The tannery site began leather tanning operations in 1908 but didn’t use the Scotchgard products for waterproofing there until the late 1950s and early ’60s. Photo by Michael Buck
A new report presented to the public last week paints a bleak picture of the pollution spreading from Wolverine Worldwide’s former leather tannery site.
Under an administrative order by the U.S. Environmental Protection Agency, the Rockford-based maker of footwear and apparel in 2018 commissioned Grand Rapids-based Rose & Westra, a division of GZA GeoEnvironmental, to test soil, sediment and groundwater samples for pollutants on the grounds of the former tannery.
The site, at 123 N. Main St. NE, had been used for the past several years as a public green space.
On Jan. 11, R&W published a 373-page summary report on the testing results, which is available via Wolverine at bit.ly/tanneryreport and will be posted at epa.gov.
R&W was present to share its findings March 26 at a Rockford High School open house preceding a town hall meeting hosted by the EPA and the Michigan Department of Environmental Quality (MDEQ), which have been partnering to test affected areas for contaminants since 2017.
The testing areas are at the former tannery; the House Street Disposal Area at 1855 House St. NE and surrounding properties in Belmont/Plainfield Township; and the Wolven-Jewell Source Area north of 10 Mile Road in Algoma Township, which Wolverine never owned and has not acknowledged being one of its historic waste disposal sites.
Together, the three areas encompass about 20 square miles. A large plume of contamination is centered in the House Street area. It runs 200 feet deep and ultimately discharges into the Rogue River.
A report on the House Street Disposal Area has been submitted and is under review by the EPA. The Wolven-Jewell Source Area was not covered by the EPA’s administrative order, as it still is being investigated.
According to the summary report focusing on the tannery, Wolverine established the 123 N. Main campus in the 1890s and began leather tanning operations there around 1908.
Tanning involved the use of chemicals such as lime, sodium hydrosulfide, chromium and various oils and solvents.
The manufacturer began using 3M’s Scotchgard water-borne product to waterproof its leather shoes in the late 1950s and early ’60s. The formula at that time contained high levels of per- and polyfluoroalkyl substances (PFAS).
Wolverine built a wastewater treatment plant at the tannery campus between 1950 and 1960.
In 2000, 3M phased out the PFAS-containing formula and switched to a new recipe. The company has said it allegedly informed Wolverine of the change and the dangers of PFAS.
Wolverine ceased tanning operations at 123 N. Main in 2009. All buildings except the shoe factory — which now is a retail store — were decommissioned and demolished in 2010 and 2011.
At the request of a local group at that time — Concerned Citizens for Responsible Remediation, led by Mike McIntosh and Lynn McIntosh — the EPA assessed the area for volatile and semi-volatile organic compounds (VOCs and SVOCs), inorganic compounds and heavy metals. The EPA said it found the tests were “within” acceptable levels and turned the site over to the DEQ to manage in 2012, according to documents posted at epa.gov/mi.
In 2017, heightened awareness over PFAS in the state by concerned citizens persuaded the EPA to step back in and assist the DEQ with testing, according to Jeff Kimble, EPA on-scene coordinator. Soon after, it issued the unilateral order requiring Wolverine to test the House Street and tannery properties.
The EPA order required testing of an array of metals and hazardous substances but did not include PFAS, as the federal government does not have an enforceable cleanup standard for it, according to the R&W report.
R&W, under the direction of Wolverine and the DEQ, included PFAS testing in the work order anyway, using the state’s standard of 70 parts per trillion (ppt), as PFAS “appears to have a tendency to travel in historic stream channels” and spread through groundwater, according to a joint document issued by the EPA and DEQ and presented at the town hall.
According to that seven-page document, available at epa.gov/mi, the PFAS impacts from the former tannery “are highest on-site” but also have discharged west into the Rogue River, and contamination concentrations in groundwater wells at the tannery have been found to be anywhere from nondetect to 450,000 ppt.
The R&W full-length report found large deposits of soil containing perfluorooctanesulfonic acid (PFOS) abutting two banks of the Rogue River at the tannery site; concentrations of PFOS in groundwater increasing from north to south of the site in monitoring wells, with the highest concentrations on the southern half of the parcel; PFOS contamination throughout surface water near Rum Creek and Rogue River; and PFOS in shallow sediment samples.
In all, testing revealed approximately 494 samples exceeding the cleanup criteria for PFAS.
Testing for non-PFAS substances revealed high soil concentrations of SVOCs, chromium, arsenic, lead, mercury, chloride, cyanide and ammonia.
Besides PFAS, testing of the groundwater uncovered vinyl chloride that exceeded the residential drinking water criteria and high levels of lead, arsenic, chromium, chloride and cyanide.
Surface water testing results showed the presence of VOCs and SVOCs; metals and chemicals testing below regulatory criteria levels, and 11 samples of surface water exceeding the PFAS limit.
Sediment profiling revealed 167 samples of SVOCs above screening values; 173 metal samples above the limit, including vanadium, mercury, chromium and arsenic; and 12 samples of cyanide exceeding the limit in seven locations.
According to the DEQ/EPA joint report, the groundwater plume’s boundaries are not fully known, but the center is at the House Street site and migrates outward.
“Groundwater concentrations range from 60 to 71,000 ppt at the core of the plume. The center of this 50- to 60-year-old groundwater PFAS plume is stable. Experts are defining its boundaries by installing long-term monitoring wells at various depths,” the document said.
According to previous Business Journal reports, Wolverine is at the center of litigation on many fronts.
A class action lawsuit was filed in December 2017 by a group of national law firms against Wolverine on behalf of residents; trial begins March 2020. Grand Rapids-based Varnum is representing various plaintiffs in the suit.
The MDEQ and Plainfield and Algoma townships are suing Wolverine under the federal Resource Conservation and Recovery Act and Part 201 of the state’s National Resources and Environmental Protection Act. MDEQ is seeking to recover costs associated with the contamination, while the townships are asking Wolverine to extend municipal drinking water to the affected areas, according to court documents.
Meanwhile, Wolverine is suing 3M for allegedly “concealing information” about the toxic nature of the 1960s-era Scotchgard chemical, with the goal of getting 3M to participate in remediation efforts, according to Wolverine in mid-December.
In late December, the judge denied Wolverine’s and 3M’s motions to dismiss the lawsuits filed against them, according to a post on the “Varnum PFAS Contamination Updates” Facebook page.
Wolverine said it “defers to regulators and health officials” on the subject of whether residents and employees near the tannery are in any imminent danger from contamination, citing Kimble's remarks at the town hall.
Kimble told the audience there isn’t “that level of contamination that’s an emergency at or near the surface where people can contact it, where it’s going to be an immediate risk,” but the EPA still is conducting an ecological risk assessment about what other risks might exist that would need to be addressed in 2019.
Wolverine added the R&W summary report showed that in the vicinity of the Wolverine retail store on the former tannery site, where people work and shop, soil vapor intrusion testing values did not exceed screening levels.
“Any substances found above screening levels in soil and groundwater are not in areas where people are exposed (i.e., soil levels are below the surface and nobody is drinking the groundwater),” the statement said.
Wolverine remediation efforts
In addition to abiding by the administrative order to sample and test the affected areas, as well as its ongoing provision of whole-house filtration systems for residential drinking water, Wolverine pledged in a March 25 blog post it will remove polluted soils, install protective matting at the public kayak launch area on the Rogue River, topping it with gravel; put up a fence between the river and the White Pine Trail near Rum Creek so people cannot access the contaminated area; and continue testing for lead and chromium and “excavate those materials where necessary.”
The former “green space” at the tannery site already is enclosed by fencing.
Wolverine also said a filtration system is in the works to intercept and treat groundwater from the former tannery before it reaches the Rogue River.
An interim version of the system is currently being installed, said Karen Vorce, an MDEQ project manager and environmental quality analyst in Grand Rapids.
The DEQ tested the foam on the Rogue River last summer, and PFOS concentrations were found to be at 270,000 ppt, Vorce said.
Residents, elected officials, state, federal and local representatives and the media packed the Rockford High School auditorium for the town hall March 26.
After a two-hour presentation by three representatives of the MDEQ and two from the EPA, residents were given 40 minutes to ask questions of the panel.
One attendee asked whether the MDEQ will test the water south of Rockford.
“We are going to be doing further testing toward the Grand River,” Vorce said. “That’s planned for the spring and summer. We also have going on a fish study that the Water Resources Division of DEQ has done close to the Grand River, and so those results we’re hoping to get in the spring and then have a report that we can then share based on that.”
Many of the residents came to the microphone to be heard rather than to ask questions. A father said he was concerned about the safety of his children’s school 1 mile from the tannery.
An MDEQ official responded the water at the school is municipal, and it has been tested and found safe.
Another participant said he believes the residents’ best hope lies with the outcome of the class action suit against Wolverine.
“We’ve already diagnosed the problem,” he said. “It’s a serious problem. We’re not going to spend 10 years with the Superfund cleanup. We’re not going to drill new wells. The only answer is the municipal water supply.”
Several participants shared personal testimonials about health diagnoses, including Hodgkin’s lymphoma, fibroids, breast cancer and other tumors.
The MDEQ encouraged those residents to respond to letters they got in the mail asking them to join the North Kent County PFAS Exposure Assessment, which the Michigan Department of Health and Human Services and Kent County Health Department are conducting to help provide residents with information about their risk.
Community Advisory Groups
Diane Russell, EPA community involvement coordinator, was on hand to let residents know the EPA is helping residents form an independent Community Advisory Group (CAG) that will help stakeholders’ voices be heard. It will be a central touchpoint for all PFAS- and other contamination-related updates and information, she said.
CAGs are active in other Michigan Superfund sites such as the Tittabawassee River area near the Dow Chemical plant, the Pine River/Velsicol Chemical site in St. Louis and the Allied Paper/Kalamazoo River site.
Those interested in applying to join can email firstname.lastname@example.org or call (989) 395-3493.