crmonomey or mums 1236mm HELIM Room Luann. AREA Never contents DIR after his '71- Saginaw Hews sto dog went into: thepondendallthehairmeoffhim. on health problems in Rockwell area. Midland Co. Real Dept. (man) fails to conduct health assessment. 07/ ?/80 - Linda Earns. sres resident! writes state officials I 9.1 12/09/82 - about concerns over toxic has dump and area ??x?msecgm fails to em health assessment. Earns tee lne Walker requesting area health assessment. was fails to react to area pleas for help in spite of this must st local: press conference. 12/16/82 -- Dr. Bailns Walker responds to L. terns 12/09/82 letter: 03/25/83 - Andrea K. Iileon. Director 04/25/83 - Rockwell meet 55? 40-33 06/ /83 - Rockwell detected. 07/12/83 07/20/83 08/25/83 08/26/83 08/29/83 "In addition. we have begin to check into each of the health problems or deaths listed in your The initial. evaluation will probst he in the fem of a door?to?door my to be con?icted in early MCHD unresponsive. of the Enviromental Congress of Mid-Michigan writes J. Hesse (mm) a G. Guenther (MDNR) documenting evidence in support of sump and surface water analysis in area. BIRD unresponsive. - at Dow. med by toxic Substance Control Commie on. Those present: Veurink, Ulrich, Ilgenfritz (Doe): en, Disk Jacob. Holcomb (T800): Lahti, Oudhier )3 Janicssk (RIDER): Wilson, Hebert. Castellanos (ROM). door-tawdoor health assessment presented in map torn. ICED wanted mom's information. has failed to collect information to verify Romain manual for area health I no get ve names I cm W. . leaking. ?Wash bNR-samph\g. MDNR sampling, sconm present MDNR resampling ECOMM receives test results. positive for variety of contaminants. ICED also sent copy. 1). Robert cells J. Bedford (DEB) for month-nation of results. Hebert calls Kerns with results. Hebert calls Hesse. Weds (IDPH) requests risk assessment: information a: meets they all terns to explain results. IDPE cells terns. Hebert calls ll. Clark (EPA) requesting Rockwell be sorted into dioxin study because contaminants fond in. swap and cruises water could contain dioxins. Clark W. called mm to be in the following?ondsy to simple. J. DeKinnis (HA) calls Robert. Sampling Muld be done, one: new new +0 Page 2 08/30/83 - Hebert cells In for area residents. smut: (mm) eaid. not 111.. would meet with - ?other 022101313. to contact reeideqte 09/01/83 09/06/83 09/07/83 09/09/83 09/12/83 09/13/83 09/16/83 09/17/83 09/22/83 - ?atten meeting with relulte at teeting. to 09/05/83 - a.ch contecte with mm. to 09 22/83 -- mm Hebert guit- vith n. Division Chief .- 5316 me in; sod idea. A. Winona-ken tennl request for meeting in writing to Guenthet. m. A. Wilson receive- yhane cell tron D. Somltz saying meeting mum muted. Schultm naked. EGOMM to make I. neon aaeed. Hebert makes malignant" Keene to get lepleton School for mumm?rimi? ease Janitor must be paid overgirm. now me to up mm not sure. Hebert arranges for mu rip. Ball. Sept. 22, 1983, 7:00. Hebert talk. to emu. to distribute flyere in are: ammo heating Oyen calls Hebert asks if new vault! ?e Iaple . School as meeting'place. Hebert ewe it can pick up fees, yea. Oyen calls later to confirm Iepleton School. Oyen eeke Hebert it would like to get flyers out. Hebert we no. mtmriate because mm is making such We. call: DNR - Ie DNR aware of ICED plen- ?or men-I? DIR - ere surprised. ICED more lent out- not information on reason for meeting. to contact area. residents exp nee-u for meeting. if lepleten thool. Vince Castellanot treduoee or DER, MDPH. EPA, proceeds to teke a seat in audience. . October 22, 1983 Phone fonversution_?ith Dow workor' Dow is burning chemicals in their powobhouwc; Th y'vo Hutun?!y ohm; chemicals directly on the coal. -I asked a coupie'ur years an; if tr had a permit to do this and nobody would answer me. ,?no day {nu Hmunu and fumes_aL1 came through the lunchroom. and made oyeryoue sick. i? couldn't even breathe. They finally took_out the.mon1tors. Thexu is . a pipe that pumps chemicals to the powerhouse. I know SLEH ?uc mu uziai? is Bay Refinery tars. They've token some or this powerhouse sun to 7 city dump on Ashman. I I . T've aiso been present when Dow has accepLod autoiao wastes to ha:4 i. the} r' incinerator. Dow his lost the!" credibili?y and all_or us knon whai?s going on, .40 can't, do ar1yfh1ng,?cabso we all know who: would happen The ?all has got lots or documents, but they'?e so small, ani Dow's on "he; brought their own brine back into the plant ejniumiha'ed with w;-vica? Tnatwaa over by the Plant, come to fhin? of i! w.,b4 was why they closed the plant down.: The kuuzovv area is bad, there?s o0 much bvnzune En giat Th ara 95 many areas whoro you can huadly breathe. rherw's 3130 3 ditch running throb?h_tbe plan? c3?!ed tho Enintg; Di? 5. ?on'n ovum think there's any water 1o thorn, Jug: shawl-51;, 1w? colt-'3 all I'm? timeJ :hink they nigh?: be - i: If wanPS f0 find something, 51? they h3?? to do i3 ?viE: av?? 400m 3331?? 'hc plant. It's ferrible.5 10! of Dow :rv in. Tncir healtr inventories are a Joke;: You know tho? duu't tell rvery*hlnu; You can only hops they dill-L911 you ,lif it's too so: bn. it's t;o lain. What's in that air ls_ba?. tnlvud ?o a rug the o?hor day who.haq had wafer }Ve? in BrooL. HJ. tr! ho son a y&n truck working on ono of the brine wails, and 10 uff running all over 1he ground and in the ditc'ws. 1! was a ?Hi;r ally; substahco. He go+ mad and called the He's been ugvried ?rwu? hir water and his wife's been real sick. Rn lovsn't 'an! ?1:!1nd Ctua'y Hvalth Dopartment,oo he's asked Sagiaww to :03? his worry. fhtn. urn ofhor peonlc near-by having the samo kinds of problems. If the city has everyone supporting them ka come #39; in and signatures on that peti?ion? Thorn should have Egon loo LOVE. 1 to? could tell you everyone who signed it, too. The? jut? do wh foo "0 told, no matter what. I know ?hey've had some pro?lems with drinki:g Jol1s awn' .. 17mm. Tomlin-'1 P'Wr-vailln Dim!!- I. .- . .. hi. ?3 August 1983 Dow used to make us change report on accidental releases, to make them look good. I never felt good about it. In 1980, David Book, of Dow sent a letter around to employees, asking them to destroy their old records. They followed up by going through the employees themselves at night. Pose 1 . About 3 years ago Dow around the Poseyville Dump, to see how people felt about selling out. About five years ago, Dow capped1a?flbwi?g?artesian well, less than a quarter of a mile from the dump. This well is behind Bobbie's Party Store, on Poseyville Rd. NOTE: I checked this spot in August, and found that this well is being used by many local residents. 2, 3, 7 "dioxin and Dow has placed asbestos, sludge from their wastewater treatment plant, and barrels in this dump. Several years ago, they had a problem with spontaneous fires at the dump. These_f&res would burn for two or three days at a time. Dow finally had to run a special line in to put out the fires. They've been working on that dump all winter. most of their work. It's pretty unusual to see them doing that kind of work in the winter. NOTE: Records show, that as late as 1980, this landfill did not have a clay liner. The people on the roads surrounding the dump(Ashby&Patterson Hds.) have had some water problems, but a lot of them werk for Dow, and are afraid Johnston Contractors does to say anything. Dow put hazardous wastes innthere, befone they were licensed to do so. It's the same with the Salzburg Landfill. They had to get that license, 'cause they already had used it as a hazardous landfill. MZO-Driving Range- 1961 That driving range used to be a city dump, and Dow used it. how hard they try, they can't grow grass out there. Phenol Pond-Dow Site- A few years ago, Dow filled in what used to be known as the phenol pond. They filled in abou 20 acres, and put in new water lines and hydrants. They hauled in sand from Ingersoll Township for fill. Dowker, and Johnston did the job for Dow. The location is about 300 yds. N.E., of the new Dow burner. No matter Porter ":uwty Jews: ?ip and Marilyn he Ginty Meridian Hd.SecLion 13 Port Tn 19?? Jim, Marilyn, and their two became i '1 at 'he same 'inb. They hogan haying nausea, vomiting. diarrhea, blinding headaches, awojlnn nodes, numbness in limbs itching burning eyes, burning and ringihg ears,exeema. respiratory ailments, allergic rhinitis. inability to .o:us eyes, blind staggers, swollen ?r everything(newsrrin?, foods, exhaust fumes, etc.) Throughout the years they have Sought treatment from various rhysicia s, but have seen little improvement. Several months ago, they began drinkivg distilled water, and did see some improvement. ?ne day Iarilyn fargnt re use the distilled water for cooking and became violently ill for s: day. Whey recently were made aware of a clinical ecologist in sin Arirr (Dr. Paula Davey, M.D.) Dr Davey has diagnosed them as having Issuer System Dysfuwotioe {Complete breakdown of the immune system) rr?hey have also been diagnosed as having chemical sensitivities. WLN vo*ire section they live in has similiar illnesses, and it is not unsomneu its all of these Families to become ill at the sane time. We have been nc'v to document times when these illnesses coincide with releases Frr* Ham. Mo Ginty's have at times observed tanker trucks going down their a? night with it's lights out. They also observed a trush gain" Li? barrels in his back very early evevr Tuesday morning. Those is Lu; Dow disposal well just down the road from them, and the entire arnn ir dotted with abandoned oil walls. A couple of years ago Lhur? mus? been some kind of incident n? this well. as tho?o were pollsthe scene. The residents were never Lois who: hnyp?gh?. None or the resident in section lB?feel'thatltheir water is safe to d~L1k. We have told EPA, about'this family, and also TSCC. 96 far we harc no action. Porter mounshipr?idland $oun+y ?gg?gg} Por?er Township Supervise". that her throat closed up. 'rhey lived next door to the POrter Township Dump. and She is very concerned about the number of people Problems with water. Her nodes became so enlarged: Her next door neighbors pad simlliar problems. have since moved away. with well problems and illnesses in the area. i - ?v?ection?zo Theo? people have also had water probl distilled water. He has had some neurological problems. ran into a man from the Midland County Health Pupt., un? He replied that he had been instructed not to disouos to est anyone's water. -aa-a- . emo, and are now considering 3n AUant, Marianne o;kud about their water. water problems with anyone and also not Bah ??thf Wheeler and w. Kent Rd. Merrill Tho wheeler's have had severe allergies. headaches. 4nd ?tar- Mr. whewler has seen gfuoks wlgy radioactive m1: logs a ing Law? the Dow injection well. Vot suru if they've or Null 1 [up familv?Ten Mile ?d.*Sectiou# 21 Fenily has been very sick. to MarilyL HoCEqu. annuals. have bean sink. Lawrence Pamily-LaPortc 0 (pi, ad malignant. growth in abdomen at: ?ue-3. Daughter :ggil L?a nor- "?vmlnai marion Maul-Section 17 3:0 other 'lefol as. Gallbladdnr problems. Fwd??n. 'y-r Phone Conversation October 25, 1983 Mr. Walter Stover 1391 w. Kent Rd. Wheeler Porter Township Mr. Stover is a trustee in Porter Township. He called to offer his support and assistance. He is very upset about the problems in Porter. He has a stream on his land that had fish and muskrats. A couple of months ago, he went down there, and the fish and muskrats were dead. There had been about a 2000 gallon spill of brine on his land. He called DNR, and they referred him to the Mt. Pleasant office. A field rep. came out and sampled. They found 25,000 parts per million salt. He's waited for two months to hear from the DNB,and is really angry. He also called to tell me that they had mailed a letter out to Frank Kelley. He's aware of all the problems in the township, and wonders when somebody is going to do something. He worked in the Dow well dept. for 30 years, and agrees that there's a good chance that the chemical disposal wells have caused some of the contamination. He also feels that the oil drilling in the area may be causing some of the problems. He said that last night, one of the disposal well tanks ran over into the di?g?twmhe says this happens all the time, and he doesn't think they're being reported. He has a disposal well about 100' behind his house. Mr. Stover lives in Section 22. Mr. Stoyer feels that this brine may have been intentionally dumped on his land, and wants someone to look into it. Porter lj??idland County victoria Bennett 3348 S. Meridian Rd. Merrill Mrs. Bennett has had many uneXplained seizures, acute pancreatitis attacks. hynertensidh, respiratory problems, and her gallbladder removed.o Her nephe' took a sample of her water this summer, and found toulene, benzene, lead, and zinc. He then became very nervous about Dow, and will not give her the written results. He said they were very low levels, and she shouldn't worry. Mrs. Bennett has talked to the EPQ, but we're still unsure if they will do any sampling in her area. Paul Kong 3328 S. Meridian Rd. Merrill Mr. Korf has severe attacks of diarrhea, headaches, Severe allergies, and nausea. He is now drinking distilled water. Bonnie Markel 3332 S, Meridian Rd. Merrill Bonnie has severe headaches, and allergies. Her daughter suffered from the same ailments before she left home last year. She uses her enter only for cooking. Don Cindy Voorhei? 312a S. Meridian Rd. Merrill This family has severe headaches, nausea, extreme fatigue, neck pains, muscle spasms, blind man staggers. Cindy has in her breast: and tacyacardia. I believe they are still drinking their water. an?. - . - Dow Rockwell Dump Area- Ingersoll Township-Midland County The dump itself is in Bay County, but the people being affected are in Midla: County. Dow started dumping there in the early fifties. There is benzene; and toulene that we know of. This area was not encapsulate until after a man reported that one of his hunting dogs died after coming in contact with this material in one of the ponds on site. There was no fence to keep peeple out. This was in 1978. Neighborhood residents recall seeing the material running through the ditches for years. There is an unusually high number of cancers and other serious illnesses. ECOMM did an informal health survey of the area. The Michigan Department of Public Health agreed that a health survey should be done, and promised to do one. That was almost a year ago, and to my knowledge, the protocol for that study has not even been done.In the meantime DNR sampling in July, detected chemicals in the ditches, a near-by pond, and a resident's sump. These chemicals found were phenol, pentachlorophenol, 2-chlorophenol, and phlates. The pentachlorophenol, and Z-chlorOphenol could contain dioxins. He became aware last year that Dow was pumping huge amounts of water out of the dump. Too much, and we thought they might be on tOp of a Spring. Dow denied this, and as late as April, of this year, stated that Rockwell was secure. In June, Rockwell began leaking. For the first time Dow admitted, very quietly, to Williams Township officials, that too much water was coming out-and they had a problem. . In this same time period two families on Bailey Bridge Rd.,began having problems with their water. Esther Grell has water that smells like oil, and tastes too bad to drink. EPA, and DNR have been informed. Again these people do not trust the Midland County Health Department, and would prefer to have the state take the samples. On October 17th, DNH, came back to resample Kern's sump, the ditches, and the pond. While looking for another sump in the area, they learned that Mrs. Sugar, also had water problems. Her water has an odor, and black sticky material in it. Both she and Mrs. Grell, are south of the dump. The ditches near Rockwell, run in that direction. Another family, about a mile south of the 3d,, removed their filter, and found that it was black and tarry. They change their filt every two months, and.had never seen anything like this before. The Noack's are on the Mapleton Community well that serves 29 families. They also state their lack of trust in the Midland County Health Department. I informed the Michigan Department of Public Health. Ingersoll Township-Midland County Tom ni 2307 E. LaPorte Rd. Hemlock . I These people have water that smells terrible. The entire family has been very ill.- Sandy had a miscarriage, and they have a child with Down's He has severe asthma. They all have severe allergies$ They I often all.become ill at the same time. After showering, they come out' with red, itchy, nausea, vomiting, and frequent infections. They were recently told that their Rslated Comp-mama :n the Erwirmtmont' son has a hearing loss. They have been seeing Dr. Davey M.D.. in Ann Arbor. She has diagnosed them asphaxing mennp System Dysfunction, and chemical sensitivities._ When, Dow, has an accidental release, they all become very ill. pop Sly Freeland Rd., near Schreiber Rd. Mr. Sly claims his water smells like phenol. He used to work with phenol at Dow, so he recognizes the smell. He also has had to change his filter once a week, lately. -This is a new well that he dug a couple of years ago. . 55-1.? Dick Bogkgr?ellg? Owns local garage between Gordonville and Stewart Rds. Mr. Rockerfellow has been with his water. He says that or 9 of his customers have mentioned within the last few months that they have 'skunky' water. They've also had a black tarry material on their filters. carol ?1116 58.886 311., (annual Evaluation Sectiw Mrs. wylie'is a teacher having water problems for years. She's had to drill a new well. Occasionally, she still gets an odor to her Her illnesses have often coincided with her illnesses. She has had both breasts removed and numerous embolisms. Recently she has been blacking out, and has lung problems. There have been brine her land. She would like sampling done, as she suspects chemicals may be in the brine. r" Ingersoll Township- Midland County Albany ?gorg 172? Sasse Rd. Mr. Moore is a Dow retiree, and a farmer. Throughout the years he has been battling with Dow, over brine spills on his land. On spill resulted in a loss of ten apres of trees. Mr. Moore claims that Dow has consistently underreported the amount of brine released; in the reports they submit to the DNR. He has slides of the spills. When he finally got in an are: he had been concerned about, they announced that they had shredded the data, because the results were confusing. Mr. Moore employee that ?what's in that brine, you wouldn't want to put in your coffee! He has become increasingly concerned that the brine may contain chemicals. Dow has injected literally trillions of gallons of toxic chemicals into their chemical disposal wells. Mr. Moore has done some calculations, and figured the amount of chemicals pumped into the ground should have raised the city of Midland. six inches. We know this hasn't happened, so where have they gone? The pressures used for disposal are capable of causing fractures underground: These?records are available through the Geological Survey Division, at DNR. In January of '83, Dow announced they were discontinuing-their practice of disposing of chemicals in wells. The reason given was that they couldn't know where those wastes were going. If they didn't know where their wastes were going in 1983, how could they know where they've gone for the past 30 yrs? We feel that these disposal wells could be responsible for contaminating the wells of township.residents.we have askeduthewEPA to consider scoring these walls .Hw? . "1 :48'1 Ht. Haley Township-Midland County Saw-Kent as Homer ads. These people have been ill, and recently switched to distilledsvaker. Larry Woodard- 25355. Homer Rd. . They have brown water that has a terrible taste and odor. They are now buying their water. The wife has heart problems and seyere allergies. E. Kent Ed. Merrill . Entire family has severe allergies. They're sensitive to everything. Probably have immune system dysfunction. He's been too sick to work,and the doctors can't tell him what's wrong. Fred Euzigh 99 E. Kent Rd. Merrill - He has seizures, severe headaches, nausea, vomiting diarrhea, and severe allergies. All of his'ten kids also had severe allergies. Gerald Eurich #9 E. Kent Merrill These people have two children who are sick all the time with infections, and severe allergies. Chris(wife) has tacyacardia. Manngu Hayes 2242 E. Brooks Rd. - Became 111 in 1978, the same time that HcGinty's, and other Porter Township families began having problems. MaryLou has severe allergies that often keep her home from work. She also has Meneire's. She said it has been one thing after another, including bladder and kidney infectii She lives across the road from a brine well. James 1658 E. Brooks Rd. Mr. Hassen is concerned about his water, but does not trust the Midland County Health Department to test it. He has asked the Saginaw Health Department to do this. His wife has been very ill. She started out with swollen Joints, diarrhea, and then heart problems. She now has extreme fatigue, arthritis, stomach problems, and allergies. 0n the week of October 10th, Hr. Hassen saw a chemical clean-up truck working on one of the wells in the area. The truck was spilling a? white milky substance all over the ground and the ditches. He got mad and called EPA. I don't know what action they took, if any. I glut-y? 'Hi? I A, ?79 .ii'.P'iegolsr Eastman Rd: Midland Townshi Pow control chemist 1936-1942, County Commissioner in 19708 About 20 years ago Mr. Piegols water started changing. The water that heMr?: The neighbor moved to Bay City as a result. About 15 years ago when Mr. Piegols turned on his outside hose his entire yard filled up with bubbles. . Ray VanSteenhouse from Dow, took samples, and said it was okay. Mr. Riegol's health began failing him and he now has two artificial :15. ?ll; always'beenyery healthy. his water problems - ii n? Between 1965-68 Mr. Piegols sold beef cattle. The butcher said he had never seen livers like that before. They were enlarged and had blisters on them. wag?true with hislchickenS. and. they u- Val-?34: :61" wins? so#h?ntjl?gned?that?thego it's brine for salting'? the Dow? about 1975. He thinks - they discovered it was contaminated with chemicals. The former county road commissioner also has nolkid?neys. He said the brine for the city is in"Section and would like to have 'them tested. He has'a? tremendous "amount ?or information about other suspect areas. hm?um wows?. "amasseseuawe Lusakaall?iem?.idem: 2v . - x. allkiitk-?eii' afo'i-fei; . i? . I .{it dunsag: .. ,vugf??imm if! 9% 1.395;.? 31cm?fma?iak?e WA-Wzmamaw ??atwasl?wni-Ema . . a. 5; . Urban h78u?5haffer Midland Mills Township Gilded in September. Her 12 year old daughter has a brain tumor. a Dow.Corning scientist. -. Testing 'f'efealed'vthat-aboth --gi their @9139; These toxic levels dropped to normal during the summer when they weren't in school. The youngest daughter was then diagnosed asmhaving a brain tumor. They have operated twice and cannot do anymore surgery. Her and.her husband Joined a parent's Vi. They observed that most of and Jefferson ??e-Mm Junior Hi. This is the school their children attend also. They asked' -. the principal if the water had ever been tested, and he said no. They finally told Rosemary that if she was uncomfortable, she could send her . a assesses our eta-anti? sens-r; r- M. . a: "Itif? Jun fhigh number of oancersfand-leukemia 3 I-Il'i I I a very small the Siebert and Jefferson schools. This also seems to be the case with many of the homes that were built. The Siebert Drain also runs through the Siebert Drain begins, there is Dow to dobertjgiegols, Dow contaminated a residents wellfin that areaKEarl'SiebertI?and had to drill him a'new one. f} Very close by on Dilloway, Mr. John Dempsey, who has lived in this area'-' for many years, tells me that there used to be an old sand pit used for- dumping Dow wastes. This street is now residential. Although we have not confirmed any of this information, it has come up enough to deserve a closer look. We have been trying to give this information to EPA, witho any success. a, Lk?n?? .H- . 5..- . I. I . . muAviva; half-7g futIf'41: .5. - . ?35.41414: .hrurkin Township from Rosemary Urban "out a year and a half ago Rosemary heard about a planned subdivision at was scrapped because chemicals were found on the site. he site in question is Section #21, Larkin Township, N.w. corner(80 acres) This land-is owned by Sasse Investment, and we've now heard that they have decided to continue construction. We think some questions should be asked before this happens. vember 5, 1983 Dear A The Midland City Council and th? Midland Count Board.of Commissioners was approachedtby Dr. I. Oyen, idlandICO. Health.Director, who requested they adopt a resolution proclaiming her as the keeper of public health and her agency as the proper agency tc-handle environmental and health issues. The original resolutions got "softened" as local officials heard-ECOMM's-Itcry. Enclosed are petitions.eigned.by residente'in the area of Rockwell Drive Landfill who express their concern and lack'of confidence in the Midland Co. Health Dept. for disregarding requests for and failing to conduct a health assessment in the area. (Only I perscm would not sign, only because he was afraid of increased taxes to do the study . chronology of events in that area, documenting local health dept. inaction andithe steps had to take_. to bring the area to the attention of more appropriate agenciests Inf-?dd- This is one example on why the Midland.area.needs to be singled out. My 3/25/83 letter mentions health problems andiour prepared map, an unscientific door?to?door survey, shows 76 severe ailments, including 24 cancers among 130 mapleton residents. Some residents suffer from more than one ailment. 7 Midland city officials, including'Dr. Oyen;will be traveling to Washington Dc, November 10 to spread the word that this area should not be singled out. Please note my letter to the Editor also describing yet another area which has not yet been investigatmi Some of these residents have been medically diagnosed as being victims of chemical contamination and.we still cannot get the appropriate agencies to investigate. - City officials are understandably concerned about the Midlanh image but is it worth sacrificing human lives for! ECOHI and the Peresight.Socdety submitted a citizens Petition to EPA in March 1983 requesting a full field investigation of the area. Internal EPA memos from scientists who reviewed our petition and attachments indicate that we provided "overwhelming evidence to warrant a full field?investigation." we are disturbed that political pressure has "watered down! that study and efforts are now directed toward fitting it into the-national dioxin study which was never the original intent. 4 2 Midland is being tested for a range of contaminants other than dioxin because we have provided evidence that a problem exists. Have other 'cities in the country that wilm.be included;1n;the National Study provided such evidence of a problem! lo. Ior reasgn?idland is being singled.out, intensely investigatedtand Justly so. After all, where else-in this country-does a nearly 100 year old chemical facility exist, several square miles in size and within city limits? And let's not orgst the contaminated fish the 8,200,000 incinerator particulate?matter, or the 100,000 TCDD in soil (according :0 probe Chenie?riee of Fire). @ij Mum ?9 1511?. Juan The tonesiqln sociETy 26 January 1984 Thomas K. Rohrer Toxic Chemical Evaluation Section Environmental Services Division Department of Natural Resources P.0. box 30028 Lansing. lit-190a Dear Mr. Rohrer: lhank you for your 18 January 1984 reply on behalf of Daniel Schulz, Ground Water Quality Division, to a couple of the comnents I made at the 23 September 1983 Rockwell Drive Landfill public meeting held at Mapleton summarized in a letter to Mr. Schultz dated 5 October 1983. Unfortunately, your reply is inadequate. With respect to the potential presence of chlorinated dioxins in the sump water of hones in the vicinity of the Rockwell Drive Landfill, I noted in my oral and written comments that the migration of dibenzo?p-dioxins for any distance through soil with water as the eluting solvent was unlikely, but that the eluting solvent at RDL was probably a solution of benzene, toluene, xylene and methylene chloride in water, which could increase the rate of migration of through soil many fold. I also noted that it wasn't clear that the RDL itself was the source of the chlorophenols. Improperly capped deep well injection ports, leaking underground pipes or spills in the area could also be the source. Pipes run underneath the Rockwell Drive neighborhood. The distance of migration need be only a few feet rather than a half-mile. Sampling and analytical methods used to test for at the Rockwell Drive Landfill to date are barely sufficient to reveal at concentrations corresponding to an increased cancer risk of 1/100, four orders of magnitude above the 1/l,000,000 level of concern. Perhaps it would be more appropriate to use EPA's preconcentration sampling methods on the RDL monitoring well and neighborhood sump water samples for purposes of testing for Regarding the evaluation of the volatilization potential of phenol and chlorinated phenols from water contained in ?Water?related Environ- mental Fate of 129 Priority Pollutants--Volume 11? published in 1979, the analyses contained in the excerpted passages are so superficial and I qualitative as to be virtually useless. The work of Hakuta (1975) indicates 1 that phenol favors the vapor phase over aqueous solution by almost two-to? one at atmospheric pressure. If the vapor pressure decreases more slowly than water solubility with increasing degree of chlorination, then penta- chlorophenol would favor the vapor phase over aqueous solution by an even greater ratio, encouraging volatilization from water until that equilibrium ratio is reached. Although not stated consistently, apparently the authors of this five year old document have concluded that volatilization is not a significant . 'a-ir- [3 0/1 I autumn AQD17 Thomas K. Rohrer Page Two 26 January 1984 transport process for chlorophenols from water. It is not clear why "(t)hese conclusions would be especially true for cases where the water concentrations of these contaminants are very low as reported in the Kearns'sunmiwater.? Could you explain? It should be further noted that the steady state concentrations of these contaminants in the air in the Kearns home are equal to the rates of their volatilization through the walls of the Kearns basement and from the sump port divided by the rate of air exchange in the house. Perhaps a quantitative analysis could be performed by the chemists or chemical engineers in the Air Quality Division. In fact, as I recall, I directed my questions regarding volatilization to the Air Quality Division representative at the RDL public meeting. Should you have access to data relevant to such a quantitative analysis, please forward it to the Air Quality Division where the appropriate calculations can be performed. Sincerely, Larry E. Fink, M.S. Director The fORESiqln 26 January 1984 Thomas K. Rohrer Toxic Chemical Evaluation Section anironmental Services Division Department of Natural Resources P.0. box 30028 Fi? fir/4H? Dear Mr. Robrer: lhanl you lor your in January 1984 reply on behalf of Daniel Schulz, Ground Water Quality Division, to a couple of the comnents I made at the i 23 September 1983 Rockwell Drive Landfill public meeting held at Mapleton summarized in a letter to Mr. Schultz dated 5 October 1983. Unfortunately, your reply is inadequate. With respect to the potential presence of chlorinated dioxins in the sump water of bones in the vicinity of the Rockwell Drive Landfill, I noted in my oral and written comments that the migration of dibenzo?p?dioxins for any distance through soil with water as the eluting solvent was unlikely, but that the eluting solvent at RDL was probably a solution of benzene, toluene, xylene and methylene chloride in water, which could increase the rate of migration of through soil many fold. I also noted that it wasn't clear that the RDL itself was the source of the chlorophenols. Improperly capped deep well injection ports, leaking underground pipes or spills in the area could also be the source. Pipes run underneath the Rockwell Drive neighborhood. The distance of migration need be only a few feet rather than a half-mile. Sampling and analytical methods used to test for at the Rockwell Drive Landfill to date are barely sufficient to reveal at concentrations corresponding to an increased cancer risk of 1/100, four orders of magnitude above the 1/1,000,000 level of concern. Perhaps it would be more appropriate to use EPA's preconcentration sampling methods on the monitoring well and neighborhood sump water samples for purposes of testing for PCUUs. Regarding the evaluation of the volatilization potential of and chlorinated phenols from water contained in ?Hater-related aniron? mental Fate of 129 Priority Pollutants?-Volume 11? published in 1979, the analyses contained in the excerpted passages are so superficial and qualitative as to be virtually useless. The work of Hakuta (1975) indiiates that phenol favors the vapor phase over aqueous solution by almost two?lo" one at atmospheric pressure. If the vapor pressure decreases more slowly than water solubility with increasing degree of chlorination, then penta- chlorophenol would favor the vapor phase over aqueous solution by an evrn greater ratio, encouraging volatilization from water until that equilibrium ratio is reached. Although not stated consistently, apparently the authors of this fiVe year old document have concluded that volatilization is not a significant Thomas K. Rohrer Page Two 26 January 1964 tranSport process for chlorophenols from water. It is not clear why ?(t)hese conclusions would be eSpecially true for cases where the water concentrations of these contaminants are very low as reported in the Kearns' whmiwater.? Could you explain? It should be further noted that the steady state concentrations of these contaminants in the air in the Kearns home are equal to the rates of tin?ir' voltiti iiZLith?i tin- wal ls of? tht? thiSG?KHlt {Hid sump port divided by the rate of air exchange in the house. Perhaps a quantitative analysis could be performed by the chemists or chemical engineers in the Air Quality Division. In fact, as I recall, I directed my questions regarding volatilization to the Air Quality Division representative at the RDL public meeting. Should you have access to data relevant to such a quantitative analysis, please forward it to the Air Quality Division where the appropriate calculations can be performed. Sincerely, Larry E. Fink, M.S. Director 26 January 1984 Thomas K. Rohrer Toxic Chemical Evaluation Section Environmental Services Division Department of Natural Resources P.D. box 30028 i. Lilli. llI .. Qi'lgll'? Dear Mr. Rohrer: lhank you ior your 1H January 1984 reply on behalf of Daniel Schulz, Ground water Quality Division, to a couple of the comnents I made at the 23 September 1983 Rockwell Drive Landfill public meeting held at Mapleton which I sunmarized in a letter to Mr. Schultz dated 5 Uctoher 1963. Unfortunately, your reply is inadequate. with respect to the potential presence of chlorinated dioxins in the sump water oi homes in the vicinity of the Rockwell Drive Landfill, I noted in my oral and written comments that the migration of dibenzo?p?dioxins for any distance through soil with water as the eluting solvent was unlikely, but that the eluting solvent at RDL was probably a solution of benzene, toluene, xylene and methylene chloride in water, which could increase the rate of migration of through soil many fold. I also noted that it wasn't clear that the RDL itself was the source of the chlorophenols. Improperly capped deep well injection ports, leaking underground pipes or spills in the area could also be the source. Pipes run underneath the Rockwell Drive neighborhood. The distance of migration need be only a few feet rather than a half-mile. Sampling and analytical methods used to test for at the Rockwell Drive Landfill to date are barely sufficient to reveal at concentrations corresponding to an increased cancer risk of 1/100, four orders of magnitude above the 1/1,000,000 level of concern. Perhaps it would be more appropriate to use EPA's preconcentration sampling methods on the RDL monitoring well and neighborhood sump water samples for purposes of testing for PCUDs. Regarding the evaluation of the volatilization potential of phenol and chlorinated phenols from water contained in ?Water?related aniron? mental Fate of 129 Priority Pollutants-~Volume 11? published in 1979, the analyses contained in the excerpted passages are so superficial and qualitative as to be virtually useless. The work of Hakuta (1975) indicates that phenol favors the vapor phase over aqueous solution by almost two?tn- one at atmospheric pressure. If the vapor pressure decreases more slowly than water solubility with increasing degree of chl0rination, then penta? chlorophenol would favor the vapor phase over aqueous solution by an even greater ratio, encouraging volatilization from water until that equilibrium ratio is reached. Although not stated consistently, apparently the authors of this five year old document have concluded that volatilization is not a signifiCant 14 lonesiqln sociETy Thomas K. Rohrer Page Two 26 January 1984 tranSport process for chlorophenols from water. It is not clear why ?(t)hese conclusions would be especially true for cases where the water concentrations of these contaminants are very low as repOrted in the Kearns'snmniwater.? Could you explain? It should be further noted that the steady state concentrations of these contaminants in the air in the Kearns home are equal to the rates of their volatilization throogh the walls of the Kearns basement and from the sump port divided by the rate of air exchange in the house. Perhaps a quantitative analysis could be performed by the chemists or chemical engineers in the Air Quality Division. In fact, as I recall, I directed my questions regarding volatilization to the Air Quality Division representative at the RDL public meeting. Should you have access to data relevant to such a quantitative analysis, please forward it to the Air Quality Division where the apprOpriate calculations can be performed. Sincerely, Larry E. Fink, M.S. Director THE fonesiqln sociETy 23 December 1983 Mr. Richard 5. Johns Chief, Groundwater Quality Division Dept. of Natural Resources P.0. Box 30028 Lansing, MI 48909 Dear Mr. Johns: Thank you for c0pying your 12 December 1983 reply to Andrea Wilson's 29 September 1983 letter to Director Skoog regarding DNR actions to character? ize, quantify and control the routes and rates of loss of toxic substances present in the Rockwell Drive Landfill (RDL) to the environment. Unfortu? nately, I have yet to receive answers to the questions I posed verbally to Department of Natural Resources staff at the 22 September 1983 RDL meeting at Mapleton Elementary School which I submitted in writing in a follow?up letter dated 5 October 1983 in response to a DNR staff request. What is the status of the staff reply to those questions? When can I expect written answers to those questions? Questions have also arisen as to the adequacy of the reported limits of detection of the sampling and analytical methods employed by DNR staff or their contractors in the most recent round of RDL sampling and analysis. The adequacy of a particular combination sampling and analytical methods is determined by the concentration of the substance at and below which there is no regulatory concern. That concentration of regulatory concern is deter- mined by the toxicological pr0perties of the substance and the dose-response model adopted. A particular combination of sampling and analytical methods is adequate if the level of quantitation (see Dow NPDES Permit MI 0000868 [April 21, 1982] for definition adopted by DNR staff) is at or below the level of concern. Risk assessment should be used as a guidance for the identifica- tion of adequate sampling-analytical methods. The limit of detection of an existing sampling?analytical method should not be used to define an acceptable risk. For example, the concentration of benzene in drinking water estimated by EPA's multi-sta e, linear dose-reSponse model to represent an increased cancer risk of 10- is approximately 6 parts per billion, if my memory serves me correctly. Thus, a benzene limit of detection of 10 parts per billion is wholly inappropriate in sampling and analyzing RDL water samples. Thank you in advance for expediting a staff reply. Should you have any questions, please feel free to contact me. Sincerely, f. Director cc: R. Skoog, DNR G. Guenther, DNR L. Holcomb, TSCC A. Wilson, ECOMM 6300 W. Michigan Avenue F-24 Lansing. Michigan 48917 517-321-7358 fonesiql?n sociETy 23 December 1983 Mr. Richard 5. Johns Chief, Groundwater Quality Division Dept. of Natural Resources P.0. Box 30028 Lansing, MI 48909 Dear Mr. Johns: Thank you for copying your 12 December 1983 reply to Andrea Wilson's 29 September 1983 letter to Director Skoog regarding DNR actions to character- ize, quantify and control the routes and rates of loss of toxic substances present in the Rockwell Drive Landfill (RDL) to the environment. Unfortu- nately, I have yet to receive answers to the questions I posed verbally to Department of Natural Resources staff at the 22 September 1983 RDL meeting at Mapleton Elementary School which I submitted in writing in a follow-up letter dated 5 October 1983 in response to a DNR staff request. What is the status of the staff reply to those questions? When can I expect written answers to those questions? Questions have also arisen as to the adequacy of the reported limits of detection of the sampling and analytical methods employed by DNR staff or their contractors in the most recent round of RDL sampling and analysis. The adequacy of a particular combination (If sampling and analytical methods is determined by the concentration of the substance at and below which there is no regulatory concern. That concentration of regulatory concern is deter- mined by the toxicological properties of the substance and the dose-response model adopted. A particular combination of sampling and analytical methods is adequate if the level of quantitation (see Dow NPDES Permit MI 0000868 [April 21, 1982] for definition adopted by DNR staff) is at or below the level of concern. Risk assessment should be used as a guidance for the identifica- tion of adequate sampling-analytical methods. The limit of detection of an existing sampling?analytical method should not be used to define an acceptable risk. For example, the concentration of benzene in drinking water estimated by EPA's multi-sta e, linear dose-response model to represent an increased cancer risk of 10' is approximately 6 parts per billion, if my memory serves me correctly. Thus, a benzene limit of detection of 10 parts per billion is wholly inappropriate in sampling and analyzing RDL water samples. Thank you in advance for expediting a staff reply. Should you have any questions, please feel free to contact me. Sincerely, 23452 rry E. Fink, M.S. Director Skoog, DNR Guenther, DNR Holcomb, TSCC Wilson, ECOMM CC: 23 December 1983 Mr._Richard S. Johns I Chief, Groundwater Quality Division Dept. of Natural Resources P.0. Box 30028 Lansing, MI 48909 '_Dear Mr. Johns: Thank you for copying your 12 December 1983 reply to Andrea Wilsonfs 29 September 1983 letter to Director Skoog regarding DNR actions to character- ize, quantify and control the routes and rates of loss of toxic substances . present in the Rockwell Drive Landfill (RDL) to the environment. Unfortu- nately, I have yet to receive answers to the questions I posed verbally to Department of Natural Resources staff at the 22 September 1983 RDL meeting at Mapleton Elementary School which I submitted in writing in a follow-up letter dated 5 October 1983 in response to a DNR staff request. What is the status of the staff reply to those questions? When can I expect written answers to those questions? Questions have also arisen as to the adequacy of the reported limits of detection of the sampling and analytical methods employed by DNR staff or their contractors in the most recent round of RDL sampling and analysis. The adequacy of'a particular combination (If sampling and analytical methods is determined by the concentration of the substance at and below which there is no regulatory concern. That concentration of regulatory concern is deter- mined by the toxicological properties of the substance and the dose?response model adopted. A particular combination of sampling and analytical methods is adequate if the level of quantitation (see Dow NPDES Permit MI 0000868 [April 21, 1982] for definition adopted by DNR staff) is at or below the level_ of concern. 'Risk assessment should be used as a guidance for the identifica- tion of adequate sampling-analytical methods. The limit of detection of an 'existing sampling-analytical method should not be used to define an acceptable risk. For example, the concentration of benzene in drinking water estimat?d by EPA's multi-sta e, linear dose-response model to represent an increased cancer risk of 10- is approximately 6 parts per billion, if my memory serves me correctly. Thus, a benzene limit of detection of 10 parts per billion is wholly inappropriate in sampling and analyzing RDL water samples. I Thank you in advance for expediting a staff reply. Should you havei any questions, please feel free to contact me. Sincerely, . r, 3.44 1 ?y M.S. 3 Director DNR Guenther, DNR Holcomb, TSCC - Wilson, ECOMM cc; 6300 W. Michigan Avenue F-24 Lansing. Michigan 48917 517?321?7358 Al l: Oi JAMES BLANCHARD, GOvernor MASON BUILDING r1 BOX 30028 IANSING. MI 48909 M'er lit 0 DINECICH January 17, 1984 llir Foresight Society West ?lir?llig'nu, Prim Lansing. Hivhiynh Fh?u have been asked to reply directly Lo your December 23, 1983 letter to Richard Johns, Chief, Groundwater Quality Division regarding laboratory detection limits. The MDNR Laboratory uses test prOCedures adopted from procedures developed by the U.S. EPA for the identification and quantification of certain priority pollutants in NPDES discharges and surface waters. These methods have been designed to perform within certain limits of sensitivityg accuracy and precision. The laboratory method for determination of purgeable aromatic hydrocarbons (including benzene) conforms to U.S. EPA Method 602. The laboratory detection limit for this scan is 5 ug/l. This detection limit can be met in the absence of interferences. However, on certain samples, where interferences exist, it is common practice for the laboratory to raise the detection limit and code the result to indicate that quantification below an elevated detection limit was not possible due to interferences. The laboratory is a support service for various Environmental Protection Bureau (EPB) programs. If laboratory services do not meet the needs oi the various EPB programs (sensitivity, precision, accuracy, capacity, and turn around time), these programs must convey their needs to the laboratory and provide the laboratory with the resources to meet Lthu on . 11' can provirh: additional information concerning detection limits, please feel free to contact me or contact our laboratory directly. Sincerely, 9? ?k George Jackson Quality Assurance Coordinator Environmental Services Division cc: D. Schultz ll. .lOlH18 K. Wu th- .y if In ?Ltd-a. I'l - LI?lltH ?l?l mums .J Governor DEPARTMENT OF NATURAL RESOURCES . I 5-H Vi Hi) I MASON BUILDING HI 30038 LANSING. MI 4690?) Hi IHM LI 0 EIKUUL: January 17, 198A llilttlil! i-xty N-mt hiya?, lanniny, Wirhipan llI'JiI? T-lr. Phil: 1 hour lvi't'i] :I-Ll-ufil lo to your Decombor 23, 1983 lctlul? Ril? llJl'l llt?l Itt?l inn luhnh, Chiul, Quality Division regarding laboratory limits. HDHH Laboratory usvs Inst procedures adopted from procedures dQVelopod by the U.S. EPA lor the identification and quantification of certain pollutants in NPUES discharges and surface waters. These have brun to perform within certain limits of sensitivity, priority methods accuracy and precision. Thu method for determination of purgeable aromatic hydrocarbons (including bwnzunc) conforms to U.S. EPA Method 602. The laboratory dutection limit for this scan is 5 ug/l. This detection limit can be met in tho absence of interferences. However, on certain samples, whrre interferences exist, it is common practice for the laboratory to raise the detection limit and code the result to indicate that quantification below an elevated detection limit was not possible due to interferences. laboratory The Bnrvan (ll lili' and .?IJ'oon?l time), laboralosv (lil?ll) WI 1' ions; is a support service for various Environmental Protection programs. it laboratory services do not meet the needs KPH programs (sensitivity, precision, accoracy, capacity, these programs must convoy their needs to the lahotaLary and provide the laboratory with the resources to meet thusu inn-min. 11 I can additional inlol'mation concerning detection limits, plwunw to contact me or contact our laboratory directly. Sincerely, 3?3??k George Jackson Quality ASSurance Coordinator Environmental Services Division rr: D. ll. .lolnis K. Nu LlAlttH MHJHUAH DEPARTMENT OF NATURAL RESOURCES bl LVE H5 I MASON BUILDING rg)x 30028 January 17, 1984 liizi' in..Jl_ Fink-1., Foresight thU w~:I Wirhiynn, F??h ?4.i?aiiwin 138?)1? Dvur Hr. Fink: hUVv naked lo reply directly to your December 23, 1983 letter In Rirhurd Johns, Chief, Groundwater Quality Division regarding laboratory ilI'Lui'llnH lilnil'h?. The MDNR Laboratory uses test procedures adopted from procedures developed by the EPA [or the identification and quantification of certain priority pollutants in NPDES discharges and surface waters. These methods have designed to perform within certain limits of sensitivity, accuracy and precision. The laboratory method for determination of purgeable aromatic hydrocarbons (including benzene) conforms to U.S. EPA Method 602. The laboratory detection limit for this scan is 5 ug/l. This detection limit can be met in the absence of interferences. However, on certain samples, where interferences exist, it is common practice for the laboratory to raise the detection limit and code the result to indicate that quantification below an elevated detection limit was not possible due to interferences. The laboratorv is a support service for various Environmental Protection Bureau (EPB) programs. If laboratory services do not meet the needs ml the various EPB programs (sensitivity, precision, accuracy, capacity, and turn around time), these programs must convey their needs to the luburulnry and provide the laboratory with the resources to meet th5v . II I can prnvidu additional information concerning detection limits, plvu?w ivwl lrur to contact me or contact our laboratory directly. Sincerely, George Jackson Quality Assurance Coordinator Environmental Services Division L'k?i ll. R. Johns l. K. Nu The for: qI-n sociETy 26 January 1984 George Jackson Quality Assurance Coordinator Environmental Services Division DNR P.0. Box 30028 Lansing, MI 48909 Dear Mr. Jackson: Thank you for y0ur 17 January 1984 reply on behalf of Richard Johns, Chief, Groundwater Quality Division, to my 23 December 1983 letter regarding analytical limits of detection. Unfortunately, your letter did not directly address our concerns. When samples are analyzed at laboratories other than DNR's Environ? mental Laboratory, the limits of detection for purgeable aromatic hydro- carbon (including benzene) can be as high as 10 parts per billion. What criteria do you use to determine when to send samples to outside contract laboratories? As I indicated to Mr. Johns, the maximum level of acceptable cancer risk determines the appropriate limit of quantification, not vice versa. The 1/1,000,000 increased cancer risk concentration for benzene per EPA estimates is approximately six parts per billion. A benzene limit of detection of 10 parts per billion is unacceptable in the context of protecting ground water for potable water supply, yet this is the l.o.d. reported by the contract lab to which Rockwell Drive Landfill neighborhood sump water samples were sent. Your reply is unresponsive in this regard. In your fourth paragraph you state: "If laboratory services do not meet the needs of the various EPB programs (sensitivity, precision, accuracy, capacity, and turn around time), these programs must convey their needs to the laboratory and provide the laboratory with the resources to meet these needs.? I directed my conments to Mr. Johns in recognition of the validity of your statement. By copy I am asking Mr. Johns to identify 1/1,000,000 cancer risk concentrations for substances of concern in ground water to the Environ- mental Laboratory so that the Environmental Laboratory can identify existing or develop new sampling and analytical methods to achieve the required limits of quantification with acceptable accuracy, precision, sensitivity, capacity and turn around time. Sincerely, Larry E. Fink, M.S. Director cc: R. JohnsHebert, ECOMM cam 1M Mlirhanan AanuP F474 Lansmo. Michiuan 51 iqhi sociETy 26 January 1984 George Jackson Quality Assurance Coordinator Environmental Services Division DNR P.0. Box 30028 Lansing, MI 48909 Dear Mr. Jackson: Thank you for your 17 January 1984 reply on behalf of Richard Johns, Chief, Groundwater Quality Division, to my 23 December 1983 letter regarding analytical limits of detection. Unfortunately, your letter did not directly address our concerns. when samples are analyzed at laboratories other than DNR's Environ~ mental Laboratory, the limits of detection for purgeable aromatic hydro~ carbon (including benzene) can be as high as 10 parts per billion. What criteria do you use to determine when to send samples to outside contract laboratories? As I indicated to Mr. Johns, the maximum level of acceptable cancer risk determines the appropriate limit of quantification, not vice Versa. The 1/1,000,000 increased cancer risk concentration for benzene per EPA estimates is approximately six parts per billion. A benzene limit of detection of 10 parts per billion is unacceptable in the context of protecting ground water for potable water supply, yet this is the l.o.d. reported by the contract lab to which Rockwell Drive Landfill neighborhood sump water samples were sent. Your reply is unresponsive in this regard. In your fourth paragraph you state: "If laboratory services do not meet the needs of the various EPB programs (sensitivity, precision, accuracy, capacity, and turn around time), these programs must convey their needs to the laboratory and provide the laboratory with the resources to meet these needs." I directed my comnents to Mr. Johns in recognition of the validity of your statement. By copy 1 am asking Mr. Johns to identify 1/1,000,000 cancer risk concentrations for substances of concern in ground water to the Environ- mental Laboratory so that the Environmental Laboratory can identify existing or develop new sampling and analytical methods to achieve the required limits of quantification with acceptable accuracy, precision, - sensitivity, capacity and turn around time. Sincerely, Larry E. Fink, M.S. Director cc: R. Johns, 000 T. K. Wu, LL JD. Hebert, ECOMM "l ?1 All ?nnlalul laI?Hln? Fem I I The to iqhi sociETy 26 January 1984 George Jackson Quality Assurance Coordinator Environmental Services Division DNR . P.0. Box 30028 Lansing, MI 48909 Dear Mr. Jackson: Thank you for your 17 January 1 Chief, Groundwater Quality Division, analytical limits of detection. directly address our concerns. 984 reply on behalf of Richard Johns, to my 23 December 1983 letter regarding Unfortunately, your letter did not when samples are analyzed at laboratories other than DNR's Environ- mental Laboratory, the limits of detection for purgeable aromatic hydro- carbon benzene) can be as high as 10 parts per billion. Hhat criteria do you use to determine when to send samples to outside contract laboratories? As I indicated to Mr. Johns, the maximum level of acceptable cancer risk determines the appropriate limit of quantification, not vice versa. The 1/1,000,000 increased cancer risk concentration for benzene per EPA estimates is approximately six parts per billion. A benzene limit of detection of 10 parts per billion is unacceptable in the context of protecting ground water for potable water supply, yet this is the l.o.d. reported by the contract lab to which Rockwell Drive Landfill neighborhood sump water samples were sent. Your reply is unresponsive in this regard. In your fourth paragraph you state: "If laboratory services do not meet the needs of the various EPB programs (sensitivity, precision, accuracy, capacity, and turn around time), these programs must convey their needs to the laboratory and provide the laboratory with the resources to meet these needs.? I directed my conments to Mr. Johns in recognition of the validity of your statement. By copy 1 am asking Mr. Johns to identify 1/1,000,000 cancer risk concentrations for substances of concern in ground water to the Environ- mental Laboratory so that the Environmental Laboratory can identify existing or develop new sampling and analytical methods to achieve the required limits of quantification with acceptable accuracy, precision, sensitivity, capacity and turn around time. Sincerely, Larry E. Fink, M.S. Director cc: R. JohnsHebert, ECOMM i lanmnu. Micluuan 48917 SIT-334358 Inn All ?uaalnlD - THE ion In sociETy 26 January 1984 Robert Miller Chief, Air Quality Division Department of Natural Resoorces P.O. Box 30028 Lansing, MI 48909 Dear Mr. Miller: At a public meeting on the Rockwell Drive Landfill (RDL) held 23 September 1983 at the Mapleton Elementary School I asked your staff representative to evaluate the inhalation route of exposure to the substances landfilled there and the substances detected in the sump water samples taken from the Kearns home in the RDL neighborhood. I followed up those oral comments with a written summary dated 5 October 1983 (Attachment 1). To date 1 have received no answers from your Division. Responses received from the Toxic Chemical Evaluation Section (Attachment II) are inadequate. Please have your staff evaluate the health risks via the inhalation route of exposure to RDL contaminants from the landfill and sump water. ShOuld you have any questions, please feel free to contact me. Sincerely, Larry E. Fink, M.S. Director Attachments cc: R. Johns lg. Courchaine . Hebert, L'thfl Mmhuqun Aw'nln' F24 lansmg. Michigan 4891? 517.391-7358 THE ton I in 26 January 1984 Robert Miller Chief, Air Quality Division Department of Natural Resources P.D. Box 30028 Lansing, MI 48909 Dear Mr. Miller: 'At a public meeting on the Rockwell Drive Landfill (RDL) held 23 September 1983 at the Mapleton Elementary School I asked your staff representative to evaluate the inhalation route of exposure to the substances landfilled there and the substances detected in the sump water samples taken from the Kearns home in the RDL neighborhood. I followed up those oral compents with a written summary dated 5 October 1983 (Attachment 1). To date I have received no answers from your Division. Responses received from the Toxic Chemical Evaluation Section (Attachment 11) are inadequate. Please have your staff evaluate the health risks via the inhalation route of exposure to RDL contaminants from the landfill and sump water. Should you have any questions, please feel free to contact me. Sincerely, Larry E. Fink, M.S. Director Attachments cc: R. Johns . Courchaine . Hebert, ECDMM F-24 Lansmg. Michigan 48917 517-321-7358 TI-IE fon sociETy ?ur 26 January 1984 Robert Miller Chief, Air Quality Division Department of Natural Resources P.O. Box 30028 Lansing, MI 48909 Dear Mr. Miller: At a public meeting on the Rockwell Drive Landfill (RDL) held 23 September 1983 at the Mapleton Elementary School I asked your staff representative to evaluate the inhalation route of exposure to the substances landfilled there and the substances detected in the sump water samples taken from the Kearns home in the RDL neighborhood. I followed up those oral with a written summary dated 5 October 1983 (Attachment 1). To date I have received no answers from your Division. Responses received from the Toxic Chemical Evaluation Section (Attachment II) are inadequate. Please have your staff evaluate the health risks via the inhalation route of exposure to RDL contaminants from the landfill and sump water. Should you have any questions, please feel free to contact me. Sincerely, Larry E. Fink, M.S. Director Attachments cc: R. Johns . Courchaine . Hebert, ECDMM 8300 Michigan Avenue {:24 Lansmg. 48917 517-391-7353 m. lukhl . 0 STAT MICHIGAN DEPARTMENT OF NATURAL RESOURCES RONALD SKOOG. Reply to: State Office Building 4ll?J East Genesee Saginaw, Michigan 48607 January l2, l984 Mr. Larry Fink, M.S., Director Foresight Society 6300 N. Michigan Avenue Lansing, Michigan 489l7 Dear Mr. Fink: We appreciate the Opportunity to respond to your December 23, 1983 letter, and apologize for the delay in responding to your October 5,?1983 comments made in reference to the Dow Chemical Rockwell Road Landfill. Your comments of October 5, were submitted to both Dr. David Made of the Michigan Department of Public Health and Mr. Rich Powers, Toxic Chemical Evaluation Section, Department of Natural Resources. Dr. wade was requested to respond to your comment numbers and 2 on page 10 on page 2; and ll and l2 on page 3. Mr. Powers was asked to respond to number 3 on page l; 9 on page 2; and l4 on page 3. While staff have not yet received a written response to these questions, we do understand that they are working on them and have requested they reSpond directly to you under separate letters. The remaining questions will be addressed in the order and by number as indicated in your October 5, l983 comments. p.l You indicate contaminants the Mapleton the landfill is leaking and therefore the levels of may be increasing. It is our position, as it was at meeting, that the seeps that did occur have been controlled. Sampling done five days after leak detection, including areas of the seep a sediment from the drain to the south, indicated that the material had not migrated away from the area of the seeps. Later surface water (south drainage ditch) and monitor well sampling has indicated that contamination attributable to the landfill seeps had not occurred, but we will continue to monitor this situation. The area of the seeps was excavated and placed in a diked area and a closed-end trench was constructed along the west face of the landfill outside the clay wall. This was to collect any possible future seeps and prevent this material from entering the south drainage ditch. Dow Chemical has maintained this trench to date and removed all water, including rain water, for diSposal at the Midland Plant. Page 2 Mr. Larry Fink January 12, 1984 In response to the conditions at this landfill, Dow was requested to expedite the dewatering system installation to reduce the water level within the fill. The company installed four additional dewatering wells, for a total of six, with two being just inside the clay wall along the west face. The wells have been operating since August 26, 1983, and have to date removed in excess of 300,000 gallons of water from inside the fill. The water level is receding and a permanent fix of the clay wall/cap interface, to include the entire perimeter of the site, will be done when weather and conditions permit. The intent is to permanently dewater the site thru long term maintenance of the dewatering wells, with the result being that any migration of water, if it occurrs, would be towards the interiordiscussion of the material within the landfill, please see the enclosed Dow Chemical report received by the DNR August 2, 1979. Styrene has not shown up in any of the surface water or monitor well sampling, including inside the fill, in any of the samples collected in 1983. The quantity of the identified ethyl benzene manufacturing residues mixed with sand is contained within the area of encapsulation: Approximately 7 acres by 10 - 12 ft. deep. The materials detected in monitor wells, both inside and outside the fill, which includes surface water samples, you will find in two enclosed reports: One dated January 10, 1984, from Dow and one dated August 25, 1983, from staff to Bill Bradford. We have not yet received results from our last round of monitor well sampling done November 16, 1983, but there is no present indication of contamination in the outside monitor wells attributable to the landfill. The geology and hydrogeology in the vicinity of the site was addressed in a Williams and Horks study from November of 1979. This study has been reviewed by Department geologists. There is little data available to address the measured or estimated rate of migration of each substance, given the variables unique to this site, but the whole intent of regular sampling of the monitor wells is to determine if, in fact, there is migration of contaminants off site. Groundwater Quality Division staff, along with the reviewing geologist, are confident that the off-site migration of contaminants from this site would be detected in the existing monitor wells. Mr. Larry Fink Page 3 January 12, l984 The hydrogeological report indicated the following: The aquifer that had been impacted was moving in a west south?west direction. This is a perched aquifer and would have been and is forced to the surface approximately halfway between Rockwell Road and Bus Road by the underlying clay base, which is where the clay surfaces. This would therefore have prevented any contaminated water from reaching any known house under drains, particularly along Bus Road, but our investigation and monitoring continues. MN numbers sample this aquifer. The data concerning benzene within a clay liner, given characteristics of this situation, is not precise. Information currently available indicates that high concentrations of benzene do in fact penetrate clay more rapidly than water, but data on water penetration that is contaminated with low levels of benzene (or the benzene separation/ penetration in water) is not yet available. He would like to point out again, however, that we feel the existing monitor wells would detect such a penetration and the dewatering will in effect cause the migration of water to be towards the inside. In addition to the above, I would like to point out that a second round of surface water sampling was done on October l7, 1983. Two sets of samples were taken from each location, with one set being sent to an outside laboratory, Mead Compu Chem, while the other set was given to the DNR's lab. Mead's report indicated that of the 114 organic compounds tested for in each sample, they were all non-detectable to their detection limit, which was, for most compounds, lO ug/l (ppb). A copy of their results are enclosed, and please feel free to contact us if you wish to review their entire report, which is rather We also hope to have our own laboratory's report shortly from those samples, as well as the previously mentioned November l6, l983 monitor well results. 1 hope this addresses your concerns pertinent to this office relative to your October 5, l983 comments. Please contact me or Dan Schultz at the Saginaw District Office if you have any questions or comments. Finally, your comments in the December 23, l983 letter relative to the limits of detection have been forwarded to Mr. George Jackson and the laboratory for response. They will be submitting those to you directly by separate letter. Mr. Larry Fink Page 4 January 12, 1984 aniosure :amc CC: L. A. Skoog . Guenther Hoicomb, TSCC Niison, ECOMM . Johns, GHQ-DHR Dennis, D. Wade, MDPH Powers, Sincereiy, Ronald D. Kooistra, P.E. Saginaw District Supervisor Groundwater Quaiity Division (517) 771?1731 0 I.i Iiir-I ll] alum! (Hun-"0 I . I. JAMES J. BLANCHARD. Govemor HONM 0 SKUOG, Dirt-um Reply to: State Office Building 4ll-J East Genesee Saginaw, Michigan 48607 January l2, l984 Mr. Larry fink, M.S., Director Foresight Society 6300 N. Michigan Avenue Lansing, Michigan 48917 Dear Mr. Fink: He appreciate the Opportunity to respond to your December 23, l983 letter, and apologize for the delay in responding to your October 5,_l983 comments made in reference to the Dow Chemical Rockwell Road Landfill. Your comments of October 5, were submitted to both Dr. David Made of the Michigan Department of Public Health and Mr. Rich Powers, Toxic Chemical Evaluation Section, Department of Natural Resources. Dr. Hade was requested to respond to your comment numbers and 2 on page l; l0 on page 2; and ll and l2 on page 3. Mr. Powers was asked to reSpond to number 3 on page l; 9 on page 2; and l4 on page 3. While staff have not yet received a written response to these questions, we do understand that they are working on them and have requested they respond directly to you under separate letters. The remaining questions will be addressed in the order and by number as indicated in your October 5, l983 comments. p.l - You indicate the landfill is leaking and therefore the levels of contaminants may be increasing. It is our position, as it was at the Mapleton meeting, that the seeps that did occur have been controlled. Sampling done five days after leak detection, including areas of the seep a sediment from the drain to the south, indicated that the material had not migrated away from the area of the seeps. Later surface water (south drainage ditch) and monitor well sampling has indicated that contamination attributable to the landfill seeps had not occurred, but we will continue to monitor this situation. The area of the seeps was excavated and placed in a diked area and a closed-end trench was constructed along the west face of the landfill outside the clay wall. This was to collect any possible future seeps and prevent this material from entering the south drainage ditch. Dow Chemical has maintained this trench to date and removed all water, including rain water, for disposal at the Midland Plant. Mr. Larry Fink Page 2 January l2, l984 In response to the conditions at this landfill, Dow was requested to expedite the dewatering system installation to reduce the water level within the fill. The company installed four additional dewatering wells, for a total of six, with two being just inside the tlay wall along the west iace. The wells have been operating since August 26, l983, and have to date removed in excess of 300,000 gallons of water from inside the fill. The water level is receding and a permanent fix of the clay wall/cap interface, to include the entire perimeter of the site, will be done when weather and conditions pennit. The intent is to permanently dewater the site thru long term maintenance of the dewatering wells, with the reselt being that any migration of water, if it occurrs, would he towards the interior. - 8, liege _2 3 4. For a discussion of the material within the landfill, please see the enclosed Dow Chemical report received by the DNR August 2, l979. Styrene has not shown up in any of the surface water or monitor well sampling, including inside the fill, in any of the samples collected in 1983. The quantity of the identified ethyl benzene manufacturing residues mixed with sand is contained within the area of encapSUlation: Approximately 7 acres by TD - l2 ft. deep. The materials detected in monitor wells, both inside and outside the fill, which includes surface water samples, you will find in two enclosed reports: One dated January l0, l984, from Dow and one dated August 25, l983, from staff to Bill Bradford. We have not yet received results from our last round of nmnitor well sampling done November 16, 1983, but there is no present indication of contamination in the outside monitor wells attributable to the landfill. The geology and hydrogeology in the vicinity of the site was addressed in a Williams and Horks study from November of l979. This study has been reviewed by Department geologists. There is little data available to address the measured or estimated rate of migration of each substance, given the variables unique to this site, but the whole intent of regular sampling of the monitor wells is to determine if, in fact, there is migration of contaminants off site. Groundwater Quality Division staff, along with the reviewing geologist are confident that the off?site migration of contaminants from this site would be detected in the existing monitor wells. Mr. Larry Fink . I Page 3 - January l2, l984 . . The hydrogeological report indicated the following: The aquifer that had been impacted was moving in a west south-west direction. This is a perched aquifer and would have been and is forced to the surface approximately halfway between Rockwell Road and Bus Road by the underlying clay base, which is where the clay surfaces. This would therefore have prevented any contaminated water from reaching any known house under drains, particularly along Bus Road, but our investigation and monitoring continues. MN numbers sample this aquifer.? #434. 33922 The data concerning-benzene within a clay liner, given characteristics of this situation, is not precise. Information currently available indicates that high concentrations of benzene do in fact penetrate clay more rapidly than water, but data on water penetration that is contaminated with low levels of benzene (or the benzene separation/ penetration in water) islnot yet available. We would like to point out again, however, thatlwe feel the existing monitor wells would detect such a penetration and the dewatering will in effect cause the migration of water to be towards the inside. In addition to the above, I would like to point out that a second round of surface water sampling was done on October 17, l983. Two sets of samples were taken from each location, with one set being sent to an outside laboratory, Mead Compu Chem, while the other set was given to the DNR's lab. Mead's report indicated that of the ll4 organic compounds tested for in each sample, they were all non-detectable to their detection limit, which was, for most compounds, l0 ug/l (ppb). A copy of their results are enclosed, and please feel free to contact us if you wish to review their entire report, which is rather We also hOpe to have our own laboratory's report shortly from those samples, as well as the previously mentioned November 16, l983 monitor well results. . I hope this addresses your concerns pertinent to this office relative to your October 5, l983 comments. Please contact me or Dan Schultz at the Saginaw District Office if you have any questions or comments. Finally, your comments in the December 23, l983 letter relative to the limits of detection have been forwarded to Mr. George Jackson and the laboratory for response. They will be submitting those to you directly by separate letter. Mr, Larry Fink Page 4 January 12,-1984 Enciosure CC: R. Skoog G. Guenther L. Holcomb, TSCC A. Hiison, ECOMM R. Johns, D. Dennis, GNQ-DNR Dr. D. Wade, MDPH R. Powers, Qt Sincerely, Ronaid D. Kooistra, P.E. Saginaw District Supervisor Groundwater Quality Division (517) 771?1731 I 5. IA ll Ul i/?u?J Governor now/u Li State Office Building 4ll?J East Genesee Saginaw, Michigan Reply to: 48607 January l2, l984 lir. l.iiw inl l4. S. lnre'jsighl. Society '0300 N. Michigan Avenue l.innirni, 489l7 Dear Mr. link: we appreciate the Opportunity to respond to your December 23, l983 letter, and apologize for the delay in responding to your October 5,?l983 comments in reference to the Dow Chemical Rockwell Road Landfill. Your comments of 5, were submitted to both Dr. David Made of the Michigan Department oi Public Health and Mr. Rich Powers, Toxic Chemical Evaluation Section, Department of Natural Resources. Dr. Hade was requested to respond to your comment numbers and 2 on page 1; l0 on page 2; and ll and l2 on page 3. Mr. Powers was asked to respond to number 3 on page l; 9 on page 2; and T4 on page 3. While staff have not yet received a written response to these questions, we do understand that they are working on them and have requested they respond directly to you under separate letters. The remaining questions will be addressed in the order and by number as indicated in your October 5, 1983 comments. p.l - You indicate the landfill is leaking and therefore the levels of contaminants may be increasing. It is our position, as it was at the Mapleton meeting, that the seeps that did occur have been controlled. Sampling done five days after leak detection, including areas of the seep a sediment from the drain to the south, indicated that the material had not migrated away from the area of the seeps. tater surface water (south drainage ditch) and monitor well sampling has indicated that contamination attributable to the landfill seeps had not occurred, but we will continue to monitor this situation. The area of the seeps was excavated and placed in a diked area and a closed-end trench was constructed along the west face of the landfill outside the clay wall. This was to collect any possible future seeps and prevent this material from entering the south drainage ditch. Dow Chemical has maintained this trench to date and removed all water, including rain water, for diSposal at the Midland Plant. Page 2 Mr. Larry Fink January l2, l984 In response to the conditions at this landfill, Dow was requested to expedite the dewatering system installation to reduce the water level within the fill. The company installed four additional dewatering wells, for a total of six, with two being just inside the clay wall alung the west iace. The wells have been operating since August 20, 1903, and have to date removed in excess of 300,000 gallons of water from inside the fill. The water level is receding and a permanent fix of the clay wall/cap interface, to include the entire perimeter of the site, will be done when weather and conditions pennit. The intent is to permanently dewater the site thru long term maintenance of the dewatering wells, with the result being that any migration of water, if it occurrs, would he towards the interior. Fldiscussion of the material within the landfill, please see the enclosed Dow Chemical report received by the DNR August 2, l979. Styrene has not shown up in any of the surface water or unnitor well sampling, including inside the fill, in any of the samples collected in l983- The quantity of the identified ethyl benzene manufacturing residues mixed with sand is contained within the area of encapsulation: Approximately 7 acres by 10 - l2 ft. deep. The materials detected in monitor wells, both inside and outside the fill, which includes surface water samples, you will find in two enclosed reports: One dated January l0, l984, from Dow and one dated August 25, l983, from staff to Bill Bradford. We have not yet received results from our last round of nmnitor well sampling done November l6, l983, but there is no present indication of contamination in the outside monitor wells attributable to the landfill. The geology and hydrogeolOQy in the vicinity of the site was addressed in a williams and Dorks study from November of l979. This study has been reviewed by Department geologists. There is little data available to address the measured or estimated rate of migration of each substance, given the variables unique to this Sltv, but the whole intent of regular sampling of the monitor wells is to determine if, in fact, off site. there is migration of contaminants Groundwater Quality Division staff, along with the reviewing geologist, are confident that the off-site migration of contaminants from this site would be detected in the existing monitor wells. l'll'. Larry link Page 3 January l2, l984 The hydrogeological report indicated the following: The aquifer that had been impacted was moving in a west south-west direction. This is a perched aquifer and would have been and is forced to the surface approximately halfway between Rockwell Road and Bus Road by the underlying clay base, which is where the clay surfaces. This would therefore have prevented any contaminated water from reaching any known house under drains, particularly along Bus Road, but our investigation and monitoring continues. MW numbers sample this aquifer. at _l P9 ge_ :3 The data concerning benzene within a clay liner, given characteristics of this situation, is not precise. Information currently available indicates that high concentrations of benzene do in fact penetrate clay more rapidly than water, but data on water penetration that is contaminated with low levels of benzene (or the benzene separation/ penetration in water) is not yet available. We would like to point out again, however, that we feel the existing monitor wells would detect such a penetration and the dewatering will in effect cause the migration of water to be towards the inside. In addition to the above, I would like to point out that a second round of surface water sampling was done on October 17, l983. Two sets of samples were taken from each location, with one set being sent to an outside laboratory, Mead Compu Chem, while the other set was given to the DNR's lab. Mead's report indicated that of the ll4 organic compounds tested for in each sample, they were all non-detectable to their detection limit, which was, for most compounds, l0 ug/l (ppb). A copy of their results are enclosed, and please feel free to contact us if you wish to review their entire report, which is rather we also hope to have our own laboratory?s report shortly from those samples, as well as the previously mentioned November l6, 1983 monitor well results. 1 hope this addresses your concerns pertinent to this office relative to _ynur October 5, l983 comments. Please contact me or Dan Schultz at the Saginaw District Office if you have any questions or comments. Finally, ynur rnmments in the Detumber 23, l983 letter relative to the limits of detection have been forwarded to Mr. George Jackson and the laboratory for They will be submitting those to you directly by separate letter. Mr. Larry Fink Page 4 January 12, 1984 [HLlhaHrw RUbi?zamc CCSkooq Guenther Huicomb, TSCC Hiison, LCOMM Juhns, Dennis, U. Wade, MUPH Powers, TCES-DNR Sincerely, @0241? Ronaid D. Kooistra, P.E. Saginaw District SuperviSOr Groundwater Quaiity Division (517) 771?173] t. I A I II. OI MICHIGAN d?b some" JAMES J. BLANCHARD. Governor DEPARTMENT OF NATURAL RESOURCES HUNAL SKDOG. State Office Building 4ll-J East Genesee Saginaw, Michigan Reply to: 48607 January l2, 1984 Mr. Larry fink, M.S., Director Foresight Society 6300 N. Michigan Avenue Lansing, Michigan 48917 Dear Mr. fink: we appreciate the Opportunity to respond to your December 23, l983 letter, and apologize for the delay in responding to your October 5, l983 comments made in reference to the Dow Chemical Rockwell Road Landfill. Your comments of October 5, were submitted to both Dr. David Made of the Michigan Department of Public Health and Mr. Rich Powers, Toxic Chemical Evaluation Section, Department of Natural Resources. Dr. Hade was requested to respond to yOur comment numbers and 2 on page l; 10 on page 2; and ll and 12 on page 3. Mr. Powers was asked to respond to number 3 on page l; 9 on page 2; and l4 on page 3. While staff have not yet received a written response to these questions, we do understand that they are working on them and have requested they respond directly to you under separate letters. The remaining questions will be addressed in the order and by number as indicated in your October 5, 1983 comments. p.l You indicate the landfill is leaking and therefore the levels of contaminants may be increasing. It is our position, as it was at the Mapleton meeting, that the seeps that did occur have been controlled. Sampling done five days after leak detection, including areas of the seep a sedinent from the drain to the south, indicated that the material had not migrated away from the area of the seeps. Later surface water (south drainage ditch) and monitor well sampling has indicated that contamination attributable to the landfill seeps had not occurred, but we will continue to monitor this situation. The area of the seeps was excavated and placed in a diked area and a closed-end trench was constructed along the west face of the landfill outside the clay wall. This was to collect any possible future seeps and prevent this material from entering the south drainage ditch. Dow Chemical has maintained this trench to date and removed all water, including rain water, for disposal at the Midland Plant. I I Mr. Larry Fink Page 2 January 12, l984 In response to the conditions at this landfill, Dow was requested to expedite the dewatering system installation to reduce the water level within the fill. The company installed four additional newatering wells, for a total of six, with two being just inside the clay wall along the west lace. The wells have been operating since August 26, l983, and have to date removed in excess of 300,000 gallons of water from inside the fill. The water level is receding and a permanent fix of the clay wall/cap interface, to include the entire perimeter of the site, will be done when weather and conditions permit. The intent is to permanently dewater the site thru long term maintenance of the dewatering wells, with the result being that any migration of water, if it occurrs, would he towards the interior. a 8, Page 2 3 4. For a discussion of the material within the landfill, please see the enclosed Dow Chemical report received by the DNR August 2, l979. Styrene has not shown up in any of the surface water or monitor well sampling, including inside the fill, in any of the samples collected in 1983. The quantity of the identified ethyl benzene manufacturing residues mixed with sand is contained within the area of encapsulation: Approximately 7 acres by l0 - l2 ft. deep. The materials detected in monitor wells, both inside and outside the fill, which includes surface water samples, you will find in two enclosed reports: One dated January l0, l984, from Dow and one dated August 25, l983, from staff to Bill Bradford. We have not yet received results from our last round of nmnitor well sampling done November l6, l983, but there is no present indication of contamination in the outside monitor wells attributable to the landfill. The geology and hydrogeology in the vicinity of the site was addressed in a Williams and Works study from November of l979. This study has been reviewed by Department geologists. lhere is little data available to address the measured or estimated rate of migration of each substance, given the variables unique to this site, but the whole intent of regular sampling of the monitor wells is to determine if, in fact, there is migration of contaminants off site. Groundwater Quality Division staff, along with the reviewing geologist, are confident that the off-site migration of contaminants from this site would be detected in the existing monitor wells. Mr. Larry link Page 3 January l2, 1984 The hydrogeological report indicated the following: The aquifer that had been impacted was moving in a west south~west direction. This is a perched aquifer and would have been and is forced to the surface approximately halfway between Rockwell Road and Bus Road by the underlying clay base, which is where the clay surfaces. This would therefore have prevented any contaminated water from reaching any known house under drains, particularly along Bus Road, but our investigation and monitoring continues. MW numbers sample this aquifer. ff 13; Base 2 The data concerning benzene within a clay liner, given characteristics of this situation, is not precise. Information currently available indicates that high concentrations of benzene do in fact penetrate clay more rapidly than water, but data on water penetration that is contaminated with low levels of benzene (or the benzene separation/ penetration in water) is not yet available. We would like to point out again, however, that we feel the existing monitor wells would detect such a penetration and the dewatering will in effect cause the migration of water to be towards the inside. In addition to the above, I would like to point out that a second round of surface water sampling was done on October l7, l983. Two sets of samples were taken from each location, with one set being sent to an outside laboratory, Mead Compu Chem, while the other set was given to the DNR's lab. Mead's report indicated that of the ll4 organic compounds tested for in each sample, they were all non-detectable to their detection limit, which was, for most compounds, l0 ug/l (ppb). A copy of their results are enclosed, and please feel free to contact us if you wish to review their entire report, which is rather We also hope to have our own laboratory's report shortly from those samples, as well as the previously mentioned November l6, l983 monitor well results. I hope this addresses your concerns pertinent to this office relative to your October 5, l983 comments. Please contact me or Dan Schultz at the Saginaw District Office if you have any questions or comments. Finally, ynur comments in the UUtumher 23, l983 letter relative to the limits of detection have been forwarded to Mr. George Jackson and the laboratory for rwupun?u. They will be submitting those to you directly by separate letter. Mr. Larry Fink Page 4 January 12, 1984 I imam .- RUKzszunn CC: R. l. EM Dr. R. Skooq Ganthor Holcomb, THEE 1 St)!i [:f)i4i4 Johns, Uvnnis, U. Nude, MUPH Powers, Sincereiy, Ronald D. Kooistra, P.I. Saginaw District Supervisor Groundwater Quaiity Division (517) 771~1731 fonesiqln sociETy . 23 December 1983 Mr. Richard S. Johns Chief, Groundwater Quality Division Dept. of Natural Resources P90. Box 30028 Lansing, MI 48909 Dear Mr. Johns: Thank you for copying your 12 December 1983 reply to Andrea Wilson's 29 September 1983 letter to Director Skoog regarding DNR actions to character- ize, quantify and control the routes and rates of loss of toxic substances pnesent in the Rockwell Drive Landfill (RDL) to the environment. Unfortu? nately, I have yet to receive answers to the questions I posed verbally to Department of Natural Resources staff at the 22 September 1983 RDL meeting at Mapleton Elementary School which I submitted in writing in a follow-up letter dated 5 October 1983 in response to a DNR staff request. What is the status of the staff reply to those questions? When can I expect written answers to those questions? . Questions have also arisen as to the adequacy of the reported limits of detection of the sampling and analytical methods employed by DNR staff or their contractors in the most recent round of RDL sampling and analysis. The adequacy of a particular combination (If sampling and analytical methods is determined by the concentration of the substance at and below whiCh there is no regulatory concern. That concentration of regulatory concern is deter? mined by the toxicological pr0perties of the substance and the dose-response model adopted. A particular combination of sampling and analytical methods is adequate if the level of quantitatibn (see Dow NPDES Permit MI 0000868 [April 21, 1982] for definition adopted by DNR staff) is at or below the level of concern. Risk assessment should be used as a guidance for the identifica- tion of adequate sampling-analytical methods. The limit of detection of an existing sampling-analytical method should not be used to define an acceptable risk. - "For example, the concentration of benzene in drinking water estimated by multi?sta e, linear dose-reSponse model to represent an increased cancer risk of 10- is approximately 6 parts per billion, if my memory serves me correctly. Thus, a benzene limit of detection of 10 parts per billion is wholly inappropriate in sampling and analyzing RDL water samples. Thank you in advance for expediting a staff reply. Should you have any questions, please feel free to contact me. Sincerely, @3344 I arry E. Fink, M.S. Director Skoog, DNR Guenther, DNR Holcomb, TSCC Wilson, ECOMM CC: Ell??7330 6300 W. Michigan Avenue F-24 Lansing. Michigan 4891? 517-321-7358 . A September 19, 1930 I 55p 20 1980 '7 n'rtar'fdu mmomv??i Dow Chemical Company -. Midland, Michigan 48640 Re: Land adjacent to Rockwell Road Landfill . .. Bay/Midland Counties, Project Number 706- . . . .-. - Dear Mr. Ilgenfritz: While landfill construction to provide containment of wastes is nearing completion; the contaminated_grounduater west Rockwell Road hadFEQEEbeen addreegegj" ..Z. - - f" ., It has been determined that the contaminated water perched on a sub- . . .f surface clay layer must be purged and treated, or confined. This decis- based on the interpretations of the available data by Department .. .Q of Natural Resources staff. The recommendation made in your study, titled "Hydrogeologic Invest- igation of Leachate Plume", is to allow time to analyze the leachate breakdown characteristics and_to determine whether "natural processes . . will clean the aquifer". The June 18, 1980, monitoring H011 sample results show that the can: tanination remains. Enough risk exists, that the natural degradation ?fEdEEf3?5fE??aiafdous materials and that they could be released at a point where the perched aquifer discharges to the surface, to make purging or containment necessary. . Please note that Tom Rohrer, Department of Natural Resources, Office of Toxic Materials Control, has stated the following parameters should be_tested for to establish the presence or absence of ants: Benzene, toluene, styrene (monomeric and polynuclear aromatic hydrocarbons, phenolics, TOG, freon extractable oils and trichloroethylene. -, 1 1' . September 4, i980 TO: Rich Sadowski, Resource Recovery Division FROM: Jennifer Daniels, Water Quality Division SUBJECT: Dom Chemicalc?lsposaihSLIQs Sec 3i, R35, Williams Township, BawaQunty_. in July of i980, you requested our Section review a hydrogeoi09icai study for the above site. in the study, Dennis Globens and Works states that (the major constituent leached from the landfill prior to encapsulation) will blodcgrade and will not pose a threat to the environment or public health. After reviewing the conyinced the situation elf without??fe?g?fl??;any problems. According to Tom Rohrer of Toxic Materials Control Section, ethyibenzene will denrado to benzene and toluene. _Ail three are found in the perched aquifer at purgabio levels. and Q?_jhe_l979 CMR. is on the i979 CMR list of chemicals to be reviewed in [980. In July of i980, Dow Chemical collected additional samples from monitoring wells l, 6, 7, 8 and 9. The TOC data for this sam lin indicate there is aquifer that haye_aot been detected jhan fir-"51? analysis showed. . At this point i feel we should request that Dow Chemical have their consultants design a purging system for review_and approval of the DNR. If you should have any questions, please contact me. kp 4 Figure CD IO TABLE OF CONTENTS I. INTRODUCTION II. HYDROGEOLOGY RegionaI GeoIogy Drainage Stratigraphy of the Site Groundwater PRELIMINARY DESIGN IV. PROPOSED MONITORING PLAN APPENDICES A - Private and Boring Logs Obtained from the Michigan GeoIogicaI Survey Figure A-I: Location of Private and Borings DriIIer's Logs of and Borings Data Sheets for Laboratory Soi] Tests LIST OF FIGURES Location PIan Preperty Ownership Map Drainage Map Locations of and Borings Summary of Logs ContOur Map of Clay Surface Summary of Logs and Laboratory Data for the Split-Spoon Borings Log of Deep Boring Contour Map of the Water TabIe in the ShaIIow Perched Aquifer PreIiminary Design for EncapsuIating the ChemicaI Wastes 03-33-wa I0 II Foliows Page IO '1 PLANNERS I ARCHITECTS SURVEYORS GEOLOGISTS I CHEMISTS - 611 CASCADE WEST PKWY . E.. GRAND RAPIDS. MI 49506 'PHrl6161N2-ap WILLIAMS 89WORKS ro lam-IBM - FD wean: 1550-1031 - we 1095-19?4 July 26, 1979 Mr. Jeff Nielsen Dow Chemical Company 47 Building Midland, Mi. 48640 Dear Mr. Nielsen: This report presents the findings and conclusions of the hydrogeologic inves- tigation of the chemical disposal site along Rockwell Road. In summary, the investigation shows the site lies on which are in turn underlain by a thick (greater than 40 feet) clay Substratum. This clay is horizontally extensive over a regional area. A perched groundwater aquifer was found in the shallow sand. water moves in a west by southwest direction in this aquifer. The chemical wastes on the site are detectable in this aquifer west of Rockwell Road, indicating a chemical plume is moving westward from the site. Based on the hydrogeology of the site, this report concludes that the chemical disposal area can be encapsulated using the native clay substratum as the base. A preliminary design for an encapsulating structure is given, and a future monitoring plan is proposed. Williams and Works appreciates the opportunity to work with you on this project, and we remain available to assist you in the future. Very truly yours, Williams Works, Inc. Dennis J. Geb en I. INTRODUCTION This report presents the results of a hydrogeologic investigation conducted for Dow Chemical Company at a chemical disposal site used from 1955 to 1958. This site covers approximately 10 acres and is located along Rockwell Road in the west side of Section 31, T14N, R3E, Williams Township, Bay County. The location of the site in respect to Midland City is shown in Figure 1. In the fifties, Dow disposed of tank bottom sludges from the production of ethyl benzene by mixing the sludge into the sandy soils of the site. These sludges have the appearance and consistency of tar and, where exposed at the surface, resemble broken-up asphalt. Analytical tests to determine the chemistry of this material have been made by Dow. The results of these analyses are not included in this report, but will be reported on separately by Dow. In recent years, Federal and State standards have been proposed for the disposal of industrial wastes. In light of these standards, Dow has decided to evaluate the environmental effects of this old disposal area and upgrade the site as necessary to meet the present criteria for land disposal of industrial wastes. To that end, this report provides the hydrogeologic information basic to the design of an ?encapsulating? structure around the disposal area. The field work done for the hydrogeologic investigation consisted of the following: 1. Eleven observation wells were installed in a shallow, perched aquifer located in the sand that covers the site. These wells are 7 to 16 feet deep and were installed both within and around the perimeter of the site to determine water quality and the direction of ground water movement. 2. Three 50*foot deep borings were drilled from which continuous split- spoon soil cores were collected. Laboratory permeability and grain size analyses were run on representative core samples. The borings penetrated 42 to 50 feet into the clay that underlies the site and were drilled to determine whether the underlying clay layer isolates and protects usable aquifers from the chemical wastes. I i present No usable aquifer was found; therefore, the boring was plugged with bentonite and abandoned. Property owned by Dow or Dow Corning in the vicinity of the site is shown on I Figure 2. Thu war), I . 15 10 I: FIGURE I LEGEND: LOCATION PLAN CITY LIMITS OF MIDLAND DOW CHEMICAL CO. MIDLAND. MICH. GRAND MICHIGA I WORKS. INC. 1 RI I-J 0 '000 .000 .000 JULY3979 85442 . II. HYDROGEOLOGY within a nine section area centered around the site (Appendix A). Bedrock in the area is approximately 150 to 230 feet deep and most of the overlying glacial sediments are clayey. However, textural variations do evidenced by deep boring logs (Appendix A) that record layers of silt and varying amounts of sand and gravel mixed in with the clay. Aquifer material is also found in some of the logs; however, at depths of less than 50 feet, these layers of permeable material are thin and rarely found. Most private 100 feet. This variation within the predominantly clay sediment is reasonable in light of the geologic history of the area. Four major periods of continental glac- iation have occurred in Michigan. Of these, only the most recent lends itself to the spatial mapping of the sediments and the interpretation of corresponding depositional histories. With increased depth, the genetic origin of the sediments becomes harder to identify, particularly for sediments deposited during earlier glacial periods. It is known that the lakebed clay at or near the surface often grades with depth into clay tills; but that change from water-deposited to ice-deposited sediment is not always easily recognized. For the purposes.of this report, the importance of stratigraphic detail decreases with depth; therefore, no major effort was made to determine the stratigraphic continuity of sediments below 50 feet. DRAINAGE community of Mapleton where drainage pattern is shown on OF THE silg South and west of the ce along the flank of the sand ridge at Eleven observation wells are installed in in Figure 4. approximately the 630-foot contour. the sand layer at the locations shown wells are in Appendix and a graphi installing these wells, The driller's logs of these summary is shown in Figure 5. I the clay layer. Therefore, pea-gravel was poured down the augers as they were retracted. This left a column of he well the entire saturated thickness of the sand layer. in order to facilitate hollow stem of the 8-inch gravel that enveloped umping these wells, screen and extends Only Well #11, is deposited. This wel strong odor were note found, probably marki sludges were in which.b1ts.9f tar and At 7 feet, 0.5 foot of topsoil was surface. .Below this, bits of tar ersisted. d.in the upper 7 feet. ng the original ground were not found, but the strong chemical odor thickness of 15 feet (Well wells, typified by fine sand that becomes increasingly silty with depth. A one-foot peat layer was found in Well The sand profiles are similar in all of these This shows Low areas in the clay exist both east and west of the site with a trough connecting the low The surface of the underlying clay layer is contoured in Figure 6. that the clay has approximately six feet of relief over the site. area around Well #4 to the low area around Wells #7 and The clay rises along the south border of the site, and a slight ridge extends east and west between Wells #3 and #10. 3 relatively low number The thickness and character of this clay was explored by means of three 50- foot deep borings from which split-spoon cores were recovered. The locations of these borings are shown on Figure 4, and the driller's logs are in Appendix 8. Figure 7 summarizes these logs and presents the results of the laboratory permeability and grain size analyses that were run on selected samples. In all three borings, the clay substratum is a sandy, silty, plastic, clay with a The thickest sand zone is at Boring 1 where a 1.2~foot layer was found at 45.8 to 47.0 feet and a 1.5+ foot layer was found from 48.5 feet to the end of the boring at 50 feet. In Boring 2, a 5-foot thick silt layer was found between 36 and 41 feet. Laboratory analysis of few fine lenses of sand and silt found mainly below 35 feet. a sample from this silt indicates that it is also very The of blows needed to drive the split-spoon sampler clayey and sandy, and has a low permeability of 1.99 10-8 cm/sec. indicates that most of the clay is plastic. Stiff zones were found below 37 feet in both Borings 1 and 3. Nineteen samples were analyzed in the laboratory for permeability and grain size. The laboratory data sheets are in Appendix C, and a summary is shown on Permeabilities range from a high of 7.58 10'7 cm/sec to a low of Figure 7. 4.33 10- cm/sec. 7 10-7 cm/sec; however, only two were greater than 1.33 10 cm/sec. Most 9 Five permeability tests yielded results greater than 1.0 permeabilities are in the 10"8 order of magnitude, and this value can be considered the general vertical permeability of the clay substratum311?nun-unn-uunn-unnma The relative proportions of sand, silt and clay in each of the laboratory samples are also shown on Figure 7. Qlay ranged from 27.5 to 74.4 percent; silt ranged from 6.9 to 56.7 percent; and sand accounted for 10.2 to 41.5 percent. In genera], the samples showed a good mix between these textural components with clay usually the major constituent. Northeast of the site, at the location shown on Figure 3, a boring was drilled 100 feet deep. log of that boring is shown on Figure 8. The purpose of this boring was to locate a deep aquifer. The As the log shows, no aquifer material was encountered; therefore, a well was not set and the boring was plugged with bentonite. GROUNDWATER Water levels were measured in the observation wells on May 30, 1979, and are listed on the well logs in Appendix 8. Based on these levels, a contour map of The natural direction of groundwater movement in the area is west by southwestf_ This the perched water table above the clay is shown on Figure 9. pattern has been altered somewhat by the ditch along the east side of the site and shallow ponds on the north end of the site. Also a_??ight mound_of . groundwater-was found_in the filled area. This mound and the depression in the water table near the ditch and ponds is a seasonal effect that is most pronounced during the wet spring season when recharge and groundwater levels are up. This effect is attenuated during the dry season when the water table reportedly falls below the level of the ditch bottom causing the ditch to dry up. Although the movement of groundwater within the sand layer is generally to the west by southwest, the exact path and speed of travel is varied. This The sand layer does not have uniform is cleaner near the top of the water to a number of factors. The sand lil a higher permeability and la greater rate of water is due permeability throughout. resulting Also, when the water table is high in the spring, much of it is column, movement. diverted to the ditch and ponds from where it drains away as surface water. Near the bottom of the sand layer, groundwater movement is slower because of the lower permeability and the flow follows the contour of the clay surface. The contour of the clay controls the path of movement for the groundwater 5 during dry seasons when the saturated thickness of the water does not exceed tt rr?ief :Tay subsurface. When water levels were measured on May 30th, the saturated thickness in the sand was about nine feet in most of the wells. for a shallow perched aquifer; therefore, during the summer, it is probable Three to six feet of seasonal groundwater fluctuation is not unusual 'that the high areas shown on the clay contour map (Figure 6) are above the water table. Rainfall and snowmelt are the sources of water that recharge the perched aquifer. Water discharges from the aquifer mainly through evapotranspiration and seepage to the surface. On the site, some seepage occurs into the ditch along the east and south border. Surface discharge zones for groundwater west of Rockwell Road have not been documented in this study. However, based on the boundary :rf the sand ridge as interpreted from the USGS topographic quadrangle, it is presumed that the sand ends at about the 630-foot contour; and seepage from the perched water table would be suspected along this line, particularly during wet seasons. Water samples were collected from all of the observation wells; and analyses for chloride, hardness, iron, nitrate, pH, sulfate and specific conductance were conducted in the Williams Works laboratory. Dow also conducted organic analyses on a second set of water samples. The results of the tests run by williams 3. works are given in Table 1. Hells? #T\'and show the greatest effect of the disposal site on the groundwater. These two wells are west of the site and are in the area where the underlying clay is topographically low. In these wells, chlorides measured 5,400 and 2,800 mg/l, iron measured 59 and 20 mg/l, and hardness measured 7,300 and 3,800 mg/l. Also, the pH was lower with values of 5.9 and 6.2. The other two wells on the west side of the site (Wells #6 and yield elevated levels of chloride and hardness compared to background levels found in wells east and north of the site. Well #11, which is in the disposal area, did not surpass the chemical levels found in Wells #7 and except for sulfate. The lower concentrations are explained by the fact that the screen for Well #11 is set below the buried topsoil horizon that was covered by the and horizontai movement of the groundwater is a much iarger component than verticai. The 250 mg/1 of sulfate from Weii #11 is anomaious since it is much lower in a1] the other weiis. waste fi11, In summary, the groundwater quality data confirms eariier conciusion on the direction of groundwater movement and indicates that a ieachate plume has spread westward from the disposai site to some undetermined distance. TABLE Results of Inorganic Analyses of Water Samples from the Observation Wells (in mg/l unless otherwise notedHELL CHLORIDE HARDNESS IRON NITRATE Eg?g?g?gi?E SULFATE 1 44 180 0.200 0.240 0.420 0.02 0.0 7.5 720 55 6 143 340 0.03 0.0 7.2 760 73 7 5400 7300 59 0.2 5.9 9500x 28 8 2500 3800 20 0.1 6.2 6000 0 9 410 740 0.51 0.0 7.4 1400 67 10 3 170 0.45 0.0 7.7 390 53 11 210 1000 0.68 0.0 7.4 1600 250 1 g/ yahos PRELIMINARY DESIGN Based upon the hydrogeology of the area and the effect the disposal site has on the shallow perched groundwater, two main areas of concern are recognized. The first is the disposal area itself and how to isolate it from the environ- ment, which is the subject of this "Preliminary Design? section. The other area of concern is the groundwater west of the site that is affected by the leachate plume. This report will not address that issue, since it is Dow?s intent to deal separately with that concern at a later date. The Resource Recovery Division of the Michigan Department of Natural Resources (MDNR) is now in the process of formulating administrative rules which will include design guidelines for landfilling various types of solid waste. Assuming that the chemical wastes on this site would require a Type I landfill design, a preliminary plan shown in Figure 10 was developed. Basically, the design is a clay structure that totally encapsulates the waste. The natural clay substratwn provides a base that will prevent downward migration of chemicals to deeper groundwater aquifers. This clay base exceeds the minimum 20-foot thickness proposed by the MDNR and also meets the MDNR's permeability requirement of less than 1.0 10-7 cm/sec. Keyed into this clay base would be a 10-foot wide clay dike that would completely encircle the waste material. This dike would be built in 9-inch compacted lifts to achieve a permeability of 1.0 10?7 cm/sec or less. A two to three-foot thick clay cover would be placed over the waste material forming a graded slope of 2.5 percent to ensure effective runoff. The hydraulic head of the groundwater outside the dike would be maintained at less than five feet by installing subsurface drains around the outside of the dikes. The plan suggests that these drains be constructed of coarse aggregate envelOped in a filter fabric as illustrated in Figure 10. A shallow ditch would also parallel the dike along Rockwell Road to collect surface runoff from the clay cover. Elevation differences are sufficient so that this ditch and the subsurface drains would gravity drain southward to the ditch along Rockwell Road. 10 I . IV. PROPOSED MONITORING PLAN Solid waste land disposal regulations require a groundwater Inonitoring program that will be sensitive to any degradation of groundwater resulting from the escape of leachate from the landfill. To achieve this, the proposed a plan consists of the following monitoring stations:- . 1. and ?as?monrtorigmeus to monitor ll w, if r. Th ll radie a ow?p?erc aqua em I ese we 5 a ewes an 0 ng rom the site. Since these wells bresentTy?j?dicate groundwater contami- nation, future monitoring_after_completigp of theglangfill should show a In time, water quality from these i wells should be similar to background water quality as measured in the wells on the north and-east.sides of the site. I a; 2. A deep monitoring well would be installed west of the site in the.sand layer found at 48 feet This is the thickest sand layer ?ound in any of the 50-foot deep borings; monitoring this permeable zone will i give some measure of assurance that leachate would_be detected penetrated the natural clay_ga?ei I . Edi-"hr 3. The subsurface drain that would be installed along the outside ofithe dike should be monitored at itsEdischarge to determine whether leakage through the dike is occurring. 4. Hell #1 presently located in the center of the waste area, would be the of can bendEtermineda I Initially, the schedule for monitoring should be four times a year on a quarterly basis.? The procedure entails collecting a water sample from each'of the monitoring points except Well Only water level need be recorded for we'n #11. I I . i The list of parameters for which the water samples are analyzed need notibe Inorganic parameters that would indicate the presence of leachate are chloride, iron, hardness and specific conductance. In addition, some organic indicators can be supplied by de. ll' 1W I a After a few years of monitoring in which no degradation of the groundwater is detected, the monitoring frequency shouid be 1engthened to once a year. Once a good record is estabiished, thio requency is sufficient to achieve the goais of the monitoring program. 12 mu. "*?t?n??Jur I IB-nno We?. . 187' - 4 - #Isn?Mhram. ??[raQM??i I I ?40? [Brine WeBrine 1 I FIGURE LEGEND: DRAINAGE MAP DOW CHEMICAL CO. MIDLAND. MICH. DITCH DRAIN FROM THE SITE BOUNDARY OF WATERSHED . 6. CIRAND - hi u. . 1 l 1\ r nuocz?? [Zn :0 BORING 2 (ELEV. ?3ch 17:12.] SI jet. ?4 BORING 431593364-8 32.! 9.9 563915 2-90 244 46.6 2? I L56 31.3 I4.4 54:17 268 5214 ?5-1 2.02 .9 04..435 4L5 2025-4 I8 30?- . 1.73 2:10 3.16 47195 17.: 34.5 43.1 *Hmt30.odiz:99 26.6 36.2 3 .I 1?4.4 [7 - 4 80 .5;opp '8 4 1_ as 40-4 21 45?_ pm: 353 272.37 28.2 31.9 39.9 . I 49,4 4.5? .t . '44 a . WILLIAMS 8. WORKS. INC. GRAND RAPIDS. MICHIGAN i A I FIGURE 7 3 SUMMARY OF I LOGS 8n LAB DATA . FOR THE I SPLIT-SPOON BORINGS BORING 3 (ELEV. 628.8) BC ['51 1 8A1 3' [Cl? LEGEND: . LAB PERMEABILJTY 1N 2.04 SS 74.4 cm/?c [0-3 :9 BOB BLOW COUNTS NEEDED . TO DRIVE THE LAST 2. . OF A 18" SPLIT-SPOON o? SAMPLER 30 .4 I L79 23.1 22.9 54.0 . 4- 8C24 BLOW COUNTS NEEDED 3. TO DRIVE THE LAST A 24" SPLIT-SPOON . - SAMPLER 34 28 DEPTH SCALE 4 SAMPLE TAKEN FOR 54 I LABORATORY ANALYSES 22 SA SAND 'l _a 32 0 125 54 (70.074mm) 2C- .- .l 2. 81 PERCENT SILT - 4 (0.074 to 0.005 mm) 20 CL PERCENT CLAY 26 1' (?0.005mm} zo? 24 . .1 REFUSAL. DEFINED AS 1 woo BLOW COUNTS 2c PER 6" OF PENETRATION Ii 25 264. ?l :73 IBSAND '4 - SILT I 2.60 2:55 303 483 -- CLAY DOW CHEMICAL. CO. 52 4 D. II 3-5' I02 567 31' MIDLAND, MICHILS 13.9 43.3 32.9 6 - war-'1? 49:. 3* JULY. l9'r'9 35442J