519 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/a42cf776085ca4f2471548e75f643f12.mp4 316a3c4d6b080cc13b2e6fb5271cb0ba https://digitalcollections.library.gvsu.edu/files/original/ea26423f111872525bd82ab4384adea3.pdf 4454970f31735606fda33697736d32d4 PDF Text Text Living with PFAS Interviewer: Dani | Interviewee: Lynn | Date of Interview: 7/29/2021 5:00:00 AM Danielle DeVasto: All right. So, I'm Dani DeVasto, and today, July 29, 2021, I have the pleasure of talking with Lynn McIntosh. Hi, Lynn. Thanks for being here today. Well, thanks for having me here with you, really. Lynn Macintosh: Yeah. Thank you for coming all this way. Danielle DeVasto: Lynn, can you tell us where you are from and where you currently live? Lynn Macintosh: Well, I'm actually from the east coast. I lived most of my life growing up on the east coast, Pennsylvania, New York, and I live now here in Rockford, where I've lived for, oh, 30 years. Thirty years. Danielle DeVasto: Wonderful. Wonderful. Lynn, can you please tell me a story about your experience living with PFAS? Lynn Macintosh: Thank you. Uh, my experience with PFAS is really on the discovery of it and the living in a town [CLICK SOUND] that spewed this into the river for years, for decades, and no one really say much about it, I think, because it's white and it's foamy, and when water goes thrashing over a dam and bubbles up, because although some of the __________ 00:01:26, it's like they were years ago, it's white, it's not an oil spill __________ 00:01:32. It's sudsy, suds make you think of clean, it's white, and, um, [CLICK SOUND] I didn't even notice it when I first moved here, but I started to notice it in the summer of 2009 and 2010, when I heard that this tannery, that's right behind me, location, location, location, I happened to move, uh, just east of a tannery, coming here from the east coast and not understanding that, and about that time when I was really concerned about this tanuh, this- [LIP SMACK] this, uh, approaching demolition, I started noticing it a little bit more than I had before, and they started taking pictures of the river, and I started noticing foam, and I collected them. I have a lot of them in a book here, and I sent them all over the place, uh, of these pictures of this awful, not even so much of just the foam, but this filmy, weird, um, substance that appeared frequently. I suppose this- this picture really shows what it was like because it was almost a pre-foam stage and it would just sort of sit on the river and if you threw something into it, it would make a hole and then close up, and it was really odd to me, and I started going on the river and kayaking, and I got pictures sometimes of the foam looking like this, piled up. This is a close up of that other picture that I had before. It's much better. I would see puddles like this when the ice melted. I'd see big spots of it. So, anyway, I started noticing the river, and one day, many years later, if I could have that picture again, I saw this picture from Wurtsmith in a photo, and I looked at that picture seven years later and I thought, why did they have a picture of Wolverine's foam in this article about Wurtsmith? 'Cause up til now all I could conclude was that it was a surfactant. As a citizen, I worked with Dr. Rediske, who told me how to do some basic sampling on the river, and when I would go and do my little samples, I decided to always add in checking for the surfactant level, and I had done some research about natural foams and these kinds of foams, and I knew that this foam wasn't good for the river, but I Page 1 �didn't know it was PFAS. [BANG SOUND] But I did start observing it. It's like my eyes were open to the river. I thought this is really weird, and when my- my eyes were on the river and- and my concern was for this coming demolition, so I started training myself, taking walks and observing things, uh, in that summer, and it started this avalanche of questions and deepened my concern about this approaching demolition on the tannery. I had seen that we live in a town and you're busy with young kids, you assume that your town's taking care of you and your water's safe and all that. Everyone cares and is doing their job, and after having witnessed a demolition gone awry in my own backyard with asbestos clouds flying in the air right behind me the year before and having to report that to the DEQ and going through the whole coverage of it, this lovely little home here was riddled with asbestos, as pretty as it is, and they took it all down without removing any of it. So, living in Rockford, now, in 2009 and 2010, after my two older children had graduated and one- one other daughter who, uh, was here until 2012, I said to myself, this is a tannery, this is 15 acres. It's obvious that my city doesn't care if they're actually in, they were in kind of cahoots with all. They got fined, everybody involved in that asbestos, they also got fined. Um, they had to haul it to maul it to licensed, haul it to a licenced landfill, and, um, and it was a dangerous thing to do. It was so irresponsible, and all the city did was do what happens a lot in politics, put a spin on it, downplay it, and make it out to be my fault or other people's fault, __________ 00:07:05, and that, too, was very clear. So, I got involved in researching this demolition, and I became what I like to talk about in my way of doing it, I hired myself [LAUGHTER] one day without an interview [LAUGHTER] to investigate this, and I called myself a ragtag. I was part of the ragtags. I was- I was a hub of the ragtags, and I found other citizens, friends, people I knew, who cared, people who were recently retired, [CHUCKLE] who were home during the day to come down and help me, first of all and do field investigations. I found a fisherman, who knew we called on the Islands of the Lost Soles up there. It's a shoe company and that [CHUCKLE] was the mystic. This fisherman said, "Oh, yeah, have you been north to see the Islands of the Lost Soles?" It's pretty- pretty gruesome up there, the foam and the stench and, so I went up there and, so I had one- one particular fisherman who went out with me- with me that day, and we also noticed the foamy, filmy stuff. Uh, I had a friend who I would call in the middle of the day, who was recently retired. [CHUCKLE] Sometimes I'd send him down to city hall with my camera to get photos of aerial views 'cause they didn't want to see me too much at city hall, and I didn't want to see them. So, [CHUCKLE] and he would playfully, and actually I think he meant it, try to get out of some of these things, but, um, [LAUGHTER] I was persistent, and he was a friend, so I was llike, he would say things like, "Well, I- I can't go down, I don't have a good camera." Here, take mine. "Oh." [LAUGHTER] Or, in the middle of the day, Andrew, I need you to get down to the river right now. "What's going on?" I said, there's 14 dead fish in the river right near the tannery. "So, uh, it's a little late for them." [LAUGHTER] And I said, no, no, you don't get it. This is a fish kill. I learned this phrase from the Department of Environmental Quality, have there been any fish kills? He's like, "Oh, this is a fish kill." So, I knew Andrew, I knew he was home, and I used my little flip phone, which I used in all my escapades up to 2018, actually. I had his number memorized, I called him up, and convinced him to come down with a bucket and a butterfly net Page 2 �and to reach through this grated bridge over the river using his length of arm, and he was six feet tall, so he's, like, really spread across the trail and he's scooping out dead fish for me and we're putting them in a bucket, and I'm bringing them down to the DEQ. This is forensic evidence. [CHUCKLE] I had people taking photos for me, walking around the tannery while it was going on, getting photos of dust. [LIP SMACK] I had people who would come meet me and get samples of the- of the river. I finally met someone who was troubled by it, too, and I said, yeah, I'd really like to get some sediment samples of this river and at that point, my husband had lost a lot of enthusiasm for helping me out on these ventures, especially after I lost his- his, uh, boots, his, uh, fisherman's boots, that I left in a thicket by the river, and he said, "Well, I'll go out with you," and so it was pretty much anybody who was tall and willing and able. I would they became, they joined the ragtags. Yeah, they helped me, uh, collect a lot of good evidence. So, we ended up getting sediment samples by taking PVC pipes and jamming it down in and water out. It was really exciting. Um, so, anyway, for about two years, I was running on kind of this startled, urgent energy that there's something wrong here. This demolition is not going to be safe. I was right, it wasn't, but the more I asked, the more I realized I needed to stay involved because outside my little city and my city government and my county and the Department of Environmental Quality in Grand Rapids, and my legislators, who didn't really want to be involved outside of that, when I would get to top people at the EPA or top people in other states or research by phone, they were like, "Really? Tell me that again. Well, who's the project, who's the project leader?" There isn't one. "No, there has to be one." No, there's no project leader. "Hmm, well what about the water department? Aren't they getting samples of the sediment? They can at least do that. They don't have to get on site to do that." Nope, they're declining. "Well, what about is- aren't there any incentives they can get to get compensated?" Yeah, they tried to get them to do a testing on baseline __________ 00:12:22, phase one, phase two, and they were given this amount of money, and Wolverine said, “No, thank you." Um, we knew that the people, some of the good people in DEQ were actually concerned, but nobody felt like they had the authority or wanted to step out and risk the ire of the company or even the governor at that time or any of that. So, [LIP SMACK] when our facts and our findings raised eyebrows everywhere else, we knew that we were right and then started to connect the ragtags to what I call the credibles [CHUCKLE] and A. J. Birkbeck, the environmental attorney, who represented our little group in 2010. He was a credible. He was an environmental attorney. Dr. __________ 00:13:15, who came in probably around the second half of 2012, and then full in, in 2015, 2016, was a credible, and someone from the DEQ, who was retired, which we loved people- good people who are retired, because they were now neu-, neutral and they could get involved, and Janice Tompkins heard me make a presentation at the river watershed council and I showed her a note that she was concerned, so she joined in and so, A. J. and Rick and Janice were thither were the hub of the credibles, and people respected them, so they could be the face, and Janice brought in other environmental groups, so that I could take what we found here, as the ragtags and then I would, um, I would say I was like second string on the credibles, but, you know, I was allowed into the room. We would go to Grand Valley, and meet [CHUCKLE] in- in, uh, one of the conference rooms there, and I would try to Page 3 �contain some of my angst and passion and- and enter into the rational looking over of evidence and making a plan and an agenda and carefully working through in strategic ways to make the most of what we got and never going to the media because A. J. forbid that, and he was right. We didn't go to the- the, uh, media until, I didn't go to the media until the summer of 2017. That was incredibly important to be the one living here, because I knew- I knew the lay of the land. I learned quickly to get permission to be on any property that I needed to be on to get good photographs and I knew a lot of people anyway who cared. So, I made sure I had lots of places where I could go and get photos. [CHUCKLE] And across the river, they put in this boardwalk high up, and I remember someone saying to me one day, "Oh, look at that over there. You could probably get some great photos from across the river." I'm like, oh, yeah, why didn't I see that? Uh, I found the ladder on the side of the post office and it was a ladder on the side of the shoe- shoe store. [CHUCKLE] I found all my crutches. There was a ladder I used to climb up onto my neighbor's roof of her porch right behind me, because part way during the demolition of this tannery, there's a __________ 00:16:09 and some people __________ 00:16:10 looking at birds. Um, [CHUCKLE] they- they hated that I was taking photos. So, I would- I would go right up to the fence. That didn't matter to me what this group thought of me. I wanted- I wanted photos, [CLICK SOUND] and after a while, they realized they didn't want these photos, so, they would circle at- at the start of the day, wherever they were working, they would take trucks and sort of circle the wagon, I think that's a phrase people used. Maybe it comes from the days of pioneers where you, to protect, yeah. So, they would take any truck they had, except the one that was being used and they would Lynne them up around where they were working. So, I couldn't get photos, and so then I found out [NOISE] that I could, it was higher up over here and I was, and I was up on that neighbor's roof with a good zoom camera. I could see what they were doing. And, uh, I- I taught piano lessons during that time, actually. I- I taught until my mom came out in 2013, so I do remember one day when I'm sitting here, and I'm teaching a piano lesson, and I'm very concerned in November, because I know they're getting right near an area of the tannery that I knew was bad and I'm concerned about dust clouds, and we had- we had at least made some progress with insisting on dust control, even though we didn't have site testing. Again, it was imperfect, but I knew the only way I could get, make sure that they kept up with it was to report big fugitive, fugitive dust clouds is what they called them. So, if there was a big ka-bang, and it was in this really bad part, and I was having a piano lesson, the only thing I could do was what I ended up doing. Uh, I remember the- my student's name was Casey and I- I said, Casey, I said, well, first of all, I'm sitting there in the lesson, I'm listening to her play, and I'm also half listening. You can see the window right there and like we got our ears kinda cranked out the window just waiting and I hear this huge ka-boom and I'm like, oh, my gosh. There's gonna be dust. Casey, I said, do your Mini Latin Jig three more times [CHUCKLE], practice scales, C major, G major, I'll be back in five minutes, and I ran out the back door, through my yard, into my neighbor's yard. I had thethe ladder already there, climbed up, had my camera set, ready to go and got these great photos from the November dust. I came back down, brought my camera, came back through here, as she was doing the last- the last time through in G. Oh, okay, well, let's go back to that one section and then I would just go Page 4 �on with my life. I, uh, I've used this phrase, and I think it was very true for me. They always talk about buy local so, mine was, like, buy local, spy local, it's just part of your life. If you don't have time to do this full time, [NOISE] well, just incorporate it into your life. I still get water samples and make my errands for the day, okay go shopping, drop off water samples, um, and then I would decide, let's see, I have enough money today to buy eggs and frozen vegetables and dah-dah-dah and I have enough money to buy samples to get, uh, let's see, I don't know the Michigan 10, which is the, um, metals, and that's a good deal, but it's-still don't have your $10. [LAUGHTER] So maybe today I'll just do, hmm, chromium [LAUGHTER] __________ 00:00:07. Should I add in mercury for an extra 25? Hexachrome means I have to get it there within 24 hours. No, I don't have time to do the hexa chrome today. [LAUGHTER] And so I would make these little judgment calls about what I could afford, because we actually did have to put money on the table. I have found the ragtags, uh, our group, our loosely formed group CCRR, we decided to pay the money to help us guide us and to be strategic, and that was money enormously well spent. We wouldn't have gotten where we needed to be without that. We needed A.J. Uh, Rick being a professor and a citizen. And of course we didn't pay him, but we did pay for our own samples. And we did pay, um, thousands of dollars, actually over time. And I never regret it, because you never have that moment in time again. Money is this odd thing. You go to, uh, nonprofit groups, and they're always talking about the budget and how to raise money. And, "If we had money, or if we got this grant dut dut dut dut dut dut da, then we could do this." And by the time you really need the money or you could have gotten the information, it's three years later, and it'sit's not even helpful at that point. So my dad, rascal that he was, [LAUGHTER] taught me to love the environment, taught me to not just accept no for an answer, ifif it was a no that was preventing good. And I had inherited some money. I never planned on it, never really even thought about it. And part of it I decided in honor of him I would use that money in a meaningful way to do that. It had a purpose. And my dad, before he passed away in 2011, was curious about what was happening. And it was my dad who had gotten me out into the wilds, into the rivers, swimming, and looking, loving. And it was my dad who taught me to roam, and wander, and figure it out as you go along. So I was comfortable with that. So it was meaningful and necessary. And it wasn't anything that I've everever thought back on. But I do say this to other people who want to get involved. Sometimes you do have to take your own money and put it out there. Because if you wait, you won't have that chance. And companies don't talk about it. They try to run up your bill if you get a lawyer. They try to discourage you in any way. And they have thousands and hundreds of thousands of dollars to spend. And it took them totally aback when we hired A.J., and when Rick and Janice started joining us. And when Westshore Environmental Consulting wrote up our samples into an actual report, which we handed to the EPA. And they were like, because they did not want there to be evidence. They didn't want facts. They didn't want that, and we knew that was the only safe way we could get anywhere. Pe--people, a news story is up and over in a day. They manage bad news, but they can't [LAUGHTER] samples for chromium, uh, mercury at screening levels with the sediment there, which weyou can't expect that. They try, but ultimately can't. Soso my story of being here with the ragtags, and reaching out to organizations beyond finding the Page 5 �credibles, um, being loosely organized, which was great because I compared that to being like a mountaineering group. Uh, back in the old days with mountaineering they used to have the Sherpas who would carry all your stuff. And you set up camp, and then you wait, and wait, and wait. Then you go to the next level. Then finally someone figured out light mountaineering. I don't know if that's a term they use, but just carry it yourself and keep moving. That's kind of how we moved, [CLEARS THROAT] by not being this official, organized group. We had no website. We didn't accept donations. We didn't have to account for anything. We were just sort of had this mutual agreement to stick together. And A.J. was our attorney, and Rick was our adviser, and Janice was our adviser, and they all worked with us. And that collaboration and the energy that comes from that, the mutual respect without having to like write it into a mission statement was there. And for me, I came to just simply enjoy them as characters. And yes, there wereit wasn't perfect. There were certain members who didn't really get the other ones. [LAUGHTER] And I was sort of the translator LAUGHTER] between different members. What I'd say is what I would sort of like explain this and that. "Really?" Yeah. Yeah. I think that's what you're-- "Oh, okay." [LAUGHTER] Because people are really quick to label each other and not move past that. And I guess being a writer and loving stories, I see the complexity, and the humor, and the, uh, human quality of all of us, [LAUGHTER] So I could see theI could be somewhat removed from it, not get entrapped in it, which was very helpful. Danielle Devasto: I bet. [LAUGHTER] Lynn Macintosh: There are a few people that I encountered that I think had I not had that attitude, people would have just decided not to work with that person, or not see the value. And somehow maybe it's just being who I am. Maybe it's being the age I was. I was able to find creative ways to soften things and bridge things, which was really, uh, which was really good because we've all come through on the other side and continued to work together afterwards. And these colleagues have only become more and more friends as we've spent more time together. Danielle Devasto: Well, and it sounds like this collaboration has been really critical in moving forward anything related to the tannery site it seems. Lynn Macintosh: Uhuh yeah, yeah, it was. And then the connections that Janice made, or ideas that others had. And finally myself bumping into or finding people from the DEQ who became interested, even though it wasn't theirnecessarily their project. There was one at the EPA who opened the door for us basically when he heard about early on this disaster. And he confirmed it. Hehe had the authority to call in to the DEQ. He called the city, and he called me back. He said, "My gosh, you're right, there's a total disconnect here. Nobody knows what's going on." And he was the one who said, "Well, if all else fails, get hundreds of photos. Talk to the tannery workers. Get it all done, and send us a petition __________ 00:08:16 , which is what we did a year later. Soso the way this story works is we all worked very effectively. We got the EPA out. After the disastrous, very unsafe demolition they came out and, um, basically, II think [LAUGHTER] I had showed you somewhere over here, you know, in the Rockford Independent, um, you know, there's this big article that came out in September. They accepted our Page 6 �invitation, or our petition. The EPA launches probe at tannery site. And, uh, there's all these nasty things already said about us in that article by the city manager and others. I don't want to go into all those. And it was, uh, it we got some sampling done. And then the city, and the legislators, and all of the players who had prevented things from happening as they should have, they, uh, convinced the EPA to give them oversight. So [LAUGHTER] then later it's kind of like __________ 00:09:28. It's almost like, The war is over! [LAUGHTER] EPA is going away! That's kind of how we felt like, Go away, EPA. We'll take care of it. We'll keep hiding this. [LAUGHTER] You know? Um, and so in 2012, after all our efforts, we worked so hard, everything went back to the status quo. It went back to exactly how it was before it happened. And Lynn Macintosh: I think anybody at that point, except for Janice and me, and Rick and A.J., would have just called it at that point. It's like, "Okay, we tried." Um, we did everything we could and here we are. We know that it rates high enough to be a Superfund site. We know that it's migrating in at least four areas into the river. We have data. We were right, but now nothing's gonna get done, and nothing did for- for five years. The only progress they made, I showed you the spreadsheet, the only progress they made in five years was to dig five soil samples in the wrong location. Danielle DeVasto: And at this point, did they know that there was PFAS involved, or were they just looking for like the chromium and the mercury? Lynn Macintosh: Well, that's what's really interesting. I'm glad you asked the question because in 2010, at the very beginning of 2011, Janice had connected with Bob Delaney, up at Portsmouth, who broke the whole PFAS story and had, was writing a paper about its dangers. And he had been writing his paper about what he foresaw as a catastrophe, really. A looming catastrophe, um, from 2010 to 2012. The same time we were watchdogging this demolition, he was up there writing a white paper. And almost to the month when the, when the EPA handed this back over to the DEQ, our DEQ took his white paper and shelved it. But he had asked Janice one day, "Janice, do you, do you know if they use Scotchgard in the tannery?" So she calls me up, and she says, "Lynn, do you know if they use Scotchgard at the tannery?" My very first interview in July of 2010, was Ralph Gould, whose nickname was Sydney because I gave them all code names to protect them, and in that very first interview within the first 10 minutes he was telling me all about Scotchgard. And I have that interview. I'm not going to get up and go, get it for you, [LAUGHTER] but it's scrawled about the Scotchgard. And I said, oh my gosh, they used it everywhere on everything. Tons of it. So, interestingly enough in 2012, partway through the EP's- EPA's investigation, we followed up our big petition with a second one, uh, Summary of Concerns Part Two, Connecting the Dots. And in that we updated our chemical list concern, and we included PFAS. So, they ought to have seen it, the EPA and the DEQ, it was, it was made known to them, and by 2011, I knew about it and I was concerned about it by that time. But they didn't test for it. This was a really odd thing. This was right- right before Flint, too, and the same director who shelved this report was the same director, Dan Lyon, who was also there during the Flint crisis. Uh, I don't know all the reasons why it got shelved, but if you ever talked to Bob Delaney, he was not to bring it up. He was, you know, hi- his job was on the line. They did Page 7 �not want this. So, he came forward and 2017, after this all blew up over here, and he finally came out and told about that paper. And then after this big explosion with Wolverine, and there was site after site after site after site, there were more sites than I even knew of. We knew of some of them, but there were others we hadn't known about. We knew about House Street. I had been there and walked around its perimeter a number of times, and I'd gotten all my facts that I needed to know about it to make me really concerned. But, um, but I'm glad you asked that because if you go back to 2012, here's Bob, all his work seems for naught, here were are, all our work seems for naught, so- so anybody after spending that amount of time and energy and putting, and getting so much grief without getting into all the grief that I had and all the intimidation that I experienced, and I did have some, a couple things that were, um, quite alarming happen, that would've been the time to thrown in the towel. Except that the tannery site and the interviews had led us to House Street and areas of outside __________ 00:05:08. All those interviews told about dumping, and we started to get more and more information about where specifically. And I kept meeting people and getting more clues. And Janice and I, and Rick, and A.J., because they don't give up, they just wanted to wait it out and keep meeting 'cause the last thing you do is stop meeting because that's Wolverine and everybody's thinking that you are gonna do, so you just keep meeting and hope. You don't know. So, we kept meeting every six months, and for Janice and I it was this burden, this heaviness inside that there could be people who live near these dumpsites, because she worked for the DEQ she understood groundwater contamination, that it could be affecting people's drinking water. So, like, I- I showed, I've showed this picture before. These are some of the children who live out on House Street and Chandler. They're- they're older now. This was in 2018. The best way I can describe it, it was like deep down somewhere you knew that there were people in trouble. It was like voices in a mine shaft. It's like so faint, but you still think you hear something. And it was like it was fate. Didn't have proof. Anything. But it was palpable. That this- this could be a very real danger to people, and we couldn't give up because I was a mother, you know. I'd- I'd raised two children, and that mother bear [LAUGHTER] clicked in, would not let me give up. Um, I just couldn't. It's like nothing told me to stop. Everything told me to keep going. I wished it hadn't some days. I wished that voice would go away some days, but I couldn't. I even would go, uh, one day after I, um, had interviewed Earl, the truck driver, who gave me the most important interview of all, someone who had actually driven stuff there to the House Street dumpsite, and after all these years, and hearing about people who gotten sick in that area, sought me out because I had talked to his son. And he sought me out because he wanted to tell me what he did. He wanted this to be known, and ultimately was wilLynng to have it notarized, and signed and sealed to stand up in court, which it did. And after realizing that what, hearing from his own lips what he did, how it was disposed of, in deep unLynned trenches, raw sludge just hauled out day after day, and poured in and left, he told me about two other locations as well. I'm like, oh my gosh, it's and nobody's listening. Now, I went to House Street one day, and I knocked on the door of five homes, including Sandy Wynn-Stelt's. I looked at there where the dump was, and I saw those five homes, and I thought I don't have a shred of evidence, I have an interview, I have what the tannery worker said, I'm not allowed on that property, I can't test that, but, if Page 8 �there were five homes I'd be concerned about, it would be these five right here. South of it, top grading of it, and just as one citizen to another, I'm gonna at least let them know that I know that this site was highly contaminated, and they took sludge from this site and dumped it there. I knew that. I didn't have any test results. But that if I lived there, I- I would be concerned about having my groundwater tested for safety. And so I did. I systematically knocked on all five doors. But what are you gonna do when someone knocks on your door. Right? I still felt I needed to do it, and what was really hard for me, Dani, was that when I went to Sandy's house, her husband answered the door, and then he died in 2016. So, when this all came out in 2017, then I had learned about that he, that he had died. And I remember meeting this one father with two young kids, and he listened. He was, but I couldn't offer any- any, uh, any proof. So, what we did is we decided, Janice and I decided to get the river tested using a program for Michigan, a Surface Water Monitoring Request, that any river that's not been checked in five years you can request that it gets tested. And, uh, some fisherman had already requested that the river be tested af- down in Plainwell 'cause they heard about the demolition. And the same guy at the DEQ who just took none of this seriously just wrote back and said, "Oh, it's all been tested by," you know, da-da-da-da-da, "no- no need to do this." [LAUGHTER] And then we found out that he had said that, and I'm like, are you kidding, they didn't test any of the river during that time, and you're the project manager. So, then we waited another year, and then we put together our own request, and they accepted it. And, Bob Delaney knew Janice, and Janice had found documents in Grand Rapids that proved that they used Scotchgard, showed where they stored it. Documents that the EPA had requested, and were too burdensome and cumbersome for the company to produce. She went through and found them all, and sent them to Chris Bush at the DHHS. And she worked with Bob, she looked 'em over and she said, "Bob, why don't you work, I- I think that we should bring Joe Bohr in, he works with fisheries there, I mean fish- fish toxicologist, and, uh, when you do the surface water monitoring request include testing for PFAS." So, we waited two years. It's normally a year process, but we waited two years, and in 2015, there was a, uh, fish advisory for PFAS in the fish in the river, and that's what we needed. So we had that, we had Janice's records of Scotchgard, and we had the interviews, and, uh, Rick, doc- Dr. Rediske, Rick Rediske [LAUGHTER] met with Rose & Westra, Mark Westra and Mike Robinson, from the environmental attorney at WMEAC, in an office and they told him that, "Well, no, we- we didn't use PFAS." They- they, like, eh, I have the copy of his memo. They feigned ignorance, and then I think reali-, they think realized they weren't going to be able to get very far with that, but that was their immediate response that we didn't use it. And by then Garret Ellison had started reporting on Wurtsmith, and he had proved his worth as a req-, as a res-, in- in terms of research, and credibility, and in-depth reporting, and I was reading his articles. I heard there was PFAS in Plainfield Township's water and they couldn't figure out where it was coming from, and I was the one based on my interviews, called 'em up and said, I think I know where, and I said, and I gave them documents that the DEQ had in their office there showing that there had been dumping at this Boulder Creek Golf Course, and over here, and, you know, this is the tannery, and __________ 00:14:13. So, in 2017 we took every, we had indisputable proof of their use of it, of their dumping of it, of that people lived in wells around these Page 9 �places, and that Plainfield Township talked about it in their own parks and recreation plan as a former dumpsite for- for the Wolverine Boot Company, or whatever, and that yes, chemicals used at tanneries are known to be hazardous, but as yet there have been no reported problems. Yeah. And then we found out that in 1966, that Plainfield Township had decided to not let Wolverine dump there anymore because everyone was complaining about the smell, and stench, and fires, and everything, and, uh, Wolverine sued Plainfield Township for not letting them dump there. And so the township settled under the condition that, and it's all in that timeline I showed you, they settled with Wolverine and allowed them to use the dumpsite as long as they didn't contaminate the water supply. They contaminated 25 square miles. There are 25 square miles contaminated __________ 00:15:33, and they contaminated the lakes nearby and streams. The plume, um, goes off in, like, the rays of a, like a daisy, like a flower, and the puddles are actually the rays. The- the flowers are the center part of the daisy. But, the- the plume goes this way, this way, this way, this way. It's just, there couldn't have been a worse place to have dumped it, and they dumped it deeply and in great quantity there, and in another place on Logan Street that I didn't know about. So, so we kept going because we kept getting clues, and 'cause we were concerned about the groundwater, about people drinking contaminated groundwater. I- I- I, that's what I'm concerned with. I mean, if the tannery got cleaned up, I knew it needed to be cleaned up, but it was outside here now 'cause we were on city water. And we had just contacted Garret, I did on July 19, 2017, when I realized that the DEQ was sitting on all the information we gave them, just biding their time, and playing around with sampling. Um, the geologist, I don't know if I have it over here, I think I probably do but if I don't I'm not gonna worry about it. [LAUGHTER] I use binders, lots of them. It- it kept me fit, in shape. [LAUGHTER] But there is a, yeah, there's an e-mail that Garret found. Somewhere in my vast array of- of, uh, 3-ring binders there's one that Garret found where the geologist Mark Bohr, the day after- the day after we talked to him in Ja-, uh, on January 24, 2017, the day after he was already concerned and mapping out plumes, and was already concerned about if there was a plume where it might go, and when he realized that they were just playin' around in April, after they finally did some testing to the east, not south which is where all indications were to go south, he wrote an e-mail to his, um, to David Donald and said, "I have a list of 150 addresses here and all my calculations say the plume is gonna go south, and it could go as far as Chandler Street. We need to get testing south of the site." And this was ignored. It was ignored. So, what happened was I finally July is my feisty month of the year [LAUGHTER] when I realized after we were trying to get updates about what the DEQ was doing, and they were just still playing games, this one person in particular, [LAUGHTER] I finally, was upstairs, it was a hot day, humidhumidity, and I said, that's it, that's it, I'm gonna call up that- that MLive reporter, that Garret Ellison. I still have that in my journal entry. It's like ENOUGH, and it's all in caps. It's like it's Garret or no one. [LAUGHTER] That's what I wrote and I called him up, and he first did the fish story, and he was all set to print that when everything came out about House Street. Now, here's something that's really interesting. We found out about House Street getting bottled water through a back door, so to speak. Happenstance, you might call it. I'll- I'll call it Providence because that was hush-hush. They weren't even telLynng the Page 10 �people on House Street that it was Wolverine. They were just calling it a potential responsible party, a PRP. Well, there's a PRP, and then we'll- we'll try to figure this out, you know, where it's coming from. You know, meanwhile, we said, "Wolverine dumped here," [LAUGHTER] you know, and they're, and they're not even telling them where it came from or why. And because I spoke up all these years, a colleague of my husband's, the colleague's wife had a cousin who lived on House Street, and my, andand the colleague's wife was an attorney. And the cousin called her cousin, who was an attorney who would, got up and read all about PFAS, and was so upset and realized how serious it was. And then did the whole Google thing, you know, and then found this and that, and was reminded that, from the Rockford Squire, that we'd been involved. So she calls me one Saturday morning in August and wants to talk to me about bottled water that's being delivered and do I know anything about it. I'm like, what? Where? "Well, I can't really tell you the location, but it's, you know." And so through her, and she was pretty clever, too, she would go and meet with her cousin, and when they were going around, they had this like in-house map that showed the houses with high readings, and this and that, and, uh, she got a couple of phone shots of this map, and got a lot of the back- back story about what was happening and why. And she shared it with me, and she finally told me where it was. And I called up Garret asking him, well, what do you think we should do about this? I just found out they're delivering bottled water on House Street. This is one of the sites that we had been so concerned about. It's bad enough that they're, you know, not taking any chances, you know. [LAUGHTER] And Garret was like, "What do we do about it?" He said, "This is a public health crisis. We report on it and, like, what do you have?" And so I sent him that little map. And it was fascinating because, and I'm gonna use the name David O'Donnell, because this is the person who he interacted with and this is the person who delayed our efforts from 2011 all the way till then, um. When Garret was doing the fish story and was trying to get documents and FOIA them, David O'Donnell, as a courtesy, took Garret's FOIA and first gave it to Wolverine. And Garret found out about it, and Garret was really mad about it. And David O'Donnell knew that. So, Garret goes down I'd love it if he would tell this part, I wasn't there but he goes down to the DEQ, walks into David O'Donnell's office, and says, "So, David, I hear there's a- there's a map for people out on House Street. People are getting water delivered to their homes. Do you have anything you can tell me about that?" And that's how it got out. It wasn't supposed to get out. The right information got to the right person at the right time. I always teased Garret, it was like this baton pass. Like CCRR, our core group, it's like we're running a relay, and you're like doing this third lap that goes forever, [LAUGHTER] five years we're running this third lap, and then there's Garret, who we identify who we need, and like we're exhausted, and we like give him all this information, and he knew exactly what to do and how to do it. And he ran that fourth lap, and then he just kept going, started his own investigation. But he got the story out, and everybody was taken by surprise. That is why it was so effective because they thought we'd gone away. They thought we were just little play things, and just pat us, hush puppies all will be well, right. Just pat us on the head. Well, you know, it didn't work. They tried to get the EPA out, you know. We won, the war's over, and no one is gonna make us do anything. [LAUGHTER] And then they got completely caught off guard, and so did the Page 11 �DEQ, and so did the city, and so did Plainfield. Everybody was completely caught off guard, and it was one wave of news after another. It was House Street, it was this, it was this, and it was such a big, like, almost like a tidal wave effect or a tsunami effect. I don't know the best way, I still struggle for words for that. But it- it couldn't be put back in. That's the thing. For all these years, the city and the company had been trying to keep it all in and covered. And going back to my image of the mine shaft, you know, it's like we had finally reached the people. That's what it was like in 2017. Yes, there were real people, and oh my gosh, I'm so glad we found them. Oh my gosh, what could we do to help? Like, when people were pulled up from a mineshaft, you know, they need triage, they need care. It's like it's still not a pretty picture at all, but at least we reached them before too much more time went by. And that's what's interesting about the outcome is that it was so quiet. We were so quiet all those years. And then just there's this huge knockout punch. They didn't have time to plan for it. Danielle DeVasto: Garret knew just what to do. Lynn Macintosh: I still- I still just shake my head thinking about it. I and I, none of us expected it to be that big. And now it's statewide, nationwide, worldwide. I told, I told Garret I think the story is Wurtsmith, Wolverine Worldwide. And that's how MPART got formed, because good, this is right on the heels of Flint. I asked myself, would Flint, would this have happened without Flint? I'm not sure it would have. I think Flint showed that you can't necessarily trust the people that you think ought to be looking out for you. So that, unfortunately, is a sad way to prepare the soils for the fact that, yeah, and this does happen, you know. Danielle DeVasto: Um, so what concerns do you have about PFAS contamination moving forward at this point? Lynn Macintosh: Oh, it's so hard for me. I- I have a hard time even riding my bike on the trail because I see it, and I know how long it's gonna take for things to get done, you know. And I've seen how litigation works and how that takes so long. And they've been talking about putting in some kind of pump-and-treat system over here. It's four years now. And whenever we have these rain events, I don't know why I do it, but I have video after video where I go down to the river, and I stand there, and I take photos and video. And I do it on days when the foam level is low, and I do it on days when the foam level is high. And I always say, look at this, 365 days a year, 24/7, these foamy trails of water, these paths, them form like little paths so it's like these stripes 'cause they stick to each other, these striped paths flow down the river, into the- the Grand River, and they do leave a trail. And it's still not being treated, and the company's still playing games about it. Just do the work. Just do the work. Get it done. Pump and treat here, pump and treat where it's entering the river. Just do it. Do it now. You're gonna have to do it eventually. Why- why cause that much more harm? Stop paying so much to your lawyers. Just get the work done. What would it be like to actually be the company that did the right thing? That owned up to it? That exceeded our expectations? Imagine what that would be like. You could be that company. No one's stopping you. All that grief, and I see it. I see it in creeks, I see itm and I report it, and now the DEQ doesn't have time to follow-up on these foam reports. But I still track it. I'm still trying to find some sources in Cannon Page 12 �Township, 'cause I- I- I do, I track the creeks, I track it to the ponds, I track it to vacant land, and I research the history of the land. I've learned pretty much what to look for, what- what signals, I can judge vegetation Danielle DeVasto Tid: 579-2 Lynn Macintosh: I- I can judge vegetation that's distressed. I use my nose, and my eyes to judge, um, and I have to figure out which ones to report, which is what they have to do. Which are the worst? But there's 5000 of these chemicals, and we're still, we're still letting them be manufactured. It's actually, it's that there's an- an- an inanity to it and an insanity to it, both. Why are we doing this? Because it doesn't go away. I remember, um, Dani, I would be swimming in Lake Michigan a few years ago, and I was thinking, oh my gosh, I'm thinking about this too much. Like I'm imagining, like, these PFAS bubbles are following me because I'm swimming and I'm seeing this trail of bubbles. I'm like those are just air bubbles. No, they don't seem to be just air bubbles. Oh, you're just thinking about it too much. Well, each year there's more of 'em. Well, yeah, now I get it. It's confirmed. There's PFAS in Lake Michigan. People from Grand Rapids are taking their water from Lake Michigan. Okay. Also, __________ 00:01:29 may need to filter their water like __________ 00:01:35 Township's doing. I don't know. Kids on the beaches are- are near foam. They take foam, they pick it up, they put it on their faces. This is dangerous stuff. And I see it, and I see it, and I've always seen it before everybody else. And in these weird times where I thought I'm just imagining it, like, oh come one, you're just seeing it everywhere because you're thinking about it. Clearly no. It's there. I know it's there. I know what it is now. I just like, in my, I didn't get this out for you today, but in my bottom drawer there,may- maybe I will because I wasn't planning amongst all this other stuff that I have here, um, which is a narrow pass, [SIGH] I keep finding things, and in here I have my journals from seventh grade. And I- I go back and I look at these and I see myself sort of as like a young sapling. And I go back and I'm reading some of these entries, and I start, I- I write about pollution in here, and how upset I am about it. Pollution. "The USA has many problems right now, but I feel pollution should be our largest concern. [LAUGHTER] Fighting wars and sending men to the moon is what is on everyone's mind. But, if you don't start realizing how pollution is affecting your lives, we will all be in danger." And I, and I go on about it. I'm talking about DDT, and- and the birds. Like it must have been shortly after Rachel Carson had come out, and- and how troubled I was. And then I'm, like, hear myself at the end as a seventh grader, "Now I feel I want to help stop pollution for we were given this world, so why should we wipe it out? [LAUGHTER] With further study of pollution, I will even understand it more, and I might be able to think up a way to help stop it." Danielle DeVasto: Wow, wow. Lynn Macintosh: Isn't that something? Danielle DeVasto: Yeah. Page 13 �Lynn Macintosh: And I just came upon this 'cause I'm going through things now, and I thought, oh my gosh, I've cared about, I've cared about contaminated air, or smokestacks and air, and water, since I was in elementary school. I did. I- I- I noticed it then, and I- I couldn't understand why we would let, we would put all this- this stuff up into the air. I think, well, it was before the Clean Water Act and the Clean Air Act. So, I grew up before that. And I would, as a kid, I would just shake my head. And I remember one time I took, um, white water canoeing lessons in the Schuylkill River in, near, outside Pennsylvania, and the river was warm, and I could, it, I mean just being in that river, too, I could tell it wasn't clean, and I didn't like being in. But the thing that hit me was that it was warm. Why is this river warm? It's pretty, so I and I moved out here, ba-, we came back here. One of the reasons we came back here, Dani, from the East Coast was because of Lake Michigan. And I love swimming in that lake. I love it. And I can't swim south of Muskegon anymore. I can't swim especially south of where the Grand River goes in because the water's different from 40 years ago. I've seen it. I've seen the water quality diminish, and it's- it's disheartening to think that this big, beautiful lake, I feel like after I swimming, I need this shower afterwards right about, right afterwards. So, I really, I- I want to do what I can to protect people's drinking water, but I- I want to continue to do things to help shake people awake a little bit. And I think that might come more through the arts and writing, and these stories like this getting out. I- I don't know how. I don't know how, but sometimes you wish you didn't know all that you did. Danielle DeVasto: Yeah. Before we wrap up, is there anything else that you'd like to either go back to or emphasize? Any last points that you wanna make? Lynn Macintosh: Yes, I do, and there are two things, that- that happen quite a bit. Um, a story like this has a lot of dark underbellies, and there's a lot of things I found out about people and about organizations I wish I didn't know. And there was one point where I- I really felt like giving up. I was so tired and I had a friend tell me, to say to me, "Well, you know, you love to tell stories." 'Cause I do, I'm Irish. [LAUGHTER] Comes with the territory and the curly hair. She said, "You should write about some of this place." And I says, I don't even, I don't want to write about it. I said, I'm just so sick of it. It's just, it's just, it's awful. I was really worn down by it. And she said to me, "Well, you don't even have to, like, you don't even have to even write it in a book. You could just record yourself while you're doing things. Kinda have fun with it, and pretend you're this person or, you know, as you're doing it." So. I thought about it and I bought myself a little handheld recorder, I have one in the other room. But, [LAUGHTER] I-I invented a character based on Lake Wobegon, Garrison Keillor. He had Guy Noir who, late at night on the 10th floor of the ACME building, was finding the answers to life's perplexing problems. [LAUGHTER] And I thought, I'll be Gal Noir, and my Gmail was already 003, I don't know why. Lmarie003, and I was just like, Gal Noir, eco spy, sleuth for truth [LAUGHTER], and I started writing about all of it in the third person. And, uh, th- this is my first journal, you know, and I- I would decorate each one. The secret life of Gal Noir 003 eco spy . [LAUGHTER] And I started writing and filLynng these journals. And here's a picture of me on my friend's roof. This is not a good picture, but it happens to be in my journal. Um, but I might try to retell my story through this character or parts of it. But I- I took it to heart and I have recordings. I have recordings from Page 14 �2011 on tapes, and I have journals that span every year, you know, and here's 2013. This is, uh, part two. This is part five the storyteller is born. Um, this is another part here. Every journal is different, you know. It was, interesting to me at the time. This was a sketch book. So I thought I was really funny on this one. I took and I added a lie. Sketchy, you know. [LAUGHTER] And my poem here, Gal Noir, Part Three, The Story Continues. [LAUGHTER] And this was my little quote that I- I had to find some humor, and it was very difficult speaking to my city council when they, you know, they sit there, you know, if they're awake, [LAUGHTER] and, um, they're- they don't like you to go on and on and on either, so I- I said Gal Noir has her own poetry, Gal Noir, la poetess, you know, like I collected all the poems she wrote. Um, [CLEARS THROAT], "Upon addressing one's city council, ration passion, keep it brief, spare yourself and others grief." [LAUGHTER] I learned that the hard way. But when I put it in those that little format, you know, it's like, okay, I get it now. [LAUGHTER] I've gotta ration some of that passion. You know, I can't, I can't, uh, be spoutin' it all the time. Sometimes I felt like when I was going into the city council meetings, like I was like getting off, like I was actually riding a real horse, like getting off my high horse and walking into the city council. The doors were like saloon doors, you know what I mean, and I would walk in and everybody would look, "Oh no, it's Lynn Macintosh." [LAUGHTER] Danielle DeVasto: Sounds like your imagination was Lynn Macintosh: It was. Danielle DeVasto: a useful tool for you. Lynn Macintosh: It was very helpful. Yeah, I- I- I pretend, I- I told people it felt like I wore the scarlet A for activism. I'm like other, but no, I- I befriended my imagination, and I had fun bringing certain people into it. Some people can't go there with you. But like another friend, Gail Mancewicz, who I hope you talk to, she was so upset that I had a, this little code 003. [LAUGHTER] And she says, "Well, who am I gonna be?" And I said, well, you could be 004. She goes, "Well, why 004?" I said, because then together we're 007. [LAUGHTER] You know? So, it was fun to carry certain people into that with you. Other people couldn't really be interested, and that's fine, too. It's who I am. The other thing I wanted to say was I was myself. I used what I was comfortable with. I used my simple cell phone. I used my bicycle. I used the real phone. I talked to people face-to-face. And I don- not, I do not think I ever would have gotten to the bottom of it if I had relied on Google and e-mail. I had to bump into the information. I had to bump into real people because then that connects you and people start to trust you and share and then they bring other people to you. That was absolutely, there- there's nothing, that's one reason I didn't want to do a Zoom call. Face-to-face, real life is so important. Conversation. And then lastly, from 2017 to 2018, for almost an entire year, I couldn't talk about the story with anybody because I was grieving that my worst fears were true that had been harmed. And I didn't want to bother the people on House Street. I didn't want my name to be out there because they were, they were deaLynng with this tragedy. And I kept a lot of it inside, and I was burdened by it. And I was out there on the front porch talking to Garrett and I was feeLynng very heavy-hearted, and he said to me, "You know, you should call up, you should call up Jen Carney." And I said, well- well why is that? He said, "Well, she said she'd like to talk to you sometime. She's really proud Page 15 �for what you've done. 'Cause I didn't want to be looking for that. And I said, "Really?" He said, yeah, yeah, no, I, she's, you know, they And he said, "Listen, I'll give you her number. Call her if you want." So, I called her, and it was lovely because her name is Jennifer Lynn, my first daughter is Jennifer Lynn. She has a lovely personality. We enjoyed talking. And then she told me, what she said made all the difference to me. She told me how sick she was. She told me how she thought she was going to have to get into a wheelchair. That family was gonna have to move in. No one could figure out what was going on. She was that sick. It was a total mystery. And it was that bad. And then I asked her, so how is it now? And she said, "I've gotten better every single day since I stopped drinking that water." She says, "I'm not having these symptoms anymore. I'm not having these symptoms anymore." She says, "Every day for a year, it's not been all at once." But she says, "But I've gotten better." And I just, I was on the other end of the phone Lynne and I just started crying. To hear that from her own heart and from her own mouth, that all this work, because it was a lot of work, it was really hard work. I look back, I- I say, who was it that did all this? That was me? You know, 'cause in the middle of it you don't think that. But seeing, like, a real or talking to a real person that you just have a sense that there's something wrong and actually hearing and hearing that they're getting better, that- that broke a log jam for me, but I couldn't talk about it much till then. And I'll never forget that day. In fact I probably could've started with that story because, yes, your imagination helps you, yes, working with other people help you. All these things, but it's like the fire trucks finally showed up. We've been talking about it for all this time. No one believes you and they tell you, "No, it's not fire," or "No, that's not smoke, that's mist." "Oh, no, it's where you're standing," and just, "It's a mirage." And finally, the fire trucks showed up in 2017, and things are changed and will continue to change, and, um, that makes all the difference. That's really what it's been about. And that's what it was about for me, and for- for AJ, and for Rick, and for Gail, and Janice. There wa- there was nothing that we wanted for ourselves. We just had a burden that we carried together. So, yeah, I think that's probably a good place to leave it. Danielle DeVasto: Yeah. Lynn Macintosh: Because we need to care for each other. We do. We- we can't just like it someone else's problem, right? So, anyway, and I'm so glad I've gotten to know some of those people out there. I've gotten to know Tobin and Sandy and Jen some, so yeah, completing that. Danielle DeVasto: Thank you, Lynn Lynn Macintosh: Yeah. Danielle DeVasto: for having the time to tell your story today, or at least Lynn Macintosh: Yeah. Danielle DeVasto: part of it. [LAUGHTER] Lynn Macintosh: Part of it. Danielle DeVasto: Yeah. Lynn Macintosh: Yeah. Danielle DeVasto: Okay, thank you. Page 16 � Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Living with PFAS Interviews Creator An entity primarily responsible for making the resource Devasto, Danielle Description An account of the resource Beginning in 2021, the Living with PFAS interviews were recorded to gather the personal stories of individuals impacted by PFAS contamination. PFAS, or per- and polyflourinated substances, are a large group of human-made chemicals used widely since the 1940s to make coatings and products resistant to heat, oil, stains, grease, and water. They can be found in countless household items, including food packaging, non-stick cookware, stain-resistant furniture, and water-resistant clothing. These chemicals are often called “forever chemicals” because they do not break down easily, can move through soils and contaminate drinking water sources, and build up in animals, plants, and people. PFAS have been linked to increased incidences of various cancers, increased cholesterol, decreased fertility, birth defects, kidney and liver disease, and immune system suppression, and thyroid dysfunction. It is estimated that PFAS are in the drinking water of more than 200 million Americans (Andrews & Naidenko, 2020). In Michigan alone, over 280 sites have PFAS contamination exceeding maximum contamination levels for groundwater (MPART, 2024). Date A point or period of time associated with an event in the lifecycle of the resource 2021 Source A related resource from which the described resource is derived Living with PFAS (project) Rights Information about rights held in and over the resource In copyright Subject The topic of the resource Oral history Personal narrative PFAs (Perfluorinated chemicals) Groundwater--Pollution Publisher An entity responsible for making the resource available Grand Valley State University. University Libraries. Special Collections & University Archives Identifier An unambiguous reference to the resource within a given context DC-11 Format The file format, physical medium, or dimensions of the resource video/mp4 application/pdf audio/mp3 Type The nature or genre of the resource Motion Picture Text Sound Language A language of the resource eng Oral History A resource containing historical information obtained in interviews with persons having firsthand knowledge. Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Identifier An unambiguous reference to the resource within a given context PFAS0024 Creator An entity primarily responsible for making the resource McIntosh, Lynn Date A point or period of time associated with an event in the lifecycle of the resource 2021-07-29 Title A name given to the resource Lynn McIntosh, 2021 (Interview video and transcript) Description An account of the resource Lynn McIntosh grew up on the east coast but has lived in Rockford, Michigan for about 30 years. Lynn noticed foam and filmy substance in the river in about 2010, and began taking photos of the contamination. In this interview, McIntosh discusses her work to bring public awarenss to PFAS contamination. Contributor An entity responsible for making contributions to the resource DeVasto, Danielle (interviewer) Subject The topic of the resource Oral history Personal narrative PFAs (Perfluorinated chemicals) Groundwater--Pollution Source A related resource from which the described resource is derived Living with PFAS (project) Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/page/InC/1.0/?language=en">In copyright</a> Type The nature or genre of the resource Moving Image Text Format The file format, physical medium, or dimensions of the resource video/mp4 application/pdf Language A language of the resource eng Publisher An entity responsible for making the resource available Grand Valley State University. University Libraries. Lemmen Library and Archives https://digitalcollections.library.gvsu.edu/files/original/aa16a57eb8efea7f583d57abeb49ca37.mp4 0f72e96739c0330afe6a1ba3319891ad https://digitalcollections.library.gvsu.edu/files/original/c79b4775892d02dce324eeb2993c0b18.pdf e8ee4bf598dd122eb31dd3927c54ba5b PDF Text Text Grand Valley State University Veterans History Project Interview Name of War: Other veterans & civilians Name of Interviewee: Ron Lyon Length of interview (01:02:26) (0:00:10) Background Born in Flint, MI on November 14, 1941, three weeks before Pearl Harbor. (0:00:26) Grew up about 20 miles northeast of Flint. (0:05:07) Father served in the Philippines in the infantry during World War II. Was colorblind and therefore able to see through camouflage. (0:01:00) Father worked as the head of the catalogue department for Buick. (0:06:27) Was the oldest child. Had one sister and a brother. (0:07:07) Suffered from hay fever, asthma, and several allergies throughout grade school. Despite this, he played sports until 10th grade, but had to quit when his symptoms inhibited his breathing. (0:02:56) Attended Lakeville High School. Describes the consolidated school system. (0:07:35) When his health kept him out of sports, he dedicated his time elsewhere. He played first chair trumpet in the band, participated in all high school plays, was the head of the Drama Club, and participated in Debate Club. (0:08:53) Attended community college for a few years studying pre-med. Wasn’t getting much out of it and decided to join the service to learn discipline. (0:09:51) Looking back, wishes that he had gone on to become a veterinarian. (0:11:15) Joined the service in September, 1962. (0:02:49) (0:11:52) Service in New York City Signed up for a missile defense site for New York City. Compared to his small town, New York City fascinated him. (0:11:52) Asked him to go into the army as an officer, but he declined. (0:12:55) FBI had to perform a background check on him before giving him top secret clearance. (0:20:52) Had a top secret clearance and therefore took care of all nuclear warheads and tools for his company. (0:13:39) Training for this included special advanced classes. (0:13:55) Was at the base during the Cuban Blockade. (0:14:05) Was the only one on base with top secret clearance on base during the John F. Kennedy assassination because the base was undergoing maintenance and everyone else had gone to New York City for the weekend. (0:14:21) Describes being instructed by a general from the SAC Air Command to arm all missiles with nuclear warheads and put up as many as possible, to put the guard dogs patrolling the perimeter on attack mode, and to shoot anyone at the gate that he didn’t recognize. (0:15:51) Didn’t know what was going on until the news of the assassination came on the radio later. (0:19:07) Recalls that the experience was very scary because he was a [Spec-4] at the time and had �never dealt with an emergency without supervision. (0:20:06) Explains the constant fear during the Cold War. (0:21:40) After the missiles were armed, helped manage and fire the missiles (0:22:58) Says that if he had been ordered to fire a missile or shoot someone if it were absolutely necessary, he wouldn’t have hesitated whatsoever. (0:23:20) The first sargeant and the lieutenant and had returned by the time that Kennedy was taken to the hospital and pronounced dead. Was relieved once the higher officers had returned. (0:25:03) Was stationed at this base for 14 months. (0:25:49) Was able to see several Broadway shows because he was stationed in New York City on the weekends. Received the tickets for free from the USO. (0:25:58) Recalls that being in New York City was an adventure. (0:29:49) The base closed down and was turned over to the National Guard. (0:30:38) Describes the switch from small nuclear warheads to high TNT missiles before he left. (0:30:50) Worked with the state police and was in charge of the Nuclear Biological Chemical Warfare team. (0:31:46) (0:32:15) Service in Germany Worked in the 9th Chemical Company outside of [Mannheim], Germany, which suppored all of the 7th Army. Provided gas masks, flame throwers, and decontamination trucks. (0:32:15) Represented his base as the Chemical Corps during the [War Games with other countries] because he was the only one with top secret clearance. Was the lowest ranking person in attendance. (0:32:57) Was in Germany for 14 months. (0:36:05) Was surprised that he was sent there because he hadn’t had 18 months of experience, which was the requirement. Was thankful because he was able to see various parts of Germany, Switzerland, France, northern Italy. (0:36:30) Was frequently left in charge while his first sergeant was out trying to sell things that were new to biological and chemical warfare to the countries of NATO. Every time he was left in charge, his first sergeant would award him three or four days of vacation. (0:37:36) Attended a 30 day program at the NCO Academy which included map reading, instructional training, and leadership. Only had about two hours of sleep every night while there. Describes his daily routine. (0:39:39) The top four received a promotion, but was 5th in his class. (0:41:52) Describes skiing in the Alps. Had broken his ankle 6 weeks before while playing in a basketball tournament on post. (0:47:35) (0:51:13) Life after Service Arrived in New Jersey at an Air Force base near Fort Dix and was discharged. (0:51:42) Returned to the Flint area and worked as a salesman for 7 or 8 months. (0:51:18) Was married three times after the war. (0:52:19) Applied for Skilled Trades at the Chevrolet Metal Factory and worked there for 36 years. (0:52:37) �Returned to college at the University of Michigan in Flint while working and got a degree in Urban Studies. (0:55:07) Has had several strokes and the cognitive portion of his brain does not deal well with stress. (0:57:42) Says that the service gave him a lot of discipline and gave him a deep understanding of army regulations. (1:00:07) Received several Solder of the Quarter and Soldier of the Month awards. (1:01:23) � Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Veterans History Project Creator An entity primarily responsible for making the resource Grand Valley State University. History Department Description An account of the resource The Library of Congress established the Veterans History Project in 2001 to collect memories, accounts, and documents of U.S. war veterans from World War II and the Korean War, Vietnam War, and conflicts in the Middle East and elsewhere, and to preserve these stories for future generations. The GVSU History Department interviews are part of this work-in-progress, and may contain videos and audio recordings, transcripts and interview outlines, and related documents and photographs. Coverage The spatial or temporal topic of the resource, the spatial applicability of the resource, or the jurisdiction under which the resource is relevant 1914- Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/page/InC/1.0/?language=en">In Copyright</a> Subject The topic of the resource Afghan War, 2001--Personal narratives, American Iran Hostage Crisis, 1979-1981--Personal narratives, American Korean War, 1950-1953--Personal narratives, American Michigan--History, Military Oral history Persian Gulf War, 1991--Personal narratives, American United States--History, Military United States. Air Force United States. Army United States. Navy Veterans Video recordings Vietnam War, 1961-1975--Personal narratives, American World War, 1939-1945--Personal narratives, American Publisher An entity responsible for making the resource available Grand Valley State University. University Libraries. Special Collections & University Archives Contributor An entity responsible for making contributions to the resource Smither, James Boring, Frank Relation A related resource Veterans History Project (U.S.) Identifier An unambiguous reference to the resource within a given context RHC-27 Language A language of the resource eng Source A related resource from which the described resource is derived <a href="https://gvsu.lyrasistechnology.org/repositories/2/resources/455">Veterans History Project interviews (RHC-27)</a> Oral History A resource containing historical information obtained in interviews with persons having firsthand knowledge. Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Identifier An unambiguous reference to the resource within a given context LyonR Title A name given to the resource Lyon, Ron (Interview outline and video), 2008 Creator An entity primarily responsible for making the resource Lyon, Ron Description An account of the resource Ron Lyon was born in Flint, MI on November 14, 1941. After a few years at community college, he realized that he wasn't getting anything out of college and decided to join the service. In September of 1962, he signed up for a missile defense site for New York City. After being investigated by the FBI and taking several advanced classes, Ron received top secret clearance and took care of all nuclear warheads and tools for his company. He served for 14 months in New York City and 18 months in Germany. Contributor An entity responsible for making contributions to the resource Collins Sr., Charles E. (Interviewer) Collins, Carol (Interviewer) Subject The topic of the resource Oral history Veterans History Project (U.S.) United States--History, Military Michigan--History, Military Veterans Video recordings Other veterans & civilians--Personal narratives, American United States. Army Language A language of the resource eng Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/page/InC/1.0/?language=en">In Copyright</a> Type The nature or genre of the resource Moving Image Text Relation A related resource Veterans History Project (U.S.) Date A point or period of time associated with an event in the lifecycle of the resource 2008-08-11 Source A related resource from which the described resource is derived <a href="https://gvsu.lyrasistechnology.org/repositories/2/resources/455">Veterans History Project Collection, (RHC-27)</a> Format The file format, physical medium, or dimensions of the resource application/pdf video/mp4 Publisher An entity responsible for making the resource available Grand Valley State University. University Libraries. Lemmen Library and Archives https://digitalcollections.library.gvsu.edu/files/original/b72738f3e68ff70985d6f7d2b22ab908.mp4 122b81de54276dc260dcce5ff9ef817b https://digitalcollections.library.gvsu.edu/files/original/503b12b874d2dba9f89036ad147c53d2.pdf cd548a290aba682d9051f931de6d2710 PDF Text Text Grand Valley State University Veterans History Project Glenn Lyons (2:15:27) Background Information (1:55)                            His grand parents immigrated to the U.S. and lived in South Dakota, Illinois, and then Michigan. (2:48) His grandparents worked as farmers in the early 1900s late 1800s. (3:32) His father was the oldest of 4 children. (2 boys and 2 girls) (4:00) His father worked in a furniture factory in Grand Rapids, Michigan. (5:11) Glenn was born April 4th 1920 in Grand Rapids, Michigan. (5:28) He is the 2nd youngest of 6 children. (3 girls and 3 boys) (5:45) At the age of 2, his family moved out to Silver Lake, Michigan, in 1922. (6:57) After several years in Silver Lake the family moved once more to Cannonsburg, Michigan in 1925. This is where Glenn began school. (8:16) The school was a 1 room school house with 2 stories. 7th grade and up was upstairs, downstairs were all the other grades. (8:34) After several years in Cannonsburg he moved south of Rockford, Michigan. (8:58) He then moved once more in Rockford and attended White Swan public school. (9:58) As a child he enjoyed ice fishing. (10:30) When going to school he had to carry his lunch to school every day. He recalls being intimidated by the older kids in his class who were older. (12:30) A pot belly stove was used to heat the school. (14:00) At age 15 he worked for 20 dollars a month in 1935. He was hired to milk cows by hand and assists in a saw mill. (14:27) He graduated elementary school in after 8th grade (approx. 1935) (17:44) He graduated from Pratt Lake one room school house. (18:05) He started high school at Pratt Lake in 1937. He wanted to play football but could not due to his chores at home. (18:50) After walking to school all first semester he purchased a 1928 Model A Ford for 50 dollars total. (20:00) His father then got a job at a canning factory. To get there, he used Glenn’s car. (20:27) He recalls the seizing of other countries by Germany during the late 1930s and early 1940s. (21:56) While in the 10th grade (approx. 1938/1939) he was kicked out of his home because his father couldn’t afford to have him live there. He applied for jobs in factories but he was not hired due to him being too close to the draft age. (23:03) He did find a job as a farm hand. (24:10) He met his wife originally in his one room school house. In 1938 he re-met her. (24:40) He was drafted into the U.S. Army on November 24th 1941.(26:40) After he was drafted he tried to enlist in the Navy but they would not take him due to his mother's tuberculosis. (27:02) He was drafted in the 2nd wave of draftees from Grand Rapids, Michigan. (27:40) �Basic training (27:44)                           He was then sent to Fort Custer in Battle Creek, Michigan. (27:49) The first thing they had him do once he arrived was peeling potatoes at 4:00 in the morning. (28:00) He was then sent to Fort Knox, Kentucky. This was the furthest he has ever been from home at the time. (28:50) He was in Fort Knox, Kentucky for basic training. Basic training lasted approx. 9 weeks. (29:19) Basic consisted of a lot of marching and learning of military discipline. (29:30) When finished with basic, he was going to be chosen to stay at Fort Knox and be a corporal and assist in training, but he was replaced and then sent to Fort Benning, Georgia. (30:00) He recalls that while in Kentucky during the winter of 1942 it rained often. (30:30) When he arrived at Fort Benning, Georgia he had not had any furloughs. He was given a 10 day leave in April of 1942. During his leave he traveled by train Back to Michigan. (31:48) He had to take a train to Atlanta then to Chicago then to Grand Rapids, Michigan. (32:10) While on his furlough he married his wife. They were planning on getting married in August but instead got married to his wife Florence on April 10th 1942. (34:48) He returned back to Fort Benning and became a supply truck driver. (36:05) The men were given the opportunity to drive the tank. The tanks the men used were shift tanks, with airplane engines in their back end. (36:59) He was then sent to Fort Bragg, North Carolina. (approx. June of 1942) (38:25) His truck was so heavy with all the men’s supplies when driving to Fort Bragg that he fell behind other men who traveled by truck. (38:50) He was instructed on the drive to Fort Bragg to stay over on the right side of the road. The ground was soft due to rain. As a result the truck flipped and a man in the back of his truck had his ear cut off. (39:30) A wrecker from the division was sued to tip the truck back over. (40:15) At Fort Bragg the tanks learned maneuvers. The men were given new tanks [M-5 Stuarts] with Cadillac engines in them (41:13) The cannon on the tank was small at 37 mm. (41:58) The company was then told they would be shipped to Africa. (42:30) The men were given landing practice with the tanks while stationed in Virginia. (43:14) While in Virginia he was given a 10 day furlough. (45:20) He was then sent to New Jersey where he would assist in the training of men for tank landings. At this time he was a corporal. (46:06) Before being shipped out he drove a supply truck to New York to ship over to Africa. (48:33) He shipped out on a flat-bottomed ship formerly used to ship railroad cars. (49:57) While being sent over to Africa, men had particular jobs aboard the ship such as a guard and lookout. (50:37) 2 days before arriving in Casablanca in Africa he spotted a torpedo and warned of its approach. The ship successfully evaded it. (50:50) Arrival in Casablanca (52:00) �     He arrived in Casablanca on December 24th, 1942. His job once the ship landed was to unload supplies. On Christmas he ate with the Navy. It was the only Christmas while in the service where he didn’t have some sort of assignment. (52:42) There were some French in Casablanca at the time when he arrived. (53:53) From Casablanca he was supposed to be moved with his company to Sicily Italy to aid in the invasion of Sicily. However he fell ill and was hospitalized for 5 days, missing the invasion. (55:11) After his hospitalization he was sent to Oran in Western North Africa and shipped out by boat to Wales. England. (57:00) Arrival in England (57:00)      He was then sent by train from Wales to Oxford, England In December of 1943, where he stayed in a Barracks. (57:35) When being sent from Oran to Wales, the men were given ice cream by the Red Cross. (58:39) The trek in the Atlantic was choppy and many of the men got sick. (59:30) There were so many troops on the ship he sailed on to Wales that some men were assigned to sleep nights and the others assigned to sleep days due to lack of beds. (1:01:05) While in England, they did go in to London on one occasion and see sights and visit pubs. (1:04:43) Invasion of Normandy (1:05:00)        His company went into Normandy on June 16th 1944 (10 days after the invasion on June 6th.) (1:06:20) At this time he was still a Liaison Corporal (a Jeep driver.) (1:06:35) While landing on the beach, a ship next to him was hit by a mine and the ship was destroyed. (1:07:00) He unloaded on a shallow part of the beach. When he drove the jeep into the water it was shallow enough that his feet didn’t get wet. (1:07:50) The beach was covered with destroyed equipment and the terrain looked to have been worn horribly. (1:09:00) At the time of his arrival, only 10 square miles had been secured by Allied forces [actually more than that, even at Omaha, but the beachhead was still much smaller than planned]. (1:09:50) His captain than instructed that he wanted to go to the front, so Glenn took him in his jeep. He recalls while he was driving this there were times he was told to drive fast and not slow down due to the spotting of snipers who fired upon the jeep. (1:10:03) Service in Northern Europe (1:11:00)   After arriving, his company was supposed to invade a town. The day before the company next to him was hit by a German bomb. (1:11:56) The men took the town with some combat and moved on. Shortly after he was given a leave of absence and moved on to Paris. (1:13:23) �          His company moved through the intersection of Belgium, France and Germany. (1:14:58) He and his commander had coffee at a Frenchman’s house. Shortly after leaving the house was struck with an explosive round. (1:15:45) While moving across the European countryside, the company went under fire by another American company on their right who mistook them for the enemy. (1:18:00) He served in B Company, 1st Battalion, 7th Armored Regiment, 2nd Armored Division (all light tanks) (1:18:50) When the military began a spearhead maneuver his company was on the outside of the spear head providing cover. (1:20:09) Shortly after the men moved back and took a house to make into the head quarters in December of 1944. (1:20:40) The men had Christmas dinner on December 31st 1944.(1:22:48) Air support was sometimes given. The men would have assistance form P38s and P47s. the P38s often were subjected to friendly fire. (1:28:58) The men would often start being shelled by artillery without warning as they advanced. He was nearly struck by a shell but never was seriously injured. (1:23:40) Some men became shell shocked as a result of this fire. (1:24:41) The surrender of the 41st infantry (1:25:40)   The [someone from the] 41st Infantry [German infantry division] called his division and said that they knew of the Allied approach and were going to surrender. (1:25:50) The Germans came in a covered truck. When the curtain was lifted the germens opened machine gun fire on the American company. Latter, Glenn’s company arrived and one surviving American from the massacre told of what happened. (1:26:05) Service in Northern Europe (cont.) (1:26:15)       The cold weather led to many problems with engines including difficulty starting or tanks trucks and jeeps. (1:26:38) When entering the boarder of Germany many German forces had retreated. The advanced was more of a cleanup rather than invasion. (1:29:34) Near the end of the war Glenn had the job of taking men who had enough points for leave to locations where they could get picked up. After words, it was up to him and his radioman to reconnect with the company. (1:29:20) While in no-man’s-land with several other officers, he was passed a bottle of alcohol that the other officers were drinking. However because he was caught with the bottle, his stripes were cut off and he was bumped from a corporal to a private. Now he operated the radio and the former radio operator was the driver. (1:30:00) He was later told that because the officer who bumped him down didn’t know who he was to just sew his strips back on. Several days later he was a corporal once more. (1:31:15) He crossed the Rhine River, however was unable to see it due to “asphalt Blindness.” This refers to the impaired vision men had when following a tank on asphalt and having the tank rip up the ground and throw it in the air. (1:31:31)] �        He had to visit the medic to have his eyes washed out. (1:32:40) He became the assistant driver of a staff tank due to his inability to see. His vision later returned at 4AM the next day. (1:33:20) He got pneumonia and stayed in the hospital for a few weeks. When he was relived he caught a supply truck back to his unit. (1:34:18) When he rejoined his unit, the commander of a tank got sent home after getting enough points. She he was then made a tank commander. (1:35:00) At this time his company was in German heading to Berlin. When they arrived there the Russians turned them away. (1:35:42) It took 3 attempts to enter the city before the Russians allowed Americans access. (1:35:18) The company seized a large building for the men to stay in. while exploring the basement of that building they found that it was full of dead bodies. (1:36:38) He was then given a 3 days leave of absence in the U.S. But after turning in their tanks at the France German Border in August of 1945, he heard that Japan had surrendered. (1:38:02) Post surrender service (1:38:50)          He then took a train from Germany through France. (1:38:50) He was told that his company was to replace the occupation forces on the French Riviera. (1:40:21) He got on a ship headed to Boston. He gambled to pass tome o the ship. (1:42:00) While crossing the Atlantic they hit a Hurricane near the Canary Islands. (approx. September 1945). (1:40:30) The top deck of the ship had women on it but he and the other male soldiers were not allowed to visit it. (1:43:00) He landed in Boston in October of 1945 and was sent to Camp Grant, Illinois. (1:43:15) He was discharged at Camp Grant, Illinois and then was sent by train to Chicago. (1:44:14) The train tickets and taxis between two different train stations were paid for by the military. (1:44:38) He took a train back to Grand Rapids, Michigan. (1:45:10) Life after Service (1:46:17)         His wife stayed with her mother on Ramsdale Avenue in Grand Rapids Michigan.(1:46:20) His first job was painting a house for pay. (1:47:10) He then was hired on a dock. While there he saved the foreman after having a heart attack. (1:47:49) In April of 1946 he bought a 120 acre farm. (1:48:55) On January 3rd of 1950 he had his first daughter. (1:49:26) In 1952 he sold his 120 acre farm. (1:49:48) He then went to live with his wife’s sister and brother-in-law where he worked the farm for a short time before going to live with his brother. (1:50:00) He then bought a house on 6 Mile Road with some farm land. (1:50:35) �              He then received a job in the yard in a plaster mine in Grandville, Michigan. (1:51:20) He then received a job as an electrician for the Grandville mine. (1:52:70) He worked her for 2 years and never received one raise. (1:53:19) He was then made the high loader on the dock. (1:54:09) He had one child in 1952 and another in 1956. (1:54:19) He worked in a factory making stoves and then later refrigerators. (1:55:00) During the summer, the factory laid men off to go work on the farm. During this time he received a job for a farm hand. (1:58:05) He then started work for Pioneer Construction Company. (2:00:05) Soon after being employed at Pioneer construction he was made a truck driver. (2:03:56) He retired in April of 1984 after working at 2 construction companies. (2:06:04) He built his house in 1954. (2:08:15) On April 7th 1985 he had a heart attack. (2:08:44) He recovered from his heart attack by walking frequently. (2:09:48) He has been married to his wife for 64 years. (2:12:18) Final thoughts on service (2:13:00)   He doesn’t think he would have enlisted if he wasn’t drafted. But he thinks the experience was rewarding and he was thankful he wasn’t hurt. (2:13:19) He belongs to the VFW and the American Legion. He served as a chaplain for one of these organizations. (2:14:30) � Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Veterans History Project Creator An entity primarily responsible for making the resource Grand Valley State University. History Department Description An account of the resource The Library of Congress established the Veterans History Project in 2001 to collect memories, accounts, and documents of U.S. war veterans from World War II and the Korean War, Vietnam War, and conflicts in the Middle East and elsewhere, and to preserve these stories for future generations. The GVSU History Department interviews are part of this work-in-progress, and may contain videos and audio recordings, transcripts and interview outlines, and related documents and photographs. Coverage The spatial or temporal topic of the resource, the spatial applicability of the resource, or the jurisdiction under which the resource is relevant 1914- Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/page/InC/1.0/?language=en">In Copyright</a> Subject The topic of the resource Afghan War, 2001--Personal narratives, American Iran Hostage Crisis, 1979-1981--Personal narratives, American Korean War, 1950-1953--Personal narratives, American Michigan--History, Military Oral history Persian Gulf War, 1991--Personal narratives, American United States--History, Military United States. Air Force United States. Army United States. Navy Veterans Video recordings Vietnam War, 1961-1975--Personal narratives, American World War, 1939-1945--Personal narratives, American Publisher An entity responsible for making the resource available Grand Valley State University. University Libraries. Special Collections & University Archives Contributor An entity responsible for making contributions to the resource Smither, James Boring, Frank Relation A related resource Veterans History Project (U.S.) Identifier An unambiguous reference to the resource within a given context RHC-27 Language A language of the resource eng Source A related resource from which the described resource is derived <a href="https://gvsu.lyrasistechnology.org/repositories/2/resources/455">Veterans History Project interviews (RHC-27)</a> Oral History A resource containing historical information obtained in interviews with persons having firsthand knowledge. Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Identifier An unambiguous reference to the resource within a given context LyonsG1311V Title A name given to the resource Lyons, Glenn (Interview outline and video), 2005 Creator An entity primarily responsible for making the resource Lyons, Glenn Description An account of the resource Glenn Lyons was born April 4th 1920 in Grand Rapids, Michigan, and drafted into the Army in November, 1941. After a year of training, he was shipped to North Africa, with the 2nd Armored Division. He spent most of his military service as a jeep driver in a light tank company in that unit. He missed the invasion of Sicily due to illness, but was with his unit from Normandy until the end of the war. Contributor An entity responsible for making contributions to the resource Blough, Ivan (Interviewer), Blough, Nick (Interviewer) Subject The topic of the resource Oral history Veterans History Project (U.S.) United States--History, Military Michigan--History, Military Veterans Video recordings World War, 1939-1945--Personal narratives, American United States. Army Language A language of the resource eng Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/page/InC/1.0/?language=en">In Copyright</a> Type The nature or genre of the resource Moving Image Text Relation A related resource Veterans History Project (U.S.) Date A point or period of time associated with an event in the lifecycle of the resource 2005-12-15 Source A related resource from which the described resource is derived <a href="https://gvsu.lyrasistechnology.org/repositories/2/resources/455">Veterans History Project Collection, (RHC-27)</a> Format The file format, physical medium, or dimensions of the resource application/pdf video/mp4 Publisher An entity responsible for making the resource available Grand Valley State University. University Libraries. Lemmen Library and Archives https://digitalcollections.library.gvsu.edu/files/original/7de259065388008bc16d0bd0820fde58.mp4 227b5084a32d6e5dbb50011cb18292d1 https://digitalcollections.library.gvsu.edu/files/original/e25b125e3cf10f3a0ef6da76ce89a983.pdf 267259e861e7c6e512169b5e63a589a2 PDF Text Text Grand Valley State University Veterans History Project Interview Name of War: World War II Interviewee’s Name: Jerry Lyons Length of interview (0:45:04) (00:26) Background  Born December 20, 1922 (00:33)  Served in the 32nd division, 107th Medical Battalion, Company D during World War II (00:37)  Left service as a T-4 (01:00)  Served in Australia, New Guinea, and the Philippine Islands (01:19)  Was living in Grand Rapids, MI when drafted (01:25) (01:52) Training  Departed for Fort Custer in January, 1943. Remembers that it was very cold. (01:57)  Sent to Camp Wood, Texas. Trip took about three days. (02:26)  Boot camp mostly included marching in various conditions. Describes training with tank destroyers. (3:22)  Was transferred to a different camp after about four months. (05:27)  Traveled to New York City by train, saw the Statue of Liberty. Told that they were going to the South Pacific (06:15) (06:44) Arrival and Training in South Pacific  Traveled by convoy down the East Coast, through the Panama Canal, and then to Brisbane, Australia (06:44)  Jerry traveled on the U.S.S. Uruguay, which was a South American luxury liner at one time that was refitted for the troops. Trip took about a month. (07:32)  His ship nearly hit a liberty ship that had a broken rudder (08:11)  Had gun practice while on board (09:00)  Dropped anchor off the island of Bora Bora. Describes his experience swimming and their interactions with the natives. (09:26)  Describes arrival in Australia. (11:50)  Marched to Camp Asbury, about 30 miles out of Brisbane, joined 32nd division. (13:17)  Describes the friendships he acquired and the occasional trips into Brisbane. (14:07)  Describes training in Newcastle. (16:48)  Traveled to Hollandia, New Guinea, and then left for Leyte, Philippines on D+4 (17:14) (18:30) Service in South Pacific  Describes first experience fighting (18:30)  Describes experience driving the ambulance on Luzon, Philippines (19:48)  Sniper had hit their ambulance during an attack on their camp. Bullet hit about two �inches from where his head had been. (21:10)  Describes some close calls while traveling through mountains. Taken to hospital once he had been hit in the shoulder. Returned to the unit afterwards and received Purple Heart. (21:47)  Describes how the ambulance he worked in dealt with certain weather and terrain conditions. (23:56)  Received Bronze Medal for the retrieval of a wounded person. Also received Good Conduct Medal (25:06)  Kept in touch with family through letters. Family made a record in which they all sang and sent it to him. Listened to it often. (26:15)  Proposed to his wife while in the service because he didn’t want to lose her. Married her when he returned to the United States in February (27:50)  Describes recreational activities he enjoyed while in the Philippines. (30:00)  Describes rescuing a wounded man with three other men while under fire from a sniper. (31:37)  Briefly describes military circumcision. (35:13)  Recalls that some men were slightly unscrupulous, but most were honest and dependable. (35:50) (37:00) Post-Service  Returned to California by boat and then returned home in February 1946. (37:14)  Worked as a truck driver in the early 1950s. Worked for Frieden Calculators and later did sheet metal and furnace work. (38:57)  Military experience taught him that it is necessary to have an army to protect our country. Was glad that he could serve his country, but decided not to continue serving because he cared about his family. (39:46)  Thinks that the military discipline and getting away from home was good for him. (40:40)  Would hate to see family members go into the service, but emphasizes the power or prayer. (41:04)  In spite of all of the negative aspects of the United States, thinks that we live in the best country. Thinks that those who have served their country should be proud. (42:35)  Recalls attending a veterans’ parade and realizing that everyone was there to thank them. Realized that even though he might not have contributed much, as a group the military accomplished great things. (42:58) � Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Veterans History Project Creator An entity primarily responsible for making the resource Grand Valley State University. History Department Description An account of the resource The Library of Congress established the Veterans History Project in 2001 to collect memories, accounts, and documents of U.S. war veterans from World War II and the Korean War, Vietnam War, and conflicts in the Middle East and elsewhere, and to preserve these stories for future generations. The GVSU History Department interviews are part of this work-in-progress, and may contain videos and audio recordings, transcripts and interview outlines, and related documents and photographs. Coverage The spatial or temporal topic of the resource, the spatial applicability of the resource, or the jurisdiction under which the resource is relevant 1914- Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/page/InC/1.0/?language=en">In Copyright</a> Subject The topic of the resource Afghan War, 2001--Personal narratives, American Iran Hostage Crisis, 1979-1981--Personal narratives, American Korean War, 1950-1953--Personal narratives, American Michigan--History, Military Oral history Persian Gulf War, 1991--Personal narratives, American United States--History, Military United States. Air Force United States. Army United States. Navy Veterans Video recordings Vietnam War, 1961-1975--Personal narratives, American World War, 1939-1945--Personal narratives, American Publisher An entity responsible for making the resource available Grand Valley State University. University Libraries. Special Collections & University Archives Contributor An entity responsible for making contributions to the resource Smither, James Boring, Frank Relation A related resource Veterans History Project (U.S.) Identifier An unambiguous reference to the resource within a given context RHC-27 Language A language of the resource eng Source A related resource from which the described resource is derived <a href="https://gvsu.lyrasistechnology.org/repositories/2/resources/455">Veterans History Project interviews (RHC-27)</a> Oral History A resource containing historical information obtained in interviews with persons having firsthand knowledge. Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Identifier An unambiguous reference to the resource within a given context LyonsJ Title A name given to the resource Lyons, Jerry R. (Interview outline and video), 2005 Creator An entity primarily responsible for making the resource Lyons, Jerry R. Description An account of the resource Jerry Lyons, born December 20, 1922, was drafted while living in Grand Rapids, Michigan in 1943. He served during World War II as a part of the 32nd Division, 107th Medical Battalion, Company D. His service took him across the South Pacific to Australia, New Guinea, and the Philippine Islands, where his unit supported the division in combat on Leyte and Luzon. Contributor An entity responsible for making contributions to the resource Lyons, Jacob (Interviewer) Caledonia High School (Caledonia, Mich.) Subject The topic of the resource Oral history Veterans History Project (U.S.) United States--History, Military Michigan--History, Military Veterans Video recordings World War, 1939-1945--Personal narratives, American United States. Army Language A language of the resource eng Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/page/InC/1.0/?language=en">In Copyright</a> Type The nature or genre of the resource Moving Image Text Relation A related resource Veterans History Project (U.S.) Date A point or period of time associated with an event in the lifecycle of the resource 2005-05-12 Source A related resource from which the described resource is derived <a href="https://gvsu.lyrasistechnology.org/repositories/2/resources/455">Veterans History Project Collection, (RHC-27)</a> Format The file format, physical medium, or dimensions of the resource application/pdf video/mp4 Publisher An entity responsible for making the resource available Grand Valley State University. University Libraries. Lemmen Library and Archives https://digitalcollections.library.gvsu.edu/files/original/f84e87ee880429bddf59ccef6cde90ef.jpg 3f9be57884e2ae726aa5c058a7cace1a 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 Decorated Publishers' Bindings Subject The topic of the resource Book covers Covers (Illustration) Graphic arts Publishers and publishing Pictorial bindings Description An account of the resource From the early 1870s to roughly 1930, many publishers issued their commercial book covers with a remarkable variety of graphic designs and illustrations. This sixty-year period saw many artists and designers contributing to this art form. While some can be identified from their style or initials, others remain unknown. Source A related resource from which the described resource is derived Seidman Rare Books Collection Michigan Novels Collection Regional Historical Collection Lincoln and the Civil War Collection 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 2017-08-30 Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/page/InC/1.0/?language=en">In Copyright</a>, <a href="http://rightsstatements.org/page/NoC-US/1.0/?language=en">No Copyright - United States</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 DC-01 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. Source Seidman Rare Books. PS1556 .L58 1913 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 DC-01_Bindings0139 Title A name given to the resource Lyrics of Love and Laughter Creator An entity primarily responsible for making the resource Morse, Alice Cordelia (Designer) Description An account of the resource Binding of Lyrics of Love and Laughter, by Paul Laurence Dunbar, published by Dodd, Mead & Company, 1913. Subject The topic of the resource Book covers Covers (Illustration) Graphic arts Publishers and publishing Pictorial bindings Language A language of the resource eng Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/page/NoC-US/1.0/?language=en">No Copyright - United States</a> Type The nature or genre of the resource Image Format The file format, physical medium, or dimensions of the resource image/jpeg Date A point or period of time associated with an event in the lifecycle of the resource 1913 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/f6b3cabbbd2d046b69940bdaa3541870.jpg b0a9f44825cb15767e9756dded5977d1 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 Decorated Publishers' Bindings Subject The topic of the resource Book covers Covers (Illustration) Graphic arts Publishers and publishing Pictorial bindings Description An account of the resource From the early 1870s to roughly 1930, many publishers issued their commercial book covers with a remarkable variety of graphic designs and illustrations. This sixty-year period saw many artists and designers contributing to this art form. While some can be identified from their style or initials, others remain unknown. Source A related resource from which the described resource is derived Seidman Rare Books Collection Michigan Novels Collection Regional Historical Collection Lincoln and the Civil War Collection 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 2017-08-30 Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/page/InC/1.0/?language=en">In Copyright</a>, <a href="http://rightsstatements.org/page/NoC-US/1.0/?language=en">No Copyright - United States</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 DC-01 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. Source Lincoln and the Civil War. PS1556 .L6 1908 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 DC-01_Bindings0217 Title A name given to the resource Lyrics of Lowly Life Creator An entity primarily responsible for making the resource Morse, Alice C. (Designer) Description An account of the resource Binding of Lyrics of Lowly Life, by Paul Laurence Dunbar, published by Dodd, Mead and Company, 1908. Subject The topic of the resource Book covers Covers (Illustration) Graphic arts Publishers and publishing Pictorial bindings Language A language of the resource eng Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/page/NoC-US/1.0/?language=en">No Copyright - United States</a> Type The nature or genre of the resource Image Format The file format, physical medium, or dimensions of the resource image/jpeg Date A point or period of time associated with an event in the lifecycle of the resource 1908 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/5081d6984d81426095217ec4f924392d.jpg bdb0e07db69a87334a8d38a15117d518 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 Decorated Publishers' Bindings Subject The topic of the resource Book covers Covers (Illustration) Graphic arts Publishers and publishing Pictorial bindings Description An account of the resource From the early 1870s to roughly 1930, many publishers issued their commercial book covers with a remarkable variety of graphic designs and illustrations. This sixty-year period saw many artists and designers contributing to this art form. While some can be identified from their style or initials, others remain unknown. Source A related resource from which the described resource is derived Seidman Rare Books Collection Michigan Novels Collection Regional Historical Collection Lincoln and the Civil War Collection 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 2017-08-30 Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/page/InC/1.0/?language=en">In Copyright</a>, <a href="http://rightsstatements.org/page/NoC-US/1.0/?language=en">No Copyright - United States</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 DC-01 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. Source Lincoln and the Civil War. PS1556 .L7 1899 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 DC-01_Bindings0218 Title A name given to the resource Lyrics of the Hearthside Creator An entity primarily responsible for making the resource Morse, Alice C. (Designer) Description An account of the resource Binding of Lyrics of the Hearthside, by Paul Laurence Dunbar, published by Dodd, Mead and Company, 1899. Subject The topic of the resource Book covers Covers (Illustration) Graphic arts Publishers and publishing Pictorial bindings Language A language of the resource eng Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/page/NoC-US/1.0/?language=en">No Copyright - United States</a> Type The nature or genre of the resource Image Format The file format, physical medium, or dimensions of the resource image/jpeg Date A point or period of time associated with an event in the lifecycle of the resource 1899 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/fa42a7f6d514d7553f4626098a0e95ad.mp4 9337b675c91321fe05f9bc3a51530a7f https://digitalcollections.library.gvsu.edu/files/original/5445c10dd4be8ae91ffeadc9a222bc11.pdf a9af2daf04a17e22e516e50faa4fecae PDF Text Text Grand Valley State University Veterans History Project Interview Name of War: World War II Interviewee’s Name: William Lysdahl Length of Interview (00:26:44) Background: (0:00:14)  Served in the Navy  Enlisted because it was his duty  Was 17, his father signed for him, thought it was a good idea Enlistment: (0:01:34)  A lot of physical training, did not consider it really hard  Boat training at Great Lakes  Gunner training at base in Virginia  New Orleans, got their ship  Went to Boston, set sail from Boston to the Panama Canal, then to the Pacific, where he stayed for the rest of the war  Not many casualties in his unit  Most frightening encounter was a typhoon (0:03:30)  Made necklaces out of seashells for their girlfriends  Story about Patrol duty and a bombardment of a Japanese island (0:05:05)  Received medals for participating in war-zones  Wrote letters back home, that was the only way to keep in touch  Thought the food was good o Had steak o Was a lot better than ground soldiers’ rations o Had plenty of supplies  Sank 8 submarines without gun-battles (0:07:30)  Slept down below o Had to cover up mattress with a fire-proof cover o Eventually hung up a hammock because it smelled so bad  For entertainment they boxed or watched movies o Every 3rd day on an island, they’d go ashore and play ball or other sports  One of the officers almost got washed overboard when he lost his footing (0:10:08)  Liked all the soldiers he worked with o Did not share the same opinions as the officers  Did not keep a journal, and was glad of it, because he didn’t want to relive deaths and battles After the War: (0:11:50)  Never considered re-enlisting  Was in the Pacific when he was discharged. Stopped in Hawaii, then to Los Angeles �             Wanted a glass of cold milk most; all they had was powdered milk on the ship and it was too warm Went to work, and took a few night classes when he returned Made a lot of friends, but did not keep in touch o Had friends in Kentucky, the Dakotas Joined the American Legion Was a salesman after the war Does not regret joining the war o Does not agree with certain decisions, but does not regret his time American Legion o Gives out scholarships o Sends boys to different organizations o Work with the community, have fish-frys His service time does not affect his life Remembers he was in St. Louis seeing a movie when Pearl Harbor was attacked o Remembers wanting to fight, but was too young at 16 Remembers anchoring on an island, could see the bottom of the ocean (0:16:48) o Looked like an aquarium, could see all the fish o Skipped from island to island o Rescued pilots and crewmen from downed planes Served on the USS Spangler (0:19:08) o Did not have big enough guns to take on a cruiser Chose the Navy because he thought he’d have a chance to see more of the world o Saw as much as he wanted to Discharged on December 1st, 1945, at 20 years old � Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Veterans History Project Creator An entity primarily responsible for making the resource Grand Valley State University. History Department Description An account of the resource The Library of Congress established the Veterans History Project in 2001 to collect memories, accounts, and documents of U.S. war veterans from World War II and the Korean War, Vietnam War, and conflicts in the Middle East and elsewhere, and to preserve these stories for future generations. The GVSU History Department interviews are part of this work-in-progress, and may contain videos and audio recordings, transcripts and interview outlines, and related documents and photographs. Coverage The spatial or temporal topic of the resource, the spatial applicability of the resource, or the jurisdiction under which the resource is relevant 1914- Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/page/InC/1.0/?language=en">In Copyright</a> Subject The topic of the resource Afghan War, 2001--Personal narratives, American Iran Hostage Crisis, 1979-1981--Personal narratives, American Korean War, 1950-1953--Personal narratives, American Michigan--History, Military Oral history Persian Gulf War, 1991--Personal narratives, American United States--History, Military United States. Air Force United States. Army United States. Navy Veterans Video recordings Vietnam War, 1961-1975--Personal narratives, American World War, 1939-1945--Personal narratives, American Publisher An entity responsible for making the resource available Grand Valley State University. University Libraries. Special Collections & University Archives Contributor An entity responsible for making contributions to the resource Smither, James Boring, Frank Relation A related resource Veterans History Project (U.S.) Identifier An unambiguous reference to the resource within a given context RHC-27 Language A language of the resource eng Source A related resource from which the described resource is derived <a href="https://gvsu.lyrasistechnology.org/repositories/2/resources/455">Veterans History Project interviews (RHC-27)</a> Oral History A resource containing historical information obtained in interviews with persons having firsthand knowledge. Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Identifier An unambiguous reference to the resource within a given context LysdahlW Title A name given to the resource Lysdahl, William (Interview transcript and video), 2005 Creator An entity primarily responsible for making the resource Lysdahl, William Description An account of the resource William Lysdahl entered the Navy at age 17 during World War II. He served in the Pacific Ocean on ships conducting antisubmarine patrols. He was discharged on December 1st, 1945, at the end of the war. He was 20 years old. Contributor An entity responsible for making contributions to the resource Balczak, Melissa (Interviewer) Miller, Leigh (Interviewer) Subject The topic of the resource Oral history Veterans History Project (U.S.) United States--History, Military Michigan--History, Military Veterans Video recordings World War, 1939-1945--Personal narratives, American United States. Navy Language A language of the resource eng Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/page/InC/1.0/?language=en">In Copyright</a> Type The nature or genre of the resource Moving Image Text Relation A related resource Veterans History Project (U.S.) Date A point or period of time associated with an event in the lifecycle of the resource 2005-06-08 Source A related resource from which the described resource is derived <a href="https://gvsu.lyrasistechnology.org/repositories/2/resources/455">Veterans History Project Collection, (RHC-27)</a> Format The file format, physical medium, or dimensions of the resource application/pdf video/mp4 Publisher An entity responsible for making the resource available Grand Valley State University. University Libraries. Lemmen Library and Archives https://digitalcollections.library.gvsu.edu/files/original/cac4aef110206fe59c46d6dcb10c6ee3.mp4 68a1e8e1f95f4e892e6ef7d48e14cf4e https://digitalcollections.library.gvsu.edu/files/original/e081c8c3e4a46eec61fb585ca49717ad.pdf 4fb705ea42c1d95b77ed932c2dd0beb5 PDF Text Text Lyssy, Walter Grand Valley State University Veterans History Project Interview Name of War: Vietnam War Interviewee’s Name: Walter Lyssy Length of Interview: (1:44:06) Interviewed by: James Smither Transcribed by: Maluhia Buhlman Interviewer: “We’re talking today with Walter Lyssy of San Antonio, Texas and the interviewer is James Smither of the Grand Valley State University Veterans History Project. Okay start us off with some background on yourself and to begin with, where and when were you born?” I was born at home in McCook, Texas, a rather remote area. Interviewer: “What part of Texas is that in?” (00:25) Very southern Texas on the Mexican border near the Rio Grande Valley. Interviewer: “Okay, and did you grow up there or did you move around?” I grew up there and then after high school attended A&I University in Kingsville, Texas. Interviewer: “Okay, now when you were growing up what was your family doing for a living?” We were dryland farmers in the 50’s in Texas, which was the time of the drought. So it was pretty tough, we were very poor. Interviewer: “Alright, how were you able to afford to go to college?” �Lyssy, Walter Didn’t really– Couldn’t afford. I had enough money to pay my first semester’s tuition and live for a month or two. I tell everybody I’ve held every job in Kingsville, Texas. Interviewer: “How large was the school in those days?” About 4,000 students and they had ROTC and I joined ROTC and– But basically just had odd jobs running, filling stations and so forth and finally got me a good job at the Kingsville Naval Air Station driving fuel trucks and fueling jets at night. Had a 40 hour week job there and went to school full time. Interviewer: “So you didn’t do a lot of sleeping then.” My joke was I got off from midnight to eight o’clock, the next morning was free time you can do anything you want, like study or sleep. Interviewer: “Alright, now the ROTC program you were in was that an Army ROTC?” (1:58) Army ROTC and back then they were actually by branch and it was Signal Corps. Interviewer: “Okay, so what did the ROTC training actually consist of?” Well you had to take obviously military courses through four years, drill and ceremonies out in a parade field, see Sergeant Martin and clean your M1 rifle every week till he was satisfied, so you got really good at cleaning an M1, disassembling, assembling, and so forth and of course between your junior and senior year you go to a summer camp for six weeks for the intensive training and when you graduate you’re commissioned. Interviewer: “Alright, now was this a place that had a four year ROTC?” �Lyssy, Walter Yes, four years ROTC but it was small compared to like Texas A&M or someplace back then. I don’t remember precisely but on graduation night I think five of us were commissioned, very small. Interviewer: “Alright, and now did the military pay for any part of your education or was this just–” You got– At your junior and senior years I think we got $40 a month, paid for cleaning your uniform and haircuts so no they didn’t– It wasn’t for money. Interviewer: “Okay, now then how did you feel about the prospect of going in the Army, was that something you wanted to do?” Yes, it was a job back then things were tough. Interviewer: “Alright, so what year did you graduate from college then?” (3:42) 19– In May of ‘65 I graduated from Texas A&I. Interviewer: “Okay, interesting time to go into the Army at that point, how– Were you aware at all of what was happening in Vietnam with the Vietnamese?” Yes and back then people were in ROTC and they saw Vietnam coming and they figured out how to get out of ROTC and then the Army changed its policy and you had to sign up some paperwork that you were a private in the Army reserves and if you decided to, for some reason, just quit you end up being– Coming into the Army as private. So there was incentive but that didn’t affect me, I was hoping to get commissioned and go into the Army. Interviewer: “Okay, alright so now once you receive your commission, what do they do with you?” �Lyssy, Walter Well the first thing you do is go to officer’s basic training at Fort Gordon, Georgia and then you get your first assignment. My first assignment was Fort Knox, Kentucky and training center. Interviewer: “So then just to back up a little bit, what do they do in officer’s basic training?” Most of it is related to Signal Corps, the equipment and that sort of thing, plus you know the normal PT tests and training and so forth. By then you’re pretty well trained as far as drill and ceremonies and all that, that’s already done. Interviewer: “Okay and what kind of equipment was the Signal Corps using at that point?” Well actually the radios at that level were the PRC 25 which it had one vacuum tube in it which eats a lot of battery and that was changed to the PRC 77, or the transistors version, it did the same thing although you’ll talk to almost all of the Vietnam vets and they’ll all tell you about the AN PRC 25. (5:55) They were actually carrying a PRC 77, it looked exactly the same everybody thought it was a PRC 25, that’s what they called it. Interviewer: “Well they also talked about carrying around extra batteries, did the 77 still need those?” Oh yes and the batteries were big and heavy and were really an important thing to make sure that everybody had a fresh battery, but even before that when they were still PRC 25s they ate the batteries a lot faster because they had a vacuum tube which uses a lot more power so the Army changed that to a PRC 77. Interviewer: “Did you also do stuff, learn things that had to do with coding and anything like that, encryption?” �Lyssy, Walter Oh yes, yes and in my time the 2nd 506, which we’ll talk about, that was a big deal having a secure radio and codes. Interviewer: “Alright, so now you– And so how long was the training at Fort Gordon?” I don’t know, six or eight weeks. Interviewer: “Okay, so not a big thing then.” Yeah. Interviewer: “Okay, so then Fort Knox, Kentucky then is your next stop?” Yes. Interviewer: “Okay, what do you do there?” (6:55) It was– Fort Knox was a major training center back then for basic training, that sort of thing, but I was in what was called radio school or teaching radio operators, 0-5-B was the MOS, they became radio operators and many, many of them went to Vietnam. Looking back at it now I think it’s silly cause the majority of the time was teaching them international morse code and well if I had to do it all over again I would go back and take that training time and teach them how to be a company commander’s radio operator and do stuff like calling in airstrikes and– Cause that’s what the real job was almost none of them used international morse code and that was probably 2-300 hours of training. Interviewer: “So where would they use international morse code, that if you went to Europe or something for a big headquarters?” Basically most radio operators didn’t do it, now Special Forces did it a lot, and we’ll talk about that later, but most Army radio operators did not use international morse code but it was still in �Lyssy, Walter the training program and they had to pass 13 words a minute international morse code and it was taught to them in a very rudimentary way, was pure memorization, dit dah- A. Okay and then write dit dah- A, dit dah and then you had to write B dah dit dit dit. Interviewer: “Okay, now how long did you spend at Fort Knox doing that?” Two years. Interviewer: “Okay, and during that time I mean did you want to go to Vietnam or not go?” Oh I was fully expecting to go to Vietnam, my commitment was for two years I could’ve just left for Knox and I’d fulfilled my military obligation and I’d probably been put in the reserves and sent home. Interviewer: “Yeah, okay but you stayed in?” (9:00) But I stayed in. Interviewer: “Alright, why did you stay in?” I liked the Army and patriotic reasons and so forth and time to go do my thing. Interviewer: “Okay, so what thing did you go do next?” Well I got orders for Vietnam, except it didn’t say “Vietnam” it said “Thailand” I said “Where’s Thailand?” So the summer of ‘67 at the Travis Air Force Base and get on this contract airplane which is totally full of Air Force and there was I think four of us Army people on this airplane and we fly to Bangkok. Interviewer: “Okay, and what did they do with you once you get to Bangkok?” �Lyssy, Walter We got to the airport in Bangkok, everybody unloaded, all these little blue Air Force buses came and picked up all the Air Force guys, they left, we stood there looking at each other “Well what do we do?” So we finally figured it out. Interviewer: “Well did someone come for you or did you just stand around?” They told us to take a taxi and go to Chapya hotel in Bangkok which we did and that was a contract hotel for Army and we went in there and made contact and pretty soon started getting assignments. Interviewer: “Okay, and what did you get assigned to?” Well my initial assignment was to go to Korat 501st Field Depot, which is a large depot operations, logistics, bringing in supplies into Thailand and they found out that I had secret clearance, which was unusual back then. (10:52) So the depot petroleum officer and I had to get together and spend the first month writing a secret plan on how to distribute petroleum to the air bases in Thailand which is– Lots of air bases in Thailand, yes so we did that and when that was finished then I was sent to Sattahip, Thailand which is on the coast south of Bangkok, where the U.S was building a large port facility and all the supplies were coming into Sattahip. So I joined, from there I was– I’m still a 1st lieutenant and I joined a 596 quartermaster company petroleum depot. There were only two petroleum companies in the Army and that’s one of them and I was the signal platoon leader, company’s supposed to be spread out 200 miles of pipeline with teletype and all this sort of thing. Well we weren’t deployed like that at all, we were all in one spot, you really didn’t have a lot of signal to do so next thing I knew I was also the company motor officer running the motor pool, which is a big motor pool. Big 5,000 gallon petroleum tankers, deuce and a halves, rough terrain forklifts for moving large drums around, and just a lot of equipment. Interviewer: “Okay, was that all staying on the base or was that going back and forth along the pipelines?” �Lyssy, Walter Well when I first got there what the mission– Well our mission was to handle all petroleum products for Thailand but our real mission was bringing in JP-4 for the Air Force and they would come in in tankers and when they first got there you used submarine cables to attach to the tankers to pump the JP-4 off the tankers and into pipelines and Utapao air base and then just at Christmas time we got our petroleum pier built which is a new modern pier and port pipelines you can actually drive a jeep out on it and had the big anchor points for tankers to come in and get tied up and we’d pump off of that but this is– What’s interesting is that a lot of air power came out of Thailand for the Vietnam war. Places like Udorn, Subang, Takhli, Nakhon Phanom, Korat, and all these basically fighter bombers scattered out throughout Thailand and they burned a lot of fuel but in southern Thailand next to us, next to the port, was U-Tapao Air Base and UTapao had B-52s and KC-135 tankers, and these tankers would take off and be airborne and there was really basically no fuel at all these air bases in Thailand. They only had minimal amounts for testing engines and emergencies, so that F-105 took off out of Korat loaded with bombs and so forth, he took off and immediately went to the tanker which came out of U-Tapao, got a load of fuel, he went north, did his mission, came back, hit the tanker, got fuel and landed and the whole war went like that. (14:33) So we were pumping U-Tapao and we averaged 1.2 million gallons a day pumping JP-4 to U-Tapao that was our main mission and we– When we first got there– Eventually we had electric pumps and we had a very large tank farm, one tank it was 100,000 barrels, huge you know other tanks and we handled, you know other products too, gasoline and diesel and that sort of thing but it’s primarily JP-4 and ships would come in, we’d offload them, they’d take off go back to the Persian gulf and get that load of fuel, another ship would come in. They’d hold about ten million gallons each and that was a week’s supply and we’d pump that all to U-Tapao. So we just basically I had the signal platoon, the motor platoon, and then I became the company commander, totally out of my field but that’s what it is. Interviewer: “And were you still a 1st lieutenant at that point?” No, just got promoted to captain and became the company commander. �Lyssy, Walter Interviewer: “Very good, yeah now what’s daily life like out on– You’re on the big base right?” No. Interviewer: “Oh somewhere–” The Army had a small camp at that point called Camp Vayama, it basically didn’t even have a fence around it, water buffalos just wandered right through our area. Interviewer: “Okay so they build you a fort facility but not really a base.” Yeah, eventually there was a new Army post, Camp Samae San but at this point it hadn’t been built yet. So ours we just had wooden hooches, pull a rope it lifts up a piece of tin for your window but compared to Vietnam it was super good. We had showers, a little building called the officers club where you could eat, it was okay. Interviewer: “Do you employ local people to work for you?” (16:35) Yes, every hooch has a house girl that shined shoes and took your fatigues down to the river to beat them with rocks and cleaned them and brought them back and, so yeah it was– Life there was okay. Interviewer: “Okay, and did you have any security concerns?” Yes, particularly at the air base in fact there was, if you read back in history, they actually got onto U-Tapao and damaged some B-52s. Interviewer: “Okay, now were these Thai communists or were they Vietnamese infiltrators or do you not know?” �Lyssy, Walter I don’t know a lot about that. Interviewer: “Okay, but where you were there wasn’t any particular worry.” No, we were probably 30 minutes away at our Army camp, eventually the new camp was over closer to U-Tapao but our little camp was kind of remote and all by itself. Interviewer: “Alright, okay so how long did you spend there?” I stayed there about– I have to recall, eight or nine months and then I went to– Well what happened the Army petroleum officer out of the Pentagon came, some Air Force colonel, and he found out that he had a signal commanding one of his petroleum companies and he was very upset about that and so pretty soon there was another captain, took over and I went to Korat and worked in logistics and maintenance, finished my tour. Interviewer: “Okay, so when did that tour finish?” (18:16) In July of ‘68. Interviewer: “Okay, so you’d been in Thailand at the time of the Tet Offensive then?” Yes. Interviewer: “Alright, did that have any reverberations where you were?” Not really, no. Interviewer: “Okay, alright so July ‘68 now you go back to the states and you– Had you decided by this time to really make a career of the Army?” Yeah, I was pretty well staying in. �Lyssy, Walter Interviewer: “Okay, alright so what’s your next assignment now?” I got orders to go to Fort Bragg to the special warfare school which is the Special Forces school. Interviewer: “Okay, so did you take Special Forces training or were you gonna work at the school?” No, I was just assigned to go there and I got there and the next thing I know I’m in the Communications Committee of the Special Forces school, back then called Special Forces training group. We have Special Forces groups there’s 1st group, 2nd group, 5th group in Vietnam so forth, and then there’s a training group at Fort Bragg that teaches the officer training and the various skills in Special Forces, weapons, engineer, signal, operations, those sorts of things and we were doing the communications portion of that. Interviewer: “Alright, so what does that actually consist of?” (19:37) Soldier comes, there are exceptions to this but, basically a soldier comes in the Army goes to basic training, then he goes to Airborne school, and then he goes to Special Forces basic training and then after that then he goes to his MOS training, then he’d come to us now and he’s already been to Airborne school, he’s had some jumps already and then he becomes a Special Forces radio operator. Now he’s learning international morse code but he’s gonna use that cause when you go to a day camp in Vietnam you’re sitting there using international morse code and he’s– And so that was really important training for them there and an important thing is at the point I got there this was already going on but, you know how do you learn international morse code, the dits and the dahs and so forth. Well there was a fellow out in California, his name was Judson Cortish, he was not a communicator or anything else but he was– Had a PhD in how the brain works. So his way of explaining this is he says “You know if I said do you know music?” “No, I don’t even know how to read music.” “But if I played Happy Birthday on the piano and hit all these keys and so forth and made a mistake you would know it wouldn’t you?” I go “Yeah.” He says you listen to a song on the radio and you like the song by the second time without even �Lyssy, Walter thinking about it, you know the words, how’d that happen?” So he came up with this mnemonic method of teaching international morse code and you basically put on a headset and there’s a male voice talking to you and he says “Alone” and you write down A and he says “Brake cylinder” and you write down B, says “Daredevil” you write down D and what it is like the world “Alone” it’s a short syllable and a long syllable, dit dah. Then you hear “Brake cylinder” which is dah dit dit dit, but you don’t pay any attention to the color, you just listen, write them down, you know. Very few people in the world know this story by the way, okay so you listen to this male voice telling you this and you’re writing it down you have an attenuation knob and while he’s saying the words there’s a little bit of code synchronized with this and as you’re bringing the voice down you bring the code up. Okay and you get to a certain point and you start out at 13, 15 words a minute this is not boring I mean just– You’re writing and then you changed the male voice to the chipmunks, little chirpy voice [chipmunk noises] and the code is there and then pretty soon you bring the chipmunks down, you bring the code up and pretty soon the chipmunks go away and you’re copying code and I actually did this at lunch hours and I don’t know two, three weeks I learned code and you know most people struggle for many, many hours trying to learn this but it all ended up that he had his way of doing things and some Army people had their way of doing things and they were not the same so they told him to take his toys and go home and the world lost that. (23:10) So guess what? Now our teaching today’s back to the old way of doing things, yeah but it’s just an interesting story. We had one soldier, he was a prize soldier, he learned at 15 words a minute solid in 12 hours of training, now most people would take probably like 7,500 hours this guy just– It worked for him–Boom! He went through the tapes, learned it said “He’s ready.” 12 hours of training that guy he could code, very unusual but at the school not only do they come in, they learn the code and then they learn equipment basically they learn a lot of basic how to build antennas, how antennas work, which antenna to use because they’re going to be using an AN/GRC 109 radio transmitter and a receiver with a hand crank generator. There’s no microphone there, this is all to build an antenna and tap out your code. In the last– I got there with my boss the Colonel Johnson he had just finished commanding CCM in Vietnam which is back then very classified, putting the guys in North Vietnam and all the recon teams and so forth. So I get there and he’s there and he says “The last two weeks of the course is a field training exercise in the mountains of North Carolina called Windmill Falls, Pisgah National Forest and Colonel Johnson said “Why are we trucking these �Lyssy, Walter soldiers up there? These are Special Force soldiers, you go up there and establish your drop zone.” “Yes sir.” Sergeant [unintelligible] He knows that area, knows people, we go up there and make relations with a farmer John Dooley, not Tom Dooley but John Dooley he has a farm and it’s small, it’s in the mountains how do you find a drop zone hid in the mountains but the train would drop down 600 feet, go across the farm and then go back up 600 feet and you’re flying at 1,200 feet to drop you know and it’s a nice farm, kind of flat but it had barbed wire fences criss crossing it with steel posts, creek on two sides, an old apple orchard but– So we established that drop zone and Air Force could never find it, cause you’re flying low it’s just mountains you know but I knew how to find it so I could direct them and we’d find the drop zone and then we started jumping. You’d only get four guys out the door though that’s how quick it was, so did that for a couple years using that drop zone and, I don’t know, imagine nowadays what it would take to do something like that. Well back then you’d just go out there and do it, that’s the way it was. Interviewer: “And then did people have problems with the barbed wire fences or things like that?” (26:37) Nope, these guys were– Had enough training by now, we had MC-1 maneuverable parachutes, kind of maneuverable, had like a 42 square feet hole in the back and you could slip your risers and they were well briefed and they knew this was a challenge for them. First time they’re not on a great big drop zone, you know at Fort Bragg or something like that, nobody ever got hurt, we all got them in, jumped in and then from there they would go out to the field and they had a four man team, build their own shelters out of ponchos, they had to get on the ground with that hand cranked generator, build antennas and translate a message encoded back to their buddies at Fort Bragg, on an a frequency at a time, and then on a different frequency at another time, they had to receive a message and decode it and if they were successful in this it would give them some grid coordinates and a password for them to get food because they only had three meals, no C rations. So their next meal was in their copper slab and there’s a lot of funny stories there but they did it and they had to learn to communicate from high ground, low ground, down in Linville Gorge, different situations, different antennas. It was good training, they learned a lot. �Lyssy, Walter Interviewer: “Okay, I’d expect a group like this would have pretty high morale, probably motivated guys?” Oh yes, they’re all volunteers. I guess I was the captain in charge but I had a group of NCOs that were all Special Forces, trained, experienced, I learned more from them from any school would ever teach me. So I got a lot of training while I was with that unit, all kinds of stuff. Interviewer: “Alright so you’re there now, you know late 60s, 1970-71?” Yes this was still– This is ‘68-70. Interviewer: “Okay, but that’s a period when the anti-war movement at home was heating up quite a bit. Does that register with you or where you are or were you not really worrying about it very much?” It registered with me but it didn’t really affect me that much at that point, you know we had a war going on and we had a lot of good soldiers getting hurt and killed. Interviewer: “And the community around Fort Bragg would’ve been– Was that fairly pro military?” (29:23) That’s no– Yeah, that’s Army community. Interviewer: “Right, okay so now you’ve got this for two years and so– Now did you want to go back to– You want to go to Vietnam because you hadn’t gotten there?” Oh I fully expected to go to Vietnam, and I got the orders. Interviewer: “Alright, so when do you go to Vietnam?” �Lyssy, Walter July of ‘70, course individual replacements, get on airplane, go to Vietnam, get off the air plane and go to this place, Bien Hoa I guess it was and there were three signal captains on this air plane and we go there and there was another signal captain that was there already and a big bulletin board. You go look at the board when your name comes up it tells you what your assignment’s going to be. Well that captain was there already he got an assignment 101st Airborne Division, woah poor guy. So we go back a few hours later, we go back and there’s all of our names, oh we’re all going to the 101st. Interviewer: “Alright, so why is it poor boy if he’s going to 101st?” Well 101st we knew then was the only division left in Vietnam that was fully engaged in fighting war, everybody else, the 4th Division was being taken down and you know people were going home. Nixon’s bringing the troops home, except for the 101st was still up in I Corps and fully engaged. Interviewer: “Okay, alright so how do you get from Bien Hoa up to I Corps?” (30:58) Well at night they wake you up in the middle of the night and grab your duffle bag and you get on the C-130 and we took off and we started flying north for a long time I said “My God we gotta be in China by now.” Well they flew us all the way to Dong Ha and we stopped there and some people go off and then it flew back to Phu Bai and got off the air plane and there we were at the Camp Eagle. Interviewer: “And that’s the headquarters for 101st?” Headquarters for 101st, next thing they do is transport you north to Camp Evans and you’re gonna go to screaming eagle replacement training. Everybody had to go to service training before you can join a unit out in the field, which when I look back now it was important. Interviewer: “What did that training consist of?” �Lyssy, Walter Firing weapons, even like the 90 millimeters recoilless, the M-60 machine guns, your basic M16s, getting refamiliarized with all these weapons, a lot of air mobile as we knew it back then, you actually jump on helicopters and fly out and do air assaults just to learn how that’s gonna work, get familiar with artillery, bringing in artillery, cobras, rockets, all the things that are gonna be happening to you once you go out to the field. Interviewer: “Okay, alright and how long does that last?” A week, and at that point Ripcord was going on this is– I think I got out of service training on the 21st or 22nd, you can see– You could actually when the chinook crashed at Ripcord we’re sitting in the stands looking at this column of smoke up there. In the evening you’re watching chinooks haul in damaged helicopters, a lot of activity going on. Interviewer: “Okay chinook crash is July 18th and then–” That would make sense, 18th, 19th, 20, 21, yes. Interviewer: “And then the 23rd is when they actually pull off the base entirely.” (33:34) Yes, 23rd is when they pull of the base, on the 23rd I was finished training and I had to go to Camp Eagle to see the division signal officer who does all the assigning of signal officers and so we went there and it was Colonel Smart was his name was his name and he says “You’re going to the 2nd 506th Infantry.” Then he told me about Colonel Lucas being killed that day and all the casualties and Ripcord and how they pulled off and so that was the 23rd, next morning I joined a unit. Interviewer: “Alright, so let’s– So basically what happens, you go out to join the unit?” You go to Camp Evans and you go to this unit and they had just pulled off Ripcord the day before and things are not normal. You start hearing all these statistics and stories and talking to people, they’re all talking to each other and first thing that happened was a memorial service, �Lyssy, Walter lined up the battalion, had a little stage, Chaplain Fox, the battalion chaplain gets up, the rifles stacked, boots, half the battalion crying they were just an emotional wreck, I mean it was bad. Interviewer: “Who was in charge of the battalion at that point?” John C. Bard was our new battalion commander. Interviewer: “Okay so he’d already been installed, or just arrived?” Just arrived, back– Major, I’m gonna say, King was the XO of the battalion, he had just come back from R&R in Hawaii, when I got there I reported in to him Colonel Bard was just, I don’t know if he was there yet but he was coming aboard that day. So I go to report to the XO, the battalion XO, he looked at me and he looked at my signal flags and he jumped up and ran out the room. I look around “Well what’s this about?” Because prior to that John Darling was the signal officer, he was a West Pointer and he got killed, Ripcord, and Captain Hopke was sent by division temporarily to fill that slot. (36:18) Well Hopke was short, he was going home so I’m there to replace him but you can imagine this major what his dying commanders did, what his operations officers did, all these people are injured or scattered to the four winds and of course personal accountability is really an important thing and he looked at me and he says “Oh my god, what did I miss? Where’s my signal officer?” So he ran out and he came back saying “Okay, Hopke’s going home. Okay, good on you guys.” Yeah so he got that done, it was crazy there was a little officers club, you go in there and you hear all of these stories and names and experiences and “Good lord what kind of unit did I join here?” The last 23 days there’s something like 72 guys killed and 250 injured and I’m gonna be in this unit for a year? Course it wasn’t like that after that it– Interviewer: “Alright so what was Colonel Bard like?” Colonel Bard was a Rhodes Scholar, Westpoint graduate, Rhode Scholar, brilliant man and I wanna say a few things but I want everybody to know that I admired him, he’s a super guy just a brilliant guy but he had very little common sense. Okay and you’ve seen it, you’ve seen like �Lyssy, Walter brilliant people who had a hard time tying their tire but he was– And don’t get me wrong he was a good commander and he really cared for his troops and that sort of thing but I thought he was in the wrong place, he was put there to punch his ticket, get his ticket punched and he didn’t last I think I’d have to go back and review the records but he was there long enough to get to know who we are and move up to be a divisions operation officer, a big job and I’m sure he’s very good at it and brilliant at it but he wasn’t a dig in the dirt infantry guy, you know type of guy. Interviewer: “So what actually now happens with the battalion once you join it, do they rebuild for a while or?” Well you have to understand now about half the battalion is new, truckloads of soldiers are coming in and we got a new battalion commander, a new operations officer, super guy Frank Willoughby is now the S3 and he is– Go back and start the Battle of Long Bay which is way up north, he was the A company commander, Special Forces guy at that camp, at that battle where he got attacked with tanks. Interviewer: “Yeah, they were overrun at that point.” (39:22) Overrun, had the tanks sitting up on the top of his operation center, Marines wouldn’t come and get them, Army had to come in there and dig them out of that, it was a terrible battle. Yeah but he was my boss, he was the S3, so you have all these new people and we’ve got– Your orders now are really only stand down which is– Try to take some of their troops to the beach to give them a little break, time to clean your weapons, clean your radios, make sure everything is working right, new batteries. Refurbish the battalion but one thing you can’t do is let this battalion sit in this emotional state now, sit in arrear. So I don’t remember– It was just days later that we air assaulted out at Katherine, Firebase Katherine, so here we are again out in the jungle’s twisted way. Interviewer: “Alright, now were you normally going to be with battalion headquarters wherever that was or would you be in the field with the battalion?” �Lyssy, Walter I was– I spent almost all my time in the field with the battalion at the battalion headquarters at the firebases. Even– I mean to the extent of even when they went one back on– Back to base camp for a week I actually stayed with– At the firebase to keep things– One thing I could always tell was this little story, when I first got there the idea was to have electricity done by little gasoline generators 1.5 and 3 KW generators and those generators were never designed to run 24/7. They’re little, you know pull a rope and crank them up and, you know but that’s what supposedly what’s going to power our radios and all that sort of thing in the top. So it wasn’t– Can’t tell you exactly how we did this but I can up with a 45 KW diesel generator. We stayed there about a month then we moved to Rakkasan and I brought that generator into Rakkasan under a chinook and placed it, sand bagged it in, got droves of diesel fuel and we ran– I provided– I was providing electricity for the firebase, I had fluorescent lights at the TOC in Rakkasan and then you make sure you put your lights in important places like with your artillery, in your operations center and so forth cause they can do a much better job if they have lights and so forth. So yeah besides commo I did lights. Interviewer: “Alright, now what was the battalion doing at that point, I mean they’re on these firebases just general patrolling?” (42:37) Yes, the typical thing you established a firebase, put the battalion headquarters on the firebase, bring in the 105 and 155 artillery plus the various other sundry things that happen, engineers and that sort of thing on the firebase, primarily working on the bunker line and I had to learn with my fellow officers– And don’t get me wrong now when you join an infantry battalion, particularly there in Vietnam, and you’re the commo officer, yeah you’re the commo officer but you’re infantry too. You’re gonna be right in the middle of it all, filling sandbags, getting your crew, and securing things and after the lessons of Ripcord perimeter defense is pretty important and you have to learn how to do that. You don’t just go out there and throw some concertina wire, you know it’s– Rollie Rollison was Delta Company commander in Ripcord and right after that he became the S4 but I considered him as one of the experts on knowing how to build that perimeter defense, taking three strands of concertina and nailing it down to the ground about yay high and then putting more concertina on that and nailing it down and down so it’s a solid barrier, plus the claymore mine and the fougas and the fighting positions, you make it really– �Lyssy, Walter Because we’re dealing with sappers, as the Ripcord story goes sappers were a big part of that too. So you have to really learn to do perimeter defense and I was a big part of that. Of course I did all sorts of things at the time I was the TOC officer at night, walked the bunker line inspecting fighting positions, doing all those infantry things too besides being commo, you know you just don’t sit there going “Oh no I’m the commo officer.” That doesn’t work, so you learned to do all that sort of thing. Interviewer: “Alright, now how long did you stay in that job?” Well I started in July and until the next spring, I believe till about the 1st of March, something like that. Interviewer: “And then what did you move onto from there?” I became a signal officer for 1st Brigade, 1st Brigade signal officer. Interviewer: “Okay, and where were they based?” (45:15) Camp Eagle, 1st Brigade Camp Eagle, 3rd Brigade is Camp Evans, 2nd Brigade was off wandering some place. Interviewer: “Alright, now what do those duties consist of now?” Where at? Interviewer: “At the brigade.” The brigade? Interviewer: “Yeah.” �Lyssy, Walter Well you’re overwatching the various battalions and what they’re doing, and of course distributing all the codes for secure radios and what we called back then the S.O.I, signal operations instructions, making sure all that gets done, talking to the bridge commander, future operations which, well he’d call me in and tell me what we’re going to be doing six– A month, six weeks from now we had big operations that went out back to the A Sau and so forth that he had me pick where he should put his brigade headquarters out there so he can talk back to Camp Eagle and cover their end and he was going to– Which took a lot of work because you’re doing basic map reading and profiling mountains and we’re predicting where the radios are gonna work and not work then actually jumping on the helicopter and flying out there and sitting down on the ground and testing it, you just sort of did that. Interviewer: “Now were you still there when the Lam Son 719 operation took place?” Oh yes, one of my additional duties while I was with the– Well after we first got to Katherine, Colonel Bard said “Get on a command control ship and run over to this sister firebase and you’re gonna learn how to be a beacon drop officer.” “What’s a beacon drop?” So I go over there and the commo officer there was a beacon, and he taught me to do beacon drops. (47:22) Interviewer: “So explain what a beacon drop is.” It’s a way to drop bombs in your area, your AO, when the weather is bad and there’s clouds and the normal sets of air can’t come in and bomb for you. The Navy Marines flew A-6s out of the main and that air plane would carry 22 500 pound bombs and then I would be at the firebase and the beacon drop officer has a PRC 41 UHF radio, a weird looking thing with a big fat antenna, to talk to them directly and a transponder. A transponder simply works with radars just like the air liner flights today they have a transponder in the airplane where they beat the signal and it shows up on radar. Well this is the opposite, I’ve got the transponder with me and it’s A-6 you know there two people in that airplane, the pilot and there’s the electronics officer with radar screens and they’re very sophisticated electronics, and it’s off set bombing from my transponder and I would feed them data, direction to the target and degrees, minutes, distance, and feet– Let’s see if I remember all this, elevation, differentials, and his flight path that I wanted him to fly on and �Lyssy, Walter he would gather all this information and go out about 15 miles and then turn– And you also had to authenticate the transponder to make sure you’re looking at the correct transponder but I would switch codes, you could switch codes from alpha through foxtrot I believe it was, and it’d come back at you and you’d do that a couple times “Okay, got you.” They’d go out 15 miles and start heading in and you’d see them on radar sweeping your transponder, it’s beeping, you’re talking, and then they had 22 bombs and you could vary things like you could drop all the bombs on one spot at one time or you could have a set length of 3-400 yards. You could have first bomb on target, center bomb on target, last bomb on target, you can vary all these sort of things and he would drop bombs and it’s the way you get a lot of bombs through bad weather and I got because– now the secret of this thing is that your batteries are charged for your transponder and your radio. Either one of those failed and mission’s gone, well I had my 45 KW generator and I knew how to charge batteries. So I was always ready and I got a reputation of being a reliable beacon drop officer because they would, you know– It’d go someplace else and if it failed they’d divert them to me, so I was just dropping bombs all over the place. Interviewer: “Alright, now this came in response to my asking about Lam Son 719–” (50:35) 719, okay 1st of the 506 was up north already, 2nd 506 where I was at was still, I think we were at Firebase Jack at that point but all of a sudden word came down for Captain Lyssy to get your beacon drop equipment together, select one soldier to help you carry equipment. Helicopter coming you’re gonna go north to the 1st of 506 because they don't have a beacon drop officer and they’re completely surrounded and they’re getting bordered heavy and they need bombs. So it’s Freddy Pitts a black soldier from Mississippi, good soldier “Ready? Pack your ruck, let’s go.” Sure enough first they flew us to Rakkasan, next morning we got a huey and we went into the battalion headquarters up on a ridge by the rock pile and sure enough we were surrounded. You could actually hear the enemy talking at night, claymores going off all night and we’re digging our hole and get there. So I was there to put in beacon drops and Freddy Pitts told me if I could ever get him back to Camp Evans, he’s stay the rest of his life and never complain, get him out of there and it was pretty bad I remember bringing in an eight inch artillery just over our shoulder, same ridge, there’s no enemy on the next one. Just pounded that thing with eight inch �Lyssy, Walter artillery and sent a squad or two down there and boom! They got hit with homemade claymores and so forth, vivid memory of the medevac hoisting up and injured soldier with border rounds flying, dropping through his blades. He took off and turned hard and the injured soldier hanging on it into a jungle penetrator about 45 degrees, then you don’t know I don’t know what happened to the guy you know, and a couple guys got killed that day bringing it back. It was a bad place. Interviewer: “Okay, now was this sort of– Was this battalion in a position where it was kind of supporting the operation into Laos at that point?” Yes, Americans were up north fighting the enemy while U.S helicopters and the south Vietnamese Army were heading into Laos. We finished that mission and funny, you know things were crazy we caught a huey back to Dong Ha [unintelligible] lot of traffic and flagged down my trader truck, Army, the cab was full of junk I climbed in there Freddy sat on the fifth wheel and we went back to the front gate of Camp Evans and came back to Camp Evans and I remember we had captured some homemade claymore, big I mean explosives just full of all kinds of nails and stuff. I brought that back just to show and tell cause sure enough the 2nd 506 went up there later, it was a pretty bad place to be, yeah. (54:10) Interviewer: “Alright now during the course of the year you had in Vietnam did you get an R&R?” Yes. Interviewer: “Where’d you go?” That was in April of– After I’d gone to 1st Brigade, it was towards the end of my tour and went to Hawaii, meet the wife and she’ll tell you I was the last guy on the last bus, she had just about given up. I finally wandered off and that was I guess pretty bad emotional situation back then, seeing everything I’d seen a so forth. We actually got to Honolulu, took a flight, went to Kauai to Hanalei Bay on the north shore and woke up the next morning and it was raining and there was �Lyssy, Walter jungle everywhere, turned on the T.V and there was John Wayne with a machine gun so hold on, I’m supposed to be on R&R. No, it was good, we had a good time in Hawaii. Interviewer: “Alright, are there other things about that Vietnam tour that kind of stand out in your memory?” Well of course you see and do a lot, all kinds of situations where you come close to being killed and also that was not from enemies but just being there, when you have that many soldiers, that many weapons, you know and RPG firing across the windshield of a loach. We had to distribute what we called the funny papers because everyone was required, specifically right after Ripcord, to have a secure radio and there are codes that they have to punch into this– Well we call it the gun the KYK 20-A and you punch it into the KY-38 that provides the encryption for a secure radio but you could only give out seven days and each unit including recon team had to have a secure radio. So you have to visit every unit every week to give them these codes and usually, typically you take a smoke grenade which comes in a cardboard canister, you open it, you take the smoke out, you put the funny papers in, tape them up and tape them to the smoke so when you’re in the helicopter and you see the guy on the ground you pop the smoke and you try to hit him with it because if you lose it, you got a big problem. (57:05) Now the division’s gonna have to change, so you don’t lose these funny papers. There’s some stories of myself and another fellow commo officer hanging in a tree get down and skid, get down in that tree to get it back, yeah so distributing those, all that, it took a lot and then helicopter guys come up and you show them all the locations, you can’t just go pop smoke at every friendly location cause you just located all the friendlies. So you do a whole bunch of false ones too you just throw smoke out everywhere. Yeah, so yeah getting that done a lot of helicopter time, a lot of helicopter time just constantly flying in your AO and so forth and the pilots show up and they get their briefing and when you show them where the 51 cals are the enemy the enemy has they don’t like to go there. For good reasons, but yeah you spend a lot of time doing that, no one ever– Well the division didn’t keep battalions in those mountains in the winter time cause you get the winter months, but boy this year we’re gonna keep one battalion out at Rakkasan, and of course that was us and the 1st of October is started raining and it rained for all of October and all of November and in the middle of that you look back at your weather history, there was a typhoon, a big typhoon that �Lyssy, Walter came through at the same time and the reports are it rained 104 inches on us and we ate C’s almost the whole time and we didn’t get out of there till the end of December. December was all fogged in too and basically we had to walk out to get out of there and brigade commander– At that point we had a new brigade commander and he was upset with soldiers not having dry socks. That’s always been a thing in the Army, always keep a pair of dry socks and started to have foot problems and you tell your sergeant major to go out there and teach those soldiers how to have a pair of dry socks and sergeant major comes back and he says “There may not be any dry socks.” When it rains constantly, day after day, week after week, and then he says “Okay, Bard you go out there and show them.” Pretty soon he sent his own sergeant major and his own sergeant major came back and told him “There’s no way, nothing’s going to be dry, everything is wet.” And it sure enough was, we came out of there at the end of December and I remember particularly Charlie Company having to carry him off a helicopter to the aid station her feet were hamburger. Yeah, took ten days before they could walk again without us, gosh there’s so many things that stick out in your mind about that, I guess first casualties, that sort of thing. Interviewer: “How much contact did you have with the South Vietnamese military?” (1:00:10) Not a lot, we pretty well operated independently and they were wary in this sort of thing but specifically us the battalion headquarters, I don’t know what even Vietnamese people because there’s no population in these mountains, it’s us and North Vietnamese. Interviewer: “When you were on the big bases were there South Vietnamese there?” They’d go on big bases, that’s how– Well at Camp Eagle when I was brigade signal officer there was some Vietnamese there but not many. Now Camp Evans there was no, what you call, house boys or house girls or any of this, we didn’t have any of that– Interviewer: “And there’s no villages outside the base or anything like that?” �Lyssy, Walter There were and I guess they ran a laundry some place, amongst us soldiers even in our base areas nuh-uh didn’t have them. Interviewer: “Okay, this tape is about up so we’re gonna pause right here, rewind and reload. Alright we were kind of tying up some pieces of your Vietnam tour, one question I’ve got is about the morale of the troops in the field when you’re there. What was that like because you joined them after the battalion had been decimated and rebuilt and so forth, what impression did you have of the soldiers?” Well, you know it was a mixed bag, we still had really good soldiers with good attitudes and so forth doing a good job but then there was always the element of commanders having a hard time with who’s gonna be in the field and who’s gonna have to get not to be in the field. That was a really big deal if you could get back to the base camp but stay back there so they play that game and your problem with of course marijuana was back in the base camps was a big deal but in the field, I won’t– I’m not gonna sit here and tell you there was none but the troops pretty well policed themselves out in the field because they knew they were in a situation where, you know if you screwed this up you’re gonna have a sapper come in there and get you killed. (1:02:37) So they wanted those fellow soldiers to be on their toes and so forth. So it kind of took care of itself out in the field but problems back in the base camp. I spent very little time in the base camp, I pretty much stayed out in the field, I take a small crew with me but of course you had to run the switchboards, run the battalion and brigade radio nets with my radio operator sitting there to talk and keep the battalion logs going and that sort of thing. So that was a big job of keeping that going and I had some really good signal guys radio operators that did that sort of thing. Interviewer: “And were you aware of problems in the base camps with racial issues or harder drugs or things like that?” Yes, there were, I remember one soldier going berserk and shooting their area up and so forth and you know those sort of things but I’d just hear about them because I was out in the field. Interviewer: “Yeah, it’s not really what you were seeing out there.” �Lyssy, Walter I’ll tell you another little story, was right after Ripcord we were at Firebase Katherine and we were only there for– I don’t remember precisely, maybe less than a week when– And I was out trying to get a light bulb in the artillery battery area for them to help them out and of course we didn’t really have any supplies trying to use copper wire to put some lights, give them a light bulb and I do it myself. We’re digging trying to bury this cable and a huey helicopter which was working for a battalion in an adjacent area DARS got disoriented at night, saw a light on our firebase and decided it was the enemy with flashlights. So he came through machine guns blazing and strafed our firebase and I got caught right– That was my first time getting shot at, I didn’t know what was going on I had all these little red firecrackers bouncing all over the place all around me and so forth till about a second later I figured out this is not good and I rolled over and got inside a bunker but that day we had received our quad 50 which was each firebase were so far north that you had a quad 50 for 50 caliber machine guns for air defense. If something does come over to DMZ it’s getting some fire power and that nervous quad 50 team just test fired their quad 50 against the side of the mountain and the disoriented helicopter went around for another pass was coming in. (1:05:45) The quad 50 guys were on the quad 50 ready to shoot this enemy helicopter when a radio operator who had some experience he was monitoring brigade net and he put two and two together, he heard what was going on outside he’s real sharp and he gets on the radio and calls him off, or else we would’ve had a helicopter shot down that night. They did hit one soldier who had just survived Ripcord, he was in a fighting position, he had seven days to go before he goes home and he took an M-60 round in his groin and up through the intestines and Dr.Harris, Jim Harris was out battalion doctor. So run down there, I’m helping with the stretcher, we pulled him up through the barbed wire and get him up by the battalion headquarters for medevac coming in. Nothing a doctor could do for a guy with that type of injury but the medevac was there, it’s dark now, it’s night and we get him in the medevac and as they’re taking off they’re barely 10 or 12 feet in the air when they start– Hovered into the clouds, cause clouds come down at night and they just did that, of course they just fly down the mountain and go away and they got him in and Dr.Harris a few years ago from now found out who that soldier was and that he lived, and of course in these times a guy gets injured he’s gone that’s the end of story, you don’t know. Well apparently that soldier lived and I’ll always remember that soldier laying on the stretcher and he grabbed his buddy by the shirt, pulled him �Lyssy, Walter down and said “You find out who’s flying that helicopter.” I don’t know whatever happened to that but he was a little hecked that he survived Ripcord, was getting ready to go home, here comes a helicopter, shoots him. There’s lots of those stories, terrible. Interviewer: “Okay so now you kind of get to the end of the Vietnam tour and so when do you leave Vietnam?” July of ‘71. Interviewer: “Okay, alright and where do you go next?” I go to the signal officer advanced course in Fort Thomas, New Jersey and almost everybody in that course– And now there’s 50 of us– Boom! So we’re gonna have I think it’s nine months, ten months of advanced course, signal advance course. Interviewer: “How do they fill that nine or ten months?” (1:08:30) Do what? Interviewer: “What do they do?” Oh well all the branches of the Army have those advanced courses, that’s how you go from captain to major and gosh you get classes on all kinds of stuff, you know from basic electronics through all the signal equipments and organizations, you know all that sort of thing it’s just a normal thing but by then it’s not getting to be– Going into ‘72 and after nine months of training the Army is having a reduction in force and half that class got rifted. After nine months of class they’re gone. Interviewer: “Now did you have some seniority on them because of when you got your commission?” �Lyssy, Walter Yes, I was late getting into the advanced course because of my assignments, the way they went, so I was actually the class leader as a senior guy in that class. So yes, when you take all these guys that just got back from Vietnam and put them in a class interesting things happen. They’re not the best behaved students around, most of them funny things happen you know. So it was a lot of fun and then following that I became an instructor for a few months and then I got selected and attended the course that was basically taught by AT&T but at Fort Monmouth to become a communication systems engineer where you study everything from telephone switches to microwave systems, triple scanner systems, cable systems, that sort of thing for, you know the opposite of the green box with the tactical equipment now you’re talking about the commercial equipment. Interviewer: “Okay, and was this a period where they were computerizing things or miniaturizing things or not so much yet?” (1:10:55) Not so much yet, although yes we had the old IBM 360s I guess they were with the punch cards, that sort of thing it was that phase, it was– During that course I remember we had some civilians with us too and we had one from Hawaii and his unit gave him a calculator, calculators had just come out and pretty soon we all had calculators but he has a sophisticated one you know and so “Wow look at this thing!” Just punch numbers and it calculates for you, what was that Texas instrument set up? T– Something or other it was just– Yeah, so that was a big step in technology there just to get a calculator. Interviewer: “Alright, and now with this training once you’ve got it what do you do with it?” Got assigned to the COPAC, communicationations, electronics, engineering and installation– Interviewer: “Pacific?” �Lyssy, Walter Pacific, so we’re stationed in Hawaii, some military commanded by colonel, lieutenant colonel, deputy commander, a bunch of captains, and about half civilians, several service people engineers and so forth. Interviewer: “Were you still a captain at this point?” Still a captain and our main mission was to rebuild comm systems in Korea because Korea had been neglected all during the Vietnam war and all of their systems were really old and falling apart and so forth, we needed to rebuild Korea. So a lot of equipment was taken out of Vietnam and Thailand, sent to Okinawa, refurbished, and we bought lots of new stuff and we basically rebuilt the backbone of Korea. This is before satellite and so it’s– The world’s split up by Army, Navy, and Air Force as to who’s responsible for communications and so forth but we had our troop system coming out of Japan, shooting across in the southern part of South Korea. Did a microwave system that went throughout Korea mountaintop to mountaintop and down to post camp stations and telephone exchanges, cable systems, you know I’ve been to almost every place in South Korea that a G.I can go to, every mountaintop, every post camp station, so I got a lot of Korea. Interviewer: “Alright, now when you went to Korea how long a– Would you go for a few days at once or weeks?” (1:14:00) Sometimes it’d be two weeks and I remember one time it was I think three months, you’d go in and yeah you’re chasing down projects. You do site surveys, see what’s there, come back and get into the big plan of what needs to be replaced or equipment, once equipment comes in you have installation teams that come in and install, then Q&A people behind that to test things, get everything going, cut over from old systems to new systems. Pretty complicated process to fix a country like that. Interviewer: “Now how did Korea compare with Vietnam in terms of your impressions of the place?” �Lyssy, Walter Well to me Vietnam was just my unit in mountains, infantry unit fighting the war, as far as the country goes I know very little about it except that spot you know. I didn’t travel around Vietnam at all, I don’t think I ever went to a village or had zero experience like that with the, you know you see a lot of other G.Is “Oh yes.” and they go to dinner and they– You’re the guest of honor and you have to eat the head of the chicken and all that, I don’t know anything about that. We were out there in the mountains eating C rations. So Korea of course I experienced a lot with the local people cause we’d go to areas where G.I aren’t normally there, they had a town with a mountaintop next to it with a microwave system and so you’d intermingle with them and they were– G.Is don’t normally stay so forth, so yeah. Thailand was to me where I really related with a lot of people, totally different, that’s my favorite place those people really loved their country and they loved their king and their queen and it’s just a different place you know. Interviewer: “Yeah, I mean do the Koreans seem to recognize why you were there?” Oh yeah, sure they, you know you hear all the stories about Korea, what they are is they are strong people. (1:16:22) Physically strong, those short legs and put an A frame and lift up a drum of fuel and walk off with it, it’s unbelievable. Interviewer: “So at that point it wasn’t really developed in the manner that it is now, now it’s a very modern industrialized country with better internet than ours.” They didn’t have cars and so forth, now they all have cars but they don’t have roads so– But no it was– But we traveled and we had some Toyota Land Rover type vehicles that we drove ourselves. We took the blue train from Seoul down to Busan– Actually flew with Korea airline from Seoul to Busan, strange because you put the people in the back of the airplanes and there’s no door to the cockpit, solid wall, bolted, they come in through windows. Nobody can hijack that airplane with doors like that, take the Greyhound bus and then you take what we call the kimchi bus in the remote areas that– Really rough roads, get back in there, get all that stuff accomplished, yeah so got a lot of Korea time. Interviewer: “Okay, now how long did you spend in Hawaii?” �Lyssy, Walter Three and a half years in Hawaii, loved it. Interviewer: “Okay, and were you going back and forth to Korea the whole time or just for part of it?” Korea and other places, Taiwan, guys would go to the Philippines, Japan, Okinawa. Most of my work was Korea, I became the deputy commander after a while, I got promoted to major and became the deputy commander, the last year I didn’t travel much other people’d be going out, staying in Hawaii at that point. Interviewer: “Okay, now you’re in the Army in this period when they’re kind of– Vietnam is over, the Army is downsizing, shrinking and so forth it’s become an all volunteer Army. Did you notice any effects of those things aside from other officers getting rifted?” (1:18:33) Oh sure, after Hawaii command staff college and then at the Fort Ord, California 127 Signal Battalion was obviously part of the 7th Division and lot of soldiers, big battalion and one of the, it’s now full armed volunteer Army, standards for coming in the Army, what do we call that Cat IV? The category IV soldiers. Interviewer: “What does that mean?” Low IQs, very low standards, all kinds of soldiers coming in, the Signal Battalion was one of the battalion in the division who had females. So we, in our battalion of maybe 600, we had– We were at actually I think 110 females. So you had that mix also, so yeah lots of troop problems, I always thought it was silly but the division commander required the battalion commanders to have a 3x5 card in their pocket with every soldier who was coming up for reenlistment. We had to know all their names and interview them and beg them to stay in the Army, and a lot of them we didn’t want in the Army, so it was kind of nutso. �Lyssy, Walter Interviewer: “Now did the Signal Battalion get better qualified personnel than one unit or?” Not really, they were poorly trained, come out of the schools– We had all our– We had, you know, all our troop problems, lots of troop problems and good soldiers too, don’t get me wrong we had great soldiers, male or female they all come like the same. I remember our soldier of the year in our battalion was a female soldier, she was great she got out of the Army and a few months later she married the platoon leader. Oh, didn’t know that was going on. Interviewer: “Did the female soldiers, I mean did having them available did that help you in terms of having people with talent to get stuff done or did they perform about the same level the men did?” Same level, really really bad ones, really really good ones, just like the guys they come in big and small, smart and dumb, all kinds yeah. Interviewer: “So what years was this that you were there?” (1:21:20) ‘78 to ‘81. Interviewer: “Okay, and what was the attitude– You’re out in California, what’s the attitude of the people in the community to the soldiers and the military?” Well of course this is Monterey, California they’re used to having the military the Naval Postgraduate School was there, beautiful facility, basically I guess they really enjoy having the economy of the Army there but would just as soon not have the Army there. I remember all the meetings you’d have to go to to see if they would give permission to shoot mortars, forget artillery that makes way too much noise you can’t do that. It’s a silly place to have an infantry division, it rains in the winter time, the grass grows up 18–Two feet high in turns brown in the summer it’s crispy, any little spark is gonna set off a forest fire so you can’t shoot any weapons, you can’t do anything like that. So all the training has to be accomplished far away at Yakima, �Lyssy, Walter Washington or Fort Irwin, California and it takes a set of tires just to get there. So I mean it’s just– So yeah it’s a nutso place and guess what? It’s closed and it’s gone and if that makes sense, it’s not a good place to have a real Army infantry division, training was– Basic training, that sort of thing yes but not, you know you really can’t do very much out in the field at Fort Ord, California without burning it up. Interviewer: “Alright, and then now from here what do you do?” Well then I got assigned to Fort Sam Houston, Texas going to Texas finally. Always volunteered for Fort Hood which no one wanted to go to and I could never get into but that’s typical of, you know requesting something in the Army. So then I got assigned to Fort Sam Houston and I was director of telecommunications for Army’s Health Services Command which is the command that control the medical school plus all the hospitals from Alaska to Panama in the continental United States, that sort of thing. Interviewer: “Now has the technology advanced some for you?” (1:24:00) Oh yes, so now we’re in the early stages of computers, desktop computers, and let’s see I got– I think I had a desktop computer in ‘83, our commanding general at Fort Huachuca basically send us all signal guys a message saying “Got these things called desktop computers are coming, there’s gonna be one on every desk and there’s no school. I recommend you go get one and start training yourself.” And the Army had just had one of their first contracts out with Zenith– What was it called the Z-100? It was a dual five and half inch floppy disk computer, you had to load the operating system each time you turned the computer on and you could do word processing and a couple little things. So we started from there, just yeah train yourself cause you know you’re out there in the leading edge and nobody else knows either. So I was bringing in the first computers in the Army and then we– I guess my main accomplishment there was to do the early work with our computer guys and the medics had their own ADP corp at that point to do medical automation and working together with them we did trying to bring on systems in hospitals. First ones were a pharmacy system, an appointments system, a system called CAPOC, computer assisted practice of cardiology where you could actually do an EKG and send the EKG to �Lyssy, Walter somebody that knew how to read it and send the results back so you could use his expertise other than being there where he was. So we had these basic systems and we were installing them at various beta sites and hospitals, testing them and getting them going, those were early stages to what today is the composite health care system I believe it’s called, something like that which automates everything in the hospital, medical records to pharmacy to whatever. So it was a lot of work and we enjoyed it. Interviewer: “Sounds like an interesting job.” Oh yeah, it was good. Interviewer: “And was the Army getting a lot of– Were you getting kind of better quality people in there to do things?” Oh sure, well now you got a big medical headquarters that you’re dealing with, pretty top notch people. Interviewer: “So it’s not a single battalion.” (1:27:00) And the– Yeah the Army’s getting better too, yes in the early days of volunteers and category IVs and that sort of thing those were tough days trying to– And the turn over back then, our turn over in the 127 Signal battalion late 70s early 80s it was 125% a year. Interviewer: “Which means people are staying on average less than a year, isn’t it?” Yes, so you get this company, platoon and start training them and three months later half of them are gone, all these new people are coming in and you start training all over again and you just constantly– And this was at the point where it was decided that we’re gonna show the Russian and we’re gonna have, what was it? 16, 17 full divisions, we’re gonna be a big army. Well it’s kind of a fake army because I mean you didn’t have your basic equipment even issued to you. Those battalions didn’t have some of the major elements of multi-channel equipment that we �Lyssy, Walter needed, it wasn’t even issued. So what do we have here, you know but it worked I guess, we won. Interviewer: “Alright, okay so when do you finish then at Sam Houston?” ‘85 and I had my 20 years in and I was thinking I’m gonna retire and so forth and then the Army gave me this, put this little carrot out there to go to Belgium to NATO headquarters, SHAPE Supreme Headquarters Allied Powers Europe, with a specific job. Interviewer: “Okay and what was the job?” To go over as a comm systems engineer now to be in charge of building basically the bunker for SHAPE, SHAPE war headquarters. Huge project, three buildings, 80 meters long, four stories high, buried under ground under very tough conditions and to be where NATO was going to fight it’s war, fight the Russians from basically what that was all about and so. Interviewer: “And what sort of team did you have to work with there?” (1:29:40) Well this is a joint assignment, we have Army, Navy, and Air Force from 15 nations all together in one headquarters. Interviewer: “Okay, and how did that go?” My joint team was all U.S Army Signal Corps officers, so that was– It was– Yeah we were all U.S Signal Corps, had a great team, very complicated project. There was an Air Force lieutenant colonel who was the head of it before I got there and I took over from him, he was born in Russia, he was an electrical engineer, very bright and did everything in his head and he left. It was basically like that, probably overstating that but gosh there was no master plan. All these contractors bringing in all these boxes under their arms and all these sophisticated systems going on all over the place and now we got to put it all together and everybody was laughing at us saying there’s no way in– This is not gonna happen, you know there’s no way you can do it. We �Lyssy, Walter did it, basically it’s built just outside SHAPE headquarters, got the above ground headquarters for all 42 generals and staffs, our offices, and now you’ve got this underground bunker next– It’s right next to it cause when General Bernie Rogers was the SACEUR the decision was we’re gonna go and hide this thing in the den in the forest and so forth with satellites and we’re going “You’re not gonna hide this thing not with a project that size.” And he said “Build it right there.” and pointed out his window and that’s where it was built and so basically you have these doors, a lot of security and when the balloon goes up certain people from the above ground headquarters come into the bunker, close the doors I guess everybody else is expendable and they fight the war from there. Luckily we haven’t had to do that, I have no idea what the situation has to be, I don’t think anybody knows how much it cost to do that project because you’re basically dealing with– And the budget guy that worked for me too, he’s a great, super guy, Notre Dame graduate he would have to go to Brussels and appear before the committee to get the money to do the next step sort of thing and he just did a terrific job of it, he never failed to come back without– You know and it was all done good and we finished it, we got that project finished before I left in three years, it was cut over and ready to go. Interviewer: “And this is another case where you’re living in a different country, how did people there view you?” (1:32:50) Well you’re living on the French border in southern Belgium, french-speaking who pride themselves a little bit better than French in cuisine. It was no problem at all, very good, good relations yeah but you know when you work at a place like SHAPE with all of these generals and people from all over it’s funny because they all laugh at the Americans cause Americans are working like crazy and they’re not working so much, taking their one month vacations. I know when we first got there I had my desk across the other’s, desk to desk with an Italian lieutenant colonel and of course Americans for lunch time we go do PT, we go run, you got a PT test coming up and you gotta stay in shape so you’re out there and this Italian said “Oh about 11 o’clock I think it’s PT time. Pasta time.” So he goes off to eat, we go run, he’d laugh at us crazy Americans. It’s true I mean when you observe the Americans they’re just working their tails off. �Lyssy, Walter Interviewer: “Now while you’re there was this getting to be the point– Was Reagan president at the time?” Yes. Interviewer: “Okay and then a lot of the push against the Soviets or the face down sort of thing.” Oh yes, we were really head to head with them, we like to think that our building that war headquarters and getting it completed and ready to go might have had a little bit to help accomplish that because we had a pretty secure place to fight a war from. Interviewer: “And it was at the point where our technology was kind of getting ahead of theirs.” (1:34:55) Yes and we were out spending them and our military was growing strong and this is a compartmented facility where you had a job and you’re allowed to go to that part of the bunker but no place else. Security was really a big deal, took a half an hour just to get in the place and– But I had a go anywhere pass because I was giving the tours because you’re gonna get very high ranking people come from various countries and find out what’s going on, where’s the money going, what are we building, that sort of thing and at one point Margaret Thatcher and President Reagan were supposed to come together, said “Oh my God.” It didn’t happen, you know how those schedules go, it didn’t happen but yes I’ve given some tours to some very high ranking NATO personnel from various countries come through and I take them on a tour of the facility and show them what’s where. It’s a very interesting facility, we don’t talk a lot about it but a lot of stuff is classified yet today I’m sure. Interviewer: “And then when did that tour come to an end?” In ‘88. �Lyssy, Walter Interviewer: “Okay, alright and then you’ve got one more assignment after that?” Yeah from there I was sent to Fort Knox, where I first started, where my daughter was born and baptized in the chapel there and during that tour she was married in the same chapel, one Army career later and became the director of information management for the armor center Fort Knox. Interviewer: “Alright, on a practical level what did that mean?” You’re the chief signal officer but they’re giving you a whole lot more stuff under your wing, ran a printing plant with about 52 employees. The Army has a few printing plants that was one of them still going, obviously you ran the telephone system for the post, every telephone switch and all of those people, you’ve got a communications center sending messages in and out, the library, the record management. Just all sorts of things, anything to do with information is sort of under your purview, a lot of people so yeah. So that’s– That was what you wanted in directors at the armor center, and armor guys are good guys to work with, enjoyed it. Interviewer: “Alright and then the Gulf War happens towards the end of that assignment.” (1:37:35) Yes. Interviewer: “What was your perspective on that?” Well, Gulf War was an armor war and I’m at the armor center so that’s a very busy place, I mean we were working hard trying to assist, you know here, there, and yonder. Everything from personnel to equipment to logistics to tracking stuff, sending people. So it became a very busy place and of course it turned out great and those armored guys would come back and give their speeches, yes they were– Some of them were classified but you learned some, what happened, they did a good job. The big thing of course was our tanks weren’t ready to go and why Saddam allowed the U.S Army to bring all these tanks in from Germany and all these other places and retrofit them in Saudi Arabia and sat there and watched all this till they were ready to go and �Lyssy, Walter finally– You know it took a long time when we first started until we actually came across the border but they all had to be retrofitted not only with some weapons and so forth but primarily chemical warfare, all that sort of thing, it was a lot of work that had to be done so– And it got accomplished and it happened. Interviewer: “And was over very quickly.” Yes, a couple of days and it was over with. Interviewer: “Alright, so what finally motivates you to retire?” Oh it was time, I had done 26 years in. Interviewer: “And it gets harder to go up from each level doesn’t it?” Oh sure. Interviewer: “So lieutenant colonel to colonel was a fairly big jump.” (1:39:30) I don’t know if it’s– The early days in Vietnam and like my job petroleum in Thailand I said “My gosh if this is– I just made captain if this is what I– That much responsibility what am I ever gonna do if I make major?” Well I probably had more responsibility then than I did later because, you know the Vietnam War started and we were all just young guys and lots of work needed to be done and you got a lot of responsibility very quickly just to go get stuff done. I think it worked out pretty good, Americans are good at that. Interviewer: “So when you did finally retire out of the military, what did you do after that?” In ‘91 with the economy the way it was and so forth jobs were very difficult to obtain, I mean you know finding jobs, but we went back to San Antonio, Texas that was, you know we didn’t �Lyssy, Walter go to a job we went to the place we wanted to be and the wife was, even before I had retired, a few months she had already moved to San Antonio and she was a librarian. While we were at Fort Knox she got her master’s degree in library science and got a job in the school system and in San Antonio she was there already, then I came. Our youngest son was– Has already left Fort Knox for Texas A&M University, so we had no children with us anymore and I went back and long story short I invented a chemical paint stripper, I’ve always been a wood worker and that sort of thing and was quite successful at it and actually got it patented and kind of got into that business and did a lot of assisting and not only lead paint removal but historical restoration, Texas spent I don’t know $500 million I believe it was, something like that, restoring old courthouses and the architects would use me and my product but I’d have to go teach the contractors how to restore these beautiful old courthouses. Which were basically built with a lot of beautiful wood work, doors, windows, wainscoting, that sort of thing, it was all varnished, the varnish turned dark and people started painting them, maybe they might have 15, 20, 30 coats of paint. Showed them how to remove all that and restored all the woodwork and then I did a lot of historic buildings across the country. (1:42:25) Did the Calhoun house at Clemson University where they were trying to restore– That’s a historic building in the middle of Clemson with a lot of tradition to it, Calhoun was vice president under Grant and that property became Clemson University and they couldn’t figure out how to do it and I helped that. I actually worked on Robert E. Lee’s house at Arlington National Cemetery taking paint off those columns up front, I thought that was quite an accomplishment. So did that then– Always been a woodworker interested in that and basically now I’m fully retired and I do mesquite woodworking where I harvest mesquite trees in Texas, mill them into lumber, and then build high end furniture items from that which is quite popular in Texas. I’ve just completed a project for a church, an old church in San Antonio building the chairs for the priest and the altar boys for the church and I guess a week from Saturday we’re having a big blessing of the chairs and that sort of thing. So tough project though, God I worked myself to death on that one. Interviewer: “Alright, well the whole thing makes for a pretty good story so thank you very much for taking the time to share it.” Thank you. �Lyssy, Walter � Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Veterans History Project Creator An entity primarily responsible for making the resource Grand Valley State University. History Department Description An account of the resource The Library of Congress established the Veterans History Project in 2001 to collect memories, accounts, and documents of U.S. war veterans from World War II and the Korean War, Vietnam War, and conflicts in the Middle East and elsewhere, and to preserve these stories for future generations. The GVSU History Department interviews are part of this work-in-progress, and may contain videos and audio recordings, transcripts and interview outlines, and related documents and photographs. Coverage The spatial or temporal topic of the resource, the spatial applicability of the resource, or the jurisdiction under which the resource is relevant 1914- Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/page/InC/1.0/?language=en">In Copyright</a> Subject The topic of the resource Afghan War, 2001--Personal narratives, American Iran Hostage Crisis, 1979-1981--Personal narratives, American Korean War, 1950-1953--Personal narratives, American Michigan--History, Military Oral history Persian Gulf War, 1991--Personal narratives, American United States--History, Military United States. Air Force United States. Army United States. Navy Veterans Video recordings Vietnam War, 1961-1975--Personal narratives, American World War, 1939-1945--Personal narratives, American Publisher An entity responsible for making the resource available Grand Valley State University. University Libraries. Special Collections & University Archives Contributor An entity responsible for making contributions to the resource Smither, James Boring, Frank Relation A related resource Veterans History Project (U.S.) Identifier An unambiguous reference to the resource within a given context RHC-27 Language A language of the resource eng Source A related resource from which the described resource is derived <a href="https://gvsu.lyrasistechnology.org/repositories/2/resources/455">Veterans History Project interviews (RHC-27)</a> Oral History A resource containing historical information obtained in interviews with persons having firsthand knowledge. Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Identifier An unambiguous reference to the resource within a given context LyssyW2160V Creator An entity primarily responsible for making the resource Lyssy, Walter Date A point or period of time associated with an event in the lifecycle of the resource 2017-10 Title A name given to the resource Lyssy, Walter (Interview transcript and video), 2017 Description An account of the resource Walter Lyssy was born in McCook, Texas in the early 1940’s and attended Texas A&I University in Kingsville, Texas where he was a part of the Army ROTC’s Signal Corps for four years. Upon graduating from college in May of 1965, he was commissioned. Lyssy was then sent to officer’s basic training at Fort Gordon, Georgia for eight weeks. Following his basic training, he received his first assignment at Fort Knox, Kentucky teaching radio operators. In the summer of 1967, Lyssy received his orders for Thailand and traveled to Korat to work in the 501st Field Depot distributing petroleum until July of 1968. Once he returned to the States, Lyssy attended a Special Forces school at Fort Bragg, North Carolina until he received orders to go to Vietnam and left for Vietnam in July of 1970. In Vietnam, Lyssy was assigned to the 101st Airborne Division and received service training at Camp Eagle where he also saw the events of the Ripcord Campaign. The day following the campaign, Lyssy was sent to Firebase Ripcord as part of the 2nd Battalion, 506th Infantry working as a communications officer for a few months before being sent back to Camp Eagle as a 1st Brigade signal officer and later additionally as beacon drop officer. Lyssy left Vietnam in July of 1971 and went to a signal officer’s advanced course in Fort Thomas, New Jersey for ten months. He then left for Hawaii, where he worked in communications, electronics, engineering and installation in the Pacific. While doing this work, Lyssy frequently traveled to Korea to rebuild communication systems and did so for approximately three years before going on to command staff college and Fort Ord, California in the 127th Signal Battalion until 1981. Lyssy was then assigned to Fort Sam Houston, Texas where he was director of telecommunications for Army’s Health Services Command until 1985. After that, he worked as a communication system engineer building a bunker for NATO headquarters until 1988. After that, he was sent back to Fort Knox for his last assignment, where he remained until he retired in 1991. Contributor An entity responsible for making contributions to the resource Smither, James (Interviewer) Subject The topic of the resource Oral history Veterans History Project (U.S.) United States—History, Military Veterans Video recordings Vietnam War, 1961-1975—Personal narratives, American Source A related resource from which the described resource is derived Veterans History Project collection, (RHC-27) Publisher An entity responsible for making the resource available Grand Valley State University Libraries, Special Collections & University Archives, 1 Campus Drive, Allendale, MI, 49401. Relation A related resource Veterans History Project (U.S.) Rights Information about rights held in and over the resource In Copyright 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/467e84283e23c560d3559ba63b5d8fe0.jpg 08f48e5c508af6a9f425f255be4edf4c 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 Ronald Oakes collection Creator An entity primarily responsible for making the resource Oakes, Ronald Description An account of the resource Collection of photographs by Ronald Oakes, who served in the U.S. Marine Corps during the Vietnam War, and in the U.S. National Guard in the Iraq War. Date A point or period of time associated with an event in the lifecycle of the resource 1968/2005 Source A related resource from which the described resource is derived <a href="https://gvsu.lyrasistechnology.org/repositories/2/resources/628">Ronald Oakes Vietnam and Iraq war photographs (RHC-80)</a> Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/page/InC/1.0/?language=en">In Copyright</a> Subject The topic of the resource Iraq War, 2003-2011 Vietnam War, 1961-1975 Veterans Photographs Publisher An entity responsible for making the resource available Grand Valley State University. University Libraries. Special Collections & University Archives Relation A related resource Veterans History Project interviews, RHC-27 Identifier An unambiguous reference to the resource within a given context RHC-80 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-80_Oakes-Vietnam-Scan-080728-0042 Title A name given to the resource LZ Gurkha artillery emplacement of 105 mm howitzers Subject The topic of the resource Vietnam War, 1961-1975 United States--History, Military Marine Corps Military life Soldiers Photographs Description An account of the resource LZ Gurkha artillery emplacement of 105 mm howitzers. Creator An entity primarily responsible for making the resource Oakes, Ronald Type The nature or genre of the resource Image Source A related resource from which the described resource is derived Ronald Oakes Vietnam and Iraq photographs (RHC-80) Veterans History Project interviews, RHC-27 Coverage The spatial or temporal topic of the resource, the spatial applicability of the resource, or the jurisdiction under which the resource is relevant Vietnam War Language A language of the resource eng Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/page/InC/1.0/?language=en">In Copyright</a> Format The file format, physical medium, or dimensions of the resource image/jpeg 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/64ccd24251ad8b43effdc3465005a9f0.jpg 7ecad65dc04a959c20b319b2283142f5 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 Naval Recognition Training Slides Subject The topic of the resource Slides Military education Airplanes, Military--Recognition Warships--Recognition World War, 1939-1945 Description An account of the resource Slides developed during World War II as a training tool, for top-side battle-station personnel on board ship and for all aircraft personnel, by the US Navy. In 1942 a Recognition School was established by the Navy at Ohio State University where the method of identification was developed. In 1943 the school was taken over by the US Navy. The importance of training in visual recognition of ships and aircraft became even more evident during World War II. Mistakes resulting in costly errors and loss of life led to an increased emphasis on recognition as a vital skill. Creator An entity primarily responsible for making the resource United States. Navy Source A related resource from which the described resource is derived <a href="https://gvsu.lyrasistechnology.org/repositories/2/resources/477">Naval recognition slides (RHC-50)</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 2017-04-04 Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/page/NoC-US/1.0/?language=en">No Copyright - United States</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 RHC-50 Coverage The spatial or temporal topic of the resource, the spatial applicability of the resource, or the jurisdiction under which the resource is relevant 1943-1953 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. Source <a href="http://gvsu.lyrasistechnology.org/repositories/2/resources/477">Naval recognition slides, RHC-50</a> Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Identifier An unambiguous reference to the resource within a given context RHC-50_1798 Title A name given to the resource M Class (ex-German) Russian mine sweeper Creator An entity primarily responsible for making the resource United States. Navy Description An account of the resource M Class (ex-German) Russian mine sweeper, October 1, 1947. Subject The topic of the resource United States. Navy World War, 1939-1945 Russia Military education Warships--Recognition Slides Language A language of the resource eng Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/page/NoC-US/1.0/?language=en">No Copyright - United States</a> Type The nature or genre of the resource Image Format The file format, physical medium, or dimensions of the resource image/jpeg Source A related resource from which the described resource is derived Naval recognition slides (RHC-50) Date A point or period of time associated with an event in the lifecycle of the resource 1947-10-01 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/22eda55567e5a34d8385cb0bfae823fc.jpg 0ebfb59d515c700b7d90574b8befeefd 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 Naval Recognition Training Slides Subject The topic of the resource Slides Military education Airplanes, Military--Recognition Warships--Recognition World War, 1939-1945 Description An account of the resource Slides developed during World War II as a training tool, for top-side battle-station personnel on board ship and for all aircraft personnel, by the US Navy. In 1942 a Recognition School was established by the Navy at Ohio State University where the method of identification was developed. In 1943 the school was taken over by the US Navy. The importance of training in visual recognition of ships and aircraft became even more evident during World War II. Mistakes resulting in costly errors and loss of life led to an increased emphasis on recognition as a vital skill. Creator An entity primarily responsible for making the resource United States. Navy Source A related resource from which the described resource is derived <a href="https://gvsu.lyrasistechnology.org/repositories/2/resources/477">Naval recognition slides (RHC-50)</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 2017-04-04 Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/page/NoC-US/1.0/?language=en">No Copyright - United States</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 RHC-50 Coverage The spatial or temporal topic of the resource, the spatial applicability of the resource, or the jurisdiction under which the resource is relevant 1943-1953 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. Source <a href="http://gvsu.lyrasistechnology.org/repositories/2/resources/477">Naval recognition slides, RHC-50</a> Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Identifier An unambiguous reference to the resource within a given context RHC-50_1709 Title A name given to the resource M class mine sweeper Creator An entity primarily responsible for making the resource United States. Navy Description An account of the resource M class (ex-German), Russian mine sweeper, October 1, 1947. Subject The topic of the resource United States. Navy Military education World War, 1939-1945 Slides Warships--Recognition Germany Russia Language A language of the resource eng Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/page/NoC-US/1.0/?language=en">No Copyright - United States</a> Type The nature or genre of the resource Image Format The file format, physical medium, or dimensions of the resource image/jpeg Source A related resource from which the described resource is derived Naval recognition slides (RHC-50) Date A point or period of time associated with an event in the lifecycle of the resource 1947-10-01 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/d325acf169abef3c8b337f96894028c1.jpg 63f3b642b37221158400f55d63223680 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 Naval Recognition Training Slides Subject The topic of the resource Slides Military education Airplanes, Military--Recognition Warships--Recognition World War, 1939-1945 Description An account of the resource Slides developed during World War II as a training tool, for top-side battle-station personnel on board ship and for all aircraft personnel, by the US Navy. In 1942 a Recognition School was established by the Navy at Ohio State University where the method of identification was developed. In 1943 the school was taken over by the US Navy. The importance of training in visual recognition of ships and aircraft became even more evident during World War II. Mistakes resulting in costly errors and loss of life led to an increased emphasis on recognition as a vital skill. Creator An entity primarily responsible for making the resource United States. Navy Source A related resource from which the described resource is derived <a href="https://gvsu.lyrasistechnology.org/repositories/2/resources/477">Naval recognition slides (RHC-50)</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 2017-04-04 Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/page/NoC-US/1.0/?language=en">No Copyright - United States</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 RHC-50 Coverage The spatial or temporal topic of the resource, the spatial applicability of the resource, or the jurisdiction under which the resource is relevant 1943-1953 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. Source <a href="http://gvsu.lyrasistechnology.org/repositories/2/resources/477">Naval recognition slides, RHC-50</a> Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Identifier An unambiguous reference to the resource within a given context RHC-50_1744 Title A name given to the resource M-2 class submarine Creator An entity primarily responsible for making the resource United States. Navy Description An account of the resource M-2 class Russian SS (submarine), April 1, 1953. Subject The topic of the resource United States. Navy Military education World War, 1939-1945 Slides Warships--Recognition Russia Language A language of the resource eng Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/page/NoC-US/1.0/?language=en">No Copyright - United States</a> Type The nature or genre of the resource Image Format The file format, physical medium, or dimensions of the resource image/jpeg Source A related resource from which the described resource is derived Naval recognition slides (RHC-50) Date A point or period of time associated with an event in the lifecycle of the resource 1953-04-01 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/7d0825da8e690239cf486520bb4b9fe6.jpg 131813c7528fd41a7d14286449fc8629 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 Naval Recognition Training Slides Subject The topic of the resource Slides Military education Airplanes, Military--Recognition Warships--Recognition World War, 1939-1945 Description An account of the resource Slides developed during World War II as a training tool, for top-side battle-station personnel on board ship and for all aircraft personnel, by the US Navy. In 1942 a Recognition School was established by the Navy at Ohio State University where the method of identification was developed. In 1943 the school was taken over by the US Navy. The importance of training in visual recognition of ships and aircraft became even more evident during World War II. Mistakes resulting in costly errors and loss of life led to an increased emphasis on recognition as a vital skill. Creator An entity primarily responsible for making the resource United States. Navy Source A related resource from which the described resource is derived <a href="https://gvsu.lyrasistechnology.org/repositories/2/resources/477">Naval recognition slides (RHC-50)</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 2017-04-04 Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/page/NoC-US/1.0/?language=en">No Copyright - United States</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 RHC-50 Coverage The spatial or temporal topic of the resource, the spatial applicability of the resource, or the jurisdiction under which the resource is relevant 1943-1953 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. Source <a href="http://gvsu.lyrasistechnology.org/repositories/2/resources/477">Naval recognition slides, RHC-50</a> Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Identifier An unambiguous reference to the resource within a given context RHC-50_1745 Title A name given to the resource M-4 class submarine Creator An entity primarily responsible for making the resource United States. Navy Description An account of the resource M-4 class Russian SS (submarine), April 1, 1953. Subject The topic of the resource United States. Navy Military education World War, 1939-1945 Slides Warships--Recognition Russia Language A language of the resource eng Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/page/NoC-US/1.0/?language=en">No Copyright - United States</a> Type The nature or genre of the resource Image Format The file format, physical medium, or dimensions of the resource image/jpeg Source A related resource from which the described resource is derived Naval recognition slides (RHC-50) Date A point or period of time associated with an event in the lifecycle of the resource 1953-04-01 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/1de78c28b1cf43bb5bc7a1f2c52c76e3.jpg 754076ae4ad8de8afde2e81a39552e90 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 Naval Recognition Training Slides Subject The topic of the resource Slides Military education Airplanes, Military--Recognition Warships--Recognition World War, 1939-1945 Description An account of the resource Slides developed during World War II as a training tool, for top-side battle-station personnel on board ship and for all aircraft personnel, by the US Navy. In 1942 a Recognition School was established by the Navy at Ohio State University where the method of identification was developed. In 1943 the school was taken over by the US Navy. The importance of training in visual recognition of ships and aircraft became even more evident during World War II. Mistakes resulting in costly errors and loss of life led to an increased emphasis on recognition as a vital skill. Creator An entity primarily responsible for making the resource United States. Navy Source A related resource from which the described resource is derived <a href="https://gvsu.lyrasistechnology.org/repositories/2/resources/477">Naval recognition slides (RHC-50)</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 2017-04-04 Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/page/NoC-US/1.0/?language=en">No Copyright - United States</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 RHC-50 Coverage The spatial or temporal topic of the resource, the spatial applicability of the resource, or the jurisdiction under which the resource is relevant 1943-1953 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. Source <a href="http://gvsu.lyrasistechnology.org/repositories/2/resources/477">Naval recognition slides, RHC-50</a> Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Identifier An unambiguous reference to the resource within a given context RHC-50_X1499 Title A name given to the resource M-51 class Swedish AMS (high speed minesweeper) Creator An entity primarily responsible for making the resource United States. Navy Description An account of the resource M-51 class Swedish AMS (high speed minesweeper), March 1, 1955. Subject The topic of the resource United States. Navy Military education World War, 1939-1945 Slides Warships--Recognition Sweden Language A language of the resource eng Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/page/NoC-US/1.0/?language=en">No Copyright - United States</a> Type The nature or genre of the resource Image Format The file format, physical medium, or dimensions of the resource image/jpeg Source A related resource from which the described resource is derived Naval recognition slides (RHC-50) Date A point or period of time associated with an event in the lifecycle of the resource 1955-03-01 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/8e6043abeb1c2eff06c45dd7d6c6e30f.jpg c72aa9b9d3898c3878d7c4b55c162c3e Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Grand Valley State University Photographs Subject The topic of the resource Aerial photographs Universities and colleges Michigan Grand Rapids (Mich.) Allendale (Mich.) Building Facilities Dormitories Students Events 1960s 1970s 1980s 1990s 2000s Description An account of the resource People, places, and events of Grand Valley State University from its founding in 1960 as a 4-year college in western Michigan. Creator An entity primarily responsible for making the resource News & Information Services. University Communications Source A related resource from which the described resource is derived <a href="https://gvsu.lyrasistechnology.org/repositories/2/resources/41">News &amp; Information Services. University Photographs. (GV012-01)</a> Publisher An entity responsible for making the resource available Grand Valley State University. University Libraries. Special Collections & University Archives. Date A point or period of time associated with an event in the lifecycle of the resource 2017-03-03 Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/page/InC-NC/1.0/?language=en">In Copyright - Non-Commercial Use Permitted</a> Format The file format, physical medium, or dimensions of the resource image/jpg Language A language of the resource eng Type The nature or genre of the resource image Identifier An unambiguous reference to the resource within a given context GV012-01 Coverage The spatial or temporal topic of the resource, the spatial applicability of the resource, or the jurisdiction under which the resource is relevant 1960s-2000s Still Image A static visual representation. Examples include paintings, drawings, graphic designs, plans and maps. Recommended best practice is to assign the type Text to images of textual materials. Local Subject Subject headings specific to a particular image collection 1960s Source <a href="https://gvsu.lyrasistechnology.org/repositories/2/resources/41">University photographs, GV012-01</a> Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Identifier An unambiguous reference to the resource within a given context GV012-01_UAPhotos_001152 Title A name given to the resource M.S. Keeler II and Edward J. Frey deposit donations to Grand Valley Description An account of the resource M.S. Keeler II (right), chair of $1,000,000 drive, deposits donations along with Edward J. Frey, finance chairman of the Board of Control. Subject The topic of the resource Grand Valley State University Michigan Allendale (Mich.) Universities and colleges College administrators Language A language of the resource eng Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/page/InC-NC/1.0/?language=en">In Copyright - Non-Commercial Use Permitted</a> Type The nature or genre of the resource Image Format The file format, physical medium, or dimensions of the resource image/jpeg Date A point or period of time associated with an event in the lifecycle of the resource 1961 Publisher An entity responsible for making the resource available Grand Valley State University. University Libraries. Lemmen Library and Archives black and white photo https://digitalcollections.library.gvsu.edu/files/original/a1fd3acc2c0a026690789f358fa7f20d.jpg 7aa9dc28de682b235d8ba729471fc9f8 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 Naval Recognition Training Slides Subject The topic of the resource Slides Military education Airplanes, Military--Recognition Warships--Recognition World War, 1939-1945 Description An account of the resource Slides developed during World War II as a training tool, for top-side battle-station personnel on board ship and for all aircraft personnel, by the US Navy. In 1942 a Recognition School was established by the Navy at Ohio State University where the method of identification was developed. In 1943 the school was taken over by the US Navy. The importance of training in visual recognition of ships and aircraft became even more evident during World War II. Mistakes resulting in costly errors and loss of life led to an increased emphasis on recognition as a vital skill. Creator An entity primarily responsible for making the resource United States. Navy Source A related resource from which the described resource is derived <a href="https://gvsu.lyrasistechnology.org/repositories/2/resources/477">Naval recognition slides (RHC-50)</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 2017-04-04 Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/page/NoC-US/1.0/?language=en">No Copyright - United States</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 RHC-50 Coverage The spatial or temporal topic of the resource, the spatial applicability of the resource, or the jurisdiction under which the resource is relevant 1943-1953 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. Source <a href="http://gvsu.lyrasistechnology.org/repositories/2/resources/477">Naval recognition slides, RHC-50</a> Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Identifier An unambiguous reference to the resource within a given context RHC-50_1778 Title A name given to the resource Maasz class destroyer Creator An entity primarily responsible for making the resource United States. Navy Description An account of the resource Maasz class (Type 34 ex-German), Russian DD (destroyer), October 1, 1947. Subject The topic of the resource United States. Navy Military education World War, 1939-1945 Slides Warships--Recognition Germany Russia Language A language of the resource eng Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/page/NoC-US/1.0/?language=en">No Copyright - United States</a> Type The nature or genre of the resource Image Format The file format, physical medium, or dimensions of the resource image/jpeg Source A related resource from which the described resource is derived Naval recognition slides (RHC-50) Date A point or period of time associated with an event in the lifecycle of the resource 1947-10-01 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/469d9b609c2eb56c068bc65b314bfef7.jpg bf0661332aa66fd7c7cbf556d252f9b0 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 Naval Recognition Training Slides Subject The topic of the resource Slides Military education Airplanes, Military--Recognition Warships--Recognition World War, 1939-1945 Description An account of the resource Slides developed during World War II as a training tool, for top-side battle-station personnel on board ship and for all aircraft personnel, by the US Navy. In 1942 a Recognition School was established by the Navy at Ohio State University where the method of identification was developed. In 1943 the school was taken over by the US Navy. The importance of training in visual recognition of ships and aircraft became even more evident during World War II. Mistakes resulting in costly errors and loss of life led to an increased emphasis on recognition as a vital skill. Creator An entity primarily responsible for making the resource United States. Navy Source A related resource from which the described resource is derived <a href="https://gvsu.lyrasistechnology.org/repositories/2/resources/477">Naval recognition slides (RHC-50)</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 2017-04-04 Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/page/NoC-US/1.0/?language=en">No Copyright - United States</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 RHC-50 Coverage The spatial or temporal topic of the resource, the spatial applicability of the resource, or the jurisdiction under which the resource is relevant 1943-1953 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. Source <a href="http://gvsu.lyrasistechnology.org/repositories/2/resources/477">Naval recognition slides, RHC-50</a> Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Identifier An unambiguous reference to the resource within a given context RHC-50_1779 Title A name given to the resource Maasz class destroyer Creator An entity primarily responsible for making the resource United States. Navy Description An account of the resource Maasz class (Type 34 ex-German), Russian DD (destroyer), October 1, 1947. Subject The topic of the resource United States. Navy Military education World War, 1939-1945 Slides Warships--Recognition Germany Russia Language A language of the resource eng Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/page/NoC-US/1.0/?language=en">No Copyright - United States</a> Type The nature or genre of the resource Image Format The file format, physical medium, or dimensions of the resource image/jpeg Source A related resource from which the described resource is derived Naval recognition slides (RHC-50) Date A point or period of time associated with an event in the lifecycle of the resource 1947-10-01 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/ed69e28efa630a4942bc30434adbfbbe.mp4 47eb9d8f260a889e0b2ad249a32e5da8 https://digitalcollections.library.gvsu.edu/files/original/91490fbb012f28505933f9f795b7b7a7.pdf d14a7179843429f38cce32b104649a22 PDF Text Text Grand Valley State University Veterans History Project Interview    Ken Maatman (1:20:27) • • • • • (3:30:00) Grand Rapids Michigan April 24 1920 Graduated from Grand Rapids Central Worked for Western Electric Company for one year after graduation Went to Grand Rapids Junior College till Pearl Harbor was announced (4:29:00)Enlists in the Army by January 29 1942 • • • Western Electric Company Installed equipment in Bell Telephone offices- Holland and Grand Haven area Crew of 5 guys Installed all of the wiring in the office to hook up equipment • • (5:19:00)Enlists in the Army 21 years old Outrage at the attack on Pearl Harbor-immediately wanted to be a part of events Went to United States Army Recruiting office –Grand Rapids Post Office Working for the phone company automatically went him and others who worked for the phone company to the signal core Reported to Fort Custer within a week Father felt it was a good idea, Mother did not think the same • • • • • • (8:03:00) Fort Custer The guys are separated by what was on the paper work Acres of barracks and men walking around as Ken gets off the bus Reported to Barracks-spent 3 months in basic training Received uniform upon arrival-was not custom fit (10:38:00)Began day at 5:30 a.m. for role call Calisthenics, breakfast, and then basic training • • • (12:49:00)Camp Crowder, Missouri New post specializing in Signal Core The Camp was not finished-part of their job was clean-up construction mess Classroom settings become part of their routine to learn Signal Corps • • • • �• Selected to go to Fort Monmouth New Jersey • (16:15:00)Fort Monmouth New Jersey Learned all aspects of Signal Corps Climbing telephone poles, laying wires etc. Ken enjoyed doing this job and felt he wanted to do something that benefited the military and the goal they had in the war Trained here for about 3 months • (17:35:00)191st Signal Corps Came from all different posts around the country • • • • (19:00:00)Joined 82nd Infantry division-Camp McCain-Mississippi Tar paper shacks Trained for role while working with infantry-approximately 3-4 months Ken wanted to apply for OCS-felt he wasn’t doing enough for his country This gave him the rank of 2nd Lieutenant upon graduation • • • • • (21:28:00)Fort Monmouth New Jersey OCS training Advanced basics and leadership role Became officer giving orders to recruits Continuously exchanged letters with family members Graduated as officer-no formal ceremony but did receive a certificate • (24:25:00)Back to the 82nd Infantry division-Officer Ken wanted to do more-applied for the Army/Air Core-accepted • • • • • (25:09:00)Sent to basic training Maxwell Field Alabama Stayed for primary training-PT17’s-3 months Became Pilot-wanted to fly Mitchell Bomber Advance training-single wing model plane Started learning maneuvers Ken developed Vertigo-released back to the Signal Corps • • (27:15:00)Fort Jackson-Signal Core-191st –South Carolina Received overseas assignment-didn’t know where though Needed China, Burma, India specialist • • • �• • • • • • • • • • • • • • • • • • • • • • • • • Constant state of flux on base-hard to establish relationship at this point with the guys Officers attended briefings, discussed men to be transferred, calisthenics, drills, and weapon training Ken was pulled out of the company to go to Wilmington California to accompany signal equipment and training equipment to Calcutta India (32:10:00)Wilmington California Waited around for 3 months-checked in daily waiting for ship to come in Norwegian freighter contracted to take Signal companies equipment escorted by one officer for each division On water 53 days before arriving in Calcutta India Traveled alone at sea doing a zigzag course Total of 7 officers from the Signal Corps aboard ship Meanwhile 191st infantry being mobilized to meet equipment in India The men had no idea what to expect in India Ken had never been out of the country before Ken noticed the people were very different in India that unloaded the ship-they were very small and dark skinned people (37:50:00)The guys went off ship looking for a place to stay and there was a mass amount of people-they didn’t think they would ever find a place to stay so they returned to the ship (38:32:00)Ledo India Equipment had to go by train or convoy 700-800 miles north from Calcutta to Ledo Headquarters for the supplies 191st infantry came to Ledo nearly 2 months ahead of Ken Companies separated according to specialties on stations all across the new Burma road They were installing pipe lines and communications down the Burma road also There were battles going on in Southern Burma (42:00:00)Burma was a jungle-nearly 150 ft deep Jungle carried mites that would give you lethal amounts of Scrub Typhus Mosquitoes carried Malaria Cholera, Dysentery, infections from leeches you couldn’t remove from your body 6,900 were killed in old campaign of China Burma India and the same were taken out for illness (45:00:00)Groups of men deployed to various locations to service communication devices �• • • • • • • • • • • • • • • • • 1,000 officers and 700,000 [ed. note—these numbers are much too high] Signal Corps men were headquartered here Some men were stationed in jungles where the Anoka head hunters were located along the India Burma borders Quartermasters and engineers would send messages telling them where they needed devices set up Had advantage on knowing what was going on with the war because they would monitor and record communications going over wire (48:40:00)Aircraft warning personal wandered into Naga area. They were greeted by Naga men with spears and were put up for the night with a guard to stay with them. They had bomb fire ceremonies and the men thought they were hostile toward them. Turns out that they were fighting off bad spirits from the aircraft personnel to protect them. Recorded message said that ‘the Nagas had gone to a village about 5 or 6 miles from them and wiped out a village of 100 people. The Nagas came back with 30 heads. We have pictures to prove it. Please send grenades back on next drop. We may need them’ The men were installing, repairing, replacement equipment (51:50:00)The officers traveled down the Burma road supervising the men and the progress Kun Ming-brought supplies to here-ended up flying over hump to Kunming, China Traveling on the Burma Road-the road was carved out of the mountains or thru the jungles. It was like riding on a shelf with total drops on the side. Many trucks fell off road and couldn’t be recovered. At times the rain would wash out parts of the roads and would have to wait for days for the engineers to clear it. (54:00:00) Monsoon season from May to October 110-150 inches of rainfall in this time Aircraft that flew over didn’t have doors on the plane and passengers would have to hold onto a rope to move around on the plane The ‘hump’ was the Himalaya Mountains-change in weather made this area dangerous Ken was in an instant hail storm-Pilot circled and climbed in one location until over the hail storm (57:00:00) Ken was responsible for Burma road leading from Burma to Ledo and turning into Kunming China for communication equipment 191st Infantry had no combat losses Had one C47 that went down-courier on board-sent out rescue party that failed to reach him into the jungle 2 men on other plane crashed over same area the first went down and they were also never heard from again �• • • • • • • • • • • • • • • • • • (100:38:00) They had the sense they were winning the war The Great Retreat out of Burma-British and Americans were badly defeated [referring to earlier events] Points determined who would be going home first-from one month to five months (103:35:00) VE [VJ?] Day-they had picked it up thru the radio-Ken and the men were happy that the war was over (1:04:20:00)Calcutta India Big cities were strange in India-many people living on the streets People in villages were more friendly-lived in shacks City people were disease ridden, deformed, many beggars Made baseball diamond and volleyball court while they were in India At the end of war they had little to do. Much of the equipment was dumped or given to the Chinese. Gave them plenty of time for recreation. (1:07:13:00) Two men made movie-8mm tape-recorded events while the 191st Infantry was overseas and brought it home-transferred it to video tape-Casper Fabragal and James Baskerville, both New Yorkers made the film-still show the film at reunions (1:10:45:00)Heading home Brought into staging area for 1 to 2 weeks waiting for your ship Ken’s ship went to Fort Lewis Seattle-troop ship-took 32 days-the ship was full (1:13:55:00) There were docks loaded with people waiting to greet the men on the ship. The men were very proud of their accomplishments. Fort Lewis-staging area before going to Camp McCoy Wisconsin Discharge process involved going back through your records and checking to see what illnesses you had while you were in the service Ken can still not give blood because he had a touch of Malaria while he was overseas (1:15:25:00) Parents met Ken at Grand Rapids train station-very pleased to have him home Two other brothers of Ken’s were also in service-all came home alive *Ken is very proud of the opportunity to accomplish the tasks that are put on officers in the military at this time. He is very proud of the opportunity to do something that big. The memories of things that he seen, with cruelties and discomforts, had great �affect on individuals. Feels the work he did had big effect on the work he did after he was out of the military. *(1:19:00) Ken shares that when he was in Kohima, there are cemeteries’ where American Soldiers are buried and he found a sign on one of the crosses where a soldier was buried. “When you go home, tell them of us. For your tomorrow, we gave our today.” �. The United States Military Awards of 1st Lt Kenneth B. Maatman for service with (he United States Army Pacific Theater, World War II and U.S. Army Reserves Bronze Star Medal Service: All Services Instituted: 1944 .' Criteria: Awarded for heroicor meritorious achievement or service. Army Good Conduct Medal Service: Army Instituted: 1941 Criteria: Exemplary conduct, efficiency and fidelity during threeyears of enlisted service. American Campaign Medal Service: All Services Instituted: 1942 Criteria: Service during 1941-46 withinthe American Theater. '" Asiatic-Pacific Campaign Medal Service: All Services Instituted: 1942 Criteria: Awarded for service in the Asiatic-Pacific Theater during 1941-46. World War II Victory Medal Service: All Services Instituted: 1945. Criteria: Awarded for service in the U.S. Armed Forces, 1941-1946. China War Memorial Medal Country: Republic of China Instituted: 1945 Criteria: Awarded to personnel who served in the ChinaTheater, 1939 - 1945. Combat Service Commemorative Service Medal Honors military personnel who servedin an overseas combat theater. ". Asiatic Pacific Victory Commemorative Medal <Victory over Japan) Honors military personnel who served in the Pacific Theaterduring WorId War Il. World War IT Victory Commemorative Medal Honors service in the U.s. Armed Forces during World WarIl. Overseas Service Commemorative Medal Honors service in an overseas theater or expeditionary operation. u.S. Army Commemorative Medal Honors honorable service in the U.S. Armybetween 1775 and 2000. National Guard and Reserve Commemorative Medal Honors service in the U.s. National Guardand Reserves over the past 200 years. �,;.... ,. I ". ~ . 'I' Pi'."" ;.~: ~ -, ·r ~, .c".>;··", " ~/ ",:.~I: ~J . :Ir.'- ', .. ~ . ' ~')"""":' ..r:,·'.\.['~.{:;0·."". . tJJ:~'" ___ . . _ .... \ .-;« ~ rJ\::tj .'.~ . ....,.. . - ~._ '... ...... __.-.. ~ .'-------,. .'l-<\~.:l' , .... .:'\....I'--J ..·.·,_.j--.~~ .. ~ .. -,:/: ,,~ .... ~., ;"'",,.-.JJiit.. - ...'-. -._1 :-. . ~ Phyllis Koning 1/ L7 ( tJ V ?k ~1 y- .?1b==-.:...:;tA...=----._- _ -~chM.~F= ~~ Z-- CL~~~_M-~_.tl'0-~ _~ iJd~~#t~~ __ ~ -~~_.~--~~­ _J_~1--C_~~ .. /f~C;U~­ ~~--~ --._­ ___ Lrj.L~ ~ Z2. ~:t~ ~_ ~A~s!fe,_, _t..._'!=~;=­ ~.u_~w_~~+­ -~!=-f-L-Ic~J-#a...~~ ~ .~~~~/lL~ --~~~~~ -~i ~ awuLIa.LLi ;1 ilL The Games of the XXVIII Olympiad Athens • 13-29 August 2004 DS311 /6 t-/ ca» - (;).e ~ ()A.e.. ~~~ ~,~, --£Y ~ ~ ~M ~ 7t r 4J: ~ fcJ...f)" ~ r~ /lA.L- ~ ~ ~p~~~~ ~~~-~ l~ ~~~/~F . . ~••. L \ . ~ ,'J I~ ~~ ~­ , .. ~~ ~ , �Velma R. Maatman 1358 W. Thornberry ~t., SE Grand Rapids, Michigan 49546 August 20, 2004 Mr. Michael Lloyd, Editor The Grand Rapids Press 155 Michigan, NW Grand Rapids, Michigan 49503 Dear Mr. Lloyd: My husband and I think the enclosed article from The Modesto Bee newspaper in Modesto, California, shoUld appear in The Grand Rapids Press. I hope you agree. Col. Koning's article appeared in The Modesto Bee newspaper July 25, 2004. This is an account-oI what the United States is doing in Iraq to rebuild services for the Iraqi people. Terrorism is only one part of what is going on in Iraq. Col. Koning returned from Iraq July 1st after a six month tour of duty as Commander of the Southern Engineer District where he was engaged in the reconstruction of civil services. He had 4,000 Iraqis working for him. Colonel Thomas L. Koning was born in Royal Oak, Michigan, graduated from the West Point Academy, and now resides in Concord, Massachusetts, with his wife and two children 'where he is the commander of the New England Engineer District outside of Boston. His parents, William and Phyllis Koning, were born and raised in Grand Rapids and lived here until after graduating from ~he University of Michigan. They now reside in Modesto, Cali­ fornia. Col. Koning's grandfather, Gillis Vandenberg, worked for. The Grand Rapids Press over 40 years. Please give this article your attention. Thank you. For more information you may contact: Judy Sly, editor of Opinions Page The Modesto Bee Modesto, CalTIOrnia Phone: 209 578-2317 E-Mail: jsly@modbee.com Sincerely, o~~ It? ~"'---' Velma Maatman (Mrs~ Kenneth) � Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Veterans History Project Creator An entity primarily responsible for making the resource Grand Valley State University. History Department Description An account of the resource The Library of Congress established the Veterans History Project in 2001 to collect memories, accounts, and documents of U.S. war veterans from World War II and the Korean War, Vietnam War, and conflicts in the Middle East and elsewhere, and to preserve these stories for future generations. The GVSU History Department interviews are part of this work-in-progress, and may contain videos and audio recordings, transcripts and interview outlines, and related documents and photographs. Coverage The spatial or temporal topic of the resource, the spatial applicability of the resource, or the jurisdiction under which the resource is relevant 1914- Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/page/InC/1.0/?language=en">In Copyright</a> Subject The topic of the resource Afghan War, 2001--Personal narratives, American Iran Hostage Crisis, 1979-1981--Personal narratives, American Korean War, 1950-1953--Personal narratives, American Michigan--History, Military Oral history Persian Gulf War, 1991--Personal narratives, American United States--History, Military United States. Air Force United States. Army United States. Navy Veterans Video recordings Vietnam War, 1961-1975--Personal narratives, American World War, 1939-1945--Personal narratives, American Publisher An entity responsible for making the resource available Grand Valley State University. University Libraries. Special Collections & University Archives Contributor An entity responsible for making contributions to the resource Smither, James Boring, Frank Relation A related resource Veterans History Project (U.S.) Identifier An unambiguous reference to the resource within a given context RHC-27 Language A language of the resource eng Source A related resource from which the described resource is derived <a href="https://gvsu.lyrasistechnology.org/repositories/2/resources/455">Veterans History Project interviews (RHC-27)</a> Oral History A resource containing historical information obtained in interviews with persons having firsthand knowledge. Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Identifier An unambiguous reference to the resource within a given context MaatmanK Title A name given to the resource Maatman, Kenneth (Interview outline, video, and papers), 2004 Creator An entity primarily responsible for making the resource Maatman, Kenneth Description An account of the resource Ken Maatman was an Officer in the Army Signal Corps during World War II. He supervised the installation and maintenance of communications lines in the China/Burma/India theater, particularly along the Burma Road in the last two years of the war. Letters and military documents appended to outline. Contributor An entity responsible for making contributions to the resource Boring, Frank (Interviewer) Subject The topic of the resource Oral history Veterans History Project (U.S.) Video recordings United States--History, Military Michigan--History, Military Veterans United States. Army World War, 1939-1945--Personal narratives, American Language A language of the resource eng Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/page/InC/1.0/?language=en">In Copyright</a> Type The nature or genre of the resource Moving Image Text Relation A related resource Veterans History Project (U.S.) Date A point or period of time associated with an event in the lifecycle of the resource 2004-09-09 Source A related resource from which the described resource is derived <a href="https://gvsu.lyrasistechnology.org/repositories/2/resources/455">Veterans History Project Collection, (RHC-27)</a> Format The file format, physical medium, or dimensions of the resource application/pdf video/mp4 Publisher An entity responsible for making the resource available Grand Valley State University. University Libraries. Lemmen Library and Archives https://digitalcollections.library.gvsu.edu/files/original/22964a83918c4f5aec20957932c65708.jpg 5c0cc2f379bc45da112060a34334ac49 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 Faces of Grand Valley Creator An entity primarily responsible for making the resource Grand Valley State University Contributor An entity responsible for making contributions to the resource University Communications Description An account of the resource A non-comprehensive collection of photographs of Grand Valley faculty, staff, administrators, board members, friends, and alumni. Photos collected by University Communications for use in promotion and information sharing about Grand Valley with the wider community. Date A point or period of time associated with an event in the lifecycle of the resource 1960s - 1990s Source A related resource from which the described resource is derived GV012-03. University Communications. Vita Files Rights Information about rights held in and over the resource In Copryight Subject The topic of the resource Grand Valley State University College administrators College teachers Colleges and universities -- Faculty Michigan Publisher An entity responsible for making the resource available Grand Valley State University. Special Collections and University Archives Identifier An unambiguous reference to the resource within a given context GV012-03 Format The file format, physical medium, or dimensions of the resource image/jpeg Type The nature or genre of the resource Image 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 MabundaDavid Creator An entity primarily responsible for making the resource Grand Valley State University. University Communications Title A name given to the resource Mabunda, David Description An account of the resource David Mabunda, Director of Model Cities Higher Education Facilities Subject The topic of the resource Grand Valley State University – History College teachers Universities and colleges – Faculty Michigan Source A related resource from which the described resource is derived University Communications. Vita Files, 1968-2016 (GV012-03) Publisher An entity responsible for making the resource available Grand Valley State University. Special Collections and University Archives Rights Information about rights held in and over the resource In Copyright Type The nature or genre of the resource Image Format The file format, physical medium, or dimensions of the resource image/jpeg Language A language of the resource eng https://digitalcollections.library.gvsu.edu/files/original/7b05543dd921eaeeab2e0a1d3dd1ce29.jpg a53a74c48a08e23fe4d0faf58d9b5f44 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 Robert H. Merrill photographs Creator An entity primarily responsible for making the resource Merrill, Robert H., 1881-1955 Date A point or period of time associated with an event in the lifecycle of the resource 1909/1950 Source A related resource from which the described resource is derived Robert H. Merrill papers (RHC-222) Rights Information about rights held in and over the resource In Copyright Identifier An unambiguous reference to the resource within a given context RHC-222 Description An account of the resource Photographs, negatives, and lantern slides digitized from the papers of engineer and archaeologist Robert H. Merrill. A Grand Rapids native, Merrill held an accomplished career as a civil engineer. He founded the company Spooner & Merrill, which held offices in Grand Rapids and Chicago. From 1919-1921, Merrill lived in China, working as Assistant Principal Engineer on a reconstruction of the Grand Canal - the oldest and longest canal system in the world. Merrill became fascinated by archaeology, and among other projects, he traveled to the Uxmal Pyramids in Yucatan, Mexico, with a research expedition from Tulane University. Merrill's photo collection includes images of his travels and projects, friends and family. 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 Merrill_1931-9_002 Date A point or period of time associated with an event in the lifecycle of the resource circa 1931 Title A name given to the resource Macatawa Bay Description An account of the resource Macatawa site of Grand Ave & Illinois Ave. Phoenix cottage looking northwest. Two houses are visible on top of a hill in right side of the frame. Subject The topic of the resource Macatawa, Lake (Mich.) Beaches Source A related resource from which the described resource is derived Robert H. Merrill papers (RHC-222) Rights Information about rights held in and over the resource In Copyright Type The nature or genre of the resource Image Format The file format, physical medium, or dimensions of the resource image/jpg Language A language of the resource eng Creator An entity primarily responsible for making the resource Merrill, Robert H., 1881-1955 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/f8b06d5d7dacb0bd89e9402007251fae.jpg b6e94a22693a2093e26011aab9ad8073 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 Robert H. Merrill photographs Creator An entity primarily responsible for making the resource Merrill, Robert H., 1881-1955 Date A point or period of time associated with an event in the lifecycle of the resource 1909/1950 Source A related resource from which the described resource is derived Robert H. Merrill papers (RHC-222) Rights Information about rights held in and over the resource In Copyright Identifier An unambiguous reference to the resource within a given context RHC-222 Description An account of the resource Photographs, negatives, and lantern slides digitized from the papers of engineer and archaeologist Robert H. Merrill. A Grand Rapids native, Merrill held an accomplished career as a civil engineer. He founded the company Spooner & Merrill, which held offices in Grand Rapids and Chicago. From 1919-1921, Merrill lived in China, working as Assistant Principal Engineer on a reconstruction of the Grand Canal - the oldest and longest canal system in the world. Merrill became fascinated by archaeology, and among other projects, he traveled to the Uxmal Pyramids in Yucatan, Mexico, with a research expedition from Tulane University. Merrill's photo collection includes images of his travels and projects, friends and family. 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 Merrill_1931-9_003 Date A point or period of time associated with an event in the lifecycle of the resource circa 1931 Title A name given to the resource Macatawa Bay Description An account of the resource Lake front looking north from Grand Ave at water edge Subject The topic of the resource Macatawa, Lake (Mich.) Beaches Source A related resource from which the described resource is derived Robert H. Merrill papers (RHC-222) Rights Information about rights held in and over the resource In Copyright Type The nature or genre of the resource Image Format The file format, physical medium, or dimensions of the resource image/jpg Language A language of the resource eng Creator An entity primarily responsible for making the resource Merrill, Robert H., 1881-1955 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/50ba05a6bca5840387de6e252e73bf09.jpg 0946f7d46b51b1a18a65aa9ed95ba96b 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 Robert H. Merrill photographs Creator An entity primarily responsible for making the resource Merrill, Robert H., 1881-1955 Date A point or period of time associated with an event in the lifecycle of the resource 1909/1950 Source A related resource from which the described resource is derived Robert H. Merrill papers (RHC-222) Rights Information about rights held in and over the resource In Copyright Identifier An unambiguous reference to the resource within a given context RHC-222 Description An account of the resource Photographs, negatives, and lantern slides digitized from the papers of engineer and archaeologist Robert H. Merrill. A Grand Rapids native, Merrill held an accomplished career as a civil engineer. He founded the company Spooner & Merrill, which held offices in Grand Rapids and Chicago. From 1919-1921, Merrill lived in China, working as Assistant Principal Engineer on a reconstruction of the Grand Canal - the oldest and longest canal system in the world. Merrill became fascinated by archaeology, and among other projects, he traveled to the Uxmal Pyramids in Yucatan, Mexico, with a research expedition from Tulane University. Merrill's photo collection includes images of his travels and projects, friends and family. 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 Merrill_1931-9_004 Date A point or period of time associated with an event in the lifecycle of the resource circa 1931 Title A name given to the resource Macatawa Bay Description An account of the resource Lake front from north end of lake-front lots Subject The topic of the resource Macatawa, Lake (Mich.) Beaches Source A related resource from which the described resource is derived Robert H. Merrill papers (RHC-222) Rights Information about rights held in and over the resource In Copyright Type The nature or genre of the resource Image Format The file format, physical medium, or dimensions of the resource image/jpg Language A language of the resource eng Creator An entity primarily responsible for making the resource Merrill, Robert H., 1881-1955 Publisher An entity responsible for making the resource available Grand Valley State University. University Libraries. Lemmen Library and Archives