1 24 26018 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 ,. 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"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? 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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/c4f0b6906a50546cbd2e4c0ab47d6010.mp4 393c3b012831c9faf054e7c5f99a0ff8 https://digitalcollections.library.gvsu.edu/files/original/456ee4d5ea78a67510f37b38df3fea51.pdf fbe60dce181af268ac53cf96079449d2 PDF Text Text Living with PFAS Interviewee: Grant Medich Interviewer: Dani DeVasto Date: December 11, 2025 Dani DeVasto (DD) (00:03): All right. I am Dani DeVasto, and today, December 11th, 2025, I have the pleasure of speaking with Grant Medich. Hi, Grant. Grand Medich (GM) (00:13): Hi, Dani. DD (00:15): Grant, can you tell me about where you're from and where you currently live? GM (00:20): Okay. Well, um, I was born in Indiana, but from a young age, uh, grew up in, uh, the locale of White Pigeon Michigan, which is in St. Joe County, uh, just north of the Indiana border. Um, and I am now living just north of Kalamazoo and, uh, Prairieville Township, which is the Southernmost, actually, I think it's the south southern southwestern-most township in Barry County, uh, just north of Kalamazoo again. DD (00:53): How long have you GM (00:54): For, I think it was 21 years. DD (00:57): Okay. So you were in Rockford 21 years. How long have you been in Prairieville Township? GM (01:02): The past four years. Yeah. DD (01:04): Okay. Um, Grant, can you tell me a story about, uh, PFAS, your experience with PFAS or with PFAS in your community? GM (01:15): Well, it's funny because we concentrate a lot on PFAS now is our, you know, with the whole, uh, issue. Well, not, not in just the Rockford associated community, but, uh, since I'm <laugh>, I'm no longer in Rockford, I'm no longer part of the community. I'm Rockford associated, I'd say. Um, but how we got, uh, concentrated on PFAS is interesting because it wasn't PFAS at the beginning. It was, it was a, uh, collo, uh, factory, which happened to be a tannery, and it was, which, which was closing down. And, uh, 1 �we knew there had been processing chemicals, and our focus was on hexavalent, well, chromium, which we were worried about the hexavalent, uh, uh, chromium. And as we got more into it and certain things are controlled or not, we found PFAS was as big, if not a bigger issue. And so, uh, I guess that's part of the story that our concerns about, um, a cleanup operation or, or a, uh, really it's a factory decommissioning operation. Uh, we wanted to see it done in a, uh, environmentally friendly way, not just for the local community, but as it's on the Rogue River, which runs through Rockford is a tributary to the Grand River. It would affect everybody downstream from that point. So, uh, again, we were focused on one issue and found, uh, PFAS was another issue. And then we found other communities were struggling with the same, same, uh, concerns. DD (03:10): So how did you come to be involved or concerned with the tannery demolition? GM (03:18): Okay. Uh, well, the tannery as is most older, um, installations are, was really a series of buildings. And, uh, the company, Wolverine Worldwide, which, uh, was the name of the company in, in charge of it at that time, they were pretty much, they weren't ever bought out by anybody, but they, that was their, um, the company name they had for quite some time. Um, they had basically, uh, continual ownership of that. And so there wasn't a case where one company bought, you know, another company's assets and liabilities. We thought, well, uh, this was founded in Rockford by people who lived in Rockford and just have a feeling that they kind of had a, an obligation besides providing jobs for so many years, uh, to decommission it you know, in a manner that didn't leave, uh, uh, leave it, um, to be a risk factor. GM (04:28): Um, but we found as they were beginning demolition, um, some of the, uh, issues involved were migratory dust. And, uh, shortly before we addressed this, uh, a couple of our streets in the downtown area started holding little meetings, um, kind of centered around the McIntosh, uh, family. Um, Mike and Lynn oftentimes hosted this, and there were a handful of other families, I think, I think, uh, my former wife and I hosted at least once. But when it became an issue that could be considered a bit more politically involved, which to us it wasn't ever a political issue, it was a, a health and safety issue. Uh, some of the families that have been involved in it all along, um, started being a little, little, uh, more, you know, circumspect and drew back from, from the continued meetings and along with the, uh, neighborhood association kind of spurned off, um, the, uh, uh, concerned citizens Association. GM (05:53): And so we would have separate meetings, basically the same, same core group for the better part. Uh, again, Lynn was instrumental in, in, uh, helping that happen, but she was always, uh, asking for help. And so, uh, we had, uh, Gail Mancewicz and I was involved in and out in various capacities, uh, selfemployed. Um, and so that gave me that freedom of interaction to where some days I was available midday and other people were not. They were at their, at their day jobs. Other times I wasn't, it was, I was in construction, so I wouldn't be available for a couple weeks because I was on a, you know, deep in a job. So that's how I became involved with that. And the more we, I don't know, I understand it. I mean, neighbors are neighbors and part of getting along with your neighborhood is, uh, being concerned for them, but not being too nosy. GM (06:52): 2 �And that is true also with corporate neighbors. So I think corporate neighbors, they like the idea of getting along with their neighbors, but they understand they are a corporation, and, uh, they can't be as chummy or, um, I mean, they, they go to their own homes and they have those neighbors, and so they, they can't really be double-dipping there. But when we get more into issues that they consider operations, um, related issues, uh, that's where it becomes none of our business, where if it's environmental, we do consider it, it is our business. Because at some point, um, Wolverine continues to be in, Wolverine Worldwide, continues to be located in Rockford. But my thought was, 'cause I had family members who worked for large corporations, and you have a change of CEO, and all of a sudden you're located in Denver or Chicago or Arizona. And, uh, even though they were a, had a long history in Rockford, I personally wasn't convinced that they just couldn't just pull up roots and get out of it. So that was kind of nature of my interest. And, and I lived right across the street from, uh, the building that remains, which is their shoe store. Yeah. But basically across the street from the, the factory complex DD (08:23): So was that a concern for you that they could leave? Or was that not a concern? GM (08:29): Uh, more concern of, well, my, you know, being in a small business that the, the, uh, scale of operations is vastly different, but I always figured there's a cost of doing business. And if they had done something that they didn't consider nefarious, but, um, over time was determined to be problematic, that cleaning up the, the residue is a deferred cost since they didn't do it, what we now consider right the first time. Or they didn't take care of, uh, spillage when it became known, but not publicized that they were dealing with hazardous chemicals that shouldn't get into groundwater. That's the time they should have dealt with it. And for it to be brought up to them at a later date, didn't negate the fact that they still had, uh, really an ethical responsibility to, um, have a clean and safe operation, not just for their workers or their consumers, but, uh, the people who worked there and lived nearby and, and their neighbors. DD (09:48): So, as someone who did live nearby, did you have any personal concerns about what was about to go down or what had gone down? GM (09:58): Well, I, I, in my, me and my family were rather blessed because we moved into our home in, uh, February of 1999. And, uh, we had city water, but that's the time when, uh, Rockford, uh, stopped drawing their city water from the river. Uh, and I believe it was downstream from the tannery. Um, and they started the deep well, um, deep well, uh, pumping system. And so my children, my family was never exposed to it, besides what it might have been residually located in the, uh, in the piping. Um, but it's, uh, been somewhat determined that ingesting PFAS is a little less issue than, um, inhaling it. And, uh, I always, I always kind of thought it odd too that, uh, the, when I was young, we always took baths. We didn't do showers, but at some point people started taking showers, and I thought, well, the aeriation of the mist in the water, maybe that became more of a health issue with issues like, or PFAS than, than just sitting in it, which is still not good for you, but seems less of an issue. But, yeah. So I had, uh, almost, oh, just kind of an ethical concern as a neighbor, um, of what, what the situation was there rather than a, a real health risk as we weren't exposed to it in that way. DD (11:46): 3 �You mentioned that, um, kind of as part of the, as someone who was able to stay and to, to be selfemployed, and you were perhaps more available at certain times than others, um, that you were asked for help. GM (12:00): Mm-hmm <affirmative>. DD (12:01): What kinds of things were you helping the, the citizens group, the concerned citizens do? Like, what, what was your role? What kinds of things were you doing? GM (12:11): Okay, well, um, early on, every now and then we would do, oh, maybe a little, a little walkabout, you know, take a look, uh, while during the, uh, demolition process, sometimes it's like, uh, Grant, what do you, you work in construction. What do you think of what's going on there? So I'd walk around and say, well, you know, they're, they're, they're spraying down the debris. This is a modern style of, uh, um, airborne dust containment. Uh, that's good. But, uh, you know, that, that, that definitely is, everything's supposed to be wet. And, and, uh, containable versus just spraying water in the area. One guy in the hose spraying in the corner of a parking lot, and they're working over there. That's not the idea, but they were pretty good about keeping the water on there. But every now and then, since these hoses were, didn't have a guy holding it, you know, it was an automated, uh, kind of a mount, and it was aerating the air while they, you know, migrate the work a little over, it's like, okay, you kind of, kind of keep that up. GM (13:22): But once the, the demolition crews knew the criteria there, and they had air monitors, they, they were able to keep on top of that. Um, other activities just was kind of us all familiarizing ourselves with things in the city that we never noticed before. Um, taking floats down the river in a boat, um, I mean, you walk down the sidewalk and you know, the same houses, but when you look at it with a different thought in your head, why is this this way? Or why is that there? Um, it gets you thinking about the potential problems and opportunities, like even the, the tannery, they, they talked about the, if there was the possibility of groundwater contamination, what were the options? And one of the more vocal, uh, I can't call him a Rockford, uh, resident or citizen because he lived in the townships, and this was a ongoing problem. GM (14:29): We had business owners that identified as being Rockford residents. I hate the term. I like citizen, not because I'm, I don't think-- it's politically charged. It means you live in a city, a citizen. I was a citizen of Rockford because I lived in the city of Rockford that didn't include the owner of the, you know, liquor store, the drug, you know, the drug store, the, the gas station. Unless they lived there, you know, I, I don't go into their townships and tell 'em how to run their, their business there. But, uh, other than weighing in on things that affect their business, I'd say, thank you, but no, thank you. We live here. You don't, we pay the taxes. You don't, so, you know, you take care of yours. We take care of ours. Um, but one of these more vocal people, he had an issue with the Brownfield in a property owned decades previously, and his thought was the only source of containment was that they were gonna pave it all over with asphalt capping it. 4 �GM (15:37): Well, when he used that term, I thought, well, capping it, it was already capped because there was a building there. It kept the rainfall from getting into the ground that was boom below with all the, the concrete pads and, you know, just flowing it into the water, um, to a, to a degree. Um, so removing the building kind of removed that cap and breaking up the found, uh, the, the, uh, paving, interior paving, uh, concrete pads did the same. So it all became an issue there. But as we looked more and more into it, and Lynn would talk, um, primarily Lynn would do a lot of interviews with other people, we found a lot of the sludge had been taken to other areas, which became almost bigger problems than the actual downtown area, which was the source of the pollution. So that was some of it, walking about, uh, taking a look at things, um, keeping an eye out, and meetings, meetings. GM (16:38): When we finally decided to write, uh, the petition to the EPA, um, I always remember the old movie, or not movie, it was a movie, actually, <laugh> after the song, Alice's Restaurant by Arlo Guthrie, where he talks about getting, um, arrested for littering. And this sheriff had a, a photograph with a paragraph with circles and arrows and a paragraph on the back of each one. And he would say this over and over again, explaining what the issue was. And this is Lynn <laugh>, she, these, all these photographs with, you know, arrows and circles and a paragraph <laugh> actually below, below each one. You know, it was so detailed. But, you know, getting it into a communicatable understandable, uh, presentation was a, a bit of, a bit of a challenge. We knew photographs are great if people know what you're photographing. You gotta explain what it is. GM (17:38): You gotta explain why it's important, and that you're not putting in additional photographs just to fill the air and make it seem like, oh, the sky is falling. These are, you know, we're, we're documenting conditions that happened. So, uh, sitting down, and usually the writing would happen by, uh, by, uh, Lynn and Gail. But, uh, I would, I would sit down, we would review what we went, what they had gone through, uh, you know, make some, some comments there. And, uh, those two kind of claim <laugh> that I would, that I'd be referee between the two, because they spent a lot of time together without me <laugh>. And then I would end up there. And so, like, almost like sisters, they would get a little, a little too personal with each other. Not, not, not in a heated way, but it's a little frustration because it was, you know, it's a lot of work. It's a lot of work. Well, you're, you being a writer. Yeah. When you collaborate, it's, it's hard enough to write alone, but collaborate. DD (18:43): It can be a challenge! GM (18:45): Yeah, does have some help. Yeah. There's some of the things I was involved with, though. DD (18:50): When did, so tell me a little bit more about the petition. I know that you, so you were, you just said you were part of helping to write it, review it. Um, tell me about, like, so the petition gets accepted, right? Like, and then tell me about like how that was, what your reaction was to that, um, like kind of the fallout from the petition getting accepted. 5 �GM (19:23): Yeah. So that was a whole, you know, a whole process of course. But as I remember, we had, um, a good number of, uh, names. I mean, there were, to my recollection dozens that, um, subscribed to it. And these are people that were familiar with the issue, uh, both people living, uh, nearby and, uh, people in the general area, um, who were, you know, wanting this to be addressed. But, uh, there were, we, we realized it would be a publicly accessible document, and that, uh, there were perhaps some parts of it that certain people supporting it would not want to, uh, have their name divulged. So we knew there'd have to be some, uh, people name who, who had names on the, on the front of it. And Lynn was fine doing that. I was okay with that because, uh, being self-employed as a, as a, basically a, a remodeling contractor, my territory was larger than Rockford. GM (20:42): And, uh, as much business, uh, work as goes downtown Rockford, I, I got project here and there, but it wasn't, was not a majority of my business. So I had no concern about losing business there. And I thought it was an important issue. And, uh, Gail, of course, was, was, uh, noted there as well. Um, yeah. So, um, had that submitted and, uh, then there's that quiet period, you know, is it still in the mail, <laugh>, what's going on? Like, you know, acknowledge receiving, it's almost like, uh, oh, like a movie with you all, you know, stamp. Okay, now it's official, but it's here, <laugh>, it's not re you know, it's, it's received, but it's, here's your receipt for it's receipt. But it's, it's not. In the process yet. So there's the discovery and, and making it known. And, uh, I can't remember at one point, but it got into the, the local newspaper. GM (21:57): And, uh, it's, I'm not a big spectator sports fan. And the tangent on that is, I remember hearing that intercollegiate sports, I guess college boys would get out and have this big brawl. It was a common thing. And so they started, you know, intramurals and they did intercollegiate. It's basically to turn people's focus towards something different, something constructive. But now it's a whole industry. But I think the side benefit is that, is that the average American thinks us versus them. And so you gotta, you gotta have a team, you gotta pick a side. And there's so few people that will look at both sides and take a, take a moment and not choose a side, but just kind of, kind of percolate. And we had a lot of people charging in, oh, Wolverine, they, you know, they've created so many new jobs. I'm like, well, what does that have to do with them dumping chemicals in the water? GM (22:59): This is what we're talking about. It's just like, and I'm not even saying they meant to do it, but it happened. It's like, you know, whether it's a child, you're in charge of, your neighbor, your neighbor has a dog that jumps the fence and bite your kid. I mean, are they gonna say, well, you should have fixed the fence? It's like, no, it's your dog. It is like, it is an issue of responsibility. So people wanted to end run because that was their team. Uh, I remember one situation where former council people would say, "oh, we never had any problem with anybody getting sick. We even, you know, we drew drinking water from the river." And I was on city council at the time thinking, oh, so you're responsible also, not that we knew that people were actually getting sick at that point, but, uh. Yeah. It just, those things that are said in the heat of the moment, and you think back and say, wow, you really said that out loud. Out loud. DD (24:07): Yeah. 6 �GM (24:08): Makes you pause. DD (24:12): How did it feel then, when the EPA turned the site back over to the DEQ? GM (24:19): Oh ho ho, yeah. I guess we didn't know what happened. Before I lived in Rockford. I lived in Ypsilanti Township down the street from a, a Superfund site. I think it was an old Ford facility or supplier. And as a local, I'm like, all of a sudden there's a chain link fence and a do not enter. And, you know, no trespassing didn't know what was going on. Uh, but that was a big concern that people would say, oh, they're gonna cordon it off and it'll look like, uh, Chernobyl, you know, a big, you know, toxic waste area. It's like, you know, 21st century, you know, I don't think all that's gonna happen. So we, we figured it'd be a guarded approach. Um, really one of the frustrating, um, parts of it being turned over to the Michigan DEQ was that, uh, previous to, uh, petitioning the EPA, uh, uh, local, um, officials in the DEQ, um, some were approached about this, and, uh, basically they had ran to Wolverine and, you know, talked all about it and just made a big, big fluster about it, and then did absolutely nothing. GM (25:53): Um, it was, to my understanding, the efforts of, uh, mostly one, one person in charge there locally, where a lot of the rank and file people did want to get involved. Uh, there were a lot of good people, some of them becoming, you know, approaching retirement age. They'd been there a good while, but they had that experience. They knew it was a bad situation, but they weren't the one politically appointed to the local office, and so they kind of had to basically follow orders. Uh, so yeah, it being turned back to the DEQ was a, was a disappointment. And, um, you know, it's, it's one of those things, sometimes you speak outta turn, but I thought, you know, at this point, point, I'll just, there's nothing I can do. But my expectation is that it would run the full course of doing nothing until, um, the EPA would have to step in again DD (26:56): Mm-hmm <affirmative>. GM (26:58): And, uh, I'm not kept up to date since I moved some four years ago. So, um, I'd still get notices about the meetings, but, uh, um, you know, things move on and my family has other, other needs. So, uh, I'm a little ignorant about what's happened more recently. But, uh, DD (27:22): After the, um, after the EPA turned the site back over to the DEQ, I know there was another kind of quiet lull for a while where a lot of things weren't hap, there was little work happening. I know that certain members in the CCRR were still trying to kind of go underground, if you will, and, um, continue to try to figure out what was going on and what was there. Um, did you remain involved after, like, were you still involved at that point? GM (27:58): 7 �Well, to answer it somewhat indirectly, what I remember of what the was happening on the site is that, um, one far end of the site got paved over into some parking spaces and they started holding farmer markets and the, like, there, um, they opened up the field for families to run across during, you know, um, movie nights. They'd, um, have some fireworks. And, um, although new fresh soil was put there, I didn't have the best, I, you know, feeling that it was necessarily safe for, uh, young people to be there. Um, there are, there are monitoring wells, but, uh, and when they talk about the fact that Rockford has a historic dam that was one point hydroelectric generation, um, and what, what, what should one do with it? Um, what's never said is that they would never wanna do anything with it, because the, the, the backwater area has so much, you know, retained sludge and who knows what, uh, presumed to be not good stuff, that it would just all get released. And again, so much of my focus has been on what was happening downtown, where the, uh, house Street site is one of the primary areas that we rolled into in playing, uh, playing field, uh, township because it's part and parcel of the same problem. Sledge was relocated and then crept into the groundwater. GM (29:54): But, uh, yeah, it just seems, uh, it just seems, uh, that there's a marked degree of irresponsibility. I mean that when we, when we were posting the petition, uh, Wolverine was, um, they were posting this, you know, um, historic gains in, in, uh, profit. Uh, there was some sort of crisis, I can't remember what it was in Texas, and they were sending down, um, you know, large contributions, you know, it was in excess of a million. I thought, well, why don't they do something local? I thought, well, because that's not glamorous, and that's not, you know, you come out and say, we, we just spent this much money cleaning up our own mess. They know that's not gonna help. But, oh, you know, children, you know, children need shoes in some foreign land. Oh, we, well, yeah, we'll cut a check for that. It's like, while that would be nice, how about taking care of what you, you created yourself? It's just, I just, just reminds me the old, the old names. The, the, the, the Rockefeller, the Carnegie, these, you know, captains of industry back in the day that, you know, they bought tooth and nail and there was a lot of blood and guts spilled, but when it comes full circle, they make donations or open libraries, which is a wonderful thing. But how they got the money, I think is sometimes more important than if, if they didn't clean up their mess on the way out. I'm just thinking, just cl if, if sooner or later somebody's gonna acquire wolverine or they're gonna shut down, or who knows what, just clean up your mess before you do. That's what I do, you know, before I go to bed, the house is still a mess, but there's certain things I make nice and tidy. I usually hand wash my dishes. That's what I like to do. I like putting 'em away so I don't come and have to put 'em away in the morning. That's what we do as responsible adults, and there's no reason why a corporate entity can't do the same. DD (32:21): Fair, very fair GM (32:24): Preaching to the choir, I suppose. <laugh>. DD (32:27): That's okay. It's good to put it down on record. GM (32:29): Yeah. Yeah. 8 �DD (32:31): Um, do you think there are any parts of the story that, as far as you're aware, that have been underreported? GM (32:42): I'm sure there are, but you know, with I am sometimes, well, I, I'm plagued with a good memory in some ways and a bad memory in others <laugh>. And one of the things I gets me through life is, uh, trying not to hold grudges. So I, I forget the bad things that happen sometimes, uh, but that, that lets people off the hook a little bit more than they should at times, I suppose. Um, and when it, when it comes to winners and losers, I mean, there were, there were relationships and friendships that were strained. Um, I had an interesting situation because my, uh, my next, so I lived right next to what had been a series of houses until at some point, uh, they were paved over for parking lot, which in Rockford that was allowed, you know, it was residentially zoned, but, uh, you couldn't build a convenience store there, but you could pave it and use it as a commercial parking lot, which seemed contradictory to me. GM (34:02): So anyway, it was nice place to have kids grow up because there wasn't much happening over there usually. Uh, so I only had a neighbor on one side, and, uh, the neighbor was a retiree from Wolverine Worldwide and his wife, and they were, uh, wonderful people. A part of the, I mean, um, the husband grew up there. I don't know if he's actually born there. I think he might've been like in the town, but he, he grew up there and he, he lived in that home after he had, um, well, they moved there in the early fifties eventually bought the home, and he died locally. So he spent his whole life there and, uh, had a lot of respect for him. Um, but, uh, his wife was on city council, and, you know, when you are in a, I always think of communities, when you're a certain community, um, your ears turned, uh, sympathetically toward those, uh, closest to you. GM (35:09): And so we were obviously on different sides of the issue, but it never really strained our relationship because we chose to be good neighbors and not, not really discuss that topic because, um, when, you know, somebody has the opposite point of view, and, uh, there is no real way of convincing them to change their opinion, um, I'm typically of the, of the opinion that, that, um, my best testimonial is just to continue. And if they ever have a question about how I feel I'll do so somebody is undecided about something, I'm more than willing to discuss it. But, uh, I'm not big into, you know, trying to change the world to agree with me. It's just, just not my way. But, uh, a lot of people that, uh, work quite differently in, in that community and other communities, but, uh, that, that strained a lot of relationships. GM (36:14): And, uh, the city manager of the time, he was a very, very energetic fellow. Um, but I think he was much on the wrong side of this issue, and I think he was used by Wolverine Worldwide. Um, which I don't know, it just, I, I, I saw the irony of it because as I said before, my opinion is that Wolverine Worldwide decided to stay in Rockford because they decided to stay in Rockford. And no matter what the city manager did or did not do, he's, he was like a gnat to them. A city of 6,300 people was not gonna do a whit of good or ill to them because they had been there since, I think the 1920s was the founding of Krause and Hurst tannery, and it's, I mean, it was a long, long time ago, and as much as he thought he was doing them favors, I think they would take any favor they gave him, but they were not gonna scratch his back in return. 9 �DD (37:30): Mm-hmm. GM (37:31): So, I, I just think he didn't, he didn't value the, the citizens of Rockford over the corporations of Rockford. DD (37:40): When did you, um, first hear about PFAS? GM (37:47): Oh, probably after we, I mean, I, I suppose I might have heard of it, you know, like in the news here and there, but is where, bang your head on, on hexavalent, chromium, hexavalent, chromium, hexavalent, chromium. All of a sudden somebody's like, well, what about PFAS? So I think, I think it might've even been after the petition was issued, I think it might've been amidst or in the formation of the, uh, community advisory group, Wolverine Community Advisory Group. I was a member, founding member for a while there. And, uh, and I think that that's where the, the focus changed over time. Uh, of course, the challenge there was that both the EPA and the DNR, they didn't have, oh, what, what do you call it? Legislative directives as to what contamination was. So, uh, after being a, uh, uh, remodeling contractor, I became a home inspector. GM (39:07): And so I got more into science, like radon and concentrations of this and that. And so, uh, oh, even some water quality analysis. So I got into a better understanding of what, what, what is, um, contamination, you know, what, what's, uh, the maximum MCL maximum contamination level, which is used with, I can't remember what is the hexavalent chromium, I think that's in, in there someplace. Uh, but, but other things, lead, arsenic, all those, and then the, the lower limits of detection, the LLD, that's where your, um, detection method can't, it might be there, but it's so small that there, it's undetectable. Um, but yeah, I find that there isn't, was no MCL and they, they knew PFAS bad, but they didn't know how much PFAS bad, which we kind of find that any amount is bad if it's, as they like to call it forever chemical. GM (40:14): And that it not only is, uh, pervasive and sticks around, but evidently is, can also accumulate as opposed to be something easily, uh, uh, removed. So, um, I'm just trying to think. The year we submitted the petition, do you recall, I thought it was 2012, DD (40:48): 2011? GM (40:48): 2011, 2012. I thought it was, yeah. 2012 came to mind, but maybe it was 2011 and I moved in 2020, so that was a long time to see not a whole lot done for that. So somewhere in the midst there, we got looking at the PFAS, and strangely enough, uh, where I live now isn't too far from Parchment, which has the, uh, paper mill PFAS issue in the Kalamazoo River. I drive by that every now and that the Kalamazoo 10 �River, I'm like, oh, there's another affected river. Unfortunately, I think it's documented to be, the documentation is more acute down here. I'm not sure that the Rogue River is better. I think it is. It's, it's, it's, it's a smaller river and it's a tributary, and it moves a little faster. So I think we have all that. But, um, yeah. Yeah. Just that an irony there. DD (41:54): So maybe that's a good segue into another question. Um, do you have any concerns about PFAS contamination moving forward? GM (42:06): Yeah. Well, largely like, if I think of, uh, people of Plainfield Township, there's a big bolus of, I can't remember the term. They would use, um, plume plume of, uh, contaminated groundwater that continues to migrate. Now they've tried to stop the wells that would draw from that, but that doesn't mean that's the only, um, vector of contamination. It comes up to the ground source. We have sludge that was there. There's a, there's a subdivision that was built over an area that anecdotally was reported to have surface, um, application over farm fields. Uh, the farmhouse is still there, the fields are gone. They put in a bunch of homes. And there was some reports of kids in the nineties having a strange form of cancer, of the sinuses and such. And it was just an uptick. And it passes and, you know, it's, it's not like a smoking gun. It happened there. How did, how did they get contaminated? Well, could have been private wells, but it was on city water, but it had developed homes with soil kids playing on the ground. GM (43:49): Who knows? Who knows? Um, in my little lake here, uh, I mean, I, I grew up downstream from, um, a paper mill. And every now and then they would have, oh, a little bit too much rain, and the holding pits would overflow, and the White Pigeon River would run a lime green. It's almost this like what they'd do in Chicago for <laugh>, or is this for St. Patrick's Day? Except for this is unintentional. This is a milky lime green. And it was disgusting. Hey, you know, it's poison. They would just go right down the river, which is tributary to the St. Joseph River, and they would get some sort of fine, but I believe it was a business decision that the fine was probably more affordable than cleaning 'em out. I don't know why otherwise they would do this. These weren't, it wasn't a, it was an old plant, but it wasn't an antiquated plant. GM (44:53): So I think that's kind of the way business used to be done quite a bit. So when we get back to the issue of the, the PFAS, um, what came to mind is, I would walk along the river as a little kid, and I'd see this foamy water, I think, oh, it just happens. It just happens. But, uh, Lynn was one who's just saying, what is this foam? I'm like, it just happens at rivers, Lynn. everybody said, it just happens. Well, it doesn't. More often than not, it's some sort of a, PFASis a what do they call it? Anti, it's a surficant. Anti. Surficant. Anyway, DD (45:33): Surfactant? GM (45:34): Surfactant, yeah. So it floats and it's a thing that keeps things from adhering to each other. So it's, it's, it's on the surface. Um, I have a neighbor at my lake here says, do you think anybody would mind if I check the water? 11 �GM (45:50): Because every now and then the wind blows and we get little foam <laugh> of water. I'm like, now don't tell me we got PFOS here. But we might, we don't know. I mean, I'm not near an airport. I understand. I think it was Grayling, the National Guard Airport, that they would use the foam that the firefighters use, and that, that there was a big contamination issue there. It just seems that, I don't know, there's, there's, there's too many things that just don't add up. I mean, we know we have, oh, for lack of a better term, plastic food. I mean, food that just isn't always food. It's just byproducts put in there, or products put in that we ingest. Um, so there's other issues. GM (46:41): But when I look at my generation and my children's generation, seems like we have a lot more problems with, uh, infertility than I remember hearing from prior generations. Um, a lot of people struggling to have children to have, uh, early, early life cancers. And, uh, it could it be the food? Could it be the water? Well, anything we can do to reduce our exposure to, um, carcinogens is, is, is not a bad way to go. And that's my biggest concern about this PFAS, that it's, it's, it's still, it's still out there. Seems like we're still adding to it. And being an old geology student, I know the earth heals itself, but I also <laugh>, like Carl Sagan would say, billions and billions of years <laugh> for the solar system. But like with, with the Earth, it can take a million years to heal something. It will heal, but it might take another species to <laugh> enjoy the benefits and we don't want that. DD (48:02): Well, you're just a jack of all trades, a geology student, construction, remodeling, and home inspection. GM (48:10): I think they, I think they now call that ADHD <laugh>. It wasn't a thing when I was a kid. I was just, I was just, well read <laugh>. DD (48:24): Is there anything before we wrap up that you'd like to add or, um, that we haven't touched on today? Or anything that you wanna go back to say more about? GM (48:38): Well, shame of it all is, uh, you know, I was a little delayed in getting back with you and, uh, by, by months, really as it's just been these weeks. But, uh, and being a little separated from the issue and distracted by other other concerns, it, it does get, it does get a little foggy over time as to And every now, and you have the, oh, yeah. That mo mo type of moment where you're like, okay, yeah, that was a, that was a, a big day or a big event. Um, but, uh, nothing really comes to mind. I, you know, as I age and mature, I, I think I oftentimes try to look at the theme, uh, versus the details. I'm very detail oriented, but I think to understand how details fit into a situation, you have to look at the overarching theme. GM (49:42): It's like, okay, what, why does the puppet move? Well, there's a puppeteer. Why does a puppeteer make that choice? Well, and it goes further and further and further back to, uh, a theme of where are we going with the whole thing. But, uh, yeah, I, I, I think we have a societal problem of not asking why we should, you know, continue to add untested, unproven products of all sorts of all sorts. That, uh, um, 12 �sometimes will have well established, um, methods of introducing, um, new products that we will just push the wayside because all of a sudden we think, oh, this is a crisis. We need to find a solution. Well, solution can be worse than the problem. GM (50:45): And, uh, I think it's important that we don't stop progress, but we start to find better methods to, uh, evaluate what things are progress. Uh, the continued proliferation of pharmaceutical drugs. We have plenty of pharmaceutical drugs that do just the same thing that the new ones will, but they're coming. The old ones are out of patents. So, you know, it's not always the case, but they try to find a, a new wheel, uh, you know, a better, you know, the wheel's been invented, get a better tire, that's fine, but gotta stop. Yeah. I don't know how we do it, but, uh, yeah. You know, fixing the past, I mean, that's an industry in itself. But, uh, trying to do, undo some of the, some of the harm we've done. I think that, you know, puts us in better stead for generations to come and say, well, they, they might have been a little warped, but they, they, they did their best to try to clean things up a bit. DD (51:59): Yeah. Well, Grant, thank you for taking the time to talk with me today. GM (52:05): Oh, gladly, gladly. 13 � 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 PFAS0044 Creator An entity primarily responsible for making the resource Medich, Grant Date A point or period of time associated with an event in the lifecycle of the resource 2025-12-11 Title A name given to the resource Grant Medich, 2025 (Interview video and transcript) Description An account of the resource Grant Medich recounts how community concerns over a Rockford, Michigan tannery demolition evolved from chromium contamination to the discovery of widespread PFAS risks. As a nearby resident, he helped monitor the site and supported a citizen petition to the EPA, raising questions about corporate responsibility, regulatory inaction, and the long-term health impacts of “forever chemicals." 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/ff2301ab38fe167a02578bf71fa7e4b6.jpg 6c4c365e691226b82e55d19b364c77b8 https://digitalcollections.library.gvsu.edu/files/original/f21331223023940f06de0886096650ab.pdf d48349224aeba5586ffea907fbba05f8 PDF Text Text Living with PFAS Interviewee: Renae Mata Interviewer: Danielle DeVasto Date: December 11, 2025 Dani DeVasto (DD) (00:00:03): I am Dani DeVasto, and today December 11th, 2025, I have the pleasure of chatting with Renae Mata and Lynn McIntosh. Hi Renae. Renae Mata (RM) (00:00:13): Hello. DD (00:00:14): Um, Renae, could you tell me about where you're from and you currently live? RM (00:00:20): I was born in Grand Rapids in 1973, so I'm 52, which will, the age thing kind of comes back around later in this interview. Um, till I was about 18, I lived, um, pretty close to downtown Grand Rapids, uh, Boston Square area. Then, um, moved with my parents to Standale. Spent a little time with my sister in Moline, Michigan, and a couple seasons in Idaho. And now I live in Plainfield Township. DD (00:00:52): And how long have you lived in Plainfield Township? RM (00:00:56): Um, well, let me say, let me go back a little bit. Okay. I got married in 2001. We bought a house in Alpine Township near the Plainfield Township border. Um, so from 2001 to 2019, we lived on Bertha Street in Comstock Park. And then in 2019 we moved to a larger house on the other side of Division, um, in Plainfield Township, still Comstock Park. DD (00:01:30): Okay. Can you tell me a story about your experience with PFAS or with PFAS in your community? RM (00:01:40): Oh, yes. All right. Here we go. Um, so I always used to love reading the Grand Rapids Press. I miss the paper and, you know, the permanency of it and, um, you know, kind of extraneously kept an eye, you know, tabs on what was going on locally. Um, but I was busy raising a family. I figured out that my boys were 10 and 13 in the year 2017, which was the big PFAS year. Um, so I had a lot of distractions going on. And, um, so let's just start at 2017, I guess 'cause that's when I got kind of pulled in. Um, I was working as a home healthcare aide and, um, met Lynn McIntosh through her mother. And, um, took care of Maya from 2013 to 2019. RM (00:02:46): 1 �And very part-time 'cause I was, um, raising my kids. But, um, so I knew Lynn for a few years before, um, she asked me a curious question and was that like summer probably? Summer of 2017. So I was there taking care of her mom and kind of randomly, I'm not quite sure how it came out, but it was just random, I guess to me. <laugh>, she said, so Renae, do you, do you live in Plainfield Township or something like that? And I was like, no, Comstock Park. Um, I prob, you know, I said Alpine Township, you know, she's like, oh, okay. And I don't recall if it was the same, that same conversation or a little later. Lynn McIntosh (LM) (00:03:32): I believe it was a little later that you brought up to me that, but you had Plainfield Township water RM (00:03:40): Yes. So Alpine Township does not have their own water source. Um, so we've drank Plainfield Township water since we moved in in 2001. LM (00:03:51): Knowing you, you probably looked up something because I had asked about RM (00:03:55): Well, I think that's where the Press came in. Garret Ellison's article, but that wasn't till fall. I'm not quite sure. LM (00:04:06): Well, his first article came out at the end of August. RM (00:04:09): Oh, August. Yeah, I guess it was around that time. Um, and I ended up calling you, which we didn't talk as friends at that point. We were just more, it was a business kind of relationship. I mean, we were friendly and friends as much as you can be in and out like that. So I called her and I don't remember exactly how the conversation went, but I, I said, you know, I, I am interested in what's going on with, you know, Plainfield Township, water, whatever. And, um, yeah. LM (00:04:38): 'cause you told me, by the way, I do live in Alpine Township, but I drink Plainfield Township water. RM (00:04:45): Yes. LM (00:04:45): And then I finally opened up to you RM (00:04:48): And you told me the whole spiel. 2 �LM (00:04:50): Yes, About my other life. RM (00:04:52): Yeah. DD (00:04:52): Because at that point, did you know what Lynn had been involved with? LM (00:04:56): Not at all. Nothing, not a word RM (00:04:57): She kept it to herself, LM (00:04:58): And I kept it from my mother, even at the till the very end RM (00:05:02): And I, I would've always been with your mom when I saw you too. LM (00:05:05): Yeah. Nope. Never shared it with anybody. I, I had <laugh>. Yeah. I, I didn't, I especially didn't want my mom to worry about anything. DD (00:05:14): So that must have been a revelation. LM (00:05:16): <laugh>, It was huge. It was like my double, it was like a double... RM (00:05:18): Yeah. It, it explained a lot of things though. 'cause I was, you know, like she seems all rather distracted all the time. You know, piano lessons must be very taxing. <laugh> RM (00:05:28): No. But, um but, uh, yeah. So, um, yeah, LM (00:05:33): I was living a double life here, <laugh> triple life RM (00:05:35): 3 �And that's, that's why I did bring along my little kind of resume because then all these different ties, like this web of like, I wasn't, you weren't just Maya's daughter and I wasn't just your mom's caretaker. No. I was like, by the way, I have, I have this other life that I used to lead. LM (00:05:52): Yes, that's right. Yeah. Your, your other life. RM (00:05:55): My other life. 'cause um, so I went, I graduated from Grand Valley, um, in 97 LM (00:06:04): Where Rick was a teacher. RM (00:06:06): Yes. Um, biology major and a Natural Resources Management minor. Um, and I worked as a student assistant at Water Resources Institute where Rick, I wasn't really under Rick, he was doing more of the chemically stuff and I was doing more field work, but I knew who he was and he didn't remember me. But, you know, there's students galore, you know. And, um, so I'm like, Hey, I have this past life in, um, this is why I'm extra interested in it. So, um, with water resources. And then, so that was around mid nineties. And then in '95 to '98, I worked for Michigan Department of Environmental Quality Environmental Response Division as a student assistant. And I was actually working, I wrote here 35 hours a week. I didn't realize that I worked that often that much because I was taking a full, pretty full course load too. Um, but that is where I met, I'm gonna just call him Dave O'Donnell 'cause I know he wouldn't like that. He likes David. <Laugh> And, um, Abby Hendershot. And, um, I, I didn't work in the same office as Janice 'cause ERD's building was actually in Wyoming because they didn't, they had run out of room downtown. So we were in a totally different building. Um, but I had heard of Janice. I had maybe had seen her or whatever, but, um, um, and then also a woman named Heather Hopkins who was in charge of the Whitehall Tannery. LM (00:07:39): That's right. Yeah. She worked with Rick over there. RM (00:07:43): She worked with Rick? LM (00:07:44): Yeah RM (00:07:45): Oh, interesting. LM (00:07:45): I tried to get her, I was hoping she would be the one who would be the contact with this tannery. RM (00:07:50): 4 �With a tannery background. Yeah. Okay. So, um, in that job I helped, you know, take samples from monitoring wells. Um, I did some GIS type geographic information system mapping 'cause at that time they were, they were trying to get the city of Grand Rapids to put some a, um, I dunno what the word is, like a restriction or a, that you can't use Grand Rapids water. Like, people might still have private wells. They didn't want people using those for anything, I guess. So I helped map all the different contamination hotspots in the City of Grand Rapids. RM (00:08:33): Um, and I got very proficient at spreadsheets, <laugh>. So, uh, I did a lot of spreadsheeting there, which I love by the way. Like, if life were a spreadsheet, you know, if I could, you know, without the grays of black and white, it goes, okay, it goes in that cell and that cell only, you know, I would be a happy camper. Anyways, so that's, that tells you a little bit about my analytical, kind of data oriented side, so. Okay. So, um, I graduated in 97 and wrapped up my time as a student assistant with the DEQ. Um, went off and had a couple adventures, which you're supposed to do in your twenties, right? I worked seasonally for the Forest Service, the first season as a forestry technician. So, um, I was hiking around measuring old growth pine trees, like, you know, literally like that big, you know, very large, um, that year. RM (00:09:34): And then the second season I got a bump up to, what I really wanted to do is a biological technician. So they paid me to, um, monitor a bald eagle's nest and, um, do birds like track down, um, some certain raptors. And, um, yeah, Idaho's a beautiful state. I loved it. But I, um, let's see, that was till '99. And then I met a guy <laugh>. So, and I never planned to not be away from Michigan. I mean, Michigan's beautiful. I'm, I'm not a big fan of winter, but all my family's here, so I, that was, you know, my adventure. And, um, so I came back and met a guy and, um, got a job with King and McGregor Environmental, which mainly, um, they do permitting working with the DEQ. So back, you know, kind of come around there working on the, the other, the other end. But working with DEQ to get the permits that our clients wanted for housing developments and such. RM (00:10:43): Um, so I worked there for almost seven years until 2007 where I got laid off 'cause that was the recession. And a lot of our majority of our clients were developers and stuff, stopped developing <laugh>, like, um, that's also right before I had my first, no second son, sorry. Um, so yeah, I met, you know, prince Charming, married him in right after, right after 9-11, 2001, had my first son went parttime at King and McGregor. Yeah. And then, um, three years later I had my second son. I have two sons that are now 18 and 22. RM (00:11:32): Um, so that's when I had the career change, which that kind of leads into how I met Lynn. I wanted, you know, my kids were young enough that I still, I knew I didn't want a nine to five job because, um, my husband was working second shift at the time, or No, he was, he was second shift then. He was a, then he went to first shift. Um, so we were, I wanted something opposite him. And, um, so we wouldn't have to worry about too much daycare other, you know, other than my mom a little bit here and there to cover. So, and the state of Michigan actually paid for my nurse aid training because I was, um, a displaced worker as, um, laid off 'cause of the recession. So, um, and actually when I went, when I, when I went to Grand Valley initially, I had got accepted into their nursing program. I thought I'd become a 5 �nurse, decided I didn't wanna wipe people's butts. But then I found out the nurse aids are the ones that do that. DD (00:12:30): <laugh> <laugh>. RM (00:12:31): But, um, <laugh>. LM (00:12:33): That's a brilliant, RM (00:12:35): Yeah. Anyways. Um, but there's a place, there's a, there's a need for that. So I, um, anyways, the flexibility is what I was looking for and, um, and helping, you know, 'cause I'm a caretaker type helper personality too. So I got a job working very part-time at a retirement community. And then when I had worked there quite a few years and the burnout's real and my back was, you know, feeling it, I wanted something a little more laid back, which was more one-on-one, you know? LM (00:13:10): More companionship care. RM (00:13:12): Yeah. And, um, so then I, in 2013, got hired on by the, the personal care company that Lynn had found. DD (00:13:23): Leaves Personal Care. RM (00:13:24): Yep. And, um, got matched up with, with Maya because she was on the north end of town, same as me. And, um, looking for evening hours, which was my availability. I was homeschooling my boys at the time, um, during the day. So that brings us back to, um, 2017. So 2013 I started working with Maya. Four years into that I got introduced to, um, Lynn's "Gal Noir" <laugh>, LM (00:13:59): My spy life. RM (00:14:00): Yes. Her "put the hush and hush puppy" she was, you know, and, um, she kind of pulled me in as kind of a little her Dr. Watson to her Sherlock, right? LM (00:14:10): Probably so <laugh> 6 �RM (00:14:11): Yes. And um, okay. So... DD (00:14:19): What did you, what were you like thinking or feeling as you were putting together these pieces of "I drink Plainfield Township water, I'm seeing these things in the newspaper, I'm talking with Lynn," like this is kind of what were your, like, do you remember your thoughts, your reactions? RM (00:14:37): Um, well, I've always been a bit of a tree hugger too. I mean, I got a natural resources management minor and worked in that field for quite a while. So, um, definitely concerned. But I have a friend who works at Prein and Newhof lab and the fact that Plainfield Township was always bragging about how they won these best tasting water awards. LM (00:15:07): Oh yes... RM (00:15:08): So going by the taste and even the labs really at that time, because they didn't test for PFAS LM (00:15:18): They didn't start testing that till 2013. RM (00:15:21): Yeah, because of...? LM (00:15:24): It was like an emergent emerging contaminant concern. RM (00:15:28): Yeah. Okay. So not directly, but you were bringing your samples to Prein and Newhof at some point? LM (00:15:33): I was. RM (00:15:34): around that same time. LM (00:15:35): Yeah. Right around that same time I was, yeah. It's interesting though. What, what be interesting to add on this was that my city manager talked to the director at Prein and Newhof and told them, you may not interpret her results because we, uh, it was the city's water. I was still, they could do the sampling for me, but they would not, they could not give me any interpretation. 7 �RM (00:16:02): Oh, so you would get the results Just no... LM (00:16:04): No interpretation. Which, which like, I, I did not want. Why would a city manager, what what right does... So I decided to, I went to Muskegon, then RM (00:16:13): Just changed labs LM (00:16:14): All the way I drive over there, like get into different county <laugh>. RM (00:16:19): yeah, it's too bad about that. Yeah. LM (00:16:22): Trace Analytical. DD (00:16:24): You were saying that you had a connection with Prein and Newhof and I was kind of asking generally like your reaction to finding out. RM (00:16:31): Yes. Back to that. Um, so I did buy an under sink water filter after that. But a lot of it is, um, you know, hindsight, I'm like, oh, you know, we've been drinking this since 2001. My first son was born in 2003. So, um, I guess the fears came out because, um, I drank it while they were in utero. They had it in their bottles. I didn't have the best milk production, so not a ton in my breast milk, which there might be a tie with. LM (00:17:09): I remember you mentioning that. Yeah. They're finding ties with that. RM (00:17:13): Yeah. And then, um, you know, they drank water in their sippy cups, you know, and not like, I didn't wanna give him juice and thought that was the healthy thing, you know? And so, and, um, but I obviously we're not able to get a whole house filter. And then supposedly the levels were lower than say, a private Well, but, um, LM (00:17:41): Isn't that also when Demand Action started to come into gear too? RM (00:17:44): 8 �Yes. Okay. So I'm pulling out one of my spreadsheets and, um, not that I got involved with Demand Action specifically, like, um, but, um, kept tabs on what was going on. So. DD (00:17:59): Just for the record, can you explain what demand action is? RM (00:18:04): Yes, it is my understanding that the main guy, Travis Brown LM (00:18:10): Yeah. And then, and there was another guy, Angel somebody. Angel RM (00:18:15): Yeah. LM (00:18:16): Last name is Angel. RM (00:18:17): Anyways, I, I don't know. That would be another good one to actually interview. He's very vocal on Facebook. I'll, you heard... DD (00:18:24): I think I've seen his name. RM (00:18:25): Yeah. Yeah. LM (00:18:28): Corey Angel. RM (00:18:30): Corey, yeah. Mm-hmm <affirmative>. I, yeah. 'cause he actually ran for, um, a township position once too. Yeah, LM (00:18:36): I think he did. Yeah. They, um, they, they, they formed probably because Corey and Travis, you know, both shared concerns and Travis knew a lot about Plainfield Township's miserable reputation. I mean, he knew about, he had some degree in water chemistry and knowledge and a lot RM (00:18:58): A lot of health issues too. LM (00:18:59): 9 �He had a lot of health issues and he was very upset about state disposal site where they used RM (00:19:05): On a, on the East BeltLine. That super fund. Yeah. LM (00:19:07): They used air strippers 'cause there were leaks going there. And, uh, he kept track of their miserable records of like, Plainfield Township was advised not to put in the North Kent Landfill there. And they, Prein and Newhof, advised them to do it. RM (00:19:25): And his research goes all the way back to like the sixties. LM (00:19:27): Yeah, a lot of good input that they, a lot of good input that was objective. They ignored. And actually they followed a lot of the advice from Prein and Newhof and Waste Management division. So he was very upset. He knew so much. And, and Corey Angel was a lot more measured, but also very smart. And they got this Demand Action. They had 2000 followers on their Facebook, and they are the ones who, RM (00:19:57): They really got the word out. LM (00:19:59): They're ones that got the word out. They were at the point where they were even calling on the, some of the commissioners to resign. They put the pressure on. And, and had they not, I don't think the word would've spread out nearly as much RM (00:20:12): <affirmative>. And that's how I knew about it. LM (00:20:14): That's how a lot of people knew about it. RM (00:20:15): Yeah. The pressure there. LM (00:20:17): Yeah. But DD (00:20:18): You weren't really involved with...? RM (00:20:19): No. 10 �LM (00:20:20): But it educated you. RM (00:20:21): It educated me. Yeah. Definitely. 'cause um, I had gathered Plainfield Township Municipal Water, um, news articles starting in, um, 2016, most of them are 2017, 2018. And, um, Grand Rapids Press, Fox 17, WZZM Wood TV, Grand Rapids Institute for Information Democracy. Um, Michigan Radio. And, um, so yeah, that got my ball rolling. As far as, um, like learning more, I'm very, I much consider myself selftaught in a lot of ways. It's like I'm a researcher type of personality. I just kind of jump in with two feet. That's, DD (00:21:11): And this, you're, you're referencing your spreadsheet right now? RM (00:21:14): Yes. DD (00:21:14): One of the spreadsheets, that was something that you decided to do on your own, just to start tracking? RM (00:21:18): I don't...I love spreadsheets. I don't remember you ever asking anything like that. I just started, and actually, um, when I worked for the, uh, for King and McGregor, um, I kind of, um, started a spreadsheet that was not related to PFAS, but, um, I just decided, decided to create an organizational spreadsheet because, you know, there was, um, too much stuff scattered around. So I, that's my, my nature to just like, to compile, you know, and, and then to be able to educate people more easily that way too, instead of going, you know, this, you know. So LM (00:21:52): Would you say that Demand Action was like, accelerated your education in certain ways to Plainfield? Or not necessarily? RM (00:22:03): Yeah. I don't think, like, I'm just counting how many, um, of these news articles have Demand Action ties so, um, let's see, October, 2017, trustees in Plainfield Township hear concerns about water contamination. I'm sure that was Demand Action. Um, so October, November, December, January 7th, 2018, residents, Plainfield residents say township board is practicing intimidation. Um, "you owe us more." Residents tell Plainfield Township. So, yeah, I'll, like, if they hadn't put the heat on, The pressure, they, it would still, they, you know, until they get the heat, they're not, you know, they're not gonna, LM (00:22:50): They wouldn't have that filtration system if the citizens hadn't put the pressure on. RM (00:22:53): 11 �Yeah. Right. LM (00:22:56): But then just, just to bring up, it was interesting that as part of CCRR, you also talked to Plainfield Township in 2017. We talked about that earlier with AJ. RM (00:23:09): Oh, yes. That, um, the small little boardroom meeting. Yes. I'm picturing a bigger one. Yes. Yeah. DD (00:23:17): So you, I'm just thinking about this in time. So you're, you've had your conversation with Lynn. You've learned about PFAS work and concerns about Plainfield Township water. You're starting to educate yourself and track these newstories. Yeah. Then what? RM (00:23:36): Let me look at my notes here. LM (00:23:39): How afraid were you at that point? RM (00:23:42): Um, I don't think, I, I don't think fear would be a good word. Um, I do remember you, there was something about a FOIA in City of Rockford once you, you had asked me to get involved with like, and I was like, you know, I'm okay to do this, but Lynn, the cat's pretty much out of the bag. You know what I mean? I don't think we need to be secret. You know, you were so used to being secretive about everything. And just like, I think another one of the interviews that you did, somebody said the genie was outta the bottle, you know, and cat outta the bag. And, um, I ended up, well, can maybe somebody else do that? You know, <laugh>? So, um, yeah. At that point, once the cat's outta the bag, then the, the fear thing isn't an issue. It's more like, all right, what do we do next? Let's fight it. I guess LM (00:24:32): I meant for your children, RM (00:24:33): Fear for my children. Um, I think when we went to the pediatrician, I, I educated, I, I'm very much a realist, so I don't, you know, there's a fearmongering. I don't get into too much, but I am also a realist. And I know stuff happens. I work in cancer data. I wear my fight to end cancer t-shirt to, um, fight to end blank fill in. You know what I mean? But yeah, when we went to the pediatrician, I was like, by the way, they've been drinking PFAS, um, all their life, including when they were a few cells old, you know? And, um, my husband happens to have cholesterol issues, which probably exacerbated, um, potentially by the PFAS we drank. But, um, also some genetic factors there, as you know. But as far as my boys inheriting some of that familial stuff, but, um, so yeah, testicular cancer is a cancer generally of younger men and teenager teenage boys. So, um, I was definitely making my, their pediatrician aware that. You know, want you to be extra vigilant and, um, yeah. Uh, I guess that's all I can think at the moment for the boys. Yeah. Okay. Let me look at my notes here. Highlight some of the things I've already talked 12 �about. So I, um, um, and if we have time, I'll get into the Parkinson's thing. But I mainly wanted to focus on Plainfield Township Water. RM (00:26:37): And City of Rockford Water. Have you interviewed anybody that drinks City of Rockford Water before? What is it, 2000, 2001, where they switched from the Rogue River? Do you interview? DD (00:26:49): No, I have not. RM (00:26:50): Oh. I'm also advocating for them too. It's just like Lynn advocated for Plainfield Township. Um, I got the okay from my friend Megan Force and her mom, Dawn Force. They grew up in the city of Rockford. She's a little younger than me, probably, um, maybe four years younger, I would say. And she happens to be my hairdresser. That's how I know her. Me and me and the boys. Um, yeah, let's just jump into the city of Rockford thing. Since I talked about Plainfield. We can come back around to Plainfield, but, um, sounds good. Um, yeah. And Megan okayed my use of her name. 'cause you never know how private people wanna be or, um, you know, litigation or whatever out there. RM (00:27:36): So, um, Megan in 2016, in her, that was probably her early forties or late thirties, um, she was diagnosed with a rather nasty thyroid cancer, which I believe Sandy Wynn Stelt also had thyroid cancer. And now, just in the last, um, six months, Megan's mother, Dawn has also been diagnosed with thyroid cancer, which I see, you know, when PFAS has talked about, where they talk about thyroid disease, but I don't know that I've seen thyroid cancer. Yeah? Okay. It is a definite, yeah. Um, so in 2000, not 2001, 2000, the city of Grand Rapids, city of, sorry, Rockford switched from drawing their drinking water out of the Rogue River, which was just downstream of the tannery, 300 yards down, the, in the inlet to suck the water to their treatment plant. LM (00:28:48): Never treated. RM (00:28:50): well, they treated it to some degree. They didn't just. LM (00:28:53): Yes. They never treated for PFAS. RM (00:28:55): Right. Because it wasn't really, it wasn't a thing, even though Scotchgard was invented. I looked this up in 1956, and they had been using it since probably this. LM (00:29:05): 58. 13 �RM (00:29:06): 58. Okay. LM (00:29:07): Yep. That's when they started, RM (00:29:09): that's when the, the hush puppies basically, or whatever they were making at that time, LM (00:29:13): Yep, the year I was born. RM (00:29:14): Oh, that was your birth year, <laugh> '58, huh? So, um, Megan being born in the late seventies, it must be, she drank it, it for her growing up years. And she lived downtown uh, near downtown Rockford. Um, and then she, she told me, you know, as she's my hairdresser, so you talk, you know, you talk about stuff like that. And she knew my background. Um, she said, the surgeon said it was one of the nastiest looking growths, obviously not just some slow growing, you know, like something caused that nastiness to yeah. Just, you know, and especially I think, I don't know exactly how old she was, but, um, like I said, late thirties, early forties, I have to do the math. But, um, uh, definitely a tie there, I'm sure. And, um, so as, as far as I know, Lynn has advocated for Plainfield Township, and she's attempted to advocate for City of Rockford people. But because it was so long ago, is that the bigger issue, or ? LM (00:30:41): Well, Dani and I, I just wrote a note, I wanna get this to her, but the city of Rockford did not express any curiosity or, or concern about, they never pushed to learn more. They just, and there's another whole little story there with both city managers. RM (00:30:59): Ignorance is a bliss sort of thing? LM (00:31:02): Yeah. They, they did not come alongside and express concern. Like, well, that was in the past. But what's been heartbreaking for me is knowing people in my neighborhoods who have suffered some of these. And I see it more RM (00:31:17): Cancers mainly. Are you...? LM (00:31:18): Yeah. And I, I tried, I don't know if you went with me, we went to a few events together, but you remember you went to that one with that person. I'm talking about the, the one who had colon cancer. We met at the library. We were wearing the same blue shirts, and we went there and she was trying to garner interest in, in educating people about it. And she kind of was involved for about a year. And she 14 �wrote a letter to the editor, challenging Rockford's attitude about, ignorance, laissez fair, and all that. And I, I have to get that contact information, but I remember attending that with you. And I remember there was a, a representative there too, Deb Avens who was running to be a Kent County commissioner, because she had to have her thyroid removed. 'cause she lived in Plainfield Township. RM (00:32:17): So, and remind me, was it Courtney Carrigan or was it another different Courtney that also...Because I haven't listened to her, um, interview yet, but I'll have to LM (00:32:26): No, I'd like to get you to another person. RM (00:32:28): She, she grew up in rockford? LM (00:32:31): No, it was, it was the one you and I that I, whose name was like Briana Mezuk. She's the one who grew up in Rockford and believes that she got cancer in her thirties because of drinking the water. Yeah. So she was, she minced no words at the first public meeting. In fact, there's an article about that first public, second public meeting at the high school. I think she was quoted in that. And then her letter to the editor, which weigh in on someone who has a background in, you know, um, at, um, what's the word for studying...Epidemiology? Yes. Someone who grew up in Rockford attended, drove over from across the state to attend this public meeting, made public comment, followed up with a letter to, to the editor, then followed up with trying to organize that one event. Do you remember the, the audio-visual wasn't working and it was a while back. RM (00:33:28): At the library? LM (00:33:29): Yeah, at the, at the, uh, middle school we went. RM (00:33:32): Middle school. LM (00:33:33): And you went with me. RM (00:33:35): Wasn't it on your birthday or something? On your birthday? LM (00:33:38): 15 �No, on my birthday was when Michigan, we made public comment about the MCLs. This was earlier than that. It was probably 2018. And she was trying to generate interest locally about this issue, about Rockford's drinking water, trying to get some traction. RM (00:33:53): Have you, have you heard any...that she kind of... LM (00:33:56): I need to get back to her. I, yeah. And it's on my list right now. Yeah. For Dani, because I think it's important to acknowledge that Rockford really the laissez fair attitude. It's like, let's just move on. Yeah. DD (00:34:16): So you are, you know, it's 2017 you found out about the water. You've started doing some of this research on your own at home and educating yourself. Um, what else were you up to? What happened with and after that? RM (00:34:32): Well, I'm, I'm glad Lynn was here to remind me about various, um, meetings I went to with her and, um, and one at Plainfield Township without her. Um, that was a pretty important meeting 'cause AJ, the lawyer and Rick Rediske, um, I lent them the credibility of being the Plainfield Township resident of like, alright, it's not just outside people creating trouble. Um, and I remember I had printed up an article, I had found, um, because the township was still saying, oh, we're still looking for a new well field still. We're looking for a new well field. And I'm like, it seemed pretty obvious to me that they weren't gonna find it. You know what I mean? So I was more on kind of on the filtration, um, aspect in this paper. I brought, I, I was gonna try to find it, but didn't have time. RM (00:35:27): Um, it just, it talked about how many thousands and thousands of not just the PFAS family, but of chemicals that, you know, you don't necessarily test for. You don't even know the, how, you know the specifics about them. 'cause, um, and the article was something about 10,000, um, chemicals that aren't even tested for. You know what I mean? So it's like I was, I, I handed that to them and I said, you know, even if you get this PFAS thing under control, what, what's the next thing that you're gonna find that you haven't, these filters aren't pulling out or whatever. So to be more vigilant on, um, being up on what the newest nasty out there that's either a new chemical or one that they're just realizing is, you know, like asbestos, they thought it was this great insulator and working in cancer data, they found out, you know, it gives you mesothelioma, lung cancer. RM (00:36:29): Um, so that, I thought that was a pretty important, um, meeting. And they did end up getting the grant and spent some of our tax money, you know, 'cause I've seen my water bill going up over these past few years too, because the grant doesn't cover everything. And, um, yeah, it's the citizens that end up picking up the, uh, the bill for this sort of stuff. So, DD (00:37:01): and the grant is for looking for a new well or...? 16 �RM (00:37:04): The grant was for the fancy filters that they put on. Yeah. And then, then they had a lot of visitors from other, um, cities, states, and even out of country to look at this filtration system because, um, realizing that, you know, they say how ubiquitous is the word that PFAS, et cetera are, there's really not clean water left is my, you know, like if it ubiquitous is a pretty big word. RM (00:37:36): You know, and if the polar bears in the Arctic circle or whatever have PFAS, then um, we just have to filter it. And like at a different township meeting, I did a that's right. I did get up there and um, I made a public comment about my children having drank this water since in utero in the water, in their bottles and et cetera. Like I said earlier, as you know, my impact statement basically. And, um, and uh, like switching to Grand Rapids water isn't a solution either. 'cause then the township supervisor said, well, they Grand Rapids. It kind of opened my eyes. I hadn't really heard much about microplastics. So that's the newest thing I educated myself on. 'cause he's like, well, Grand Rapids has their own issues like microplastics. And I'm like, microplastics? You know, and 'cause that's really come about in the last how many years? RM (00:38:29): Few few years. Pretty recent. Pretty recent. And how they, they think the average person has a credit card's worth of plastic in their brain. Have you heard that stat? DD (00:38:39): That's awful. RM (00:38:40): Yeah. So I don't like to hyperfocus on just one bad guy. You know, I, the big, I'm kind of a big picture person. Um, you know, like Lynn's mentioned before, you know, they originally were looking at chromium or, you know, these other tannery associated chemicals, which can be just as bad, you know, maybe not last in the body as long, but they can, you know, it's, um, it's not just PFAS. It's basically, you know, we're talking about PFAS here because it's, um, different than a lot of these, you know, with a, such a long term effect. And, um, yeah. When it's called a forever chemical that is fear producing, you know, so. DD (00:39:28): Did you keep drinking Plainfield Township water once you knew that there was a problem? RM (00:39:36): Well, we got one under sink filter for the kitchen, um, you know, separate little spigot, and we used that for our drinking water for the most part. But, you know, we maybe still fill the spaghetti pot from the regular filter. I mean, this, um, you know, before they put the fancy filter on, it's not like we were buying drink, um, bottled water. So it's like, what's your choice? You know? And then you find out that bottled water has PFAS too, and probably microplastics. And so, um, that's, that's not an answer either. So, um, yeah. So we had a three stage Aquasana water filter. I forgot what year we installed that. Pretty, pretty quickly after all this. And then, um, but you know, of course, you know, we were still showering and their skin and, um, laundry and you know, we, like I said, we just had the one undersink filter, so 17 �DD (00:40:36): You've, you've mentioned that you had spoken about concerns for your children. Did you ever have concerns for yourself? RM (00:40:45): Well, that's a good segue, <laugh>. Thank you. Um, you know, now I'm 52 and I, you know, I feel like I've, I've lived a good share of my life. Of course I'm not old, but, um, whatever your definition of old is, <laugh>. But, uh, it keeps getting pushed back farther and farther. But, um, yeah, always have been pretty healthy. Not never on meds or have any health issues that really caused me any major. You know, I just went for my yearly physical and had, um, uh, no concerns really. I mean, I figured it was probably too little too late anyways, because by the time I'd been drinking it since 2001 and all my other environmental exposures that, um, you know, just living in a developed country, you know. Um, but okay. Here's our segue to, um, if you had done this interview with me before March 25th, 2025, I would've pretty much been done with what I wanted to say for the most part. RM (00:41:58): But that is the date that I was diagnosed with young onset Parkinson's Disease. And, um, I am a realist, like I mentioned before, and I, I just tend to jump in with two feet. And, and actually I had, I had actually jumped into the Parkinson's thing a few years ago because I have a very strong family history of it. So I was already fascinated with kind of like maybe the genetic, um, factors there. My dad had it, his sister, um, their mother, my grandmother had essential tremors. So when I got a tremor a year or two ago, I was really hopeful it was an essential tremor, you know? 'cause sometimes people just get a little shaky, you know? Not necessarily at age 50 or 49, however old I was. But, um, you know, I always kind of half joked between the three of us siblings, you know, probably one of us is gonna get Parkinson's, you know, um, and I won the lottery there. Hopefully my other two older siblings don't get it. Um, so I have a, a strong family history. So, um, um, so how that ties in with PFAS. RM (00:43:14): So in, um, in 2019, I, I, I, um, 2018, I, I got a, I kind of changed careers from the, um, nurse aid thing 'cause burned out in my body, you know, I knew I couldn't do it for the rest of my life. And so I got a, went to Ferris and got a certificate in cancer Information management. Always been fascinating 'cause who hasn't been affected by cancer. Um, my husband's, uh, 28-year-old brother died of a rare sarcoma that may or may not have been from, um, pesticide exposure 'cause they grew up, um, in migrant housing and up north. With pesticides and such. Um, so I, you know, I've always been kind of concerned for my husband with, he was out weeding fields from age 10 and up, you know, um, that exposure. And, um, so how that ties in, you know, so I was a researcher for cancer and, you know, I'm looking at people's medical records all day and, um, educating myself, and not just cancer. RM (00:44:20): And, um, and just recently since I was invited to do this interview, kind of arranged with Lynn's help. Thank you, Lynn. And, um, I've just kind of delved into this. I work with cancer registry. So in 1971, Nixon passed, you know, kind of a law like the war on cancer, which there's been different, there's a war on, you know, war on Parkinson's or war, you know, sort of thing too. Um, that's been more recent. But, um, so hospitals and such are required to, to report their cancer cases to state and national registries. So that's what I deal with. I deal with pulling that information out of people's medical records and putting it, you know, it's not even, it's sort of de-identified, I guess, you know, the, when it, when it gets to 18 �public, um, access of that sort of statistics. But, um, so that got me thinking about, um, cancer isn't the only thing out there that's caused by environmental contaminants. RM (00:45:40): That's, it's been established with Parkinson's that, um, that they, they actually know, they figured out that it's actually a higher number than they thought was genetically related. So I did do some genetic testing, which surprisingly came back negative for the known monogenic causes of Parkinson's. So there's like top seven mutations that, that is a definite connection with getting Parkinson's, especially like young onset. Um, and, um, I did, I tested negative for those, and then they did an additional panel of like 21 additional genes that are associated with Parkinson's, Parkinsonism, whatever you wanna call it. And that was also negative, but educating myself, I've always been fascinated with genetics, you know, and the epigenetic thing is that those top seven singular genes that I could have inherited, which, you know, I could, there, I could have one bad guy that they just haven't discovered yet. RM (00:46:46): Because even with cancer, they find different mutations, not just the BRCA, the BRCA is the main, is the well-known one, but. With cancer. Um, so yeah, I could potentially have, you know, since I have such a big family history, potentially have an unknown bad guy or, um, there's, it could be polygenic just in, like my husband has high cholesterol that runs in his family. He, you know, when his twenties, you know, kinda a younger onset of high cholesterol and all the stuff that comes along with heart disease. And, um, so I may may very well have two genes working, what's the word? Um, together, together in tandem. Yeah. Together, um, to cause my trigger to get Parkinson's to be more sensitive to environmental contaminants. Um, genetically predisposed. Yes. So, I mean, and I had looked into it. My dad was officially diagnosed, I think in his early seventies, but I'm sure he had it at least 10 years before that he didn't have, have really have a tremor. RM (00:48:03): So if I hadn't gotten my tremor, I would, I, right now I could be sitting here not knowing I had Parkinson's because I didn't give the tremor. But all this other stuff that I've been chalking up to perimenopause and long COVID and like, 'cause I lost my smell with COVID. So I'm like, well I've, maybe it's just long COVID all this more cognitive and mood issues that I was dealing with. 'cause it's not just a tremor. Um, so, you know, to turn my lemons into lemonade, I've gotten involved just in the, it's not even been a year yet, you know, nine months or whatever that since my diagnosis with, um, kind of educating and not really the advocating yet, but the educating of others. First of all, what Parkinson's is, being not just a tremor, like my, I sent you that, the iceberg, because there's so many, um, symptoms that of course, you know, I'll, if you have 'em, you don't necessarily have Parkinson's. RM (00:49:09): But, and there can be overlap, but people with Parkinson's can have a lot more than meets the eye. I don't know if you have any family members with Parkinson's or know...? DD (00:49:21): I don't have any family members with Parkinson's. RM (00:49:23): or know anybody closely? 19 �New Speaker (00:49:25): Yeah, I do know a few people. New Speaker (00:49:26): Yeah. So, um, I've done a little writing, which I don't consider myself a writer. I love more technical stuff, but I've, I apparently have a little bit of a flare for it. You know, I sent you the one article, but more nuts and bolts and, um, so the lemonade, lemons into lemonade, um, this interview and kind of like, well, is there a Parkinson's registry? You know, like cancer registry? And, um, I sent you that. I found out just right before I sent that to you, I'm like, oh, California, Utah and Nebraska have Parkinson's registries. RM (00:50:02): And California specifically had talked about Parkinson's hotpots, and I'm like, with cancer, cancer clusters. I'm like, Hmm. And, and somebody offhandedly mentioned to me at some Parkinson's gathering, they're like, oh, so maybe that's why there's so many people in West Michigan with Parkinson's. And I'm like, wait, what really? What, what did you just say? You know what I mean? So that's kind of whet my Sherlock Holmes, I guess of like <laugh> my, my data mind, um, to go Well, um, I listened to Kevin Elliot's, um, interview that you did, and he said, he talked about substantial scientific uncertainty. You know, they base, you know, the, of course the essence of science, there's always gonna be some sort of uncertainty, but substantial, I guess was the key word. So if you're gonna use the excuse of no data, let's try to fix that. You know what I mean? RM (00:51:06): Like, oh, it might be tied to Parkinson's, you know, PFAS tied with Parkinson's too, but the absence of evidence is not evidence of absence. So how can we get the evidence, the data, um, because when somebody says there's no reported problems, that's not good enough for me. You know what I mean? Like, um, I, uh, yeah, we talked about how these government people like kind of fein or the lawyers or whatever, whoever you're talking about, fein ignorance or, or they, well, we don't know. You know, that's, I'm not the type to just be, oh, we don't know, then just stick my head in the sand. You know, it's like, yeah, it sucks to have Parkinson's and I, I maybe overanalyze it, but at the same time, just like Lynn, maybe people thought she was overanalyzing what was going on with Wolverine and so forth. RM (00:52:13): Um, it just seems like a no-brainer that, um, PFAS in Parkinson's needs to be delved into more deeply. DD (00:52:28): The role of PFAS? RM (00:52:29): The role of PFAS, especially since it's such a forever chemical and it's shown to be a neurotoxin. Um, and one of the things I've researched for one, one of the articles I wrote was about brain first versus body first origins. And, um, that was eyeopening to me because, you know, you assume it starts in the brain, you know, maybe a lot of Parkinson's people lose their sense of smell from Parkinson's, like the olfactory bulb. But there's lots of research lately about how it could start in your gut and then travel up your vagus nerve to your brainstem. Yeah. So poor gut health, leaky gut, all that. And what if you're putting in 20 �your gut could affect getting, you know, the incidence prevalent or whatever incidence of increasing your risk. RM (00:53:19): Especially, you know, if you have that genetic predisposition. I'll have to send you that article. DD (00:53:24): That's wild. RM (00:53:26): I know. And then there was another article I haven't even read, it was quite long. I haven't read about how your gut microbiome is. So they, they're just learning so much about how instrumental those are in your general health. You know, not you just, you think of them as digestion, but, um, some of them might help take PFAS out of your body or some, you know, if you have poor gut health, you know, or low by low amount of the good bacteria. And, um, you're more susceptible for, um, nasties to maybe travel up your vagus nerve to your brainstem, for example. So, um, DD (00:54:12): So you've been kind of throwing yourself into this new research project, it sounds like. RM (00:54:16): I tend, I tend to do that, which isn't always necessarily good for my physical and mental health, but, DD (00:54:25): And is this this kind of been since your diagnosis or were you starting to do this work before? RM (00:54:32): Not in relation to PFAS, but actually, um, I like to promote Michael J. Fox has a data study called PPMI. Um, I could look up what exactly that stands for, but basically anyone, any adult can join it. And I actually joined it in 2022. Um, I think that's around the time that I noticed a twitch behind my right knee. And I, I didn't necessarily, you know, a lot of it's hindsight, you know, like Huh. Subconsciously or whatever. But I had looked into, um, you know, 'cause Michael J. Fox has helped just bring the, the Parkinson's to the forefront, just like with Lynn and PFAS here in this area. And, um, so since 2022, I've been, um, taking data surveys every three months so they can, um, track progression. Like, 'cause so I, I started it when I wasn't diagnosed. Then there's like, you know, you keep asking you every time, "Have you been diagnosed?" RM (00:55:29): No, no. And then finally I said, yes, you know, 'cause I got diagnosed and my got my sister to do it. She hasn't been diagnosed. And hopefully it won't be, but to compare, you gotta have your control of who doesn't get Parkinson's. So if, if you'd like to join PPMI, I can send you info. 'cause um, they need that, you know, kind of, you know, the, the non-Parkies that, um, uh, and actually that that ties in like jumping in with both feet. I joined a clinical trial, which, um, they actually compare their, the date of their, um, they compare what they're finding out from my blood tests or brain scans and comparing it to 21 �some of the data that's been gathered through PPMI to say this, I'm taking a neuro antineuroinflammatory pill that's hopefully will slow my Parkinson's, but that's kind of subjective, you know. RM (00:56:38): So they do, they do draw blood to see if my inflammasomes, you know, these inflammatory markers, how they respond or don't respond. You know, like it could be on the placebo too. It's one of those. So, um, but the PPMI is helpful to have something to compare, you know what I mean? Such a big data set to, um, to know how people tend to progress. But my neurologist said, if you've seen one Parkinson's patient, you've seen one Parkinson's patient. Because it's so variable. And that's the tricky part of Parkinson's is like young onset generally progress slower, but not always. So, um, and DD (00:57:19): Then I'm sure if you're trying to link in PFAS, it just makes it all the trickier. RM (00:57:24): Yeah. And like, and I kind of put PFAS to the back burner, you know. But now this is kind of brought it to the front burner, which it, you know, like it is what it is. And I'm, like I said, I'm a realist and, um, yeah, I went, I went through the stages of grief and probably still am going through a, a, you know, potential loss of abilities and, and a lot of hindsight stuff like, oh, that's why I, you know, it wasn't just necessarily like seasonal effective disorder, why I'm, my anxiety and depression have increased and, you know what I mean? 'cause of my, my dopamine, my serotonin, my norepinephrine, um, I showed, I showed Lynn this graph, which she's like, oh, you have to need to unsee that. And I'm like, yeah, I wish I could. It says that by the time you have your motor symptom, you've already probably lost up to 70% of your dopamine producing neurons. DD (00:58:18): Wow. RM (00:58:18): Yeah. So it's not just like, oh, you get a tremor. Oh, now you have Parkinson's, you've had Parkinson's, and now it's just finally enough death of which I was thinking that Parkinson's is almost like a reverse cancer in a way, because instead of cells proliferating these alpha nucleon misfolded proteins are going in your body and killing off stuff and causing a tremor causing, um, my right leg. I don't, I don't take as big of a step with my right leg. And, um, when I, when I walk without thinking about it, my right arm doesn't swing. And, you know, my loss of smell might be from the Parkinson's also, even though my husband can't smell either from the COVID from in 2021. But, um, anyways, to kind of wrap up, um, what my newest, I guess not really tangent, um, about how, I dunno, what, what was your, your wrap up question of, um, I think you kind of asked it already, but DD (00:59:27): What concerns do you have about PFAS contamination moving forward? RM (00:59:30): Moving forward? Um, yeah, Lynn's comment about, I don't know, I think she maybe maybe said it off the record, but, um, about like Tobin's family thinking that, assuming, you know, that terrible word of 22 �assuming that their treated Plainfield Township water after they got put on that expensive, you know, extension of Plainfield townships, um, waterlines. Assuming that first of all, that government's gonna take care of you to the extreme. You know, they, they, you know, that's not a, not a thing. And, um, just to be more aware and, and, uh, and you can't, you can drive yourself crazy with like, oh, should I eat this? Not eat that, drink that, not drink that. And that's no way to live either. So it's a balance. It's definitely a balance. Like just with my Parkinson's, it's like I really shouldn't be eating sugar and carbs. 'cause you know, especially gluten, it's a, it's an inflammatory substance. RM (01:00:41): Do I still eat some, I eat a lot less of it, but I put sugar in my tea. And, um, so that's still a struggle for me. I don't, you know, especially with being only 52 and I have potentially 30 some years, my dad passed away when he was almost 86 with Parkinson's, so it's won't necessarily shorten my life, but do I even wanna live till I'm 90 with being stuck in a nursing home? And like, he, it was a very traumatic time with my dad being stuck in a nursing home during COVID. Didn't get to see him butt through a window for a year. So I could, I, I won't go down that rabbit hole, but, um, DD (01:01:23): Well maybe thinking about rabbit holes, is there anything else that you want to touch on or go back to before we wrap up? Or things that we didn't get to bring up? RM (01:01:31): Right. Um, let me just look at my notes RM (01:01:40): Because one of the things with Parkinson's is it can affect, not necessarily your long-term memory, like Alzheimer's, but, um, I remember Googling adult onset ADD before I was diagnosed on like, what is going on? Like, I felt like I was getting ADD and I'm like, isn't that usually, you know, you get diagnosed when you're hyper kid or whatever, but like, especially with women, a lot of times, you know, I'm probably, I might have some ADD too, but it's more of a mental ADD, but then add in Parkinson's and I'm gotta refer to my notes and cues and such. RM (01:02:17): You know, I've pretty much touched on all my notes. I guess getting back to Parkinson's registry and like how finding Parkinson's hotspots, like I think it was, um, Bob Delaney that was talking about his interview about autism along highways. I'm like, that, that was eyeopening to me. So I'm very interested in maybe advocating, and I'll probably jump in with two feet and like advocating for a Michigan Parkinson's registry like California has. And, um, of course that takes money, you know, money, you know, as much as we hate, you know, oh, evil corporations and blah, blah, blah. You know, money does make the world go round in some respect. Obviously some, um, CEOs take it to the extreme to, like, money's more important than people's health. Um, but, uh, yeah. So I, I'll I'll keep you updated on that. <laugh>. DD (01:03:19): please do. RM (01:03:21): 23 �so. Um, oh, 'cause oh, and ADD 'cause you know the autism and like ADHD, um, ADD has also been linked to dopamine issues and surprisingly enough, so I dunno if you've heard that. Hmm. So it is a dopamine thing potentially, or part of it with, um, ADD. So, um, you know, the explosion of autism and ADD, you know what I mean? Like ADHD, uh, then we have, you know, putting kids on all these meds 'cause I've, I've never been a pop a pill person and I'm a little conflicted about this clinical trial, but I'm like, Hey, if it'll slow my Parkinson's, why not throw, throw the kitchen sink at it, sort of thing. So, yeah. RM (01:04:08): Yes. So I think that's, I guess my, my last little note I said, um, had a little flow chart of, um, you know, just like my little Plainfield township, Lynn's city of Rockford and private wells, and then, oh, that's, we don't have time to get into this, but, um, the health study that they did. That's Lynn really advocated and I, I, I volunteered for it too. I really wanted to be a part of that. This, it was a few years ago now, right? And, um, there's, I think there's still a place for the 40,000 people that have been drinking Plainfield Township water, um, to have participation in some sort of study. Um, obviously you have to, you have to cap it somehow, you know, and, but, um, but again, they're data, right? Like, just like money makes the world go around in a lot of ways. RM (01:05:11): You know, if, if you don't have the data, then you, they throw up their hands and Oh, well we don't know. And I'm like, you know, that's... And I saw a little ad for, you know, these ugly Christmas sweaters and, um, this one said I was, I told my boys, I'm like, I would actually wear this sweater. It said, "this calls for a spreadsheet." And that's like, you know, if I could spreadsheet, you know, Parkinson's prevalence incidents and, you know, with, with geographic information systems, GIS mapping, hotspots, you know, just like with cancer clusters and apparently autism, you know, and, and now it was fascinating too about the upper class people getting, um, having more exposure to PFAS with the Scotchgarded carpets and such. But, um, yeah. So, oh, so my flowchart said, yeah, you start with township and city. Can I go to the county? 'cause that was like a Kent County. Um, did they limit that? Do you know much about that health study? I, I looked into it, but I've forgotten a lot of it. But I've. DD (01:06:16): They've done a couple different health studies... RM (01:06:17): North Kent. Yeah. There's been different ones, you know, and affecting Michigan and their governance. And then, you know, we've had, um, Italy and Japan and what other countries can you think of that have been...? DD (01:06:28): Australia. RM (01:06:30): Australia that's been very, um, 'cause besides Wurtsmith, um, this epicenter has really helped explode the testing and the knowledge. I mean, right? <Laugh>. DD (01:06:47): 24 �Yeah. Yeah, I think so. Yeah. RM (01:06:50): Yeah. So, so yeah. Alright. I guess that's about it. DD (01:06:56): Well, thank you so much, Renee, for taking the time to talk with me today. New Speaker (01:06:59): You're very welcome. 25 � https://digitalcollections.library.gvsu.edu/files/original/468d76fb663640a3710095dfd16ac3ac.mp3 0053b46eff4e1dd3b7ecd18dae7213be 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 PFAS0043 Creator An entity primarily responsible for making the resource Mata, Renae Date A point or period of time associated with an event in the lifecycle of the resource 2025-12-11 Title A name given to the resource Renae Mata, 2025 (Interview audio and transcript) Description An account of the resource Renae Mata describes drinking Plainfield Township water for years before learning it was contaminated with PFAS and reflects on the health implications for her family. She also discusses her later diagnosis of early-onset Parkinson’s disease and the questions it raises about long-term environmental exposure. 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/61b95429dbe0bf3288fa99d75e8fe2d2.mp4 60ff07bf5b99036ac083bfc33ae8e2e8 https://digitalcollections.library.gvsu.edu/files/original/2c006ccc82049de6d5c5d005c4cf193f.pdf 6c44df5c20edc3f7f4aff26450e40901 PDF Text Text Living with PFAS Interviewee: Paul Golembiewski Interviewer: Dani DeVasto Date: November 6, 2025 Dani DeVasto (DD): I'm Dani DeVasto and today, November 6, 2025, I have the pleasure of chatting with Paul Golembiewski. Hi, Paul! Paul Golembiewski (PG): Very good. Thank you. DD : Thank you. Paul, can you tell me where you're from and where you currently live? PG: Grand Rapids, Michigan. Rockford, Michigan. It's not far. The same places basically. Went to school at the University of Michigan State. What am I saying? University of Michigan? Michigan State. Graduated with two degrees, horticulture and crop and soil sciences and have been working my own business for 43 years. And have lived here for 48. DD : And your business is? PG: Expressive Horticulture. Landscape design, installation, problem solving. I throw a lot of pesticides out there, so I'm aware of chemical use. And that would be of benefit probably to this discussion also. I'm lived here very intensely. Um, city lot. Planted 40 trees. Someone told me the last thing I planted was my feet. <laughs>. DD : And how long have you been in Rockford? PG: 47 DD : For 47 years? PG: Yeah. DD : 1 �Awesome. Paul, can you tell me a story or several stories about your experience with PFAS or with PFAS in your community? PG: Um, I'd like to start with a story that I was six years old and my parents loved to ride around on Sunday afternoons and, uh, in the old Oldsmobile with no AC and I'd get the middle of the backseat 'cause my sisters got the windows. And my dad was told of a gentleman in Rockford who had animals in cages on his front yard. My dad worked at Fisher Body and he knew he was a very good oh politician. Met a lot of, met a lot of people and knew them well. And so he'd always have conversations on where to go on a Sunday afternoon because he'd like to drive. So we ended up, my my recollection is we came down Oak Street and we went across the railroad. And the first house on the right was Mr. Cahill's house. The gentleman whose name is used on our road. PG: And sure enough, there were cages in the front yard. There was a, there was a bear, there was a black large cat. There were peacocks walking around. I think there might've been some monkeys. My sister Sue got out of the car and ran up the front door, and Mr. Cahill, you know, came to the door and invited her in the basement to look at other animals. And here's my parents not doing anything like, oh, yeah, go ahead. I mean, they, they didn't, they didn't give her permission, she just, just went. DD : Wow. PG: So she emerged about 15 minutes later, and while I was waiting, I looked to the, uh, northwest, which is where this development that I live now is, and it was totally barren. There wasn't a stick of a grass or weed, anything, nothing. And the smell...watering my eyes and burning my nose. And I asked my dad, what's that smell? And he says, oh, that's pig. That's why nobody moves to Rockford. DD : Hmm. PG: <laugh>. So later I found out that where I live was basically a field of the waste from the vats at Wolverine. And when the smell got to be too bad, they trenched it in. Now jump ahead 50 years. And this became a development. Nobody has record of where those trenches are. Nobody has any information on what was in those trenches, except it's obvious, it's lead, mercury, chromium, and likely PFAS later on. So this whole development had likelihood of a lot of contamination. Consequently, uh, because of HIPAA, you can't get enough information to know how people's health are, you know, their health is around here. But in my experience, there have been four premature deaths and several people with blood, bone and, um, oh, muscle activities, you know, that they can't do anymore. Um, two 10year-old kids who were next door to each other, but they were 10 years apart, and they played in the same sandbox. And when I got involved with Lynn McIntosh, I was responsible for taking soil samples. And I, I found that, uh, kind of a shaded area where the sandbox would've been between their two properties. It was right on the property line, and I took a sample and, uh, it was sent off to Prein and Newhof to be analyzed. Uh, it never came back. And Lynn and I found out later that all the samples were 2 �lost, or they were tossed intentionally. And that's because Wolverine instructed them to, they didn't want any of the soil tested from Rockford. DD : But you guys were paying for those tests? PG: Well, we never paid for 'em, because they never came back. <laugh>, DD : but they were like your own private tests? Samples? PG: Yeah. It was, it was very disheartening. We took other samples, and I think Lynn may have sent some of them out. Um, so let's keep this in some sort of chronological order. I'm jumping around a little bit. DD : Can I ask you a question? PG: Sure. DD : Um, Mr. Cahill, who is he? PG: Oh, he was the mayor, the chief of police, the, um, uh, the governor, the, um, he was every officer that could be possible for the city of Jericho. And, um, I went to his house about four or five years ago, and there was a new owner, and I asked if there were any, any sort of documents, any sort of newspapers of any sort left up in the attic, maybe used for insulation or anything. And they said they'll look, but I've never heard back from them. Um, but the, yeah, the city of Jericho was, uh, a sad place to be, unfortunately. Just, just a little side note. The, uh, just to the east of the bridge that goes over the Rogue River, that is the Jericho Road. There is a sandy level surface there. It's the only such surface that I know of on the Rogue River. I've canoed it a couple times. And the gentleman who bought the property there, Mill Pond, built the condos, did research to find out that that was an Indian trading post for 10,000 years. <laugh>. DD : Wow. PG: Yeah. And here's, uh, Jericho came in, put up a dam to flood their entire trading area. And the Indians just decided to leave. They, they didn't have much left to hunt anyway, because all the forests were gone, so the animals were not there anymore. So they basically agreed, you know, there was no 3 �skirmish at all. And, uh, so Jericho became a horrible place after a while. They were nice and friendly to the Indians at first. Now I got all this is, this is not directly from the Indians, but this information I got from Charles Hornbach, who was the owner and developer of that property. And he went back through archives, actual physical pieces of paper and the internet, and found this information. And, um, I'm very grateful for him doing that. And while I did the landscaping there, I found countless number of arrowheads and pieces of pottery, you know, so that, yeah. You can tell there was life there for a long time. Yeah. Anyway, so how about the next subject? DD : <laugh>. Alright. So, so you, yeah. You were six and seeing these animals in cages and seeing the, just the barrenness of the land up here. Um, and then you were talking about the, the trenches. But that there are no, there's no record, no. Of where the trenches have gone. And I assume no testing? PG: Uh, intentionally. And we'll get to that later. Living with PFAS, that's, that's the stuff that, um, this little interview will be very much valuable for with the information I have. But later on, I was told by the great, great grandson of the homesteader of that property, Mr. Giles, he said his grandfather was told it was fertilizer and to dump it on the, on the ground. And they could be in, in some way, having, you know, better crops, didn't do anything but kill everything. DD : Oops. PG: Yeah. Um, there's, there's a couple of side notes on that. I, I guess I could say this now that he told me that right along my property line was a two track that went to the railroad, that Wolverine at about, uh, 1915, got permission to dump their waste on the railroad's property because it was lead. A lot of, uh, arsenic is lead. So the railroad would spray the railroad bed twice a year with arsenic. So in this case, from, from what is my property line to 12 Mile became a dumping site right alongside the railroad. Because the, the terrain was possible to run a, what would be a, if you can imagine a truck from the 1915s, you know, the wheels are about, you know, six inches across and there may be 20 horsepower or flatbed. And they had barrels on them, and the barrels would slosh around while they would go, you know, down the two track and across and down to the railroad's property, and they'd dump them, just kick 'em off. PG: And imagine, you know, how ridiculous that would've been. But, so that was what Mr. Giles told me. So that's, that's firsthand information. I asked the DEQ if they could test the railroad, and they told me, oh, they already did. And there's nothing, there's, there's no lead. It's all set. Right. You got a hundred years of applying arsenic, and then you got Wolverine dumping on it. It doesn't make sense that it doesn't have contamination. I tell everybody to keep their dogs on the asphalt, and if it's a dry, dusty day, don't go out there because the dust is gonna be blowing and you're gonna get inhaling it. PG: Oh, yeah. I'm sorry. I skipped over the story between the two kids that were 10 years apart. Um, yeah. Uh, let's see. Kruisenga, Derek Kruisenga and his neighbor, neighbor of 10 years later, her name was 4 �Tammy, I don't have her last name. They both died of the same very rare nasal cancer. And it's because they played in that same sandbox, and there wasn't enough sand in it. And if you look at the terrain, it was right on top of a, of a ridge that the truck from 1915 would have then dumped and probably spilled over and ran down the hill, and probably on the wrong side. And so that area right there is probably very, very contaminated. And they were playing in the dust, and they both had a very horrendous death. They, they suffocated they had cancer in their sinuses that couldn't be cured. PG: Um, yeah. And I was really quite amazed that the, the doctor that was treating, um, Derek actually diagnosed that. He said, this is a chromium toxicity. And at that point, no one had even thought of that, so whatever happened to that information I don't know. It never was then found to be a serious issue, which again, at the end of this interview, I have a a point to make, but, well, let's see. Let me go on to, oh, yes. <laugh>, our founding fathers, can I mention their names? They're long gone. Rockford's founding fathers. Mr. Blakesley, Mr. Farmer and Mr. Krause. Mr. Krause was the architect of Wolverine Worldwide. In 1905, Ford began to want chrome bumpers. Mr. Kraus had been to Europe and saw where their plating process was great for cleaning up hides from pig hides for, for leather, because the acid would eat the remaining flush away without any having physical work to clean it. And in that same vat, there were lead, mercury, and chromium, which made the leather heavy and ductile. So their boots that they made at the time. They would advertise 'em as a hundred year boot <laugh>. I wouldn't wanna, I would imagine that. But, um, so that's how Mr. Kraus made his money. Now, these three gentlemen all agreed to allow the dumping of that solution wherever Wolverine wanted to get rid of it, because that was Mr. Krause's venture, and they all knew it had lead. Lead has been a poison for 6,000 years. So they just said, oh, okay, fine. No, the next generation will take care of it or the next. And they never kept, never kept any records. Uh, they did own Bell Disposal in the sixties, and basically it just disposed of their liquid waste up to House Street DD : Who owned Bell Disposal? PG: Yeah, the, uh, gentleman that told me that he lived on 10 Mile and was able to see the vats and the solution sloshing out as they go down the road. And some of the hides would come out and he'd run out in the street and pick 'em up and play with 'em. And today he's blind. DD : And Krause owned Bell disposal or Wolverine did? PG: Wolverine did, yeah. Krause was the, he made his money in, in lumber, and, uh, then went into the, uh, tanning industry. And disposed of all the waste wherever he could. But he picked up the waste because of the booming plating industry, because of the Ford company. All throughout Rockford, which would be Keeler Brass, McInerney Spring & Wire, and probably three dozen other little, you know, outlets that were plating. And when they, they could only use that material for about six to eight hours, then it'd get contaminated. So they would change it out, and Wolverine would come and pick it up for free, and they'd put their hides in it. And then they dispose of it wherever was easy for them to dispose of, which in my degrees, I could tell where the foliage was incorrect. Where the, the growth of trees had been 5 �suffering and lead grows trees to death. It, it accelerates their growth. So you would find, um, elm, box elder, uh, choke cherry, all soft wooded trees along the, along the trail and in other places I found about 104 that were showing very, um, disfigured growth and a lot of dead growth. I gave a partial list of that to the EPA during a, um, interview, and they pretty much discarded it. DD : Hmm. That must have been disappointing. PG: Yeah, I think I mentioned this when we talked earlier, um, that only, that was about six years ago, that the EPA was looking for liaisons that would be able to talk to the community through information that they would give us. It was not that at all. It was just a ruse. It was to find out how many people knew how much, and to make sure that that information wasn't so widespread that people would panic. So it was an attempt to just feel around to understand who knows what and why. And I'm sure they got to me, they didn't want anything to do with me. They didn't want me to go out and start telling people what I know. Because <laugh>, that would not be DD : You knew too much. PG: They would, they would, I don't wanna panic people. Yeah. In fact, I want to do the other. But, um, we'll get to that at the end of this. Let me go on with my stories here. I'll, I'll go a little quicker. Um, I have a gentleman friend that I've known for several years. He and his wife live just over on Childsdale. And Carol had a condition that was never, uh, diagnosed and she had lower GI um, cancers and chronic pain and such that it was just horrific. Um, the back of their house is a ravine that had some water in it, which is the MO for Wolverine. They look for places just off the roadway that are already wet, and then they, they can dump their liquid and it's not as obvious. And, um, the gentleman that lived in that house before worked for Wolverine and had nine foster kids. <laugh>. DD : Oh my. PG: So it really didn't work. So what the fact was, he was being paid by Wolverine to dump, and at Carol and Conrad's backyard. And I had that as one of my sites with the EPA, and I never got notice back. But Carol had very serious health issues. And, uh, they divorced. And she's, she's okay. She's had a lot of surgeries, and she's been through chemo several times. So, and that's one story. Uh, let's see another story. DD : And those were neighbors of yours on Childsdale? PG: Yeah. Right up here, about a quarter mile away. My, uh, former cousin-in-law, Tom Breihof lived, he, he passed away from, again, lower GI cancer concerns. And he lived on the site that was later, much later, 6 �announced that from House Street to the Grand River, there was an underwater or underground, um, movement of that water from House Street, which was where there was a large amount of contamination for almost 20 years. Boy, you see what they do with that now. They really cleaned it up, maybe, but he lived and he had a well, and he drank his own water there, you know, so that was likely how he was affected. I've had two other accounts in that neighborhood. Um, one, the gentleman died when he was in his mid fifties of cancer. The other, while I was working there, they had health issues, and their backyard was literally seeping water, and they were lower than House Street on the other side of 131 Highway. By about maybe a half a mile, but they were right on top of that aquifer that was draining into the Grand River. And, uh, my job was to drain their backyard. Didn't know it at the time that it was, you know, likely PFAS. The water was, um, very, uh, it had an iridescent sheen to it, so it had oil in it. Um, but it was, it was a lot. I mean, we, we, we put in three tile lines and they ran water out just constantly into a wetland area behind their house, which then I also gave to the EPA. I get nothing. It's, it's, it's right around houses that are worth half a million dollars. And that's another issue that drives this. Property values. PG: So let's see. Next story. Oh, yeah. Right near the Rogue off of 12 Mile, Rogue River, there's a, uh, a development, it's a dead end road. There are 10 houses on that street. I did work for two of them. And while I was there, the account that I was working on said that there were nine people in those households, nine outta 10, that were suffering from cancer and are not expected to live. They all had wells, and they all were on a wetland or near a wetland that was used by Wolverine. Another site I gave to the EPA, nothing happened. Um, right now there's a, there's a new dog park just down the street from there. <laugh> and I, I look at that and I, I, the dogs have access to the river and, you know, people are there, you know, they, they've got a drinking fountain. I don't know. It must be a, well, I don't think so. I don't know. They must have had city water come into there because this, this development also had city water. But just recently. It had been almost 15 years that they were still using their wells. And all those houses sold out. I mean, they, they sold most everything, all those people that were there when I was there. They all sold their homes. DD : And left. PG: Yeah. So you know, talk about you don't really wanna publicize this stuff. But you have to. But, but there's, there's concentrations in places that are overwhelming. And then there's just a general understanding that, that these contaminations exist everywhere. I, I can drive down the road and I can look at just off the, off the side of the road, if there's a wetland area, you can right away see that it's contaminated. There's one DD : What, what kinds of things do you see that clue you in? PG: Trees that are growing like this <laugh>. I mean, they just don't, they have a very poor form, or they've rotted away, and then they're still trying to grow some more growth on them. And, you know, they're, they're terrible in that they, they can't, you know, they're growing too fast. They're, they're trying to, uh, 7 �grow more cells. It's cancer. And there's a, there's a holding pond at Rockford Public Schools, right between baseball fields. And that was a site that I told the EPA was, you know, to go test for. Two weeks ago. Now, this was nine years ago, eight years ago, I told 'em to. Last two weeks, they put up signs, metal signs every 30 feet. Caution, stand back. Do not enter, do not approach. Very serious language, very serious metal signs. Probably cost as much as a fence would've been <laugh>. But I'm sure that, you know, teenagers will be teenagers look, you know, looking through this and go pick up frogs that are, you know, dead and dying in there. DD : So someone's doing something PG: Yeah. That, what is is that? It's just a bandaid, you know? PG: Uh, let's see. Um, oh, I was on a, a site on Plainfield. And, um, this was for a, oh, a little retail, a strip mall. And I was in charge of the outdoor landscaping and such, and I was there to make sure that the excavation was gonna take place correctly. And, uh, we had an excavator putting in the, uh, I think it was a gas line. And he excavated down and he found metal barrels down about four feet in the ground. And so we dug around a little bit, and there were about half a dozen of them. They called the township, um, inspector over. And the inspector looked at them and waved his hands like this and walked away. They reburied the barrels and they rerouted the line. DD : Oh. PG: That, that whole area, that Plainfield and East Beltline was once a swamp. It was barely trackable in the 1900s. And then they put in a little sand, um, berm. So, you know, you could run a little truck over it or something. But, but that was all filled in. And that is also the location of Plainfield Township's water supply. It's the, the lake, DD : The current, the current location? PG: Yes. It's, it's the lake right to the east. It's, it's even got a public swimming area. No boats allowed, but I can't remember the name of the lake right now. <laugh>. But, but, uh, that's DD : Is that Versluis? PG: Versluis. Thank you. Thank you. So that's their water source for Plainfield Township. I was told by a prominent person regarding the, uh, they worked at the Plainfield, uh, offices and, 'cause we, I, I 8 �brought up the fact that that was all filled in and I can't imagine that that lake has clean water at all. And, uh, she said that the incidences of cancer and serious, serious health issues in Plainfield is 30% higher than the national average. They don't want that publicly known. Also, in the 1940s, there was a landfill just to the south of that by a quarter mile up by where Robinette's is. Just the other side of the road. You'll see these mounds that are there, and you'll see the pipes that come up every so often. So the, the property near Robinette's to the northeast driving down East Beltline, you'll see that there's this barren hillside with pipes sticking up and it's all fenced off. That was a landfill in the thirties that Wolverine used to dump serious amounts of PFAS and that drains into Versluis Lake. Now, they went through extensive amount of effort to ensure that the, that landfill doesn't have the opportunity to have enough water sourced actually, you know, penetrate the ground and go into the lake. So what they did was they, they put in wells, put in probably 30 wells all around so they could suck the water out continuously. And then on a Sunday afternoon, a Sunday morning, for some reason I was going down East Beltline and there's no churches there that I go, I don't go to church <laugh>. Sorry. So there's a lot of churches there. PG: But on a Sunday morning, I was going by there and there were, uh, at least a hundred guys that were rolling out white PVC over that entire, like, 10-12 acres site. And they were gluing the seams together. And then they, later on in the week, they then brought in top soil and put top soil over the PVC liner. So that way there's no water that can get through. Imagine the expense. Yeah. It's just an, an incredible expense. Why in, why does Wolverine get away with this? You know, it's so many ways in places that they've contaminated, it would be impossible to clean them all up. But this one is possible. It's a very condensed area. It's just like House Street. DD : That landfill. I think I've heard about it before. It's, um, Wolverine, this was not, Wolverine was not the only company dumping there. PG: Correct. It was not DD : So that, that also probably gets them out of PG: Yeah. Liability had to be stretched out over several people. And what, and then Wolverine could say, excuse me, <laugh>. DD : Mm-hmm <affirmative>. Okay. PG: Yeah. Okay. Let's see. What do I got here? Oh, I worked at the, uh, the CEO of Owen-Ames and Kimball, um, who built most of the schools in Rockford. I worked at his house for 25 years. Um, the house is worth probably 10 to 12 mill. It was right on the Rogue River. And, um, he told me the story of when he 9 �bought the place that it was just a little shack and it was all in need of all kinds of things. Of course, being involved in <laugh> Owen-Ames and Kimble, things got really fixed up and really very nicely. And, uh, the wellhead that was part of the original house was right next to the front door. And on the north side of the house, about 50 feet away was a wetlands that was right off of Algoma. And there was a nice little roadway back to four other homes further out into the woods and on the Rogue. And, uh, that was a site that Wolverine used. Um, the owner of the house knew it. When I told him what information I knew, he and his wife looked at me like deer, you know, staring at the headlights because they didn't want, they didn't want any way of suggesting that they already knew that 'cause their property values. And, uh, so the, the wellhead was moved to 150 feet away from the house, right at the very farthest point of their property. And the furthest they could get away from that wetland. Um, they still had five, six gallon containers of water delivered to their house every week. They still had a refrigerator in the garage stocked with bottled water. And all their grandkids and their kids all drank from that. Nobody drank from the water. But he was very smart. He probably had that tested soon after they moved in because he may have even suspected that the growth of those trees was not right. Everything was just twisted and gnarled and, uh, and it's right on the Rogue River, which, let's see, that is, yeah, that's, uh, upstream from where I discussed about the nine households that had cancer. But there are several other places along the Rogue River that are very easily accessible. And again, the MO of Wolverine is to have found a way that they could just park alongside a road or pull into a very, uh, well established roadway that's solid enough for a very heavy truck to dump all the liquids into the wetlands and down a slope. PG: It's a, it's really obvious to see those places and, you know, right away the trees, most people will probably think, well, that's just wetland and that's what trees look like when they're sitting in water. That's not the case. I can show you plenty of cases where there are wetlands that don't have that. Well, anyway, uh, <laugh>, uh, let's see. Oh yeah. Recently, I had an account. Well, let me, let me back up on, on Lake Bella Vista. Are you familiar with Lake Bella Vista? DD : Yes. PG: Okay. I don't think there's a home on the lake, no matter how small or how insignificant it is, that isn't worth over a mill. Right now, I've seen houses that are worthless places on the lake selling for 2.3. DD : because they're on the lake? PG: Yeah, they're on the lake. Um, I did the condos on the lake back in the early nineties. And, uh, there were two wells that were drilled on the condo property that were designed to keep the lake full of water because the lake was manmade. And it was supposed to be sealed with clay. Of course, you know, there are going, it's a huge place, you know, so there's always gonna be some, some ways in what the water gets out plus evaporation. But there may be one little spring in there someplace. But I wouldn't touch that either. But, um, so while we're working there, um, the water would flow a lot. I mean, there was a stream that was probably four feet wide and, and 10 inches deep of water flowing in all the time. 10 �Um, and I'll jump ahead to last year, I was working at a house, um, not far from there. And, um, one of my projects was to ensure that there was gonna be enough water for irrigation. And I looked at their water meter and it had a five eighth inch water meter. So I went to their association and I got permission to put in a one inch water meter because they didn't have much water running out in the yard. It was very poor water pressure and not a lot of volume. An irrigation system would've been a lot more expensive. 'cause you gotta put in more valves and more, more heads to be able to cover it. Uh, so I, I put in a one inch meter and, um, I, as I'm doing this, I'm cutting the pipes. I've had water turned off at the road, and I'm cutting the pipes and I'm measuring, I'm putting it in, and I cut the pipe and I look inside the pipe, and here it is nearly blocked with a black jello like stuff. It is. Um, I, I stuck my finger in it thinking, well what's this? <Laugh>. DD : Oh, Paul PG: Well, I take other measures. I wash my hands right away. But, um, it was, it was not a salt, it would've dissolved. It was not an organic compound. 'cause that would've, you know, rinsed away. Um, it, it was not a water soluble con, it's not a water soluble product at all. Okay. Think about PFAS. Okay. Teflon does not, you know, in any way, uh, connect with any other surface. So water is one of them. So here it is just at the meter, it slows down and this, this goo collects there. That, that's what was shutting off the water supply to the whole house, which they had a little tiny water filter. And the gentleman says, yeah, that's good enough. But that's another story. But anyway, so I I, I put the water meter in and I saved the pieces of pipe that I cut out. And I called the water authority. And the water authority that week had just changed hands. In other words, they hired somebody else to take care of the water around Lake Bella Vista because it's a closed system. PG: And the gentleman that came out, two of them had no history at all of what Lake Bella Vista was. They barely knew that it was a manmade lake. Now, when I did the condos, I was told that the wells were also going to feed the houses for a short time on the, uh, north or southeast corner of the lake, because they didn't have enough homes to afford a massive system with a wa with a water tower and, and had and water, um, wells. Which by the way, they did about 10, 12 years later. And they put it at the exact opposite place on the other side of the lake, furthest away from the condos, furthest away from what was the most likely dumping site because it was the lowest part of the lake. It was, it was a swampy area. It was called Grass Lake. I remember seeing it before it was ever excavated. And that was where they could have easily had access to it. Well, um, these two gentlemen had no idea. Well, I was, I told them that those two wells are still feeding this side of the lake. They should have been shut off 20, 25 years ago. And that's why the neighbors all around this cove were getting sick. Two people had died. And the people that live there are not very healthy. Um, low, low energy. They're going to the doctor often. Um, and they're using water from their faucets. So, uh, I told these guys, I said, you know, this has gotta stop. You gotta do something, you know, you gotta expand, you know, the water system around this side of the lake. Okay. Jump ahead a year later. And the wells are turned off. PG: Lake Bella Vista's water level now is down almost 18 inches. People can't get their boats in because in some cases it's too shallow. They can't run their jet skis because you gotta have 18 inches above the 11 �sand. Otherwise they're, you know, they burn out the, the pump. So there's all sorts of people wanting to know what's going on. Nobody's telling them. I know. Because they shut those wells off because the people on that side of the lake are finally getting water from another source. And it could be from Plainfield Township, who's been putting in a lot of water lines, although I haven't seen any construction there. It may be that they continued off to the, to the other side of the lake and used a bigger pump or dug another well, where their water tower is. But the, the creek doesn't run water into the lake anymore. So I know those wells are shut off. DD : That's a significant water difference for two wells. PG: What do you mean, sorry? DD : Like 18 inches down. And it, you think it was the two wells that got shut off? PG: Yeah. PG: That's a lot of supply. PG: Yeah. These are two eight inch wells. And there's a separate pumphouse for them. And there's, they probably run on 4-40 and they run day and night. And, uh, that's why the, uh, the service fees for like Bella Vista is something like $1,800 a year, which is probably not bad anymore. If they keep it there. But the, um, the, the new Water Authority looked into when I told them to look into it, and, you know, it took them a year before they, they recognized what the problem was. I just told an account, this goes back to my summary about that the lake has excessive amount of PFAS. DD : Has anyone tested Lake Bella Vista's water? PG: I again told EPA. They didn't. They probably did. They don't wanna let it out. Because these are million dollar homes. You know, people are gonna get really upset. A lot of lawsuits, they're gonna take, you know, EPA to court, a lot of lost time, a lot of money. So, but there, there's probably a lot of other contaminations in there too. DD : Did the, the black goo in the pipe ever get tested? PG: 12 �Uh, I gave it to the water authority, and I don't know, <laugh>, DD : Did the homeowners have anything to say? Or did they not see it? PG: Oh, they saw it. I, I showed the gentleman when I, you know, first cut it, he was home. I stuck my pinky in there and I said, look, <laugh>, DD : now we know why you didn't have water. PG: I only did it one time. I didn't do it twice. But, um, they were, they were bo both, uh, Air Force, uh, retirees. And they still make a lot of money doing related. And, uh, they told me that, well, if the Air Force didn't kill 'em, whatever's in the water is not gonna kill 'em. I, you know, I can't argue with that <laugh>. So you, but yeah. You know, they went through survival training and, you know, they had to, they had to eat crow and all sorts of fun stuff, you know, so but, um, yeah. So, so that's that whole ring of effort there. PG: And I, well, I did talk to an account and kind of the subject came up about the lake being low. And I told her about the wells being down and why. And she says, you mean the lake is contaminated? And I said, I wouldn't doubt it. I don't know if it's been tested, but I highly would <laugh> imagine that it has, because there's so many people and there's so much liability. And she got a little upset with me that I would suggest that Lake Bella Vista is toxic. I didn't quite say that. She asked me, is it contaminated? And I said, likely. That was just, you know, gotta be so careful. PG: Okay. Next effort. Uh, let's see. Oh yeah, I told you a certain, I won't name it, very prominent, um, engineering firm on East Beltline. I can say that much. Um, took my soil samples and threw them away. And at the same time I had insight that was, it was one of their employees that, that told me later that they were told by Wolverine. They didn't want, they weren't supposed to test anything from Rockford. So that's firsthand. PG: Uh, let's see. Hey, we're onto the second page. Almost done. Um, Lynn, when Lynn McIntosh first met up with me, she was riding her bike. She saw me out and she wanted to stop and, you know, say something about the landscape. And then she identified herself and, uh, she wanted me to try to have, you know, some understanding of where the contamination was. And that's when I told her about, you know, trees being disformed. So I, I said, well, just, I'll show you something. I said, so we walked out, we walked to the trail, and if you look to the east, you'll find nothing but disfigured trees. Soft wooded trees. A lot of 'em have fallen over recently. And the brush is gonna be there forever. 'cause they can't get a, a heavy truck on there with a chipper <laugh>, one thing only put one inch of asphalt out there. They shouldn't have done that. So, <laugh>. But you look to the, you look to the east, and the trees are 13 �gorgeous. They're absolutely beautiful because the creek stopped the buckboard and the little truck from going that way. And the, the, the creek wandered all the way up to the north. So this was the dividing line between here and 12 mile DD : Your house. PG: Yeah, so the property on my, on my property line is very contaminated. I don't do much of there. On the other side, it's not. DD : And the, the, um, the trail runs behind your house, right? PG: Yes. Correct. Runs parallel to the back property line. Yeah. So I, I showed Lynn that, and she, she got pretty excited about the fact that that was so obvious. DD : The cont the, the damaged trees are to the west or the east PG: To the, to the east. DD : To the east, yeah. And then west of it is...? PG: Yeah. From here to 12 mile is the worst. And, uh, it's a big difference. Um, and again, told the EPA nothing <laugh> one of the other sites. Should I stop saying that? <laugh> uh, let's see. See, I told you about the baseball pond and has the signs up. Uh, okay. I can, I can summarize this. Um, I, I own a, uh, tfel fry pan. Teflon. And I would never give that up. You'd have to prime my dead hand off of it before I'd give it up. <laugh>. I make breakfast every morning. And if I'm gonna clean the fry pan for, for more than 30 seconds, that's years off of my life cleaning a fry pan. So, okay. PFAS standing in the kitchen cleaning a fry pan, <laugh>. So, you know, the point is, um, there's toxins everywhere. And Wolverine got to the point where, where they knew that there was going to be more PFAS, there was going to be more lead, there was going to be more toxins. And there, there still is. I mean, there are a lot of things that we take for granted, like dish soap. How do we know that dish soap doesn't build up and then have effects on our environment and us, you know, nobody wants to know that. And if it does, if there's a, no one's gonna afford the testing for that because somebody's gonna be in very deep trouble <laugh>. So, um, yeah, nobody wants to know it's the norm. And without really knowing what is the norm, there's no absolutes, there's no, there's no guidelines, there's no baseline, there's, there's nothing. We all live in an industrial area that always has and always will be contaminated until, you know, you get up to, uh, probably Manistee, you know, you gotta go further north <laugh>, it's just, Ludington maybe. There's probably not a lot of industrial, uh, environments there. 14 �PG: They, there, there's a river. So there probably was some, at some point, whenever there's a river, there's gotta be some, some industry that decided they're going to make something and dump their waste into it. But further north, you go the further off of 94, you get goes east west, and so then you're out of the corridor. So shipping becomes a problem. So as global warming occurs and everybody goes north, hey, it'll probably be a better lifestyle. <laugh> who knows but, uh, yeah, Rockford, Rockford is toxic by design. It's, it's always gonna be that way. Uh, Wolverine did probably the most damage. And, uh, the, uh, the EPA did this huge cleanup, right where Wolverine was, where, where the tanning plant was, but they neglected to do the river. Now there's a dam immediately there. So lead chromium, zinc, they're very heavy. They're heavy elements. PG: They settle in the lowest spots. So the opposite side of that dam is probably one of the most contaminated areas. Someday that dam isn't gonna be there, it's gonna break, and all that stuff is gonna float down river. It is now, because it's being agitated all the time. A lot of it, you know, still comes around, but there's, that needed to be cleaned up. I mentioned that. Nothing happened. You know, they, they did the land, they, they actually trenched and dug and did a fine job. Uh, they did a fine job on House Street too. An enormous project. Took them four years. And I, it was, it was very similar to the, the landfill on East Beltline. They, they took out all the vegetation. And Lynn, you know, said to us that, that all had to go to Byron Center's landfill because it was toxic. PG: Now the trees are toxic. I didn't know that. Now that means all this vegetation along here is also toxic. You know, if you're, you're sitting there with a chainsaw and you're cutting up a dead tree that was on the railroad's property, and you're getting this dust from this, and Yeah. You, you shouldn't be there. No one should even be on the trail. It, it should have been fenced off and forgot about it. Oh. There's portions, portions of the trail further on the, the Mesquite Trail that go to Muskegon. They, they did that 'cause of contamination from, um, farm, uh, concerns for, um, factory farm for cattle. That they can't clean it up. And it's, it's got a lot of heavy metals in it. And so they just blocked off the trail indefinitely. DD : I can't imagine that happening for the White Pine. It's such a big thing. PG: Yeah. They should have signs up. You know, stay on the trail. Don't let your dog wander away. Stay off of this. And if it's dusty, if it's hot, if it's dry, don't go there. <laugh>. That's not gonna happen. You gotta have signs that show that, you know, people falling over on, on the ground around <laugh>. But, uh, so, you know, toxins are everywhere. And here's my point, the last thing. People are complacent, and they have to be, they have to be, otherwise they would panic. They'd go crazy thinking about all the things they have to be concerned about. And if life expectancy doesn't get beyond, you know, 75 or whatever it is, 78 now, then I guess that's okay. Um, you can't expect anymore if you're going to expect a Teflon coated fry pan <laugh>. And, you know, I, I gained three years of my life with that. So what, what I, you know, <laugh>, you know, I don't wanna stand by the sink that long. You know, there, there's just things you have to have to give up. And so I'm, you know, I, I don't want to burst your bubble or anybody else's, but we all live with a lot of toxins and they're not gonna go away. And, uh, if in fact, in the time, in the future that there is a way to clean this stuff up easily, marvelous. But there's gonna be side effects to 15 �that too. Probably cost, if anything, but um. Even in the cooling towers and the smoke stacks for what, what our power plants, they spray them down with PFAS on an every other week basis to keep the, the byproducts from accumulating so they all fall to the bottom. PG: And of course it all goes up in the air. There was a study done back early 2000s that from, Port Sheldon Power Plant, which is 46 miles away from us, their stacks, if you take a, a 60 degree angle out of those stacks to the west, that the incident of breast cancer is quadrupled for the next 30 miles. So we're just to the east of that. But you can imagine, you know, they're burning coal. Um, they were supposed to shut down and Trump said, no, don't shut down. Now they're going, I don't know, a couple more years. That makes some real good sense. PG: But, you know, again, this information, it, it either gets forgotten or it's not to be public. It's, it's to be, not to frighten anybody, let's just imagine what healthcare costs would be. What, you know, you wanna, you want a rider in your healthcare plan that says if you, if you are, you know, deemed to be too toxic to burn your body, <laugh>, they have to ship you over to Byron Center's landfill where, where everything else is toxic already. You know, because it, it's just a matter of, uh, there's no absolutes, there's no understanding it, there's nothing more than just be aware of it and do what you can to safeguard yourself. I eat chicken bones, a lot of chicken boats, <laugh> not, not the shafts, but the ends of the bones. I get a source of calcium that replaces the calcium that I, that I use every day. That's a whole other story, which I, I know you don't want to hear <laugh>, my kids don't ever wanna hear it either. <laugh>, I got one of them, one outta the four that's finally eating. No two, got two that are now eating their chicken bones. Sometimes <laugh>. DD : Oh my goodness. PG: So that, that would be the premise of how I feel. Yeah. And it's not easy. Yeah. DD : I'm, I guess it's striking me listening to all these different stories that your line of work has really put you in a position to see things in a way that most people don't get to see. You know, you're seeing both the kind of work you do, but also that you, you know, are working at all these different places in the area, PG: Black goo in someone's plumbing. Yeah. That's. DD : Like, you're just, you, your perspective is, is really like, you have a lot of data points in a lot of ways. So I think that's just, um, that's just not a perspective that, you know, most people, it's like, it's, it's me, it's here, it's in my neighborhood, or it's my thing. And you have all these different kind of reference points, which is very interesting. 16 �PG: I'm a very, um, empathetic and very, uh, observant person. And I'll, you know, toot my own in that way. But, um, so I, maybe that's why I, I see all these things. I don't know. I don't know if other people do and then they just don't, you know, take a, a moment to think about it. But, um, DD : Do you have concerns about, um, like exposure through your work? I mean, if you're, if you're digging in soil or you know, you're doing all these projects, um, do you have concerns for yourself? PG: I have for the last 45 years, applied some very horrific pesticides. And I don't wanna sound like those people that, you know, went through the Air Force and decided that if they didn't die from that, you know, that they're not gonna die from PFAS. But, but, um, I, I take, you know, some, uh, responsibilities to know what I'm using and what its action is. I stay away from any nerve agents. There's very safe pesticides out there in the last 22 years now that, um, you can spray on yourself. They're, they're actually labeled that way. They're, they're bifens. Well, bifen is a product name, but they're, uh, pyrethrins, which are made from, uh, originally made from, uh, chrysthemum and eucalyptus extracts. Now they're made synthetically. And you can buy the, the original, which is made from those two products. PG: Or you can buy the synthetic, which is a lot less money. And it works the same, but it, it is so safe. Um, it actually can be sprayed on the surface of your skin and on your clothing if you go out camping to keep out mites to keep out, uh, ticks and fleas. Um, I don't <laugh>, I, I don't do a lot of camping, but I do a lot of spraying. And I get a lot of, you know, overspray. I think I sprayed about 69, 68 people last year, and each of these places was a hundred gallons minimally. And they don't have a single insect for a year. And, uh, they can't be happier. Um, no spiders, no anything. No ants. Ants is a big thing because if you let ants get away, you know, they can destroy your house and your trees, you know, landscape, they can undermine your concrete. I have had so many people think that their driveway is cracking up because it was poorly installed. No, it was ants, <laugh>. They, after 25 years, the ants have moved out the sand and they've created their space. I could stop talking anytime. You could tell me. Shut up. DD : <laugh>. No, but, um, so it sounds like maybe you're not concerned about PFAS exposure for yourself through work. PG: Uh, boy, or That's a good question. I, I, um, no, I guess, well, one other little story I have, when I first moved here in '78, um, when 1980 came along, I looked at, I had been looking at Rockford's water supply was the Rogue River. It was just downstream from Wolverine Worldwide. And I was, I was mentioning this to people around here, and I says, what are we, what are we drinking here? We we're getting the water, just, it's going through a, a swimming pool filter, you know, diatomaceous earth. And, you know, it's supposed to be cleaned up and it's, that's not getting, you know, the chemicals out. So I went to at the time. DD : 17 �So what was, what was, what were people's reactions as you were...? PG: Oh, they, they thought I was, no, it's fine. Of course they wouldn't, you know, they wouldn't put poison in the water. And why would anybody do that? So I went to Builder Square at the time, you're not old enough, <laugh>. It was the first big box, uh, national chain. It was owned by Kmart. And on the shelf, I looked at all their water purification systems, and they had, well, larger, no, this was the larger one, <laugh>. It had a reverse osmosis filter in it, and a sediment filter and a carbon filter. And they were big filters, and this thing was big. And it took up the entire space underneath my cabinet in the kitchen. And, uh, I brought it home, cost a thousand dollars in 1980. And my wife said, no. I said, yes. I said, we're not drinking that water. Now, to this day, my kids are all very healthy and sane. Knock on wood. I don't have any but <laugh>. But I, I have other neighbors who they, you know, they don't have a filtration system, and they have health issues. They have fatigue issues. They have, um, poor reflex to, you know, food items. They get allergies, they get, uh, um, what's it, um, <laugh>, I said it earlier. But, but they have other concerns that, that are easily cured. You have to create, create for yourself an environment of your body that can withstand that. And your skin is your most important organ and it's the largest one, and you better make sure it stays perfect. I don't have any cracking. I don't have any soreness. And as of, you know, last year I calculated the amount of, you saw the trailer out front with the firewood in it. Okay. I've been doing that for 37 years, and sometimes many earliest years, I'd handle that amount of wood six times before it was burned. Now I got it down to like three, but I did the calculating over 37 years, and I have moved 1 million ton of wood personally. DD : Wow. PG: Yeah. DD : Wow. And, and it's, can I ask, how old are you? PG: 71. DD : 71. And it's, and you credit chicken bones. PG: What was that? DD : You give the credit to the chicken bones. PG: 18 �Well and we also eat, uh, products that are mostly organic. Or if they're not organic, they are no pesticides, hormones or antibiotics. And I go outta the way to get it. Um, we, we haven't gone out to eat in <laugh>, I don't remember, it's probably five plus years. Maybe we've gone out once or twice in there. But I don't trust, uh, food in a restaurant because they're always trying to make a profit. They're gonna give you whatever they can that's gonna make them money. And that's not gonna be the healthiest stuff. But we do eat Qdoba once in awhile we like that, but we don't eat burgers out anywhere. We eat organic ground beef. I, I buy salmon from Alaska. Um, which I still have. I have enough right now. But yeah, I eat fish two or three days a week. And, uh, so that's my efforts to get away from the contaminants. Yeah. Um, there's probably another three dozen of 'em. You don't want to hear my DD : No. But it does make, so I, you know, you've got the filter are on your street. Are you, are you on city water here? PG: Yes. Yes. And I just bought a new filter because the other one I couldn't get parts for and it was starting to leak. And the other one I got now is really nice. The first one I had, this is, it was a water pic, and it was one of the earlier, um, reverse osmosis, and it took 11 gallons of water to make one gallon of filtered water. So my water bills were always kind of high. Yeah. Plus I, you know, irrigate and, but, um, I cut my pipes here and I'm looking in the pipes. There is phosphorus, which is what it's supposed to be. It's supposed to be a coating. It's supposed to be white. So I know that there's no buildup of that much. PFAS. The, there's a pamphlet that comes out every year, and it's always suggesting that the, now the PFAS doesn't exist. PG: Well, it does, but their wells are well away from, from Wolverine. There's three eight inch wells that are water, our water source. And that has been in service now for, oh, since 06, 07. But I did hear through the gentleman who I mentioned earlier, who's the engineer. I asked him, I think the last couple days, no days, not months. Um, how's the water doing? And he says the aquifer is half empty, so there's gonna be a time when we're probably gonna have to switch. And the only other source of water is Lake Michigan, which was an option for Rockford. But the previous manager decided he was gonna do the well thing and then do, um, Wolverine or have, uh, the water sewer system. Oh, yeah. There's another caveat to that. <laugh>. This, this is, this is fun. Um, we were told by the city manager that we were going to have, um, the water sewer North Kent water sewer authority paid for by Wolverine. OK. And the sewer line, Wolverine was gonna pay for it all the new sewer line and the, the sewer cleaning facility. And, um, I dunno if they were gonna throw in the new wells there or not, but it was going to cost Wolverine, uh, over 20 years, millions of dollars a year to be able to afford to do that. Well, um, at the time they announced that, uh, about two and a half years went by, and then our city manager said, oops, Wolverine's no longer gonna pay for this, so everybody in Rockford's gonna have to pay for it. So my water bill now has an additional charge of $45 every billing period, which is two months. Um, and that's gonna go on 40 years <laugh>. But at the time, they, that Wolverine had announced that they were going to pay for it. They had already bought the permits to build in Big Rapids and move their facility there for tanning hides. So they weren't going to be using the sewer, they weren't gonna be using the, the sewage treatment plant. That was just our city manager wanting them to announce that. So the people in Rockford will all get all happy and excited and that he was doing a fine job and Wolverine is being so nice, <laugh>, but it was all planned. It was all planned. Two and a half years later, he said, oops, sorry. Uh, everybody's gonna have to be charged now. 19 �PG: <laugh>, It's corruption everywhere. You, you just, it's like it toxic, toxic substances. And then there's toxic people, there's toxic events, and then yeah. Everybody wants to have some sort of power and control, and they, they want to see if they can get away with it. Um, that's unfortunate. But it's, yeah. To, to preserve yourself, you have to know the facts. You have to feel that you are capable of making decisions, which also is, I'm still in Rockford and I know why the water system is the way it is, that I know that there's contaminants everywhere. And, um, and they're not just PFAS. Um, DD : So you sort of maybe hinted at this, um, but what concerns do you have about PFAS contamination kind of moving forward from here, if any? PG: Right in my neighborhood? DD : Locally or broader. PG: I, I guess I see it as being still being used. Um, there is not enough regulation on where and how it goes after it's been used. And if it can be contained at all. I don't, you know, the, the whole effort to give us a limit on how much PFAS can be in our water or any other sources around us is just a cover up. There's not, it's not ever going to be controlled. There's not ever gonna be enough testing. Um, there's not gonna be enough ways to try to change that substance into something that is not toxic. You know, the research to do that, I'm sure there is some, probably the makers of Teflon have to come up with something, or they have to have a, you know, a laboratory someplace, you know, that looks like they're trying. People are greedy. They're gonna keep being greedy and eat your chicken bones <laugh>. That's all DD : <laugh>. PG: Oh, it's, it's, I don't know. I, I find that, uh, I've been very fortunate and my kids are all very healthy. And I, I do know that in the past, some of my relatives have probably passed because of alcoholism before anything else, or they, they were not recognized as being, um, gay. So, you know, they committed suicide. So those are concerns too. Mentally. And, uh, I don't know. It, it's a, it's a crazy mixed bag of everything around us and probably PFAS may not be the worst. DD : I should ask you, before we wrap up, if there is anything that you'd like to add that we haven't touched on, or anything that you want to go back to, to say more about? PG: 20 �I, I have to give Lynn McIntosh enormous amount of credit. Wow, she is just one great woman, <laugh>. Yeah. If it weren't for her, I don't know where this would've gone. You know, I mean, she used me for information, but she put it all together. She presented it, she went to all the council meetings. She went to fight, you know, for some sort of understanding. And, uh, yeah. That's great. Yeah, there's been a couple of other people, I, I don't know them personally. I was part of the CCRR group and, you know, it's still kind of casually am. Um, Lynn kind of keeps me in tow, but, um, I've been so busy, <laugh>. But, uh, yeah, I, I really do have to give her probably 99% of the credit. Yeah. PG: And, uh, for me, it's just been, just been in the wrong place, or the right place at the right time, wrong time, whatever, you know, people open up, I see things that are not normal. I recognize that there's, uh, extenuating circumstances that should be looked into and never are. And I had my chance to talk to the EPA. Over an hour and a half, three very nice people that sat across the conference table. And I told 'em what I knew and how many ways they could check and test. Um, they didn't get back with me. Of course, <laugh>, there was never, never any liaison. DD : When did you meet with the EPA for that? When did, when was that? PG: Uh, four years ago. DD : Oh, so somewhat recently. PG: Yeah. Yeah. And they were just doing a, a fishing to find out who knew and how much, and to know if they had to try try to find out a way to be, uh, calming people down. Yeah. I've tried in so many ways to not be hysterical, not be playing, you know, commenting, you know, commenting, commenting to people that, you know, this is not good. There have been people on my street though, that I have told 'em not to let their kids play in the sandboxes. Uh, just, just abandoned them. And kids that had, you know, parents that had kids that were, uh, young toddlers and yeah. There have been incidences of, of childhood cancer here that, that really are out, out of the line. I mean, way outta line. I have warned people, you know, to, you know, if they have a, a daycare in their house. Uh, the, um, the development right to the north of me is also where, well, that's where the, the field was that the, you know, Mr. Giles' great-great grandfather had been, well, great-grandfather had been dumping or allowing Wolverine to dump. So they have a, a holding area, <laugh>, little retention pond that, that's built up like a up. And <laugh>, there's an overflow that goes down, Jericho. PG: Oh, yeah. There is one other story I should tell you anyway, that, that water goes into a, a storm drain that by all regulations, all ordinances, state, federal should have gone into a retention pond. And it had to be a a hundred feet away from the, from the bank of a water source. Which was be the Rogue River. Well, they, they ran that line, uh, down the new home. Here is his driveway underneath the driveway, and they emptied it out 15 feet from the Rogue River without it being in a retention pond. <laugh>. Why? I mean, they did, they, they just bypassed all of the regulations. So, and he goes, oh, here's 21 �something. And geez, I forgot to tell you, I dunno why I didn't write this one down. When I first moved here in, uh, '78, um, it was in March, and I noticed there was these two guys that were dressed in very dirty coveralls, uh, and driving a pickup truck that was all rusted out with a winch on the back, cable winch, and a motor that ran the winch. And they would, between the sewer manhole covers of the old sewer line which runs, you know, back that way. Um, they would send down a fish line and then pull back a, a stainless steel bucket the size of the sewer line on the power winch. They would do this continuously. Every 200 feet is a manhole cover that goes from here to Comstock Park <laugh>. And they would drag the bucket, pick it up, and dump it on the ground right next to the manhole. PG: You can imagine how contaminated that is. Again, I told the EPA, but I did tell million dollar homes across the river here. There's a development called, uh, River Bluff, I think it is. And, um, there's, there's two houses with a manhole cover on their property line, because the sewer line goes underneath that. And I told them, please don't let anybody near that. Don't, don't even touch it. Don't mow it, don't do anything. Just let it grow wild. And they don't, they manicure it and it's lot, a lot of dead <laugh>, but every 200 feet is probably the most contaminated surface in Rockford that you could have that runs right through those million dollar homes and all the way, all the way to Comack Park. Um, the EPA, nothing. DD : So you said you noticed them doing this back when you first moved here? Yes. Is this a practice they're still doing? Or they don't do it anymore? PG: No, they don't do it anymore. Um, they still use the old sewer line like we talked, and it's probably rusted through in so many ways 'cause of the acid that it's just leaking it out and it doesn't have to be dragged anymore <laugh>. So it, it just seeps into the ground. And you can imagine how that's going to affect the aquifer in 30 to 50 years from now. Um, especially. Right you know, right near the Rogue River, we're talking about surface water and we're, we're talking these manhole covers are just on either side of the Rogue River. And that's where they've been dumped. And, you know, every time it rains, a lot of that still finds its way into the river. DD : Oh yeah, for sure. PG: Yeah. I did, I did have a gentleman who lived across the street from me and his dad bought a piece of property and had owned it on the end of Rio Rogue, which was a dead end road, and it's beautiful little site right on the river. And, um, I remember talking to him and I told him, I says, you know, this could be contaminated. That sewer line runs, you know, right alongside your property. I told him what I knew. He sold it in a couple months, got rid of it. He didn't want any part of it. DD : Hmm. I wonder now that the, since the tannery closed, um, how that affects, you know, they're, they're not discharging in the same way that they used to 22 �PG: In Big Rapids they are <laugh>. DD : They have the boot making factory up there, don't they? PG: Yeah. They have asphalt lined retaining pods, retention pods DD : In Big Rapids? PG: Yeah. They have to, they have to pump it out and where they run it to, I don't know. Um, that would be a good story for MLive to look into <laugh> DD : Because, Yeah, go ahead. PG: It probably, they probably dump it somewhere around Big Rapids. So maybe on people's property that is abandoned, maybe probably the same scenario that they did here. They're just doing it up there now. It'd be impractical to haul it and it doesn't evaporate when it gets down to a, a certain level, it just becomes sludge and it doesn't evaporate after that very much. I don't know. Unless they have a lot of retention ponds and as it 'cause it rains, it, it becomes a liquid again. I don't know. Leather. Leatherette. It's a good idea. <laugh> the fake stuff. Actually that is still leather. It's a very thin coat of leather on top of a polyester. leatherette. It looks like leather. DD : Well, Paul, thank you so much for taking the time to share your stories today. PG: Thank you for listening. I think I got 'em all out too. It's that last one I totally forgot about the bucket. That was a good thing. That was when I first moved here, I saw that and thought to myself, why? This is weird. What are they doing, <laugh> DD : Yeah. And just cleaning the pipe PG: Cleaning the pipe. And they're dumping it. Sewage. I mean, if it's just sewage, it's bad enough. But it was from Wolverine and all the heaviest metals you could possibly imagine. Yeah. They didn't go down the pipe. There's not enough fall, not enough, you know, circulating. So they had to scoop 'em up. <laugh>. 23 �DD : That's wild. Well, thank you. PG: No, thank you. Oh gosh. <laugh>. Yes. I'm free <laugh>. 24 � 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 PFAS0042 Creator An entity primarily responsible for making the resource Golembiewski, Paul Date A point or period of time associated with an event in the lifecycle of the resource 2025-11-06 Title A name given to the resource Paul Golembiewski, 2025 (Interview video and transcript) Description An account of the resource Rockford resident and horticulturist Paul Golembiewski reflects on decades of living and working near the former Wolverine Worldwide tannery, sharing detailed observations of chemical dumping, environmental damage, and community health concerns tied 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) 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/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/516290f44ebb80dfc21b6a29c5948cc1.mp4 baf485936f0c641671916bc95b304ebc https://digitalcollections.library.gvsu.edu/files/original/90ad3f6ba6322588ccf7e474ef16ac32.pdf 92e5b6335948f8e007e8192f2702e78d PDF Text Text Living with PFAS Interviewee: Robert Delaney Interviewer: Dani DeVasto Date: August 1, 2025 Dani DeVasto (DD): All right, so I'm Dani DeVasto, and today, August 1st, 2025, I have the pleasure of chatting with Robert Delaney. Bob, can you, just to get us started, tell me a little bit about where you're from and where you currently live. Robert Delaney (RD) (00:00:39): Okay. I'm essentially from Michigan. My family moved quite a few times, but we were always within the state of Michigan. Most of my relatives were in the upper part of the lower Peninsula. Right now, we're living outside of outside of Lansing in a small village, small town called Potterville. DD (00:00:59): Alright. Thank you. How long have you been in the Lansing area? RD (00:01:06): Since 1979, I think. On and off we, we were a few years in France and a few years in, or one year in Colorado. Otherwise Michigan. DD (00:01:18): Okay. Bob, can you tell me a story about your experience with PFAS or PFAS in your community? RD (00:01:26): Sure. the PFAS my discovery of PFAS and what was happening in the state of Michigan and worldwide dramatically changed my career direction and my personal life really in many ways. And what happened was I was a project manager of the state's oversight of the US Air Force cleanup at the former Wurtsmith Air Force base that's up in Oscoda, Michigan. And it was a SAC base. In other words, it had the bombers that carried the nuclear weapons that were, well, the strategic bombers to protect us from nuclear war. They were a deterrent. Anyway, that that base closed in, I think it was 93, well, 95 might have been official year. And it was therefore part of the cleanup program for these major sites, it happened to be a Superfund site, EPA biggest site's most difficult ones that states weren't able to deal with on their own. And so I worked through a program where the Air Force paid for my services to help them follow our state laws as they cleaned up the project. And so during that time I oversaw the different technical consultants and all the, the grant work and all that. And, and handled the negotiations with the Air Force on this cleanup, well we were at the point where we had conquered, the Air Force had cleaned up, or we had a remedy in place for all what we consider the traditional contaminants, the chlorinated from the metals and oils and gasoline, that kind of stuff. We had, we've gone through virtually every site got have remedy in place. And I was starting to think about I need another, something else to work on. And I was praying in church one day and I said, God, I'd like to do something where I, I've never really used my intellect. This has been too easy. And and so I just, before I retired, I'd like to do something that really challenged me. Well, little did I know that within a month I would be down and at a conference and I would learn about PFAS chemicals, the firefighting foams the Air Force had well, the DOD had a, a session where they came in and told us about chemicals that were on the horizon of as potential problems. And it just so happened that while I was at that conference, my consultant calls me from Wurtsmith Air Force Base, and he says to me, we have this soil at at fire training area where we had been arguing with the Air �Force for years about the cleanup there. And they finally agreed to do what we told 'em they needed to do. And he calls and he says, Hey, they dug down in here 'cause they were installing the remedy. And he says There's a black soil horizon two foot down here. And that nobody told us, nobody knew anything about it. So that would change the potential for the effectiveness of the re remedy as is. And I said, okay, well grab three samples of this soil and send them to a lab and see if you can and analyze 'em for absolutely everything. 'cause We didn't know what they poured out there. And I said, and while you're at it, see if you can find a lab that can analyze for PFOA and PFOS. And so he said, so he found one in California and we sent it out to them. And it comes back with loaded with PFOS and PFOA, especially PFOS. 'cause It's a, it was a firefighting foam. And and I was surprised because they're essentially soaps, that's what they're used a lot as a soap. So I'm thinking they're, they should be all swept away outta that soil. And I won't get into the technical reason why they weren't, but they weren't all, there was a lot of 'em in that, those soil. So, so I said, well sample the groundwater. And then and then from this training I had gotten, I realized that there were all kinds of potential sources across the base. And so we started sampling across the base, all the surface waters soils. And every, absolutely every single sample came back with PFAS in it. Every one. I had never seen anything like it. And this is like four or five square miles of, of area that we're sampling and we're finding it everywhere. And we finally found one well, that didn't have any PFAS in it. DD (00:06:36): And did you decide to sample or test for it because of the conference? Or had you already started hearing about it before that conference? RD (00:06:43): I, I went back through my records and I had one message in 2008, two years earlier from a toxicologist that said you guys might think about PFOS or PFOA, you know this is something on the horizon. That was one of our lead toxicologists, but it wasn't on any of the stuff we worked on or knew and had no idea what it was. And at that point in time, there wasn't much literature even on it. And so I was shocked to find that we had, and I think we even mentioned it to the Air Force at the time, but I, it was just such a random thing. I totally slipped my mind. So it was because of that conference and just the uniqueness of the, the situation that we sampled for it. DD (00:07:26): And was it hard to find a lab at that time to test for it? Or was that not, RD (00:07:30): Well, I don't know. 'cause My tech, my my consultant does all the hard work. I just do the, you do this, you do that, and then he goes, do the hard, the hard work. DD (00:07:40): I see. Okay. RD (00:07:41): But yeah, it was, it was actually difficult because like, we went out the next year and sampled fish, and the only place that would analyze fish flesh was in Canada. So we had the whole cross border thing, and we had to figure out how to send a sample up there and stuff like that. So yeah. People weren't doing it. It was unusual. 'cause You know, there was no regulatory reason to sample for it. DD (00:08:06): Sure. So you started sampling and looking for it and finding it everywhere, except where you said one well, �RD (00:08:14): One, well, eventually we would find some other wells, you know? Yeah. That's just forest upgradient of the, of the Wurtsmith. So there, forest doesn't produce any PFAS. So it was yeah, it all came from, so it started at the base boundary, basically. DD (00:08:32): And what then? RD (00:08:34): Well this, the thing that really changed the direction was that my I went, I didn't know. I knew that these chemicals by this point were indestructible, essentially indestructible. And they also were ubiquitous. And so I went to our, went to the toxicologist in our department, the one that usually worked with me and asked him, can you come up with some criteria? Because that's how we operate. Something needs to have a criteria or some reason for you to try and regulate it. So he did a back of the envelope calculation, and he came up with a hundred parts per trillion as the cleanup, potential cleanup standard for PFOA and 60 parts per trillion for PFOS. Now, those words, those numbers, those words don't mean anything to anybody. But to me, in my line of work, if a contaminant was around a part per billion, which is a, an order of magni-, I don't wanna get into that too technical. But anyway, that's a lot, maybe a hundred times or a thousand times what we were eventually looking at for PFOS and PFOA as far as the criteria. So like, it's a thousand times maybe, or a hundred times higher. If I saw a chemical that was that bad, I thought, this is a really bad chemical. It's really dangerous. Then you back down into the parts per trillion. Well, there's only a few things that we worry about, you know, dioxins and mercury that we look at at that level. So here's a chemical that is on the level of a dioxin or mercury in people's systems. So that was pretty shocking. And then the kind of the weirdest other coincidence, there's a lot of weird coincidences. My son, we'd been told that they thought he was on the spectrum having Asperger's, and because of some of his and now he's, if he is, he's super high functioning. So, and I'm waiting until he becomes a billionaire, but he hasn't yet <laugh> Anyway. He so we my wife, you know, she's concerned and she knows that I want technical information. I do not want what some talking head says or whatever. I wanna understand something at a more base level. And so I started researching autism and what, how the brain worked and, and a lot of the things that go on, and it came to the realization that it was rising. And it's been rising since. Well, we know since 2000. So it's the last 25 years, it's gone up every year, the rate, and as I read about where autism was showing up, that, you know, I started realizing, okay, it's showing up in various areas in various subpopulations of the country at the same time, because my consultant had come to me and said, or my toxicologist had said, this contaminant is like super, super dangerous. And I said, okay, I've gotta go back to the military. We all think that we're almost done cleaning up Wurtsmith. Tens of millions of dollars have been spent, you know, 20 years or more have been spent on cleaning this place up. And I'm gonna have to go back and tell them that this is, we're just starting all over from scratch. So I didn't want to go to them. And <laugh>, I, I always joke, I always saw toxicologists as witch doctors. You know, when you want a criteria, they take some bones in the back room, throw 'em out on the floor, come up with a number and come out and tell you what that number is. And I'm a geologist, so I just follow whatever the toxicologist says. I had faith that they knew what they were doing. I'm just joking about the <laugh>, about them being witch doctors. But anyway, I decided, I want to know for sure if I, this is a dangerous chemical. Is this dangerous enough to go try and fight the Air Force? 'cause You, you know, you fight the Air Force, it's not a fair fight. So you had take it on with some, some intelligence. So I started doing a research on the toxicology of of PFOS and PFOA and the epidemiology. Where, where did it show up? What populations had higher concentrations? So as I'm reading these two sets of things, they're mirroring up. Like, autism was higher �in Minnesota. Well, who had the first widespread known PFOS contamination? It was Minnesota. And it's more common among rich people. Well, who gets new cars and new stuff, and it comes off electronics and stuff. Well, your carpets where they're covered in PFOS, your cookware, your fancy clothing, your floss, it's, and so the things that wealthy people did expose them more to PFOS than what the regular people did, you know? You go to Goodwill, that stuff's been washed outta that clothing by that time. You get it. And we don't change your carpeting probably as much. So anyway, then like, autism was higher among the military. Well, I already knew the military was drinking this stuff all over the place. Autism is higher in, along expressways within 300 feet of an expressway, or I think, no, 300 yards. I don't remember exactly. But if you look at where, where contamination non-point source contamination is, it's a lot of times along major freeways and stuff like that, because it's in diesel. There’s five systems in a, in a, in a diesel truck that de-gas. And, a lot of those fluids have PFOS in 'em. PFAS. So anyway, I'm getting, down rabbit holes. But, so anyway, I started thinking, well, maybe this is why autism's going up, because the use of this stuff has been going up dramatically through all this time. So I, I, there's, there's research being done on that now, but you know how it, is cause and effect, very hard to prove. So anyway, I just, for me, when I thought, oh my gosh. And I had, I was bouncing this off another one of our geniuses at the state, and I'm not kidding, he's a genius. And we were thinking, well, yeah, it's seemingly like this is the case. So anyway, I felt like literally I felt like I was standing at the edge of the abyss looking in that we were poisoning ourselves. And the more you read about diseases on the rise, the more you realize we're poisoning ourselves. And so to make a very long story short, <laugh>, I haven't made it short. But anyway that changed the, my motivation level to where I became super motivated that I had to do something about it. And it was not just deal with Air Force, but this was a, a reality that was way bigger than just the Air Force. And the Air Force and DOD actually proved to be a catalyst for people becoming aware of PFAS and, and the dangers. So it was really strategic. I was strategically placed because I was negotiating with the upper management of DOD on their environmental issues. And they were in a position to actually make a difference with our understanding of it and, and doing something about it. DD (00:16:59): Can you say more about how you, through DOD, were able to be a catalyst? RD (00:17:07): Sure. DD (00:17:07): From what you could see? RD (00:17:08): Okay. Well so, so many backstories. So anyway, I advised my management of, of this, at the end of 2010. I did a big slideshow, brought the toxicologists in and, and leaders of our division. And we went through all this. And then when this, and, and those were old time environmental leaders that were in that meeting, and they knew exactly what to do. 'cause They had already done the dioxins and the mercury and the variety of lead. And, and so they'd already gone through all this. And they recognized instantly the challenge that was there before us and what needed to be done. And so they set up immediate work group to work on on the toxicity and what we should be doing about these things. And we had some ideas. They were gonna test all the waters each year. The state tests a certain number of, of streams. So we were gonna do all this. And, and so there was, we, we started up gung-ho and then the Snyder administration came in and they stopped what the division and the department was doing. And and, and what they told what, I came back through the, through the grapevine. 'cause We asked our, our chairman chairperson of the group, why aren't we doing anything? Why aren't all these things we were supposed to do, we're not doing? And they said, well, the Snyder �administration had told our management is that if our management, DEQ's management, had made one more problem for business that we would be put outta business. And so obviously PFAS is a huge, huge problem for business. And not necessarily always because of their own fault. I mean, they didn't know, most of 'em didn't know. A few knew. So, so that kind of killed what was going on with the state, you know? Not until Rockford broke. Did, did anything happen with regard to PFOS, PFAS. But I was on these national committees working with the Department of Defense with EPA and with all the other states. And there I had carte blanche. My, I think my intermediate management said, yeah, you can go to any conference you want. You can speak to anything. They didn't say this to me personally, but every time I asked for, can I go do this, can I do that? They said, yeah. And so I went out and I would just tell the story of Wurtsmith, you know, and what was happening there. I didn't get into the toxicology or what I thought, you know, how bad it was or anything that, but and I, I talked to, well, in 2012, it was in Salt Lake City. RD (00:20:03): I told, told the defense department, they asked me to talk about contracting. And I said, well, you got a problem with your contracting. Because they were going to a method where you pay somebody to clean up a whole site and whatever was on that site, they were gonna clean it up. And they had to give you a price up front. The contractors had to say, alright, this is how much we're gonna do to clean this up. I said, you, you, yeah, you, there's a couple of problems with that. But anyway, they're gonna clean this up, but they don't know about PFAS or PFOS. And when the regulators come and say, Hey, you've got a problem, then there's no way they're going to have accounted for that in their costs. There's no way. 'cause It's about impossible to get rid of. It's terribly costly. So I said, so this is the demon in the closet, PFOS, PFAS, it's going to screw up your relationships, your, your contracting. RD (00:20:59): And it was from that point forward that I, I just started building, you know, building coalitions or you know, network of people that we were all concerned about it. And we, I, I you know, did issue papers for ASTSWMO, Association of State Waste and Manage Waste Management Operators. So it's a state organization that works with all the different states. That's where I was on the committees. Well, one of the places I was on the National committees was them. And so I would just go and I would just tell the story and you know, and find labs that I could work with and just people all over. And I got relationships with the media so I could feed the, you know, like InsideEPA from Washington would call me all the time to ask me what was going on with PFAS, PFOA. And so I was able to influence the nation and then within EGLE, or now called EGLE. But it was the Department of Environmental Quality at the time within that group, you know, all those peons, we all really cared about the people and the environment. And so, you know, word got out amongst us. And so when the Rockford thing broke, there were people that were already, were already knowledgeable about what was going on. DD (00:22:23): So you had initially been worried that bringing that information to the DOD about, Hey, we just finished cleaning up, but I just found this new thing that you need to think about. You were concerned. But it sounds like they, they kind of went with it, or No? How did they receive that information? RD (00:22:48): Well, it's the federal government. So <laugh>, what up here starts out as a shout, do this. And what actually gets at the bottom is two different things. Like they, the people at the bottom have no idea what's going on. You know, what the management really wants. And the people at the bottom can be shouting, and it gets muffled by the time it gets to the top. So, so there was this weird, I, because I was in acting at both levels, I could see the dynamic. So the person that was in charge of, at Wurtsmith, �he was anti-environmental. Anything environmental was bad in his worldview. And so they would do, they were doing nothing. And I knew they would do nothing. But what happened was we we went out and sampled the fish, like I mentioned, well, we sampled them in the AuSable River. And when we sampled in the AuSable River, the day that the data came back from the labs, this Canadian, this Canadian lab, the health department made an or, an order do not eat the fish in the AuSable River. Okay. So that had political resonance. Yeah. Is that right? All the way up to Washington. Suddenly Washington had a big PR crisis on their hands. And so they brought in outside people to deal with the situation and stuff. And so there was actually immediate action to control the contamination off that fire training area. And they built really the first DOD treatment system for PFOS or PFAS, anywhere that they had. and so, it was, so it just then, you know, just more and more information coming out, more of the waters are impacted people's drinking water's impacted, the on base water system was impacted. Uh, they, it became a political thing for both our state, you know, the governor's office and for DOD. And so that's why there was movement down at the bottom. There would never have been movement based, you know, from the, the local, local group. And so that's what I meant when it came to negotiating with those people. They, they, they are a law unto themselves at times when it comes to, what the president say. Well, I didn't hear it. You know? And, and so there's a kind of a weird dynamic, politically with the DOD. DD (00:25:43): Sure. And then you said too, that at that time, under Governor Snyder's administration, the state was also not pursuing... RD (00:25:55): Well, let's see...Well Snyder didn't come along until, well, he came along around. Yeah, that's true. He we were working on it. And, and Snyder administration, you know, they weren't stopping us from like we couldn't create criteria, or we couldn't, you know, start enforcing against anybody else. But they didn't care what we did to DOD essentially. So we were out pushing DOD, and and they were under Superfund. So Superfund doesn't necessarily need our criteria. Fortunately we didn't get surface water criteria long before we got a drinking water criteria. So we were, we were pushing that at 'em. 'cause They had a surface water, Because the treatment plants, they could regulate them under a different set of laws than what we were operating. Anyway, it was all lots of maneuvering. It was like I had a, when I wanted an intellectual challenge, that was it. I mean, they had to understand law toxicology, epidemiology to be able to talk to all these people. So, DD (00:27:04): Yeah. Can you tell me about the Delaney paper? I heard you wrote a paper. RD (00:27:12): Yeah. Myself and Richard DeGrandchamp professor out at Colorado University of Colorado. And that has another crazy backstory. But I, my, so I knew that PFOS what PFAS was a problem. 'cause My toxicologist had given me those criteria, and I'd started doing my own research. Okay. But my, my toxicologist was swamped. They were re-writing criteria and doing all kinds of things, and he just said, I, I can't support you. And the weirdest thing happened, another weird coincidence, but one day, one of the unit chiefs from the Superfund section comes over to me with a thing that had come across the fax machine. Somebody had done one of those, grab a fax numbers from all governmental offices and fax out an advertisement. And what it was, was a this toxicologist Richard DeGrandchamp was advertising, and they did, he did epidemiological and toxicological not studies, but research and what he did a lot was going, going to court as expert witnesses. So anyway, this, he was doing it on PCBs, and I think dioxins those two things. And she, so she brings it over to me, this unit chief, and says, well, you know, you might, you might be interested in this. And and so I say, oh, yeah, it sounds like it might be something interesting. Maybe this person can do some work �on PFAS. So I told my contractor, contact this contractor and subcontract him so we can, we can get to his expertise. And so we got him, and I remember meeting him at the airport, and he was just a, he was a classic professor type, corduroy coat, hat. And it was just all, it was just classic Indiana Jones. I kind of, all I thought of at the time. So he shows up and brilliant, brilliant man. And I have funny stories about him, if you ever want to hear any <laugh>. But he's a, he's a brilliant man and conscientious. And so I told him we, I got this problem. I got this PFAS stuff in the groundwater and the soils up at Wurtsmith. And I don't know if it's really dangerous or not. I didn't tell him that. I suspected it was super dangerous, that I had been doing the research. And and very much convinced that this was a, a very, very dangerous chemical. So I just say, will you go out, do the research, come back and advise me on what we should be doing about this? So he comes back to me and he tells me that this is really, really bad stuff. And he said, the studies in, West Virginia, Ohio area are, the gold standard for studies. You can't do a better study than this. And they say that this stuff is really dangerous, and, you know, it's almost better stuff than what the cigarette industry or the cigarettes were, you know, is that it was really good, good data and good information. So I say, okay, well, well, anyway, so that gave me direction on how to go with pursuing the, the military. But we had a new director come in. And the new director, it was funny, he, this is under Snyder, so this new director comes in, and he really wasn't, and he wasn't, didn't know much about environment. He was quite honest. He didn't know about, the environment. Uh, this is Dan Wyant. And he said he wanted to meet all of his 3000 employees, I think that was, so he had these meetings where you got to stand up and you had five minutes or something like that to tell him what you thought he should be working on or any, you could tell him anything. And he said, you could even tell him he didn't know what he was doing. So when it came my turn, I think I was the only state employee to do this, but I stood up and said, you don't know what you're doing. And then I launched into PFAS and PFOA See, in 2009 the European Union had already begun to regulate this stuff. And my director had never even heard of it. So this is 2011. My director hasn't heard of this, these chemicals, and yet they're that critical. Maybe it was 2012, I can't remember exactly what the date was. So I say to him, I'm gonna write you a report. And so I got myself and Richard DeGrandchamp wrote the, I think it was 95 pages. There's 96 page report on PFAS and PFOA, talking about the dangers, its distribution, its history. And one chapter, which turned out to be particularly inspired was what, what can the department do to address this? So it was, it was pretty, it was actually pretty funny. 'cause I always thought, well, I heard that. Don't bring a problem to your boss unless you got a solution. So this was a throw in, throw, throw in a chapter. I was just off the top of my head stuff, well, this is what we could do. We do this, we could do this, you know, or we should do. I never said we could. I said, we should do this. You know? And later that would be the kind of outline of what the state did. So it was kind of funny 'cause it was just off the top of my head to try and not, not do a faux pas and bring a problem without a solution. DD (00:33:21): I was impressed by that chapter or that part of the paper when I was reading through it. I was like, oh, they actually offered, like, some steps forward and some like very reasonable things. Like next steps. So I was very impressed when I read that part of it. RD (00:33:38): Yeah. That was the, that was the easiest part to read, write. 'cause I didn't have to really think hard. It just <laugh>. It just flowed. So it was funny. DD (00:33:45): And how, so once you had that paper written, how was it received? RD (00:33:50): Well I mean, it was received well, I, I had I had a good friend that was advising the, the director. And he was on, he was one of the, he and myself and the director had all met together. He, he �myself and another fellow that I have a lot of respect for was there as well. I can't remember his name. But anyway, they they received it well. The director was fairly interested in the autism thing. I hadn't mentioned autism, but he had ridden with my student assistant somewhere. And my student assistant was talking to him about autism and the link. I really didn't wanna talk about that 'cause I was a geologist. And this autism thing is just my, my my thing. I put it out on the web because I wanted to provoke conversation. So so anyway I didn't find out until later, but they distributed about 20 copies to other leaders in the, in the department. So, but that was in 2012. And it got lost after that. DD (00:34:58): Mm. Why do you think? RD (00:35:02): Well, it was, it was huge. And I mean, to me, it was like, to me, it radically changed my whole view of what we'd been doing. I thought that America had been making advances on contaminants that we had stopped putting out, you know, TSCA, RCRA ,all designed to stop us from doing this. And then I realized at that time that those, those were mirages, those were not doing, protecting us, that we were creating new problems. 'cause I thought, oh, we've stopped making new problems, and so suddenly here's a problem that is so huge that it's mind boggling trying to address it. And mostly, like a lot of reasons the DOD went and did some pretty positive things is they didn't realize how big it was and how expensive it was going to be. When it started dawning on them, how incredibly expensive and difficult this was. That's when you finally got push back at the top levels. Before that they were, they're most of the people, what, contrary to everybody's opinion nowadays, are really decent human beings. I mean, they're Americans. They're not like, they're not crazy people. They're Americans. They are honestly decent human beings. And yes, there are some bad ones up there, but wherever there's power or money, there will be bad people. You can't help that. But there were a lot of great people out there, and they wanted, like, one of the things I said in that 2012 meeting was I said, look, you guys have the young people in your ranks, the people that are gonna be having babies. It is critical for you to go out and find out and, and I didn't do it quite this dramatically, but it is critical for you to go out and find out if your people are drinking this water. So they literally went all around the globe and sampled every water supply that they had at their bases. And that becomes key at what happens in Rockford. And, and so if we get to Rockford, I'll tell you how, that became a key thing that made Rockford happen. DD (00:37:17): Can you just clarify one point, you said you put it out on the web, was that the autism information. Like did you have your own like, website or what? RD (00:37:27): The other person that I was working with is I'll just say Mark for right now 'cause I know if he wants his name out there. But Mark had a, a website for his business. And so we quick put it onto his business website, and for awhile it was the number one you put in PFAS and autism, it would be the number one paper that popped up. But, now, I don't know if you'd ever find it again, but still out there I think. DD (00:37:56): Wow. Thanks for that clarification. Okay. So how, so you're, you know, you're, sounds like you're working nationally. You're kind of, you've got kind of that perhaps unofficial carte blanche to do these conferences. Meanwhile, the state at some points is not really embracing this... RD (00:38:18): I gotta say like the health department was, and the surface water people, they were still going out and sampling fish. And they're still sampling the surface waters. So there was work being done at all the Defense department sites. So we're gathering information and there's this little pool of �information that's growing. But yeah, the department itself is, it's you know, we'd rather sweep this one under the rug. DD (00:38:43): So then how did you get connected in, or how did this get connected in with Rockford? RD (00:38:52): Oh, well, that is a, that I, I, like I mentioned in 2012, I had spoken, there was both, it was an Air force and Army conference, environmental conference with a small, um or they called it a summit. And I gave my little spiel and I told them, you guys, you know, you got these young people, you gotta go out and sample your water to make sure they're not drinking this stuff. So they literally, they didn't, they didn't check with me, but they went ahead and did that. And so they're sampling all around the globe. And that's where you, you find that suddenly the military has all these sites. And they were always mad and rightfully so. 'cause Everybody was saying, oh, the military's so horrible. They've contaminated everything. Well, the only difference was they sampled for it, nobody else did. So that, you know, they were really doing a great thing. Opening up the reality that this is super widespread problem. But, you know, they got whacked for, for doing it. But one of the last rounds they did were all these low risk sites. And it so happened that in Rockford there was a a facility that they had purchased, and its only function was to provide a place for the band to practice. Okay. And they never operated anything there. It was and they hadn't bought it that long ago. Well, when they sampled that water, it came back highly contaminated with PFOS, PFAS. And so they started investigating, you know, how is this possible? We know we didn't do this. You know, they reported it to the EGLE, the DEQ, whatever they were called then. And, and it, so that pointed back to, well, they were, they did weird things. The department, the, the people, first of all, the people that were responsible for doing the sampling, they, we don't know why, but they sampled down gradient instead of upgrade, or No, they sample, what did they do? They sampled either cross gradient or something to the groundwater flow. And then they didn't detect anything. And so they were trying to write it off as something, I don't know what, you know, nobody knows the full story of what was going going on with them. But anyway, they got called out eventually. 'cause They sampled, the, I don't know how it got tied back to the, the tannery, but it just, the investigation, I guess eventually got it back to the tannery. And, so it was because of that, because they found this high levels of contamination from a DOD site. And they know they hadn't done it that eventually was found out it was the tannery. And, and the other side note is that there's a friend, Janice, that had called me from, in 2000, I think it was 2011, that's when the emails are from, she called me and was talking to me about, contamination at the tannery. And I told her at the time, the thing that I said, she was worried about heavy metals because in tanning they used heavy metals. But, I said, wait, at the time, I said, well, you should have, you should be checking into PFAS. Because I had lived in Rockford, I knew about the tannery, and I knew they used Scotchgard on, on those shoes. And so, and the water tasted horrible. So <laugh>. Anyway, I told Janice, you guys need to be looking into the PFAS and see if they used Scotchgard and stuff. And so as Janice went through all the, all the files, from the tannery, she found evidence that they were using Scotchgard. And so, they were working from that end of things, from the public, trying to bring EPA in and, and various other things. You probably know Janice's story better than I do now. But, so those, those were the two things that were brought it together, DOD's discovery and, and that that group, fighting to have the place, that cleaned up properly. DD (00:43:32): And you knew that Scotchgard at that point had PFAS in it. RD (00:43:36): Yeah. In fact, in all my slideshows, when I talk about what, what's it in, Scotchgard is mentioned. �DD (00:43:42): Wow. That seems like two really lucky breaks in terms of putting that together. Right? Like these low risk band practice site, and, you know, Janice happens to contact you. Those are really tenuous threads RD (00:44:03): There are and as I've mentioned to you I have had a couple of supernatural experiences in my life. And this in total felt like one string of miracles. I mean, and I know I'm a scientist. Okay. I'm, I'm a I'm a skeptical personality type, and I don't expect anybody to believe it. But to me, the things that happened literally at, when I was sitting with upper management in our work groups at EGLE, and we were discussing, you know, we're gonna go out and sample all the water and all the systems in Michigan, I'm sitting here pinching myself. Like, this is unbelievable. This is like, I can't believe this is like a miracle. I never, I never thought in the world I could get, I would get them to do anything. You know, because the of the business angle, and if it hadn't been for Flint, Flint was also critical to what happened in PFAS because the, the, the governor could no longer look like he was ignoring environmental problems. He just didn't, he didn't, couldn't risk that. And so there was no political way of stopping what was going on. And so yeah, it was just crazy stuff just went on that, you know, when I was looking at that abyss, I was looking at it from the standpoint of there's a horrendous problem out here, and there is no way in the world it's ever gonna get addressed because we're going so far away. Even back then towards in the environment, it was, it was already an obvious thing that we were tired of caring about environmental things that was causing us problems with jobs or whatever. So I was thinking, there is no way we're gonna take on this. Like we took on the dioxins and, and the, and the lead and the mercury. And so to see what happened was, has been just amazing. DD (00:46:07): It sounds like your whole world became, at least work world became RD (00:46:10): Yeah. DD (00:46:11): PFAS RD (00:46:12): Yeah, I was just thinking this morning, my mom was the second one of the second leading experts on PFAS in Michigan. 'cause She would sit and listen to me when I ranted on and on about it. <Laugh> <laugh>. So yeah, it was, it, it became very very dominating in my life. DD (00:46:29): What what if any concerns do you have about PFAS now moving forward? RD (00:46:35): Well that, that anti-environmental spirit that has now gripped our nation, a lot of our nation is PFAS isn't the only environmental problem. We have so many diseases that are arising, not just autism and a lot of the autoimmune diseases, thyroid disease childhood cancers and diabetes. There are so many things hitting us all at once. And so it's not because we're all eating at McDonald's or some fast food place, that's not what's doing it because this is happening in other places around the globe that they don't have the same cultural behaviors that we do, and the same foods. And yet you'll find autism raising in you know, China and, and other places that don't, don't do what we do. And so there has to be an explanation for what's causing these real rates. Not just population trend changes. Like, you know, a lot of us are getting dementia while we're all getting older. The population get older. You expect dementia to increase, but you don't expect childhood cancers leukemia or something like that to increase. They're the same age, you know? So there are environmental things that are impacting us. And I've already, I've already seen rumblings of the Trump administration lowering the standards on, on �PFAS. And I don't, I haven't been able to verify this 'cause they just saw it yesterday. But there's even a move to to allow PFAS contaminated sludges from municipalities to be spread in farmland when they were trying, the Biden administration just apparently passed something that said, you can't put PFAS contaminated sludges on land, on farmland. And, you know, there's a, there's a business reason why, you know, tax and business reason to put that stuff on the land. RD (00:48:55): And that, again, I don't want to use this as a, a pun or whatever, but that's, that trumps protecting people's health right now at, at almost every turn. If it's perceived as bad for business, bad for American economy, real or not real. It is, is under attack. And so I see you know, I <laugh> it's almost suicidal. If people understood they were killing their children and their grandchildren, then I don't think this would be happening. Because like I say, I don't know if we can afford to clean up PFAS and stop it from getting into us, but I do know we cannot afford to poison our children. If you're doing your economic analysis, then what is the price of our children? What's their worth? So to me, it's mind boggling where we're at. So Yeah. I'm concerned. DD (00:50:04): Yeah. Sobering. RD (00:50:06): Yeah. Yep. DD (00:50:09): To say the least. Is there anything that you would want to add that we haven't touched on today or that you would want to go back to and say more about? Anything that's kind of bubbled up since we've been talking? RD (00:50:32): You know, the only thing I thought about is like what you're doing and what one of the things that was remarkable to me about the American system was the power of the media. You know, for all the garbage that the media puts out, they're also totally instrumental in counteracting the lies and the nonsense. If you want to know the truth, it's out there. And a lot of why I didn't get touch into what the media did with regard to helping the story here in Michigan and how they were so instrumental in, in in getting the, getting public awareness out there and making it impossible for the politicians to ignore. They were just so critical. And so it was, it was, it was great to see, you know, we had, we do have some important political and social things that have helped us. And that's what I'm more, almost more afraid of losing in this country now, is that with all the pressures that are going on towards I don't even blame people for being so thoroughly confused about what's true, but, but it is a scary thing. DD (00:51:53): Do you want to say anything more about media and PFAS and if you have any part of that story or...? RD (00:52:02): Well I'll tell you, there was a couple of people and that were critical. Garret Ellison and oh, drawing a blank on his name. This is a sign of old age. Steve Gruber Steve Gruber, he got me onto his show. When I broke the story, I think that's probably something I'd like to tell about is the, how, how Michigan actually became a leader nationally on PFAS and PFOA. And this is another one of those really crazy stories, but in the, in the Flint situation where they had the drinking water problem with the lead, and it was, it was caused by a bad decision to change water sources. There was a state employee that came to management and said, look at if we switch this water source from from Detroit to, or no, from whatever they were using in Flint to the Detroit water system, what's gonna happen is lead is gonna leach into the water. He told him, flat out, it's gonna be in everybody's water. That person was actually indicted by the Attorney General of Michigan, Bill Schuette. 'cause He, he needs to, he needs to hang or �not hang that this needs to be hung on him, that this, you did this. But he went after this this employee that was trying to warn people. And it, it was because his theory, from what I understand, was go after the little people and they will give you the big, big, big fish, which was John or not was Governor Snyder. 'cause He wanted Governor Snyder's job, basically. I guess. So he goes after all these small fry at the state and wrecks careers, hurts their lives, their families, all this because he wants to be governor, not because he wants the truth. So I was driving down the road one day when Rockford had broke. It was out in the news they'd find, they find the contamination all over the place. And I thought to myself, out of the blue, well, who knew about this first? Me. They're gonna go after me. And so I so I called my friend who's an attorney, and I say, Hey, can I meet with you? And we get together and I explain the situation. I explain why I'm concerned that I will be the next victim of this, this political war. And he takes my report home. 'cause I said, look it, I gave this report in 2012 to, to management. And he reads the thing and he comes back and, you know, after he's read it, the guy could read awfully fast, apparently. Anyway. And, you know, he's just really, he's blown away by it. And he, and so, so this is the amazing thing, Steve. This was on Wednesday. It turns out that Steve Gruber on his radio program here in Lansing, a talk radio in the morning. And he was talking on Thursday about what was happening in Rockford. And he's familiar with the Flint situation. And he says, somebody at DEQ had to know that this was out there. That this was a problem. And that's where I found out about the 20 copies that had been spread around. That somebody had read my report that was driving in to work at the state and they heard Gruber say this. And they call in and say, yeah, I saw this report report from this DeGrandchamp guy or whatever. And on Friday morning, Gruber is reading my report on the radio. This is a, I mean, that's how crazy this is. So Wednesday, Thursday, Friday. DD (00:56:17): Are you hearing this on the radio? RD (00:56:19): No, I didn't know anything about this. This is, this is this is just, this is what's so funny. So I, and I don't know how, I don't know how my attorney found out. My attorney found, my attorney turned out to be friends with Gruber. Okay. So another weird connection. But, so my attorney has this contact in the attorney general's office. And so he contacts this Attorney general and says, Hey, I got this guy that knows all about this PFAS stuff, and he's willing to come in and talk to you and give you everything he's got for immunity. So, well, Sunday or Monday, Sunday I think it is, I, we get back an offer from the Attorney General's office. And what they offered me was the deal they offer to mobsters, if you, we will, we will not con not prosecute you if you tell us every bad thing you did and everything, all your information, and if you hold anything back, we can come after you for that. Okay. So there's assumption that I did something wrong or bad in this and that. And so I said, I'm not signing that. So my attorney gets together with some some judges and some other attorneys. We all meet together on Monday evening and the decision is made that I need to get my story out before the attorney general comes after me 'cause then there's a, like gag order on you and whatever. And so that's where it comes out to me that Gruber has been talking about me and <laugh>. And so they set up an interview for Wednesday morning. So this is within a week. Wednesday morning I go on, I take time off from work, get it cleared so I can't get me for moonlighting or whatever. I don't know. Anyway, so I go on radio and we talk for two hours about the report and, and stuff. And you know, other co coworkers or people in the governor's office driving in listening to Gruber, hear my, what I'm saying on, on the radio about Yeah, they knew about it in 2012. And you know, this is the report. And, and so many of the questions you asked that kind of stuff too, was being asked. RD (00:58:37): And so it was really a tremendous relief to me because I felt like I've got all the, I'm so concerned about this stuff and I can't get the communication out. And so from there as one person said, �well, your attorneys made you prosecution proof that nobody can come after you. And but anyways, really, I knew I didn't really want to do it because, you know, it would be perceived as betrayal to the department. And, and so my career got, got whacked. But the nice thing about civil services, they can't fire you for telling the truth. Or they might be able to, but they're not supposed to <laugh>. So I, I knew they could make my my life miserable, but firing me would've been a, was a huge problem. Yeah. So they did make it kind of uncomfortable, but other than that, it wasn't bad. DD (00:59:29): That sounds like a really stressful week-ish. RD (00:59:33): I was under well on the stress belt too. Because you know, I no longer, well, I know I no long, I always felt like I was part of a team. And and that of course had been breaking down because of our division was headed in all the wrong direction. But then it got really bad. So they had one other person supposed to be spying on me, and all this other junk was going on. So it was stressful. But every morning I'd get up and I have my quiet time and I, I survived it all. My doctor gave me some pills to keep my blood pressure down. DD (01:00:15): And then from that point on was, I know you're saying the department was changing and like your role changed and things like that. So then was PFAS less a part of your life and your work? RD (01:00:32): You know what, well, what happened was the Air Force went after me trying to get me fired. And my division chief, she at one point was trying to get me fired. And and what they were doing was micromanaging me and they were making it so I couldn't give my, I give instructions to my my consultants. My consultants wouldn't do anything. And then they put another person that was supposed to be helping me, but rather was the one that was truly being made the project manager. 'cause They couldn't really take me off the site. They couldn't make it look like they were punishing me or anything. So they left me in position, but then took, stripped my abilities to do anything. And wasted my time basically. But I kept working on the outside on, on the issues, so DD (01:01:28): Yeah. Are you still working outside? I know you're retired now, but, RD (01:01:34): Well, I did a lot of volunteer work, but because of family issues I had been pulling away and just too much stress. So I have pulling away from doing much of anything anymore right now. So, but I was doing a lot of consulting on the side for, for free. You know, I was just helping out with the communities and still those kind of things, but I'm pretty tired. DD (01:02:05): You wanted to use your intellect... RD (01:02:08): Yeah. <Laugh> I did. Yeah. DD (01:02:10): Oh my goodness. Okay. I'll ask it again. Is there anything else that you wanna add or go back to before we wrap up? RD (01:02:19): There's a lot of wonderful people out there in the world. A lot of great people. I wish Americans could realize that even the people on the other side are not such bad people. But that's, that's relates to everything, not just PFAS. DD (01:02:35): Well, thank you so much, Bob, for taking the time to share your story with me today. �RD (01:02:40): Oh, it was a pleasure. I haven't thought about it much lately, but it was fun. � 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 PFAS0040 Creator An entity primarily responsible for making the resource Delaney, Robert Date A point or period of time associated with an event in the lifecycle of the resource 2025-08-01 Title A name given to the resource Robert Delaney, 2025 (Interview video and transcript) Description An account of the resource Robert Delaney, a former Michigan Department of Environmental Quality project manager, became one of the first in the state to identify and investigate widespread PFAS contamination. His work at Wurtsmith Air Force Base in Oscoda and later statewide helped bring public, governmental, and national attention to PFAS risks, despite facing political pushback. 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/b5c54c29d9bd0dde27d330f89d732d07.mp4 9adc279610ce2a47a044b44769a8783e https://digitalcollections.library.gvsu.edu/files/original/0ae3455606e94ca69f92985f702e6989.pdf a5c8375ec745f4152b9b1b19aa6e8887 PDF Text Text Living with PFAS Interviewee: Colleen Linn Interviewer: Dani DeVasto Date: April 30, 2025 Dani DeVasto (DD): I'm Dani DeVasto, and today, April 30th, 2025, I have the pleasure of chatting with Colleen Linn. Hi, Colleen. CL: Hey, how's it going? DD: Great. I'm so glad to have you here and talk with you today. CL: Yeah, thanks for having me. DD: Colleen, can you tell me about where you're from and where you currently live? CL: Yeah, I grew up in the Upper Peninsula, Michigan, in the Houghton-Hancock area, so that's in the left thumb of the state, if you will. And I'm currently in the metro Detroit area, southeast Michigan, attending Wayne State University in Detroit. DD: And how long have you been in the metro Detroit area? CL: Since about 2016. That's when I started the master's in anthropology program that year. So I've been in graduate school the entire time I've been in the Detroit area. (0:52) All right. DD (00:58): Colleen, can you tell me a story about your experience with PFAS or with PFAS in your community? CL: (01:01) So I really got into looking at PFAS from the perspective of a researcher. It became a huge topic in Michigan at the same time that I was trying to figure out what to do in my dissertation research specifically. And I was originally interested in drinking water issues. And so when everything started coming out about PFAS, those two very much so overlapped. And it was a topic that the state kind of took in full, especially after the Flint water crisis, which is a place, which is an issue that I also had been doing research on. So it was really curious to me that there's this other drinking water crisis that kind of came out in the state. And at the same time, I was working with some folks at Wayne State, working on an interdisciplinary research project. And one of my colleagues in that capacity was interested in groundwater issues. So we were trying to figure out an interdisciplinary project to work on together that combined all of our expertises between engineering, pharmacology, and anthropology. And groundwater contamination kind of is able to capture a lot of those, all of those together at once. So when I started formulating my dissertation research plan, it seemed kind of like the natural progression. �But since starting it, I've been thinking about it in the context of like other chemical issues. Because once you start talking about PFAS with other researchers, they constantly refer to the other types of chemical issues that they've worked on before too, like PCBs and mercury and VOCs and microplastics, things like that. So as I started my dissertation research, I was kind of approaching PFAS as like a way to think about how we deal with chemical exposure in general, and also how it relates to these other kinds of chemical problems. So I don't know if that's a story specifically, but that's how I got into the dissertation research and what I wanted to do, to do my work on and kind of how I started thinking about it, but yeah. DD: One follow-up question, were you aware then of PFAS before you started your dissertation or much before you started your dissertation research? (3:16) CL: Barely. Yeah. Just barely before I started that. Um, yeah. DD: But just it coming up in the news was kind of how you started learning about it? CL: Yeah. Because I heard the stories from West Michigan specifically that there was, and it was so quickly after Flint, it was like, well, what is this happening all of a sudden? I think it was the idea that, or a strange idea to have so many drinking water crisis in a state, with so much freshwater resources, that really, that issue really does not compute with me, especially having grown up in the Keweenaw next to Lake Superior. So my perception of water is just like everlasting and never ending and always accessible and always there, always present. So the idea that people wouldn't have access to clean water, like it just does not compute. It does not work in my head. DD: And then you moved down to Detroit and you're hearing all these new stories. CL: Yeah. All these different stories. And Flint was such a specific case. And then of course, the Detroit water shutoffs too, which came, which kind of like escalated, was escalating in the early 2010s and had continued up until the pandemic as well. So all these different ways that we were managing water just became clear that, you know, it's not about the presence of water, but how water is managed, you know, from a political standpoint and a social standpoint that really contributes to how people are able to access it and use it and the safety and affordability of that and at that too. DD (04:49) : Yeah. Would you be willing to tell us more about your research? CL: Yeah. So I, what did I do? I traveled to three different sites in Michigan and my goal was to connect with private well users who were impacted by PFAS specifically and talk to them about their kind of household experiences with having, you know, basically a letter from the state saying that they're drinking, their well water is unsafe. You know, how do people �process that and how do people adapt to that? And then I also wanted to connect with those kind of working in the state governance capacity to kind of work on the issue. And that includes local government officials and state government officials. You know, how are they helping households and how are they also like in the community and environmental context to try and fix the issue if there are solutions possible for these different parts of groundwater contamination. And then also the community activism, because that includes folks who weren't directly impacted by a well water, but they were still concerned about this issue in their community broadly. So it works to connect with all those different stakeholders in three different sites across Michigan and conducted interviews, did some door to door canvassing to get kind of like a neighborhood perspective. I did these in Rockford and Grayling and then in Hawley, Michigan, which have very different experiences with PFAS. And that was another part of what I wanted to understand was how the state approaches different pollution scenarios. And so Rockford represented a corporate polluter, Grayling represented a military polluter, and then Hawley represented a kind of an quote unquote orphaned site who didn't have a direct owner. And they had less people directly impacted by the PFAS contamination, but still like this like historical dump site that just hadn't been cleaned up. And so that affected social land orders and land owners in the immediate vicinity, their experiences with their environment. So all this was done for a comparative context to see just like kind of like the energy and the work that it takes for a community to be able to like effectively respond to groundwater contamination, which not only affects drinking water, but like recreational, environmental resources and just the idea of water resources into the future. Because there's always this concern with groundwater that maybe it's not affecting you now, but it's going to affect you soon if, you know, things travel a certain way. It's such a difficult substance to predict and track because everything is underground. And so anthropologists love that kind of stuff. Like, how can we know what we what we can't necessarily physically see? How do we how do we map that? How do we model that? And how do how do kind of different social groups make sense of it when they when they can't know certain things? Because that's where that, you know, our cultural ideas come in is when we the gap between our ability to know and what we what we know. DD: So I know that the research is still sort of in progress and we should all go read your dissertation and anything that gets published from it once that's done. Do you have any, like, initial findings or conclusions that you're drawing from your research that you'd be willing to share with us or lessons learned or? �CL (8:14): Yeah, I think the uncertainty that comes with folks having to deal with this was really prominent throughout everything, but then also just the I think what what I was noticing specifically was just the the complications that it came up with, like health care, like conversations with health care professionals and just the need to focus on health care access in general. When we're talking about not just PFAS, but just all kinds of chemical exposures, it became very difficult to not understand PFAS in relation to other types of of chemical issues. But having that like health care access seemed like a way to kind of address it like the end point instead of focusing on the prevention and exposure, which is which is super important. But since there's like already all these exposures, how are we, you know, how are people able to access those resources? And then also just the necessity of having multiple actors across scales, like in alliance of values to make anything happen. You know, you can have support from the state and you can have support from local officials. But if you don't have that citizen component, things don't go as far as they could. And then also, if you have that citizen component and that state component, but not that local governance component, there's also going to be like a, you know, kind of a break in the road and how things are able to kind of get done. And that's really tricky to do. And that's really dependent on the capacity of municipalities, of water treatment departments and also just cost. You know, there's a lot of stuff, environmental pollution issues that get tied up in legal stuff. And that is dealt with in a very like case by case basis. And hopefully, you know, those cases set precedent for other communities. But it's really hard to have like one community’s success expand to to other areas as well, if that makes sense. So that alliance of values, I think, is a specific one that I'm working on fleshing out at the moment. DD: Wow. CL: Yeah. DD: It's a lot. CL: Yeah. It’s a…yeah. DD: Tell me about any concerns, if any, that you have about PFAS contamination moving forward, either for you personally or like as a researcher thinking about these questions about, you know, how states approach and communicate these kinds of issues? Do you have any concerns about PFAS contamination moving forward? CL (10:55): I do. Alongside kind of the other major global issues, I think my biggest concern is things like this not receiving the attention that it was, you know, a couple of years ago. Changes in administration affect how certain issues are dealt with, including PFAS. So because it's such a big problem, such an expensive problem, I worry about it being �normalized, the exposure being normalized and people not taking it seriously over time because they don't feel that they can escape, you know, not just being exposed to PFAS, but other other types of chemical issues as well. So like VOCs especially. So that's so I think awareness and communication like public health education and just general community awareness is is a big concern of mine. But I think Michigan has been setting a lot of precedent for that. So and then I think it's just the funding thing again, municipal water departments are, you know, without, you know, staff funding expertise in a lot of places to to to retrofit their infrastructures. So it's kind of like we have to go back to, you know, when we first initial initially built our our water infrastructure kind of like system and we're in this place where we need to to update everything that was done, you know, 80 years ago, 100 years ago. And that's a huge task. So but and I, you know, once people know about it, they they want to be able to find the tools to to fix it. But when there's an absence of those resources, you know, I just worry it gets it like slips through the cracks, if you will. I hope that made sense. DD: Yes, I mean, funding is funding is a huge component of addressing this and being able to address it. And when you don't have it or you have other issues, it is easy for something like this to become normalized and fall through the cracks, especially when it's, you know, showing up as being everywhere. CL (13:03): Yeah, yeah. And I think something that should always be said is, you know, how are we using chemicals and, you know, in our society in general? I think that was the hardest thing to really get answers about was just like the manufacturing use of it and kind of like it's used in the corporate corporate industries. So I think transparency there, like, I don't know. That was the one thing like I just don't know how to like I can talk about the governance side of things and like, you know, critique it to, you know, whatever ends. But that there's a lot of like corporate obfuscation, if you will, and just opaqueness and how it's used. And I don't know how to address that. But I have a feeling that's going to continue. And that's where a lot of these exposure possibilities kind of remain. DD: I just had another question that kind of goes back a little bit more to your research. Speaking of, you know, not always remembering the questions right away. You mentioned that, you know, a big part of the research was thinking about (14:05) the process or like trying to better understand people's reactions when they get these kinds (14:10) of water notices and just like that, that process, that reaction, like, like just looking at kind of that whole scenario. Am I understanding that correctly? CL: Yeah. �DD: So I just was curious if you would say more about that. Like, what did you I'm just curious, what did like what did you find? Like, how did how are people responding to that? And how, you know, I don't know anything around like what did you notice about that part of it? CL (14:35): Yeah, I think they were very individualized responses, which kind of tracks against kind of the individualized nature of well water management in the first place. From my my sample size, it wasn't enough to kind of understand like a very specific pattern. But, you know, a lot of people, people who were, you know, they were, you know, they were there were certain people who could be very pragmatic and they could just, you know, call the call the county and get the water filter that they needed to to get to reduce PFAS exposure. And they got it installed and they just never really thought about it again. For others, that process was a lot trickier. And so it became, you know, a question of of procuring enough like bottled water resources in the meantime until they could figure out how to implement that. And for others, they just it was just like another piece of paper on their counter that they never really looked at again or were concerned about, or it was just, you know, the thing on the list of to do on a person's to do list that you just couldn't really like get around, get around to because everyone is is working and overloaded and, you know, in many different capacities. So the range of reactions was kind of surprising because it was very clear that the toxicity issue, like the the the risk of being exposed, I felt like that that part of it wasn't always communicated the most clearly. I think there was a there was a gap in that specifically. And it became more challenging, especially when I met, you know, I met people who were not affected. You know, they had a slight detection in their well. They didn't do anything to their water. A lot of people had like the habit of drinking bottled water anyway, so they weren't necessarily concerned about the water coming out of their faucets. They weren't using that for their personal consumption anyways. But there are some people who are very severely affected to, I think, an unimaginable degree to the folks that, you know, weren't affected in the same capacity. And so it was just it was just so much a lot of up and down, if you will. And so it's like, how do you take the person's experience who, you know, lost a loved one who's dealing with a very serious health effect and then have somebody be so apathetic about it? That was that was difficult to kind of make sense of, but it really was a wide range of experiences. (17:01) And I think it kind of reflects that that individual nature of well water use where you're not always talking to someone else about it because your well is your well. And so somebody else's well is a different context. You know, stories about people who their well water was testing very high price for trillion and their neighbors were not detected. You know, that was there's just such a variance of pattern. That's why I think the original testing that was done in Rockford in 2017, those folks who were who had �contamination very early on had a point of connection because, you know, we didn't necessarily know what to do about it. I think as the kind of response became a little bit more standardized and regulated, those points of connections weren't as prominent because they had that intermediary of the state. And so they were just it became a very one directional transaction instead of understanding what it was like at a community level. And of course, there's, you know, variances of this. But, yeah. DD: Well, it's so interesting to be able to think about it like over time and as because PFAS is kind of still in some ways an unfolding, emerging situation, right? To think about how that response was handled and received in the beginning versus, you know, like, as you said, once the once the kind of state response became more codified, perhaps, or like the process for handling and responding to it. It's so interesting. CL: Yeah. Yeah. There's a huge difference there between 2017 because I talked to a few folks who were (18:44) part of that. But then the newer identification in Rockford area in 2023 was tied back to Wolverine headquarters. And so just much different. Those are the same two neighborhoods of multiple people in those neighborhoods and very different experiences and kind of levels of engagement with it. And more limited options because the lawsuit had already been filed and settled. And so Wolverine's responsibility was, you know, kind of already decided upon. And then another instance kind of came up and they couldn't quite directly prove. And just the ability to not quite directly prove something and not having the reasons for the lawsuit results in a different household experience of this. DD: That's fascinating. Wow. I was just thinking about how many how many variables there are. Right? As you said, the resources, finances, you know, time, people's own knowledge and just…Wow. CL: It’s one chemical. (19:52) And we think like, I think one chemical class, you know, should maybe experiences are more uniform. But no, it's it's it's it's very, varied DD: Yeah. Wow. Before we wrap up today, do you is there anything else that you'd like to add that we haven't touched on or anything that you want to go back to and say more about? CL: Um, there is a specific thing. It's, um. I think that this idea of chemical exposure and how people are affected by it. Actually, the experience with this helped me reflect more on what happened to my grandfather specifically. (20:35) He passed away by senior year of high school from mesothelioma, which is from asbestos exposure. And just on a personal level, it was interesting to kind of revisit and rethink about what happened to him, because I think at the time being like a senior in high school and not really understanding, just understanding that, you know, your grandparents get, you know, they age and they get �older. But I think the the randomness of the PFAS experience and hearing people, you know, what happened to their loved ones, I kind of re-reflected on on what happened to other people that I knew, basically, to understand, you know, why certain why or how different health health issues are managed later in life. So it became a very personal, self-reflective project because of that as well. DD: I can imagine. (21:28) I mean, as you said in the beginning, conversations about PFAS were naturally kind of lending themselves to also conversations about other kinds of chemical exposures and certainly water-based ones like lead. But I can definitely see how like something like asbestos would again kind of fit into that and allow for that kind of reflection and comparison. CL (21:53): Yeah, yeah. It's made me wonder how we how we how we approach all these issues. They're so segmented by type, but I'm just wondering how do we how do we approach them not necessarily by type, but just by by experience and by like health outcome, if you will, instead. DD: Yeah, I often hear people talking about how, you know, pulling lessons from other ways that we've we've handled lead or PCBs or things like that. Like, can we pull lessons from those in order to think about how we deal with exposures moving forward or the defenses of like, well, this is that's this and this is that and they don't compute. (22:42) CL: Yeah, yeah. DD: Well, thank you so much, Colleen, for taking the time to share your story and your research today. I really appreciate it. Yeah, thanks so much for having me. It was great talking with you. � 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 PFAS0039 Creator An entity primarily responsible for making the resource Linn, Colleen Date A point or period of time associated with an event in the lifecycle of the resource 2025-04-30 Title A name given to the resource Colleen Linn, 2025 (Interview video and transcript) Description An account of the resource In this interview, Dani and Colleen discussed Colleen's research on PFAS in Michigan, focusing on how private well users and communities respond to water safety issues. Colleen's research also led her to reconsider her grandfather's experience with asbestos exposure, highlighting the broader implications of chemical exposure studies. 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/5babbe2a3f22da4b1f105c7b7c2cfc2f.mp4 69db2c20acf6e76f06521bd567a8bc9b https://digitalcollections.library.gvsu.edu/files/original/f814d527f47259f9230520cb52a3a489.pdf 3daf04fb5734351148a390a3a72f83b8 PDF Text Text Living with PFAS Interviewee: Tom Konecsni Interviewer: Dani DeVasto Date: May 18, 2023 DD (00:02): All right. Uh, I'm Dani DeVasto and today, May 18th, 2023. I have the pleasure of chatting with Tom, an individual who has been impacted by PFAS. Can you tell me about where you're from and where you currently live? TK (00:26): Yes. I, I currently live in, in the west Wolven area of Rockford, and I've been here, um, going on 16 years. DD (00:37): Great. TK (00:38): Prior to that, um, different states, uh, 23 years in Southern California. Um, couple years in Dallas, Fort Worth in Austin, Philadelphia, four years, and then, uh, Cleveland, Ohio, eight years. DD (00:58): Oh, you've really been in a lot of different places. TK (01:02): <laugh>. Yes. It was driven from, you know, childhood moves to, uh, young adult adulthood in southern California. DD (01:14): Awesome. Thank you. Can you tell me a story about your experience with PFAS or with PFAS in your community? TK (01:24): Yeah, and I'll, I'll start with, um, how, how I even came upon, you know, PFAS and that was, uh, in the, oh, I think the summertime of, uh, or the spring summertime of, um, 2010. I was driving my kids to school one day and I noticed a cloud of dust and particulate coming from the, uh, the tannery. And I looked over and they have a, a security fence around the property. And, uh, I noticed, uh, Pitch and Rockford were demoing the buildings. Pitch, being the demo, and Rockford doing the, the, the, the construction work. So there was a general, and I believe a sub on that job site. And while I was looking, um, I, I noticed that the buildings that were being knocked down were very old, and the dust being emitted and the cloud that was being generated from all the demolition activities was being blown into the neighborhoods and, uh, the local school. TK (02:40): 1 �So I, um, um, was concerned about that because I, I, at the time with my background, I believed that the buildings contained, you know, asbestos and lead and other chemicals, and I didn't like the fact that it was going beyond the, the property line. So I went to a public hearing at, at the high school, uh, a couple weeks later just to try to understand what was going on. And, uh, uh, a lot of the parties were present from, uh, Wolverine executives to the law, you know, the, the law law firm that was, um, um, that was hired basically to help them out through any legal matters. And then, uh, which was Rose & Westra, and then I believe GZA was there, and then city council, Mayor Michael Young and, and some other staff. And the presentation was basically trying to, um, soothe or, um, calm, calm people's concerns and fears of what was happening at the site, um, stating, um, situations or their facts of the contaminants that are, are there, aren't harmful. TK (04:08): And, you know, you'd have to drink a, an Olympic sized pool, you know, every day for 10 years to be affected by it. And with my environmental safety health background, when it became, um, question and answer period, I raised my hand and I, you know, I said, well, you know, that's not totally accurate because, you know, 23 of my career years, uh, or my career was in Southern Cal, and they have the toughest environmental regs in the country. And I said, you know, especially with lead, if you're six years or younger or 65 and older, you want zero in your blood. So, you know, there is no such thing as drinking an Olympic size pool and not be affected by, you know, lead and, uh, with the Flint problem, and, you know, this and that going on. Uh, that was just one of my concerns. TK (05:00): So when I stated that, um, the, uh, concerned Citizens Group at the time that was formed approached me and wondered if I could help them out, you know, with, with, um, their research into what's going on with, with that activity at the tannery and, um, the companies I worked for and me being in, in the, uh, Rockford school system and the stories that I was told with, um, certain intimidations going on with, uh, individuals in the, um, concerned Citizens Group and, and, and other people, uh, I wanted to be anonymous. And, uh, I chose to be that way for quite some time, um, until now. And, uh, uh, after some research and FOI-ng information, we were getting, um, a lot of, oh, excuses that it's a hardship to find this paperwork. Uh, you know, we don't have safety data sheets 'cause the building's been knocked down and, you know, it's required by regulation. TK (06:13): You have to have 'em for 30 years and or, you know, um, or even if you, you transfer ownership, that new ownership should need to, has to have them. Same with has waste manifest. And because we were getting, um, just a lot of, uh, no's from them or basically, um, obstacles in our way to get this information, uh, you know, more and more research was being done until we did get information that we needed so that we could present our findings to E uh, DEQ at the time, which is now Eagle, um, and presented to a Cadillac, which is the enforcement branch of it. Um, a few years went by where they were interested, but nothing was being done. And then we ended up, uh, going to Chicago and, uh, getting the interest of EPA Region five involved in 2017/18, where, um, the hand was forced, you know, to clean up the tannery and the House Street, um, sites where samples were taken and obviously high levels were found at House Street, a, a as well as the Rogue River in, in Rum Creek. And since then, I've been part of the monthly, um, community awareness group, Wolverine CAG, and, um, continue to, you know, just make sure things are being done right, you know, for the community and, and, uh, you know, all affected parties that come to Rockford, whether it's for entertainment or business or they're just living here. 2 �DD (08:00): Mm-Hmm. <affirmative>, just for folks who might not be familiar, can you explain what a haz waste manifest is? TK (08:11): Yeah. Um, with anytime you have a, they call it a RCRA waste, which is a Resource Conservation Recovery Act, um, that was put together many, many decades ago, um, in the eighties, if you're on this list or if you have any of the characteristics of a hazardous waste, like if it's ignitable toxic, corrosive reactive, uh, there's definitions for that, then, um, it's, it's considered a RCRA waste and then it has to go to an approved treatment storage disposal facility where they either treat it, store it, or dispose of it. It could be just a landfill. And, um, you know, a lot of the toxic chemicals, reactive chemicals, ignitable, you know, those are, um, uh, you know, high risk, uh, that could cause immediately dangers to life and health situations if it's not, uh, monitored and, uh, handled properly. DD (09:16): Thank you. So you, you mentioned that when you, um, were first noticing the building being demolished, you were concerned about other hazardous, potentially hazardous substances like asbestos. Um, did, were you aware of PFAS at that time or when, like when did, when did PFAS kind of enter your, your world? TK (09:38): When, um, safety data sheets were, um, um, were looked at and reviewed, that's when the compound came up with Scotch Guard. So at the time, you know, and that was several years, um, after, um, getting Wolverine to try to do the right thing to clean up the site. So that was, uh, when I first got involved was the immediate aspects of, um, asbestos, you know, uh, particulate or, or dust, and then, um, you know, lead, lead as well. So that's what initiated, uh, my interest in, you know, trying to figure out, Hey, what, what, what's happening? There's contamination in the river, in the land, in the air, just from those two substances alone, hazardous substances. Mm-Hmm, DD (10:37): <affirmative> TK (10:39): Or materials or waste, but that they're called different, um, you know, different names based on the regulation that follows 'em. So you have OSHA that regulates asbestos, EPA, DOT, same with lead. DD (11:02): All right. It sounds like it was, um, a good thing that they, that they were able to get you in on the Concerned Citizens Group. <laugh> sounds like your your knowledge of, of environmental safety regulations and policies would be particularly useful. TK (11:22): Yes. Yes. And, uh, you know, it, it helped, you know, steer the path of, you know, where things are at currently to try to remediate, you know, the both sites, the tannery site as well as House Street. 3 �DD (11:38): And when you started seeing PFAS showing up on those, um, safety sheets, were you familiar with that concept or with that, with the class of chemicals? TK (11:49): I, I, I, I knew about it, but I had to do research on it. Um, I've heard it, but I didn't really know the toxicity of it, you know, until, until I did some research on it. I, I knew it was, you know, a water repellent that's, that they have for, you know, Teflon pans. It's a, it's a, it's a great, you know, chemical, so is asbestos, you know, a mineral. It's got a high tensile strength. It's was used in a lot of things, and it's still used in some brake pads today. So, um, you know, things could be chemicals, hazardous substance materials can be handled, but they need to be handled safely, you know, write PPE disposed of properly. You know, you could, you could do things, but you need to have procedures in place, you know, and, and follow them and enforce them. That's why they're there, you know? Mm-Hmm. DD (12:47): <affirmative>, yeah. What concerns do you have about PFAS contamination moving forward, if any? TK (12:56): Um, just that, uh, it's the forever chemical and, uh, you know, the concentrations that are, you know, currently in the Rogue, um, that, that goes to the Grand River, the Grand River goes to Lake Michigan and so on, so forth. Um, will it ever get to be a, a level that's safe, you know, for not only drinking, but you know, the general public, just recreational activities, boating, kayaking. So, um, I, you know, that's, that's a concern. You know what, since the science is somewhat new, and since health studies are new, considering studies on other chemicals that have been around for decades, um, it's evolving. And, you know, we don't know the exact, um, effects 10, 20, 30 years from now from, you know, PFAS in your blood, you know, at high levels. So, um, you know, will it lead to more cancers or, you know, other illnesses, you know, uh, for, for being in your body, you know, for a duration of time. DD (14:14): Yeah. So some of those really long, the unknown of the long term. TK (14:19): Yep. Yeah. The acute effects would be short term, you know, are are there acute effects, you know, possibly, you know, possibly if you consider getting cancer, you know, in a short period of time. Uh, but it's the long term that I, I think isn't, um, the science isn't out for that yet. But, you know, I'm not a toxicologist, so I can't, you know, verify that. DD (14:49): Fair enough. Uh, is there anything that you would want to add that we haven't touched on today, or anything that you want to go back to in what you've already said that you'd like to say more about? TK (15:05): Um, lemme think. No, other than, you know, it's been a long, long journey, you know, to see where things first started, to where everything has ended. I mean, there's, uh, you know, details on how information was, uh, received and gathered and, and put together and, and, uh, you know, that those 4 �aspects, um, I may come back to in a, in a future time. But, um, for the purpose of this, this recording, um, I'm just given a high, high level, high look down, um, summary of my, uh, um, my experience through, you know, living here and being part of the community and being part of the CAG, um, to actually having these sites mediated. So, uh, it's, it's, you know, it didn't happen overnight and it's continuously evolving. Again, it's not a destiny, but it's gonna be this, you know, this long journey to see how this, this ends up, if we ever do, you know, DD (16:32): Mm-Hmm. <affirmative>, TK (16:34): Maybe not in my lifetime, but, um, my, my gen, you know, not my kids generation and so on and so forth. DD (16:45): Yeah. PFAS is the, the situation both in Rockford area as well as kind of, I think globally. Yeah. Around PFAS. It's all still emerging and unfolding. And, and that's part of the, I think the challenge, TK (17:03): The tough part is, you know, it's, they're even finding it in rainwater. So when it rains, you know, there's <laugh>, you have PFAS and pretty much everybody has it in their, in their body throughout the world, and, you know, at different levels, depending on their exposure, their dose, the duration, that's what really determines, you know, what your health effects will be, DD (17:30): Right. Yeah. It's, uh, like you said, it's still an evolving, unfolding situation and TK (17:39): You be cautious, right? It's everywhere, right? DD (17:42): Mm-Hmm. <affirmative>. Yeah, TK (17:45): Exactly. And, uh, you know, I just, uh, just want people to do, do the right thing. I've always been, um, on the defense side of, of corporations, you know, from a OSHA, EPA, uh, standpoint, um, DOT standpoint, and, you know, having this opportunity in front of me to, Hey, let's just, you know, have corporate America do the right thing. Um, kids live here, go to school here. It's a good, good community. You know, I enjoy, you know, the, the environment and, you know, I'd like to stay here. So if I'm gonna do that, um, you know, do what we can to clean, clean up, uh, you know, the contaminated areas. DD (18:35): Yeah. It sounds like you are doing that -- what you can, TK (18:39): 5 �Right? DD (18:41): It does sound like TK (18:42): With the power invest invested in me, right? You grant me that, right Dani? DD (18:48): <Laugh> If I could, I would. <laugh>. Oh, well thank you so much for taking the time to share your story today, even at a high level. I understand that, like I said, the situation is evolving and, um, I really appreciate that you're willing to talk and share the parts of your story today that you did. TK (19:14): Yeah, no problem. Dani, remember when you put this into a book or a movie, I want to be the one of the actors. Don't ask for Tom Cruise. I wanna be able to be the main character and pick, you know, my, uh, my partner like Michelle Pfeiffer, Julie Roberts has had too many roles like that <laugh> with Erin Brockovich. So as long as that happens, Dani, you'll get all the details from me. All right, DD (19:40): <laugh> Sounds good, Tom. 6 � 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 PFAS0038 Creator An entity primarily responsible for making the resource Konecsni, Tom Date A point or period of time associated with an event in the lifecycle of the resource 2023-05-18 Title A name given to the resource Tom Konecsni, 2023 (Interview video and transcript) Description An account of the resource Tom Konecsni is a resident of Rockford, Michigan. After observing a building demolition in 2010, Tom became concerned about the environmental impacts of industry and chemicals in the area. He joined the Concerned Citizens Group. In the interview, he shares his observations about PFAS from various corporations that impact the area around Rockford, Grand Rapids, and the Grand River. 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/d1af20dddb59506ed78052ac4774ca29.mp4 e6aa24ce84980a180424e40d73d9d3d4 https://digitalcollections.library.gvsu.edu/files/original/a34de98270340852c9721faa57738ffb.pdf de73a45ac4a20f4e703d78c93feca3c7 PDF Text Text Living with PFAS Interviewer: Danielle DeVasto Interviewee: Wendy Thomas Date of Interview: 2023-03-01 Danielle DeVasto: Okay. I'm Dani DeVasto, and today March 1, 2023. I have the pleasure of chatting with Wendy Thomas. Hi Wendy. Wendy Thomas: Hi, how are you? Danielle DeVasto: I'm doing well. How are you? Wendy Thomas: Oh, I'm hanging in there. Thanks. Hanging in. Danielle DeVasto: Wendy, can you tell me about where you're from and where you currently live? Wendy Thomas: Sure. Um, well, I grew up in, uh, Fairfield, Connecticut, and then I moved to New Hampshire in 1980, and we, I currently live in Merrimack, New Hampshire, and we've lived here for 32 years, my husband and six children, adult children. Danielle DeVasto: I have a sister-in-law who lives or was from New Hampshire, and she tells me that that is a very beautiful area of the state. Wendy Thomas: It's gorgeous. Um, we're known as the mountainous state for a reason, you know, um, lots, especially up north there's, there's lots of parks and trees and mountains and lakes. It's, it's gorgeous. It's a beautiful State to live in. Danielle DeVasto: Wendy, can you tell me a story about your experience with PFAS or with PFAS in your community? Wendy Thomas: Sure. Um, I'm going to start at the beginning, um, because that works the best for me. So in 2016, I heard about a water group in our town. Merrimack Concerned Citizens for wat- uh clean water. Um, and so I went to one of their meetings because I thought it had to do with a pipeline that had been proposed that was gonna run through our town, which was, we had feared, it would disrupt our water supply and, and I, and they, they pulled the pipeline project. And so I, I thought that the water situation had been, you know, resolved. So I went to this meeting, and I heard about something called PFAS chemicals. And that was really my first introduction to it. I didn't, I didn't know what these chemicals were. I didn't know they were in the water. Um, we have a private well, so I thought we were okay, 'causae they were talking about public water being tested. Um, and so, um, but because I, as I said, I have six kids, um, at the time they were living at home. So I got our private well tested. Um, and again, this was 2016, um, and our levels, um, were so high that we had to shut our well down immediately. Um, and um, now the state had told us, so we know who is polluting our town. It's, it's an industrial corporation called Saint Gobain. They've been spewing this chemical into the air, into the soil, into the, uh, water for decades. Um, and it was only discovered in 2016 when they self-reported. So it had to have been bad at that point. Um, and originally the State of New Hampshire had said the only people that needed to be concerned about contamination in their water were people who lived within a half mile radius of this company. Um, pretty quickly after doing some testing, they modified that to a mile radius. Now I lived three miles from this corporation. So the state was telling me that my water was safe, and I got it tested and it was so high, we had to shut it down. So my husband and I installed a full house filtration system. Page 1 �We put in an, uh, reverse osmosis in the kitchen. The kids were only allowed to drink from the reverse osmosis. Um, and again, I mean the cost of a full house filtration system plus the reverse osmosis, plus to maintain them yearly, plus the, the fee to get them installed was about $5,000. And we had to pay this because a corporation did this to our water, you know, so, um, but, but of course we did, and we were fortunate that we could afford that, but so many people in our town, you know, couldn't afford that. So, um, I got active in this group, and we tried real hard to, um, to educate people in town about PFAS. But, um, the problem with these chemicals is you can't see them, you can't smell them, you can't taste them. And so the group was primarily women, and we were labeled fearmongers um, you know, you know, we hate our town because we're trying to get people not to move here. You know, we're gonna cause the, the town property values to go down because we're talking about this contamination. So initially we, we had a lot of, um, uh, pushback from the town. Um, and then, you know, throughout the years there, there were a couple of red flags, but I never really put them all together. All six of my kids, um, were born with dyslexia, um, which is a learning disability could be genetic couldn't, you know, might not be genetic who knows. Um, I recently put down my fourth dog who has died of cancer. Um, and that seems a little problematic to have four dogs, you know, in one household all have cancer like that. Um, my kids all have autoimmune issues. Um, again, genetic, maybe, maybe not it's, it's not in either of our families. Um, my husband, um, had, uh, several heart attacks and had a quadruple bypass at age 55, which is fairly young for that, and again, you know, we thought, you know, maybe it's just bad luck and everything. Um, and then in May of last year I was diagnosed with, uh, breast cancer. Um, it was invasive lobular cancer, which, um, very lucky to have found it early. Um, and so I opted for, uh, a bilateral mastectomy. Um, they, they were trying to get me to only do one side, but I, I did both. Um, and they found four precancerous conditions in the unaffected breast. So, um, I had, I spoke with the environmental working group in DC, and they suggested I get my blood tested for PFAS chemicals. And this is after being on a whole house filtration system, having water delivered by Saint Gobain for the last three years, plastic bottled water. Um, I have 12 chemicals in my blood that are above the toxic limit that that is allowed for humans, 12 PFAS chemicals. My, um, PFOS chemicals are 38 times the maximum value that's allowed for humans, and those are associated with breast cancer. Um, my PFOA chemicals, I have more than 99% of Americans do. Um, and those are associated with ovary and fallopian tube cancer. So I had previously had, um, a hysterectomy, but, um, because of the blood levels, my oncologists, um, decided that, that it would be, um, prudent for me to go and remove my ovaries and fallopian tubes to, to get rid of them before the cancer could essentially find them. So, so that's what it's like living in a contaminated town. We have to amputate parts of our body, our bodies to stay ahead of the, the poisonous toxins that will give us cancer, um, in order to stay alive, you know, we have to, we have to lay them at the altar of corporate greed because they're not stopping. They're to this day. They're still, um, emitting PFAS, uh, chemicals into our, our environment. Well, and, and my husband had his blood tested, and he has the same chemicals I do. He doesn't have them at as high a level as I do, but, you know, and of course the, the, the corporation is saying, there's no direct proof right now that PFAS causes chemical or causes cancer. Um, Page 2 �but we're finding that there, there are cases where it's causing cancer, and you know, I'm done, I'm done, I've got cancer, you know, so, I, there's nothing for me to, to, to hold back anymore.So, you know, they're saying that that it's not related, and I'm saying it's quacking like a duck, it's looking like a duck it's walking like a duck. You know, I think what we have here is a big fat duck. Danielle DeVasto: So you had mentioned that you were starting to get involved with the, the group, your local group. Um, is it something that you're still doing, or how did that, how has that been? Wendy Thomas: Yeah. Yeah. So because of that group, um, that's the reason I ran for state rep the first time there were two others that were involved in that group. So we became the water warriors for our town, and we got elected. It's a very red town, we're blue, but, um, we got elected. Um, and so we immediately went up to the state house and we, we put bills forward to, um, uh, have maximum containment, uh, contamination levels for PFAS in our water. Um, and again, uh, a lot of people, um, pushed back because they didn't know what PFAS was. They didn't know the damage. Um, and we were, we were just constant. We would sit down next to somebody at lunch, and we'd say, hey, how are you? I'm Wendy Thomas, have you heard about PFAS? You know, so, um, we did a, you know, know a real educational job, um, educating the other, uh, state representatives. Um, I also put together a team that, um, outside of the legislature, because sometimes you can get things done faster outside of, um, the procedures. And we, uh, developed some educational, uh, material regarding PFAS, uh, for people in New Hampshire. Um, and, and I've been to some conferences and, uh, attend, you still attend meetings on it. And, and now, so I wasn't a state rep for the second term, but I got reelected the third term, so, oh, I'm back up there putting more PFAS legislation in. Danielle DeVasto: Did you have a background in government in, in legislation? Wendy Thomas: No. Danielle DeVasto: Running for representative? Wendy Thomas: No. No. Um, I have, um, a degree in, in communications. I have a degree in, um, medical biology. So, um, you know, the impact of all of this made, made tremendous sense to me. Um, I'm also, um, I, I am an instructional designer. I'm a tech writer, I'm a journalist, you know, so all of these things sort of merge together in this, in this, um, path forward for advocacy Danielle DeVasto: You have a lot of skill sets to draw on that I'm sure — Wendy Thomas: Yeah but government wasn't one of them though. some of these archaic rules that we have to follow are like, you can't walk in front of the speaker during session, if you do, you have to apologize to the entire, you know, it's just some very weird things, Danielle DeVasto: But you mentioned that, so since, since working in this position and as a representative that you've been doing a lot of education, not just for the community, but also within the legislature. Wendy Thomas: Yes. Yeah. So this year I've put two bills forward. I think they're both gonna die because, um, there's, there's problems with lobbyists, you know, lobbyists have money, and they don't want, you know, PFAS to be acknowledged because it's gonna cost money to remediate and to, to treat Page 3 �it. One of my bills was that if, if, um, a real estate agent is, is showing property to a prospective buyer, they need to notify the buyer about PFAS in the water. It sounds logical. I mean, PFAS, if you drink it for a long time, it, it will hurt you. Um, but the real estate agents, um, were against that because they thought it would put too much of a burden on the seller. You know, the test is about $200. It's come down from about $400. Um, and the thing is in New Hampshire, we only recognize four, four of the many, many, many thousands of PFAS chemicals. So, you know, it was just a drop in the bucket, but at least it was something. Um, and then I put a bill forward to, um, mandate that insurance companies pay for preventive care, uh, PFAS care, if your blood tests over 20 parts per million. Um, and boy, they didn't like that one at all, the, the lobbyists and they, you know, they're, they're pretty strong up there. Um, and the reason that that came forward is that, um, originally my, the surgery to remove my ovaries and fallopian tubes was denied by my insurance company, because they were like PFAS. What, you know, what's that, you know? So, um, once my physician, um, diagnosed me with environmental toxins, then it went through, um, I also know of a young woman in town, um, who I think she's 24 years old. She has some breast issues. She had some lumpy breasts and went to, you know, lives in our town. Um, I urged her to go, you know, to, to a clinic and have her, her breasts examined. And, and, um, she did, and she asked about a mammogram, and they said, oh, no, no, no, no, you don't get a mammogram until you're 29 years old. Well, if she has cancer from PFAS in her breasts right now, she could be dead by age 29. You know, so things are going to have to change for those of us that have high levels of PFAS in our blood. You know, um, the CDC came out with some terrific guidelines, uh, recently they haven't fully adopted them, but they will. Um, and these guidelines, even, you know, if a, if a baby has PFAS, um, above 20 parts per million in their blood, you start checking them for cholesterol at age one, you know, um, when we talk about high cholesterol, um, high blood sugar, um, as a result of PFAS in our body, we're not just talking about an inconvenience inconvenience. Those are killer diseases, you know, cholesterol that's, that's what almost killed my husband. You know, so it's, it's invasive, it's pervasive. Um, you know, and the biggest thing I think is that, uh, PFAS chemicals are hormone disruptors and everything revolves around hormones, everything in our lives. And if you doubt the power of hormones, you've never had a teenage son, you know. You know, but everything revolves around, uh, hormones. And if you, if you mess those up, you know, you're messing up the entire body. You know, one of the, the, um, medications that they wanted me to go on is an estrogen blocker for, um, my, my breast cancer. But no one, no one can tell me if these hormone disruptors work with these, this medication, or if it works against this medication. So yeah, I've been reluctant to take it. I, I take a supplement instead, um, hoping that, you know, maybe that will, that will work, but it's things like that. We don't have the science, um, it's going to be, I'll probably be long dead before we have the science that's gonna prove this because we're working so slowly in the United States, Europe is doing a better job, but, uh, we're really dragging our heels on PFAS studies in, in the United States. Page 4 �Danielle DeVasto: I've heard from other people that dealing sometimes dealing with the medical community has been frustrating because, because of that leg, has that been your experience or have you been able to get, like, get support and — ? Wendy Thomas: No, no. That's another one of my crusades. So, um, when I got the, the, um, results of my blood P my blood PFAS levels, I presented them to my surgeon who did my mastectomy, who I was still under her care. And I said, these are my results. These are the interpretation of my results. And without even looking at them, she pushed them back to me. And she said, I'm just a surgeon. I don't need to know about PFAS. And I said, well, I've been advocating against PFAS since 2016. You are no longer my doctor. If you choose to remain ignorant, we can't have a relationship. See you, bye. Um, and my oncologist, she basically said the same thing. I said, what is the relationship between a, a hormone disruptor and this estrogen blocker? And she's like, beats me. So I don't have a surgeon. I don't have an oncologist. I'm trying to find somebody who's knowledgeable. As a State rep, I do have a platform. So I am going to go to the supervisor of, of these doctors in Southern New Hampshire and discuss PFAS education, because this is criminal, you know, all of Southern New Hampshire. It's not just our town because, um, water doesn't understand boundaries, air doesn't understand boundaries. Um, and so it's slowly spreading to the other towns, um, and to be a physician practicing in Southern New Hampshire and not know about the impact of PFAS on the human body is in its malpractice. Um, that's what it is. It's malpractice. Danielle DeVasto: Have you, um, have you been in touch with other communities or has your work kind of, I mean, you have, like you say, you have a larger platform, so I'm just curious if — Wendy Thomas: Oh, yeah. Yeah. So, um, the, you know, we've, we've formed sort of a coalition with the other, uh, communities, and we're working with them, although they're at the place we were in 2016, people are starting, you know, they're, we can't smell it. We can't taste it. I've lived here my whole year, and I'm not sick. I mean my whole life, and I'm not sick, you know, so, but the thing is there are, there is more information about PFAS, and people now are accepting that it can cause damage, you know, to, to humans and cancer. I mean, we have just a ton of cancer in this town. The State of New Hampshire does a cancer survey, but they're, they've only done it up to 2018. So they're five years behind. You know, so they have this false picture of how much cancer we have. I have been de I mean, every time I go to the state house, I desperately ask for, um, a, a survey on small animals, you know, pets, cats, dogs, even, uh, we're an agricultural community. So farm animals, um, because, um, I've talked to area vets, and they say they always know a dog or a cat when it comes from our town, 'cause it's got, you know, it's riddled with cancer, and it's got, um, uh, tumors all over its body. Um, Yeah. And then in Europe, the very first PFAS conference I went to, um, in Italy, there's a town that's very contaminated with PFAS, and they did, um, studies on their food, and it turns out that eggs, um, have a high amount of PFAS, produce has a high amount of PFAS because this company, you know, they burn their refuse and the, the soot, you know, the, the temperature doesn't destroy these forever chemicals. That's why they're called forever chemicals. So they're, they become particulate matter. It's spread over our town. Every time they burn this Page 5 �stuff, the rain drives it into the ground. The produce sucks it up. So our produce has PFAS in it. Our meat has PFAS in it, you know, any milk that comes out of this town has PFAS in it. So, you know, I mean the CDC, if you go to their guidelines, um, not the ones where you have PFAS in your blood, but just sort of general guidelines, they say, you know, the best thing you can do is remove the source. Well, that works. If you're only wearing a Gore-Tex jacket when you're camping, or if, you know, if you get rid of your glide, you know, dental floss, but when you live and breathe this stuff, the only way I can eliminate the source is to move out of my town, and who's gonna buy a house with no water in it. Danielle DeVasto: So what do you do? Wendy Thomas: Well, you know, again, I've got cancer, so, um, I have no, no F's left to give. So, um, I I'm out there banging the drum. I write letters to the editor. Um, I write op-eds, um, I've shared my cancer story, um, publicly in our town forum. Um, and many, many, many women have contacted me privately, um, to, to say that they also have breast cancer, or they have ovarian cancer or uterine cancer or, you know, things like that. So, um, I'm using my story to get attention about the problem, you know, I'm, I, I'm not doing it to get sympathy. That's not why I'm doing it. I'm doing it to, because this is not fair and people need to speak up about it. Danielle DeVasto: You've kind of hit at some of these already, but what concerns do you have about PFAS contamination moving forward? Wendy Thomas: I am concerned about the life of my town. Um, one of the things that is so underappreciated is that when pregnant women drink PFAS laced water at the levels we're seeing in our town, their children have a high incidence of learning disabilities. And, you know, they're, again, this is going to affect their hormones, which, you know, we have a, we have a high degree of, of kids with gender confusion in our town. And in, in surrounding towns, is it because of the PFAS chemicals? You know, again, we don't know, but again, it's another quacking like a duck situation, you know? So, so, you know, women, especially pregnant women, they need to be given filtered water. You know, we, we just can't, we can't let them drink this stuff. Um, and, and kids, you know, of women that have PFAS in their blood, we need to screen them immediately and start, you know, special education services or just, you know, monitoring services for these kids and the older people, you know, that have lived in town. Now, again, I've been here for 30 years. Um, I nursed all of my kids, so I drank a ton of water, um, which could explain why I have higher chemicals or higher levels than my husband. Um, but I'm worried about my children, you know, they're adults, um, they all have health issues, you know, what's gonna happen to them. I worry about, you know, my neighbor's children's, I worry about our town, you know, and it's, it's just, it's criminal what's happening. Um, but we can't, we're not, we don't seem to be able to stop it, which is, you know, I can't figure that out because it's directly hurting people, and yet they're allowed to continue. So, you know, whenever that's the case, you always have to follow the money, and I'm trying to figure out where the money is involved. Um, and I haven't come up with much yet. Page 6 �Danielle DeVasto: I mean, it's so ironic, right? You, you drink water because that's, what's supposed to be healthy for you.Good for you. And you're trying to make good decisions. And yet, as it turns out, you know the consequences. Wendy Thomas: You know, and I'm one of the water warriors. So, so I did all the right things. We installed that the filtration system, we, we drank from RO, um, and, and still, still, it looks like I may have gotten sick from these chemicals. Um, it looks like my whole family has been affected by these chemicals. So, you know, if a water warrior can't even protect our own family, what chance do other people in town have? I mean, right now in New Hampshire, you know, the, the utility bills are through the roof, you know, with inflation, with, with, you know, people losing work because their kids are home sick from school because they're getting infected with COVID. People don't have a spare $5,000 to, to make sure their water is clean, you know, and again, it's because of this, this corporation, you know, it's, it's truly an example of profit over people. You know, and the social warrior in me is just chronically incensed. Um, because it shouldn't be that way people should, should be first over profit. Danielle DeVasto: And this has been going on in Merrimack for quite some time. It sounds like. Wendy Thomas: Yes. Yes. Well, the, the company before this company was a one called Chem Fab, and I'm quite certain, they were probably doing the same thing, you know, disposing of their chemicals, uh, in, in ways that, that perhaps, well, no, that not perhaps that aren't legal. Um, but this company that moved in Saint Gobain it, their headquarters are in France, you know, and France has very strict environmental rules. If they did this in France, their CEO would be in jail, You know, but they came to America, and they came to the, to, to New Hampshire, live free and die. It's supposed to be live free or die, but, um, where we have, you know, few regulations, um, and they, they picked a town that was near river that had, you know, that wasn't, you know, a, a, a town that, that was organized. We don't have a town square or anything like that. Um, and they, they just ran with it because they could, so one of my goals is I wanna try to reach out to President Macron and just say, are you aware of this company destroying my town, this French company, you know, and if you are, why aren't you doing something about it? Danielle DeVasto: Boy, the things I bet you thought you'd never be doing, reaching out. Wendy Thomas: No, no kidding. I mean, I'm also trying to have a, have a meeting with President Biden, you know, because he's, he's big on the moonshot, you know, cancer program, and it's fine to fly to the moon. It's fine to land on the moon, but if we don't clean up planet earth, it's not gonna do us any good, you know, so, um, but very often politicians don't wanna hear this because, um, it impacts, you know, big donors to their campaigns. And I don't have big donors. I, um, am a state rep in New Hampshire. I am paid a hundred dollars a year to be a state rep. Danielle DeVasto: No big donors, Wendy Thomas: No big donors. No, no. I'm lucky if I get a free lunch every once in a while. Page 7 �Danielle DeVasto: Before we wrap up today, Wendy, is there anything else that you want to add that we haven't touched on or that you want to go back to and say more about? Wendy Thomas: Um, not really. I mean, that's, that's the story. Um, you know, as a result of this, I, I now have to live the rest of my life wondering if every pain is cancer or if, you know, every symptom is cancer. Um, thanks to this, this company, living in my town, I have to be concerned about my two daughters, you know, whether or not they're going to have cancer. I have to be concerned about my four sons, whether or not they're gonna have to, you know, end up having cancer. Um, it's just this chronic anxiety. Um, and, and I could leave my town, you know, I could move to greener pastures, but the damage has already been done, you know, so I'm gonna stay here, and I've decided I'm gonna stay here and fight, um, and try to get acknowledgement and maybe some re- remediation, you know? Um, but yeah, I'm not going anywhere, and I'm not being quiet. I've never known for being quiet. So Danielle DeVasto: Well, thank you so much, Wendy, for taking the time to share your story today. Wendy Thomas: Oh, my pleasure. Thank you for what you're doing. This is really important work. Danielle DeVasto: Thank you. Wendy Thomas: You're welcome. Page 8 � 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 PFAS0037 Creator An entity primarily responsible for making the resource Thomas, Wendy Date A point or period of time associated with an event in the lifecycle of the resource 2023-03-01 Title A name given to the resource Wendy Thomas, 2023 (Interview video and transcript) Description An account of the resource Wendy Thomas grew up in Fairfield, Connecticut and now resides in Merrimack, New Hampshire with her husband and six children. After her concerns and advocacy over PFAS grew, Wendy was elected to the New Hampshire State House of Representatives, where she worked to improve water quality and educate other representatives. In this interview, Wendy discusses her family's history with PFAS contamination of their well water, as well as her own advocacy and political action related to PFAS. 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/836a13c38e936443effbf5034abd889f.mp4 e2af5c96a3d378d8ac6f7a99f8896749 https://digitalcollections.library.gvsu.edu/files/original/20900ff7830055b61eb8f83574a068d6.pdf d872b7f0104e225c1a62d6bfc9606994 PDF Text Text Living with PFAS Interviewer: Danielle DeVasto Interviewee: Andrea Amico Date of Interview: 2023-02-10 Danielle DeVasto: I'm Dani DeVasto. And today, February 10, 2023. I have the pleasure of chatting with Andrea Amico. Hi Andrea. Andrea Amico: Hi, Danielle DeVasto: Andrea, can you tell me about where you're from and where you currently live? Andrea Amico: Sure. Um, I grew up in central Massachusetts, uh, Leominster, Mass, but I currently live in Portsmouth, New Hampshire. Danielle DeVasto: How long have you lived there? Andrea Amico: I moved to Portsmouth New Hampshire in 2007 when my husband took a job up this way, it brought us from Massachusetts to New Hampshire. And we have been here since. Danielle DeVasto: Can you tell me a story please? About your experience with PFA S or with PFAS in your community? Andrea Amico: Sure. So I like to say in May of 2014, my life changed forever. I read a newspaper article that had said they found high levels of PFAS in the drinking water wells at the Pease Tradeport, uh, which is imports with New Hampshire, where I live. And it is home to a former Air Force base that had been shut down in 1991. So many years before I had moved to the area and really knew a lot about the prior Air Force base and the fact that it was a super fun site. I didn't know that, but why it was important to me and devastating to me, frankly, when I learned that there was contamination, there was because my husband was working for a company at the Pease Tradeport. And my two children were attending a daycare center located at the Tradeport, and all three of them were drinking the water every day. And so when I read that article that they had found high levels of PFAS, and they had to shut down a large drinking water well, because the contamination was significant. Um, my heart sank, you know, because I was like, whoa, I don't know what these chemicals are, but my family's drinking that water. My kids are drinking that water. Like, what is this? What does this mean? So that's how I became introduced to PFAS back in 2014. Danielle DeVasto: And then what happened after that point for you? So you found out, you read the article and then, and then what? Andrea Amico: Yeah. So I started attending community meetings that were being hosted by our city and our state, and I just started trying to learn as much as I could about these chemicals. And, you know, back then in 2014, there wasn't a lot of information. Honestly, I, you know, searched the internet and I could find stuff about the C8 health project and C8 health study in Parkersburg, West Virginia. I found some EPA documents that were like 800 pages long and really hard to make sense of, but PFAS was not, uh, known and given the, you know, attention in the media and, uh, frankly like the scientific studies and resources that it is today. Um, and so I attended some community meetings and tried to do my, do my best to educate myself. And, um, the first thing I really started advocating for was blood testing for my community, because I knew that these chemicals built up in the body, and they stayed there for a long time. And I knew that you could have a blood test to determine how much was in your body. Um, even Page 1 �though we don't really know what that means, but you know, or at the time we didn't really know what it meant, but, so that was like one of the first things I did was advocate for blood testing. And then I formed a community action group with two other moms whose children also went to the daycare center, and we formed a group called Testing for Pease. And our first big, big push was that blood testing program. Hence, the testing part of Testing for Pease. Danielle DeVasto: And how did that go? Andrea Amico: Um, so we were successful. It took a lot of pressure, um, but we were able to get our State health department to offer a PFAS blood testing program to our, to the community at the Pease Tradeport, um, between 2015 and 2018 of almost 2000 people participated in that program. And it did reveal elevated levels of PFAS in the blood when compared to the, you know, general population. We know everybody has some detectable levels of PFAS in their blood, but the levels at the Pease Tradeport were elevated when compared to, you know, the general population. And with that information, we were able to advocate for filtration of the drinking water and the Air Force paid for that. Uh, we were also able to advocate for health studies for the community, and we were successful in getting two PFAS health studies for our community. One was with the ATSDR, Agency for Toxic Substances and Disease Registry. They're a kind of like a sister branch of the CDC. They're a federal health agency that works with communities who have dealt with environmental contamination. Um, so we did have a large health study done, uh, that actually wrapped up about a year ago, and we're still awaiting our community results. And we have another health study that's ongoing today, um, called the PFAS reach study and that's funded by the NIEHS, and that is, um, looking at children of mothers who drink water at Pease, um, and looking at their, the child's PFAS levels and their immune function, 'cause we know PFAS can impact vaccines and vaccine effectiveness and the immune function of children. So, um, so we've been really successful here, you know, that blood testing program that we initially advocated for, I think opened up a lot of opportunities for advocating for remediation filtration and additional health studies. Danielle DeVasto: Wow. That's great that you guys have been so successful. What do you attribute that to? 'Cause I don't think that's the story everywhere. Andrea Amico: Yeah, I completely agree. I think there's a couple things. I think we were one of the first communities to really grapple with this. I know there were some others, but um, we were one of the first back in 2014, like I said, you know, Parkersburg, West Virginia was kind of on the radar with the CA health study there. But, um, and I know that, uh, the Wurtsmith Air Force Base had found their contamination as well. But I think us being one of the first, uh, communities to have a really significant contamination, uh, especially to a trad port of, you know, about 10,000 people were coming to this tradeport to work every day. Um, so I think timing being one of the first and really pushing when there wasn't a hundred other communities asking for the same thing, we were kind of the first ones. Um, I also think, like I said, we were a tradeport. Um, our forma military base was closed under what's called the bra program. It was the first BRAC site with DOD base realignment closure. Um, that program was really that program focuses on taking former bases and redeveloping them. And so I know Pease was considered a Page 2 �very big success story to the Air Force. The fact that they took this old base, redeveloped it into this large industrial park with 250 businesses, 10,000 employees like there's, you know, community colleges, restaurants, a golf course, um, all kinds of businesses, medical office buildings, restaurants, like this was a highly successful place for New Hampshire as well as a large economic hub for New Hampshire. You know, so they really, we, no one could just really walk away from this community. You know, I mean this was a, a significant resource and asset to New Hampshire. So I think that was part of it as well. Um, and I also think we were very successful in establishing relationships very early on with our congressional delegation and our elected officials and a lot of the efforts that happened at Pease, where as a result of, you know, our Senator from New Hampshire Jeanne Shaheen, who's been a PFAS leader in the U.S. Senate, uh, making sure we have funding for the health study, the at ATSDR Health Study, really pushing for the air force to clean up and filter the water. And, um, we also had an EPA order from region one that ordered the E uh, Air Force to clean up the contamination. And again, I think part of that was timing of being one of the first, but also just, I feel like it was a lot of things that came together, you know, timing quick, organizing on the community part, asking for things, being one of the first and having strong relationships with congressional leaders who were able to really, um, put legislation in place to give us action. So I attribute all of our successes to a combination of those things. Danielle DeVasto: Prior to all of this beginning, were you, um, did you have a background in community organization advocacy work? Andrea Amico: No, I get asked that a lot. No, I didn't. [LAUGHTER[ Um, so by training, I'm an occupational therapist. I work in the world of rehabilitation, neuro adult rehab. Um, and so yeah, no, I didn't have any knowledge. Like I was never an envi-. I wouldn't, you know, didn't think a whole lot, lot about the environment, you know, like this just never politically active. Um, it just wasn't, it just wasn't something I ever did or was never part of my life, even my family, you know, it just wasn't something I was raised to do. So it honestly took this happening to my family and my community to kind of spark a fire inside of me and say like, all right, like we gotta do something here, you know? And I think that's what was so shocking to me in the beginning when like they found our contamination, they shut down the well, and, you know, at first we were asking for blood testing, and it was like, we weren't getting, making a lot of progress on that. And it just, it kind of like, it shocked me that like a large amount of people could have been exposed, you know, were exposed to high levels of contaminants and drinking water. And at the time they were calling them emerging contaminants and our State health department was like, we don't really know the health effects. Like we're just not really sure. And it seemed like everyone was okay with just not being sure as a reason to not do anything. And that just, I couldn't accept that, you know, and like, I can't accept the unknown as a good enough answer not to do anything. Like if you don't know, you have to find out, you have to do health studies, you have to do blood testing. Like you can't just leave us all to carry on with our lives and not know if we're gonna get sick from this over time or, you know, so, um, yeah, sorry. That was a long winded answer, but, uh, no, I didn't have any prior experience and in a way I Page 3 �feel like that was a benefit. 'Cause I just came at this like trying to use common sense and be like, okay, you have to do more like, it's like not acceptable to just accept the unknown. Danielle DeVasto: So you're continuing right now with your advocacy work, correct? Andrea Amico: Yes. Danielle DeVasto: Like it's not, it's not done. Andrea Amico: Oh, it's definitely not done. I, I tell people it's, it's like a lifetime. I have set my mind up that this will be a lifetime of work for me in some way or another, you know? Um, I do a lot of work at the national level now, so I'm part of the national PFAS contamination coalition. I helped found that in 2017, and we're a large group of community, community leaders like me from all over the country, um, who are also dealing with this issue, whether it's at former military bases like mine, whether it's at industrial sites, like Saint Galvan um, that's contaminated, Miramac New Hampshire, Husick Falls, uh, Husick Falls, New York, uh, lots of firefighters who also are concerned about PFAS. Um, so yeah, we're a real, you know, broad group of people and working at the national level to try to get better EPA regulations, you know, hold polluters accountable so they are forced to clean up this mess. They're forced to fund health studies and, and make people whole again, you know, um, it's, it's incredibly wrong what has happened with PFAS in this country? You know, the fact that manufacturers hid the health effects for so many years, they were just allowed to manufacture so many PFAS, put them out into our environment. They're in our bodies, um, with no regulations with no consequences. And even now what we know, we're still, we still aren't at a point where they're regulated at a federal level. I mean, we're getting there, but, um, it's, it's, it's absolutely horrific to me how this is all played out in our country. And I hope it's an example of like how we need to do so much better as a country and as a society and how we treat chemicals and what we're willing to expose people to. And, um, because these chemicals are never going away. And so anyways, I see my work as something that will go on forever. I really do. As, as long as I'm living, there will be something to work on with PFAS. Um, and, and I'm committed to that. You know, I, I gave a, a TEDx talk in my community a few years ago, and I ended, I ended the line, like, I'll see people, and they're like, oh, you're still doing that water stuff. And I'm like, yeah. And I, I ended my talk saying like, you know, I, I'm never gonna stop because I'm just as per persistent as PFAS, you know, like, I'm, [LAUGHTER] I'm just as persistent as PFAS. So like, yeah, it's, my work will evolve over time, but like I have committed my mind to a lifetime of work on PFAS to some degree Danielle DeVasto: In the move that you've made from kind of focusing on just the local to the national, um, like what, what has that shift been like for you, or what have you noticed in making those shifts? Andrea Amico: Um, well the I've noticed that I'm not alone., [LAUGHTER] um, we're not alone, you know, as frustrating as it feels to be. Sometimes you can feel siloed in your own community and how everything happens. Um, I've realized that there's a lot of other people out there just like us who have experienced the same things, um, who want the same things. And all of our stories are different. You know, our polluters are different. Our sources of PFAS are different in some cases, but like, we all want the same things. Like we don't wanna be exposed to chemicals that we didn't volunteer or sign up for, you Page 4 �know? Um, and so I've, I feel a sense of collaboration and I feel a sense of validation with a larger group of people that it's not just us, it's not just New Hampshire, it's not just Portsmouth. Um, and I also feel a bigger sense of responsibility. The more people that join our coalition and the more stories I hear, I feel more of a sense of responsibility of why I need to keep going, because if I stop and look at like everything we've gotten in my community, I'm really proud of that. And I'm really happy. And I feel like I could just be like, Hey, we have our, you know, the Air Force is cleaning it up. They're filtering our water. We're getting our health studies. We've had our blood testing like good, you know, like I could just, but I, I feel a bigger sense of like, like you said, that's not the norm in most communities. Like people are fighting tooth and nail for blood testing and health studies and filtration and, um, and the numbers of communities discovering this contamination continue to grow. So I just, I feel a bigger sense of responsibility to something bigger than just my community and trying to use the knowledge and the experience I have to move the needle even further. Like we have to stop exposing people to PFAS. We do. Um, and, and we have to study the people who have been exposed, and we have to make the people who have been exposed and are harmed, we have to make them whole again, you know? And so, um, so there's yeah, a lot more to do. And it's bigger than just here. Danielle DeVasto: Mm-hmm, mm-hmm what concerns do you have about PFAS contamination moving forward? Andrea Amico: Well, I, I am concerned that a, a few things I'm concerned that we can't even detect all of them, you know? So the current testing, we have lacks the ability to really know what's, you know, uh, when something is said to be PFAS free, or we're gonna, you know, stop using PFAS, like my antenna immediately goes up, like, what does that mean? Is that mean just 20 of 'em, you know, PFAS is a class of, I've heard 12,000, 15,000, the number keeps growing. So it concerns me that we can't even detect all of them or truly know what we're being exposed to. Um, it concerns me that we don't have any federal regulations at this point. We have health advisories. Um, I know the EPA is working on that, but, you know, we've known for a long time that PFAS are bad. And the fact that we don't have regulations yet to stop exposure is unacceptable. You know. Um, another challenge that I think people are facing, and one that I've spent a lot of effort on is the fact that health, the healthcare community doesn't know what PFAS are. And, um, I mean, even in my own community, people got blood testing done, and they bring the results to their doctor, and their doctor was like, I don't, I don't know what this is. I don't know how to read these blood tests. I don't, I don't know what to do with this information. And so, you know, that's another thing as more communities become exposed. I mean, one of the first things that pops into your mind when you learn you're exposed for at least for me, it was, is my family gonna be okay? Like, are they gonna get sick? Like, what do I need to do to monitor their health? Like, what should I do now? I can't undo the exposure. I can't take the PFAS out of their body any faster. So now what, and then you, you know, go to your doctor, which seems like a very appropriate step. And, and they're, they're just, you know, they're uneducated about it. And, um, and it's not, it's not their fault, the physician's fault, it's that they don't get environmental health training. They're not given guidance on PFAS. They don't even know Page 5 �how to order PFAS blood tests, you know? So, um, I think there's a lot more that needs to be done too, on the healthcare side of things. So like, you know, I think when, when you think about lead exposure in kids, like doctors know that that's not good, and there's a level in the blood that you wanna be below. And if a kid has lead, there's steps, you can take, you know, to help them. I hope someday with PFAS, we can be there too with the healthcare community. They're gonna know how to test for it in the blood. They're gonna know what levels are concerning. And if you have an elevated level, they're gonna know what tests to run and steps to take, to monitor your health and try to keep you healthy, you know? And we have, we've seen some progress on that for sure. But that's another area I think, need that needs a lot of work. Danielle DeVasto: Before we wrap up today, is there anything else that you would like to add that we haven't touched on today or anything that you'd like to go back to and say more about? Andrea Amico: Um, I just think, I think a few thoughts, or just, I'll kind of elaborate on a few things I've said, um, it's infuriating to me how far this PFAS issue has become, um, how far it's gotten out of hand, I should say in the sense that the chemical companies that made these chemicals decades ago knew, knew the harms of them. Um, they hid that information, and they continued to make these chemicals profit off of them. And, and frankly, they continued to do that today. And I just, I, I really struggle with that. You know, I really struggle that a company, uh, can do something like that to our entire society and yet face no real consequences. Um, it's crazy to me that the people that have been harmed by these chemicals the most are the ones that have to like stand up and fight tooth and nail, uh, while these chemicals were, these companies were just allowed to profit off of them. And I, I think, I think our government and our society should make a very strong example of these companies. And I think they need to be criminally held responsible, uh, for what they've done. And, um, and I hope that we'll, I'll hope I'll see that in my lifetime because they absolutely need to be held responsible. Um, I will also say that, you know, as a mom, like this has been like one of the most emotional things for me as a mother, you know? Um, I think as a mom, you, you try to do everything right. You know, when I was pregnant with my kids, I like took my prenatal vitamins. I went to all my appointments, um, when, when I was looking for daycares for them, like, I, you know, toward the daycares, I asked so many questions. Like, are you first aid certified? What's your curriculum? What's your teacher to child ratio? Never once. Did I question the quality of the water? Never once. Um, that's like something that just eats me up inside as a mom that like, unbeknownst to me, I sent my children to a daycare center that had highly contaminated water. Um, and the daycare didn't know either, you know, so even if I had asked the question, they wouldn't have known, but I can't tell you like what that's done to me emotionally, that I made a choice that put my kids in harm's way and that, you know, that's honestly, the reason why I fight so hard is for them, like, I can't undo, what's been done in the past, but like, if I can do everything I can to make this better in the future, I will. And if I can do anything, I can to prevent this from happening to another mom or family, like I will. Um, but it's really robbed me of a lot of my happiness. And it's really like taken a lot away from me as a person. Um, and that's like something I don't think people truly understand like emotionally and psychologically, what contamination does to a family or an individual or, uh, to a community. You know, it's just, it's just, Page 6 �it's just absolutely devastating. It feels like the ultimate betrayal, honestly. Um, and so, you know, I guess I just, you know, talking about the human side of things and, you know, it's easy to be like with, I advocated for this, and we got this and like, you know, I'm so proud of those things. Those things bring me a lot of pride and joy that I've been lucky to work with community members, and we've accomplished so much, but I, I just want people to know that it's not easy, and it's, it's life changing, and it's not for the better, so I guess that's what all, but I guess, and one other thing just like, what keeps me going though, and I'll just end with this is that we have seen progress, you know, a lot. Um, not only in awareness, like I told you, no one knew what PFAS were or even heard of 'em before. Like the amount of legislation that's passed the amount of resources. I mean, there was $10 billion put billion with a B put in the infrastructure bill to address PFAS. Like that's huge, you know, um, a lot of money, a lot of attention, a lot of awareness, a lot of science going on. Um, that's what gives me hope. And I just, um, wanna just keep moving forward. Like I said, just if we can prevent this from ever happening again, make a strong example of what's already happened and help the people who have been harmed like that. That's what we need to do. Danielle DeVasto: So I suspect that you can never, you mentioned before being, you know, you want to work to help communities and people feel whole again. Um, and I suspect that after the kind of, you know, you say betrayal that you felt and, um, the other, you know, just all the ramifications of finding out something like this happened to your community, that you can never maybe a hundred percent be as you were mm-hmm, but I'm just, I was curious for you or for your community, um, or people that you work with, what do you think could be done to make you feel as whole as possible? Like what, what would that look like for you? Andrea Amico: I think it's a few different things. So it's having like an established medical monitoring program that allows people to have access to healthcare, so they can monitor their health and catch any health effects early. Like right now we don't have that. It's very fragmented. Um, so having a system in place that will help people monitor their health, that they don't have to pay for that, you know, and if people do suffer health effects as a result of that, they of their contamination, they should be compensated. I think if people have lost property values, because they live in a, in an area that's contaminated and people don't wanna buy their house now, or live there, they should be compensated for that. Um, I think holding the polluters accountable, you know, like criminally, um, is so important, you know, like, no, one's no one's ever apologized. Like, no one's ever said, like, we're sorry, this happened to you. You know, like I think owning the mistakes of the past are so important. Like as much as I like to look forward to the future and like, how do we change this and make this better? Like that past is so important and acknowledging the mistakes, apologizing to the communities and like taking full accountability is also another part of it. Um, absolutely cleaning up the contamination. Like it shouldn't be left in our water in our soil and, and that's even trickier. Like it's everywhere now, it's in our food, it's in our plants, it's in our fish, it's in the air, it's in rainwater. Like, you know, so I think being whole, again means a lot of different things, but it comes down to like accountability, cleaning it up, um, and not putting the burden of paying for all of Page 7 �this stuff on the communities, you know? Um, and, and whether that's paying for filtration of their water or paying to go to see the doctor, 'cause they might have health issues or losing, you know, some folks like in New Hampshire, um, you know, their property values went down like that's their retirement, you know what I mean? Their home, the value of their home. Um, it's just, it touches on so many issues. And so I think there's a lot that needs to be done to make us whole, but those are just some that pop off pop to the top of my mind. Danielle DeVasto: Mm-hmm those would all be excellent places to start. Mm-hmm mm-hmm even if, maybe it's not, you know, ultimately you can't undo what, what has been done as you've said mm-hmm so, Andrea Amico: Yeah, and I, I just hope too, like the technology advances on how to get rid of PFAS, you know, 'cause even at this point we can't destroy it. We can't like even incineration there's concerns with it there. So it's like in some ways too, I'm so grateful in my community, they're filtering it from the water, and you know, they concentrate it and right now they send it to a landfill aligned landfill, and I'm grateful that it's leaving my community, but in the back of my mind, I'm like, we're just like taking this pollution and moving it somewhere else. Like we're making it somebody else's problem someday. And that seems wrong too. You know, it's like we don't even have, and then I wonder like then why do we approve new PFAS on the market? We can't even handle the PFAS. We have, we don't even have a good understanding of the health impacts of all the PFAS that are on the market. Like why would we add more into the environment? You know? Um, so again, I'm just hopeful with the resources and the awareness and the scientific interest in PFAS that we will see more advances on remediation, technology and destruction. Um, so we're not just like picking up the pollution and moving it around instead of actually getting rid of it. But again, all the reason we probably should have never made this stuff in the first place 'cause we can't get rid of it, you know? Um, so yeah. Danielle DeVasto: Well thank you Andrea for taking the time to share your story today. Thank you. Andrea Amico: Yeah. Thanks for talking with me. Page 8 � 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 PFAS0036 Creator An entity primarily responsible for making the resource Amico, Andrea Date A point or period of time associated with an event in the lifecycle of the resource 2023-02-10 Title A name given to the resource Andrea Amico, 2023 (Interview video and transcript) Description An account of the resource Andrea Amico lives in Portsmouth, New Hampshire where she moved in 2007. In this interview, Andrea discusses her activism and advocacy about PFAS contamination after learning about the superfund site at the Pease Tradeport, where her husband worked and children attended daycare. 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/91d644bf74a52844d9c16510d6a95e05.mp4 7b2b542d78ca331a97df008e0d95cb99 https://digitalcollections.library.gvsu.edu/files/original/200569fc976d3b20857c55eafd28958e.pdf a25ffe5194e638dd9987fb1d36bb81ce PDF Text Text Living with PFAS Interviewer: Danielle DeVasto Interviewee: Karen Vorce | Date of Interview: 2023-01-13 Danielle DeVasto: I'm Dani DeVasto, and today, January 13, 2023, I have the pleasure of chatting with Karen Vorce. Karen, thanks so much for coming and talking with me today. Karen Vorce: Of course. Thanks for having me. Danielle DeVasto: Can you tell me about where you're from Karen, and where you currently live? Karen Vorce: Yes. Um, I- I live here in Kent County, Michigan, um, on the west side of Kent County in the City of Walker, and I also work here in Kent County as well, um, at the Michigan Department of Environment, Great Lakes, and Energy in the Remediation Redevelopment Division, and our district office is in downtown Grand Rapids, in Kent County. Danielle DeVasto: And how long have you been in Kent County, Karen? Karen Vorce: Let's see, I've lived in Kent County now for about six and a half years. Um, I actually moved to the west side of Michigan, from the Metro Detroit area in the summer of 2016. Danielle DeVasto: Thank you. Karen, can you tell me a story, please, about your experience with PFAS or with PFAS in your community? Karen Vorce: Sure, yes. Um, so it kinda has to deal with me working for the State of Michigan and the Department of Environment. Um, I started here at the state, um, in February 2017. I transferred over from doing environmental work in consulting, um, for a number of, uh, [LIP SMACK] the regulated community in the State of Michigan, for about seven years, and so I was really excited. Um, I applied for the job at the state, and I was able to get the job and, um, [LIP SMACK] always had wanted to work for- for the State of Michigan. And, [LIP SMACK] um, so I started in February 2017, and that was right when [NOTIFICATION SOUND] we were just starting to learn about Scotchgard, um, the fabric protectant, uh, waterproofing used by Wolverine Worldwide, um, at their tannery facility in downtown Rockford, which was, uh, had been long gone since about 2010. And, um, so yeah, I was assigned to cover as a project manager and geologist, uh, northern Kent County on my first day, and it just so happened that this Wolverine site was located also in northern Kent County, so it landed in my lap, and I remember about a month in, you know, hearing that the citizens' group had- had met with some of my colleagues and my supervisor in January, so just about a month before I started, and had brought concerns about the waste stream that would've left the tannery [SNIFFLE] containing PFAS, the Scotchgard material, and where that was disposed of at this, uh, property called the House Street Dump. And so I remember we started looking for any records on that, and then, um, [LIP SMACK] we had never sampled for PFAS at a site, an environmental site, [LIP SMACK] um, any sites of contamination in our district before that time. So this was definitely something new to- to Eagle in our divi- our district. Um, there were a couple other sites, military installations, that had been doing testing [SNIFFLE] in other places. So we kinda had to learn, myself and colleagues had to learn the process of collecting PFAS samples, how to do it properly, um, and so we started sampling some wells, um, just to the northeast of the House Street Dump because a Page 1 �well permit had come in. Someone wanted to install a new well and knowing that the concerns that were brought to us from the citizen group, um, you know, and obviously the local health department, we all kinda were like, well, let's sample those houses around where this permit is to make sure that there's not PFAS in there. Um, Wolverine agreed to do that sampling. Um, it was difficult to- to get liable parties to do that sampling at that time 'cause we didn't have regulated, um—PFAS compounds were not regulated. We had no criteria, so really no legal teeth, um, to request sampling, but, uh, you know, Wolverine did agree. Uh, we also requested onsite work to start doing onsite sampling at the House Street site, as well as at the tannery site where it was occurring—where the tanning operations happened, but, um, you know, that was in April 2017, and then, you know, those results, fortunately, um, they did- they did detect some PFAS, but at that time we thought, okay, it's- it wasn't above the EPA lifetime health advisory that we were using, uh, which was 70 parts per trillion for PFOA and PFOS, [LIP SMACK] and, um, so we thought, okay, well at least those folks are, you know, below the 70, 'cause we didn't really have any other levels or- or known values to go off of. So, uh, we said, okay, let's- let's shift Wolverine. We need you to keep—we need you to do something at the site. We gotta get groundwater samples at the site cause there's other houses around here, right, um, that, you know, could be impacted. So that was- that was going on, and lo and behold—so the sampling was done in April. In May, the end of May, we got a call from the Department of Defense, um, because they had done sampling of the Belmont Armory, [SNIFFLE] which is on the House Street site—not on the hou—is on House Street, just down the road from the House Street Dump. They sampled their private well for PFAS because the Department of Defense was sampling all their properties across the United States at that time for PFAS because of their training with, um, [LIP SMACK] the Aqua- Aqueous Film-Forming- Film-Forming Foam, the AFFF, that they've been using at a lot of their properties. Um, that was—AFFF was not used at the Belmont Armory. It used to be a church, and then they used it for, like, band practice. So, um, when they got a hit in their well of, I believe it was 120 parts per trillion for PFOA and PFOS, um, we got that result, and we were, like, look, this- this is what, you know, we're worried about Wolverine. This is why we've been asking you to do this. We need you to sample wells now, like we know there's a problem. You can't just be focusing on the- on the site, we need to sample residential wells. And so that summer of 2017, it's kind of a blur now, but that's when, um, you know, especially as a new state employee, it was pretty intense going out to the neighborhood, um, with this emerging contaminant telling people, hey, we wanna sample your well, it may or may not be impacted with this PFAS stuff that's at this dump, that's down the street from your house, that's covered in trees, that you may not have known was there. [DEEP BREATH] Um, you know, going door to door, just having those- those conversations with people and- and not knowing in the beginning, just thinking, oh, hopefully, you know, then maybe this won't be that bad, maybe- maybe their wells are at a good depth, and it won't be a problem. I do remember the first house besides the- the homes to the northeast. Once we started going down House Street, the first door I knocked on, um, who you've probably interviewed, was Sandy Linstelz' door. She lived right across the street from House Street, and, um, yeah, I remember meeting her and just from the moment I met her, she was just such a Page 2 �nice lady, and, um, she was just so nice. She said, "Oh yeah, come on in, take a sample, do whatever you gotta do," and you know, we sampled. I think there was about 46 houses during that- that initial sampling in May 2017, or June. It was June by that time, 2017. And I still remember, uh, being in the office and getting the email results, uh, coming in of the lab, the lab sampling results, and, um, just seeing, you know, those results coming of some of those houses and the tens of thousands of parts per trillion in their drinking water well, and it really was at that moment I realized, you know, even being new to the state, sensing that something just was really wrong, this is not obviously good. Um, it's way above that 70 parts per trillion, and I'm not a toxicologist, I'm geologist, but just seeing that number I knew that's obviously not something that is good for people to be drinking, or safe. Um, and so, yeah, then I remember that afternoon, at that time my supervisor and the health department took—had to take those results and go to- go to people's houses and- and tell them right away [DEEP BREATH] what their results were. Um, yeah, so I can keep going on this story. I can go up to where we are current day, um, [LAUGHTER] if- if you wanted, um, but, yeah, that's kind of just going back to those early days. Um, just the panic that's involved with projects like this coming from a regulatory standpoint. Um, I- I think of other states, especially, or really around the world, anywhere, any- any geographic location or government, um, [LIP SMACK] where, you know, they haven't started testing for PFAS, um, they haven't started looking for it. Um, you know, I- I just want people to learn from Michigan, and- and learn from what we've experienced and had to go through to kinda learn how to look for it and address it because, um, people will find it. We're gonna keep finding it, um, but they need to start looking sooner rather than later, and I'm sure the residents who have been impacted here in Michigan, at all of our PFAS sites, not even just here in Kent County, would echo that the sooner that you can let people know that they're drinking something they're not supposed to be drinking, the better, um, because, you know, now we're learning more about it. There's kind of no more excuses that people can have. I mean, it's in- it's in the everyday CNN and all the publications are talking about PFAS. Everyone's talking about PFAS now. Um, we know it's an issue. We have more science, more health studies to document even lower levels, so our levels are now below 70 parts per trillion here in Michigan, for a number of compounds. Um, and EPA has since updated that 70 parts per trillion right to below one parts per trillion for PFOA or PFOS. Each of those are below one parts per trillion now. Um, so obviously these are harmful chemicals at very low concentrations. Um, and I think the more people realize how we're exposed to those every day, not just in our drinking water, through our everyday commerce goods, through potentially touching things that could be contaminated, dirt, soil, um, couches, you know, laying around on couches that are Scotchgarded, um, uh, cosmetics, you know, different, uh, adhesives, different things we're breathing in, even the dust particles that we're ingesting, you know, it's- it's once you start realizing kind of how ubiquitous and how much PFAS is a part of our, unfortunately, society now, it really goes to show the- the urgency and the need that is needed to- to keep addressing PFAS [SNIFFLE] 'cause the more we find out, it just seems like the more we're realizing that they're not good for us. I mean, they do their job good [CHUCKLE] on the- on the waterproofing and, um, Page 3 �the chemistry end. Yes, they're a modern marvel and, um, they do their job, but obviously they weren't made to be inside of us. Danielle DeVasto: Yeah. Right. Um, I'm wondering if you might, if you're willing to say more about your experience with PFAS from that kind of regulatory work perspective. You've kind of hinted that, you know, you're not a toxicologist, you're a geologist, and so I guess I'm just curious if you have anything else that you might say about how PFAS has kind of been a part of your work experience and- and- and impacting that. Karen Vorce: Yeah. So, um, yeah, P—un- understanding, we- I mean, we've just been like sponges soaking up the data over the last six years now, um, at this site and at others. You know, we have over 240, uh, PFAS sites now in the State of Michigan, identified. Those are locations where we have groundwater above our cleanup standards. [SNIFFLE] We have samples, um, showing that the groundwater's contaminated above that. So we have at least 240. I'm sure there's plenty more out there, we just haven't found yet. Um, I- I think Wolverine's site here in northern Kent County, it does span approximately 25 square miles of groundwater contamination. It is, I'm pretty sure the largest, um, area of contamination that we have found to date, and I'm—hopefully it stays that way. Uh, I [CHUCKLE] don't wanna find any more like this, especially such high concentrations in private drinking water wells. I mean, we have found, um, concentrations as high as 100,000 parts per trillion in private drinking water wells, um, which is just pretty- pretty insane to say out loud, um, that to date from just the various conferences, the various interactions that I've had, that I've heard others having, I haven't heard of anyone having a higher result than that 100,000 parts per trillion in a drinking water well. I've heard of it in environmental wells at sites. You know, we have 1,000,000 parts per trillion in groundwater at the tannery site, [SNIFFLE] but for someone to actually be drinking that, um, is pretty astounding and, um, you know, what we've learned about the contaminant fate and transport of PFAS, especially in this area, um, has really helped us be able to address PFAS at other sites faster, uh, get a better understanding because in the beginning, there's no way when this first started, um, that- that we knew this contaminant plume would encompass 25 square miles. Like, we were thinking, oh, you know, we have, uh, chlorinated-solvent plumes, we have petroleum, you know, gasoline-parameter plumes. We're used to dealing with contamination. That's what we do here in my division. So I would always tell people, you don't wanna see me 'cause when we show up, that means you have contamination, right, [LAUGHTER] um, unfortunately. So it's—we- we're used to it, like, okay, we'll start with these close houses and that was really hard for me personally, when this started in gaining, really having to gain the trust back of the public for- for the agency, you know, before I even, sometimes, you know, before I was born, obviously when this dumping occurred, but before I even worked at Eagle, because, um, you know, we—in the beginning of this, we were handling it like every other site we handled today, not knowing that PFAS traveled as far as it could, it's so mobile. In the complex geology that we're dealing with here in northern Kent, um, the glacial geology, and just a lot of the sand and gravel that just acted as a beautiful, unfortunately conduit for PFAS to travel long distances. You know, in the beginning, if- if what we know now, yes, I—we would've Page 4 �been expanding those sampling areas from the get-go, making them bigger. But in the beginning we— when we were taking this, okay, you start on site and then you step out and then you step out more, and then what happened was, you know, word started going around and then people were mad that, you know, well, why isn't the state or the health department coming to tell us about this? Why am I finding out from my neighbors? Or, you know, there were law firms going around, right, knocking on people's doors, and that really was difficult personally, um, for me to deal with, with people having that anger. You know, it felt very personal to me, to the department, that we weren't doing our jobs, when at the time we thought we were doing our jobs based on how other contaminants behave, based on other projects. We had never, um, dealt with anything like this. So we- I tried to take that and not- and not take it personally 'cause I knew these people, you know, these residents were not mad at Karen Vorce, they- they were mad at the situation that- that this is- that this has happened and that they have been unknowingly drinking PFAS and subjecting their families and their children and- and things to this. And so taking that, um, not taking things personally, but wanting to be an agent of change and an agent of help, to help the residents was what I started to focus on and really empathizing with them and- and- and putting myself in their shoes because yes, I was experiencing my own emotional and psychological issues with dealing with this PFAS and being a first, you know, "emergency responder" to this, which has its own types of kind of stress, but, you know, I—it was nothing compared to what people who were exposed to this and drinking it were having to deal with, and I just kept reminding myself of that. Um, and so what we learned, I think one of the main takeaways from our Wolv—as a regulator from- from Wolverine, a) transparency is extremely important to everyone, um, especially the folks who are—may or may not be impacted. So making sure you're, um, transparent and honest, even if you don't know the answers, saying you don't know the answers and that, you know, this is what we're trying to do. B) Having a robust communication plan with how you're going to reach out to residents, how you're going to have enough people to go door to door to let people know, um, using local municipalities, uh, email blasts, using different ways to reach people through social media, through door hangers, through mailers, multiple ways, 'cause some people like their information different ways, but really making sure—you're gonna think you're overcommunicating, but you're—but to some people you're still not communicating enough. So until you feel like you're communicating too much, you're not communicating enough when it comes to sites like this. Um, so that was something we learned 'cause we really had to up—the state really ups their game, if you will, on communication and public outreach based on PFAS. It was definitely lacking, um, before this. [SNIFFLE] The—and th- the residents of this area helped facilitate that change 'cause they- they were the ones who were able to point it out to, I think the agency, to say, "Hey, you know, I'm mad that I found out from my neighbor, or I found out from someone knocking on my door,and I didn't find out from the state," like, how can we make sure this doesn't happen again? Okay. So that was kind of a humbling and important learning aspect. Um, another one, especially when we're dealing with emerging contaminants and I kind of, so I said, um, [LIP SMACK] communication is pooling your resources. So I understand not every state has the same resources as Michigan, uh, every- every environmental, you know, agency, but Page 5 �really reaching out to neighboring states or reaching out to other divisions or even the federal government, putting your head in the sand and saying, you don't have the people to address the problem isn't going to solve the problem. You need to be vocal that you don't have enough resources, that you are concerned. That's how you get funding and that's how you get people involved, and you get legislator— legislative change, and you get more funding in state budgets, and so being- not being afraid to be vocal about that, to show your "vulnerabilities," as a state agency, I think a lot of agencies are afraid to do that 'cause they don't wanna look like they can't do their job, right. And you don't wanna scare people, like, oh no, my- my state agency isn't equipped to handle this. Well, no we didn't—of course not, like we didn't know about PFAS and no one really expects that 25 square miles of somewhere is going to be impacted. So, you know, you- you- you plan for the worst and hope for the best, but we really need to be—PFAS showed us we need to be prepared for things like this and don't be afraid to ask for help, and don't act like you know all the answers 'cause you're—it's gonna be pretty obvious that you don't. So we are- we tried to be pretty humble and open and honest in the beginning in north Kent, and I think that went a long way with the residents as well. Um, so those are kind of my three main, um, I guess suggestions to other regulators. And you know, we learned—we had to change a paradigm, our thinking of how we address sites of contamination, where before, and this was some of the frustration in the beginning that residents had, they were like, "Well, why are you starting on the source property with groundwater sampling and then stepping out, like, why aren't you out sampling all of the wells?" And so we had to explain, well, normally in order to know where to sample the wells, we need to know, like, groundwater flow at the site, and we need to know what the source is and, like, what the local geology is, so then we can, like, better pinpoint, you know where to sample and understand it. And then—but then in the public side and in some cases depending on the concentrations, you kinda had to go ahead of that, and you can't wait for thatthat HydroGeo investigation to happen. You have to go to the- to the receptors now and sample, and you may have to sample more than you thought you would, or you may- you may over-sample, but, hey, at least you're sampling. I'd rather over-sample than not sample enough and- and do it in a timely manner. So there definitely is an expectation, um, that you prioritize the drinking water response over the science or the academic or the hydrogeologic, which in some cases is difficult because we need the hydrogeology to tell us where it's going and where to sample, so you have to use your best professional judgment, you have to use your—the tools you have, the digital resources, best inferred groundwater direction, right, yet you gotta kinda think on your feet and- and- and do things that way. So that was obviously difficult to figure out in the beginning as you're going through this. Um, we had, in the beginning of this, um, we did call in our incident managers that we have here, our environmental, um, emergency incident managers, that we have in our Remediation and Redevelopment Division here at Eagle. So each district of RRD, Remediation and Redevelopment Division, um, has an incident manager. They all came from across the state [CLICK SOUND] to north Kent, when this started blowing up in 2017, um, to help us because this was getting to be so big and so large, and there were so many things we needed help. I- it was just me and one other colleague and my supervisor trying to field all these calls and address all these things, so Page 6 �we needed help. So we pulled in, we were able to pull in extra resources. Um, making sure you have open communication between the local, state, and federal health agencies was really crucial and the local—or the state and federal environmental agencies. So everybody was kind of at the table and everyone kinda had their lane, if you will. We started figuring out, okay, Eagle, this is your job to- to figure out where the contamination is, identify wells that need to be sampled, get the contractors out there, oversee Wolverine doing the work, um, make sure it's being done right, QAQC stuff. And then it was like, okay, health departments, your job is getting residents the results, explaining what the results mean, telling them do they need to filter, do they not need a filter? Figuring all that out was a whole thing, too, in the beginning when this was happening and who's communicating what, right. Um, that was crucial, um, to make sure that we had the right people communicating the information, who were the toxicologists epidemiologists, the health folks. Um, and- and then we were staying in our lane doing our thing and—but we were all working together, um, on the same goal. Um, so that was another huge aspect, 'cause at the end of the day, we all kinda have our- our little ex—areas of expertise, and it is tempting to kinda go out and try to boss around other agencies, but- but at the end of the day, you kinda just all start working together and get over that tur—like, this is my turf, no, this is my turf, and you just start working for your citizens, that are basically your bosses. Um, [CHUCKLE] that's what—who I work for, right, the taxpayers. So, um, that was a learning experience, and, um, you know, now- now I- I- I know who to contact if- if I have issues, you know, the health—local and state health were, like, you know, really close and EPA. Like, we're kind of all allies now from having gone through this, um, helping each other. It's not a local versus state versus federal. It's not us versus them. That can hap—I- I don't know if the general public knows that, but that- that can happen, you know, Eagles get in the way, um, you know, like, oh, the state has this handled, we don't need the fed help, or, you know, local people will be like, "Oh, the local county has us. We don't need the state's help," you know, so kinda getting in over that, those- those, um, those, you know, can- can be a humbling [CHUCKLE] experience for- for other, I'm sure states and both, they experienced similar things. Um, but I would say, you know- you know, this was, this has been—I- I call this my baby, my- my site, since I started at the state. I'm still heavily involved. I—we did hire a new, you know, project, uh, project manager [SNIFFLE] since I've transitioned into district supervisor work, um, but, you know, people from the beginning told me this is a once in a career type of issue or- or site or- or experience. When I first started, I didn't really realize that. I thought, Oh, this is- this is its normal to work, you know, have- have- have- have public meetings four nights a week and work till nine at night, and, you know, start the day again at seven a.m., and be doing all this crazy stuff and- and- and be suing multibillion dollar companies and having, you know, mediation and- and drafting consent decrees, and, well, no, that's not normal, but, um, you know, I wouldn't trade it for anything. I- I do believe, um, that God had me come to west Michigan, for a reason, um, that I was given north Kent, for a reason. I felt very underqualified in the beginning, uh, you know, a new PM, a newbie, um, kinda had that imposter syndrome, but as- as time went on, I realized that, hey, you know, I have a whole department, I have colleagues, it's not just me doing this, it's us, it's a team, everyone has their part, and I just really started focusing on the Page 7 �people and the outreach and the empathy and caring for, you know, the residents. Um, and I think at the end, you know, just focusing on your strengths, you don't need to know everything as a regulator. You have resources. You have people and experts to rely on. That was also a, um, [SNIFFLE] something I learned early on in this project. Danielle DeVasto: What a way to start, huh? Karen Vorce: Yes. [LAUGHTER] Danielle DeVasto: It's really that- that, like, tested by fire and— Karen Vorce: Yes. Danielle DeVasto: —hopefully it is truly a once-in-a-career situation. Karen Vorce: Yes, I hope so. Danielle DeVasto: Um, maybe looking forward then, what kinds of concerns do you have about PFAS contamination, moving forward? Karen Vorce: Yeah. Um, definitely I have concerns. Um, you know, as- as a mother now, when I started this project, I wasn't a mom, and, you know, went through this and- and now I- I have a one and a half year old, um, so I can empathize, uh, a lot better, too, with- with folks who had children who have been affected by contamination, you know, imagining my son drinking it or- or having been nursed on, you know if the mother was ingesting it- it tran- transmisses through- through breast milk and when the baby's developing and- and things like that. So I really worry. I really am just concerned, you know, especially always thinking ahead to the next generation, how can we reduce exposure to them? Um, and I'm really excited to see some states now, um, are banning certain products with PFAS, certain food- food packaging, um, you know, certain—I- I swear I read somewhere certain consumer goods won't be— clothing won't be allowed to have PFAS in it with—and something in New York City, I have to dig into that more. Um, you know, the- the more we can eliminate when we really don't need it, if we really don't need something to be waterproof or to have specifically these compounds, these PFAS compounds in it, let's eliminate it. Like we don't need it in dental floss. I'm pretty sure I can still use dental floss without having PFAS in it. I'll be fine with it, even if it's a little bit stickier, I don't know. [CHUCKLE] Like, um, you know, kind of just- just re-thinking our- our, um, 'cause- 'cause I understand, the manufacturers play their part, right. The- the- the capitalistic selling of things, it- it all plays its part, but at the end of the day, consumers have power, too. We have a lot of power, um, as- as consumers, and we need to be vocal with our dollars and what companies we're supporting and with our- with our legislators of what kind of legislation we wanna see in our states to foster positive change of prohibiting, you know, these products from coming into our state that eventually is gonna end up in our landfill, right, um, and end up in our environment. So I'm really excited to see the legislation and policies starting to get put in place little by little. Um, I know it'll be a long challenge, but, um, that- that is kind of a positive light. In- in the more health studies that we have done right now, there is a multi-site health- PFAS health study happening in Michigan, north Kent's involved. There's a- another site in south, uh, southwest Michigan, involved, um, and other state—other sites across the country in that as well to better understand the health, um, and document the health Page 8 �effects of exposure to PFAS and at what levels, what may you see certain adverse effects of, you know, anything from cancer to hi- high cholesterol to, um, preeclampsia, uh, things- things of those nature. So really getting a better understanding of that, I think is crucial, too, so, um, we can just spread that knowledge, so people can make informed decisions. So we know now Teflon pans with PFOA and others, some other PFAS compounds, not a good idea. So let's let consumers know that, so they can then use stainless steel or alum— you know, what different types of pans. Yes, it may not be as great for eggs, but, you know, you can- you can deal with a little bit of eggs sticking to your pan if you don't wanna eat PFAS, right? Um, you know, letting people make—being informed to make decisions about how much—at least having some control over how much PFAS they're being exposed to. I just bought a new couch for the first time 'cause I've been using hand-me-downs from family for a number of years. First question, is this Scotchgarded? Like, please, I do not wanna buy a couch that has Scotchgard or any stain-resistant treatment on it. No, it wasn't. Oh, and it's filled with recycled, um, [LIP SMACK] pieces of couches that didn't work or, you know, the filling from other—like it's recycled material on the inside. So that's even better. Cool. Okay. So making, like, decisions like that to- to eliminate, you know, your furniture, sheets, you know, clothes that really don't need to be waterproof, you know, do you really need GORE-TEX or, you know, that water repellency on those. Little decisions like that, um, but also making sure your representatives in your, um, states, your federal representatives, understand that you want, um, policy and laws that protect citizens from exposure to these that make- make us aware when things— when PFAS is in- in products. Like, trying to know all the different trade names is really difficult. I'll even try to read labels, and I'm like, I can't even tell if this is a PFAS, like, what is this, I don't know. So having better labeling, you know, there- there's things that can be done that I think, um, will start happening that are going to at least make things a little bit better for the next generation, um, so we can at least learn something from- from all of this, right? That's- that's kind of what we need to do as our responsibility, um, with- with having this knowledge. [SNIFFLE] Danielle DeVasto: And gives concrete things that we can do, instead of— Karen Vorce: Yes. Danielle DeVasto: —you know, as you pointed out, sometimes this is pretty overwhelming and— Karen Vorce: Mm-hmm. Danielle DeVasto: —widespread, far more complicated than we imagine, but— Karen Vorce: Yes. Little things we can- we can- we can try to do to make change. [SNIFFLE] Danielle DeVasto: So before we wrap up, Karen, is there anything else that you'd like to add that we haven't touched on today or anything you'd like to go back to and say more about? Karen Vorce: Hmm. I'm sure there is. I could definitely talk all day [LAUGHTER] about- about PFAS and north Kent, and just the experience and, um, and, uh, you know, the good and the bad 'cause as- as much, you know, sadness and, um, obviously harm that this contamination, um, has caused the residents in Kent County. [SNIFFLE] Um, you know, I don't- I don't let that over-shadow the, um, the good that's actually come out of this, in that I've met a lot of people that I never would've met, friendships have been Page 9 �made, um, being able to- to feel at the end of the day that you're making a difference, um, and- and helping people, um, and- and passing that on to others. It- it really feels like the citizens here have also, you know, they've really stepped up to be, like, leaders in- in this fight against PFAS, um, to- to talk to other states, to other affected communities, and seeing that, um, just has been really inspiring as well, just- just people knowing, like, you don't have to be in a position of authority. You don't have to just—you don't have to be working for an agency or- or whatever to- to be teaching people about PFAS or about your experience. Like, anyone can- can talk to people, you know, just even it—it doesn't matter what your day job is, right. If- if you've, you know, been ex—if you've been exposed to PFAS and especially folks in Kent County who have been through this, um, you know, I think it's invaluable for them to kinda reach out and- and be there for- for the other people who are going through this, um, in other communities here in Michigan. So that's- that's been pretty amazing to see, [SNIFFLE] um, to see that happen as well. Um, and I think, you know, it's always important for- for us to have our lessons learned, to learn from them, to admit when- when things could have been done differently, you know, even- even industry, right? We had industry standards and practices back in the 1940s, and '50s, that were vastly different than what we have today, right, and so just, you know, admitting that, understanding that, and trying to address that. It's- it's- it's not necessarily in all cases, like, I gotcha, like, ooh, I'm gonna- I'm gonna get those- those evil corporations, right? It- it's about, okay, I understand, I totally get it. Things were different back in the day, right, but if we know things were different, and we know there was contamination in our waste streams, companies do have—should be thinking about their historic operations and where there could be other "House Street Dumps." I know—you know, anyone listening to this to who may be a CEO of a company, you know, [CHUCKLE] or know a CEO who runs a company and- and, you know, you really need to look at- look at your company and your heart to say, hey, are- are there skeletons in the closet that I need to address, because you're gonna be living with that for the rest of your life, knowing that you ignored something and potentially hundreds of people have been impacted because of that. So that's also kind of a warning [CHUCKLE] that I'll give- give to folks, um, to, hey, just- just be- just be honest. We're- we're not dumb. People who aren't in your company, we can see through things. We- we know, and the more proactive you're going to be, the more people are gonna wanna work with you, the more collaboration you're gonna get, and, you know, you could really turn this into something that, um, doesn't have to be, you know, a fight, um, to get things done. So that- that's something I'll- I'll just throw out there as well. Danielle DeVasto: I mean, throughout the—this conversation, that theme of relationship seems to kinda— Karen Vorce: Mmm. Danielle DeVasto: —keep cropping up in your story in different ways, the different kinds of relationships that you can or have, or could build— Karen Vorce: Yep. Danielle DeVasto: —seems really important. Karen Vorce: Definitely. That's a good point. [CHUCKLE] Page 10 �Danielle DeVasto: Well, thank you so much, Karen, for taking the time to share your story today. Karen Vorce: Yeah, thanks for having me. I appreciate it. And thanks for doing this project. Page 11 � 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 PFAS0035 Creator An entity primarily responsible for making the resource Vorce, Karen Date A point or period of time associated with an event in the lifecycle of the resource 2022-01-13 Title A name given to the resource Karen Vorce, 2022 (Interview video and transcript) Description An account of the resource Karen Vorce is a geologist who lives in Walker, Michigan and works for the Michigan Department of Environment, Great Lakes, and Energy in the Remediation Redevelopment Division. In this interview, Karen discusses her work with PFAS contamination sites in Kent County, as well as how her concern over PFAS have impacted her family and personal decisions. 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/25c314b9654a34509ff2c59a7c874a46.mp4 3a79e52cea8d4d954d85b9f2b7d67179 https://digitalcollections.library.gvsu.edu/files/original/6406ae1b9118fd892e2c0cb2d2a8d8df.pdf a8682d79f16cd6d4b12aaaa5df014196 PDF Text Text Living with PFAS Interviewer: Danielle DeVasto Interviewee: Alan Eberlein Date of Interview: 2022-11-29 Danielle DeVasto: I'm Dani DeVasto, and today, November 29, 2022, I have the pleasure of chatting [BANG SOUND] with Al Eberlein. Hi, Al. Al Eberlein: Hello. Danielle DeVasto: Thank you for having me over to your house today. Um, Al, can you tell me where you're from, [CLICK SOUND] and, um, let's start with that. Where are you from? Al Eberlein: Right here in Rockford, born and raised. Danielle DeVasto: All right. So you've been here a long time. Al Eberlein: Yep. I grew up as a child on Myers Lake and went to Rockford Public Schools and then resided within a couple miles of town, or in town, my entire life. Danielle DeVasto: That's truly something. As someone who's moved around a lot, I wish that I could— Al Eberlein: Which is more the norm now than not. Danielle DeVasto: Unfortunately, yeah. Um, Al, would you tell me a story about your experience with PFAS or with PFAS in your community, please? Al Eberlein: Well, it's a funny thing because it's an unfolding story, right? And I lived through it, not knowing I was living through it for many years. Like I said, uh, went to Rockford schools, went to the junior high school and the high school here. Um, lived around, uh, Rockford, uh, for a number of years. Um, uh, my first home was a- a mobile homesite, uh, at Algoma Estates, [CLEARING THROAT] which I lived with several years after I was married in 1980, with my wife, Lori, and, um, as we were discussing earlier, uh, lo and behold in future years, I found out—and we always knew that it was something not quite right about the water there, uh, but we were close to the 12-mile dump because Algoma's off of 13 mile, and the 12-mile dump was, you know, backed up to that. And, um, [LIP SMACK] so I'm sure that we were probably drinking water that wasn't too great then. And, uh, we had our, uh, first child, um, there, uh, when we lived in Algoma Estates, Matthew, uh, in 1982. And, um, it was a- it was, um, [LIP SMACK] a strange birth. Matthew was, uh, born with what they described as immature lung- lung syndrome that you nor- normally don't experience unless a child is, like, two months early. His lungs were that bad or worse, but Matthew was full term. He was almost eight-pound baby, and they said they never had seen that before. Um, so, consequently, he almost died. Um, he was in neonatal unit in Grand Rapids, for two weeks and, um, he did pink up right away. For hours and hours after he was born, he was purple and, uh, he pulled out of it miraculously, um, [LIP SMACK] but consequently, uh, it left him with a lot of problems. He had episodes of schizophrenia, uh, odd, uh, feelings in his body, like his spirit was half out of his body. Um, uh, we tried some therapy with, uh, Wellbutrin and, um, [NOISE] Ritalin to try to help him, uh, control his thoughts, but they didn't work for him. Um, so anyhow, uh, they barely got him—kept him mainstream through, uh, grade school, and once he was junior high, and after, he ended up in special ed and unfortunately kids like Matthew, they fall through the cracks. They're not bad enough to be, you know, Page 1 �sent off to Kenosha, or something, but they're—they try to mainstream 'em, and they have a couple hours in special ed and put 'em in a regular class, and they're, you know, how children can be cruel and- and it was a terrible experience. Um, he was a very melancholy child and, uh—because by the time he got to high school, uh, he started self-medicating with alcohol, dropped outta school, and we didn't even keep alcohol in our house, but he sought out his own medication. And, um, consequently, he died at 24 years old, uh, from alcoholism. Well, like I say, he was born in, uh, '82. In 1986, we tried again for a child, uh, Christopher. And so we moved back into town in—before he was born— Danielle DeVasto: Into Rockford? Al Eberlein: — into Rockford, on Lewis Street, on the Wolverine plat, north of town, in an older home, and so that my wife could afford to stay home with the baby. And so consequently, Christopher was born a little early, not a lot, a little, and he was rather small birth weight, he's—but not terrible. He was about six pounds, and they thought he was normal at the- uh, at the moment he was born, but it quickly became apparent that he was not thriving, and they couldn't figure it out. Finally, after about a month or so, a geneticist in Grand Rapids, said, "Um, [CLICK SOUND] I can't tell you what's wrong with your son, but I'm heavily suspicioning that there's something wrong with him, genetically. Um, I think you should go to Chicago, uh, Children's Hospital." So we took Christopher down there five different times, and they did studies, and actually they did workups on Christopher. Uh, he's actually in a journal someplace. They took, uh, pictures of him, and he was very unusual and the best determination that they could come up with is they said, "Well, he sort of like neonatal renoleukodystrophy," and I go, what in the world is that? And they said, "Well, that's [CLICK SOUND] where the protozoa in the cell structure is low, and the ones that are there are deformed." So what does that mean? Well, the body does not have a good capability of dealing with heavy metals, like, uh, copper and so forth. And so as the months went by, all this kinda built up in his brain and damaged his brain. He lost his eyesight and, uh, he didn't thrive. He didn't get nutrition out of food well, and, um, they said he would only live two months, but, um, we loved him and took care of him, ended up having to feed him with a stomach tube, and we kept him alive for two years and two months, and gave him the best life that we could give him. But I remember them saying this towards the end of- of the time that we went to Chicago, at the Children's Hospital, and they said, "You know, there's several different kinds," that they had, uh, described at the time of- of that disease, but they said, "Christopher's really not like any of them, he's like his own thing." There again, both with Matthew and with Christopher, nothing remotely like this in my wife's family history, our family history. This was just crazy stuff out of the blue. So [SIGH] my daughter, Sarah, was born in 1992, and, uh, she was, uh, it seemed to be a normal pregnancy, and then all of a sudden my wife started having trouble and, uh, Sarah came, uh, two months and two weeks early. And, um, anyhow, trying to keep a long story shorter, [CHUCKLE] um, we, uh, you know, we, of course we were worried about these other things and, um, but I had a month old. They said, "Well, you know," they- they were worried about the Christopher disease, the neonatal renoleukodystrophy, but it- it didn't seem to, uh, manifest itself. And we don't know why she was born early. We don't know why she was red when she came out, but, um, she seems to be doing better Page 2 �now. So Sarah grew into a nice, healthy, young lady and, um, she got married at 21, and shortly thereafter, um, she got pregnant for my granddaughter. Well, my granddaughter's, uh, pregnancy seemed to be normal, and, um, along about six or seven months pregnant, my daughter said, "Dad," she goes, "Something's wrong. I'm just profoundly tired." And of course they checked out her iron and all the-, you know, the normal things, and, "We can't find anything wrong and your blood pressure's okay, you know, we just, you know, probably some people just get more tired than others, you know, during." She goes, "But dad," she says, "They're not listening to me. This is profound. I can hardly keep my eyes open." Lo and behold, the day that her water broke, and she went in for labor, she started hemorrhaging, and I mean, profuse blood loss. And she actually almost died twice, and they were pumping fluids into her, plasma, trying to keep her alive. And, uh, she basically died twice, and it was, uh, a rare form of, uh, HELLP syndrome. There again, no sign of it, neither side of the family. And, um, [CLICK SOUND] she actually saw her gr—, uh, deceased grandfather in the room, smiling at her, waiting for her to come to heaven with her- with him, but they pulled her through. And by-by golly, they saved my granddaughter, and they said for that to happen right at birth, it's almost very unlikely that both of 'em were to live.They said usually if you can save one or the other, [CHIME SOUND] you've done—you've had a good day, and they saved them both. My daughter was very weak. It took her over a year to get back on her feet. Uh, psychologically it did something to her because she still gets tired. I think it's mental. I think it's mentally tired. Um, it- it- it really goes deep into you. So anyhow, my granddaughter, we thought she was perfect, you know, beautiful little girl, and, um, went in for a two-month checkup, and they says, "You need to see a specialist. Something is wrong with her." And you know, here, my first son, second son, my daughter, and now my granddaughter, oh, what's wrong? "Well, we think she's not seeing good, and you need to see a specialist." Well, unfortunately my son-in-law was in the Navy, and he said, "Well, we're about ready to move." And my daughter, he was gonna deploy outta San Diego, and my daughter was coming back here with my granddaughter, uh, while he deployed for six months. [SNEEZE] Well, God bless Helen DeVos Hospital because they got down to brass tacks and figured it out quite quickly. What they missed is that she had cataracts in her eyes, but they weren't normal, I say_ normal cataracts that are more visible on the outside of the eye. These were deep with inside the eye. And they said it was rather unusual. And, uh, so they operated on her, got the cataracts out, and here she's just a lit—by this time, I think Natalie was five months old, and, it's so hard to have, when children to have to have operations right off the bat, it's—and she, you know, suffered through that. And then they, [CLEAR THROAT] she had these really thick glasses that we tried to put on her, and, um, also we had to force contacts into her eyes so that she could have enough imagery, you know, but still be fuzzy, but that she could—her mind could develop. And, um, that got actually very arduous 'cause by six, seven months old, she could fight back, and I actually had to leave the house because she would scream and fight not to have those contacts forced in her eyes. Well, they can't put lenses in a little baby's eyes right away, 'cause the eyes are too small. And they said, "We would like to wait at least till six, five, six years old." [NOTIFICATION SOUND] Excuse me, we will delay that message. Page 3 �Danielle DeVasto: Would you like me to pause? Al Eberlein: That's uh, that was my daughter. [LAUGHTER] She must have knew I was talking about her. Danielle DeVasto: She must have felt it. [LAUGHTER] Al Eberlein: So consequently uh, they—we had to wait till she was over two years old to put lenses in. So my beautiful little granddaughter, so she ended up having six surgeries all together. And they put the lenses in finally, and oh, what a joyous day that was, and the next day. All of a sudden, my granddaughter discovered going outside and said, "Oh, grandpa, look at the clouds," and she could see relatively clearly for the first time. And- and uh, we were so happy and overjoyed for her after all the torment she went through, and we could see her starting to regress. We could see her starting to act like she did before, when she didn't see good and straining her eyes. And so we called up and said, "Well, you better bring her back in." And so we took her back in and, um, they said, "Oh, we got bad news. Her eyes are rejecting the implants." And I said, I thought you said this, eyes, that this material- material you use, that the body doesn't reject, and they says, "For some reason, hers is." So they had to take the- the, uh, implanted lenses back out. And that was one of the worst days of my life, right up there with my two sons dying. And sh—I wheeled her out to the car, and she balled all the way out going, "Grandpa, I can't see, I can't see." And I go, oh honey, I says, we're gonna fix it, hoping that we could. Well, we—the doctors had a form online just to see if any other eye doctor in the nation, and even other countries, had any suggestions because Helen DeVos had run out of ideas, and that's a bad place to be. So we had everybody praying. [LIP SMACK] One man, I'd like to meet him someday, I'd like to know who he was, one man responded, and he said, "I had a- an adult patient once that had that exact thing happen." And this was one particular, really strong steroid, he says that worked for her. He said, "I've never used it on a child," but he says, "You don't have anything to lose." So we did it, and by golly, it worked. And so she's been progressing. She has to come every six months and be checked out, but from that second set of lenses, um, her- her eyesight has held and uh, you know, every time she gets checked though, you know, we've had so much trouble and turmoil that you always kinda tighten up a little bit, you know, and they come back and say, "Oh, her eyesight's even a little bit better," and I go, oh, thank God, you know. But, yeah, so my experience, you know, is—in our life is two sons with strange diseases that died, my daughter that almost died, and her daughter that almost died and almost lost her eyesight. So to find out—so like I said, it's like an unfolding story, right? We—I lived through all this when we know that in the '70s and '80s, and so forth, that the PFAS was being dispersed all over. And one thing that doesn't get talked a lot about, this river out here, the whole bed of that river that I—you dig down in that mud, and I'll guarantee it's got layers of PFAS in it. Our water, city water here in Rockford that, well, there's about 4,500 of us now that live here, they were getting all the city water out of the Rockford Rogue River. Who's talking about that? The water that I drank in high school and junior high school, and that I drank living all the decades that I lived here in town. Yeah, it was a horrible thing they did, burying it out in the countryside, and I have relatives that got poisoned by that. But in hindsight, and working at Wolverine Page 4 �Worldwide for 31 years and seeing how they used that strike to try to close the tannery down, I believe was nefarious that they wanted to cover up their sin. Danielle DeVasto: Can you—do you want to say anything more about the strike? Al Eberlein: About the strike? Danielle DeVasto: Yeah. Al Eberlein: Yeah. Danielle DeVasto: Or your experience at Wolverine? Al Eberlein: Well, my grandfather worked—my great-grandfather worked at Wolverine for 54 years. Nobody ever worked there longer than him. He was hired by Otto Krause back in 1903, when it was family own. And you know how it was back in these—that—those days of small towns and, you know, Wolverine was a big business, see, I mean even then for a small town, and, um, my grandfather went to work there at 16 years old. You know, times were hard back then. There wasn't safety nets, you know, and, um, people were glad to have a good job. He could walk to work. He lived on Main Street. His grandson, my cousin, still lives in the same house that my great-grandfather lived in. And, um, when times were hard, um, uh, in- during the depression, uh, several times Otto Krause came and said, 'Boys, I- I don't have money for payroll," but he says, uh, he said, "If you stick with me," he says, "I'll gladly pay ya in company stock." And my grandfather held onto that stock his whole life, and it divided. And, uh, my grandmother inherited a portion of it, and she gave it to all of us, her grandkids, that came from my greatgrandfather. You know, it was, like, a heritage. And you felt good about—we felt good about Wolverine back in those days, you know, in the old days. And, um, geez, half my relatives worked at the company. You know, it was a stepping stone company that a lot of people—my mother worked there in the office for a year or two, you know, to help buy a new car. You know, it was nice to have a big company that, you know, could facilitate and help out the local community, and everybody always felt good about it. And, uh, when I first started working there, uh, in the early '70s, um, there was still a—Wolverine was corporate by then. It went corporate, I believe in the '50s. And—but there was still, you know, oldtimers that- that worked there. There was—I remember one old guy that remembered my great-grandfather, you know, 'cause my grandfather worked till 1957, from '03. I started working there in- in '72, and I worked there 31 years, but I- I remember, oh, I remember your grandpa, Platton, you know, and- and just that continuity, you know, of community and the work and the pride that our little town, you know, is known worldwide for Hush Puppy shoes. And I personally—I was the dye maker. I- I made, uh, [SNIFFLE] I made dyes that made shoes for, uh, Shaquille O'Neal. [LAUGHTER] You know, hi- his personal loafers, you know, and I thought, you know, I made, uh, I made running shoes when- when we owned Brook's, uh, Running Shoe. I made running shoes for Greg Myers, you know, and- and you had pride in that, in- in our little town, you know, that all this wonderful stuff coming out of our little town and from my perspective, the way that, and this is my opinion, you know, this is the way I perceive it, but that because of PFAS and corporate greed, that they didn't have any problem covering it up, even though it was still currently poisoning people. When 3M told Wolverine in the '90s, that this stuff causes cancer and childhood, uh, diseases and maladies, Page 5 �okay, now I just gave you my testimony about all the childhood maladies that me and my sisters and my brother, who never had any children, he did end up adopting, uh, boy, that's a lot of damage. And for them, that's at the point in the late '90s, where I have a bone to pick with Wolverine Worldwide because they had to be forced to make penance for what they did to the people out in the countryside. How about people like me that lived in this town most of my life in or around the town and all of my—two of my sons are in heaven. You know, I got a—my daughter almost died and had extreme trouble. My granddaughter almost was blind. I mean, I could say if I wanted to be bitter person, I could say you owe me at least a million dollars. I know I'll never get—that would just be a token. That would be a token, you know? But, no, I'll tell you the strike was—so what happened. You see all this was happening at the same time. 3M tells Wolverine Worldwide, oh yeah, you know that stuff's bad. So what do you do? Did you come clean? No, you tried to cover it up. That's what you tried to do. And I believe with all my heart and that's why, you know, there's times in life I- I didn't like my career, I loved my career. I loved the people I worked with, you know, and you made my life a living hell by your corruptness, you know. And like they always say, even, like, with Watergate, the coverup is even worse. If you said, "Oh, we didn't know back in the '70s, and '80s, that this Scotchgard and all this stuff was so bad, oh, geez, you know, and that we went out to farmer John and paid him 40 bucks or whatever to dump it in his back acres," you know, "Oh, what can we do to, what can we do to make it right?" No, you didn't care about making it right. You cared about covering up your sin. They recorded their 12th record profit that year that they drove us out on strike. And why do I say drive us out on strike? Because they came to us with a proposal. They wanted to take a dollar an hour away from us across the board, a dollar an hour. Well, listen folks, I was their dye maker. I'd been their dye maker for 31 years, saving all their shows for 'em and everything, and I never made- I never made $18 an hour. So it wasn't that we were so greatly paid, and I'll tell you what, those guys down there, you know, I don't know what the average wage was, but I know a lot of those guys, their base pay was, you know, $13, $14 an hour, and if they worked real hard in that stinky place that, you know, they could make 125% sometimes on piece rate, but they worked hard in horrible conditions, horrible conditions. And they want to take a dollar an hour away from us while they were posting their 12th record quarter in a row. [BANG SOUND] Do you see how egregious that is? Well, geez, who would do something like that? Who- who would risk throwing away people? I- I, like I said, 31 years, that was on the- the small side of things. Man- many of those guys had 38, 40, 42 years. One guy had 45 years in there as a loyal employee, and they were throwing us away like yesterday's news. Who would do something like that? Oh, yeah, I can see a motive. Somebody that has a greater sin, they're trying to cover up, that's who would do something like that. That's exactly who would [BANG SOUND] do something like that. And you know, back then [SNIFFLE] we didn't- we didn't understand the PFAS thing in- in 2003. We didn't really understand what was going on yet, but we knew just by our innate common sense that something was terribly wrong. Something was terribly, terribly wrong. And so we stayed out on strike and I think we kinda surprised them. And we thought, well maybe when they see we've been out for five or six weeks, and of course, you know, Wolverine's a large company and that's gonna start hurting, Page 6 �hurt- hurt the profit, right? They still didn't care. I remember hearing they- they hired, uh, replacement workers. They said, yeah, we don't need you guys. And they- they kept going all through the summer and into the early fall. Well, we heard news that, um, they received back, I believe, now don't take this verbatim, but I think it was around 170,000 to 180,000 pair of boots, boots or shoes, because of inferior leather, because the replacement workers were not paying 00:27:42 ___________. Did they end the strike there? Did they try to come back to us and say, okay, okay, forget that taking a dollar an hour away, we'll give everybody, uh, 50 cents and next year you get a quarter, and we'll keep everybody happy? No. No, they were bald face as ever. No, not dealing with you. Went all the way past Christmas. And they came the day after Christmas and said, "Well, we'll take a third or so of you back." It'd give you, it was a paltry amount, I forget, 25, 35 cents, but the rest of you are gone, [NOISE] 'cause they still [BANG SOUND] wanted—had it in mind, they wanted to close that place down. I can't believe anything else. It's the only thing at that point. Now this is like six, seven months out on strike, and uh, they still wanted to get rid of us. And I knew I was gone 'cause at that point I'd done—I did an interview with a Christian, uh, radio station, and I did an interview with TV8 and I says, uh, how much is a man's life worth, 'cause most of these people, including myself, gave the best years of their life to that place, and they were throwing us away like yesterday's newspaper. I said, stark fact, while they were making record profit, there again, who would do such a thing? Hmm, somebody covering up a very large sin, I would propose. So anyhow, yeah, we had people die. So there, again, I believe they were covering up their sin. They wanted to sh—they wanted to get us—rid of us quite quickly, I believe. Uh, they wasn't counting on us, um, putting up such a fight. Of course, that got—that garnered, uh, attention from the powers that be, and because it was so egregious, the- the ones such as myself that they let go, and they finally did call us back, uh, long about the end of January, end of February, um, they- the people they let go, they had to, uh, either give a year of, uh, college or pay half of our wages at a new job for a year to help get us hired 'cause, you know, most of us were older guys. You know, I mean it- it's a sad fact, you know, there's nowhere in writing, especially nowadays, if things change so fast now in technology. You're over 50, and you can hardly get an interview, you know, especially then, things were pretty slow. So anyhow, a lot of us, uh, you know, got jobs elsewhere, and they took some of the guys back, and they worked them for, I don't know, I- I think around 2005, or thereabouts, they finally closed it down for good. And I did not get anything 'cause I was long gone by then, but I heard, and I felt a little bit good about this because we had gotten enough. We got enough sunlight shined on their darkness that they had, you know, people were watching them at this point, and I believe that the average person got $17,000 severance pay to, you know, to go somewhere else, and they had to help 'em out. Um, I was already at another, uh- uh, job shop, so I did not get any of those benefits, but, uh, [LIP SMACK] anyhow, so that all happened and then just about that time it starts being un- unveiled of the PFAS problem. And it became more and more apparent what had happened and that they were covering up this horrible sin of burying this stuff around. Oh, come to find out they had buried stuff right by the plant. Uh, I had—and afterwards, you know, in hindsight, now you start looking back and putting the little pieces of the jig pu- jigsaw puzzle together. I had a very dear friend Page 7 �of mine that used to live right next to the tannery, and he says, "Oh yeah, there was a low area there, and they were throwing all their hides right in there to fill up the low area, and then once it got full, they, you know, threw some dirt over it and covered it up." Well, that's one of the, you know, egregious areas that have been, you know, dug up and taken out of there. But that river is loaded with PFAS, from that plant sitting there. They said that- that 15 acres that sits down there now, where, you know, they quickly, you know, tore the tannery down, they were trying to, they almost had a deal going.They were going to try to build a, um, [LIP SMACK] a, uh, hotel there, if you can imagine. Oh, a lovely hotel on the river, you know? Quick, cover up our PFAS, but that dirt, there's areas in there that is one of the top toxic sites in the whole country for PFAS, and it's still sitting there. Now they've done some remediation along the river, but it's very possible with the way these people operated over the years that there could be other spots in that river, and I'll guarantee you, out there, how much PFAS over all those years do you think is lying in the muck of that river? I wouldn't eat one fish out of that river. I want—I had people park behind my house here in- in Pickett Park, and catching salmon and trout out there all the time, and I almost feel like I should tell 'em, I won't eat that stuff. That river's loaded with PFAS. And if you go down the river a little bit farther, the Rockford Paper Mill used to pump stuff. I can remember going behind the Rockford Paper Mill in- in, uh, the '70s, when I was in junior high school, and there's a pipe about that big, that was pumping red effluent right out into the river, you know. [NOISE] So we kinda got it at both ends that way, but I wouldn't eat- I wouldn't eat anything out of that river, you know. So, but let's come back to Rockford. So our water, until all this was coming out, our strike and, uh, the news of, uh, oh, there's a problem with PFAS in the early 2000s, well, what about all the people, the thousands of people that lived in the city all this year, and you fed us PFAS water. How about that? How about people like me that lost two sons andand all my families had childhood maladies, how's about that? [BANG SOUND] Where's the remediation for that? It would be real easy to be real bitter, but, you know, [SNIFFLE] time does heal to a point, and you have to go on living, right, and- and you can't live happily as a bitter person, but there is right and wrong. And I don't think Wolverine Worldwide has, by any means, has gotten to the end of their penance for what they did. And especially that they chose to do a cover-up and to throw people away that made their company for 'em because they wanted to cover up a sin. Well, that's a nice way to treat people that you've been poisoning for 40 years. See, but you have to go on. And so I just, you know, I thank God for people like you, for people like, no seriously, people like, uh, Lynn McIntyre, that actually care about people, like Wolverine used to. Oh, yeah, I got some real good memories of Wolverine. I remember when I first started working there and Tom Gleason would come down, and he wanted anybody that wanted to shake his hand. He'd look you right in the eyes, and,"Thank you for your service, you know, we truly need you around here," and maybe even have a cookie or a little holiday drink with you. It used to—it was like the last vestige of- of a good age. And somewhere in, when we started sending all of our work over to China, and we became a human resource, it became less and less. And it always happens by shades, right, less personable, a little less personable, and now all you are is a resource to throw you away like yesterday's news. And that's the way—it's a bitter pill. I definitely gave Wolverine the best, you know, Page 8 �my—I say, best years, I— that's not totally true 'cause you- you do think, you hope that you gained some wisdom, and, you know, and- and I did home care for 10 years and that was a wonderful time in my life. And I'm glad I did that 'cause it actually was a salvation for me because it really put some, uh, a deeper meaning back into my life and, uh, really did a lot of healing for how my career at Wolverine ended, with them trying to cover up their sin, you know, but uh, yeah, PFAS has done a lot of damage physically, probably mentally, to a lot of people and so on and so forth, but when companies like Wolverine go into cover-up mode, the mental and spiritual damage that they've done to people, you know, some people don't have the wherewithal to come back, and I think about those people often. I think I- I know probably a lot of 'em probably aren't even alive anymore. I- I know that, uh, yeah, there's several people I- I personally knew. There was a maintenance man down there that died from cancer at 42 years old. My friend's dad was having back problems, and he worked down there in the tannery, and [BANG SOUND] so he retired early at 54, only to find out, yeah, his back problems was he was loaded with cancer. And I think that had been repeated with maladies and cancer, people that worked down there over and over again, you know, and uh, so I just hope at some point, you know, we keep moving into the future, right, and then you get into, if I went up to Wolverine now there's probably not even anybody up there that I— even remembers me, or it's a whole new set of people. And you would- you would hope at some point they say, okay, you know, we know that our company, you know, probably did some wrong things, did things the wrong way, and we just- we just want to do whatever it takes to give us that good reputation again, and- and so forth. But, uh, yeah, I— for—looking back in hindsight over my life, after I knew all the facts, yeah, PFAS did a lot of damage. Danielle DeVasto: So then looking forward, what concerns, if any, do you have about PFAS contamination, moving forward? Al Eberlein: Well, for one thing, like I said, I believe it's- it's damaged my lineage. How- how long is it- is it going to keep doing that, you know. Oh, you know, are we still learning? I- I hope the science is- is still gonna find out more and more of, or how can we head things off at the pass, maybe. Like what happened to my daughter with th- this rare form of, uh, preeclampsia. How can we get, you know, more proactive about things like that? And on Wolverine side, I'm not convinced that they've totally come clean yet. I'm not convinced that that whole river is- is remediated yet. Um, and should people like me that lived here all my life, you know, is- is there any compensation for us, you know, is there, or- or any, uh, health benefits or anything? You poisoned this whole town, Wolverine. You poisoned the whole town. Nobody even talks about it. It's kind of convenient how big business and even, you know, unfortunately gov—you know, government, city governments, this little town that was all beholding to Wolverine, how they can kowtow down to money, but just a thought, you poisoned the whole town, the people that made all your money for you. [BANG SOUND] Danielle DeVasto: [SIGH] Big thought. Um, [CLEARING THROAT] before we wrap up, is there anything that we haven't talked about that you'd like to touch on or anything that you want to go back to and say more about? Page 9 �Al Eberlein: Well, there's other things I could say, you know, but I better not, you know. I don't want to get into other people's business, you know. But I'll tell you, like we were talking before you turned the cameras on, just want anybody that might s—watch this or- or maybe even somebody from Wolverine that would look in, do you really realize how deeply and generationally that this kind of thing affects people? And I would think going forward, any good thing comes out of this is that you would double, triple, quadruple down. Never, ever, ever let anything like this ever happen again [THUMPING] because if we don't learn that lesson, then what are we doing here? [NOISE] Danielle DeVasto: Thank you so much, Al, for taking the time to tell your story. Al Eberlein: You're welcome. And once again, thank you for caring, 'cause we've gone through a lot of years where it didn't seem like too many people were caring, and I'm glad to meet people such as yourself and Lynn McIntyre, to know that there are people being vigilant out there, and, um, [LIP SMACK] and, you know, I mean it's- it's all over, and it's not just one thing. Um, like I said, I grew up on Myers Lake. They just found out here recently. I mean, I swam in that lake my whole childhood. Oh, guess what, there's mercury in Myers Lake. Where did that come from? Some business at some point dumped something in there, you know, so how many times can we exponentially extrapolate that out to the countryside? You know, it's like there's landmines all over the place. And uh, so I- I don't think this is anything that's gonna be solved for a long time 'cause we had a lot of industrial years where, I mean, EPA didn't even come about to what, late '60s, into the early '70s, so, you know, it's, uh, we're just kind of getting on, excuse me, on top of a lot of these, uh, more egregious things, you know. But, yeah, do I believe PFAS damaged my life? Yeah, more ways than one. Career wise and personally with my family that even has come into the future with my daughter and granddaughter. And after she had all that trouble with preeclampsia and with the D&Cs that she had to have afterwards that, um, they scarred her for life, and she can't conceive now. So I've got one grandchild, and [KNOCK SOUND] hopefully they'll adopt someday 'cause we got a lot more love to give. Danielle DeVasto: Yeah, absolutely. Well, thank you again, Al. I really appreciate it. Al Eberlein: You're welcome. Danielle DeVasto: It was an honor to listen to your story. Al Eberlein: Well, thanks for saying so. Page 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 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 PFAS0034 Creator An entity primarily responsible for making the resource Eberlein, Alan Date A point or period of time associated with an event in the lifecycle of the resource 2022-11-29 Title A name given to the resource Alan Eberlein, 2022 (Interview video and transcript) Description An account of the resource Al Eberlein lives in Rockford, Michigan, where he was born and raised. In this interview, Al discusses his family's history and medical troubles which can be attributed to PFAS exposure. 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/6fb64d87b8d476cfa944fa70ab9b59b9.mp4 63e6db84b89e7ecd037c554b4b98ba5e https://digitalcollections.library.gvsu.edu/files/original/ac530960811b9ba2a67ae1b77ab770c3.pdf 46047858a4641a92b9e986e19f81f7b4 PDF Text Text Living with PFAS Interviewer: Danielle DeVasto Interviewee: Courtney Carignan Date of Interview: 2022-11-18 Danielle DeVasto: I'm Dani DeVasto, and today, November 18, 2022. I have the pleasure of chatting with Dr. Courtney Carignan. Hi Courtney. Courtney Carignan: Hi Danielle DeVasto: Courtney, can you tell me about where you're from and where you currently live? Courtney Carignan: I'm originally from New Hampshire, and I currently live in mid-Michigan and work at Michigan State. Danielle DeVasto: Uh, how long have you been at Michigan State? Courtney Carignan: Since 2017. Danielle DeVasto: Courtney, can you tell me a story about your experience with PFAS or with PFAS in your community? Courtney Carignan: I sure can. Um, so I started actually first got involved in PFAS, um, when I was doing a postdoc in Boston, and I was living in Southern New Hampshire, um, and actually in Portsmouth, New Hampshire, which is right on the coast. Um, and I saw in the paper, our, our community, uh, news Seacoast online, there was a woman who wanted PFAS blood testing for her kids, because PFASs had been detected in the drinking water of Pease Tradeport, which is at the former Pease Air Force Base, and, um, I guess the State had told her that they would do the testing and then a year later they still hadn't done it and were saying now that they couldn't, she was getting very upset. Um, and so I actually had training in PFAS, um, I have a degree in, a Ph.D. in environmental health from the Boston University School of Public Health. And, um, I was trained in under a training grant called Environmental Epidemiology in Community Settings, and I worked on flame retardant, human exposure flame retardants, and, um, I was actually at that time doing a post doc on fertility and flame retardants at Harvard. And, um, so anyway, so I had a lot of training, and you know, how to provide support, technical support for PFAS impacted communities. And my advisor at BU had worked on the C health study. So people in my research group had been working on PFAS for, you know, the past five years or more. Um, and so I just sort of happened to know a lot about PFAS, um, and, you know, saw her in the paper. And so, um, I asked the reporter to tell me, you know, to connect us, and I connected with her and started providing her with technical support and started trying with her, the State with technical support. Um, 'cause I, you know, seem to know more about PFAS than anybody in the area. Um, and you know, Andrea went on to found testing for Pease. She was able to get PFAS blood testing for over 2000 people who worked, um, or was at, were at daycare at Pease Tradeport. Um, from that we learned that PFHXS is, which is, which is a PFAS that has a very long half life. It stays in the body for, uh, quite a long time. Um, that this was something that was part of the, astroblast mixture. So people with astroblast, source of drinking water contamination, um, have this kind of unique signature of PFAS in their bodies that, you know, at the time really wasn't understood at all. So, um, I can remember people misunderstanding the blood test results Page 1 �from Pease as, oh, well their levels aren't that high, but they were looking at PFOA, which is not a major part of AFFF. Um, and if you looked over at the PFHXS, it was quite high, you know, um, a lot of people in, in the community had levels that were elevated above, above what you see in the, the general population. So, um, I worked with Andrea for a few years, and then we helped organize the, uh, national PFAS conference. The first one that was at Northeastern University, um, we put in a proposal to NIHS, um, to do more work on understanding effects, uh, of PFAS in the immune systems of children exposed to 00:03:59 ___________ Pease and also had to community in Massachusetts. Um, and then I got recruited to MSU and I came here. Um, and since I, you know, since I came here, a few communities have learned about actually many communities have learned about PFAS contamination. Um, so I should have mentioned another thing that I did when I was at, um, Harvard is I was part of a, a group that wrote a paper, uh, using the UCMR3 data. So this is data from EPA, uh, that EPA had on PFAS across the country and drinking water. We were able to get that out and published. Uh, we found that over 6 million people had likely been served by PFAS impacted drinking water. Um, and we were able to sort of see that people were more likely to have drinking water contamination if they lived, if the drinking water system was closer to, um, a place that used Atripla for training airports, wastewater treatment plants. Um, and so that paper really, um, set off, um, monitoring in places or helped set off monitoring places. Michigan was one place that started doing statewide monitoring of public drinking water systems. Um, and that happened shortly after I came to MSU and, um, you know, that's how a lot of communities found out about their contamination, but of course, you know, um, in Rockford they had found out a different way. And I think you have a lot of videos of people explaining that situation. Um, and then Portsmith obviously found out was one of the first sites in the United States to discover PFAS contamination. Um, so I've been working, you know, with those communities, provided them with technical sports. Since I came to Michigan, um, I've been working with communities in the southeastern part of the State, um, that had quite high levels detected in their water through the statewide monitoring. I have a small exposure study, uh, where we're looking at exposure, via drinking water, diet and indoor environment. Um, so we know that drinking water is the main way that, so if you have elevated PFAS in your drinking water, um, we know that it's a, a large contributor to exposure and that's why, you know, a lot of the interventions are focused around drinking water. Um, and so, you know, that's the main focus, but, but we also know in the general population that the main exposure is through diet. Um, and so the question that comes up in a lot of communities is, you know, if they have my drinking water, um, treated, and we intervene and, and reduce or eliminate hopefully PFAS and the drinking water, um, do I have an ongoing elevated sources of exposure? So for example, through local and homegrown foods, so some communities have been told not to, you know, eat chicken eggs, not to eat the produce in the gardens. Um, if they irrigated using PFAS contained water and so forth. So communities have found elevating level 00:06:59 ___________ in fish or fish advisories for many PFAS impact communities. Um, and right, so this is a important question. So that's one, one of the questions that we've really working on for the past few years, um, and then the other, we got our, that NIHS project funded. And, um, I think what we've recognized, you know, through Page 2 �work on contaminants over the years, I've been working on contamination issues for 20 years now. And I look young, but I'm not actually that young. Um, so, you know, I've been working in this area for a long time. And what we've, what we've found is that, um, you know, no one research group can effectively help all communities, you know, not anyone scientists can do all the work that needs to be done. And so, um, a big part of our project is, you know, trying to build out resources for PFAS impacted communities. We started doing this before, you know, good resources really existed on federal or State agency websites. Um, and we think has been, you know, hopefully have been used as a model for a lot of those websites and help them, you know, um, give them ideas for how to improve and vice versa. Um, but we have a website called the PFAS exchange. So ww.pfas-exchange.org, and we put up a lot of different tools to help PFAS impact communities and also to help ourselves because we get a lot of emails from people. Um, and it's really helpful to be able to refer them somewhere where all the, you know, things that we think are useful for them are also located. So we have a tool that helps people understand their water. Our blood test results, so puts them into context. Um, so one of the water tool will compare your water results to state and federal agency advi, you know, advisories or MCLs. Um, and that's really complicated 'cause they're always changing, and there's a lot of, you know, to, to sort of dig up all that information on your own as a, you know, even as somebody who works in PFAS is a lot of work. And so, um, it's a really helpful tool, I think for people and also for professionals to be able to use, um, and then also compares you to sort of a representative levels across the country. Um, and I think what you notice when you look at that tool is that, you know, a lot of places are elevated above, you know, what the guideline, which seems to just continue to decrease as we learn more about the toxicities of chemicals. Um, and then the blood tool does something similar except there's no, I don't, I don't think we've come to a great guidance level yet for whats safe in blood. Um, we see effects of PFAS in the general population in general population levels. Um, so, you know, we think that we're, well, we know that we're all exposed, and we think from the data that we have so far, um, in the literature, et cetera, that, you know, these are affecting people at general population levels. Um, and of course that risk goes up as you're more highly exposed and as you have more risk factors, um, and that communication is always difficult with people with, you know, known occupational or drinking water exposures that, um, you know, just because you see this list of health effects, it doesn't mean you're gonna get it. 'cause you've been exposed, we've all been exposed. Some people have been exposed at higher levels than other people. And some people have been exposed at much higher levels than other people. Everyone has been exposed unwittingly. Um, and you know, there's a lot of risk factors that go into why would, why would you get a disease? Um, and so, you know, reducing your exposure moving forward and um, you know, talking to your doctor and trying to reduce your other risk factors and monitoring. So, um, I was part of, um, uh, community liaison for the national academies of engineering and sciences. And 00:11:01 ___________ just did a study on PFAS, um, blood testing and medical monitoring. Um, so as part of that group, and they came up with some nice guidance for clinicians, for talking about to their doctors or for clinicians talking to their patients, they have a nice guidance. Actually they came up with, um, some numbers so that people with levels in their blood Page 3 �could, um, you know, sort of understand better doctors in particular could look at blood levels and then, you know, make some, uh, informed decisions about screening. So there are medical screening guidance that exist out there. We have one on the PFAS exchange on the resources page. Uh, it's a companion guidance, so there's one for clinicians, and there's one for, uh, community members, and they're, you know, really kind of meant to be used together. Um, and then we have a new resources page for clinicians, and we've just put our new, um, continuing medical education video up there that we made with, you know, um, PFAS experts and physicians and, um, people who've been impacted by PFAS. Um, so that's up on our website now along with other tools for clinicians. So we're still building that out. Um, and sorry. I feel like I'm like, um, going around a little bit um, this has been helpful information so far. Danielle DeVasto: Absolutely. Yeah. I mean, that's kind of the way some of the PFAS stories works. I feel like it kind of wins and winds its way around and kind of gets into everything in its own weird way. Um, it sounds though like your, the PFAS exchange is still something that's kind of actively evolving or kind of growing. It sounds like? Courtney Carignan: Mm-hmm. Danielle DeVasto: Are there any, um, obvious next steps that you guys have in mind or other ways that you'd like to see it kind of keep evolving? Courtney Carignan: Well, another recent evolution has been, um, a new map. So we have a mapping tool on there under the community, connecting communities tab that, um, shares PFAS site data across the country. And then also, um, my collaborators came up with this idea of, um, suspect sources. So they actually map all, you know, kind of entities that may use PFAS in their, you know, processes, um, or at PFAS. And so they've mapped all of those, and I mean the map just like lights up completely, and it helps you see like all the places. 'Cause I think one of the things that is hard to communicate about PFAS is that, you know, there's a whole lot of them. I think the, the number keeps growing. I think the last I remember is like 20,000 PFASs um, when I started, I, I mean, I feel like just a few years ago we were saying like 9,000 or 4,000 or 2,000. Um, so the number really gone up a lot and um, you know, I, I tend to talk about them as legacy PFASs. So we know a lot about PFOA and PFOS health effects of these PFAS. We've been for a long time that were faced out a decade ago in the U.S., all of a, of them. Um, some countries have continued to produce some overseas, uh, in that time, but you know, in the U.S., we've been using other PFAS for many years now. And so we tend to talk about those as current use PFAS. So, you know, there's been a focus on monitoring for legacy PFASs and a lot of the data that's out there is legacy PFASs, it's a small panel. Um, and so a lot of our work focuses on looking at expanded panels that include current use PFASs and talking about current use PFASs um, because, you know, it's, it's basically doing a bunch of different jobs at the same time. You're looking back at all of the contamination that's occurred over the past, you know, basically my lifetime, our lifetimes, right. Um, and trying to clean it up, you know, for these bad, very persistent PFASs. And then there's all these new PFASs that, you know, as we learn more about them, we're learning, you know, that they can act in similar ways, a lot of them are less persistent. Some of them are precursors to the legacy PFASs of Page 4 �PFOA, um, and the, the chemistries are very complicated. I work with a lot of analytical chemists and, you know, part of the challenge of looking at PFAS in food is that, you know, different types of food are different types of complicated matrices and the, um, chemistry just didn't exist, you know, to be able to, to reliably, um, quantify large panels of PFAS and food. And then also, um, there are these interferences in food that will give you false positives. Um, and so it's just, it's very complicated, and you know, I'm not analytical chemist, but my work relies on good analytical chemistry. So, um, that's, that's a big challenge for PFAS. We're just like we just been playing catch up. Um, I just feel like since I started working on it, we're just playing catch up and, um, really communicating about, you know, moving to floral polymers, um, doesn't solve the life lifecycle issue of PFAS, which is that you're creating, you know, you're using PFASs to create Flor polymers, and then they're eventually gonna, um, break down back into PFAS over time. You know, we think that hope right, that floral polymers are reducing exposure to the consumer and during the lifetime of the, um, during the, you know, use portion of the product, but we know that, you know, we're not completely solving the problem of PFAS that it's, um, really a life cycle issue. And, uh, yeah, I'm not, did that answer your question? Did I just go off on like another — Danielle DeVasto: No, I mean, it, it raised a lot of really interesting points and, um, you know, uh, wow. And like, it actually makes me think of like probably five more questions that I could ask. Um, but one of the things that struck me about what you're saying too, is that I'm thinking I'm listening and hearing all of these different people that you're collaborating with to kind of, to do your work, you know, analytical chemists, um, all the collaborators that you have as far as like creating the PFAS exchange, the communities that you're interfacing with. And it just, um, it seems like you're, you're involved in a lot of different kinds of conversations about PFAS, you know, whether it's talking about kind of like the, like the chemical makeup and like the really technical nitty gritty, or talking with people who just wanna understand like their test results or what to do next. And I guess, you know, having kind of worked in this realm now for 20 some years, um, what, like, can you, can you say more about that or like what you've learned by doing some of this, this interfacing between all these different groups in order to do your work? Courtney Carignan: Um, I don't know. I, I mean, it's complicated. It's not, you know, we were talking about this before a little bit before we started filming that, you know, it's a really complicated landscape and that what I've learned. And I think I learned, you know, within the first decade of working on these kinds of issues was that no, you know, so I, I got my Ph.D. 'cause I was working in a community where they had drinking water contamination of trichloroethylene. It was a rural community in Pennsylvania and, um, people there really weren't being told much, you know, I kind of witnessed on 'cause I was, I was working in the community for two years doing the response action. I was a consultant. Um, we were, you know, consulting for the responsible party. And so I got this unique, you know, I don't think it's a unique look in, in terms of consulting. That's what consultants do, but it's unique in the sense of academic academics, don't tend to have this perspective. Um, so I really saw what happens in a community when this kind of contamination is discovered and, you know, understood what I thought they needed. I thought they needed studies. So I went back to it, got my Ph.D. Um, I thought they needed people who knew Page 5 �about contamination could help them, which is true. Um, and you know, I think in the process getting my Ph.D. and then, you know, providing technical support at Pease, I realized that or learned, um, through that work that again, you know, scientists and researchers do not have all the answers and do not work on their own, which, um, I'm sure people told me along the way through my training, um, you know, you hear that referred to the importance of community engaged work and the importance of working with your agencies. Um, but I didn't really understand that until, you know, I started doing it and making lots of, you know, probably lots of mistakes along the way. Um, 'cause it's very humbling to, you know, want to do all of this work and then realize like you cannot achieve [LAUGHTER] the things that you think need to be done without, you know, um, these relationships Danielle DeVasto: That's, that's so true., it's so true. And because, you know, as you said, this isn't just the legacy PFAS, it's kind of an evolving, it's an evolving story. Um, it's not just, you know, this one and done kind of thing, which maybe leads me into my next question. Um, thinking about PFAS contamination moving forward, what kinds of concerns do you have? Courtney Carignan: Um, so I'm, you know, I'm concerned about our ability to monitor for and make progress on the current use PFAS issue, right? The tap is still on, it feels very urgent, um, to make progress on that issue quickly. Um, and while simultaneously, you know, addressing all of the legacy pollution, you know, kind of how do we do that all at the same time? Um, the, you know, I, I do a lot of biomonitoring and health studies. Um, that's my main, the main thing that I, if there's a main thing I focus on, that's it, um, it's the, you know, maybe one of the things I'm best at, and you know, the way that we monitor for exposure to legacy PFASs is easy in the sense that you do a blood draw. Um, we just developed, um, or validated a new finger prick test, which is kinda exciting, um, because getting a blood draw is there's a lot of barriers for people. So we've been working on those kinds of issues as part of the reason we have the clinician resources page, we've got lots of resources there to help people get PFAS, blood testing, 'cause that's one of the main things that people tell us that they want when they find out that they've exposed. Um, but you know, legacy PFASs you can detect them in the blood for a very long time after exposure. So if you were exposed five years ago, and you were exposed to PFLS or EFFF um, and you do a PFAS blood test, um, and opposing your drinking water, you know, you could actually back back calculate what your exposure was five years ago. Like we understand, you know, the behavior in the body well enough that we can do that. Um, whereas with current use PFASs, they're gonna be eliminating from the body more quickly. They're still persistent, but not as persistent. And so when, if you're doing bio monitoring the blood, um, and you are ignoring the fact that all these different PFASs have different, you know, longevity in the blood, um, you are not gonna understand exposure correctly. Um, and so I think that's as an exposure scientist, I think, I think, you know, sort of the, the thing I'm thinking about the most right now is, you know, I think a lot about like how, how not to do harm and how to make sure my work is not harming anyone and making mistakes like that could be very big mistakes. So, um, being careful about, you know, how do we make sure that we are understanding people's exposures and representing them correctly, not only exposure assessment, but also importantly, in these environmental epidemiology Page 6 �studies, because exposure misclassification is one of the biggest problems in expo, uh, environmental epidemiology. Um, if you don't have exposure assessed well, um, you have a bias towards the mill, which means you're more likely to conclude there's no effect when one, in fact is there Danielle DeVasto: Can you just for people who maybe are listening and don't know, can you say a little bit more about what biomonitoring is? Courtney Carignan: So bio biomonitoring is, um, testing for or monitoring for, um, usually, you know, in my context, contaminants in the body are in biological matrices. So in people, um, you know where we're testing blood or urine or hair or fingernails, or, you know, you know, different biological fluids or matrices. Um, and you know, before, when I was a consultant, we'd even do it. And in, in lots of people still do this, right. Uh, you can do bio monitoring of, of IOTA also, um, but in my context I'm usually talking human health studies. Danielle DeVasto: Before we wrap, is there anything that you would like to add or, um, that we haven't touched on today or anything you wanna go back to and say more about? Courtney Carignan: Um, I mean, I, I plugged the PFAS exchange website. I think that's a really helpful place for people to get information. Um, and you know, we do, you know, it is a work in progress. Hopefully we can get funded to continue working on that, 'cause I think our project period is expiring, but, um, you know, we, we always wanna make it better, and it's helpful to, you know, know from people not only like what ways to improve it, but also, you know, sometimes we partner with people who can volunteer their time or, [LAUGHTER] you know, can help us find funding to, to be able to continue improve it. 'cause it is, like you said, I'm doing a lot of different things, and you know, spread pretty thin. So it's, um, there's like the pie in the sky, what we wanna do. And then there's like the nuts and bolts of getting it done and so people wanna, um, get connected. Uh that's great. And then I guess I would also say, you know, I, I, I would encourage people who, you know, are exposed, and you know, wanna take action. Um, there's a lot of different groups. So if you go to the PFAS exchange connection, connecting communities page, uh, it'll help you find different groups that are working on PFAS and taking action in their communities. And then we have a national PFAS contamination coalition, um, or shouldn't say we, there is one, um, I serve, um, serve as a, you know, provide technical assistance for the coalition. Um, and I provide technical assistance for a lot of community groups, you know, a lot of my funding, um, you know, my salary, right. It's all comes from the public. So, you know, I see that work as, you know, as long as I have the bandwidth to do it, you know, I'm gonna do that kinda work. Danielle DeVasto: I imagine also find, find meaningful because it sounds like that's sort of, you know, working with communities sounds like where your story started way back in Pennsylvania. Courtney Carignan: Yeah. I mean, you know, I'm from a mill family. So my, um, grandfather actually was a lumberjack in Maine and my grandmother worked at a shoe factory in Maine, Um, and you know, I'm, you know, I'm from New Hampshire, but you know, we have a lot of, you know, my husband's family help build the mills in New Hampshire. Um, so we kind of have this, um, history to our families that, um, you know, we also are French Canadians, so we also have indigenous, you know, backgrounds. So, um, I Page 7 �think I see those communities and, and I understand, you know, what challenges they face. Um, so yeah, I do find a lot of meaning in that work. Danielle DeVasto: Well, I have poked around the PFAS exchange website, and it looks awesome. I'm very grateful to you guys for creating that. Seems like such a great resource in so many ways, and I'm excited to see where it keeps going. Have you gotten much feedback about the website since it's launch? Courtney Carignan: Yeah. I mean, mostly we get mostly we get, uh, feedback from the coalition 'cause we meet with them and ask them, um, but, and then I have feedback from myself. Right. All things we wanna do. [LAUGHTER' Um, so yeah, it's definitely a work in progress. Well, I'm, I'm so glad that it's there, and I'm always happy to have it because you know, there are lots of questions and there's so much information and confusing information. So having somewhere to be able to send people is a really, seems like a really great thing. So. Courtney Carignan: I guess another thing to mention is, um, that I am working with firefighters as well cause firefighters have occupational exposures to PFAS. Um, and so I'm connected with a group that has a website called PFAS for EPPE. Um, and I'm connected with the IFFF and, um, I'm doing a very small exposure study on firefighters. I know that there's a bigger study going on in the State led by NDHHS, but, um, I decided mention that as well, that, you know, occupational exposed groups, I think, um, you know, there's been a lot of focus on drinking water. Um, and that's what I'm focusing on a lot on the last, you know, five to 10 years. But, um, occupational exposure is something that is also very important, and there's so many ways that people can occupation expose to PCOS and have no idea. So firefighters for a long time were told that Atripla was like soap and water and, um, it's just, that's how they treated it. So they, you know, exposed themselves, they, you know, spread it all over the environment. Um, PFASs are used in, have been used in ski wax. Um, I'm trying to think of all 'cause I usually like rattle off a list of occupations that you use PFAS and might not know. Danielle DeVasto: Yeah. What are, what are a couple of the most surprising ones? Courtney Carignan: Well, I mean, carpeting has been, you know, something that we were working on at BU during my Ph.D. So our group was the first to show PFAS, you know, and in the indoor environment from carpeting, um, and that, you know, it's in the air and dust and, and people also spray Scotchguard on their furniture. It was very common in the past. I was at my local hot tub store last summer and didn't get a hot tub, but I did notice that, uh, no, I wish I, they had a can of that kind of spray, and it actually said on it, you know, perifluoro-, blah, blah, blah. And I was so shocked that they still sell this kind of spray. And I told the cashier like, do you know what's in this? Um, so yeah, I mean that, those kinds of sprays are still in the market and, you know, people, you know, for the past, you know, a few decades used to spray it in their homes, um, parchment paper. Um, so the paper that you used to line, you know, holiday seasons coming up and doing a lot of baking, um, I'm curious to know what PFASs are being replaced in parchment paper. They think they're moving away from PFASs in food packaging, um, and food contact papers. Um, and so I guess those are the two sort of indoor environments, I think about the most. Um, I think UFM published a study on PFASs on floor wax, um, or they had a poster on it. So they found that it Page 8 �was being used in the, those big machines that wax the floors. Um, so that, I think that's another surprising place they're used in extrusion of plastics. So vinyl flooring there's trace levels at least of PFASs in, uh, artificial turf. So the plastic blades of graphs, grass in artificial turf, um, I mean, it's just like the list just goes on and on and on places that PFASs are used that are surprising. I mean, originally the first sort of surprising place that that was discovered was popcorn bags, microwave, popcorn bags, and again, I'm not sure what replacements being used currently, if it's still a PFAS or something else. Um, people ask all the time about, you know, pans, um, stuff on pans or nonstick pans. Consumer reports just put out a nice report on that. So I'm referring people to that report for more information. Um, but yeah, there's a lot of sources, you know, kind of lurking sources of PFAS, um, that you expect or know about. And often don't have control over, like right in your workplace, if you have a stain resistant carpeting, like, you know, um, what are you gonna do about that or in your home even, um, can you afford to replace it? Um, so I did that answer your question. on another tangent, but like in terms of occupational exposure zone, people who actually did make stain resistant carpeting, people who work, you know, in paper, the paper industry, you know, they actually mix the paper, you know, pull up in the PFAS together. Uh, people who worked in tanneries and used PFASs on leather goods, um, people who worked in the plating industry and are standing over vats of PFAS containing you know, so, you know, I think about those people and, um, wonder what's being, what's being done for them. Danielle DeVasto: Well, thank you so much, Courtney, for taking the time to share your story and your work today. Um, it's been a pleasure talking with you, Courtney Carignan: You too. Page 9 � 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 PFAS0033 Creator An entity primarily responsible for making the resource Carignan, Courtney Date A point or period of time associated with an event in the lifecycle of the resource 2022-11-18 Title A name given to the resource Courtney Carignan, 2022 (Interview video and transcript) Description An account of the resource Dr. Courtney Carignan lives in central Michigan and works at Michigan State University, though she was raised in New Hamphsire. She holds a PhD in environmental health from the Boston University School of Public Health. In this interview, she discusses her involvement with PFAS advocacy and research in her communities, as well as a new mapping tool that will collect and share PFAS site data across the United States. 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/56633af223e46292a26f2b48512f45cb.mp4 43143efa6ab44119f1b0a11f64e384a7 https://digitalcollections.library.gvsu.edu/files/original/1c88a5fe46be90623647803f675c3b72.pdf 7a5e5b4e95c0f3f44479eb0505c4f964 PDF Text Text Living With PFAS Interviewee: Kevin Elliot Interviewer: Dani DeVasto Date: October 17, 2021 DD: I’m Dani DeVasto, and - [Recording paused] chatting with doctor Kevin Elliot. Hi Kevin. KE: Hey. DD: Kevin, can you tell me about where you're from and where you currently live. KE: Sure, well originally I grew up near the Chicago area - in the suburbs. Currently I live in Okemos, Michigan, which is just to the east of east lansing where im a faculty member at michigan state university. DD: And how long have you been there? KE: I came in January of 2014, so I guess it's been about 7 and a half years. DD: Kevin, can you tell me a story about your experience with pfas or with pfas in your community? KE: Yeah, so um... I don't have a good story about PFAS in my community, but um, I have, over the past year been involved with the center for PFAS research at MSU, and then I’ve been on a, um, National Academy of Sciences Committee thats is trying to give guidance to clinicians as they work with people who are concerned about PFAS exposure. And I guess maybe just a story that might be of interest related to that is that we’ve been having these public sessions where people who have been dealing with PFAS exposure can share their experiences, and several of the sort of stories that I've heard through that have been some that are really striking to me. And um, I guess maybe i'll just say one general sort of reaction first then you can let me know if you want me to get more concrete. The general reaction that has just been striking to me as I hear from different people who have been saying, saying they have children who ended up with testicular cancer or you know, other sorts of effects, or um other people, you know, spouses who have been dealing with health effects is just how frustrated they've been, feeling like their um, the physicians they've been working with, haven't been very supportive or in some cases even kind of minimize the likelihood that PFAS contributed to the health problems. And of course, you know it is - you can't be sure what caused it. But it was just so surprising to me hearing about the disappointment they've had working with doctors that either don't know anything about �PFAS, which I can kind of understand. But then also, just plain kind of being dismissive and not wanting to be very helpful in exploring PFAS as a potential contributor to these problems. So that was really striking to me. DD: Can you maybe take a step back and talk a little bit about how you got to that point of having those conversations; some of your background in any context, I think that might be helpful. KE: Yeah, I mean It would be helpful to talk about sort of how I ended up, like, how this committee ended up forming, or like sort of my background in terms of my scholarship and stuff like that DD: Yes, yes. KE: Okay, I'll talk about it all. So i'm a philosopher of science and I uh, - I don't know how much nitty gritty to go into - I have a background in chemistry and then I got interested in philosophy, and so I ended up doing my PhD in the history of philosophy and science and alot of scholarship involved studying controversies about science, and especially environmental kind of areas of science, and um, especially environmental pollution. And so, I would sometimes look at the role of conflicts of interest in that science. How they all have different groups with different financial stakes or other personal stakes in scientific controversies or how harmful chemicals may be. So I'm interested in, sort of, what are the judgements that go into evaluating the science in trying to say, yeah we think this chemical is pretty harmful or no its not that big of a deal. So yeah, as a philosopher I dont do the hardcore science but I sort of reflect and look at the dates and try to understand why are there these disagreements, how do we handle the disagreements, how do we sort of address them responsibly and so on. So anyway, as part of that work, I have ended up getting a little bit connected with agencies like The National Institute of Environmental Health Sciences which is part of the national institute of health. Which funds alot of our medical research in the US, and the national academy of sciences. I don't know if it's helpful for me to say what that is for folks, uh DD: Sure. KE: Folks watching this may not know so much, The National Academy of Sciences put together, actually back during the civil war, as um sort of an expert organization provided by [?] to the federal government. And so, It will create committees to address certain issues when government agencies want certain advice on things. Most of the time it would be science on these committees, um, and uh so I was a little surprised when I got a approached to see if I could serve on this particular committee, that um, was actually partly - trying to think of the right word - commission, I guess, by a branch of the center of disease control, the ATSDR, which is the �Agency for Toxic Substances and Diseases [?] This is this group that helps deal with communities who are facing chemical exposures, pollution, spills [?]. And so they've provided advice to doctors in the past about how to deal with PFAS, but they've had pushback from communities feeling like the advice they've provided hasn't really been what they hoped for, communities feel like the current guidance isn't very supportive for them to be able to get tested for their exposure to PFAS, and it maybe doesn't - Yeah maybe just isn't as aggressive when accepting that their might be health effects from PFAS exposures as i think a lot of people in these communities would want. Anyways, so this community was put together and its mostly scientists, I was a little surprised as a philosopher that they asked me to be involved. But, I now understand why, because one of the things the committee asked to do is to provide principals for clinicians who are making decisions and providing advice under scientific uncertainty. I think they use the language of substantial scientific uncertainty. Scientists often don't really like having to provide advice in those kinds of situations. And it's just a tricky, tricky issue. So anyway, I think they realized maybe it'll be good to have someone like me on this committee, and I think it turned out to be a good move. So that's the background behind this, and I’m just blabbing away but as we got started, often it would just be us experts deliberating, and we ended up realizing this is so tightly connected with people's own experiences, maybe to be responsible, we really need to have some open town halls where we can hear from various people and communities who have had these experiences, and so that's where my story came from, that we’ve been hearing these [?] experiences, and that's probably what I’m most useful for sharing during this discussion. Because I don't have personal experiences but I’ve been struck by what I’ve heard from people. DD: Absolutely, were people something you were aware of before you started this project? How did you kind of come to be aware? KE: I was hearing about it a bit, just from you know interacting with other people in the university setting, um so I don't know exactly when I first heard of it, but I kept hearing little bits and pieces about it, and kind of got the sense, you know, i feel like the environmental health community will go through these waves where there will be this new big thing we realize, “Ah” This is a problem and there hasn't been enough work on it, then you know maybe it dies down, or it maintains attention and something else will come up that we realize, so I just kept hearing bits and pieces about it and thinking wow maybe this is a significant area I should try and learn more about. And then when some of the faculty at MSU started kind of pursuing like, some research funding to try and make a center for research on PFAS, I thought well this is a great opportunity to find out more, and so I got involved in that center. Thats been the past couple of years I’ve been learning a lot, I really didn't know much previously. DD: And do you foresee PFAS continuing to be part of your research focus moving forward or do you think this is - Like once you develop these guidelines? �KE: I think that, so you know participation in the national academy will be over, were supposed to have a report submitted in May of 2022, but, I would like to continue sort of exploring this issue, kind of as a philosopher I tend to sort of explore areas like case studies where i’ll sort of look over the research being done on them, you know, ask questions about it. So I would like this to be uh one of these case studies that I look at in the future. I have the benefit. Scientists have to develop all this infrastructure in their labs and really focus on something. I have the luxury. I can look at multiple case studies, but I’d like this to be one of them for a while to come I think. DD: So, as a philosopher then, are there particular questions or aspects of this particular PFAS case study that interest you, or challenge you, or you know... keep your attention? KE: Yeah um, well I think - I don't know that PFAS is totally unique compared to you know, other things, but I think there are some issues in this case and in other cases that strike me as really interesting. And one is, it once again highlights the question of how to engage in appropriate regulation and policy and responses to these issues where we're just not gonna have all the scientific knowledge that we'd like. Because, you know like I constantly hear, you know about thousands, you know often the numbers like five thousand different PFAS compounds that could be used, that are out there, depending on how you find exactly what counts in this category, and so there's just no way we can test all these things in detail, it's like a micro[?] of our general problems with, you know, chemical recreation, so we have to find strategic ways to sort of make decisions without knowing all of the nitty-gritty details. You know, some people suggest we should group them together as either a huge class, or as some class and say look, if a chemical falls under this general group, then shouldn't use it, or try to minimize the use, or try to look for alternatives for the greatest extent possible. And so, those are the things that interest me, sort of looking at the science and the decision making and trying to figure out what do we do given that this is just too messy, there's just too much going on to really study in great detail. DD: So I know your report and your study are still ongoing, but do you have any ideas about what we should do? KE: Yeah well... so... so this is where I probably can't say a ton about the details of the report at this point. But, um, I think a general theme in my work is to argue that it's a real mistake to think that you have to have the science figured out, before you can make decisions. I tend to be a fan of the folks who, you know some folks have been writing articles, saying things like given how persistent these are in the environment and given that, you know a lot of them seem to be fairly bioaccumulative, meaning that um, a build up in organisms and as it goes up the food chain you know, humans can end up you know [?] in our bodies. I think we have to be willing to go ahead and take some sort of action, even if we don't have decisive proof that there's a problem. And that's actually a little bit different from what I’m saying from the details from what we're talking �about in our report, our advice for clinicians. I guess I’m giving this general sort of perspective that we cant be perfectly precautionary with respect to everything, but I think it doesn't make any sense to say well we can't take any actions until we get the science. I think that's a mistake. DD: Well I will be looking forward to reading your report, in the near future hopefully. KE: Yeah, yeah. I’m hoping that it will be useful and it has been really interesting so I’ll just mention one other thing. As part of putting it together we looked at sorts of frameworks for making decisions under uncertainty, and it has been kind of striking to me that again, I feel like these frameworks in general are much more geared towards making the decision when you’ve got a good deal of evidence that we don’t have as quality frameworks for making decisions under uncertainty, and I think the scientific community just doesn't feel super comfortable with that. That's just the one comment I would make that's been interesting for me as I've been reading and [?]. DD: And can I maybe ask about another- other frameworks in terms of guidance from medical professionals. What's kind of the status on guidance for that or for medical professionals specifically dealing with PFAS right now? KE: Yeah, I’m not much of an expert on the medical stuff, but it's been very interesting for me learning a little bit more, there's a well put together framework from the United States Preventive Services Task Force (USPSTF) And I get the impression they provide all kinds of guidelines for things like, you know when you should start getting prostate cancer screening or colonoscopies or breast cancer screening or all that kinds of stuff. And so they’ve got this whole framework in place for trying to evaluate evidence and decide when it's enough to definitely recommend that people do something or recommend that people do it, um, if they want to, you know leaving more judgement for them, and like how much evidence they wanna see in order to make these kinds of recommendations. So it's really pretty aggressive, but again, my sense of the framework, they don't really like to provide recommendations when there's substantial scientific uncertainty. So that’s one of the frameworks that was interesting to learn a little bit more about. DD: Sure. So what concerns, if any, do you have about PFAS contamination or PFAS related issues moving forward from this time? KE: Yeah, one of the things that strikes me, and this is coming from hearing people talk in these town halls from the committee, was just how sad it is, that you’ll have communities where on the one hand, people will want to find more about the contamination in their communities. But then, they’re afraid, at least some people in the communities are afraid, that if there were more, well then it would end up being economically harmful, like people don't want to come to those communities as tourists or people don't want to buy houses in those communities - or um - It was �so striking hearing about, like, farmers or ranchers like once they found out that they're, lets say, herd of animals was contaminated. Then they are in just a total mess in terms of not being able to sell the animals or sell milk from the animals or things like that. And so, It really worries me realizing that there's this tension between wanting to learn more about, you know, the potential threats one faces, then they are communities will disadvantage finding this stuff out. That can create tension between communities, and just, - serious economic problems, and so anyways that was really striking to me. DD: Yeah, I can imagine that playing out in a number of different ways into communities. Well, before we wrap up, Kevin, is there anything that you'd like to go back to, that we - or anything you'd like to add that we haven't touched on? I know you jumped around your story. KE: Right, right. DD: But I wanted to hear if you had a chance to go and say anything additional. KE: Yeah, another thing I guess - I guess that has just struck me, as I’ve been learning more about PFAS and maybe this is more sort of, you know the cognitive and academic thing you're looking for, but um, It's just been interesting - One of the things that I have been intrigued about is debates about biosolids, which are you know kind of produced from waste water treatment plants and have lots of, fertilizer potentially. So farmers will, you know, put them on their fields, and in principle it seems like a great way to kind of have a circular economy where you know, we're producing sewage waste, but we can take some of the good aspects of it and put it back on the land. But, then there are concerns now about pollutants in biosolids and so on, and worries that if we put it on farmers' fields it can cause problems, you know, potentially taken up by crops and then be a problem for people or be a problem for people near those fields and so on. It's just been striking as I learn more about this, I don't know enough about the scientific details on how much you should be worried about this and so on, um, but just realizing what a problem it is to sort of deal with these when they are so persistent in the environment, that its like they just keep cycling around. So you know, well go into the wastewater treatment plant, and then they go to the biosolids and the biosolids either have to go to some landfill somewhere or have to get spread on someones fields, then it goes to the landfills and eventually seems to come out in the [?] then that has to go somewhere, maybe back to a wastewater treatment plant, if it spreads on the fields then it may go into water. And the ways in which - We can’t get rid of this stuff, you know, unless I guess you burn it at 1000 degrees celsius or something, again the scientists can provide more nitty-gritty but that has been pretty striking to me, and again has kinda furthered my thinking, where you know, it just doesn't make sense to use persistent compounds like this, if we can avoid it. Because it’s just such a mess if they might become a problem. And so I think that's something that has been really striking and interesting to me as i've learned a little bit more about PFAS. �DD: Yeah, a whole other set of problems. KE: Right, exactly. And I - I don't know if there's anything else, um, that struck me. [Brief Pause] I guess just the other thing, and again this isn’t particularly profound, but it's been so interesting to me also hearing about some of the communities, or like, uh, seeing your military bases, or like firefighters where they are especially using these foams, they call them “A Triple F” [?] Forming foams I think, they reason in which they were told this is just like soap and they had no worries about these, and you know sometimes they would just use it for fun. Kids would play in this stuff, figuring you know they could just spray this everywhere and not worry at all about being exposed to it. And um, It just makes me wonder kinda the lesson I kind of gleamed from this is, what things are we exposed to now, where we’re just assuming there's nothing to worry about, and then we might find out 10 years from now, oh there was a problem, and again, we wanna ask these questions about surely there should be a better way of strategizing in terms of putting products onto the market. I know we don't want to halt innovation, but it's just so striking to me the way we just produce thousands of chemicals and just throw them out there and then end up finding out kinda later at some point that there's a worry. I'm just pontificating about all kinds of stuff. DD: Well I mean from a historical perspective too it's interesting right, I'm sure you've seen this is not the first time humanity has done something like this. Like, we seem to keep doing these things where we throw products out there and discover after the fact that we need to [?] back. So I imagine there might be some interest for you there from a historical perspective as well. KE: Of course, of course, absolutely. Great point. DD: Yeah, well thank you so much, Kevin. For taking the time to share your story today. KE: Yeah! It's a pleasure and I'm really glad youre doing this project. DD: Thank you. KE: Thanks. � 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 PFAS0029 Creator An entity primarily responsible for making the resource Elliott, Kevin Date A point or period of time associated with an event in the lifecycle of the resource 2021-09-27 Title A name given to the resource Kevin Elliott, 2021 (Interview video and transcript) Description An account of the resource Dr. Kevin Elliott lives in Lansing, Michigan, and is involved in the Center for PFAS Research at Michigan State University. He also serves on a National Academy of Sciences Committee that gives guidance to clinicians working with people concerned about PFAS exposure. Elliott holds a PhD in the history of philosophy and science, and studies controversies about science and environmental pollution. In this interview, Elliott discusses his involvement with PFAS research and education. 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/935e807f8abb9b882679cb5709eec416.jpg cb948fca1bf8114518740b26abdbae17 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. 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 College Charter signing, 1960 Creator An entity primarily responsible for making the resource Grand Valley State College Board of Control Description An account of the resource Governor G. Mennen Williams signing the bill that established Grand Valley State College as Michigan's 10th state-supported, four-year college on April 26, 1960. Governor Williams appointed nine individuals as members to the first Board of Control. Their first meeting was held in Governor Williams' office on October 17, 1960, where each member was sworn in, and a chairman was elected. Pictured with Governor Williams (seated) are seven members of teh first Board of Control: [Left to right] James Copeland, William Kirkpatrick, Icie Macy Hoobler, Kenneth Robinson, Grace Kistler, L. William Seidman, and Arnold C. Ott. Not pictured are Edward J. Frey and Dale Stafford. 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 Date A point or period of time associated with an event in the lifecycle of the resource 1960-04-26 Source A related resource from which the described resource is derived University Photographs, GV012-01 Rights Information about rights held in and over the resource In Copyright Subject The topic of the resource Colleges and universities Michigan Publisher An entity responsible for making the resource available Grand Valley State University Libraries, Special Collections & University Archives Identifier An unambiguous reference to the resource within a given context GV012-01_UA002087 Format The file format, physical medium, or dimensions of the resource image/jpeg Type The nature or genre of the resource Image black and white photo https://digitalcollections.library.gvsu.edu/files/original/aabbc21713e56a19354302543c764027.jpg 417b0758ecd07c2a86eb78e89f481aeb 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 Douglas R. Gilbert Photographs Creator An entity primarily responsible for making the resource Gilbert, Douglas R., 1942-2023 Description An account of the resource Photographs scanned from negatives and transparencies from the Douglas R. Gilbert papers (RHC-183). Douglas R. Gilbert (b. 1942) is an American photographer from Michigan. He was born in Holland, Michigan and is the son of Russell W. and Carmen (Andree) Gilbert. Gilbert earned a B.A. in social sciences and art at Michigan State University in 1964, an M.S. in photography from the Institute of Design at Illinois Institute of Technology in 1972, and a M.S.W. from Salem State College in 1993. He is married to Barbara (McDonald) Gilbert, and has three daughters, Robyn, Rachel, and Anne. Gilbert took a serious interest in photography at the age of fourteen. In 1963 he joined the staff of Look magazine in New York as the second youngest photojournalist in the magazine's history. As a Look photographer from 1964 to 1966, he photographed folk musician Bob Dylan, the Newport Folk Festival, Simon and Garfunkel, the New York City Financial District, the children and facilities at the Manhattan School for Seriously Disturbed Children. From 1967 to 1969, Gilbert did several shoots, including that of folk singer Janis Ian for Life magazine. After moving to Chicago, Illinois in 1969 to attend the Illinois Institute of Technology, Gilbert conducted notable photo shoots of business and political figure Lenore Romney, and pursued more personal and artistic photography, focusing on urban and rural landscapes in Illinois and Michigan. He then joined the faculty of Wheaton College, where he taught from 1972 to 1982. In 1993, Gilbert graduated from Salem State College, Massachusetts, with a Masters in Social Work, and later pursued a second career as a psychotherapist. Douglas Gilbert died in June 2023. Throughout his photography career, he pursued both freelance commercial work as well as artistic work. His art photography is characterized by its classic black-and-white format, and features people, places and objects shot great attention and sensitivity. Gilbert's works are held in the permanent collections of the Art Institute of Chicago, the High Museum of Art in Atlanta, The Norton Simon Museum in Pasadena, and the Grand Valley State University Art Galleries, as well as in numerous private and institutional collections. Date A point or period of time associated with an event in the lifecycle of the resource 1960-2011 Source A related resource from which the described resource is derived <a href="%E2%80%9Dhttps%3A//gvsu.lyrasistechnology.org/repositories/2/resources/783%E2%80%9D">Douglas R. Gilbert Papers (RHC-183)</a> Rights Information about rights held in and over the resource In Copyright Subject The topic of the resource Photographs Photography -- United States Publisher An entity responsible for making the resource available Grand Valley State University. University Libraries. Special Collections and University Archives. Identifier An unambiguous reference to the resource within a given context RHC-183 Format The file format, physical medium, or dimensions of the resource Image Type The nature or genre of the resource image/jpeg Language A language of the resource eng 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. 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-183_AN065-0042 Creator An entity primarily responsible for making the resource Gilbert, Douglas R. Date A point or period of time associated with an event in the lifecycle of the resource 1999-08-30 Title A name given to the resource City Hall Civil War Memorial, Williamston, Michigan Description An account of the resource Black and white photograph of the Williamston City Hall Civil War Memorial, a statue deditcated to the local soldiers of the Civil War, located on East Grand River Road in Williamston, Michigan. The statue's inscription reads, "In memory of Eli P. Alexander, Post No. 103, 1861-1865." Scanned from the negative. Subject The topic of the resource United States--History--Civil War, 1861-1865--Monuments--Michigan Statues--Michigan--Williamston War memorials--Michigan--Williamston Black-and-white photography Source A related resource from which the described resource is derived <a href="https://gvsu.lyrasistechnology.org/repositories/2/resources/783">Douglas R. Gilbert papers (RHC-183)</a> 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 Image Format The file format, physical medium, or dimensions of the resource image/jpeg Coverage The spatial or temporal topic of the resource, the spatial applicability of the resource, or the jurisdiction under which the resource is relevant 1990s 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/a4f30c29d57247b2d4b895e5e440b85b.jpg 9b4b84774bde20471b9551622b858f2a 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 Douglas R. Gilbert Photographs Creator An entity primarily responsible for making the resource Gilbert, Douglas R., 1942-2023 Description An account of the resource Photographs scanned from negatives and transparencies from the Douglas R. Gilbert papers (RHC-183). Douglas R. Gilbert (b. 1942) is an American photographer from Michigan. He was born in Holland, Michigan and is the son of Russell W. and Carmen (Andree) Gilbert. Gilbert earned a B.A. in social sciences and art at Michigan State University in 1964, an M.S. in photography from the Institute of Design at Illinois Institute of Technology in 1972, and a M.S.W. from Salem State College in 1993. He is married to Barbara (McDonald) Gilbert, and has three daughters, Robyn, Rachel, and Anne. Gilbert took a serious interest in photography at the age of fourteen. In 1963 he joined the staff of Look magazine in New York as the second youngest photojournalist in the magazine's history. As a Look photographer from 1964 to 1966, he photographed folk musician Bob Dylan, the Newport Folk Festival, Simon and Garfunkel, the New York City Financial District, the children and facilities at the Manhattan School for Seriously Disturbed Children. From 1967 to 1969, Gilbert did several shoots, including that of folk singer Janis Ian for Life magazine. After moving to Chicago, Illinois in 1969 to attend the Illinois Institute of Technology, Gilbert conducted notable photo shoots of business and political figure Lenore Romney, and pursued more personal and artistic photography, focusing on urban and rural landscapes in Illinois and Michigan. He then joined the faculty of Wheaton College, where he taught from 1972 to 1982. In 1993, Gilbert graduated from Salem State College, Massachusetts, with a Masters in Social Work, and later pursued a second career as a psychotherapist. Douglas Gilbert died in June 2023. Throughout his photography career, he pursued both freelance commercial work as well as artistic work. His art photography is characterized by its classic black-and-white format, and features people, places and objects shot great attention and sensitivity. Gilbert's works are held in the permanent collections of the Art Institute of Chicago, the High Museum of Art in Atlanta, The Norton Simon Museum in Pasadena, and the Grand Valley State University Art Galleries, as well as in numerous private and institutional collections. Date A point or period of time associated with an event in the lifecycle of the resource 1960-2011 Source A related resource from which the described resource is derived <a href="%E2%80%9Dhttps%3A//gvsu.lyrasistechnology.org/repositories/2/resources/783%E2%80%9D">Douglas R. Gilbert Papers (RHC-183)</a> Rights Information about rights held in and over the resource In Copyright Subject The topic of the resource Photographs Photography -- United States Publisher An entity responsible for making the resource available Grand Valley State University. University Libraries. Special Collections and University Archives. Identifier An unambiguous reference to the resource within a given context RHC-183 Format The file format, physical medium, or dimensions of the resource Image Type The nature or genre of the resource image/jpeg Language A language of the resource eng 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. 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-183_AN065-0001 Creator An entity primarily responsible for making the resource Gilbert, Douglas R. Date A point or period of time associated with an event in the lifecycle of the resource 1999-08-30 Title A name given to the resource Great Lakes State, Williamston, Michigan Description An account of the resource Black and white photograph featuring an exterior view of the "Great Lakes State Heating and Air Conditioning" business located in Williamston, Michigan. Scanned from the negative. Subject The topic of the resource Heating and ventilation industry--Michigan--Williamston Small business--Michigan--Williamston Williamston (Mich.) Black-and-white photography Source A related resource from which the described resource is derived <a href="https://gvsu.lyrasistechnology.org/repositories/2/resources/783">Douglas R. Gilbert papers (RHC-183)</a> 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 Image Format The file format, physical medium, or dimensions of the resource image/jpeg Coverage The spatial or temporal topic of the resource, the spatial applicability of the resource, or the jurisdiction under which the resource is relevant 1990s 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/c49e841b7f858b6c2b82cc6d9c2753e3.jpg be0cc9fb937f2c6e44fd0d63fff5d573 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 Douglas R. Gilbert Photographs Creator An entity primarily responsible for making the resource Gilbert, Douglas R., 1942-2023 Description An account of the resource Photographs scanned from negatives and transparencies from the Douglas R. Gilbert papers (RHC-183). Douglas R. Gilbert (b. 1942) is an American photographer from Michigan. He was born in Holland, Michigan and is the son of Russell W. and Carmen (Andree) Gilbert. Gilbert earned a B.A. in social sciences and art at Michigan State University in 1964, an M.S. in photography from the Institute of Design at Illinois Institute of Technology in 1972, and a M.S.W. from Salem State College in 1993. He is married to Barbara (McDonald) Gilbert, and has three daughters, Robyn, Rachel, and Anne. Gilbert took a serious interest in photography at the age of fourteen. In 1963 he joined the staff of Look magazine in New York as the second youngest photojournalist in the magazine's history. As a Look photographer from 1964 to 1966, he photographed folk musician Bob Dylan, the Newport Folk Festival, Simon and Garfunkel, the New York City Financial District, the children and facilities at the Manhattan School for Seriously Disturbed Children. From 1967 to 1969, Gilbert did several shoots, including that of folk singer Janis Ian for Life magazine. After moving to Chicago, Illinois in 1969 to attend the Illinois Institute of Technology, Gilbert conducted notable photo shoots of business and political figure Lenore Romney, and pursued more personal and artistic photography, focusing on urban and rural landscapes in Illinois and Michigan. He then joined the faculty of Wheaton College, where he taught from 1972 to 1982. In 1993, Gilbert graduated from Salem State College, Massachusetts, with a Masters in Social Work, and later pursued a second career as a psychotherapist. Douglas Gilbert died in June 2023. Throughout his photography career, he pursued both freelance commercial work as well as artistic work. His art photography is characterized by its classic black-and-white format, and features people, places and objects shot great attention and sensitivity. Gilbert's works are held in the permanent collections of the Art Institute of Chicago, the High Museum of Art in Atlanta, The Norton Simon Museum in Pasadena, and the Grand Valley State University Art Galleries, as well as in numerous private and institutional collections. Date A point or period of time associated with an event in the lifecycle of the resource 1960-2011 Source A related resource from which the described resource is derived <a href="%E2%80%9Dhttps%3A//gvsu.lyrasistechnology.org/repositories/2/resources/783%E2%80%9D">Douglas R. Gilbert Papers (RHC-183)</a> Rights Information about rights held in and over the resource In Copyright Subject The topic of the resource Photographs Photography -- United States Publisher An entity responsible for making the resource available Grand Valley State University. University Libraries. Special Collections and University Archives. Identifier An unambiguous reference to the resource within a given context RHC-183 Format The file format, physical medium, or dimensions of the resource Image Type The nature or genre of the resource image/jpeg Language A language of the resource eng 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. 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-183_Z038-0038a Creator An entity primarily responsible for making the resource Gilbert, Douglas R. Date A point or period of time associated with an event in the lifecycle of the resource 1985-09-01 Title A name given to the resource Bumper Cars, Salisbury Beach Description An account of the resource Black and white photograph of a group of people riding bumber cars at Salisbury Beach’s Amusement Center in Salisbury, Massachusetts. Scanned from the negative. Subject The topic of the resource Amusement rides--Massachusetts--Salisbury Salisbury (Mass.) Salisbury (Mass. : Town) Black-and-white photography Source A related resource from which the described resource is derived <a href="https://gvsu.lyrasistechnology.org/repositories/2/resources/783">Douglas R. Gilbert papers (RHC-183)</a> 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 Image Format The file format, physical medium, or dimensions of the resource image/jpeg Coverage The spatial or temporal topic of the resource, the spatial applicability of the resource, or the jurisdiction under which the resource is relevant 1980s 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/da22042518f950e706d40ebe8571fcd0.jpg dc66b2476cb1cd0ad3f12a868364d386 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 Douglas R. Gilbert Photographs Creator An entity primarily responsible for making the resource Gilbert, Douglas R., 1942-2023 Description An account of the resource Photographs scanned from negatives and transparencies from the Douglas R. Gilbert papers (RHC-183). Douglas R. Gilbert (b. 1942) is an American photographer from Michigan. He was born in Holland, Michigan and is the son of Russell W. and Carmen (Andree) Gilbert. Gilbert earned a B.A. in social sciences and art at Michigan State University in 1964, an M.S. in photography from the Institute of Design at Illinois Institute of Technology in 1972, and a M.S.W. from Salem State College in 1993. He is married to Barbara (McDonald) Gilbert, and has three daughters, Robyn, Rachel, and Anne. Gilbert took a serious interest in photography at the age of fourteen. In 1963 he joined the staff of Look magazine in New York as the second youngest photojournalist in the magazine's history. As a Look photographer from 1964 to 1966, he photographed folk musician Bob Dylan, the Newport Folk Festival, Simon and Garfunkel, the New York City Financial District, the children and facilities at the Manhattan School for Seriously Disturbed Children. From 1967 to 1969, Gilbert did several shoots, including that of folk singer Janis Ian for Life magazine. After moving to Chicago, Illinois in 1969 to attend the Illinois Institute of Technology, Gilbert conducted notable photo shoots of business and political figure Lenore Romney, and pursued more personal and artistic photography, focusing on urban and rural landscapes in Illinois and Michigan. He then joined the faculty of Wheaton College, where he taught from 1972 to 1982. In 1993, Gilbert graduated from Salem State College, Massachusetts, with a Masters in Social Work, and later pursued a second career as a psychotherapist. Douglas Gilbert died in June 2023. Throughout his photography career, he pursued both freelance commercial work as well as artistic work. His art photography is characterized by its classic black-and-white format, and features people, places and objects shot great attention and sensitivity. Gilbert's works are held in the permanent collections of the Art Institute of Chicago, the High Museum of Art in Atlanta, The Norton Simon Museum in Pasadena, and the Grand Valley State University Art Galleries, as well as in numerous private and institutional collections. Date A point or period of time associated with an event in the lifecycle of the resource 1960-2011 Source A related resource from which the described resource is derived <a href="%E2%80%9Dhttps%3A//gvsu.lyrasistechnology.org/repositories/2/resources/783%E2%80%9D">Douglas R. Gilbert Papers (RHC-183)</a> Rights Information about rights held in and over the resource In Copyright Subject The topic of the resource Photographs Photography -- United States Publisher An entity responsible for making the resource available Grand Valley State University. University Libraries. Special Collections and University Archives. Identifier An unambiguous reference to the resource within a given context RHC-183 Format The file format, physical medium, or dimensions of the resource Image Type The nature or genre of the resource image/jpeg Language A language of the resource eng 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. 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-183_Z038-0017a Creator An entity primarily responsible for making the resource Gilbert, Douglas R. Date A point or period of time associated with an event in the lifecycle of the resource 1985-09-01 Title A name given to the resource Witch Castle Ride, Salisbury Beach Description An account of the resource Black and white photograph of the "Witch Castle" amusement park dark ride at Salisbury Beach’s Amusement Center in Salisbury, Massachusetts. Scanned from the negative. Subject The topic of the resource Amusement rides--Massachusetts--Salisbury Salisbury (Mass.) Salisbury (Mass. : Town) Black-and-white photography Source A related resource from which the described resource is derived <a href="https://gvsu.lyrasistechnology.org/repositories/2/resources/783">Douglas R. Gilbert papers (RHC-183)</a> 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 Image Format The file format, physical medium, or dimensions of the resource image/jpeg Coverage The spatial or temporal topic of the resource, the spatial applicability of the resource, or the jurisdiction under which the resource is relevant 1980s 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/3506b4b87cf3d3cc0a5bf983bbb77bc0.jpg 971f9f90dbb3fb4caea0ea631d0babfb 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 Douglas R. Gilbert Photographs Creator An entity primarily responsible for making the resource Gilbert, Douglas R., 1942-2023 Description An account of the resource Photographs scanned from negatives and transparencies from the Douglas R. Gilbert papers (RHC-183). Douglas R. Gilbert (b. 1942) is an American photographer from Michigan. He was born in Holland, Michigan and is the son of Russell W. and Carmen (Andree) Gilbert. Gilbert earned a B.A. in social sciences and art at Michigan State University in 1964, an M.S. in photography from the Institute of Design at Illinois Institute of Technology in 1972, and a M.S.W. from Salem State College in 1993. He is married to Barbara (McDonald) Gilbert, and has three daughters, Robyn, Rachel, and Anne. Gilbert took a serious interest in photography at the age of fourteen. In 1963 he joined the staff of Look magazine in New York as the second youngest photojournalist in the magazine's history. As a Look photographer from 1964 to 1966, he photographed folk musician Bob Dylan, the Newport Folk Festival, Simon and Garfunkel, the New York City Financial District, the children and facilities at the Manhattan School for Seriously Disturbed Children. From 1967 to 1969, Gilbert did several shoots, including that of folk singer Janis Ian for Life magazine. After moving to Chicago, Illinois in 1969 to attend the Illinois Institute of Technology, Gilbert conducted notable photo shoots of business and political figure Lenore Romney, and pursued more personal and artistic photography, focusing on urban and rural landscapes in Illinois and Michigan. He then joined the faculty of Wheaton College, where he taught from 1972 to 1982. In 1993, Gilbert graduated from Salem State College, Massachusetts, with a Masters in Social Work, and later pursued a second career as a psychotherapist. Douglas Gilbert died in June 2023. Throughout his photography career, he pursued both freelance commercial work as well as artistic work. His art photography is characterized by its classic black-and-white format, and features people, places and objects shot great attention and sensitivity. Gilbert's works are held in the permanent collections of the Art Institute of Chicago, the High Museum of Art in Atlanta, The Norton Simon Museum in Pasadena, and the Grand Valley State University Art Galleries, as well as in numerous private and institutional collections. Date A point or period of time associated with an event in the lifecycle of the resource 1960-2011 Source A related resource from which the described resource is derived <a href="%E2%80%9Dhttps%3A//gvsu.lyrasistechnology.org/repositories/2/resources/783%E2%80%9D">Douglas R. Gilbert Papers (RHC-183)</a> Rights Information about rights held in and over the resource In Copyright Subject The topic of the resource Photographs Photography -- United States Publisher An entity responsible for making the resource available Grand Valley State University. University Libraries. Special Collections and University Archives. Identifier An unambiguous reference to the resource within a given context RHC-183 Format The file format, physical medium, or dimensions of the resource Image Type The nature or genre of the resource image/jpeg Language A language of the resource eng 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. 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-183_Z037-0044a Creator An entity primarily responsible for making the resource Gilbert, Douglas R. Date A point or period of time associated with an event in the lifecycle of the resource 1985-09-01 Title A name given to the resource Pirate Ship Ride, Salisbury Beach Description An account of the resource Black and white photograph of a "Sea Dragon" pirate ship amusement ride at Salisbury Beach’s Amusement Center in Salisbury, Massachusetts. Scanned from the negative. Subject The topic of the resource Amusement rides--Massachusetts--Salisbury Salisbury (Mass.) Salisbury (Mass. : Town) Black-and-white photography Source A related resource from which the described resource is derived <a href="https://gvsu.lyrasistechnology.org/repositories/2/resources/783">Douglas R. Gilbert papers (RHC-183)</a> 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 Image Format The file format, physical medium, or dimensions of the resource image/jpeg Coverage The spatial or temporal topic of the resource, the spatial applicability of the resource, or the jurisdiction under which the resource is relevant 1980s 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/d1043736a0a7b1d12989f23ccedc7c2d.jpg 89fc6a4ab43e8999a412e7c98a5809d3 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 Douglas R. Gilbert Photographs Creator An entity primarily responsible for making the resource Gilbert, Douglas R., 1942-2023 Description An account of the resource Photographs scanned from negatives and transparencies from the Douglas R. Gilbert papers (RHC-183). Douglas R. Gilbert (b. 1942) is an American photographer from Michigan. He was born in Holland, Michigan and is the son of Russell W. and Carmen (Andree) Gilbert. Gilbert earned a B.A. in social sciences and art at Michigan State University in 1964, an M.S. in photography from the Institute of Design at Illinois Institute of Technology in 1972, and a M.S.W. from Salem State College in 1993. He is married to Barbara (McDonald) Gilbert, and has three daughters, Robyn, Rachel, and Anne. Gilbert took a serious interest in photography at the age of fourteen. In 1963 he joined the staff of Look magazine in New York as the second youngest photojournalist in the magazine's history. As a Look photographer from 1964 to 1966, he photographed folk musician Bob Dylan, the Newport Folk Festival, Simon and Garfunkel, the New York City Financial District, the children and facilities at the Manhattan School for Seriously Disturbed Children. From 1967 to 1969, Gilbert did several shoots, including that of folk singer Janis Ian for Life magazine. After moving to Chicago, Illinois in 1969 to attend the Illinois Institute of Technology, Gilbert conducted notable photo shoots of business and political figure Lenore Romney, and pursued more personal and artistic photography, focusing on urban and rural landscapes in Illinois and Michigan. He then joined the faculty of Wheaton College, where he taught from 1972 to 1982. In 1993, Gilbert graduated from Salem State College, Massachusetts, with a Masters in Social Work, and later pursued a second career as a psychotherapist. Douglas Gilbert died in June 2023. Throughout his photography career, he pursued both freelance commercial work as well as artistic work. His art photography is characterized by its classic black-and-white format, and features people, places and objects shot great attention and sensitivity. Gilbert's works are held in the permanent collections of the Art Institute of Chicago, the High Museum of Art in Atlanta, The Norton Simon Museum in Pasadena, and the Grand Valley State University Art Galleries, as well as in numerous private and institutional collections. Date A point or period of time associated with an event in the lifecycle of the resource 1960-2011 Source A related resource from which the described resource is derived <a href="%E2%80%9Dhttps%3A//gvsu.lyrasistechnology.org/repositories/2/resources/783%E2%80%9D">Douglas R. Gilbert Papers (RHC-183)</a> Rights Information about rights held in and over the resource In Copyright Subject The topic of the resource Photographs Photography -- United States Publisher An entity responsible for making the resource available Grand Valley State University. University Libraries. Special Collections and University Archives. Identifier An unambiguous reference to the resource within a given context RHC-183 Format The file format, physical medium, or dimensions of the resource Image Type The nature or genre of the resource image/jpeg Language A language of the resource eng 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. 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-183_Z037-0040a Creator An entity primarily responsible for making the resource Gilbert, Douglas R. Date A point or period of time associated with an event in the lifecycle of the resource 1985-09-01 Title A name given to the resource Go-Cart Racing, Salisbury Beach Description An account of the resource Black and white photograph of a go-kart race track at Salisbury Beach’s Amusement Center in Salisbury, Massachusetts. Scanned from the negative. Subject The topic of the resource Karts (Automobiles)--Massachusetts--Salisbury Amusement rides--Massachusetts--Salisbury Salisbury (Mass.) Salisbury (Mass. : Town) Black-and-white photography Source A related resource from which the described resource is derived <a href="https://gvsu.lyrasistechnology.org/repositories/2/resources/783">Douglas R. Gilbert papers (RHC-183)</a> 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 Image Format The file format, physical medium, or dimensions of the resource image/jpeg Coverage The spatial or temporal topic of the resource, the spatial applicability of the resource, or the jurisdiction under which the resource is relevant 1980s 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/647589857ac6097926f06d17fee83031.jpg 7a0ebf095d33be80d6c0e3cefee6576b 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 Douglas R. Gilbert Photographs Creator An entity primarily responsible for making the resource Gilbert, Douglas R., 1942-2023 Description An account of the resource Photographs scanned from negatives and transparencies from the Douglas R. Gilbert papers (RHC-183). Douglas R. Gilbert (b. 1942) is an American photographer from Michigan. He was born in Holland, Michigan and is the son of Russell W. and Carmen (Andree) Gilbert. Gilbert earned a B.A. in social sciences and art at Michigan State University in 1964, an M.S. in photography from the Institute of Design at Illinois Institute of Technology in 1972, and a M.S.W. from Salem State College in 1993. He is married to Barbara (McDonald) Gilbert, and has three daughters, Robyn, Rachel, and Anne. Gilbert took a serious interest in photography at the age of fourteen. In 1963 he joined the staff of Look magazine in New York as the second youngest photojournalist in the magazine's history. As a Look photographer from 1964 to 1966, he photographed folk musician Bob Dylan, the Newport Folk Festival, Simon and Garfunkel, the New York City Financial District, the children and facilities at the Manhattan School for Seriously Disturbed Children. From 1967 to 1969, Gilbert did several shoots, including that of folk singer Janis Ian for Life magazine. After moving to Chicago, Illinois in 1969 to attend the Illinois Institute of Technology, Gilbert conducted notable photo shoots of business and political figure Lenore Romney, and pursued more personal and artistic photography, focusing on urban and rural landscapes in Illinois and Michigan. He then joined the faculty of Wheaton College, where he taught from 1972 to 1982. In 1993, Gilbert graduated from Salem State College, Massachusetts, with a Masters in Social Work, and later pursued a second career as a psychotherapist. Douglas Gilbert died in June 2023. Throughout his photography career, he pursued both freelance commercial work as well as artistic work. His art photography is characterized by its classic black-and-white format, and features people, places and objects shot great attention and sensitivity. Gilbert's works are held in the permanent collections of the Art Institute of Chicago, the High Museum of Art in Atlanta, The Norton Simon Museum in Pasadena, and the Grand Valley State University Art Galleries, as well as in numerous private and institutional collections. Date A point or period of time associated with an event in the lifecycle of the resource 1960-2011 Source A related resource from which the described resource is derived <a href="%E2%80%9Dhttps%3A//gvsu.lyrasistechnology.org/repositories/2/resources/783%E2%80%9D">Douglas R. Gilbert Papers (RHC-183)</a> Rights Information about rights held in and over the resource In Copyright Subject The topic of the resource Photographs Photography -- United States Publisher An entity responsible for making the resource available Grand Valley State University. University Libraries. Special Collections and University Archives. Identifier An unambiguous reference to the resource within a given context RHC-183 Format The file format, physical medium, or dimensions of the resource Image Type The nature or genre of the resource image/jpeg Language A language of the resource eng 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. 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-183_Z037-0014a Creator An entity primarily responsible for making the resource Gilbert, Douglas R. Date A point or period of time associated with an event in the lifecycle of the resource 1985-09-01 Title A name given to the resource Zig-Zag Ride, Salisbury Beach Description An account of the resource Black and white photograph of a "Zig-Zag" amusement ride at Salisbury Beach’s Amusement Center in Salisbury, Massachusetts. Scanned from the negative. Subject The topic of the resource Amusement rides--Massachusetts--Salisbury Salisbury (Mass.) Salisbury (Mass. : Town) Black-and-white photography Source A related resource from which the described resource is derived <a href="https://gvsu.lyrasistechnology.org/repositories/2/resources/783">Douglas R. Gilbert papers (RHC-183)</a> 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 Image Format The file format, physical medium, or dimensions of the resource image/jpeg Coverage The spatial or temporal topic of the resource, the spatial applicability of the resource, or the jurisdiction under which the resource is relevant 1980s 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/da4d19756bdd1a81b96128861b3affa2.jpg 355e226e257e09940722bc77d0d7a4c3 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 Douglas R. Gilbert Photographs Creator An entity primarily responsible for making the resource Gilbert, Douglas R., 1942-2023 Description An account of the resource Photographs scanned from negatives and transparencies from the Douglas R. Gilbert papers (RHC-183). Douglas R. Gilbert (b. 1942) is an American photographer from Michigan. He was born in Holland, Michigan and is the son of Russell W. and Carmen (Andree) Gilbert. Gilbert earned a B.A. in social sciences and art at Michigan State University in 1964, an M.S. in photography from the Institute of Design at Illinois Institute of Technology in 1972, and a M.S.W. from Salem State College in 1993. He is married to Barbara (McDonald) Gilbert, and has three daughters, Robyn, Rachel, and Anne. Gilbert took a serious interest in photography at the age of fourteen. In 1963 he joined the staff of Look magazine in New York as the second youngest photojournalist in the magazine's history. As a Look photographer from 1964 to 1966, he photographed folk musician Bob Dylan, the Newport Folk Festival, Simon and Garfunkel, the New York City Financial District, the children and facilities at the Manhattan School for Seriously Disturbed Children. From 1967 to 1969, Gilbert did several shoots, including that of folk singer Janis Ian for Life magazine. After moving to Chicago, Illinois in 1969 to attend the Illinois Institute of Technology, Gilbert conducted notable photo shoots of business and political figure Lenore Romney, and pursued more personal and artistic photography, focusing on urban and rural landscapes in Illinois and Michigan. He then joined the faculty of Wheaton College, where he taught from 1972 to 1982. In 1993, Gilbert graduated from Salem State College, Massachusetts, with a Masters in Social Work, and later pursued a second career as a psychotherapist. Douglas Gilbert died in June 2023. Throughout his photography career, he pursued both freelance commercial work as well as artistic work. His art photography is characterized by its classic black-and-white format, and features people, places and objects shot great attention and sensitivity. Gilbert's works are held in the permanent collections of the Art Institute of Chicago, the High Museum of Art in Atlanta, The Norton Simon Museum in Pasadena, and the Grand Valley State University Art Galleries, as well as in numerous private and institutional collections. Date A point or period of time associated with an event in the lifecycle of the resource 1960-2011 Source A related resource from which the described resource is derived <a href="%E2%80%9Dhttps%3A//gvsu.lyrasistechnology.org/repositories/2/resources/783%E2%80%9D">Douglas R. Gilbert Papers (RHC-183)</a> Rights Information about rights held in and over the resource In Copyright Subject The topic of the resource Photographs Photography -- United States Publisher An entity responsible for making the resource available Grand Valley State University. University Libraries. Special Collections and University Archives. Identifier An unambiguous reference to the resource within a given context RHC-183 Format The file format, physical medium, or dimensions of the resource Image Type The nature or genre of the resource image/jpeg Language A language of the resource eng 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. 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-183_Z037-0010a Creator An entity primarily responsible for making the resource Gilbert, Douglas R. Date A point or period of time associated with an event in the lifecycle of the resource 1985-09-01 Title A name given to the resource Roll Over Barrel Ride, Salisbury Beach Description An account of the resource Black and white photograph of a "Roll Over Barrel" amusement ride at Salisbury Beach’s Amusement Center in Salisbury, Massachusetts. Scanned from the negative. Subject The topic of the resource Amusement rides--Massachusetts--Salisbury Salisbury (Mass.) Salisbury (Mass. : Town) Black-and-white photography Source A related resource from which the described resource is derived <a href="https://gvsu.lyrasistechnology.org/repositories/2/resources/783">Douglas R. Gilbert papers (RHC-183)</a> 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 Image Format The file format, physical medium, or dimensions of the resource image/jpeg Coverage The spatial or temporal topic of the resource, the spatial applicability of the resource, or the jurisdiction under which the resource is relevant 1980s 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/44d93efa3e7edf0d0d2725502e5ac4a7.jpg ca7b9ffb85fd6288f778a18ff8c41ed7 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 Douglas R. Gilbert Photographs Creator An entity primarily responsible for making the resource Gilbert, Douglas R., 1942-2023 Description An account of the resource Photographs scanned from negatives and transparencies from the Douglas R. Gilbert papers (RHC-183). Douglas R. Gilbert (b. 1942) is an American photographer from Michigan. He was born in Holland, Michigan and is the son of Russell W. and Carmen (Andree) Gilbert. Gilbert earned a B.A. in social sciences and art at Michigan State University in 1964, an M.S. in photography from the Institute of Design at Illinois Institute of Technology in 1972, and a M.S.W. from Salem State College in 1993. He is married to Barbara (McDonald) Gilbert, and has three daughters, Robyn, Rachel, and Anne. Gilbert took a serious interest in photography at the age of fourteen. In 1963 he joined the staff of Look magazine in New York as the second youngest photojournalist in the magazine's history. As a Look photographer from 1964 to 1966, he photographed folk musician Bob Dylan, the Newport Folk Festival, Simon and Garfunkel, the New York City Financial District, the children and facilities at the Manhattan School for Seriously Disturbed Children. From 1967 to 1969, Gilbert did several shoots, including that of folk singer Janis Ian for Life magazine. After moving to Chicago, Illinois in 1969 to attend the Illinois Institute of Technology, Gilbert conducted notable photo shoots of business and political figure Lenore Romney, and pursued more personal and artistic photography, focusing on urban and rural landscapes in Illinois and Michigan. He then joined the faculty of Wheaton College, where he taught from 1972 to 1982. In 1993, Gilbert graduated from Salem State College, Massachusetts, with a Masters in Social Work, and later pursued a second career as a psychotherapist. Douglas Gilbert died in June 2023. Throughout his photography career, he pursued both freelance commercial work as well as artistic work. His art photography is characterized by its classic black-and-white format, and features people, places and objects shot great attention and sensitivity. Gilbert's works are held in the permanent collections of the Art Institute of Chicago, the High Museum of Art in Atlanta, The Norton Simon Museum in Pasadena, and the Grand Valley State University Art Galleries, as well as in numerous private and institutional collections. Date A point or period of time associated with an event in the lifecycle of the resource 1960-2011 Source A related resource from which the described resource is derived <a href="%E2%80%9Dhttps%3A//gvsu.lyrasistechnology.org/repositories/2/resources/783%E2%80%9D">Douglas R. Gilbert Papers (RHC-183)</a> Rights Information about rights held in and over the resource In Copyright Subject The topic of the resource Photographs Photography -- United States Publisher An entity responsible for making the resource available Grand Valley State University. University Libraries. Special Collections and University Archives. Identifier An unambiguous reference to the resource within a given context RHC-183 Format The file format, physical medium, or dimensions of the resource Image Type The nature or genre of the resource image/jpeg Language A language of the resource eng 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. 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-183_Z036-0044a Creator An entity primarily responsible for making the resource Gilbert, Douglas R. Date A point or period of time associated with an event in the lifecycle of the resource 1985-09-01 Title A name given to the resource Three Wise Owls Machine, Salisbury Beach Description An account of the resource Black and white photograph of a "Three Wise Owls" amusement park machine located at Salisbury Beach’s Amusement Center in Salisbury, Massachusetts. In the photograph, a sign is hanging above the machine that reads, "The Three Wise Owls Can Tell 1 Cent." Scanned from the negative. Subject The topic of the resource Amusements--Massachusetts--Salisbury Salisbury (Mass.) Salisbury (Mass. : Town) Black-and-white photography Source A related resource from which the described resource is derived <a href="https://gvsu.lyrasistechnology.org/repositories/2/resources/783">Douglas R. Gilbert papers (RHC-183)</a> 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 Image Format The file format, physical medium, or dimensions of the resource image/jpeg Coverage The spatial or temporal topic of the resource, the spatial applicability of the resource, or the jurisdiction under which the resource is relevant 1980s Publisher An entity responsible for making the resource available Grand Valley State University. University Libraries. Lemmen Library and Archives