and traffic accidents on segments where volumes are presently approaching capacity during the peak period, and are expected to grow in the future. The extra lane will improve the Level-of-Service on this segment of Pontiac Trail. Hence it was included in the analyses of proposed combined actions. - 116 - �,_.. ...... -- -- - I.. I .... ) ---~ . j :-7 ~ TABLE 30 IMPACT OF PROPOSED ACTIONS ON AVERAGE DAILY TRAFFIC VOLUMES (ADT} ESTIMATES FOR BASE YEAR INDIVIDUAL ACTIONS Maple Connector Bas:e ACTIOt~ '(ec1r (BY) _____ -----------PONTI AC TRAIL ...... ...... " to BY ------------ ---------- __________ _,. ADT to ElY AOT to BY 10532 10826 16035 ' 15760 -13891 0.92 1.08 0.81 0.67 0.98 10730 12775 17313 27101 15009 1135:3 1265:3 1265:3 139€:6 14350 14350 122(18 1.23 1.13 1.13 13394 18577 na na 10611 913'1 . 10471 0.99 0.76 4349 12927 0.41 6961 14 Mi le t.o E. West Mc1pl,aa 14502 Maple to P. Trail 10896 P. Tr.ail to S. Commerce 7838 116Sl9 11617 asea 0.81 1. 07 1. 13 18917 11552 8347 1.30 1.06 r,a 96=:5 na 0.96 na 10426 S. Co,nmerce to Pontiac Mai:,l e Conne,:tor n.3 Ratio Ratio Ratio 11451) 10015 196TT 2::565 14221 E. ~JEST MAF'LE l~e le h to De,:ker Decker to S. Com,nia-rce- E:i<tend S. Coa1Mt=rceto Maple TraPf'ic: LIN~: Welch to Oe-:ker Decker to s. CommerceS. Co,nrnerce to Maple Maple to w.lled Lake Wal led Lake to Sh,::,rel iM• Clos&E. ~Jal ld Lk to Thro1J9h 18577 0.94 1.28 0.88 1. 15 1.06 1. 18 1.47 1.47 na ROT _... 10674 11546 12314 25276 15228 0.93 1. 15 0.63 1.07 1.07 13722 13168 16843 1.21 1. 04 1. 33 N na W11LLED LA~:E . 14 Mile to P. Trail P. Tr~il to Angle 1.41 10489 13476 0.99 1.47 11373 9966 7849 0.78 0.91 1.00 9502 10920 1.09 DECl<ER S. CC1MMERCE Extension <Maple to P. T na P. Tr.ail to Decker 10001) rt 1.06 na 1.04 na --.J ,... ·-1 �-_-.-:-7 j TABLE 31 IMPACT OF PROPOSED ACTIONS ON AVERAGE DAILY TRAFFIC VOLUMES (ADT) ESTIMATES FOR YEAR 2010 INDIVIDUAL ACTIONS Ba!:e ACTIOH '(e;.,r <B'r') Lrn~~ -------------P0HTIAC TRAIL ...... ...... 00 We le h to De,:ker Decker to S. Commerces• . Co111merce to Maple Maple to Walled lake Wal led Lake to Shorelin•~ FtDT YR 2010 With H,, Ct-,ange in R,,ad Sy:;tem in City of w.alled Lake Ratio to BY A0T ------ -----------11450 1(1015 151677 2::565 14221 Maple Connector AOT 1,16 1.38 1.52 17168 14462 23490 23026 19'~19 1.44 1.44 Ratio to BY ACIT ":atio to BY ---------- ---------- ----- 144E,8 ·22011 .326::0 216(12 16519 Clos~ E. w.allcl lk tc, Thruc,g h Traffic: 1.5(1 1. 44 1,19 0.9E: 1.40 16753 16675 23578 ::22:27 ~:1346 E>,tend S. Commerce to Maple Rcati,, to ____ B'l' _,. ________ _...., AOT 1.46 1.67 1.20 1.37 1.50 1€,340 1€,042 1926'3 . 34037 21710 1.43 1.60 0.'38 1.44 1.53 1.86 1.91 1.91 1. :39 1.57 1. '32 na 21414 1s1a9s 24361) n.:11 E. ~JEST MAPLE Welch to De,:ker Decker to S, Cc,mmerceS. Cornmerce to Pontiac Maple Conne,:tor- 1135:3 1265:3 1265:3 n-:11 21310 207E:7 207E:7 1.88 1.64 1,64 r,a 22301 22146 22146 1. 9€, 1. 75 1.75 na 15635 nc1 ~:1078 24162 24162 na WALLED LA~:E 14 Mile to P. Trail P, Tr.ail to Angle 10611 9139 . 162(16 193E:3 1.53 2,12 15773 11508 1.49 1. 2E, 5451 19162 0.51 2.10 lE,320 21711) 1.54 2.38 0EO:ER 14 Mile to E. West Me1plti 14502 t1apl1t to P. Trail 10896 P. Tr.ail to S, Com,ner·ce 783:3 15234 155=:2 1207'3 1.05 1.43 1,:54 14791 16509 12172 1.02 1.52 1.55 2031)0 15302 12194 1.40 1.40 1.56 15563 1'.::843 11578 •- 1.0? 1 ..,., 1 .48 S. COMMERCE Exten:;ion <Maple to F·. T na 1(1()00 P, Tr-3i l to Decker r,a 13292 na 1.33 na na 1. 31 na 13800 na 13071 1.38 15162 14577 1.46 na • .... I na ---·,J �r •~-- [ \ r· . - ; --] ,·--7 ,-- -··-, '"7 :=--7 LEGEND lii'l):i:!iiMi1\I\\@\~\l 10,000 Vohlclo~Day "''"''' .... ..... ' ...27 ,., ]6 BASE YEAR ADT WITH THE MAPLE ROAD CONNECTOR CITY OF WALLED LAKE lloKEHNA AISOCIATEI, INCORPORATED oOfflfnLWltlw ~ I nan dH~ f.,-.nlnttonhllt 11\khlgM ... ....,. "--'"• A.Ned, .... ,,..,.,.....A,,........ Alwit,.., .,.,_ , • OAKLAND COUNTY • MAP 17 MICHIGAN lJlJl - n .-- �, ■ i. l ,· Close E. Walled Lake to Through-Traffic Table 30 and Map 18 show the estimated traffic volumes in the City if E. Walled Lake was closed to through-traffic this year. Table 31 gives the estimated ADT as a resul t of this closure in 2010. The assumptions of the model for the Base Year and for 2010 are slightly different. For the Base Year the model assumed that the E. Walled Lake through-traffic would be diverted to an adjacent nearby route, such as Decker Road. By year 2010, it was reasoned, other routes would be found and the potential through-traffic would be distributed throughout the road system and not all onto Decker Road. The model results show that the greatest impact of the E. Walled Lake Road closing will be, as expected, a dramatic reduction in traffic on E. Walled Lake Road from 14 Mile Road to Pontiac Trail. It is estimated that this reduction would be 41 percent in the Base Year and 51 percent in 2010. In other words, this action would reduce traffic from more than 10,000 ADT to 5,000 or less, and succeed in converting this street to a local "collector" rather than a regional arterial. i. However, this proposed action will have negative effects on other segments of the road system in the City. Because of regional traffic patterns which result in east/west traffic throughout the City, the closure of E. Walled Lake Road will result in diversion of traffic, first to Decker Road (14 Mile Road to Maple Road) and then to E. West Map 1e Road (S. Commerce Road to Pontiac Trail ) , Pontiac Trail (Map 1 e Road to E. Wa 11 ed Lake Road), and back westward to W. Walled Lake Road (Pontiac Trail to Decker Road). The increase of traffic on these road segments in the Base Year would be 30 percent on Decker, 47 percent on E. West Maple Road, 15 percent on Pontiac Trail, and 47 percent on W. Walled Lake. By the year 2010, the increase of traffic on these road segments is estimated to be 40 percent, 91 percent, 37 percent, and 110 percent respectively. Even though this proposed action is desirable as far as E. Walled Lake Road is concerned, the estimated traffic volumes are too large for either Decker, West Maple, or Pontiac Trail to carry at their present configurations. The ADT on Decker Road between 14 Mile and Maple Roads would increase to about 19,000 in the Base Year, and to 20,000 in 2010. Decker Road currently carries 14,502 vehicles. Widening of Decker Road to three or four lanes from its present two lanes would be required. Similarly, widening of E. West Maple Road to four lanes would be required if traffic increases from the current 12,658 to 24,162 in 2010. i I I ',. Because of the estimated large increase in traffic on nearby roads resulting from the closure of E. Walled Lake, it is recommended that this alternative not be implemented alone. If implemented, this closure should be part of a larger strategy, involving other recommended actions. Extend S. Convnerce Road to E. West Maple Road This action is part of the recommended strategy of building a more complete traffic network in the City. It would have the added benefit of opening up the triangular area north of Coe Railroad, between Decker Road and Pontiac Trail, - 120 - �r-· r-----~ f l I I '<- ~ - ---II---~- - - --:--1 r··:7 C-::7 -------, J +-- - - - - l LEGEND i! i! i! I Ii! !i !ii'!!' ll: 10,000 Vehicles/Day ;1!! ~~ ~ JLJ( .;:~::: rr ri~t//1,· I CD "'-~ & ,/ 36 I l 4~E ·11~ BASE YEAR ADT UPON CLOSURE OF E. WALLED LAKE DRIVE CITY OF WALLED LAKE ,._.,.,_,.......,....., .... McKENNA AS.SOCIATE&, .. COAPOAATEO communHy plfnntng urbtn de•91 ,.,m1ng1on NI• rnlc~an T,w+.,..,-.01-~ ,._A,,._,...,,... • OAKLAND COUNTY • . MAP 18 MICHIGAN lfU7U .-- - ·- �, • for development. The objective is to complete this link of S. Commerce Road, and connect it to a new collector in the triangular area, as part of a strategy for developing a road hierarchy. {; I l . l l - It is estimated that if the S. Commerce Road Extension was in place now, it would carry ,9,502 vehicles per day. In the year 2010 the AOT is estimated to be 15,162. At the present time, this extension could reduce traffic on Pontiac Trail between S. Commerce Road to Maple Road by 37 percent, and divert it onto Maple Road between S. Commerce Road to Maple Road, resulting in an increase of 33 percent on this link. Other impacts would be relatively small. Impacts of Combined Actions t. ' i I l . The individual actions cited above were combined together and evaluated by the computer model for the Base Year and 2010. Since there are 10 possible combinations of the 4 actions and since the analysis of the individual actions identified the Maple Road Connector as having the most positive impact, all combinations tested included the Maple Road Connector. The combinations tested are: 1. Adding the Maple Road Connector and widening Pontiac Trail between Walled Lake Road and the Coe Railroad to 5 lanes. 2. Adding the Maple Road Connector, widening Pontiac Trail and extending S. Commerce Road to E. West Maple Road. 3. · Adding the Maple Road Connector and closing E. Walled Lake to throughtraffic. I, ' 4. Adding the Map 1e Road Connector, widening Pontiac Trail , extending S. Commerce Road, and closing E. Walled Lake Road to through-traffic. Table 32 shows the Base Year AOT on the major road segments in the City. resulting AOT values are compared to the Base Year values. I I \ . The Examination of the results for the Base Year shows that constructing the Maple Road Connector and widening of Pontiac Trail produces extremely good results. Traffic volumes will be substantially reduced on Pontiac Trail. Additionally, the turning lane on Pontiac Trail will enhance the Level-of-Service and traffic safety. Adding the S. Commerce Road Extension to the above two actions does not significantly change the estimated traffic volumes on the major road segments in the City. The merit of this action is in opening up an area of the City for development and for improving local circulation. The combination of the Maple Road Connector and the closing of E. Walled Lake Road to through traffic will produce an increase of traffic in the eastern part of the City on Pontiac Trail, E. West Maple Road and Decker Road. The benefits. of this combination are not as great as from the previous two combinations when traffic volumes are considered. The chief merit of this solution is that it changes the function of E. Walled Lake Road to that of a collector street. - 122 - �0 - -7 ft TABLE 32 --- IMPACT OF PROPOSED ACTIONS ON AVERAGE DAILY TRAFFIC VOLUMES (ADT) ESTIMATES FOR BASE YEAR COMBINED ACrtONS AC:TIOH Bas:e 'teer M.31ple, C,:mne-ct,,r &: J.lidei1 P. Tr·ail Maple Connector ec Widen P. Trail Ix Extend S. Co1T1merce Maple Connect.or Ix Clo:3e E. I.Jal 1ed Lk <B'r') LmK I--N w -----TRAIL POHTIAC Uelc:h to DeckerDecker to S. Commerces. Commerce to Maple Maple to Walled Lake· l~alled Lark~ to Shoreline E. I-JEST MAPLE l~elch to De,:kerDeck er tc, S. Cc,m merceS. Co111(ner-ce to Pontiac Maple Cor,nea:tor· AOT Ratio to BY ------ ----------11450 10015 1~6n 2:::565 14221 10269 10758 16006 16110 13709 0.90 1.07 0.81 0.68 0.96 ADT 1056::: 1168€, 13291 163U:, 1391 ~· 0.92 1~17 0.68 O.E,9 0.98 1.23 1.04 1.33 na o.n 1.08 3734 6333 0.35 0.69 3802 6239 0.36 0.68 181347 111372 8657 1. 3(1 1. 09 1.10 18747 7785 0.74 0.90 0.99 7823 1.29 1.21 1.00 8731 10959 na 1. 10 na 10467 na 1.05 10085 11819 1.18 0.99 0.78 11484 7054 DECKER 14 Mile to E. West Mapl~ 14502 Maple to P. Trail 10896 P. Tr.ail to S. Commerce 783:3 11659 · 117E:9 88€:3 o.ao 1068(1 na 10765 1.20 1.53 1. 68 10493 7141 0.96 to 8'( ----------- ------------- 135"30 19310 21282 12627 10611 9139 na Ratio 1.18 0.1€, 1. 55 na 96::t3 ADT 13438 1•,72 19572 12•,10 13932 1316€1 16891 1182E: COMMERCE Extension <Maple to P. T · n.a P. Tr-.aiil to Oec:ker 10000 Ratio to BV 1091)2 13361 14939 18864 13462 1.25 1.14 1.14 s. FIOT 0.94 1. 30 0.9(1 O. 7E: 0.94 14254 ·14434 144:::4 11929 1.08 1. 13 R.atio ti:> BY ------♦------- 11358 12653 12658 n.a WALLED LAKE 14 Mile to P. Trail P. Tr.ail to Angle lu FIOT Mcipl~ Cc,nnector- ;5c ~Ji den P. Trail & E,.:tetid s. c,,,nn,e-rc~ ~ Clos~ E. W.311le,d Lk '3780 na 12•,97 171576 18445 13423 13140 0.95 1.33 0.76 0.80 0.95 na na ... ~)-·1 �l - The combination of all four actions does not produce significantly different results from the Maple Road Connector and E. Walled Lake Road closing alternative. The merits of this solution include: addition of the Maple Road Connector, the widening of Pontiac Trail to accommodate through traffic, opening up an area for development, and the building of a road hierarchy for better local circulation. Table 33 shows the model results for year 2010. Traffic volumes for the Base Year and 2010 are shown for the "do-nothing" condition. The ratios for 2010 "do-nothing" alternative show the growth in traffic that could be expected if no changes are made. These ratios can be compared to those obtained for combinations of actions. Map 19 shows the "do-nothing" traffic volumes for 2010 in graphic form. r i; \ - Two computer model results are presented in the table: 1) the combination of the Maple Road Connector, widening of Pontiac Trail and extension of S. Commerce Road, and 2) the combination of all four actions. Map 20 graphically portrays the results of combining the four actions. The computer model indicates that the combination of the Maple Road Connector, widening of Pontiac Trail and the S. Commerce Road extension will produce lower traffic volumes than with the combination that includes the closing of E. Walled Lake Road to through traffic. With the closing of E. Walled Lake Road to through traffic, volumes are somewhat higher in the eastern part of the City. However, it should be noted that this combination enhances the road hierarchy system in the City and allows E. Walled Lake Road to function as a collector. Conclusions and Recommendations Overview I !' l.., Analysis of present traffic conditions in the City of Walled Lake, review of regional growth and transportation plans, and modelling and estimating impacts of proposed actions for road improvements indicated that the key contributor to the transportation problems in the City of Walled Lake is the traffic generated outside the City, over which the City has no effective control. Planned changes in land use inside the City are expected to have only marginal impact on the overa 11 traffic on the City roads. However, efforts by the City to contra l access and develop collector streets could have substantial impacts on improving local circulation and traffic safety. In order to effectively address the problems in the City's transportation environment, the following three sets of actions are recommended: 1. Road improvements to relieve through-traffic impacts. 'l__ 2. Road improvements to build a road network hierarchy and improve local traffic circulation. ; 3. Control of access and future development. ' L - 124 - �' I . - ·-·--, J -·- - •1 IMPACT OF PROPOSED ACTIONS ON AVERAGE DAILY TRAFFIC VOLUMES (ADT) ESTIMATES FOR YEAR 2010 COMBINED ACTIONS AC:TIOt~ Base '(ear YR 2010 lHth N,::> Change in R•:>ad Syst.err, in City of w.all e-d Lake- ADT Ratio to E:Y Maple Connector ~, Widen P. Trail ti Extend S. Corr,merc:e (B'r') • LUU< ---------------------- POtffIAC TRAIL Welch to OieckerDecker tc, S. Commerces. CoinmEir·ce to Maple Maph- to WallE.>d LakEt l~a 11 ed Le1k e to S hot"Ei line ..... N u, FIOT ------11451) 1(1015 -lS1677 2::565 14-221 Map l E• C,::>t'\nec t,::>r ~: Widera P. Trai 1 ~< Close, W.al lE•d Lk ~: Exter,d S. Cc,mm•?rce AOT Ratio to B'Y' -------------- -------------- ADT Rdtio to E:Y 16519 144E.8 22811 326::0 21602 1.44 1.44 1.16 1.38 1.52 21310 20787 20?87 2124::: 1973E, 25761 16025 1. E:7 l. 56 2.(14 na 1.88 1.64 1.64 na 287::t na 164S18 16206 19383 1.53 2.12 15549 12124 1.47 1.33 3283 11439 15397' 1. (16 1.24 1.45 202:::1 137:::2 1.26 12914 1.65 16792 16057 1~637' 25552 20l6S1 1.47 l. E,Q l.(10 1.08 1.42 170€,5 180~3 206€,9 25020 196E:9 1.49 1.80 1.05 1.06 1.38 E. ~JEST MAF'LE Welch to Decker· . Oeck,er tc, S. Commerces. Coin~er-ce to Pontic1c Mai:,l e Cor,n,e,:tor· WALLED LAl<E 14 Mile to P. Trail P. Trail. to Ang! e 1135:3 12658 12658 n.:i 10611 S•13'3 DECKER 14 Mile to E. West Mc1ple 14502 Maple to P. Trail P. Trai J. to S. CommEir·ce 15,??.4 1.• 05 1.43 1.54 ~~ 15!i32 12073 n~ 10000 na na 1~06 13292 1.33 14490 L0896 1348E, 11381 209~i8 23825 1.85 1. 88 2. 27 na 0.31 1.25 1. 40 S. COMMERCE Extension (Maple to P. T P. Trail to Decker kl N 1.45 15925 na 16081 1.61 �la] .-,- l -~ J J J LEGEND ljl Ill !~ !!'1!;11::1;\ti;\1::::1:11 10,000 Vehicles/Day }_____fl---· ~ 1 :•:• :•=~1 + - - - + I - - - iI- - · \W? :::•::Jl--, :::::::::::·: :·=·=·=· ~t-'-'-'-'-'-' ~ ',';69J 1'l \'if ·_.1.p II J n g==: : ~ 1 NO . "\i_Hf,!,!~!:::-.~ ·,. · ; _ ~ •, 1 MckEHNA ASSOCIATEI, tr,CORPOftATEO "9~ IM't)Aft dHlgn fennlngton hlle tnlchtga,n tC>fflffllSIH.r ,,....,.. ..............,. . .,,,.,. ........ ,....,,,~.......,1:1 •• , J.rtltA,,l,w, ..dllle,\ • 36 I 5 2 3 4 -; m-1~,~·~~ :~i l~lil ~~~=:=!:::::==::'::====== ADT IN 2010 ·w1fH CHA~GEsT TO THE ROAD SYSTEM CITY OF WALLED LAKE 1 OAKLAND COUNTY • MAP 19 MICHIGAN mnn �-- - "j -- -~ .. J i, . - 1 -~-- l ; LEGEND - 10,000 Vehlcles/Day :!\l\@oomtmn ~r·tr-1.r~ ,I~:: r.: r.:. ~:- c::::;J ~ 36 fl-Ji\\\\\\\;%\\\\ft'• "· "~'·.._·.'\:, · I I I I I I 19689 ::::::: n l":::ll\\\:'' .:: 1111 I 11ITlrlljl1,~. ., ~,:;;::_:\':l\\\\\'.\'" I 1 C•lt ti •·•• I ] ,,,. , .. , di,.; ,j ·- - · ~-b,Vl·irrn:·t:•:•:-:-:-:-:-:111.u.).J.UI~ [) \,~ Un ., ADT IN 2010 UPON IMPLEMENTATION OF ALL RECOMMENDED ACTIONS CITY OF WALLED"""LAKE ..... ,-~,... ,..NW\, .... ,,....... llcKENHA AIIOCIATEI, INCORl'OIIATEO nan .. ,1gn 1••• eommunttr ,..,_.. 1""""'91on- ffllc:hlgen MftAIMt, .. lftltM • OAKLAND COUNTY I -1 I I I Uu • MAP 20 MICHIGAN utn - n .-- ! �High Priority Road Improvements Pontiac Trail in the downtown is the key to the transportation problems in the City. Pontiac Trail has the highest traffic volumes, lowest Level-of-Service, and lowest traffic safety. In order to improve transportation conditions, at •present and more importantly in the future, the City has to first concentrate on Pontiac Trail. Currently, Pontiac Trail between E. West Maple Road and E. Walled Lake Road carries about 23,000 vehicles per day. It is estimated that by the year 2010 and without further road improvements, this road segment will carry close to 33,000 vehicles per day, an increase of about 40 percent. I l .. Already, there is congestion and backup of traffic at the Pontiac Trail intersect ions during the peak periods. Without road improvements to re 1i eve this through-traffic pressure, the traffic situation on Pontiac Trail is expected to deteriorate even further. To address this problem we recommend as high priority: 1. Construct the Maple Road Connector 2. Widen Pontiac Trail between E. Walled Lake Road and the Coe Railroad These two projects are complementary. The greatest reduction in traffic on Pontiac Trail is expected to result from construction of the Maple Road Connector. While an additional fifth lane on Pontiac Trail will not add much capacity, it will accommodate turning movements and thus allow for smoother flow of traffic. Its impacts are expected to be realized in terms of improved Level-of-Service and traffic safety. It should be noted that without reduction in traffic on Pontiac Trail itself, the turning lane alone would not be very effective and both projects are needed together for maximum effectiveness. It is estimated that during the Base Year the Maple Road Connector (alone or in combination with 5 lanes on Pontiac Trail) would carry approximately 12,000 vehicles per day, and about 15,500 vehicles per day by the year 2010. For the Base Year this diversion of east/west traffic from the Pontiac Trail funnel is estimated to reduce traffic on Pontiac Trail between S. Commerce Road and E. West Maple Road by about 25 percent, and between E. West Maple Road and E. Walled Lake by about 33 percent. In fact, the computer model indicates that with the Maple Road Connector in place and in spite of substantial regional growth, traffic on this section of Pontiac Trail in the year 2010 would not be much more than the present level. It is estimated that traffic volumes will remain virtually unchanged, at about 23,000 ADT between E. Walled Lake and E. West Maple Roads, and will increase by only 19 percent to 23,500 between W. Maple to S. Commerce Roads. These two complementary projects are effective on their own merits. However, they are important also as pre-requisites for effective functioning of the other road improvements, namely closing E. Walled Lake Road to through-traffic and - 128 - �'- I extending S. Commerce Road southward to E. West Maple Road. Without the Maple Road Connector/Pontiac Trail Widening, closure of E. Walled Lake would worsen traffic flow in the City, and the S. Commerce Road Extension would not have much effect. . In summary, 'the Maple Road Connector/Pontiac Trail Widening is a high priority road improvement project for relieving transportation problems in the City of Walled Lake - both on its own merit, and as a pre-requisite for the effectiveness of the additional road improvements considered in this study. Second Priority Road Improvements I l. The second priority road improvements will enhance circulation and help to develop a hierarchical roadway system in the City. For effectiveness, however, they need to be implemented in tandem with the widening of Pontiac Trail and the Maple Road Connector. Thus, the following actions are recommended as having second priority: 1. Extension of S. Commerce Road to E. West Maple Road 'I . 2. Closure of W. Walled Lake Road to through-traffic These two projects are independent of each other and do not necessarily have to be implemented together. They will improve local traffic circulation, assist in developing a road network, provide for collector streets, and accommodate future 1and development. However, if implemented with out the Maple Road Connector/Pontiac Trail widening, they will not alleviate the major traffic problem of the City, i. e. the through-traffic. Accordingly, they should be considered as the second part of a staged road improvement plan in the City. South Comerce Road Extension The S. Commerce Road Extension would expand the limited road network in the City by providing an additional north/south link (from Pontiac Trail to E. West Maple Road). More importantly, it could al so serve as a means for opening the triangular parcel of land located north of the Coe Railroad, and east Pontiac Trail for development. It is proposed that this improvement and any 1and development be conditional upon the construction of a collector street in the triangular area described above. The collector street would serve smaller local streets and be connected to Decker Road and Pontiac Trail. The building of the S. Commerce Road Extension, by itself, would not change the overall traffic conditions in the City, and its impact on through-traffic will be marginal. This segment of road will basically act as a localized traffic divertor. It will reduce traffic on the short segment of Pontiac Trail between S. Commerce and E. West Maple Roads by diverting it to E. West Maple Road, and than back onto Pontiac Trail. Closing E. Walled Lake Road to Through-Traffic E. Walled Lake Road, the most scenic road in the City, connects the City to its focal point, Walled Lake. The recreation activities on the lakefront leads to - 129 - �pedestrian movement across the road and to boating related activities near the road. These activities and local traffic conflict with the through-traffic on this narrow curved road, resulting in congestion and accidents. Furthermore, the anticipated closure of the southern segment of this road to through-traffic in the City of Novi is expected to increase traffic on the segment of road .within the City of Walled Lake beyond its present high volume. The objective of the proposed closure is to reduce through-traffic on the lakefront portion of E. Walled Lake Road between 14 Mile Road and Pontiac Trail, and allow it to function as a collector. Currently this segment of E. Walled Lake Road carries almost 11,000 vehicles per day. Closing it at 14 Mile Road will reduce traffic to about 4,000 vehicles per day in the Base Year and to 5,500 vehicles per day in the Year 2010. I ' Implementation of this action alone, will have negative impact on the overall circulation in the City, and is not recommended. Because of strong east/west regional traffic patterns, this closure would divert traffic (from east to west and vise versa) first onto Decker Road (between 14 Mile and E. West Maple Roads), and then, via E. West Maple Road and Pontiac Trail to the western boundaries of the City. This additional traffic would overload these roads and reduce the Level-of-Service. If E. Walled Lake Road was closed to traffic today (with no other road improvements), traffic on Decker Road would increase by about 30 percent from 14,500 to 19,000 ADT, and on E. West Maple Road by about 45 percent from 12,500 to approximately 18,500 ADT. By the year 2010 the traffic volumes on Decker Road would be about 20,000 ADT and 24,000 ADT on E. West Maple Road. Such volumes would indicate a need to widen Decker and E. West Maple Roads to up to four lanes. A way to efficiently accommodate this diverted east/west traffic would be to channel it through the Maple Road Connector/Pontiac Trail widening. Hence, the successful implementation of this closure is conditional upon the completion of the Connector. In summary, it is recommended that Walled Lake should not be closed on its own. It should be viewed as a "staged" project contingent upon completion of Maple Road Connector/Pontiac Trail Widening project. r Control of Access and Future Development To further separate local traffic from through-traffic, provide for a more efficient circulation of local traffic, and to improve traffic safety, it is recommended that the City take the following actions: 1. Control access by a more restrictive set of driveway ordinances, 2. Eliminate on-street angle parking in the City, 3. Develop a collector road system in new developments by exercising stronger leverage on developers, and - 130 - �.. I 4. Limit access to the major •arterials by developing a system of frontage roads. Control of Access Points Access control is one of the few actions the City can take to affect its transportation system, without dependence on outside {regional) forces. Thus, it is highly recommended that the City exercise its power in this area to more effectively control the way vehicles enter its road system. There is a somewhat undefined system of driveways along the City roadways. This is particularly evident on the outskirts of the downtown area along Pontiac Trail and at the intersection of E. West Maple Road with Pontiac Trail. /" It is recommended that the City develop and enforce a good set of City ordinances regarding driveways and curb cuts. A critical time to address the problem of these driveways and curb cuts is before the widening and/or repaving of any roads. However, it is recommended that the City take a more disciplined approach and address this problem as soon as possible. l. Eliminate On-Street Angle Parking Another area where the City has power to affect its transportation system is in the control of parking. In the City there are two locations where angle parking is permitted in the City: on E. Walled Lake at the intersection with Pontiac Trail and on E. West Maple Road near the intersection with Pontiac Trail. I c .. r i' L Angle parking, while providing more spaces per linear foot of curb, has the disadvantage of allowing vehicles to back into traffic and should only be used in very low volume environments. Both of these are high volume intersections and are inappropriate for angle parking. It is recommended that the City eliminate the angle parking on E. West Maple Road and E. Walled Lake Road near their intersections with Pontiac Trail. ! i. Develop Collector Road System in Hew Developments It is recommended that the City develop a Collector Road System by using the site plan review process 0 to encourage developers to construct collector roads. l L Only residential development plans which incorporate a collector road system should be approved. A collector road should collect local traffic in the development, then channel it to an arterial. Direct access/egress from a new developments onto an arterial should be discouraged. This policy should apply to partially or fully undeveloped areas such as: 1. The triangle bordered by the Coe Railroad, Pontiac Trail and Decker Road, - 131 - I-= �I 2. The area bounded by Pontiac Trail, Coe Railroad, Commerce Township, Wolverine Lake and 3. The area between Pontiac Trail, Coe Railroad Ladd, and W. Walled Lake Road, 4. The area in the southwest corner of the City, and 5. The area east of downtown. It is also recommended that for public safety, to accommodate emergency vehicles, the collector system in each of these areas should be connected to at least two different arterials. This configuration would assure alternative access route by emergency vehicles, even if one of the other access points is blocked. Limit Access to Major Arterials by Developing Frontage Road System Pontiac Trail, the major arterial through the City also serves as a residential street from S. Commerce Road to the eastern boundary of the City. Along this segment of Pontiac Trail there are numerous residential driveways which exit directly onto the major arterials. This is a very undesirable configuration. I, I It is recommended that the City consider developing local frontage roads on either side of Pontiac Trail between S. Commerce Road and Decker Roads to provide land access. These · frontage roads would serve as local collectors, reduce conflicts, and further separate the local traffic from through traffic. Summary l • The following three-stage program is recommended to improve the transportation system in the City: 1. Build the Maple Road Connector and widen Pontiac Trail. 2. Build the S. Commerce Road Connector and /or close E. Walled Lake Road to through-traffic. 3. Initiate a program to develop a collector road system, and control access to the road system. Construction of the Maple Road Connector and widening of Pontiac Trail are the most critical projects to relieve impact of through-traffic. These two projects are complementary and should be implemented jointly. Together they are expected to reduce the pressure of through traffic and improve the Level-of-Service in the downtown area of the City. The second set of projects which can be implemented separately or together, but only after the Maple Road Connector and Pontiac Trail widening projects are completed, includes the building of a S. Commerce Road Connector and the closing - 132 - - - - - -- - - - - - - - - -- - �of E. Walled Lake Road to through-traffic. These projects will improve local circulation, assist in developing a good road network, provide for collector streets and accommodate future land development. The third recommendation, which does not necessarily depend on the first two, . ca 11 s for a'.dopt ion and enforcement of a stricter policy on curb-cuts and driveways, eliminating angle parking in the City, and encourage the building of a collector road system in new developments. L References AJH Associates (1987), "Quick Response System II, Reference Manual", Prepared for the Federal Highway Administration, U.S. Department of Transportation. iI • Michigan Department of Transportation, and the Federal Highway Administration (1989), "Draft Environmental Impact Statement for the Haggerty Road Connector, Oakland County, Michigan, Prepared by Envirodyne Engineering, Inc. Sosslau, A.B., A.B. Hassam, M.M. Carter, and G.V. Wickstrom (1978), "QuickResponse Urban Travel Estimation Techniques and Transferable Parameters," NCHRP Report 187, Transportation Research Board, National Research Council, Washington, D.C. Transportation Research Board (1985), "Highway Capacity Manual, Special Report 209, Transportation Research Board, National Research Council, Washington, D.C. - 133 - �FUTURE LAND USE Introduction r Walled Lake .and the rapidly growing suburbs surrounding it are similar in one · respect: they both have vacant buildable lands that are primed for the development boom that has been in progress in western Oakland County for the past several years. Almost a quarter of the land area in Walled Lake, about 370 acres, is still vacant. Walled Lake stands apart from neighboring communities, though, because it also has a historic downtown, older neighborhoods near the lake, and aging strip commercial districts. In short, Walled Lake has a much more diverse land use pattern than surrounding communities. There are neighborhoods and business districts whic~ represent several decades of development, and in some cases are in need of modernization or revitalization. On the other hand, there are lands which have never been built upon, which could be developed with new, modern residential, commercial, or industrial buildings and uses. Early in the planning process, the Planning Commission reviewed and approved a series of goals to help sort out some of the difficult issues related to planning a community with such a diverse land use pattern. Primary goals agreed upon by the Planning Commission include the following: - Neighborhoods: Foster strong, vital neighborhoods to ensure that Walled Lake continues to be recognized as a stable community were families and individuals reside, work, and shop. - Master Physical Planning: Maintain complementary land use relationships which promote a harmonious, attractive community; preserve natural resources; promote a sound tax base; and provide for manageable traffic volumes. I i i - Roads and Transportation: Develop an orderly program for improvement, maintenance, and expansion of the road system in order to meet increasing traffic demands, provide smooth traffic flow, and provide proper access to all property within the City. l .. - Property Maintenance: Recognize that the City and its physical resources are dynamic, and aggressively encourage property maintenance and reinvestment. I . - Fiscal Stability: Promote the development of a financially secure community which can continue to provide all necessary services to its residents and businesses in an efficient manner. Land Use: Promote efficient use of the land and encourage assembly and orderly redevelopment if appropriate land use plans are presented for new development on vacant lands, underdeveloped areas, areas isolated among more intensive uses, or areas which are declining or negatively impacted by nonresidential traffic or incompatible land uses. - 134 - ....u �i - Urban Design: Promote development that is consistent with the urban design concept that is defined and described in the Master Plan. ltt r~ ( L [ [ ,·· I 1. l ' - Planning Innovation and Flexibility: Encourage innovation in land use planning where innovation would achieve a higher quality of development than wduld be possible under conventional zoning. : ' i In addition to these general goals, the Planning Commission reviewed and approved more detailed goals concerning land use, housing, the environment, economic development, transportation, community facilities, and recreation. Future Land Use Map The Future Land Use Map (Map 21) sets forth recommendations for continued use, new development, and reuse of land in the City over the next two decades. The Future Land Use Map is a link between what exists and what City leaders and citizens would like to have. Together, the Master Plan and Future Land Use Map provide a flexible guide to promote informed public and private decisionmaking for the betterment of the community. The land use designations on the map are generalized; they are not intended to be site specific or to follow specific property lines. Although the Master Plan and Future Land Use Map form the basis for the Zoning Ordinance and other rigid legal controls, the Plan and Map are intended to be flexible policy documents and decision-making guides. General Form of the City. Review of the Future Land Use Map reveals that the general form of the City is affected by three key parameters: l l. L 1. Existing land use patterns and recent development proposals. 2. Transportation corridors, both existing and planned. 3. The overriding goal to maintain the quality of the City's residential areas. As a result of the interplay of these three parameters, it is proposed that the development of intensive commercial and office uses be confined to existing business districts along major thoroughfares and near the lakeshore. The map provides limited opportunity for expansion of the commercial/office district to accommodate the needs identified in the Economic Analysis chapter of this plan. The plan further proposes that the two existing industrial districts located along the railroad tracks on opposite sides of the City be retained, but that future industrial development be confined primarily to vacant lands on the north side of the railroad tracks adjoining the easterly industrial district. Aside from this core of intensive commercial and industrial development which builds upon past growth and prevailing development patterns, the plan proposes - 135 - r-::. �r I that most of the rema1n1ng land area be reserved for single and multiple family residential development. Multiple family districts are used as transitional land uses, to buffer the lower intensity single family uses from the more intensive development and traffic along the thoroughfares . . A key element which is displayed on the Future Land Use Map is the proposed transportation network, consisting of several new roads that are intended to alleviate traffic congestion, forestall cut-through traffic in neighborhoods, and provide access to vacant lands. Implementation of the transportation recommendations is mandatory to achieve the goals set forth in this Master Plan and improve the quality of life for residents. Recommendations for each of the land uses identified on the Future Land Use Map are reviewed in the next several pages. Residential Land Uses ( I l. I I. The Population Analysis revealed that Walled Lake has experienced continued population growth over the past thirty years. Since 1980 the population has increased an average of 2.65 percent per year. The growth in population has been attributed to five key factors: regional growth patterns, the quality of the residential environment, expanding economic opportunities in western Oakland County, improved public services, and new housing construction. The population projections anticipate continued impact from these five factors. By the year 2005 the City's population is expected to increase to 6,908, an increase of about 1,200 persons. To accommodate the projected population increase an additional 513 housing units would have to be constructed by the year 2005. Accordingly, about 102 acres of land must be turned over for residential development during the next two decades. I. The type and design of housing is an important concern with regard to future residential development. Over the past twenty years the number of rental units has increased from about 26 percent to almost 52 percent of the total housing stock. The predominance of higher density residential development has affected the character and appearance of neighborhoods, contributed to traffic congestion, and affected the "small town" environment sought by many residents. I l: Although the Future Land Use Map proposes locations for new multiple family development, a high standard of development is desired. The following standards apply to both single and multiple family development: - The creation or enhancement of "neighborhoods" should be a primary residential development objective. There is a need to coordinate housing construction with the development of schools, parks, community services, and neighborhood shopping services. - Improvements to the road network are needed to support large-scale residential growth. Local streets in new residential developments should - 136 - �- r be connected with abutting local streets. Residential developments should generally have more than one point of access to enter and leave the development. New resipential developments should be designed to be compatible in appearance with existing single family housing. With regard to multiple family development, well-designed townhouse units are generally preferred over conventional apartment buildings. - Low density multiple family development (maximum of 10 to 12 units per acre) is considered most compatible with the existing character of the community and planning objectives set forth in this plan. The Future Land Use Map identifies three general areas where single family development is appropriate: - Southeast Part of the City. This area consists of older cottage-style homes near the lake, plus newer housing in the Tri-A and Lakeland Hills Estates Subdivisions. The opportunity for additional single family development exists on vacant land located between Gamma and Leon Streets. Also, large parcels of land located north and south of Leon Street, west of Decker Road, could be split to create new home sites. Attention must be focused is this part of the City, Subdivision. Also, there of a neighborhood park in on maintaining the quality of older housing in particularly in the Welfare Lakeview is a need for recreation facilities in the form the southeast part of the City. - Southwest Part of the City. This area consists of small homes in lakefront subdivisions, plus a few larger homes on large parcels along W. Walled Lake Drive. The opportunity for additional single family development exists in principally two locations: 1. Between W. West Maple and Pontiac Trail, near the City's western boundary. The single family designation is consistent with the existing use of the land, the planned development of land in Commerce Township to the west, and the desire to preserve certain natural resource features. 2. North of W. Walled Lake Drive, where large lots could be divided to create additional home sites. - North Part of the City. The lowest density single family subdivisions are located in the north part of the City. For example, the lots in Supervisor's Plat No. 4 east of S. Commerce Road are up to one acre in size. Unlike other single family areas in the City, the subdivisions in the north part of the City are fairly well insulated from heavy traffic and incompatible land uses. No more vacant land is left for large scale subdivision development in the north part of the City, but there are some opportunities for infill. - 137 - �Multiple family areas are generally located on the Future Land Use Map where they can serve as a transitional use between commercial or industrial development and lower density single family housing. The Future Land Use Map identifies eight general areas where multiple family housing is appropriate: - ln the Qorth end of the City at the intersection of S. Commerce Road and Decker Road. Multiple family development in this location serves as a buffer between the single family areas to the south and east and the more intensive non-residential uses and traffic at the intersection. There is a limited amount of vacant land available for additional multiple family development in this area. - On the south side of Pontiac Trail at the intersection with Decker Road. The multiple family development in this location provides a transition zone between the single family development to the south and the existing and planned non-residential uses at the intersection. A multiple family development is currently under construction in this area. - ln the central part of the City, extending generally between Decker Road and S. Commerce Road, north of the industrial and commercial districts. Existing and planned multiple family development in this part of the City provides a transition zone which separates the single family districts to the north from the industrial and commercial districts along the railroad and along Pontiac Trail. A limited amount of vacant land which has access to Pontiac Trail is available for development to complete this transitional buffer. - On the west side of the City, between the Commerce Township boundary and S. Commerce Road (the "Foster Farm" site). A portion of this parcel is occupied by wetlands, but it is estimated that there are over 40 acres of buildable land. Multiple family development at a density of no greater than 10 to 12 units per acre is considered appropriate in this location provide that: 1. Two or more points of access should be provided. Ideally, access should be provided to S. Commerce Road, Pontiac Trail, and Ladd Road . 2. Consideration should be given to developing a mixture of housing types, including single family housing on the north side of the parcel. Single family development is not considered appropriate for the entire site because of the intensity of existing and planned development on adjacent lands. Industrial uses are planned for the adjacent lands to the west in Commerce Township, and commercial development is planned along Pontiac Trail to the east. However, single family development borders the parcel on the north in Wolverine Lake. 3. Direct access should be provided at the rear of any future adjacent neighborhood shopping facilities developed along Pontiac Trail. i. I I, - 138 - �- On the south side of E. West Maple Road, west of Decker Road. Apartments and a duplex subdivision occupy much of the land in this area, but there are a few remaining parcels where new multiple family construction could occur. Such development provides a transition zone that protects the single family subdivisions to the south from the intensive activity on Maple Road. - East of Pontiac Trail, between E. West Maple Road and the lake. A proposal for construction of 128 attached condominium units (Winwood Place) has been approved for a 21.9-acre site immediately west of the Tri-A Subdivision. Similar development would be appropriate for the vacant land immediately south of the Winwood site, provided that care is exercised so as not to encroach on the extensive wetlands in this area. At the intersection of Decker and Fourteen Mile Roads, in the southeast corner of the City. The Lake Village residential complex occupies about 33 acres of land in the southeast corner of the City. In the long-term, the boundaries of this multiple family district could be squared off, resulting in the reuse of about 4.2 acres of land along Fourteen Mile Road that are currently occupied by single family homes. - In the southwest part of the City, west of the lake. Four areas have already been developed for multiple family use in the southwest part of the City, including Walled Lake Villa Apartments, Maple Hill Apartments, and Shoreline Condominiums. In the long-term, the boundaries of this Walled Lake Villa multiple family district could be squared off, resulting in the reuse of about 2.4 acres of land that are currently occupied by single family homes. No other new multiple family development is considered appropriate in this part of the City. The Future Land Use Map designates one location in the City, north of the railroad tracks and west of Pontiac Trail, for mobile home park development. The existing Fawn Lake Estates Mobile Home Park is located in this area; vacant lands north and east of the existing park are designated for additional mobile home park development. A portion of the area that is designated "Mobile Home Park" is covered by wetlands. Commercial and Office Uses t The Economic Analysis revealed that there is strong potential for additional commercial and office development in Walled Lake, as the population, number of households, and total income in the trade area continues to increase. Research presented earlier revealed that opportunities exist to fill certain niches in the convenience goods market. In addition, there is a need for new office development to provide higher quality office space for the professionals who serve Walled Lake residents. Furthermore, the service sector represents a clear-cut opportunity for substantial new business development in Walled Lake. [_ - 139 - �A description of the commercial and office areas designated on the Future Land Use Plan follows: 0 - E. West Maple Road/Pontiac Trail/Commerce Road. The Master Plan proposes that the most intensive concentration of commercial activity be located in the vicinity of E. West Maple Road/Pontiac Trail/Commerce Road. Accordingly, the Future Land Use Plan calls for additional commercial develo~ment on vacant lands on both sides of Pontiac Trail, between the railroad and S. Commerce Road. A new style of commercial development is desired in this area. Instead of individual businesses on separate parcels, there is a need to assemble lots and develop larger, well-designed commercial developments with ample landscaping, parking, loading, and other site features. New developments must be adapted to pedestrian as well as vehicular transportation. Finally, transportation deficiencies must be addressed if this commercial district is to function properly. Traffic congestion and inadequate access affect the viability of the commercial district. S. Commerce Road should be extended south of Pontiac Trail to E. West Maple Road, and the missing link should be constructed between E. and W. West Maple Roads. - E. West Maple Road. Over the next twenty years, the E. West Maple Road commercial district is expected to continue as a mixed service and convenience retail district, serving residents of Walled Lake and surrounding communities. New development on vacant lands, most notably at the intersection of Decker and E. West Maple Road, is expected. Redevelopment and renovation of aging commercial buildings and sites must also be included in long-term strategy for this district. The continued operation of service-type businesses, such as printers, collision shops, repair shops, and so forth, is generally considered appropriate east of Decker Road. The Future Land Use Map calls for the eventual removal of incompatible industrial uses along this corridor. I I l. I I I l. ll . - Pontiac Trail. The Future Land Use Map calls for continued commercial use of the frontage along Pontiac Trail south of E. West Maple Road. Because of the cramped site conditions in this area, intensive commercial uses that generate a lot of traffic (such as convenience stores) should not be permitted. The Pontiac Trail frontage would be best-suited for low intensity office uses. The Future Land Use Map does provide for greater depth for the commercial frontage wherever feasible, particularly on the east side, to allow for limited expansion as well as improved site design on the existing inadequately-sized sites. - Waterfront District. The historic downtown along the waterfront is no longer a center of retail activity. Continued development of restaurant, entertainment, and specialty goods businesses appears to be the key to long-term economic viability of the waterfront district. However, as noted earlier in the Master Plan, the market niche served by the waterfront district must first become better-defined. Also, certain functional problems must be resolved, particularly the parking deficiency, before any significant growth can occur in the waterfront district. - 140 - �■ I - Ladd Road Neighborhood Commercial District. The business district on the west side of Ladd Road, south of W. West Maple Road, is an excellent example of a properly functioning neighborhood commercial district. The businesses provide for the basic necessities of surrounding residents, yet the intensity of the use is not disruptive to nearby residences. The Future Land Use Map calls for continuation of this neighborhood district, with the ' opportunity for limited expansion to the west on approximately three acres of vacant land. - Pontiac Trail/Decker Road Business District. Currently, the only businesses located in this commercial district include medical offices and a gas station. However, additional retail development is planned for the intersection, with the intent that it become a full-fledged neighborhood commercial district. In fact, a proposal for a neighborhood shopping center was reviewed and approved for the northeast corner of the intersection in July of 1988, but was never built. In addition to the retail development, the Future Land Use Map calls for additional office development on the northwest corner of the intersection. There are five large parcels of land that could be assembled and developed into a planned professional office park. S. Commerce Road Office District. The S. Commerce Road office district consists of several existing office buildings near the turn in S. Commerce Road at the north end of the City. The Future Land Use Map calls for no additional office development in this part of the City. - Maple Road Connector Office/Research Park. One of the most exciting developments on the horizon in Walled Lake is expected to occur upon completion of two major public projects. First, plans and funding proposals are being formulated for the construction of the "missing linkn that will connect E. and W. Maple Roads. Second, the deteriorating Walled Lake Junior High School is expected to be vacated in 1992, upon construction of a new school elsewhere in the district. The combination of these two projects provides the opportunity for planned office/research development on the vacated 13-acre school site, which will have frontage on the Maple Road Connector. Industrial Land Uses The Economic Analysis revealed that conditions are not conducive for large scale industrial growth in Walled Lake, although the City can accommodate limited light industrial or research development. The lack of large vacant tracts of land and transportation deficiencies are the two major constraints to industrial growth. l. To counterbalance its liabilities, the City offers a central location within the county, proximity to attractive neighborhoods and residential communities, adequate public utilities, and receptive public officials. Industries that would benefit most from Walled Lake's assets include small manufacturing, design or fabricating shops, or research or administrative facilities. - 141 - �The Future Land Use Map calls for continued industrial development in the two existing districts on the east and west sides of the City. The west industrial district along Ladd Road consists of the 40-acre Textron research/adm j nistrative complex, and various manufacturing operations which are located partially in Commerce Township. Limited new manufacturing development is expected in this district, but there is vacant land within the Textron complex that could be developed for additional research and administrative uses. The extension of Maple Road would make such expansion more feasible. The continued operation of this stable industrial district is important for the overall well-being of the City. Over the next twenty years the City must continue to make improvements to public facilities serving this area as an inducement for the industries to maintain or expand their operations . . The Future Land Use Map also calls for continuation and expansion of the east industrial, located east and west of Decker Road along the railroad tracks. However, in contrast to previous plans, the new Future Land Use Map does not propose industrial frontage along E. West Maple Road. As noted earlier, commercial service uses are considered more appropriate for the Maple Road frontage on the east side of the City. · A twofold strategy is required to address the development issues in the east industrial district. First, a strategy is needed for revitalization and renovation of a number of existing deteriorated or inadequately maintained industrial buildings. This strategy may involve, for example, investment in public facilities (such as road paving or drainage) or efforts to encourage general site improvements when site plans are submitted for expansion or renovation. · L Second, a strategy is needed to facilitate new industrial development on vacant lands north of the railroad and west of Decker Road. Foremost, plans must be formulated for a new road to provide access to these vacant industrial lands via Decker Road. If the railroad ever ceases to operate, the abandoned railroad right-of-way could be reused as a road right-of-way to provide the needed access to the vacant industrial lands. Industrial traffic should be kept off of Pontiac Trail. Parks and Recreation The Recreation Analysis indicated that the immediate emphasis in terms of parks and recreation planning should be on the development of facilities in existing parks, rather than acquisition. However, the analysis recognized that new park development would be desirable under the following circumstances: 1. There is a need for community park land of sufficient size. According to accepted national standards, community parks should be at least 15 acres in size. - 142 - �2. . 3. 4. There will be a need for additional neighborhood park space in 1992 when the Walled Lake Junior High School closes. The 14.9-acre Junior High School site serves as a neighborhood park . • There is need for greater lake access for residents. Future residential development will generate the need for additional parks. Efforts must be made to assure uniform distribution of park sites. The Future Land Use Map identifies all existing City-owned parks, including Sims Park, Pratt Park, Marshall-Taylor Park, Mercer Beach, and Riley Field. A Five-Year Action Program is set forth in the Recreation Analysis chapter of this plan, which itemizes specific improvements that are needed in each of these parks. In addition, the Future Land Use Map identifies general locations for three future park sites, as follows: 1. A neighborhood park will be needed in conjunction with future residential development on the "Foster Farm" site, west of S. Commerce Road and south of Wolverine Lake. Such a park could be incorporated into the plans for construction of a retention basin on the property for the purposes of stormwater management. 2. Consideration should be given to developing a neighborhood park on the former well site on the north side of Pontiac Trail, east of S. Commerce Road. 3. For the purposes of achieving more uniform geographic distribution of parks, the Future Land Use Map indicates a possible future park in the southeast corner of the City, north of Leon Street. Public and Semi-Public Land Uses In addition to park sites, the Future Land Use Map identifies the following public and semi-public facilities: 1. City Hall Complex. The City Hall complex located on E. West Maple Road is the center for most municipal operations. The City Hall building houses the City administrative offices, the Police and Fire Departments, and the library. In addition, the Department of Public Works facilities and a Volunteer Fire Department building are located on the site. 2. Schools. Two existing schools are identified on the Future Land Use Map: Decker Elementary School (located on Decker Road, north of Pontiac Trail) and Walled Lake Elementary School (on W. West Maple Road, west of Ladd Road). Since the Junior High School is slated to be closed in 1992, the desired use for the Junior High School site -- office/research -- is - 143 - �shown on the Future Land Use Map. The two elementary schools are expected to continue in operation for the foreseeable future, but no new school construction is planned within the City. 3. Other Facilities. Other public and semi-public facilities shown on the Future Land Use Map include churches, the District Court, and sites occupied by utilities. Road Network The Traffic and Transportation chapters of the Master Plan identified several circulation system deficiencies, including: - Lack of a road hierarchy, resulting in inadequate separation of local traffic from through-traffic. - An excessive amount of through-traffic on city streets. - Lack of road network. Most traffic is funnelled onto Pontiac Trail, causing congestion. Where there is a well-developed network the traffic is distributed among several streets. - Excessive number of access points onto the City's arterials, resulting in traffic conflicts, accidents, and congestion. - Excessively high levels of traffic on Pontiac Trail. Recommendations to address many of these deficiencies are set forth in the Traffic and Transportation Evaluation and Recommendations chapter of the Master Plan. To summarize, the Master Plan proposes a three-stage road improvement program as follows: - First Priority: Trail. , I Construct the Maple Road Connector and widen Pontiac - Second Priority: Extend S. Commerce Road from its present terminus at Pontiac Trail to E. West Maple Road. When the Maple Road Connector is completed close E. Walled Lake Road to through-traffic at Fourteen Mile Road. Third Priority: Initiate a program to develop a collector road system, particularly in new developments, and control access to the road system by limiting the number of driveways or curb cuts. The Future Land Use Map identifies general locations for new roads, including the Maple Road Connector, the S. Commerce Road Extension, and access roads needed to serve vacant lands. In addition, the Future Land Use Map serves as a master thoroughfare plan, identifying three types of roads which serve the City: - 144 - �- Arterial roads serve the major centers of activity, the highest traffic volume corridors, and the longest trips. Arterial roads generally should have a 120-foot right-of-way. Arterial roads designated on the Future Land Use Map include Pontiac Trail, E. West Maple Road, S. Commerce Road, and Ladd Road . • - Collector roads provide both access to abutting properties and traffic circulations within residential, commercial, and industrial areas. The purpose of a collector road is to collect traffic from throughout the City and channel it to the arterial system. Collector roads should generally have a 86-foot right-of-way. Collector roads designated on the Future Land Use Map include Decker Road, Fourteen Mile Road, Walled Lake Road, and Angle Street. - Local roads primarily provide direct access to abutting land and to collector and arterial streets. Movement of through traffic is usually discouraged on local roads, which typically have a 60-foot right-of-way. l [ I~ l - 145 - �") '~ w "., C w z ~ w > ., 0 • ~ 0 ., w ◄ ., > " ·:) ·;7 ~.1!1JJ!!:jitS3 MOBILE HOME PARK - - ..... [l FUTIJRE PARK- ~ t,~ -~'-•· ~. ~ {r!.fi:~.. ■ GENERAL LOCATION ROAD CLOSURE ■ RETAIL & OFFICE ~ UTILITY -•- PROPOSED ROADS (GENERAL LOCATION> ■ OFFICE/RESEARCH ffi CITY HALL - ARTERIAL ROADS lj LIGHT INDUSTRIAL l2l CEMETERY - COLLECTOR ROADS = LOCAL ROADS ~ PUBLIC & SEMI- PUBLIC [ ] LAKESHORE MIXED USE DISTRICT MAP 21 FUTURE LAND USE LAKE CITY OF W A LLED MICHIGAN OAKLAND COUNT Y ■ Ml.Kenna Associates, Incorporated C01111TU11ty Plamlng • Urban Design Fannlngton HIiia, Michigan m north scale 3001 600 120011760 feet 1/3 mle �I APPENDIX A Haggerty Road Connector Alternatives L d �I :z LAKE I I MAPLE 0 a:: RD. BLOOMFIELD WEST 14 RD. MILE RO. 0 ~ a: 13 Ml E "RO. \ o} 0 a:: = z ~ ~ 10 MILE 9 MILE LI 0 r-I MILE - [ ( I ~ $.Q..Y.C.C~: 1 SCALE HAGGERTY ROAD CONNECTOR Draft ALTERNATIVE 2 Michigan Department of Transpportation, Environmental Impact Statement, Haggerty Road c_o_n_n_e_c_t_o_r_,_M_a_y_1_9_8_9_ _ _ _ _ _ _ _ _ _ , ! I____ _.J"--------~-= =~-----'- �·--- - - ----- - - ·-- z MAPLE RD ALTERNATNE LAKE RO. RD MAPLE WEST BLOOMFIELD c:i a:: 14 MILE RO. d a:: 0 a:: 13 0 MILE RO • a: i 12 • = ~ ~ NOVI 10 ~ :E a:: f 0 > 0 9 MILE 0 l&J t; ~ < ! 8 L ::z::: D 1 MILE RD [I ' I MILE HAGGERTY ROAD CONNECJOR --~.QJJD;~: Michigan Department of Transpportation, Draft I I Environmental Impact Statement, Haggerty Boad I · SCALE r-;=:= 0 Connector, May 1989 ALTERNATIVE 3A �z MILE ER NATIVE 4A H LAKE I o. BLOOMFI LD 0 c:: 10 14 MILE RO. 13 MILE RO. MILE 0 LaJ ... Cl) ..J 8 MILE RO < :c SCALE 7 I) l I MILE RO . I I~ HAGGERTY ROAD CONNECTOR .S.9..!.lC..«;.e: Michigan Department of Transpportation, Draft Environmental Impact Statement, Haggerty Road Connector, May 1989 ALTERNATIVE 4 �I I APPENDIX B Parameters and Ratios Used in Transportation Model e �PARAMETERS AND RATIOS USED IN QRS-11 MODEL The following tables contain parameter values that are typical of U.S. cities. TABLE 1 TRIP ATTRACTION RATES [l] l Retail Employees Purpose l Home-Based Work \ NonHome-Based Home-Based NonWork • [l) Source: :.~el'l-ing NonRetail Ernployees. ___ ·- · .....uni.ts 1.7 1.7 o.o 10.0 0.5 1.0 2.0 2.5 0.5 NCHRP Report 187, p. 15 . TABLE 2 AVERAGE TRIP PRODUCTION PARAMETERS [l] Size of Urban Area (l,OOO's) >750 <100 250-750 100-250 Parameter I r\ l Average Trip Prod~ction 14.1 14.5 11.8 7.6 Home-Based Work Percent 16.0 20.0 20.0 25.0 Home-Based NonWork Percent 61. 0 57.0 55.0 54. O' NonHome-Based Percent 23 •.0 23.0 25.0 21.0 [l) Source: l. ! I i I if '1 I I NCHRP Report 187 , pp. 13-14. �TABLE - 3 VEHICLE OCCUPANCY PARAMETERS ('AUTOMOBILE ONLY) [ 1] I Size of Ur-ban ·Area ( l , 'O•O'O.,·s <100 . , 10·0-:~s-o 2so--is:O---c:-·-- >7:S.O_ 0 ) Paramett.1r • Home-Based Work Occupancy 1.38 1.37 1. J's Home-Based NonWork Occupancy 1.82 1.81 1. 77 l°.74 · NonHorne-Based Occupancy 1.43 1.43 1.43- 1 ·. 4,3 (1) Source: h ·3 3 . NCHRP Report 187, p. 90. TABLE 4 VEHICLE OCCUPANCY PARAMETERS . (AUTOMOBILE AND BUS) [1,2] ·• ( I I l I I I ( I l - !j I Parameter Size of Urban Area (l,OOO's) >750 <100 100-250 250-750 Home-Based Work Occupancy 1.40 1.44 1.45 . 1.50 Home-Based NonWork Occupancy 1. 84 1.90 1.89 1.95 NonHome-Based Occupancy 1.45 1.51 1.54 1.61 [1] Source: NCHRP Report 187, p. 90 and p. 15. [2] Assumes 10 passengers per bus. �TABLE • 5 TRIP DISTRIBUTION PAru\'.METERS FO~THE POWER FUNCTION: [ l J, S-ize of· Urban [l,rea, ( 1, 0,00 's) Paramete r <100 100- 250 2 59-=-750 Home-Based Work :t . 9 9 l.9'9- ~.•. 08_ 1. 9,4 Home-Based NonWork (2) 2.73 2. 7 3 ~ .. Q9 z~ 9.5 NonHome-Based 2 .68 2.68 2.65 2.91 (1) Source: NCitRP Re port 1 87, p. 55. [2] Unweighted average o f home-based shopping, home~Qa.seg social/recreation, and home-based othe r. TABLE 6 SPEED/VOLUME FUNCTION PARAMETE.RS Parameter s ·tep Size Volume to Capacity Multiplier Volume to Capacity Exponent : I l l l. I >750 ~' ·- - Value 0.25 0.15 4.00 � Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Wyckoff Planning and Zoning Collection Creator An entity primarily responsible for making the resource Planning & Zoning Center (Lansing, Mich.) (Organization) Wyckoff, Mark A. Description An account of the resource Municipal master plans and zoning ordinances from across the state of Michigan, spanning from the 1960s to the early 2020s. The bulk of the collection was compiled by urban planner Mark Wyckoff over the course of his career as the founder and principal planner of the Planning and Zoning Center in Lansing, Michigan. Some additions have been made to the collection by municipalities since it was transferred to Grand Valley State University. Coverage The spatial or temporal topic of the resource, the spatial applicability of the resource, or the jurisdiction under which the resource is relevant Michigan Date A point or period of time associated with an event in the lifecycle of the resource 1960/2023 Source A related resource from which the described resource is derived <a href="https://gvsu.lyrasistechnology.org/repositories/2/resources/870">Planning and Zoning Center Collection (RHC-240)</a> Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/vocab/NoC-US/1.0/">No Copyright - United States</a> Subject The topic of the resource Michigan Comprehensive plan publications Master plan reports Zoning--Michigan Zoning--Maps Maps Land use--planning Publisher An entity responsible for making the resource available Grand Valley State University. University Libraries. Special Collections & University Archives Identifier An unambiguous reference to the resource within a given context RHC-240 Format The file format, physical medium, or dimensions of the resource application/pdf Type The nature or genre of the resource Text Language A language of the resource eng Text A resource consisting primarily of words for reading. Examples include books, letters, dissertations, poems, newspapers, articles, archives of mailing lists. Note that facsimiles or images of texts are still of the genre Text. Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Identifier An unambiguous reference to the resource within a given context Walled-Lake_Master-Plan_1990 Creator An entity primarily responsible for making the resource McKenna Associates, Incorporated Date A point or period of time associated with an event in the lifecycle of the resource 1990-04-10 Title A name given to the resource Master Plan Description An account of the resource The Master Plan or the City of Walled Lake was prepared by McKenna Associates, Incorporated with transportation analysis provided by Ann Arbor Planning Associates in consultation with McNamee, Porter & Seeley and was adopted on April 10, 1990. Contributor An entity responsible for making contributions to the resource Ann Arbor Planning Associates (consultant) McNamee, Porter & Seeley (consultant) Subject The topic of the resource Master plan reports Walled Lake (Mich.) Oakland County (Mich.) Source A related resource from which the described resource is derived <a href="https://gvsu.lyrasistechnology.org/repositories/2/resources/870">Planning and Zoning Center Collection (RHC-240)</a> Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/vocab/NoC-US/1.0/">No Copyright - United States</a> Type The nature or genre of the resource Text Format The file format, physical medium, or dimensions of the resource application/pdf Language A language of the resource eng Publisher An entity responsible for making the resource available Grand Valley State University. University Libraries. Lemmen Library and Archives https://digitalcollections.library.gvsu.edu/files/original/7bfc0958a03c94fcca1055e9cd68d101.mp4 2b6785eefaafffa29eebad04126ee4ca https://digitalcollections.library.gvsu.edu/files/original/ab4874972adeb6aba47193e47bdadb3c.pdf fd072d861047d095bbf084e217a7e160 PDF Text Text Grand Valley State University Veterans History Project Interview Notes Length: 44:46 Donald McKersie WWII Veteran United States Army; February 1943 to January 1946 87th Division, 347th Infantry, 3rd Army (0:33) • • • • • Pre-Army Background Born in Grand Rapids, MI in 1924 Graduated from South High school in 1942 His father was a farmer, whom he learned to be a hard worker from Worked for Michigan Bell before joining the army Inducted into the army on February 1st (3:15) • • • • Notions of World War Two Before Joining the Army Remembers hearing about Pearl Harbor All the news he gathered was from the radio Did not follow news of the war very closely He had expected to be drafted in the near future (4:00) • • • • • • Pre-War Training First sent to Fort Custer in Battle Creek, MI Next sent to Camp Roberts in CA Spent 90 days in infantry training He passed a test that made him eligible for Officer Candidate School Joined a Special Education program Was later sent to Stanford in CA for engineering classes (5:25) • • • • • • Nazis Invade Europe Promptly removed from Stanford and sent to Fort Benning in GA Learned maneuvers for additional assignments Assigned to the 71st Infantry Division, which was a light division from Panama Very few of the men in his division could read or write He first spent six weeks doing KP and Guard Duty, which he did not like Finally complained to Captain Swope, who in return asked him to sign a document, in which Donald unknowingly volunteered to go over-seas (9:10) • • • • 87th Division Traveled from Fort Dicks to England on the Queen Elizabeth There were 10,000 division troops on the ship Spent five weeks in England and then traveled to France Walked across France, Belgium, Germany, and Luxembourg �(11:25) Experience in Europe Differed from Training Experience • Training is not even comparable to combat • He lost several of his friends in Europe (12:30) Experience of Combat • Combat is “One day after another of fear” • Carried a running automatic rifle • Combat = killing, being shot at, automatic rifles • He had a mortar experience in which he believes a guardian angel protected him (17:00) Experience of Front Lines in Campaign • Was not completely aware of what was going on with the War in other parts of Europe • Read the Stars and Stripes newspaper to learn more of his surroundings • He did not know much of the German attack in the Battle of the Bulge before getting involved • He acquired frost bite on his feet at the Battle of the Bulge • His division spent 3-4 weeks in the freezing cold before they were able to sleep somewhere warm • The enemy was actually about 500 yards to a half mile away, so there was no close-hand combat • They were always very happy to see the “flyboys,” who helped support the artillery • There were so many of the “flyboy” bombers that they turned the sky black (21:00) End of the War • By the end of the war, his division had pushed all the war through Czechoslovakia • His division had gathered up thousands of prisoners (21:30) Battle of the Bulge • Can’t recall much of the experience because he blocked most of the memories out • Does remember crossing over the Rhine • While staying at an inn in Germany, the building was attacked and all the windows broke. The inn-keeper was crying and Donald felt very sorry for him. He said it was pitiful. (23:20) Relations with Europeans • Many Americans did not get along with the French • They had good relations with German citizens and Donald enjoyed the country of Germany • Encountered evidence of concentration camps and saw lamp shades made of human skin • While in training, he had been taught to fear the SS, yet had not gathered much information regarding the Nazi regime �(26:20) The Last Stages of the War • His division had taken in many prisoners • The violence had stopped instantly • His division accepted the prisoners and were thrilled to see so many surrender • Donald left Czechoslovakia and headed to New York, eventually leaving for Japan • His division left the prisoners with the Russians (28:20) The Last Six Months of Being in the Army • Donald was on a 30 day furlough when the war in Japan ended, which was in July • He had been re-assigned to the Finance Corps in New Jersey where he helped to pay other soldiers that had been discharged • The government had tried to convince him to stay in the army longer, yet he felt that he could never get out fast enough • He had been shipped back to Grand Rapids where he met his future wife • Afterwards Donald attended classes at Michigan State University with his GI benefits, yet he eventually dropped out when his old job at Michigan Bell offered his a raise. He continued to work there for 27 more years (31:00) Description of General Army Experience • Donald disliked being a soldier because he had been taught to kill • He respects all men who have served in the armed forces and has a great loyalty to the flag and the United States as a country • His army experience had a major effect on his life afterwards, which helped him to start his own business where he sold and installed telephone systems for 19 years; his son now runs the business • Donald is personally responsible for the break-up of Michigan Bell because he brought the company to court regarding their monopoly over phone service (36:00) Prisoner Experience • Did not witness any maltreatment of prisoners (37:00) Experience of Training • Similar comparison to present-day training (38:40) Bombing of Japan • Donald was very excited when he had heard the bombs had been dropped • The city of Grand Rapids was booming with excitement; they had even set off fireworks, which had startled him because it reminded him of his combat experience (40:20) World War Two Movies • The movies really bring back old memories and experiences • Donald thinks that every American should see “Saving Private Ryan” �(42:00) Guardian Angel • He had four major operations in the past fourteen years and has made it through all of them relatively well • Recalls the mortar experience in the war and believes that he was protected by a guardian angel • While in the war, he never once thought that he might not make it home � Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Veterans History Project Creator An entity primarily responsible for making the resource Grand Valley State University. History Department Description An account of the resource The Library of Congress established the Veterans History Project in 2001 to collect memories, accounts, and documents of U.S. war veterans from World War II and the Korean War, Vietnam War, and conflicts in the Middle East and elsewhere, and to preserve these stories for future generations. The GVSU History Department interviews are part of this work-in-progress, and may contain videos and audio recordings, transcripts and interview outlines, and related documents and photographs. Coverage The spatial or temporal topic of the resource, the spatial applicability of the resource, or the jurisdiction under which the resource is relevant 1914- Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/page/InC/1.0/?language=en">In Copyright</a> Subject The topic of the resource Afghan War, 2001--Personal narratives, American Iran Hostage Crisis, 1979-1981--Personal narratives, American Korean War, 1950-1953--Personal narratives, American Michigan--History, Military Oral history Persian Gulf War, 1991--Personal narratives, American United States--History, Military United States. Air Force United States. Army United States. Navy Veterans Video recordings Vietnam War, 1961-1975--Personal narratives, American World War, 1939-1945--Personal narratives, American Publisher An entity responsible for making the resource available Grand Valley State University. University Libraries. Special Collections & University Archives Contributor An entity responsible for making contributions to the resource Smither, James Boring, Frank Relation A related resource Veterans History Project (U.S.) Identifier An unambiguous reference to the resource within a given context RHC-27 Language A language of the resource eng Source A related resource from which the described resource is derived <a href="https://gvsu.lyrasistechnology.org/repositories/2/resources/455">Veterans History Project interviews (RHC-27)</a> Oral History A resource containing historical information obtained in interviews with persons having firsthand knowledge. Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Identifier An unambiguous reference to the resource within a given context McKersieD Title A name given to the resource McKersie, Donald V. (Interview outline and video), 2007 Creator An entity primarily responsible for making the resource McKersie, Donald V. Description An account of the resource Donald McKersie is a WW II Army veteran who served in the European Theater and in Japan. He took part in the Battle of the Bulge, and talks about the disposition of prisoners by his division. After being sent to Japan, he was on furlough when the war in Japan ended. McKersie discusses the effect serving in the Army had on his life and on his success as a businessman. Contributor An entity responsible for making contributions to the resource Smither, James (Interviewer) Subject The topic of the resource Oral history Veterans History Project (U.S.) Video recordings United States--History, Military Michigan--History, Military World War, 1939-1945--Personal narratives, American Prisoners of war--Germany Veterans Language A language of the resource eng Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/page/InC/1.0/?language=en">In Copyright</a> Type The nature or genre of the resource Moving Image Text Relation A related resource Veterans History Project (U.S.) Date A point or period of time associated with an event in the lifecycle of the resource 2007-07-02 Source A related resource from which the described resource is derived <a href="https://gvsu.lyrasistechnology.org/repositories/2/resources/455">Veterans History Project Collection, (RHC-27)</a> Format The file format, physical medium, or dimensions of the resource application/pdf video/mp4 Publisher An entity responsible for making the resource available Grand Valley State University. University Libraries. Lemmen Library and Archives https://digitalcollections.library.gvsu.edu/files/original/78fd9314cf47f90f06fb841e85bd25cc.mp4 46ab2eee2323376b39aa310f472b2680 https://digitalcollections.library.gvsu.edu/files/original/3bd05776d1866a0e4acf235cc7f11b3c.pdf 79bb6088b723dfa36f2a9f0c3f55326f PDF Text Text Grand Valley State University Veteran's History Project WWII Jack McKindley Total Time (00:27:43) Introduction / Service (00:00:10)  Jack was born March 23rd, 1925 in Kalamazoo, Michigan (00:00:33)  He graduated from Mendon High School in 1943; he remembers his family were together when they first heard about the Pearl Harbor attacks and was very shocked (00:02:13) ◦ Although Jack was drafted, many of the older guys in his high school enlisted after Pearl Harbor (00:02:50) ◦ He was sent to Keesler Air Force Base for basic training in Biloxi, Mississippi (00:03:38) ◦ At that point he was designated as Army/Air Force (00:04:24) ▪ Jack's drill sergeant was a corporal and was very loud and strict; he said they were all afraid of him because of the consequences they would suffer if they made mistakes (00:06:01) ▪ Jack and a few others were sent to Arkansas to be a part of the military band; he played trumpet for them (00:07:02)  He played trumpet as a child and this was seen on his application for the military (00:08:20)  He was at the Air-force base in Arkansas for about a year and a half and spent about eight hours a day either playing or practicing trumpet (00:09:18) ◦ Jack didn't think much about how the bars in Memphis, Tennessee were racially segregated; he didn't really notice or pay much attention to it (00:10:24) ◦ In addition to being trained as a musician, Jack was also trained for medical responsibilities as well (00:12:42) ◦ He was part of the 469th Air-force Band; there were 28 members in total (00:13:30) ▪ Jack and his band arrived at Newport News, Virginia in early 1945; they were placed at Camp Patrick Henry, Virginia (00:14:07) ▪ Most of the men in his band were young but he did have a master sergeant who was about 15 years older than him at the time (00:16:28)  They played all kinds of music: classical, dance, swing and military marches (00:17:10)  Jack remembers when the Germans surrendered in 1945 while he was at Newport News and he describes it as a thrilling experience (00:19:01) ◦ He was stationed in Virginia through 1945 and into 1946; he was discharged in March of 1946 (00:20:10) ◦ Red Skelton came through Patrick Henry along with other celebrities to perform at USO shows (00:22:00) ▪ Jack remembers he and a few others had to give a stubborn, rich recruit what they called a “GI Bath” to teach him a lesson (00:23:56) ▪ Jack's mother used to write him page after pages of letters; he had two brothers in the Navy as well (00:24:45) �▪ He received one leave to go home while at Newport News (00:25:17) Back Home (00:25:22)  Jack got a job in Mendon working with batteries and cables; after that he enrolled at Western Michigan University- he received his Bachelor’s in Music in 1950 (00:25:56)  He and his wife taught in Howard City and then ended up in the Wyoming, Michigan school system in Grandville (00:26:36)  He played with the Grand Rapids Symphony for a year and then went onto the Grand Rapids Symphonic Band for six years (00:27:10) � Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Veterans History Project Creator An entity primarily responsible for making the resource Grand Valley State University. History Department Description An account of the resource The Library of Congress established the Veterans History Project in 2001 to collect memories, accounts, and documents of U.S. war veterans from World War II and the Korean War, Vietnam War, and conflicts in the Middle East and elsewhere, and to preserve these stories for future generations. The GVSU History Department interviews are part of this work-in-progress, and may contain videos and audio recordings, transcripts and interview outlines, and related documents and photographs. Coverage The spatial or temporal topic of the resource, the spatial applicability of the resource, or the jurisdiction under which the resource is relevant 1914- Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/page/InC/1.0/?language=en">In Copyright</a> Subject The topic of the resource Afghan War, 2001--Personal narratives, American Iran Hostage Crisis, 1979-1981--Personal narratives, American Korean War, 1950-1953--Personal narratives, American Michigan--History, Military Oral history Persian Gulf War, 1991--Personal narratives, American United States--History, Military United States. Air Force United States. Army United States. Navy Veterans Video recordings Vietnam War, 1961-1975--Personal narratives, American World War, 1939-1945--Personal narratives, American Publisher An entity responsible for making the resource available Grand Valley State University. University Libraries. Special Collections & University Archives Contributor An entity responsible for making contributions to the resource Smither, James Boring, Frank Relation A related resource Veterans History Project (U.S.) Identifier An unambiguous reference to the resource within a given context RHC-27 Language A language of the resource eng Source A related resource from which the described resource is derived <a href="https://gvsu.lyrasistechnology.org/repositories/2/resources/455">Veterans History Project interviews (RHC-27)</a> Oral History A resource containing historical information obtained in interviews with persons having firsthand knowledge. Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Identifier An unambiguous reference to the resource within a given context McKindleyJ1593V Title A name given to the resource McKindley, Jack (Interview outline and video), 2014 Creator An entity primarily responsible for making the resource McKindley, Jack Description An account of the resource Jack McKindley was born in 1925 in Kalamazoo Michigan. He graduated from Mendon High School in 1943 and was drafted to the United States Army. After doing his basic training at Keesler Air-force Base in Biloxi, Mississippi, he was sent to Arkansas to be part of the military band. He played trumpet for the 469th Air-force band with 27 other members. They were stationed outside of Newport News at Camp Patrick Henry in Virginia during the end of the war. He was discharged in March of 1946. Contributor An entity responsible for making contributions to the resource Smither, James (Interviewer) Subject The topic of the resource Oral history Veterans History Project (U.S.) United States--History, Military Michigan--History, Military Veterans Video recordings World War, 1939-1945--Personal narratives, American United States. Army Language A language of the resource eng Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/page/InC/1.0/?language=en">In Copyright</a> Type The nature or genre of the resource Moving Image Text Relation A related resource Veterans History Project (U.S.) Date A point or period of time associated with an event in the lifecycle of the resource 2014-04-17 Source A related resource from which the described resource is derived <a href="https://gvsu.lyrasistechnology.org/repositories/2/resources/455">Veterans History Project Collection, (RHC-27)</a> Format The file format, physical medium, or dimensions of the resource application/pdf video/mp4 Publisher An entity responsible for making the resource available Grand Valley State University. University Libraries. Lemmen Library and Archives https://digitalcollections.library.gvsu.edu/files/original/cce4fd468b90d1cc20ebe196f5384581.pdf 7458ebb0199cafd172e0d47ca039207e PDF Text Text 1 Grand Valley State University Special Collections Kent County Oral History collection, RHC-23 Mrs. Ford McLachlan Interviewed in 1974 Edited and indexed by Don Bryant, 2010-bryant@wellswooster.com Tape #54 (1:02:34) Biographical Information Mrs. McLachlan was born Veronica Elizabeth Josephine Jungbaecker on 1 August 1883 in Grand Rapids, Michigan. The family name is pronounced ―Youngbaker.‖ She was the daughter of John Jungbaecker and Johanna Frances Keister. The parents were married in the Netherlands about 1872. John Jungbaecker died 20 November 1923 in Grand Rapids, Michigan at the age of 77. Johanna died in Grand Rapids 5 May 1936 in Grand Rapids at the age of 87. Both of Mrs. McLachlan’s parents were buried in Mt. Calvary Cemetery. Veronica was married 20 February 1920 in Grand Rapids to Ford H. McLachlan. Ford was born in Grand Rapids in August 1887, the son of John Norman and Harriett E. (Hooker) McLachlan who were married in Grand Rapids on 27 April 1882. John McLachlan was born in Canada April 1860 and died in Grand Rapids on 11 September 1944 at the age of 84. Harriet was born in Michigan in 1859 and died in Grand Rapids on 24 April 1943. John and Harriet were buried in Fulton Street Cemetery in Grand Rapids. Ford McLachlan died in Grand Rapids on 14 January 1943. Veronica died in Grand Rapids on 21 December 1988. Both were buried in Mt. Calvary Cemetery. ___________ Interviewer: You said you and your sisters would go there [Crescent Mill] collecting. Mrs. McLachlan: Well, when Dad used to do work for them before he built that house, you see… Interviewer: I see. Mrs. McLachlan: And the Voigt family lived on the West Side. Interviewer: I see, before they built the Voigt House they lived over on the West Side. Mrs. McLachlan: Near the mill you see. The mill was on the corner. [She is talking to another person here] Interviewer: And he worked for them. Before the building, what kind of work did he do before building? Always building or just carpentry? Mrs. McLachlan: Yes, when he was a young man and after he left school he took up carpentry work. When he was eighteen, he went into the army, of course, that was compulsory over in �2 Germany. When he was through with the army, he emigrated into Holland. His father had preceded him, because his farther was living in Middleburg. Dad was working in Vlissingen? on a big railway station, depots they call them here. And that’s where he met my mother was in Holland. Interviewer: Yes, And when did they come to this country? Mrs. McLachlan: In eighteen seventy-three. Interviewer: Yes, Mrs. McLachlan: They settled in Grand Haven, and my older sister Mary was born there. Then after a year or so there, Dad said there were no prospects here so I am going to move on to the bigger city. Of course, he heard Grand Rapids was a bigger city than Grand Haven. Interviewer: Did he come to this part of the country mainly because of his wife’s Holland connection? How did they happen to come to Michigan? Mrs. McLachlan: I will tell you what, when my mother was ten years old, of course her father died, and she had a little brother seven. They had gone into another city to collect some money; you know how they did that years ago - they didn’t mail it. You had to go and collect it. Some little inheritance, maybe it was—I never knew. They contracted, there was an epidemic in the city, and they both contracted this disease and they came home and they both died. Interviewer: Oh, my. Mrs. McLachlan: Her mother meanwhile had met a Hollander from Grand Haven, who was traveling over there. He was a widower, a Mr. Ball, and he wanted to marry my grandmother, so she said alright and so she came to this country and she left my mother there alone with the grandparents. Interviewer: Oh, I see, so she had a natural want to come over here. Mrs. McLachlan: When she came here, she hadn’t seen her mother in fifteen years. Interviewer: Then, your father came up to Grand Rapids because there was more work here. Mrs. McLachlan: He thought there would be. He was working on boat down there; you know finishing up the cabins and that. Interviewer: So he was a skilled finish carpenter. Mrs. McLachlan: Oh yes, of course that was German legendary know how. Even Ralph Voigt said that in his letter, in his article in the ―Wonderland‖. When they came to Grand Rapids the population was only sixteen thousand five-hundred here in eighteen seventy-four. I read that in the paper a year or so ago, so I kept track of all that. �3 Interviewer: Not a big city, but it seemed like a big city for this part of the country then. Mrs. McLachlan: And there were Indians here on the island in the Grand River and Campau, if you read the story of Campau. Interviewer: They used to get paid off every year. They paid off the Indians every year. Your father then became a builder as soon as he got here. Mrs. McLachlan: Now right away, he worked as a carpenter, and I think when I was born in eighteen eighty-three, he just started his business. Interviewer: My, are you ninety-one years old? Mrs. McLachlan: Yes, I will be ninety-two in a few months. Interviewer: You’re remarkable. Mrs. McLachlan: I don’t know. Interviewer: You don’t know, I’ve seen some people ten or fifteen years younger that didn’t look as good. Mrs. McLachlan: That’s a good age too in the seventies, of course, I think that is young, because I was active in my seventies and eighties. Just my eyesight now that has… I can read the finest print; I could until just a few weeks ago but now I am using (?), but sometimes I am better off not using it. Interviewer: What did your father do when he (?) Mrs. McLachlan: Well, he was a carpenter for about ten years after he came here. See the language barrier was what held him up. He learned the English language. Then he told my mother I am going into business and she said, ―I will tell you something.‖ (Dad was awfully quiet) ―Dad if you are going into business, you are going to have to start talking.‖ She said he never stopped after that. Interviewer: Did you speak English at home? Mrs. McLachlan: Always, I still don’t see how they learned to read and write. I just don’t know. Interviewer: As far as you’re concerned, when you were growing up you spoke English at home. Mrs. McLachlan: I never remember them speaking German except when some of their German friends came over. Interviewer: And they didn’t teach you German either? Mrs. McLachlan: No, we went to a German school. �4 Interviewer: You did? Mrs. McLachlan: We went to German Parochial School. And they kept up these old languages, like the Polish school taught Polish, they wanted their children... Well some of them they had to because they couldn’t communicate with their children unless they knew how to talk Polish or German or something. My folks they started to learn right away. Anyway my father was the progressive one in our family. Interviewer: Because he went into business for himself. When he went into business for himself, did he go into it as a builder? Mrs. McLachlan: Yes, a contractor and builder. Well, you saw, this is one of the last billheads and it is all yellow with age. The first decade of this century, Interviewer: That’s right, it would be nineteen ten and on up. Mrs. McLachlan: And he retired in nineteen eleven. Oh, quite a while ago, Mrs. [Barbara] Roelofs, when I talked with her which was three or four years ago, or three, anyway it was before Ralph Voigt died, because I went over to the Voigt House because he invited me over there… Interviewer: Oh, did he? Mrs. McLachlan: …after that article came out in the ―Wonderland‖. What he said to the reporter from the Press was, he said, ―They don’t build houses like this anymore. This was built by artists.‖ Well, I just couldn’t resist the next day, I called him up and told him who I was and said I am the last member of this family, of my father’s. I told him that and I couldn’t help but call him up. He said, ―I want you to come over and see this house. If anybody’s entitled to see it you are.‖ We had pictures, Ralph’s father had given my dad two pictures, oh they were about this size; one was of the outside of the house and one of the beautiful stairway. And my mother had them framed in little gold frames. And they hung in our dining room there was a sort of a niche toward the living room where my father’s safe was. And she had hung them over the safe. And I can remember looking at those pictures a hundred times. When they sold the old house and built the new one, I don’t know what became of all these old pictures. I didn’t help my mother move and I never knew what became of them. Unless they were put in a dresser in the attic at the new house, but I never went up there. Interviewer: Was the stairway special and did your father do that himself? Mrs. McLachlan: No, he didn’t work at all, he never worked at the trade after he went into his business. Interviewer: I see, just a contractor, then? �5 Mrs. McLachlan: He had some of the finest carpenters, craftsmen I would call them. One of them was Ralph Lypse, he was good on stairways and mantelpieces and stuff like that. Interviewer: And he carved them himself, that man carved the round… Mrs. McLachlan: No they didn’t do any carving. That was all done in the factories by expert carvers. Our factory that got out this work. Interviewer: Yes. Mrs. McLachlan: I was too young to tell who got out all this interior finish. The Ocker and Ford Company were the ones that did it. And my father was the president of that company for twenty years. Interviewer: I see. Mrs. McLachlan: He started that company, he and Mr. Clark bought the land, built the factory and had the stocked subscribed for. Interviewer: I see. Mrs. McLachlan: That was in the early eighties, before eighteen eighty-six because he went to Germany in eighty-six, when my sister Anna was born. Anyway. Interviewer: What was the name of the company again? Ocker and Ford. Mrs. McLachlan: On Fourth Street, and the Voigts lived right there in our corner of Mount Vernon, You know where Front Street is, all these people had their homes right along near the factories where they worked because they had no transportation. Interviewer: You had better be there. Mrs. McLachlan: You had horses and buggies and the streetcar, that was all; and my dad bought his first horse and buggy at that time and then, of course as the family grew so does the vehicle. We had a two-seated cutter and a double-seated phaetons with the fringe on top. And then he had two single buggies. We always had two horses as long as I can remember until the day he retired and then he had a horse yet. Even after he had bought his cars, we had two cars later on and he learned to drive he still had a horse. He was getting older, sixty five you know and he was coming around the corner of Monroe and Bridge Street and he was going to cross the bridge and he put his foot on the accelerator to get around the corner and a policeman stopped him and said you are going too fast. But I wanted to get around the corner, the policeman told him you have to slow down when you go around the corner,. Interviewer: ...instead speeding up? �6 Mrs. McLachlan: He was the funniest guy, full of life you know, wonderful sense of humor. This lady wanted me to make up a list of the different homes that he built in the [thirties?]. These are old, I wrote these, this has been revised, there are a lot of things I didn’t think of until later. That was my first copy; then I wrote this one over. Did I tell you he built the house that Jack built out at Reed’s Lake? Interviewer: No, I didn’t know that. Mrs. McLachlan: That was sold, that was William Jack that owned the American Boxboard Company. Interviewer: Yes, yes. Mrs. McLachlan: He had a awfully hard time getting started because he had no capital, he went to the Goodspeeds, John. And he didn’t want any part of it. See, he didn’t know who to go to, of course the Goodspeeds were in the real estate business and they made all kinds of money. And later on in thirty-six when I worked for Harrison Goodspeed, just temporarily you know, to catch up on some of the work. Mr. Perkins, who was a state bank examiner, was John Goodspeed’s bookkeeper. He worked half days, that’s the way they were hired, but I was on full time. And then Harrison, when I worked for him, I found out from their statements that Harrison had threehundred thousand dollars in that company and his father had five-hundred thousand dollars. You see, they kept putting in money after it got going. They practically owned the thing. Interviewer: Oh, for heaven’s sake. Mrs. McLachlan: Of course the Jacks were quite well to do. I knew William Jack because, I’d forgotten that my dad had built that house, that was when he was semi-retired and my brother was taking care of it and his foremen. Mr. Jack came up to see me when I was working in the Metz Building for Mr. Dykhouse lumber. He said to me, ―Are you Miss Jungbaecker? And I said, ―Yes, I am.‖ He said, ―I’m Mr. Jack and I wanted to tell you that your brother wasn’t taking care of his work out to the house.‖ ―Well‖, I said, ―the foremen are there, and Dad has good foremen.‖ You see, Dad just financing the thing, he wasn’t really wasn’t active anymore and wasn’t inspecting anymore. ―Well,‖ I said, ―I will go home tonight and tell my father.‖ But they finished the job and …it’s a very beautiful home. I guess I was never in it. Interviewer: Were you ever in Dr. Hake’s house? Mrs. McLachlan: No, but that was sold to Judge Raymond Starr, Interviewer: Raymond Starr, you said, yes! Mrs. McLachlan: I don’t know who bought it when he retired and was in the nursing home, he was at Olds Manor. Then his wife Minnie was out to Pilgrim Manor, not Pilgrim Manor the other one the Porter Hills and she died. And I don’t know if this Judge Raymond Starr was, he was the �7 last one. That’s right. Then there was the Wenzel Cuckerski home. Then there was the Bernhard May home, the brother of Meyer May of the May Company downtown. Bernhard was from New York, married a New York girl, he came back here to Grand Rapids with his wife and he wanted to build a home so they got a hold of my dad and they built that house, and I’ve never seen it. But his wife didn’t like it here so she wanted to move back to New York. Interviewer: So they went back to New York, and sold the house. Mrs. McLachlan: Sold the house to a Mr. Godfrey. Interviewer: Yes. Mrs. McLachlan: He went through there and said, ―Who was the contractor and builder?‖ He said, ―Mr. Jungbaecker.‖ ―I want to get in touch with him because he knew his business and I want to remodel a few things and change a few things.‖ Interviewer: Now, were those houses built after the Voigt House? Mrs. McLachlan: I know the Voigt [house] was because she was a Voigt girl you know? Interviewer: Yes. Mrs. Hake was Clara Voigt. Mrs. McLachlan: And she was Ralph’s sister. And the Meyer [Bernhard?] May house? I was quite young, because I remember him coming home to mother and saying what is a French toilet? Interviewer: Oh, oh. Mrs. McLachlan: She said how would I know if you don’t. She said the plumbers and fitters will know what it is. Interviewer: They wanted a French toilet, huh? Mrs. McLachlan: I never knew what that was at my age and my father didn’t know, and I got down to Cuba in nineteen twenty-eight, I was in the Imperial hotel, three of us women and I went to the bathroom and my gosh I must have pushed the wrong button or something and I got all wet. Interviewer: Oh, you had a bidet! Mrs. McLachlan: So I found out what that was. I told them I got all wet and they said well that is a French toilet. Well, my father never knew… Interviewer: Were you in the Voigt House when it was being built? Were you around, then? �8 Mrs. McLachlan: Ralph told me, he was going to Union High School when I was going to St. Mary’s on the west side same street a couple of blocks away. And I use to see him as a kid, he was a year older than I was. He told me that after school he went over there every night, every afternoon after school and would talk to my father. All he could remember was that his name was John. He said he had the plans up in the attic and he could find out. I said I can tell you what his name was, and it is a hard one to remember and I spelled it out for him and he said yep, that’s it. I said I suppose Ocker and Ford did the interior work and I said yes, my father was the president over there and turned all the work over to them and I said yes he would. There was something else here, the Bernhard May house. The C. A. Lindner home too, he was the manager of Ocker and Ford Company when I worked there. I worked there, that was my first job. My father put me in his office when I was sixteen years old. I worked there until I was about twentyfour and then they went into receivership. Mr. Dykhouse was one of the vice-presidents and so was Mr. Robert Sherwood. Mr. Dykhouse and Dad and Mr. Sherwood were the receivers. Then later on I went to work for Mr. Dykhouse when I was thirty years old. I have a long history of my own life. The Maurice Shanahan home on Plainfield Avenue; I don’t know what Dad did up there but I can remember him saying he was out in the yard and talking with Mr. Shanahan, planning what they were going to do. But what he did there, I don’t remember. That’s the big home, the Creston Mortuary bought this home way up on the hill and it was too hard getting up there, so they built the mortuary down below. Why they kept the home for, I don’t know. But Maurice Shanahan was with the Bissell Company. He was president of the Bissell Company for years. We had a lot of good people, built the Evangeline Home. Interviewer: I saw that, wasn’t that the predecessor to the Booth Memorial Hospital. Mrs. McLachlan: That’s a lovely old building, the architecture was so much nicer than the buildings are today. Take the buildings downtown they look like cracker boxes to me. Take the old City Hall, that was architecture. Take the Voigt home, they call that a Queen Anne but I can’t associate that with Queen Anne; I didn’t know they had homes built like that. Interviewer: They can’t seem to be able to afford to do is any of that really elegant decorative work on buildings nowadays. It looks very plain and functional. Mrs. McLachlan: They used to do a lot more of something they call ????, not cheesecake, but another name for it Interviewer: I know, that jigsaw work, well it will come to me in the course Mrs. McLachlan: Decoration on the… Interviewer: Gingerbread. �9 Mrs. McLachlan: Gingerbread and that’s right and that porch is so beautiful, that they had a flooring of wood on that porch, and wondered how they could keep wood from, course they used cypress for outdoors. Interviewer: Is that what they used in that? Mrs. McLachlan: Because that takes care water and stuff. Interviewer: Do you remember how much it cost to build the Voigt House? Mrs. McLachlan: No, I don’t. Interviewer: I suppose at that time … Mrs. McLachlan: It was a recession, in 1895 there was a terrific recession on. Interviewer: That is interesting. Mrs. McLachlan: Of course during that time, I can remember my mother saying… I was going to have a white dress for my first communion, and Mary my older sister was going to make it for me. You know we all made our own clothes in those days. There were no ready-made garments. Interviewer: That’s right. Mrs. McLachlan: And Mary was to make this white dress, and Mother said all your going to have is a plain white dress. I said that’s alright who cares, I didn’t care about clothes. So I went downtown a couple of days after that, with a girlfriend of mine from school. I went into the Boston Store and saw this collaret with embroidery and a little lace and it would fit right over the top of the dress and it was quite pretty. I said how much is that, she said that’s two dollars. And I came home and told my mother about it, and I had never asked for anything. And I said to her, Mother I saw a little collaret downtown that I thought it would look nice on this….I said that’s alright it’s too much money and she said how much was it? And I said it was two dollars. She stood and looked at me for the longest time, and then said you a are going to have that collaret, I will give that money to you tomorrow and you go down and get that collaret. Interviewer: When you went downtown in those days, you lived on the West side and you went across Bridge Street? Mrs. McLachlan: And then to the school and then across Bridge Street, turn north on Turner just one block, really a block and a half and walk downtown over the Bridge Street Bridge and then walk back home to the west side. Interviewer: Did you know any other of the other Voigts, except Ralph. Mrs. McLachlan: No, I knew Carl and Frank, and the oldest one was Frank and he was married to a Miss Seyferth. �10 Interviewer: Seyferth. Mrs. McLachlan: Beautiful blonde woman, I used to see her so much on the west side they lived on the west side too. And I even mentioned that to Carl, to Ralph, I remember your brother Frank and his wife the blonde woman and he said wasn’t she beautiful and I said, I’ll say she was! Interviewer: He was considerably older than Ralph, though Frank was, he was the oldest. Mrs. McLachlan: You see there were three girls too in that family. Interviewer: The girls were all in the middle and Frank and Carl and then the girls and then Ralph. Ralph was the youngest. Mrs. McLachlan: Yes, he was, he told me that. Interviewer: And he never married. Mrs. McLachlan: No, Carl did, then his wife died. When they got married the father said this is it. You can never come back home. Interviewer: Oh, really. Mrs. McLachlan: He meant, if anything happened to them. Interviewer: They would have to live away from home. Mrs. McLachlan: And then (?) lost her husband. Interviewer: But Clara did you go back home, after Dr. Hake died. Mrs. McLachlan: Yes, she did. Interviewer: Was that before her folks died? Mrs. McLachlan: No, her father was dead. She came to our house and he (her dad, not Voigt father). He was semi-retired but he would figure the jobs and that. She came over to the house and said I want you to figure a plan I want to build a house. And dad said alright I’ll figure it for you. And she came back and said oh, that’s way too high. Well, her father was the same way. Dad said well if you want good work, that’s what I have to have, that much money. So she said I’m going to forget about it. So the next year she came back again with another plan. And Dad said didn’t you get anybody to build that house, yet? She said nope, I am not going to have anybody else build it. I want you to figure this one. Interviewer: So Mr. Voigt was close with his money too? Mrs. McLachlan: Yes, well of course, I wouldn’t say they were tight. He was just that type that would say, oh. Gosh when we would go and collect some small bill, when Dad did some work �11 for him on the old home on the west side. Dad would warn us, ―Don’t say one word. Now he’s going to say what’s the matter with this John, he is trying to rob me.‖ Just sit still and he will pay it. So, I went there a couple of times and presented the bill. He’d look at it and frown and say, ―My goodness that man is trying to rob me.‖ I would sit there and look at him and not say a word and finally he’d say, ―Okay go downstairs and get the money.‖ Interviewer: The office was downstairs in the old house on the west side? Mrs. McLachlan: No, the Crescent Mill. Interviewer: Oh I see you went to the mill to collect. Mrs. McLachlan: His office was upstairs in the mill. The bookkeeper and the other office help were downstairs. Interviewer: Oh, I see. Mrs. McLachlan: That was before Ralph was in charge. Ralph went to colleges in the East, he went to Andover and either Harvard or Yale. He told me that he had two Masters, he had two degrees, anyway. Interviewer: And he came back and was actively engaged in the mill. Mrs. McLachlan: Yes. Interviewer: Was Carl also in the Milling business with his father? Mrs. McLachlan: Yes. Interviewer: Now his wife, did his wife die? Mrs. McLachlan: Yes, very nice looking woman too, I remember her. Interviewer: Yes. Mrs. McLachlan: I use to see her in the mill, I knew people in the office there. Miss Annette Klanderman worked there a long time, she was lame. And a Miss Diver. I didn’t know her as well as I knew her sister but I knew who she was. They were good looking girls. Interviewer: Somebody told us Mr. Voigt didn’t like to spend money on electric light either. Mrs. McLachlan: Didn’t he? Interviewer: No, he used to tell them hang a bare bulb in the office and put all three desks around that light bulb because they only could have one bulb for three people. Maybe that was just a story. �12 Mrs. McLachlan: (?) he was quite frugal like all the Germans are. Interviewer: He wanted value for his money’s worth, obviously. Mrs. McLachlan: …He came over with the Herpolsheimers. He started in the Herpolsheimer building. I was in that store. Interviewer: I see you put a note on this saying your father put the first escalator in Herpolsheimer’s. Mrs. McLachlan: That was in the first Herpolsheimer building. You see the old HerpolsheimerError! Bookmark not defined. when he was with Voigt, was up there further near where the ? drug store was later on, right in the middle of that next block between Ionia and Ottawa. And I used to go in there and shop and they still have that name up on the building if you go down East Fulton Street you can see it up there Herpolsheimer, Voigt-Herpolsheimer. Interviewer: It is still up there? I would like to see that. Mrs. McLachlan: Yes. My nephew told me that. I’ve seen that name up there too a good many times, but never gave it a thought. If I had known this was going to happen, I would have saved those pictures that Mr. Voigt gave me. Interviewer: Too bad you didn’t save the pictures of the interior of the house. Mrs. McLachlan: Well it was just the stairway. Interviewer: That is such a beautiful stairway. Mrs. McLachlan: I can remember my dad coming home, I was twelve and my dad would come home telling my mother, he used to talk about things once in a while and we kids would hear it. He said, ―Mother, you know what the people are doing, they are laying the flooring in the Voigt House. You know they have to walk around in their stocking feet. There might be nails and cleats on the bottoms of their shoes. And that wood didn’t dare to be scratched.‖ It had this parquet flooring, just the border around in the foyer. That was imported. Interviewer: It was? Mrs. McLachlan: Yes, it was. Interviewer: Where did they get that from, Germany then? Mrs. McLachlan: I imagine so. They came from Bavaria. He told me that. Interviewer: But the rest of the wood, the regular oak for the flooring came from this country. And you said cypress for the outside. �13 Mrs. McLachlan: Well, that’s what they used to use for porches, because it holds water and won’t break down. I would think in that length of time that they would have to put on new flooring on that porch. It wouldn’t last that long. Interviewer: Maybe, I don’t know. We’ll ask about that. It may be that’s the original flooring. That building is so sound, it really doesn’t deteriorate. Mrs. McLachlan: That’s the way things were built, years go. Interviewer: Yes, Mrs. McLachlan: Everybody built their homes that way. And in their basement they have walnut beams. Interviewer: The interior of the house has beautiful woodwork in it. And it is beautifully kept up. Mrs. McLachlan: Is it oak? Interviewer: Well, what interested me was in the drawing room, the library and the hall it is oak. In the downstairs bedroom it looks to me like cherry, It is beautiful, beautiful wood, polished. Mrs. McLachlan: What color is it? Interviewer: The cherry in the bedroom is the regular red cherry color, beautiful and very close grained like cherry, and it is the deep rich red. Mrs. McLachlan: Cherry is wonderful. Interviewer: And it is so close grained that you know it is not mahogany, No mahogany is a wider grain. Looks to me like cherry wood and it looks so pretty how could they left it out of…..You know they have oak in the Music Room and … Mrs. McLachlan: Oak was a big thing in those days. Interviewer: Yes. Mrs. McLachlan: Especially quarter-sawed oak. Interviewer: Quarter-sawed oak. Mrs. McLachlan: We had it in our home, too. Interviewer: Do you know anything about that stenciling around the top in the library? Who did that? Mrs. McLachlan: I don’t even remember that. �14 Interviewer: Well, there is some kind of stencil pattern up around the edge of the library. Mrs. McLachlan: Didn’t they say one time, that one of the girls did that? Interviewer: They did say the family did some in either the dining room or library. Mrs. McLachlan: Oh, they have some in the dining room too. Interviewer: There is some painted work up around the top of the dining room. Then there is some wall paper, no, not paper, this looks like fabric on the walls. Mrs. McLachlan: It is fabric, it is tapestry. Interviewer: Yes, tapestry, there is furring strips behind it. Mrs. McLachlan: Yes, they need that to hold it. But they’ve got the damask in the living room. The walls are all covered in damask. The second living room was the music room. Interviewer: Yes, Mrs. McLachlan: And that had a piano in it -- an upright. The thing I missed in the home like that would be a beautiful grandfather clock. Instead they have this big giant mirror, this huge thing. On the other landing there were some plants, artificial plants of some kind. Interviewer: There is a grandfather’s clock, but it is down in the hall. Mrs. McLachlan: Where is it? Interviewer: Now, is that the one you remember seeing? Mrs. McLachlan: I don’t remember seeing a grandfather’s clock Interviewer: There is one in the hall. Mrs. McLachlan: See, there were so many things we saw that I probably forgot. Interviewer: I think if you go with more than one or two people I think it is hard to see everything. Mrs. McLachlan: Well, there was just my niece and I. Interviewer: Just you and your niece? Mrs. McLachlan: Oh yes, we didn’t go on [a tour], it wasn’t open then yet… Interviewer: You went before it was even open. Mrs. McLachlan: He was still alive. �15 Interviewer: Oh, I see. Mrs. McLachlan: He was sick. [END OF SECTION ONE] [SECTION TWO] Mrs. McLachlan: You will revise that? Interviewer: No, it’s alright; I’ll just take off the part that had to do with the Voigt House off the tape, if that’s alright. Mrs. McLachlan: Is it off now? Interviewer: It’s on. Mrs. McLachlan: It is? Interviewer: It won’t bother you, I hope. What we’ll just take the stuff to do with the Voigt House off the tape. Sometimes if you just sit and talk, you learn more about. When did you go with your niece to the house? Mrs. McLachlan: Well, when I called him (Mr. Voigt), this was in the paper earlier about nineteen seventy, in the Wonderland. And he wanted me to come over. Well, I have been having trouble with my eyes and it hadn’t been operated on yet, I didn’t think about it until later and I thought my nephew would go with me, Arthur, who died in January. He wanted to see it and all that, but he, I couldn’t pin him down to an appointment. So in the fall, I said to my niece, not Mrs. Buist, will you take me over to the Voigt House? And she said, I sure will. I called up and this housekeeper answered and she said just a minute, I’ll call the nurse. I thought, gee a nurse, and so she called the nurse, and she said ―Mr. Voigt has been in the hospital and he’s had had a heart attack. He’s home now but I am here taking care of him.‖ I said ―Well, I’ll just have to forget about it.‖ She said, ―No, no don’t say that‖ she said, ―I’ll talk to him about it and you call me back Monday morning.‖ This was on a Saturday morning when I called him. So I said alright. So I called her about eleven o’clock and she said, ―Mr. Voigt said you should come in about two o’clock and I will take you through.‖ Between two and four, anyway. So we went over there, she took us through and showed us a lot of things, I was intrigued with the dining room quite a bit, and also that brass bed and that huge dresser in that one bedroom. Interviewer: Isn’t that pretty? Mrs. McLachlan: I didn’t even notice what kind of spread he had on there. I was so intrigued with the bed and the dresser; I didn’t know what else was in the room at all. Interviewer: Was he in the downstairs bedroom at that time? �16 Mrs. McLachlan: Yes, he was, but I didn’t see him. Interviewer: Yes. Mrs. McLachlan: And so she took us through Dr. and Mrs. Hake’s room, and she called attention to this beautiful secretary that the doctor had, and then we went down through the dining room and the other rooms. I don’t remember what I was going to say. Yes, and another thing was in the library, but I must have missed it, but I was always crazy about these big world globes, you know. I always thought when I grew up I wanted one of those and a big dictionary, an unabridged dictionary. I couldn’t remember seeing one there. I didn’t remember too much what was in that room except the fireplace and this housekeeper was watching TV (television) and we didn’t stand there long, but there was a beautiful bookcase there. Interviewer: Yes, full of old books. Mrs. McLachlan: There was another bookcase in another room somewhere that was filled with books too. Interviewer: After Mr. Voigt died, some of the furniture that was in there when you saw it was taken by relatives, but all the old furniture was upstairs in the attic so they brought that down. The furniture that is in there now, is the old furniture that was in the house when Mr. and Mrs. Voigt were alive. Mrs. McLachlan: They had a lot of Louis the Fifteenth, is it? Interviewer: Yeah and they had some of the horsehair sofas, that sort of thing. And then some beautiful imported stuff, I guess. Mrs. McLachlan: Yes, they had two imported chairs they were carved, little straight back chairs, you know. Interviewer: That stuff went to the relatives. Mrs. McLachlan: Those were very valuable I thought; and there was a music box underneath a seat of one. And this nurse, she played it Interviewer: She did? Mrs. McLachlan: After she took us, I thought the house looked kind of cluttered, there was so much furniture in those two little rooms, it looked to me like they shoved lots of stuff in there, with…. Interviewer: Without taking anything else out. �17 Mrs. McLachlan: Yes, and without getting it arranged in a proper way. Well, that was my impression anyway. But those two chairs intrigued me, and there was a beautiful big rocker that was carved, a high backed rocker. Interviewer: Is that the one with corn ears on top; that has the ears of corn on the top? Mrs. McLachlan: I don’t remember that. Interviewer: There is a beautiful high back rocker that has corn… Mrs. McLachlan: Is that still there? Interviewer: Yes, that’s still there. Mrs. McLachlan: I was intrigued with those cotton curtains at the windows, with the wide lace. Interviewer: Beautiful lace all…. Mrs. McLachlan: How could they wash those and keep them from… Interviewer: I think probably they were washed by hand. Mrs. McLachlan: Must have been. Interviewer: The story we have is that there were two sets of curtains for each window. Mrs. McLachlan: I thought it was two sets of shades? Interviewer: Well now, the story to us was that there two sets of curtains to each window. So when one was taken down to be washed they put the other set up. This meant that there wasn’t as much wear on each set… Mrs. McLachlan: No, probably not. Interviewer: This meant that they were in good condition. Mrs. McLachlan: Cotton, they must have been wonderful cotton. Interviewer: I don’t know because I can’t tell cotton or linen in a case like that, but I think most were cotton. A lot of that was handmade lace you know, the old Battenberg lace on some of those beautiful curtains. Mrs. McLachlan: They had a lot of beautiful things in there but today the people today don’t appreciate those things. But, I lived in that period and I know they were an affluent society, when you had lace curtains at your windows you were considered affluent. Interviewer: Yes…You father must have been pretty affluent, wasn’t he himself…? �18 Mrs. McLachlan: Pretty what? Interviewer: You father must have been a pretty affluent himself, if he was a good builder. Mrs. McLachlan: At one time, yes. He had quite a bit of money. Interviewer: Yes, because… Mrs. McLachlan: But you see there was no Social Security in those days, no nothing; and they had to save their money and he had at all in real estate. It seemed to me that everything he sold, he had quite a bit of real estate and a cottage down at Spring Lake which we loved. Interviewer: How did you get out to the cottage? Mrs. McLachlan: Not the Greyhound, but the interurban. Interviewer: It was a railway then or a bus? Mrs. McLachlan: No, it was a big bus, just like the Greyhounds, but bigger I think. They went on this electric rail. I think the tracks were electric. Interviewer: It was like electric a railway, I know there was an interurban between here and Spring Lake. Mrs. McLachlan: This was to Spring Lake and Muskegon. Interviewer: Now when did your father pass on? Mrs. McLachlan: In twenty, no, nineteen twenty-three. Interviewer: So he retired in nineteen eleven. Mrs. McLachlan: Yes. Interviewer: And lived about twelve years after that. Was your mother alive all those years? Mrs. McLachlan: Oh, yes she died when she was eighty-eight, almost eighty-eight. Interviewer: Oh, she stayed on. Mrs. McLachlan: Well, I came from pretty good stock … Interviewer: How many children in the family? You mentioned a couple. Mrs. McLachlan: Nine, three of them died before I was born, they all died in one week, diphtheria. Interviewer: That’s when they had those terrible… �19 Mrs. McLachlan: My little sister and the two next oldest sisters, so my mother raised three, six of us I mean. Interviewer: Do you know how many men worked on that house when your father was building it? Any idea? Mrs. McLachlan: Well, at that time, he had about thirty six men, but he had other jobs, too, you know. Interviewer: Not all of them were working on the Voigt House? Mrs. McLachlan: I imagine about twelve, or maybe more? I wouldn’t know. He had two good foremen the Dengler Brothers, Fred and John Dengler, his first foremen, when he first went into business. He had others when they they started to retire. Interviewer: The brick, for the outside of the building. Do you know where that came from? Mrs. McLachlan: Well, I… Interviewer: Some of that tile work is really beautiful. Mrs. McLachlan: Tile work? Interviewer: Well, that sort of decorative tile work. Mrs. McLachlan: Is there some tile work? Ceramics is it? Interviewer: Well, it looks to be… Mrs. McLachlan: More shiny than ceramic? Interviewer: Well. It looks to be the same color as the brick; there is some circular decorative piece, I think, that is in the top of one… Mrs. McLachlan: That is the mason work, then. Interviewer: Yes. You don’t know how much a mason made in those days, do you? Mrs. McLachlan: How much what? Interviewer: What they paid a mason a day, a brick layer? Mrs. McLachlan: I wouldn’t know what a bricklayer made. I wouldn’t know what my father’s men made, but when I worked at Ocker and Fords, I know what those men made. They did all this interior finish. The foreman on the three floors each made thirty cents an hour. Interviewer: That was a great rate, wasn’t it? �20 Mrs. McLachlan: Eighteen dollars a week, for sixty hours work. I made up the payroll, so I remember. Of course, my dad later on… Interviewer: You remember that. That was for a foreman, not just one of the men? Mrs. McLachlan: Then the next scale down, would be sixteen fifty. And Charlie VanderVelde, that started this Grand Rapids Camera Club, was one of the fine craftsmen, up on the third floor, under Ralph Fosget, he made sixteen fifty a week. The next scale down was fifteen and the next was thirteen fifty and then there was twelve and there was a ten fifty. And my uncle ran the freight elevator and he was getting nine dollars a week. Interviewer: How much of a family did he have? Mrs. McLachlan: Well, there was Jenny, Anna, and Francis and of course John, by that time. John was still going to school, I think. There were six children, there were seven children, the older ones were working you see. Interviewer: My goodness, that’s not much to bring up a whole family. How long did it take to build a house in those days? How long from the time they started to dig until they finished it? Mrs. McLachlan: I can imagine this house took a couple of years, wouldn’t you say so? Interviewer: I have no idea how long it would take, I am just curious if you were aware of how long it would take to do a job like that? Mrs. McLachlan: The mason work, the whole front of the building is beautiful. Interviewer: Oh yes, it is a very handsome building, and there is a lot of hand work in it. Mrs. McLachlan: Would they call that an estate, if it is just on a big lot? Interviewer: I doubt it, just a big house, maybe a townhouse. Mrs. McLachlan: It might be a mansion; they’ve got a carriage house and all that. Miss Lindner had a ten acre estate out on Reed’s Lake. The house wasn’t anything like the Voigt House, and she had spent thirty-thousand dollars to build on this big living room, on the one room but it included the furniture that she bought, carpets and drapes. It was my first job to check on it, I was with her for ten years. That house was a more livable home than the Voigt home. What I mean by that is, it had more of a woman’s touch, of course she lived there alone. Interviewer: Did Mr. Voigt make most of the decisions about what was to go into the house? Mrs. McLachlan: You mean the old man? Interviewer: Did he get to decide or did Mother get to say what she wanted? �21 Mrs. McLachlan: I wouldn’t know that, but I imagine he had a lot of ideas. You know this house was copied from a chateau in France. Interviewer: Yes, I heard. Mrs. McLachlan: Not exactly but parts of it, I think it is more Victorian than it is Queen Anne, don’t you think so? Interviewer: I am not very up on architecture. Mrs. McLachlan: I think so, but I am not either. As long as I have been with my father, and even with all that and even in the lumber business so many years, I still don’t know that. I did know a lot more about furniture because I was in the furniture business, too. I worked for Robert Irwin Furniture Company for ten years. Interviewer: Did you really? Mrs. McLachlan: Yes, Interviewer: Did you know Mr. Irwin? Mrs. McLachlan: Heavens yes, he would come over to my desk and talk to me. Interviewer: He was a remarkable man. Mrs. McLachlan: Yes, he was, he was in his eighties when he sold out there, you see. Sold the factory; they sold the one on Fulton Street first. They still had the Royal on Bond Avenue where he started. He started as a bookkeeper and so did Mr. Dykhouse. And they went into the lumber business later on. Mr. Dykhouse worked for the Ball-Barnard-Putnam groceries, delivering groceries. I was with him eight years. Interviewer: You were a bookkeeper? Mrs. McLachlan: Well, I was secretary, too, and also went into accounting. Interviewer: Did you learn to use a typewriter or did you write everything by hand? Mrs. McLachlan: No, I used a typewriter, I was sixteen years old I used a typewriter. But we didn’t have any carbon copies. Interviewer: What would you do, did you have to make two copies? Mrs. McLachlan: No, we had a machine, well, it was a funny thing. It was a big machine with a wheel on it. First of all it was a tissue paper book. And we put this, we had a tank with water in it and a wringer. And we would wring out this, it was made of, what’s this stuff. Heavy stuff, but pliable and you would put it thru the wringer. And we would put this wet thing in this tissue �22 paper book and put this tissue paper over this wet, a kind of like cardboard, I’d call it and then letter on top of that this way, you know upside down. And then we’d put another wet pad on top of that and put another sheet of tissue paper, and I would have four or five letters, and then you put them into this, all I can think of is this compress. You put it in there and then turn this wheel and then press down. Sometimes it would smear and you would have to do the letter over again. Interviewer: Oh, dear. Mrs. McLachlan: Shortly after that there was a girl at the city hall, she was an Irish girl, Miss O’Connor or something like that. I think that was the first thing, she used to make perfect copies, you know. But, she had carbon paper then and she used to make perfect copies. Interviewer: And that was a great thing. Mrs. McLachlan: Yes. And then I learned about carbon paper, it just came out. I was about seventeen or eighteen, probably. Interviewer: That would have been the turn of the century, wouldn’t it? The late eighteen hundreds. Mrs. McLachlan: Yes, I was seventeen years old at the turn of the century. I remember all the factory whistles and church bells all ringing. Interviewer: It was big excitement. Mrs. McLachlan: It was just terrible. Interviewer: Now, you’re about to live to see the bi-centennial of the United States. Mrs. McLachlan: I hope I live that long. Interviewer: Sure, you will, you’re in good health. Mrs. McLachlan: Well, all but my eyesight. I had my eye operated on then, after, I went there before yes. Interviewer: I see here, you have something about Mrs. Charles Roelofs residence. Mrs. McLachlan: No I haven’t she was very, very gracious on the phone, and she was to send some lady over here with a tape recorder. And she never came. Interviewer: Oh, I know who Mrs. [Barbara] Roelofs is, she is the Heritage Hill lady. She is the one that was the head of the Heritage Hill. Mrs. McLachlan: Mrs. Roelofs? Yes, didn’t you know her father? �23 Interviewer: No, I don’t know her, I’ve always worked just at the Voigt House, and I’ve never been an official. The name was familiar to me and I was just…. Mrs. McLachlan: She is Dr. Roelofs’ wife and then there is Dr. Pilling’s wife. Interviewer: I have met Dr. Pilling’s wife, I’ve worked with her. Mrs. McLachlan: I’ve saw her in the picture in the paper in the foyer of the Voigt home. Interviewer: This one home that you mention is later known as the Edmund Wurzburg home, and sold to the Franciscan Fathers, that is on Lake Drive, isn’t it? Mrs. McLachlan: Yes, my father built that picture gallery for Mrs. Clark, Melvin Clark’s wife. Is that the name? Interviewer: Yes, Melvin Clark…. Mrs. McLachlan: I met him too when I was over at one office. He came in there and that was before my father built that, yes. He said, ―You know what, Margaret my daughter,‖ (she was his daughter Mrs. Edmund Wurzburg) ―wants me to buy her a car.‖ Interviewer: Oh, Mrs. McLachlan: I said, ―Well, why don’t you?‖ He said, ―You mean that?‖ I said, ‖Yes, why don’t you buy her a car?‖ I was in my twenties then. He said, ―I guess I will.‖ Interviewer: Oh, dear. Mrs. McLachlan: Another one was the old Claredon Hotel, where Olds Manor is today? My father built that. Interviewer: He built that? Mrs. McLachlan: The Claredon and then it was razed and Rowe brothers who owned the Valley City Milling Company right next door, right across the canal. Or was there a canal? Not on the east side, there wasn’t. They bought that and built the Rowe Hotel, because at that time there were these furniture men were all coming to town and .. Interviewer: Oh, for the exhibitions, yes. Mrs. McLachlan: Yes, exhibitions they had to have more hotels. So they built the Rowe Hotel and later on it was changed to the Olds Manor for the elderly and it was taken over by Fountain Street Baptist Church first, and then I don’t know who is running that now. But they didn’t have too much luck with it, Fountain Street Church. Interviewer: No, they tried to run it as an old people’s home, didn’t they? �24 Mrs. McLachlan: Yes, Interviewer: It’s a commercial thing now, isn’t it? Mrs. McLachlan: I guess, my brother in law was there for awhile, so was Judge Raymond Starr. Interviewer: Is there a North Star Hotel, too? Mrs. McLachlan: Over in Comstock Park, that wasn’t much of a hotel but for a small place like Comstock Park, it was. Interviewer: Yes. Mrs. McLachlan: And Mr. Teele, Joseph Teele ran it. I knew that family, the whole family, they had the Watson House before they went out there. They owned the Watson House was on the corner of Bridge Street and Lexington. Interviewer: Yes. Mrs. McLachlan: And that old building, I don’t know if it is still there or not. I don’t get over to the West side at all. Interviewer: To get back and forth over there now…. Mrs. McLachlan: I have a niece over living in my sister’s house and she stayed right there, bought it when my brother-in-law died, she and her husband bought it and she lives there all alone now in that big house. And I haven’t been in that house in ten years, and she is right in the city. We talk to each other over the phone. Interviewer: well, it is probably just as hard for her to get back and forth as it is for you. Mrs. McLachlan: Yes, she has a busy life, and doesn’t drive anymore. She’s seventy-five now. I was raised over on the West side. Interviewer: Now, were you, you mentioned you went to St. Mary’s when Ralph was going to Union High School. Did he go to Union High before he went off to Andover then? Mrs. McLachlan: Oh yes, Union High, they call it Union High, it was a high school at one time, if there was elementary classes there I don’t know that. Interviewer: Yes. Mrs. McLachlan: They called it Union High. Interviewer: I remember reading about it. �25 Mrs. McLachlan: It was located on Turner Street. So was St. Mary’s School. My father built St. Mary’s School, the Convent and the Rectory. Then he built the Palmer and Buchanan Street Schools for the Board of Education. But those have all been replaced, not St. Mary’s. Interviewer: But the public schools have been. Mrs. McLachlan: Yes, the man next door went to the original Palmer Street School. Interviewer: The Palmer Street School and the Buchanan Street School. Mrs. McLachlan: Yes, I got that on my list. I guess, I gave you the one that has Charles Greenway’s name on it. No, this is the one I want you to have. You want to take this? Interviewer: I would love to, if you don’t mind parting with it? Mrs. McLachlan: No, I don’t need it for anything. I got these other two copies, which is that one? The little one? Interviewer: That is the little one, you’d better keep that. Mrs. McLachlan: I added more to it, that’s why. Interviewer: Yes, there is a lot more. Mrs. McLachlan: Do you want to take it along? Interviewer: I am afraid, do you have several copies there? Mrs. McLachlan: Yes, I have several. Interviewer: I would like to have that. Mrs. McLachlan: That name is so hard to remember. It is pronounced Youngbaker (Jungbaecker)? You know the Knape and Vogt Company? Well, the German name was Knapee. From that original John Knape that got up that firm, that started that firm, his wife Dina was in the same Whist Club that my mother was. Interviewer: Oh, really. Mrs. McLachlan: We knew all these people. Interviewer: It was nice because Grand Rapids was smaller then. Mrs. McLachlan: Of course it was, I went around collecting, too and I met so many businessmen, lumbermen like Orin Ward. Orin A. Ward’s daughter married this Harrison Goodspeed. And this old man Ward was one of the nicest men you could ever meet; he was so nice to me and I was just a youngster in my teens then. Then there was old man [Frank] Chickering was in the lumber �26 business. He was in the Tower Building right across from the Pantlind Hotel where the Woolworths are today; and I used to go up to see him. I don’t know whether I collected, it must have been that; or whether they bought things from our firm or what. This Mr. Chickering was so nice. Interviewer: Is that when you were with Ocker & Ford? Mrs. McLachlan: That was my first office job, that’s where I learned all the office procedures. Interviewer: All that you needed to know. Mrs. McLachlan: Mr. Moore, was the bookkeeper, he came up from Widdicombe’s, and came over there and was our bookkeeper. Mr. Lindner(?) was the manager, then there were a lot of stockholders, Mr. [Clark H.] Gleason the lawyer. Old man Thayer, George W. Thayer was mayor of Grand Rapids at one time. The old house on Ottawa Street that was his; that should have been preserved. Interviewer: Yes. Mrs. McLachlan: It was a one-story kind of stone house. Interviewer: Oh, it’s always a shame to see those beautiful old places go, isn’t it? Mrs. McLachlan: There is one on Front Street, too, it was all made of cobblestone or something. Interviewer: Yes, yes. Mrs. McLachlan: Then there was Mr. Sherwood, Robert Sherwood, was a nephew of the Mr. Thayer, and he was one of the biggest fruit growers in Michigan. He had this big farm in Watervliet. Interviewer: Yes, Mrs. McLachlan: He was vice-president of this firm. But that was before I went with them. Interviewer: I see, your father was an officer of Ocker and Ford at one time? Mrs. McLachlan: President Interviewer: President of it. Mrs. McLachlan: Twenty years. Interviewer: Twenty years, that is a long time. Was he doing building and being president at the same time? Both companies at the same time? �27 Mrs. McLachlan: But you see he wasn’t active in that business, he just took his business over there. Interviewer: I see. Mrs. McLachlan: That’s why he started this business because he was affiliated with his contracting business. Interviewer: It was to get all the finished carpentry done and finish all the millwork. Mrs. McLachlan: But the factories got out all the mantels and stuff, and like that. Interviewer: Was that mostly hand done or was it done on lathe? Mrs. McLachlan: No, most ,well some of it might have been done on lathes, but they did a lot of handwork. Interviewer: A lot of handwork, hand rubbed and polished? Mrs. McLachlan: This great big band saw, and [Alexander] Barbey was this little fellow, and I’d go up there, and run up and down those stairs two or three times a day, you know a couple of flights. I would go up there for some reason and Barbey would say, ―Want me to make you a little chair, cut you out a little wooden chair?‖ He would put a little chunk of wood on that band saw and in a few minutes, there would be a little chair. I wish I had saved all these things. Interviewer: Oh, yes. When they put the parquet floor in, was that put in on the spot, when they built the parquet floor, do you know? In the Voigt House? Mrs. McLachlan: Did they what? Interviewer: Did they fit the pieces as they laid it or was it already cut? Mrs. McLachlan: I would think it came in a certain design. Interviewer: I don’t know, I was just curious? Do you know anything about that? Mrs. McLachlan: They used to call the first floor of the Power’s Theatre the ―parquet circle‖. I often wondered why. Interviewer: Maybe the floors? I don’t know either. I think it is nice we are preserving the Voigt House, I think. It is certainly an example. Mrs. McLachlan: There were other houses that were beautiful, too here in town. Interviewer: Or prettier houses, but this is so complete though. Mrs. McLachlan: You take that McInerney home... �28 Interviewer: Yes. Mrs. McLachlan: …and some of the others, the one that always like so much was on the corner of Union and Cherry. It was a man by the name of Friant, a lumberman that built that. That was always my favorite and right across the street was the Metz home – of the Metz Building. And there was another one that Mr. Lemmon once lived in. It was her home, she was Mrs. Cramer and then he married her after his wife died. Leavenworth was the head of the G R & I Railway and that was right next to, on the corner is the Jonkhoff Funeral Home. Before that was Mr. Straight, he was the manager of the Majestic Theatre anyway, whatever his name was; he built that house. And right next door to this was the Cramer home and that was one of my pet ones. Just the kind of house I would have liked, you know. And later on it was sold to the St. Andrew’s Cathedral, to the parish I mean. Interviewer: Yes, is that where the bishop lives now? Mrs. McLachlan: Yes Bishop Kelly lived there. Interviewer: That’s a beautiful house. Mrs. McLachlan: Yes, it is. Interviewer: Actually the Voigt House may not be the prettiest house in town, but it is beautifully preserved and everything is in it. Mrs. McLachlan: Well, they kept it like it was in those days. Interviewer: Yes and when you go into it now and you can see what it looked like in nineteen five, you know. Mrs. McLachlan: Eighteen ninety-five. Interviewer: Yes. Mrs. McLachlan: And they never even remodeled the bathrooms, and the old-fashioned tubs, and the marble-topped lavatories. That’s what we had too, the marble topped lavatories too. Interviewer: The downstairs bathroom has what looks like to me to be like a sitz bath in it. Mrs. McLachlan: Well, I didn’t see that. Interviewer: No, must have been off the bedroom … Mrs. McLachlan: Off the bedroom. Interviewer: Off the bedroom where he was, and you wouldn’t have seen that. Mrs. McLachlan: I didn’t see the kitchen or the ballroom. �29 Interviewer: Now the ballroom is not open to the public, that’s way upstairs, right. Mrs. McLachlan: Well, I don’t blame them. Interviewer: Well, I think the trouble is there is so much stored up there, you know, they found dresses from way back. Mrs. McLachlan: They kept everything. Interviewer: It’s nice because you can see a picture of Mrs. Voigt; well we have the dress she is wearing. You know, down there they will have a model will wear the dress she is wearing in the picture. Oh, their beautiful. Mrs. McLachlan: Are they that well preserved, they probably have closets up there. Interviewer: Oh, beautiful wardrobes to keep them. Mrs. McLachlan: Miss Lindner had them too. Interviewer: Gorgeous handwork. Mrs. McLachlan: The dressmakers did a lot of that, they were proud of their trade. Interviewer: Did you make your first communion dress? You had to have a sewing machine for that, didn’t you? You didn’t have to make it all by hand? Mrs. McLachlan: My sister Mary made it. I was only twelve. She was nine years older. Interviewer: She made it for you. Mrs. McLachlan: She made this plain white dress. I had my picture taken. I got to thinking about that collaret one night, oh two or three years ago, and wondered if it shows on the picture and it does. I paid two dollars for it. Interviewer: I would hope it shows. Two dollar collaret, well that’s a lot of money. When you think the men worked the whole week for eighteen dollars, then a two dollar collaret is pretty much. Mrs. McLachlan: And a foreman, and when he hired this one young man, the Heller Brothers, of Youngstown, Ohio used to throw a lot of work to us and Mr. Lindner would go down there and he met this young man just come back from Europe, educated in Europe and he’d speak four different languages. And he hired him to come up and do the drafting. Lay out the work and everything; we had a drafting room in back of the office, all in one building. He paid him fifteen dollars a week. Interviewer: Oh, my. �30 Mrs. McLachlan: With that kind of education, he was very well educated, and I kind of liked him too, he would come over to the house. It was natural for him to take me out because he didn’t know anybody else, you know. Very handsome looking, I have a picture of him in the drafting room, he took mine and I took his. Interviewer: Yes. Mrs. McLachlan: There were the men in the upper floor were interested in photography, so they had the two top floors. The original Grand Rapids Camera Club. Later on I was in that too. Interviewer: For goodness sakes. Mrs. McLachlan: Later on I was on the board of directors. Interviewer: So you used to take a lot of pictures yourself. Mrs. McLachlan: I have just oodles of them, they’re seventy years old, just snap shot after snap shot. I bought a camera when I was about eighteen or nineteen years old. And then, when we bought the cottage, most of pictures were from down there. Interviewer: That’s the trouble, when you are at home you forget to take pictures of everything around you, don’t you, as it was. Mrs. McLachlan: I had pictures of my new house, my bedroom and I had a brass bed there. I don’t know what happened; I think I tore that up. Pictures of the inside upstairs and lot of them of downstairs, pictures of the rooms downstairs but Arthur said don’t you give those pictures away. Of course, he’s in some of them, he was young boy then. Interviewer: They are very precious then and they sure are. Mrs. McLachlan: Some of the old bathing suits I had. Interviewer: Now, how long, did everybody work sixty hours a week then? They worked six days a week, right, ten hours a day? Mrs. McLachlan: Ten hour and ten minutes a day, so they could get out at five o’clock on Saturday afternoons. And they just looked forward to that extra hour. Of course, they put it in during the week, but they looked forward to getting off a little early. Interviewer: Yes. Mrs. McLachlan: I was the same. I got there at quarter to seven in the morning. Interviewer: Oh my goodness, �31 Mrs. McLachlan: I gave out the clock tickets, we had a watchman’s clock, and my husband’s uncle ran that watchman’s clock. He had an office in… the not the Pantlind but the Sweet’s Hotel in the basement. The stairs were on the outside, and the offices were the coal office down there… INDEX A F American Boxboard Company · 6 B Ball-Barnard-Putnam Wholesale Grocery Company · 22 Barbey, Alexander · 28 Bissell Company · 8 Booth Memorial Hospital · 9 Boston Store · 10 Buchanan Street School · 26 Buist, Mrs. · 16 C Chickering, Frank · 27 City Hall · 9 Claredon Hotel · 24 Clark, Mr. · 5 Clark, Mrs. Melvin · 24 Cramer, Mrs. · 29 Crescent Mill · 1, 11 Creston Mortuary · 8 D Dengler Brothers (Fred and John) · 20 Diver, Miss · 12 Dykhouse, Mr. · 6, 8, 22 Fosget, Ralph · 20 Fountain Street Baptist Church · 24 Friant (home) · 29 G G R & I Railway · 29 German Parochial School · 4 Gleason, Mr. Clark H. · 27 Goodspeed family · 6 Goodspeed, Harrison · 6, 27 Goodspeed, John · 6 Grand Rapids Camera Club · 20, 31 Greenway, Charles · 26 H Hake, Dr. · 7, 11 Hake, Dr. and Mrs. · 16 Herpolsheimer family · 12 Herpolsheimer store · 12 Hooker, Harriett E. · 1 I Irwin, Mr. Robert · 22 J E Evangeline Home · 8 Jack, Mr. (William) · 6 Jack, William · 6 Jonkhoff Funeral Home · 29 Jungbaecker, Anna · 5 Jungbaecker, John · 1 Jungbaecker, Mary · 2, 9, 31 �32 Jungbaecker, Veronica Elizabeth Josephine · 1 K Keister, Johanna Frances · 1 Kelly, Bishop · 29 Klanderman, Miss Annette · 12 Knape and Vogt Company · 26 Knape, John · 26 L Leavenworth, Mr. · 29 Lemmon, Mr. · 29 Lindner, C. A. · 8 Lindner, Miss · 21, 30 Lindner, Mr. · 27, 31 Lypse, Ralph · 5 M Majestic Theatre · 29 May Company · 7 May, Bernhard · 7, 8 May, Meyer · 7 McInerney (home) · 29 McLachlan, Ford H. · 1 McLachlan, John Norman · 1 Metz (home) · 29 Metz Building · 6, 29 Perkins, Mr. · 6 Pilling, Dr. (wife) · 24 Power’s Theatre · 29 R Reed’s Lake · 6, 21 Robert Irwin Furniture Company · 22 Roelofs, Dr. · 24 Roelofs, Mrs. [Barbara] · 4, 23 Roelofs, Mrs. Charles · 23 Rowe Hotel · 24 Royal Furniture Company · 22 S Shanahan, Maurice · 8 Sherwood, Robert · 8, 27 St. Andrew’s Cathedral · 29 St. Mary’s School · 25, 26 Starr, Judge Raymond · 7, 25 Starr, Minnie · 7 Straight, Mr. (home) · 29 Sweet’s Hotel · 32 T Teele, Joseph · 25 Thayer, George W. · 27 Tower Building · 27 N U North Star Hotel (Comstock Park) · 25 Union High School · 8, 25 O V O’Connor, Miss · 23 Ocker and Ford Company · 5, 8, 20, 27, 28 Olds Manor · 7, 24 Valley City Milling Company · 24 VanderVelde, Charlie · 20 Voigt family · 5, 10 Voigt House · 1, 4, 7, 8, 9, 13, 15, 16, 19, 21, 23, 28, 29 Voigt, Carl · 10, 12 Voigt, Clara · 7, 11 Voigt, Frank · 10 Voigt, Mr. and Mrs. C. A. · 17 Voigt, Mr. C. A. · 11, 12, 21 P Palmer Street School · 26 Pantlind Hotel · 27 �33 Voigt, Mrs. · 30 Voigt, Ralph · 3, 4, 8, 10, 12, 16, 17, 25 Voigt-Herpolsheimer store · 13 W Ward, Orin A. · 27 Watson House · 25 Woolworths · 27 Wurzburg, Edmund (home) · 24 Wurzburg, Margaret (Clark) · 24 � https://digitalcollections.library.gvsu.edu/files/original/906c598f489cd2ee0e412016141fc2b0.mp3 93b67ddc1a8125ef218596d49900e890 Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Grand Rapids Oral Histories Subject The topic of the resource Heritage Hill (Grand Rapids, Mich.) Local histories Memoirs Michigan--History Oral histories (document genre) Description An account of the resource Taped and transcribed interviews conducted in the early 1970s primarily of the children and grandchildren of many of the founders of Grand Rapids, Michigan; many of whom were residents of the Heritage Hill neighborhood. Interviews were collected to develop a significant collection of oral resources that would supplement other primary and secondary local history materials. Initially funded as a private project, Grand Valley State College (now University) assumed responsibility for continuing the project until 1977. Creator An entity primarily responsible for making the resource Various Source A related resource from which the described resource is derived <a href="https://gvsu.lyrasistechnology.org/repositories/2/resources/452">Grand Rapids oral history collection (RHC-23)</a> Publisher An entity responsible for making the resource available Grand Valley State University. University Libraries. Special Collections & University Archives Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/page/InC/1.0/?language=en">In Copyright</a> Format The file format, physical medium, or dimensions of the resource application/pdf; audio/mp3 Language A language of the resource eng Type The nature or genre of the resource Text; Sound Identifier An unambiguous reference to the resource within a given context RHC-23 Coverage The spatial or temporal topic of the resource, the spatial applicability of the resource, or the jurisdiction under which the resource is relevant 1971 - 1977 Sound A resource primarily intended to be heard. Examples include a music playback file format, an audio compact disc, and recorded speech or sounds. Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Identifier An unambiguous reference to the resource within a given context RHC-23_54McLachlan Title A name given to the resource McLachlan, Veronica Creator An entity primarily responsible for making the resource McLachlan, Veronica Description An account of the resource Veronica Jungbaecker was born on August 1, 1883 in Grand Rapids. Her father, John Jungbaecker, was the building contractor for the Voigt House. She married Ford McLachlan in 1920. She worked at the Robert Irwin Furniture Company as a secretary/bookkeeper. Mrs. McLachlan died on December 21, 1988. Subject The topic of the resource Michigan--History Local histories Memoirs Oral histories (document genre) Grand Rapids (Mich.) Personal narratives Heritage Hill (Grand Rapids, Mich.) Grand Valley State University Women Language A language of the resource eng Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/page/InC/1.0/?language=en">In Copyright</a> Type The nature or genre of the resource Text Sound Format The file format, physical medium, or dimensions of the resource application/pdf audio/mp3 Source A related resource from which the described resource is derived Grand Rapids oral history collection (RHC-23) Date A point or period of time associated with an event in the lifecycle of the resource 1974 Publisher An entity responsible for making the resource available Grand Valley State University. University Libraries. Lemmen Library and Archives https://digitalcollections.library.gvsu.edu/files/original/190a456e9e0cd573fc3a672cb5340a8b.jpg 502566f83b43564553ad37b6220e2e15 Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Grand Valley State University Photographs Subject The topic of the resource Aerial photographs Universities and colleges Michigan Grand Rapids (Mich.) Allendale (Mich.) Building Facilities Dormitories Students Events 1960s 1970s 1980s 1990s 2000s Description An account of the resource People, places, and events of Grand Valley State University from its founding in 1960 as a 4-year college in western Michigan. Creator An entity primarily responsible for making the resource News & Information Services. University Communications Source A related resource from which the described resource is derived <a href="https://gvsu.lyrasistechnology.org/repositories/2/resources/41">News &amp; Information Services. University Photographs. (GV012-01)</a> Publisher An entity responsible for making the resource available Grand Valley State University. University Libraries. Special Collections & University Archives. Date A point or period of time associated with an event in the lifecycle of the resource 2017-03-03 Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/page/InC-NC/1.0/?language=en">In Copyright - Non-Commercial Use Permitted</a> Format The file format, physical medium, or dimensions of the resource image/jpg Language A language of the resource eng Type The nature or genre of the resource image Identifier An unambiguous reference to the resource within a given context GV012-01 Coverage The spatial or temporal topic of the resource, the spatial applicability of the resource, or the jurisdiction under which the resource is relevant 1960s-2000s Still Image A static visual representation. Examples include paintings, drawings, graphic designs, plans and maps. Recommended best practice is to assign the type Text to images of textual materials. Local Subject Subject headings specific to a particular image collection 1980s Source <a href="https://gvsu.lyrasistechnology.org/repositories/2/resources/41">University photographs, GV012-01</a> Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Identifier An unambiguous reference to the resource within a given context GV012-01_UAPhotos_000240 Title A name given to the resource Field House. Construction of the new Field House Creator An entity primarily responsible for making the resource McLaughlin, P. Description An account of the resource Construction of the new Field House adjacent to the remodeled old Field House is completed in 1982. Subject The topic of the resource Grand Valley State University Michigan Allendale (Mich.) Universities and colleges Facilities Building Language A language of the resource eng Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/page/InC-NC/1.0/?language=en">In Copyright - Non-Commercial Use Permitted</a> Type The nature or genre of the resource Image Format The file format, physical medium, or dimensions of the resource image/jpeg Date A point or period of time associated with an event in the lifecycle of the resource 1981 Publisher An entity responsible for making the resource available Grand Valley State University. University Libraries. Lemmen Library and Archives black and white photo https://digitalcollections.library.gvsu.edu/files/original/b6b5cfa0a298f65b88cea12a3342b1b3.mp4 636e0354541f88d595cbb07af403243e https://digitalcollections.library.gvsu.edu/files/original/25155f21770e20e3f93ec7c908f0a513.pdf 1c2e8b50cb96a54e1a778b388cf6b087 PDF Text Text Grand Valley State University Veterans History Project Interview Beatrice McLogan Interviewer: James Smither Transcribed by Emilee G. Johnson, Western Michigan University Length: 20:22 Jim Smither: Hello, I’m Jim Smither, I’m the director the Veterans’ History Project, at Grand Valley State University. We’re here talking today with Mrs. Beatrice McLogan, she served in the military during the Second World War, and she going to tell us something about her experiences there. Why don’t you start by telling us a little bit about your background, where were your born what did your family do, that kind of thing. Beatrice McLogan: I was born in Ann Arbor, my father was a professor in engineering at the university. 1:00 I attended the University of Michigan and graduated from there in 1944. Jim Smither: Can I ask how old you were when you graduated? Beatrice McLogan: I was 20. Jim Smither: Ok, so how did you do it that fast? Beatrice McLogan: Oh, well, when I was in elementary school they would always pass, I guess kids would talk too much, pass them on to the next grade to get [laughs] get rid of them, so I was passed a couple of times in elementary school, so I was 16 when I graduated from high school, so that’s why I was 20 when I graduated from college. Jim Smither: Ok, and how did you meet Ted? Beatrice McLogan: At the university. One of my best friends in Ann Arbor was dating his college roommate. So that’s actually how I met him. Jim Smither: And at the point where he went off into the Army, were you engaged at that point? Beatrice McLogan: Well, not formally, but we had, maybe, a little understanding 2:00 I would say. Jim Smither: And what did you think about him going off to war in World War II? Beatrice McLogan: Oh, it was the saddest day of my life. It was very tragic to see those boys go. Jim Smither: Ok, and you were then, you stayed in school then for the next two years? �Beatrice McLogan: Yes, well, I was finishing my sophomore year when he went. Jim Smither: And, then what did you do when you graduated, then? Beatrice McLogan: Well, then, I graduated in February, in the middle of the term, because I accelerated a little bit. So, I had decisions to make about what to do, I was an English major and a history minor, as a matter of fact, I decided to join the, apply for the WAVES. That was the naval program and the acronym for Women Accepted for Volunteer Emergency Service. Jim Smither: And why did you choose the WAVES rather than the WACs or another group? 3:00 Beatrice McLogan: Well, I think probably, the uniform had a little something to do with it. [laughs] It’s a very attractive uniform, but I just, well, I’ll tell you the real reason I selected that service, I had a friend at Michigan whose father was a senator, Senator Brown, from northern Michigan was a US Senator and I think he might have been chairman of the Armed Services Committee, he was a very important senator, only, I didn’t appreciate that at the time. The WAVES had just been formed, and Barbara Brown, my friend was considering going into the WAVES. So she asked her father to find out what he knew so he mentioned this to Captain MacAfee, who was the designated head of the organization, and she wrote this wonderful letter, hand-written, two-page letter to Barbara. And I thought, 4:00 my goodness, if they care that much about people this must be a very wonderful organization, so Barbara did not join, but I did. Jim Smither: Ok, what kind of training did they give you once you joined? Beatrice McLogan: Well I went in as an apprentice seaman at midshipman school for two months, we were apprentice seaman. Jim Smither: And where did they have school? Beatrice McLogan: That was in Northampton at Smith College. So we started the first, actually the whole period was two months, not…it was a two-month class, but one semester, the first half, we were apprentice seaman, the second half we were midshipman. We were told that the, that Annapolis set up their program, they sent their staff up to select the classes and train the staff. And we had just remarkable women that were highly trained in their fields and it was amazing to get 5:00 courses like Naval Law, and Ship’s Aircraft Ordnance, we had to learn how to identify by its silhouette, the ships, that was a tough class, because it was in [SKIP] �…active all the time, we were tired a good bit of the time. Jim Smither: Ok, and once you finished that period of training, then what did you do next? Beatrice McLogan: Then I went into communications, I went to communications school, which was held at Mount Holyoke, it had been and then it was moved back to Smith. So that everything was on the Smith campus, that was a two month course. Jim Smither: Now the women that were in there with you, were they also college graduates or? Beatrice McLogan: Yes, they were all college women. My very best friend with whom 6:00 I spent, lived in Washington after, well, she was my roommate at communications school. She had just graduated from the University of Illinois, but we had people from almost every school and many of them were just recent graduates, like I. Jim Smither: Ok, in communications school what kind of work were you doing? What were you learning to do? Beatrice McLogan: Well we were learning how to code, encode and cipher, actually, we did learn a little bit about codes, but codes were not what the Navy used, they used ciphers. Letter-for-letter substitution of messages. So we had to learn how to operate the equipment that does that sort of thing. And we were qualified to handle other varieties if they should ever arise, but they didn’t, they never did at my assignment, I was sent to Washington. 7:00 Jim Smither: And what did you do there? Beatrice McLogan: Well, I was in the code room of what was Radio Washington. We were on watches, there were four watches, to handle it cause we went 24 hours a day, and the watches would start, the first one was a day watch that would be 7:30 in the morning till 3:30 in the afternoon, or maybe it was 4 o’clock, 4:30. Then the next watch came on duty, not us, but the next one, and so forth, it went around the clock. Well, we would work two watches a day, we would work two days on one schedule, which was like 7 to 4, then we would be on 4 to 11. No, wait a minute, I’m getting a little mixed up. Yeah, then 4 to 11, then 11 to 7. So, we would do two days of each. 8:00 So after the sixth day, we would have one day off. And then we would start again on mornings. So we were always, our biological clocks were always being very disturbed, because… Jim Smither: It’s mixed up. Beatrice McLogan: Right. Jim Smither: So what happens in the code room or whatever, when you’re on a watch, what’s going on or? �Beatrice McLogan: Well, the messages came in on a teletype machine. And went, then we got the message which would be just, a series of six letters, five letters, no, yeah, five letters, and then a space and five letters and then we would sit at a typewriter and type the—we can talk about it now because it’s public knowledge about the enigma machine now, you know, that was what we were using—so we would set the wheels for the day, every day the wheels would have a different set, 9:00 and then we would set the wheels and type five letters and it would come out in English. My, now we were just, we were naval communications, I lived in a group house with five other WAVES and three of them were in the Japanese code, but we never knew what they were doing and they never knew what we were doing, because we were very discreet. Jim Smither: How much sense did the messages you were getting make, I mean, when you were decoding did you understand what they were doing and…? Beatrice McLogan: Oh, well, actually there might be voice codes, or, not voice codes, word codes within a cypher. For instance we all chuckled one time, we got a, the Office of Research and Development, dispatches went through out office. And that was the Manhattan Project, the you know, kind of super-secret messages. They were always things no one could possibly understand. 10:00 And one time there was one from London that said, “Eric is home sick.” Well, obviously that meant something, but we, worried about poor Eric off in London. [laughs] We handled the dispatches for the White House, President Roosevelt was a Navy person so he like the Navy to handle his communications. Winston Churchill and Joe Stalin, course we never personally saw the messages, only the watch officer was authorized to decipher, encipher the White House dispatches. But we delivered them, picked them up and delivered them to the White House when they were typed out. Jim Smither: Did you meet any interesting people when you were on that duty? Or ones that were famous? Beatrice McLogan: Oh, yeah. One of my good friends in the office was 11:00 Deborah Kirk, whose father, Alan Kirk, was commodore of the landings at Salerno and D-Day, and he came home quite a conquering hero. But his parents were very close friends of the Achesons’, and I know one Christmas Eve, Debbie was very down, she said to me, “Would you go with me to the Achesons’ Christmas party?” Because we could go on our lunch hour. Because we were on an afternoon shift and she was sort of blue because she couldn’t attend this nice party, so we got a cab and we went to Dean Acheson’s house, that was pretty exciting. And I met Justice Frankfurter, and I didn’t know that they were called Mr. Justice Frankfurter, let’s see how were they called, Mr. Justice Frankfurter, I guess, is the way he was introduced. 12:00 We saw Douglas Fairbanks, Jr., was assigned to the Commander in Chief’s office, so when we got word of that, we were off �and just wandering down the hall to look in and see him. Robert Young, who you probably, do you remember him? Jim Smither: He played Marcus Welby many years later. Beatrice McLogan: Oh, yeah. Well he was in the, I’m trying to think what it was, well actually he’d been on sea duty but he came back to the Navy Department and he was below us, a floor below us, and we’d see him once in a while. And then Admiral Halsey, once the war was over, was assigned an office right across the hall from the code room! And I’ll never forget him, he’d just sit there and watch the girls and he had these big glasses, [laughs] watch us going in and out, and I’m sure he’d never seen a WAVE 13:00 up close before. Well, I guess I can’t, what else can I think of that would be of interest. It was very exciting when the war was over, we were all very thrilled, and I remember probably everybody had a little too much to drink that night, we had, we were on the night watch and I remember a commander saying, “Ok, I guess it’s bout time for us to settle down and get to work!” [laughs] Jim Smither: Do you remember getting the news about the first atomic bomb? Beatrice McLogan: Let’s see. Jim Smither: Cause that’d be a little bit before… Beatrice McLogan: I have a feeling that I was on leave. I think maybe we were on leave at that time when the atomic bomb was dropped. No, no, we were in Washington, Ted had been transferred to Washington 14:00 at that time. And yes, we did k now and it was a huge relief. Absolutely, because everybody knew that everybody who could walk or crawl was going to be involved in the invasion of Japan, and after all we’d been through, it was a pretty nice thing to know the war was over at last. Jim Smither: What was life in Washington like while the war was still going on? What sort of place was it to be if you were a young woman working in the WAVES? Beatrice McLogan: Well, the Navy assumed that if you were an officer, you could take care of yourself, and there were no services as far as housing or you know, a rental organization or anything. So my friend and I who had gone through communications school together, we agreed we would live together in Washington. So, we got the paper out every night and we read the want-ads and course they were always fruitless, the few things that were published. 15:00 And we finally found, well, my sister was living in Washington, and she found a place for us to stay for a short time. It was available for maybe two weeks. And my friend, Elgie said we moved eight times, but I don’t think it was that much! I had a very good friend in Ann Arbor whose father had transferred, or given a position in �Washington on the War Labor Board, and they had a beautiful apartment. And I think Mrs. Skinner was feeling terribly sorry for us and she said, “Would you do me the favor of staying at my apartment so you could water my plants,” while they were going away for two weeks and oh my, that was heaven. [laughs] But finally, it just turned out on our watch that one of our, one of the gals who was working on our watch, was looking for a roommate. 16:00 We said, well, two, take two, you can have us. Jim Smither: Very good. Beatrice McLogan: So that’s the way we moved out to Bethesda. But everybody had a terrible time finding houses. There were people, interestingly, a lot of military wives, whose husbands were overseas, would sometimes find someone to live, rent their house out, so they knew how desperate the situation was. And one of my friends in Ann Arbor who went to Washington moved into a house where the owner actually just took a bedroom, an old bedroom, and the girls had complete run of the house. And when they were there, she went up to her bedroom, so she never intruded on their feeling of togetherness. So housing was a terrible problem in Washington. 17:00 When Ted and I were married, we were very lucky to find an apartment, one of Ted’s colleagues, people were going out on points at that, after the war was over, they went on points, and one of his colleagues points were upped and so he had an available apartment. I don’t think he told many people, I mean, he just told Ted it was available, and he said, “We’ll take it!” [laughs] Jim Smither: So what did you do before he got that apartment, did he still have a place somewhere else or? Beatrice McLogan: No we had it after our wedding, we went with, he stayed with friends of my parents in Arlington and I lived in Bethesda, so it was quite a distance, and he had to save his gas. Gas was rationed in those days. So he would get out to Bethesda and then we were able to move into this apartment right after our honeymoon. 18:00 So that was very, very nice. Jim Smither: Are there other things, either your experiences or for that matter, you husband’s that you’d like to have on record or think that we should know about here? Beatrice McLogan: Well I just didn’t know if you knew that he’d been invested in the hall of fame, Ranger Hall of Fame, he had ranger training, as he told you, in Hawaii and, he was invested, oh, I’d say, seven or eight years ago. Jim Smither: Ok. Well, that’s good to have on the record. Beatrice McLogan: Yes. �Jim Smither: Overall, how do you think your time or experience in the military affected you, do you think it changes the way you do things or did it expose you to things you wouldn’t have seen otherwise? Beatrice McLogan: Well, I was maybe a little more sophisticated than some of the girls that went into service because first of all, I knew Washington. My parents’ good friends at Arlington 19:00 with whom we stayed, and I had a sister who was living there who worked at the Library of Congress, so I had been to Washington several times and I knew the town, I felt very comfortable there, like it very much, it was fascinating to be able to go—one thing Ted didn’t mention was after the Marauder Operation, there was such an uproar about the way the soldiers had supposedly been mishandled, or mistreated, that there was a Congressional investigation and they were given the order that the Marauders could never go into active duty again unless they so selected. And those hearings were held in Washington, obviously, the Congressional hearings. So, when I had time off or I would just work it out, there were days that I was working 20:00 afternoons or whatever, I could go listen to those hearings and the Pearl Harbor investigation, and hearings and that made Washington a very exciting place to be. Jim Smither: All right, well, thank you very much for taking the time to talk to us. Beatrice McLogan: You’re very welcome. Jim Smither: It’s been a pleasure. Thank you. 20:22 � Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Veterans History Project Creator An entity primarily responsible for making the resource Grand Valley State University. History Department Description An account of the resource The Library of Congress established the Veterans History Project in 2001 to collect memories, accounts, and documents of U.S. war veterans from World War II and the Korean War, Vietnam War, and conflicts in the Middle East and elsewhere, and to preserve these stories for future generations. The GVSU History Department interviews are part of this work-in-progress, and may contain videos and audio recordings, transcripts and interview outlines, and related documents and photographs. Coverage The spatial or temporal topic of the resource, the spatial applicability of the resource, or the jurisdiction under which the resource is relevant 1914- Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/page/InC/1.0/?language=en">In Copyright</a> Subject The topic of the resource Afghan War, 2001--Personal narratives, American Iran Hostage Crisis, 1979-1981--Personal narratives, American Korean War, 1950-1953--Personal narratives, American Michigan--History, Military Oral history Persian Gulf War, 1991--Personal narratives, American United States--History, Military United States. Air Force United States. Army United States. Navy Veterans Video recordings Vietnam War, 1961-1975--Personal narratives, American World War, 1939-1945--Personal narratives, American Publisher An entity responsible for making the resource available Grand Valley State University. University Libraries. Special Collections & University Archives Contributor An entity responsible for making contributions to the resource Smither, James Boring, Frank Relation A related resource Veterans History Project (U.S.) Identifier An unambiguous reference to the resource within a given context RHC-27 Language A language of the resource eng Source A related resource from which the described resource is derived <a href="https://gvsu.lyrasistechnology.org/repositories/2/resources/455">Veterans History Project interviews (RHC-27)</a> Oral History A resource containing historical information obtained in interviews with persons having firsthand knowledge. Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Identifier An unambiguous reference to the resource within a given context McLoganB Title A name given to the resource McLogan, Beatrice (Interview transcript and video), 2007 Creator An entity primarily responsible for making the resource McLogan, Beatrice Description An account of the resource Beatrice McLogan was a World War II veteran who served in the Navy WAVES from 1944 to 1945. In this account, McLogan discusses her family life, her enlistment and training, and her work in the code office in Washington D.C. Contributor An entity responsible for making contributions to the resource Smither, James (Interviewer) Subject The topic of the resource Oral history Veterans History Project (U.S.) Video recordings United States--History, Military Michigan--History, Military Veterans United States. Naval Reserve. Women's Reserve World War, 1939-1945--Personal narratives, American Women Language A language of the resource eng Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/page/InC/1.0/?language=en">In Copyright</a> Type The nature or genre of the resource Moving Image Text Relation A related resource Veterans History Project (U.S.) Date A point or period of time associated with an event in the lifecycle of the resource 2007-10-31 Source A related resource from which the described resource is derived <a href="https://gvsu.lyrasistechnology.org/repositories/2/resources/455">Veterans History Project Collection, (RHC-27)</a> Format The file format, physical medium, or dimensions of the resource application/pdf video/mp4 Publisher An entity responsible for making the resource available Grand Valley State University. University Libraries. Lemmen Library and Archives https://digitalcollections.library.gvsu.edu/files/original/d67f5010c1243fd8ae3a272af55c4295.mp4 2afe67be8baf0c69a2d263bb2e3881f8 https://digitalcollections.library.gvsu.edu/files/original/0a6caf2320adb2c21c3461c76b831c1d.pdf 5c9a7d919471949780736b47dc61dd03 PDF Text Text Grand Valley State University Veterans History Project Edward McLogan (01:04:34) Early Life, Family, And Education. 01:19:24 born in Flint MI; he went to high school in Flint, graduated from the University of Michigan in 1942; he was in the ROTC program in college, and he went “immediately into service as a second lieutenant infantry” 01:49:23his father was in the retail china and glass business; he was also mayor of Flint, though it was a "weak" mayor because it wasn't a full-time position 02:05:28he has two brothers; he and his wife [Beatrice] have six daughters, one son, twenty-one grandchildren, and three great-grandchildren 02:30:25he studied economics and political science, those were his majors, at the U of M Military Experience Before The War 02:45:11ROTC started in the freshman year [college], 1938 for McLogan, before hostilities broke out in Europe; they met twice of week for an hour or two, and it was mostly about the history of war, and much less about weapons 03:26:03his father was a "great flag waver," and encouraged him toward the ROTC and military service 03:48:28he remembers Pearl Harbor day "vividly"; in the fraternity house, most of them did not know for sure where Pearl Harbor was; they all picked up broom handles and marched around the room, not realizing how serious it [the attack on Pearl Harbor] was 05:02:15he does not believe that there were any changes in the ROTC program after the attack on Pearl Harbor, but they were already wearing uniforms and they knew that they would be participating "directly and very soon" 05:21:16he knew he would be in infantry because those in "engine" school had a choice between signal corp., ordnance, or engineering, while but those in "lit school" had to go in infantry Mr. McLogan's Formal Entry Into The Military 05:52:16he went into the military in the summer of 1942, to an infantry replacement training camp in Georgia 06:27:18one weekend, all the lieutenants went to Europe, the next week's lieutenants went to the Pacific; his college roommate arrived in camp the week before him and was sent to Europe; McLogan himself went to the Pacific, he was in camp in Georgia until almost Christmas time 07:09:03as far as training, there was "too much marching around," training with mortars, pistols, rifles, some marksmanship 07:28:03in his junior year in college, he went to Camp Custer in Battle Creek with the ROTC, and he had "fine" training there �08:46:10he shipped out from San Francisco, CA passed under the Golden Gate bridge, and arrived at Pearl Harbor a week later � infantry training and Ranger training began; it was "pronounced and rigorous training of a physical nature," and firing guns was part of the program; this lasted about a month In The Pacific 09:41:21from Hawaii, they sailed to New Hebrides, on the way to the staging area in New Caledonia; from there, the next destination was either the Solomon Islands or New Guinea; he was assigned to the unit that had relieved the Marines on Guadalcanal in January 10:25:21almost 100% of the combat on Guadalcanal had ceased at that point, and he went into training “under McArthur's edict of island hopping”; they knew they would be "making a beachhead" in the Solomon Islands but not exactly where 10:47:13in August, they left on the ship; he was on a destroyer one night with a battalion of men, and they went north in the dark at around 10 p.m.; they stopped at about 3 a.m., about a half mile from shore 11:41:23the battalion commander, Colonel Larson, decided, after talking with McLogan's company commander, that McLogan would take the lead going onto the beachhead; the coast watcher there had designated an area where it was believed they would be unopposed 12:47:10 they “off loaded” at 5 a.m. and went toward shore in a PT boat, which hit coral a hundred yards from shore--the men jumped into the water holding their rifles up; the colonel told him that the coast watcher would hold up one lantern if they were unopposed, and two if their was opposition; they got halfway to shore, and he saw the coast watcher holding up one lantern--they landed on Vella Lavella, “halfway up the chain” of islands [in the New Georgia group of the Solomons] 14:10:10Japanese Zeros were flying over, and there were many dead Japanese soldiers in the water; he believes that those soldiers had been machine gunned from the air, because there were no American soldiers on the island 14:56:14on shore, they dug their foxholes, they were told what position they were supposed to be in, maps were brought out, they were told where the enemy was supposed to be 15:12:06three or four days later, he got an order from headquarters telling him to have his men assemble for an important announcement; a major came along and told them that volunteers were needed for a dangerous assignment and they would have one minute to think about it � if they wanted to volunteer, they were supposed to take one step forward, but there was to be no pressure � he was in a regular army unit then, and the regular army units "never volunteered for anything" � a voice behind him told him that there was his chance—it was Sergeant Michael, and McLogan responded that he would if the sergeant would, knowing that the sergeant would not—it was a "challenge"—but the sergeant said "you're on" and there were two or three more from the approximately forty men in the group �out of 4,500 men in the regiment on the island, there were thirty-two volunteers 17:07:24four or five days afterward, another destroyer took them to New Caledonia; they didn't have much training there, they waited to be transported to Europe; there were three battalions of 900 men each, waiting, and even his battalion commander didn't know what would happen next 17:54:00his colonel put him in charge of the officers’ luggage that would be on the ship that was to take them back to the United States; he went into the town, Noumèa, found a barge, took it to the ship, and the men on the ship yelled that they had come from San Francisco, so McLogan was the first person who knew they would not be trained in or assigned to Europe 18:42:10a day later, they all left on the ship; they stopped in Brisbane, Australia, where they picked up the New Guinea guys � they traveled south, "under" Australia, to Perth; they could then leave the ship, but they had to walk in formation through Fremantle, where barmaids and waiters in restaurants and pubs came running out bringing them steins of beer, and people on the sidewalk applauded them � the next day they left, and it was three days later, when they were in the Indian Ocean, before they got the orders: the destination was Calcutta � India 19:50:26ten days later, two days away from port in Calcutta, it was discovered that the draft of their ship was too deep for the port there; they turned south and landed at Bombay after spending 29 days and nights on the ship 20:33:25they went on trains 100 miles north to a British camp run by General Orde Wingate, who was a "toughy" despite being 5'5" tall; they worked with Wingate for one month 21:04:28they traveled by train again, to central India where they built their own camp; they had two months of training there, beginning at the end of October 21:57:07on January 3, Brigadier General Frank Merrill arrived; he was a big guy, smart, had attended both West Point and MIT, was fluent in Japanese and knew "a bit of Chinese as well" � after a week Merrill contacted Lieutenant General Joseph Stillwell, the commander of the Pacific theater; the War department code word for the men was "Galahad Force" � Stillwell sent McLogan's battalion, by trains, to the Assam province in northeastern India, bordering Burma [Myanmar] 23:17:16McLogan was in the green combat team (each of the three battalions had a combat team), the only one with combat experience, in the Solomons and New Guinea, while the other two were from the States or the Caribbean 23:53:27Merrill decided to split up the battalions, and McLogan transferred from his battalion to the Caribbean battalion, and there were two combat teams in each battalion; once behind the lines they operated together in a sense, with "no more than a day's march" between trails; his [the one he transferred into] was the second battalion; the first battalion was the one from the States 24:51:23they didn't know exactly what Stillwell wanted them to do, but knew they �would be going behind the lines in Burma; they had seen a British map with Burma on it, but it was a thirty-year-old map, though the city of Myitkyinā, on the Irrawaddy River near the China border, was probably on it; they did not know at the time that that was their objective � they went behind the lines at the end of January and were there until the first week in June Burma [Myanmar] 25:49:00they marched and battled their way across Burma, 700 miles, each soldier carrying sixty to seventy pounds of equipment on his back 26:17:26there was just one road through northern Burma, a dirt road that the Japanese had built for supplying their own troops; McLogan never saw any buildings, only bamboo and grass shacks; it was 125 days of sleeping on the ground, digging foxholes, and some "bad" battles; they picked their way until they found "no opposition" then went around them [the Japanese] 27:31:21the terrain was hilly, forested, and they didn't get much sunlight because of the height of the trees; when they marched at night it was pitch dark and they had to hang on to the backpacks of the guys in front of them, or the horses' tails [horses and mules carried supplies] 28:22:02they would be up at the crack of dawn, breakfast was K- rations, the same for the entire 125 days; they tried to have an air drop every five days, because fivedays worth was the limit of the food and ammunition they could carry—they had radio contact with the base for supplies; the Japanese interfered with some of their supply drops from parachutes 30:10:03their initial mission was to take the village of [he didn't remember the name] 55 miles away, and it took them five days to get there; it was a tough battle that lasted three days; with the three battalions acting together; the Americans prevailed � two or three weeks later, the second main battle happened; it had taken two or three weeks of marching to get to it 31:54:19their objective was “five miles south of the village where the Japanese troops were”; they were supposed to block the road below the village � their destination was a few hundred yards from the road; late in the afternoon they crossed the river, "a big river," and dug themselves in; late that night they heard Japanese trucks coming up from the south and heard tailgates slamming; in the morning, the Japanese attacked the Americans 33:39:08at 10 a.m. that morning, McLogan was summoned by Lieutenant Colonel George McGee; McLogan was told to take his platoon of thirty men [it had been thirty-nine] go to the road, through Lieutenant Whitten's area, because Whitten was not under attack; McLogan was told to get two light machine guns from the heavy weapons depot; after that, "we'll come and try to rescue you" 36:03:29they got the guns moved over to Whitten’s platoon; they went "maybe a hundred yards," suddenly there was a Japanese patrol, and the Americans and Japanese were shooting at each other; three Americans were wounded and perhaps two killed; McGee, on the radio, told them they had to get to the road 38:57:06McLogan's men outnumbered the Japanese—there were about ten Japanese—and they scattered; ten minutes later, they ran into another Japanese �patrol—McLogan told McGee on the radio that two more Americans were wounded including one of the machine gunners, but they would still try to get to the road 39:55:05McGee came back on the radio and told them that American planes flying over the road strafing had informed him that the area was "crawling" with Japanese; McLogan was ordered to bring his men back in, but there was a lot of fighting throughout the day 40:19:20late in the day, they were ordered to go back across the river; the men were tired, had not slept "in several nights," and were out of food, but were still fairly healthy; it had been raining all day and it was muddy � they walked until midnight, then were ordered off the trail to rest, and they slept for two hours; they hit the trail again at daybreak, and in one or two days were back at the foot of the hill where they had started; they met up with one of the other battalions, went halfway up the hill and dug in 42:15:06the next morning, moving back onto the trail, they came under Japanese artillery fire that was "accurate from the first round"; both men and animals fell, and there were many wounded � they were at the top of a ridge, and the only way to go was straight forward; they marched, reaching Nhpum Ga at 10 a.m.; Merrill was there and told them they had "to hold this place"; he then moved his headquarters five miles away 43:23:20at 4 p.m. the Japanese infantry attacked, beginning ten days of fighting; they tried to send two patrols a day to each of the other two battalions, but on the third day, some Marauders were killed, and they gave up the patrol idea; Merrill himself had a heart attack and was evacuated 44:01:17they lost their water hole in the village to the Japanese; they then had no water except what drained into a “swampy area” in a defilade and there were a dozen dead horses and mules lying in "that stuff"; each man was limited to half a canteen of water a day 44:48:03the Japanese seemed "a nocturnal type," and the Americans would hear them laughing, talking and chopping down trees, and they would yell insults to the Americans 45:15:07they had translators: thirteen Japanese Americans from California � the one McLogan knew best, his family had returned to Japan before the Pearl Harbor attack � "Roy's younger brother" wound up in the Japanese Army and his parents went to Nagasaki [the older son, Roy Matsumoto, served in the US Army with McLogan] � McLogan's platoon held the top of a hill containing a trail, and it vital to hold that trail; McGee, on the radio, told him to send Matsumoto, who took off his pack and crawled down the hill to enemy lines; twenty minutes later, he reported back to McLogan that his platoon would be hit "full strength" the next morning 47:52:19McGee told McLogan to vacate his foxholes, booby trap them, and move a hundred feet up the hill, giving them a longer firing field 48:37:17the next morning, the Japanese came up the hill and McLogan gave the order to shoot; there were about seventy-five Japanese and lots of them were shot; the �surviving Japanese retreated back down the hill, trying to drag some of their wounded with them 49:10:13in another ten minutes, the Japanese charged again, trying to take the hill, about fifty of them--the Americans counted fifty-four bodies 49:48:03the next day was Easter Sunday; McGee sent out patrols to look for the Japanese, but they found none, and the Americans moved back five miles, to Merrill's camp 50:16:09seven hundred men were now left out of the nine hundred originally in McLogan's battalion, 352 had been wounded and 54 killed 51:36:15they heard a rumor that they would be sent to Myitkyinā; a few days later they were given new maps, then the orders came threw for them to move to Myitkyinā, a hundred miles away, with a 6,000-foot mountain range to cross, and the monsoon was starting besides; it took them twenty-seven days to get there, the trail hadn't been used in ten years and "it got muddy right away from the animals" � the objective was to take the airstrip, a big one, two or three miles from the city; they completely surprised the Japanese; one of the other battalions captured the field � Chinese troops followed them in and made two aborted attempts to capture the city, and even fought each other at one time 54:22:19around June 1 or 2, McGee told McLogan he had lost contact with the Japanese, so he sent him out with his platoon, number ten, to find them � it was a "scrubby, hilly area," and the platoon separated at a "huge bush," with eight men going around to the right, and McLogan and Sergeant Michael going to the left; McLogan saw a Japanese soldier kneeling in his foxhole holding his rifle--he shot Michael in the forehead The Adventure In Burma Ends 56:11:13Stillwell wrote in his diary that "Galahad is just shot"; the next day they were flown out, and everyone went to a hospital; McLogan himself had been wounded at Nhpum Ga, and the wound, though not serious, had not healed 57:16:17part of his men went back in and captured Myitkyinā, but "didn't take it until August" while McLogan was in the hospital 57:46:24McLogan was in the hospital for two months, then he went on leave, to Darjeeling, in northern India 59:03:27after a week, maybe ten days in a “beautiful hotel in Darjeeling, McLogan received shipping orders to go home; he was the "train commander" of the troops returning home; the train took seven days and nights to get to a certain town [McLogan did not remember the name] in Pakistan, where they were put on planes to go home Back In The States 1:00:21:15he was not immediately discharged from the military when he got home— he went to a camp in Florida 1:00:42:28he was reassigned to Fort Benning, and was assigned to do map reading there; he was ordered to the commandant's office—the general's aide de camp was ill, to be sent back to the states; they were selecting aides for him, he had a junior and a �senior aide; McLogan was selected � he saw "all of these famous names," the president of the Phillipines, for example, and was "always in the front seat with the driver" when the "big generals" came through Fort Benning Marauders Rewarded 1:02:24:09bronze stars were given to the Marauders, "to everybody who went through the whole bit," with few exceptions; there were no silver stars or congressional medals, other than the Purple Heart; "we were not mistreated"; colonels and the column commanders got silver stars Beatrice McLogan 1:04:00:15McLogan and his wife had known each other at the U of M; she joined the WAVES [during WWII], a “very fine” and “she enjoyed every minute of that” Washington DC 1:04:34:11after the end of war: at Fort Benning: his colonel was replaced and sent to the Pentagon, where he would not need an aid, but he got McLogan a "decent assignment" working with the ASTP [Army Specialized Training Program] � Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Veterans History Project Creator An entity primarily responsible for making the resource Grand Valley State University. History Department Description An account of the resource The Library of Congress established the Veterans History Project in 2001 to collect memories, accounts, and documents of U.S. war veterans from World War II and the Korean War, Vietnam War, and conflicts in the Middle East and elsewhere, and to preserve these stories for future generations. The GVSU History Department interviews are part of this work-in-progress, and may contain videos and audio recordings, transcripts and interview outlines, and related documents and photographs. Coverage The spatial or temporal topic of the resource, the spatial applicability of the resource, or the jurisdiction under which the resource is relevant 1914- Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/page/InC/1.0/?language=en">In Copyright</a> Subject The topic of the resource Afghan War, 2001--Personal narratives, American Iran Hostage Crisis, 1979-1981--Personal narratives, American Korean War, 1950-1953--Personal narratives, American Michigan--History, Military Oral history Persian Gulf War, 1991--Personal narratives, American United States--History, Military United States. Air Force United States. Army United States. Navy Veterans Video recordings Vietnam War, 1961-1975--Personal narratives, American World War, 1939-1945--Personal narratives, American Publisher An entity responsible for making the resource available Grand Valley State University. University Libraries. Special Collections & University Archives Contributor An entity responsible for making contributions to the resource Smither, James Boring, Frank Relation A related resource Veterans History Project (U.S.) Identifier An unambiguous reference to the resource within a given context RHC-27 Language A language of the resource eng Source A related resource from which the described resource is derived <a href="https://gvsu.lyrasistechnology.org/repositories/2/resources/455">Veterans History Project interviews (RHC-27)</a> Oral History A resource containing historical information obtained in interviews with persons having firsthand knowledge. Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Identifier An unambiguous reference to the resource within a given context McLoganE Title A name given to the resource McLogan, Edward (Interview outline and video), 2007 Creator An entity primarily responsible for making the resource McLogan, Edward Description An account of the resource Edward McLogan entered the ROTC at the University of Michigan in 1938, and joined the US Army in 1942. He served as an officer with an army unit in the Solomons, participating in a landing on Vella Lavella, and subsequently volunteered to join a specialized unit that turned out to be Merrill's Marauders. He served as an officer on the unit's mission behind Japanese lines in Burma, and despite being wounded remained with it until the end of its mission. He served for the rest of the war at Fort Benning and in Washington. Contributor An entity responsible for making contributions to the resource Smither, James (Interviewer) Subject The topic of the resource Oral history Veterans History Project (U.S.) United States--History, Military Michigan--History, Military Veterans Video recordings United States. Army World War, 1939-1945--Personal narratives, American Language A language of the resource eng Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/page/InC/1.0/?language=en">In Copyright</a> Type The nature or genre of the resource Moving Image Text Relation A related resource Veterans History Project (U.S.) Date A point or period of time associated with an event in the lifecycle of the resource 2007-10-31 Source A related resource from which the described resource is derived <a href="https://gvsu.lyrasistechnology.org/repositories/2/resources/455">Veterans History Project Collection, (RHC-27)</a> Format The file format, physical medium, or dimensions of the resource application/pdf video/mp4 Publisher An entity responsible for making the resource available Grand Valley State University. University Libraries. Lemmen Library and Archives https://digitalcollections.library.gvsu.edu/files/original/ee3a9d0ccf8bdec2d9fc240c09ec4b46.mp4 4e21b291227b7090977b0077f2bff5df https://digitalcollections.library.gvsu.edu/files/original/a0b4d2016fb07e17eb8dd68e89265cde.pdf ae0f297e8ca247e6fd960d0e4ba99670 PDF Text Text Grand Valley State University Veterans History Project Interview Notes Length: 23:40 Peter McMillan WWII Veteran United States Air Force; December 1945 to 1947? * Important note: McMillan often refers to WWII as WWI, however, based on content and his birth date, he means WWII. (0:38) Pre-enlistment/Enlistment • High school student; inducted 9 days before graduation • Air Force gave him 6 months to “tie up loose ends” so was able to graduate • Finished basic training when the atomic bombs were dropped on Hiroshima and Nagasaki • Shipped over to Guam but cadet school closed; became clerk (3:30) Pearl Harbor Day • 9th grade • When heard news, knew he had to start planning so that he could finish high school and then enlist in the war. (4:30) Story about Japanese and Marines in Guam • When in Guam (while considered a “rookie”), McMillan saw a group of Marines go into the jungle to find Japanese soldiers. He thought the Marines were just joking but then he heard gun shots. The Marines came back saying they had killed two Japanese. • Many Japanese on Guam didn’t realize war was over o Stayed in caves • The Japanese on the island had a habit of “sneaking up” on American soldiers who were taking showers and killing them. (American soldiers in these situations were easy targets because the showers were outside in a relatively private area near the jungles). (6:10) Baseball • Played baseball all the time. (6:40) Most memorable experience in Guam • 7 days after arriving in Guam, went to midnight mass for Christmas (which was held outside). During the mass, he heard a shot fired, which had killed a lieutenant. A few Marines went out to investigate. Soon, the Marines returned having killed the Japanese soldiers who killed the lieutenant. �(7:51) Casualties • Continued even after WWII was over because Japanese on island didn’t believe war was over. • In the barracks, cots were organized in rows. Often McMillan would wake up and find the men who slept on the ends of the rows stabbed to death. (9:30) Leisure and home correspondence • Baseball, cards, movies, instruments, singing • Discussion of the USO – United Service Organization (12:32) Short discussion on holidays (13:17) Skills/lessons learned (13:57) Last day in the service • Came into Detroit Central Station and then took a cab home. Wanted to surprise mom so he had the cab driver stop a few houses away. But his mom had an “eagle eye” and saw the cab stop. She ran out to greet him and instead, surprised him! (14:55) Family’s ties to the service • Dad and his dad’s brothers served in WWI • McMillan and 2 of his brothers served in WWII; youngest brother served in Korea (15:51) Life after the war • GI Bill and college • Marriage about a year and half after home from war • Friendships made in war were not kept up after war; each went his own way. • Became teacher and a coach (21:23) Interesting question and response to: “How did you feel when other Americans began protesting the wars following WWII?” • Discusses briefly why went to war • Called “the greatest generation” in that they were patriotic and did what called to do • Protests of the 1960s required a lot of adapting for his generation o Realized WWII generation was often “blindly patriotic” o Had great effect on his generation because people realized that they had been following blindly and perhaps should challenge the government. (22:54) Slideshow of 7 pictures from his time in service � Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Veterans History Project Creator An entity primarily responsible for making the resource Grand Valley State University. History Department Description An account of the resource The Library of Congress established the Veterans History Project in 2001 to collect memories, accounts, and documents of U.S. war veterans from World War II and the Korean War, Vietnam War, and conflicts in the Middle East and elsewhere, and to preserve these stories for future generations. The GVSU History Department interviews are part of this work-in-progress, and may contain videos and audio recordings, transcripts and interview outlines, and related documents and photographs. Coverage The spatial or temporal topic of the resource, the spatial applicability of the resource, or the jurisdiction under which the resource is relevant 1914- Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/page/InC/1.0/?language=en">In Copyright</a> Subject The topic of the resource Afghan War, 2001--Personal narratives, American Iran Hostage Crisis, 1979-1981--Personal narratives, American Korean War, 1950-1953--Personal narratives, American Michigan--History, Military Oral history Persian Gulf War, 1991--Personal narratives, American United States--History, Military United States. Air Force United States. Army United States. Navy Veterans Video recordings Vietnam War, 1961-1975--Personal narratives, American World War, 1939-1945--Personal narratives, American Publisher An entity responsible for making the resource available Grand Valley State University. University Libraries. Special Collections & University Archives Contributor An entity responsible for making contributions to the resource Smither, James Boring, Frank Relation A related resource Veterans History Project (U.S.) Identifier An unambiguous reference to the resource within a given context RHC-27 Language A language of the resource eng Source A related resource from which the described resource is derived <a href="https://gvsu.lyrasistechnology.org/repositories/2/resources/455">Veterans History Project interviews (RHC-27)</a> Oral History A resource containing historical information obtained in interviews with persons having firsthand knowledge. Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Identifier An unambiguous reference to the resource within a given context McMillanP Title A name given to the resource McMillan, Peter (Interview outline and video), 2006 Creator An entity primarily responsible for making the resource McMillan, Peter Description An account of the resource Peter McMillan is a WW II veteran who served in the United States Air Force from approximately 1945 to 1947? in Guam with a six-week stint in Hawaii. Although a majority of his time in the service occurred after WWII had ended, McMillan's story still provides a unique perspective on post-WW II conflict in the Pacific Theater. This account details how tension and confusion continued well into the post-WWII years. He talks briefly about the role of the United Service Organization and his correspondence home. Finally, McMillan discusses life after war - the role of the G.I. Bill and his generation's commitment to WW II - and what impact the anti-war protests of the 1960s had on his generation. Contributor An entity responsible for making contributions to the resource McMillan, Kelsey (Interviewer) Forest Hills Eastern High School (Ada, Mich.) Subject The topic of the resource Oral history Veterans History Project (U.S.) Video recordings United States--History, Military Michigan--History, Military World War, 1939-1945--Personal narratives, American United States. Air Force Veterans Language A language of the resource eng Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/page/InC/1.0/?language=en">In Copyright</a> Type The nature or genre of the resource Moving Image Text Relation A related resource Veterans History Project (U.S.) Date A point or period of time associated with an event in the lifecycle of the resource 2006-06-28 Source A related resource from which the described resource is derived <a href="https://gvsu.lyrasistechnology.org/repositories/2/resources/455">Veterans History Project Collection, (RHC-27)</a> Format The file format, physical medium, or dimensions of the resource application/pdf video/mp4 Publisher An entity responsible for making the resource available Grand Valley State University. University Libraries. Lemmen Library and Archives https://digitalcollections.library.gvsu.edu/files/original/29fc6655d4b24d1a4cf0bba5a6d10d98.mp4 250198c72d3a3a879bad40b34aae813c https://digitalcollections.library.gvsu.edu/files/original/47a1a5466698b40184d2e73934f3ad3a.pdf a6f84553c303badf7b2b6f2500150c9d PDF Text Text Grand Valley State University Veterans History Project Martin McNamara (1:25:53) Background Information (00:11)        Born in 1916 in Michigan. (00:16) His mother and father both emigrated from Canada. In Michigan they ran a farm. (00:32) Martin attended school through the 6th grade. When he was 10 he quit school there due to the death of both his parents. (1:31) He had 9 brothers and sisters. After his parents’ death, Marin lived iwith one of his older sisters. (2:18) Martin completed high school and moved to the Lower Peninsula to work at an auto dealership in 1937. (2:30) He joined the National Guard in 1938 with several of his close friends. (2:53) In 1939 [1940?] his unit was activated and Martin was then in the U.S. Army. (3:26) Service in the National Guard (4:15)     He served in the 119th Field Artillery. (4:16) Every summer the men went on Maneuvers. Every Thursday night the men met for training. (4:36) He was made sergeant in the motor section. (5:58) After being mobilized, the unit was sent to Fort Knox, Kentucky for basic training. (6:16) Basic Training (6:20)            His work was assigned in the motor pool. (6:40) The trucks that Martin used were not very reliable. (7:18) The men were assigned to go to Fort Leonard Wood, Missouri, but due to construction the men were sent to Fort Knox. (7:46) The men were at fort Knox for approx. 3 months before being moved to Fort Leonard Wood. (8:28) At Fort Leonard Wood, the areas used for training were former residences. Because the people were forced out, often live stock was left behind to turn wild. (9:30) There were a number of units at Fort Leonard Wood aside from Martin’s. (10:15) The men were given liberty to go into town quite often. (11:05) When off base there were caves that Martin explored and bars. (11:37) Martin was about 5-10 years older than the average recruit. (14:00) Martin was eventually transferred out f the 119th Field Artillery to the 260th Coast Artillery. (14:52) He was sent to Washington State in 1942 to be shipped off to Alaska. (16:16) Travel to Washington and Alaska (17:40)  The men were not given a furlough before being sent to Washington. (17:45) �            While in the 260th Coast Artillery, the unit was given larger 6 inch guns than the men had in the 119th Field Artillery. (18:35) The men were given Caterpillar tractors. Martin was given the responsibility of knowing how to repair these tractors. (19:30) The men were shipped to Washington by train. (20:37) The guns were loaded on to flatbeds to be shipped. Martin very clearly remembers seeing the mountains while traveling to Washington. (21:30) The trip to Washington took several weeks. (22:25) The men stayed in Washington as a stopover to load up on ships before being sent to Alaska. (24:07) Martin was sent to Alaska in an old German troop transport that the U.S. acquired after World War I. (24:26) There were sightings of submarines that resulted in the ship needing to stop in various ports during the voyage. (25:40) There were multiple ships traveling with Martin’s but not very close together. (26:25) Ship stayed in a cove for 1 week while waiting for submarines to pass. During this week, the men played many cards and listened to music. (27:17) The ship landed in Kodiak Bay in Alaska in early summer 1942. (28:08) After landing, the men traveled up the coast to a field where they sent up camp. The purpose of Martin being in Alaska was to protect the Coast. (28:48) Service in Alaska (28:49)             Martin was given the task of getting the heavy guns the men had up to the top of the mountain. To do this, the men had to make a road up the mountain. (30:14) Martin does not recall if the men had engineers with them to assist them with moving and setting up position for the guns. The men did not have heavy equipment such as bulldozers to aid them with the task. (31:41) The guns were set up after approx. 1 month. (33:14) The weather was very wet and muddy while the men set up the guns. It rained almost every day. There wasn’t any snow. (34:26) The weather was still quite warm. (35:39) Martin was still in Kodiak after winter began. The temperature was not overly severe. (37:15) The men did build barracks for the winter that the men stayed in instead of tents. (38:10) Martin did not have any encounters with the Japanese. Other islands did though. (38:46) After Kodiak Martin was sent to Amchitka. This island is near the end of the Aleutian Islands. (39:15) Martin was able to see Japanese planes land on an airstrip on Kiska. (40:40) The Japanese often put dummy planes on their airstrip to trick bombers into continuously attacking targets that were not real. (42:00) When moving to Amchitka the men had to rebuild the equipment on the new island. (43:11) Life in Alaska (43:42)    There was a lot of snow. The men often played cards for entertainment. (43:50) In Amchitka, men often had to dig themselves out of snow banks. (44:12) Special work had to be done on the trucks to stop their engines from freezing. (44:50) �           The Caterpillar tractors could be used in the snow when trucks could not. (45:21) Men often used skis or snowshoes for transportation during periods of high snow. (46:30) The men did not experience too many problems with low morale. (47:22) Martin never felt like he was in any danger while in the position he was in. (49:30) Radios and a paper printed in Kodiak were used to inform the men on the state of the war. (50:00) There were still native civilians in Kodiak while Martin was stationed there. (50:29) There were no civilians on Amchitka. (50:57) There was an abundance of wildlife including bear and sea otter. (51:48) The men Martin served with were mostly from around the country. A good number, however, were from Michigan. (53:55) The food supply was very nice. The men were given beer on occasion. (55:40) Martin was not given any furloughs during the 3 years he served in Alaska. (56:30) Leaving Alaska (57:16)      Martin left the Aleutian Islands with part of his unit to Washington. He was then sent from Washington to Texas. (57:44) Martin was sent to Texas in mid 1944 and was given training in night fighting and maneuvers. (1:00:31) Martin and his unit were also given engineering training and were made to build pontoon bridges. (1:01:12) While nearing the end of the war, there was a great push for paratroopers for the invasion of Japan. Martin was recruited and switched from engineer training to paratroop training. (1:03:40) Martin decided to join the paratroopers because he wanted to invade Japan and see some action. (1:04:38) Paratrooper Training (1:04:50)        Martin was 5-10 years older than the average paratrooper recruit. He had no problem with the training. (1:05:10) The men did jump off towers for their first 5 jumps. (1:05:40) The first time Martin jumped from a plane the experience was surprisingly casual. (1:07:17) Many men were afraid to jump from the plane. There were, however, very few accidents. (1:08:33) The men were not given any information on the Japanese invasion. (1:09:06) The men had to jump with dummy weights that were intended to train the men for being dropped with their supplies. (1:11:51) The paratroop training was finished before the war ended. Martin's training was 2 weeks longer than normal due to an additional demolitions course. (1:14:11) Discharge (1:15:25)    When the men on Martin’s base learned of the end of the war, the men celebrated. (1:15:30) With 88 points, Martin was discharged 2 weeks after the war ended in August of 1945. (1:16:00) Martin returned to work at a car dealership shortly after returning home to Michigan. (1:16:43) � Martin was married in approx. 1946/1947. (1:17:33) Thoughts on Service (1:20:31)   Over all, Martin enjoyed his time in the service. (1:21:02) Martin, an Eagle Scout, was made a scout master of a Boy Scout Troop. He thought his time in the service helped him serve in this position. (1:22:14) � Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Veterans History Project Creator An entity primarily responsible for making the resource Grand Valley State University. History Department Description An account of the resource The Library of Congress established the Veterans History Project in 2001 to collect memories, accounts, and documents of U.S. war veterans from World War II and the Korean War, Vietnam War, and conflicts in the Middle East and elsewhere, and to preserve these stories for future generations. The GVSU History Department interviews are part of this work-in-progress, and may contain videos and audio recordings, transcripts and interview outlines, and related documents and photographs. Coverage The spatial or temporal topic of the resource, the spatial applicability of the resource, or the jurisdiction under which the resource is relevant 1914- Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/page/InC/1.0/?language=en">In Copyright</a> Subject The topic of the resource Afghan War, 2001--Personal narratives, American Iran Hostage Crisis, 1979-1981--Personal narratives, American Korean War, 1950-1953--Personal narratives, American Michigan--History, Military Oral history Persian Gulf War, 1991--Personal narratives, American United States--History, Military United States. Air Force United States. Army United States. Navy Veterans Video recordings Vietnam War, 1961-1975--Personal narratives, American World War, 1939-1945--Personal narratives, American Publisher An entity responsible for making the resource available Grand Valley State University. University Libraries. Special Collections & University Archives Contributor An entity responsible for making contributions to the resource Smither, James Boring, Frank Relation A related resource Veterans History Project (U.S.) Identifier An unambiguous reference to the resource within a given context RHC-27 Language A language of the resource eng Source A related resource from which the described resource is derived <a href="https://gvsu.lyrasistechnology.org/repositories/2/resources/455">Veterans History Project interviews (RHC-27)</a> Oral History A resource containing historical information obtained in interviews with persons having firsthand knowledge. Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Identifier An unambiguous reference to the resource within a given context McNamaraM1143V Title A name given to the resource McNamara, Martin (Interview outline and video), 2008 Creator An entity primarily responsible for making the resource McNamara, Martin Description An account of the resource Martin McNamara, born in 1916 in Michigan, joined the National Guard in 1938, serving with the 119th Field Artillery. His unit was mobilized over a year before Pearl Harbor, and sent to train at Fort Knox and Fort Leonard Wood. In 1942, he was reassigned to the 260th Coastal Artillery and sent to Alaska. He served as a driver for trucks and caterpillar tractors, and helped build bases on Kodiak and Amchitka Islands in the Aleutians. He was sent to Texas in 1944 and trained as a combat engineer and as a paratrooper in preparation for the invasion of Japan, but the war ended before he could be sent overseas, and he was discharged shortly afterward. Contributor An entity responsible for making contributions to the resource Smither, James (Interviewer) Kentwood Historic Preservation Commission (Kentwood, Mich.) WKTV WKTV (Wyoming, Mich.) Subject The topic of the resource Oral history Veterans History Project (U.S.) United States--History, Military Michigan--History, Military Veterans Video recordings United States. Army World War, 1939-1945--Personal narratives, American Language A language of the resource eng Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/page/InC/1.0/?language=en">In Copyright</a> Type The nature or genre of the resource Moving Image Text Relation A related resource Veterans History Project (U.S.) Date A point or period of time associated with an event in the lifecycle of the resource 2008-07-10 Source A related resource from which the described resource is derived <a href="https://gvsu.lyrasistechnology.org/repositories/2/resources/455">Veterans History Project Collection, (RHC-27)</a> Format The file format, physical medium, or dimensions of the resource application/pdf video/mp4 Publisher An entity responsible for making the resource available Grand Valley State University. University Libraries. Lemmen Library and Archives