?1026 CAROLLO JACOB A HOEFER STEPHEN MONSMA HILARY SNELL WENDLEH HARRY STATE OF MICHIGAN {Pu-u" ukupl A9312 DEPARTMENT OF NATURAL RESOURCES STEVENS MASON BUILDING BOX 30028 LANSING. 8.4148909 SOURCES COMMISSION AS ANDERSON RONALD 0 SKOOG. DireCiOr April 11, 1984 T0: Keith G. Harrison, M.A., R.S., Cert. Ecol. Senior Environmental Specialist Toxic Substance Control Commission FROM: Daniel Schultz, Water Quality Specialist Groundwater Quality Saginaw District Office Dow Chemical Rockwell Road Landfill Dow Chemical Poseyville Road Landfill SUBJECT: I have been asked to respond to your March 13, 1984 memo concerning the Rockwell Road Landfill and your March 28, 1984 memo concerning the Poseyville Road Landfill. The dewatering program at the Rockwell site has been Operating since August of 1983, and has, as of April 4, 1984, removed 515,676 gallons of leachate. The leachate is transported by licensed vehicle to Dow Chemical's wastewater treatment system, and the repair work is scheduled to begin when the static water level of MN ll inside the fill reaches 635.00. As of April 1, 1984, this level was 635.88, having been reduced from 637.82 last August, and we will be mailing out a report to area residents when the time frame for the repair work becomes better defined. Additionally, copies of the latest round of monitor well results are enclosed, including are two new wells placed in the area of the plume excavation just west of Rockwell Road. We split sampled with Dow MN 17 on March 26, 1984, (MN 16 was frozen) and the results are not yet available. He will be sampling 16 in the near future and will fonward the results from both 16 and 17 to you when they become available. Regarding your March 28, 1984 letter pertaining to the Poseyville Road site, our geologist has identified 13 monitor wells for split sampling but is awaiting further information from Dow before further evaluating the effectiveness of the encapsulation and leachate collection. In this regard, and also pursuant to your request, please find enclosed a copy of Dow's May 20, 1981 letter identifying the types of material disposed of at this site and a copy of my March 6, 1984 letter to Dow requesting more information. Also enclosed is a copy of Dow's request for a time extension to reply. Finally, we have established April 17, 1984, for split sampling the 13 monitor wells and the leachate collection system. We will certainly attempt to keep you informed as more information and the analytical results become available for review. d??ihi Memo to Keith G. Harrison Page 2 April 11, 1984 In response to your numbered requests, I wou1d Iike to respond in a simiIar manner: 1. In De1 Rector's Nov. 9, 1983 memo to Dr. Larry Ho1comb, it was indicated that this 1andfi11 was not 1icensed in the past nor is it current1y 1icensed. Dow Chemica1 did app1y for 1icensure under Act 87, P.A. of 1965, on Feb. 7, 1979, but it was not approved pending resubmitta1 under Act 641, P.A. of 1978. Dow decided, however, to c105e the site rather than reapp1y. 2. The 1andfi11 is current1y c1osed and capped with a Teachate co11ection system. 3. The 1981 hydrogeo1ogica1 report is several inches thick and wou1d be costIy and time consuming to copy. This report is certain1y avaiTab1e for your review, if you wish, or perhaps we cou1d discuss it? I wouId be happy to discuss this by phone, and if you sti11 wouId 1ike a comp1ete copy, it certain1y can be arranged. Fina11y, for your information, Ron Kooistra has been transferred to the Jackson District Office and I wi11 be the contact for this Division in the Saginaw Office for these two sites. P1ease contact me at 517?771?1731 if I can be of further assistance. EncIosures DS:amc cc: Dave Dennis De1 Rector DOW CHEMICAL USA. March 27, 1984 MICHIGAN DNISION MICHIGAN 48640 Mr. Dan Schultz RECEIVED Saginaw District Office Water Quality Division MAR 3 0 ?08 State Office Building 4 4ll-J East Genessee Saginaw, MI 48706 TAFF Dear Mr. Schultz: As we agreed during a telephone conversation on March 27, l984, a response to your letter of March 6, l984 concerning the Pose vill6_BQQd Landfill_ will be sent to you in early April after several memEers of our staff return from vacation. If you have any questions, please contact me. Sincerely, raf?? -02? . H. Story Technical Manager Environmental Services 628 Bldg. (517)636-3595 AN UNIT OF THE DOW CHEMICAL COMPANY Reply to: State Office Building 4ll-J East Genesee Saginaw, Michigan 43607 March 6, 1984 Mr. David Hilson Dow Chemical U.S.A. Environmental Services 628 Building Midland. Michigan 48640 Dear Mr. Wilson: Attached is a copy of staff geologist Leonard Lipinski's memo to me dated 2/27/84, concerning the Poseyville Road Landfill. If you have any questions concerning this review, please contact either myself or Mr. Lipinski at 5l7-373-2794. I would like to reiterate some of what Mr. Lipinski indicated as well as discuss some additional informational requests concerning this site. Specifically, we request the following: 1. Hhat is the current flow rate from the leachate collection system to Dow's wastewater treatment plant. and how does this correlate with any available previously obtained flow rate data? This Department expects Dow Chemical to monitor this rate in the future for determination of effectiveness and assist in determining whether the internal situation of the fill is impacted by any artesian systems in the area. 2. We understand analytical data of the leachate is available. and request you submit this information to us. He also request we be allowed to split sample the outgoing leachate at the same time we split sample the monitor wells. 3. We emphasize Mr. Lipinski's request concerning the contamjgation_jn the saturated sand tg_the_northeast ointhe.site. This information is necessary to make an accurate assessment of the effectiveness of the operating recovery wells. 4. An unresolved point concerning this site is a gas vent system. Mr. Diak has indicated in his inSpection reports that the venting system is not sufficient. In a letter from you dated Aug. 19, 1981, you indicated the plan was "to install six 4" vents packed in a gravel base along an equally spaced midline of the site, going from east to west." The inspection Mr. David Hilson March 6, l984 Page 2 We would appreciate a response to this letter by March 30, 1984. report by Mr. Diak dated 5/12/82 indicated the vents were "to be installed.? Has this been accomplished? We request copies of plans showing the design and installation of such a system for review. We have requested the Midland County Health Department undertake another round of domestic well water sampling in the area for comparison to earlier results. In discussions with you, we have tentatively established March 15, 1984. for split sampling of the monitor wells (weather permitting). Mr. Lipinski has identified 13 monitor wells for sampling, in addition to the leachate sample. Please don't hesitate to contact me at 517-771?1731 if you have any questions. Sincerely, (l M. Dan Schultz Water Quality Specialist Groundwater Quality Division Saginaw District Office 517-77l?l73l DS:amc CC: R. Kooistra D. Dennis File - Poseyville L.F. :5 MICHIGAN DEPARTMENT OF NATURAL RESOURCES INTEROFFICE COMMUNICATION February 27, 1984 TO: Dan Schultz, Saginaw District Groundwater Quality Division FROM: Leona Li inski, Geolo ist 1/ . . . ?holy. Groundwater Quality D1v181on ifh SUBJECT: Dow Poseyville Road Landfill After reviewing the file on this site and meeting with representatives of Dow, I have reached the following conclusions: 1. I am wall. Two additional monitor wells should be installed on the north side of the site. One midway between wells 17 and 24 and the other midway between wells 24 and 25. These should be screened at approximately an elevation of 590 feet into the uppermost confined saturated sand. There is some confusion as to whether Dow sent us the correct well log for well 9. If they did send the correct well log, the well should be replaced because apparently it is screened in clay. If they did not send the correct well log they should do so. Dow should submit a repert.gn the groundwater contamination and the remedial actions undertaken by them for the saturated sand to the northeast of the site. It is my understanding from the meeting that they will do so. This report should address at least: Extent of contamination Direction of groundwater flow Pumping rate of purge wells Areal extent of influence from the purge wells Location of piezometers reported to be present Type and concentration of contaminants Hammocrn: Based upon this report, it may be determined that additional monitor wells will be needed in this area. We should split sample at least some of the wells around the site. Those wells in the uppermost saturated zones would be of greatest interest. still studying the information on the clay key way and the slurry My review should be complete within a week and another memo to you will be written covering those items. DOW CHEMICAL USA. Way 20, [961 MQDLAND, ddhp?.? a RECEE x/Lu Hr. Larry Thornton Resource Re?nVerv Division . . Department of Natural Resources P.U. Box 123 ?1 48?53 angst-rec Recovery Dmdan Region Dear Mr. Thornton: SUBJECT: VPOSEYVILLE LANDFILL CLOSQEE Ah diseuased with you on 4/30/81, am providing as?built drawinra of the collection system for the north, west and wouth ?inch of the Landfill. The llow rate from the north sump haa been meujurnd 4: approximately 50 and the south sump at approximately 70 upm. Leachate analysis has been measured as follows: Chloride 9,930 TOD 1,320 TUC 080 . pH 1.3 Leachute organic analysis hava identified and confirmed the presech 0f Six organiua at lean than 10 for each constituent. A more ex- Lensive evaluation would he necessary to determine the key compounds. Inorganic analysis for brine chemical levels have been performed dud are consistent with the brine and inorganic chemical residues dihpUbHd at the site. Landfill material: hnve consisted oi SAFKNN, plastic materialb, demo? .ljtiCHI di?rris, ruldwinll, liltPX, \?lhtt' allutnt+., iv? It%ll alul CilldETrH, Eli?ICl?J'u :ushie;t-n;, ;.5i 5: yard clean?up holidu, FDA product; (METHUULLW, acid, dud and Inorganic residues. A further deCUSbiUn of these ma- terials Minion-3d. Drawings showj 112.1. the final. grade;-; and contour of tin: ti) you 50011;?) they ;ung connaleted. Rain has held up survey field activitien onr the labt Lwo Sincerely, . I I I (L WMQKIH J. D. Wilson Environmental Services 636-5925 rm 6 Enclosure 1* . lE v46" AN OPERATING UNIT OF THE 00W CHEMICAL COMPANY RECEIVED c? I is: 3 0 Resource Recovery hate1_?lud?es -- Latexcs are polymer or?cOpolymer particles dispuc?e? 5n water. They are important to industry primarily as binders and saturants. Examples are styrene-butadiene latexes and vinylidene chloride materials Dow produces three major types of plastic molding and extrusion materials: styrene?rwntaining, ethylene and chlorinL-containing. in addition, extensive research and develOpment ac? tivity is directed to new and unique polymers that can open new application OppOrtunities for thermoplastics. Resins are designed for particular suit? ability to the broad range of commercial fabrication methods, including in- jection molding, sheet and film extrusion, thermoforming, blow molding, rota? tional casting and coextrusion. The Dow resins serve nearly all markets, with particular emphasis on packaging materials, appliances, furniture, and industrial parts. Examples are: TYRILH (styrene-?acrylonitrile ABS and (poiuutvruna polymers). Uses include injection molding, ?upS. lids, toys, furniture. automotive parts, appliances, etc.. Dow flocculants are high-molecular?weight, water? soluble polymers. The products span a broad range of molecular weights and include cationic, essentially nonionic, and anionic materials used {or soild/ liquid separations in water and wastewater treatment; and mining and paper process applications. Examples are: and acrylamide poly? mers. Packaging Products The Dow Chemical Company markets materials which are Used by other manufacturers to contain, support, or protect their products. These packaging materials include clear films, coextruded films, and loose?fill packaging. An example is SARAN a vinylidene chloride vinyl chloride copolymer film, used for industrial packaging, bakery products, and households. cellulose ether products are water- soluble gums having surface-actiVe properties and selective organic solubility. The products are nonionic, are not metabolized, and possess unusual thermal-gel properties. The products function as thickeners, suspending agents, dispersants, binders, film formers, water?retention aids, emulsion stabilizers, or impart a combina? tion of these preperties. Some products are used as food thickeners. lon Exchange Resins -- ion exchange resins are produced in four major types. ?trgn??acid_gation resins are capable of exchanging cations, or posi- tively charged ions. For example, such resins will exchange sodium (is) for calcium (Ca) and magnesium as in water softening, or hydrogen for calcium, magnesium, and sodium, as in "salt splitting". The geek acid_cation resin is capable of exchanging positively charged metal cations associated with weak bases, such as bicarbonates, for hydrogen at near-stoichiometric regeneration use and does not split salts. The strong base anion resins are capable of exchanging anions, or negatively charged ions, and can split salts to bases. The geek page anign_?esin? are capable of neutralizing acids. Combinations of cation and anion exchange resins can effectively demineralize water, recover wastes from process streams, and function as condensate polishers for nuclear and fossil-fuel power plants. Foamed Product Residues used for flotation for docks, rafts, insulation for residences, etc. resins -- These products are used as gel lacquer coatings for bowling pins, generator field coils, and glass bottles; hot-melt strippable coatings and paper coatings: lacquers for paper coating, electrical insulation, strippable coatings, fabric coatings, bronzing, and alkali resistance lacquers. They are also employed as binders or viscosity modifiers for nitrocellulose lacquers, glass frits, delayed? release coatings, printing inks, varnishes, and pigment print pastes. Inorganic Residues Examples; Calcium chloride CaClz Magnesium hydroxide Mg(0u)2 Magnesium sulfate Hg(504) Potassium bromide Sodium bromide NaBr Asbestos Insulation and Demolition Asbestos FDA Products Salicylic acid residues, METHOCELO, SARAN Demolition Debris from Building Demolitions Waste Treatment Sludgcs Flyash Cinders from Powerhouses I Incinerator Ash PWAY 2 i381 Spill Yard Clean?up Solids Resource Recovery DWISIOH Region II unnuam :mttl 8/83 .J COST .3 I "2 fr LOCATION I '1 came CENTER 16?45(? PR "Ul- SAHPLED 9?ka) AW I Engz': 1:558 AT TINE LS 3:9 1:175:27"? Remzs (NAHE 0R DESCRIPTION 4 INFORMATION mum 33439919514331.9951 -7?13933337". ":59 "a "1 i? 4? -1 1:323:74: 1991-36.62.39"7657 "1 a I "gig?{g ?7 7 1 1 jam-ARUHATIC HYURUCAR*HINHYHRUCRRBUN BRUH HYDROCARBOHS QRUHRTIC (CIRCLE108ENVIRONMENTAL QUALITY 504 1001 DISSOLUED IfBIOLOGICAL DIS N024P31 504BUD IUTAL612345678910 4C64 XEPI PHEHULICS PHEUPHTTIN FECAL FREE IUTQL FECPIL 7C4. 4" tlbiOliltoIo0Dl IOF4 4.345'1934 L. E: 11- E: 3H: LHEH L1 *3 L. 75:3 Isl LHR WHHULFH IHW LHH LUU Iiwwi 1 lit?i ih?t??til?? liwyit Lidia rum I..I El 53.23 ii}? ?imm Hwiamtimn limit th? rum iHii :iwm i i ?atwmiimn limit molar Df?ii?id?? hwtwuiixMr Limit w+?iuyhitw? Iim El??4 EJNMWEHTE ii?? ihitwwiiQWi innit thi?.rmni LH Hn?? U?taciimn limit ihi? run IJH ..1H .Hmi?iHLiMrl limit firm?irnr? H?i??tiuh iiMiL ?ii Uth?V? UWHL EEHH i EUHHEHTB 1.HH Net??iium limit thig rum WHMH limit thi? run 1.. [1:1 3? LHBH LHBH :53: lee-1 r: [.1455 must ?10 T: I- II iu?? waft '32; .. 1551 f: .. in?? MHFL LHH ?atwctimn Hntwutimm thwutimm . l' D?t??ti?h ?Ht??ti?h ECHH th??timn M?t??tiwn 43 mmhti in? H10 limit W?i?t we timi?e; limit ?hth?i?t?? iimit thi? CUHHEHTE LH limit thi? run KUHHEHTH limit limit td?luuthwr? innit thi? ru? HQHHEHTE limit thi? rum KUHHEHTE Him iimit W?iti?id?? limit Hhth?l?t?? CUHHEHTE limit thi? rum LHH LOU HH-L LH EHUH Hatwmtimn limit thi; rum EEHH 93h nl? Umtamtimu limit Hrm?lmra Dmtewtium limit ?ll mthert I l.?m Hatwutimn limit thig rum iinL limit thia rum Shli?? Iiw ldu?? Umt?utimm limit ?E?ll?ld?? in?m limit Dhlh?l?t?? LHBH uw?h ECHH CUHHEHTE lilEl lniteui ham hnit t??ia rwni Edd?? uwfl EKHH LH U?t?ctiwm limit thl? er 3446? HHFL EKHH KUHHEHTS ?nT? U?l??tlmh limit li?? Hmt?ctimn limit all mart in?? Dwtactimn limit thig rum ?lt?F H?fh ?ntmi linw?i thi?.rwun LHBH 3446? uwa ECHH HUMMEHTS Udiiw? I FE thwutimn limit molar P??tl?ld?? lu?? U?t??tluh limit whth?l?tw? LHBH Lyi?m EEHH CUMHEHTE Datwmtimn limit thit rum ECFWJ LH Nat?mtimn limit thii run Bdi?T uw?L 3&4 HUHHEHTE ?lm W?t??tl?h limit limit all HHFL SCHH 1 lnw? thamtimh limit thin 34463 uw?l EEHH HUMMEHTE EHEWJ ?Ht??mii?l limit tlmLa rum I 344%? 'ff. 1. ?1E-l ll LHW LHM ?793 WUHH ??T??ilmH HwTeullmn 11:: m: I, I I'm 62:13:: Parentimn Hm+wct1wh Hwt??tlmn I'llhe1gvt}wn hwhantimn IIJ- i r'l lim1l limit I 11m1L II 1 11- limit 11mit "f 12- limit 1S u?ht" ELFHIHHLHIL Flhr?n? 1431.? i_ ?1 131};- Ph1h01Uf?? rh]; run KUHHEHTS lH rhia rum U11 rhie rum If thie rum LUHHEHTH polar whthaloLEE LUHHEHTS T. i r" 1 +122: =l=t 33;: at. [.4451 I I, i113. :33: :53. L. 5'3} 1}}fle-jl [1155- t. 1,1: 1-: Ll. .L 12 1.. 3446? EKHH 33W CUHHEHTE D&twu?imn limit "?Wi Tm?wn?mhmw lbwit all ?thEF? wwr? Fur menoumd? mm EEHH li?t 33" are rmund?d to Figurw?" DOW CHEMICAL U.S.A. Narch 27, 1984 MICHIGAN DIVISION MIDLAND. MICHIGAN 43540 Mr. Dan Schultz RECEIVED Saginaw District Office Hater Quality Division MAR 3 0 ?08 State Office Building 4 dll-J East Genessee Saginaw, MI 48706 TAFF Dear Mr. Schultz: As we agreed during a telephone conversation on March 27, 1984, a response to your letter of March 6, l984 concerning the Pose ville Rgad Landfill will be sent to you in early April after several mem ers of our staff return from vacation. If you have any questions, please contact me. Sincerely, gm, 74%; . H. Story Technical Manager Environmental Services 628 Bldg. (517)636-3595 AN OPERATING UNIT OF THE DOW CHEMICAL COMPANY State Office Building 4ll-J East Genesee Saginaw, Michigan 48607 Reply to: March 6, 1984 Mr. David Wilson Dow Chemical U.S.A. Environmental Services 628 Building Midland. Michigan 48640 Dear Mr. Wilson: Attached is a copy of staff geologist Leonard Lipinski's memo to me dated 2/27/84, concerning the Poseyville Road Landfill. If you have any questions concerning this review, please contact either myself or Mr. Lipinski at 5l7-373?2794. I would like to reiterate some of what Mr. Lipinski indicated as well as discuss some additional informational requests concerning this site. Specifically, we request the following: l. What is the current flow rate from the leachate collection system to Dow's wastewater treatment plant, and how does this correlate with any available previously obtained flow rate data? This Department expects Dow Chemical to monitor this rate in the future for determination of effectiveness and assist in determining whether the internal situation of the fill is impacted by any artesian systems in the area. 2. We understand analytical data of the leachate is available. and request you submit this information to us. He also request we be allowed to split sample the outgoing leachate at the same time we split sample the monitor wells. 3. We emphasize Mr. Lipinski's request concerning the contamination_1n the saturated sand $9?thg_northeast a?_tbe_site. This information is necessary to make an accurate assessment of the effectiveness of the operating recovery wells. 4. An unresolved point concerning this site is a gas gent systemw Mr. Diak has indicated in his inspection reports that the venting system is not sufficient. In a letter from you dated Aug. 19, 198l. you indicated the plan was "to install six 4" vents packed in a gravel base along an equally spaced midline of the site, going from east to west." The inspection i Mr.? David Wilson 6, 1934 Page 2 report by Mr. Diak dated 5/12/82 indicated the vents were "to be installed." Has this been accomplished? We request copies of plans showing the design and installation of such a system for review. 5. We have requested the Midland County Health Department undertake another round of domestic well water sampling in the area for comparison to earlier results. 6. In discussions with you, we have tentatively established March 15. l984, for split sampling of the monitor wells (weather permitting). Mr. Lipinski has identified 13 monitor wells for sampling, in addition to the leachate sample. We would appreciate a response to this letter by March 30, l984. Please don't hesitate to contact me at 517-77l?1731 if you have any questions. Sincerely, naM_ Sgyv?gy Dan Schultz Water Quality Specialist Groundwater Quality Division Saginaw District Office 5l7-77l-l73l DS:amc cc: R. Kooistra D. Dennis File - Poseyville L.F. MICHIGAN DEPARTMENT OF NATURAL RESOURCES INTEROFFICE COMMUNICATION February 27, 1984 T0: Dan Schultz, Saginaw District Groundwater Quality Division FROM: Leonard Lipinski, Geologist 2/ Groundwater Quality Division SUBJECT: Dow Poseyville Road Landfill After reviewing the file on this site and meeting with representatives of Dow, I have reached the following conclusions: 1. I am wall. Two additional monitor wells should be installed on the north side of the site. One midway between wells 17 and 24 and the other midway between wells 24 and 25. These should be screened at approximately an elevation of 590 feet into the uppermost confined saturated sand. There is some cgnfusion as to whether Dow sent us the correct well log for well 9. If they did send the correct well log, the well should be replaced because apparently it is screened in clay. If they did not send the correct well log they should do so. Dow should submit a the groundwater contamination and the remedial actions undertaken by them for the saturated sand to the northeast of the site. It is my understanding from the meeting that they will do so. This report should address at least: Extent of contamination Direction of groundwater flow Pumping rate of purge wells Areal extent of influence from the purge wells Location of piezometers reported to be present Type and concentration of contaminants Based upon this report, it may be determined that additional monitor wells will be needed in this area. We should split sample at least some of the wells around the site. Those wells in the uppermost saturated zones would be of greatest interest. still studying the information on the clay key way and the slurry My review should be complete within a week and another memo to you will be written covering those items. 'handfild a i o??n?tobov 24th, I called warty him to investigate the Bump, in hid?dnd. b? two Dew workers that plaezd in this dump some buildinf ted been the? had a lot of problems a few years bank with Spuntnnecus firr was told by a retired Iwnizi specie].ZLhie into t0 [nth them Quin PJH?ihf artcsinn well 1 quarter nf 3 Dow worker that How capped Earty Store. mile down the road behind ymhbie's was told civirigj.. angertegiauwll behind the party that there was one next it that was capped. According to neighbnor developed an wily taetv within the pa. hood resident the flowin? well year, and many people hdv~ etcpped using it. In 1080?81, Rune wf the residents t?d problems with their private wells-dincmicrdtinn and adore. I A twee revealed that this landfiJI had no compacted clay liner,and test borjnes encountered an aquifer within 20 feet of the buttum of the adjacent fill.- h?m has met with Dow at least twice since my phone ceii sampling has the facility was neVer licensed, and no rigiri?scl [It] ti??d i:ir] weiln yet. I asked the 37y questimn. evaluat- iut they to ask tin the site. (it?mp, in 195. A1'tiuiuggh. lhiuv tnit irl 53L12r117 :1n tile it was operated for years of the wells in the area Viittvnit my understanding that are quite a few artesian walla in that area. i tut g. I . STATE OF MICHIGAN =1 .2 M. RESOURCES COM ION 651).) HOMASJ ANDERSON JAMES J. BLANCHARD. Governor 5* D: ?114:;wa DEPARTMENT OF NATURAL RESOURCES . mu: WENDLER STEVENS MASON Hummus I HARRY BOX 30028 LANSING, 43909 RONALD SKOOG. D.:eclor December 2, 1983 TO: Larry C. Holcomb, Executive Secretary Toxic Substance Control Commission FROM: Richard 8. Johns, Chief Gr0undwater Quality Division SUBJECT: Poseyville Dump Near Midland In response to your October 24, 1983 memo to Del Rector, staff of the Groundwater Quality Division plan to contact Ms. Hebert, as you sug- gested. Provided below is information concerning your inquiries: l. A review of the Saginaw District file for this facility shows that the landfill was not licensed in the past nor is it currently licensed. An application for licensing under Act 87, P.A. of 1965 was filed in February 7, 1979, but was not approved pending re- submittal under Act 641, P.A. of 1978. A memo dated May 4, 1981, by Larry Thornton indicated that: Dow operated the facility for nonhazardous waste; b. The City of Midland ceased dumping at the site in 1955 (for- merly a city dump was located on a portion of the site); and c. 'Dow was planning to submit a schedule of closure for the site. 2. Dow Chemical in a letter dated May 20, 1981, c0py attached, pro- vided information as to what materials went into the landfill. We do not have information as to what materials went into the old city dump. 3. Dow ceased Operation of the facility in late 1980. The entire landfill including, the old city dump, has been encapsulated with a compacted clay cap together with a clay key (with slurry wall in northeast portion around the site perimeter). A perimeter leachate collection system has been installed inside the capsule. The leachate is routed to the Dow plant for treatment. maze. ?Quad 4. Holcomb -2- December 2, 1983 The data base for the hydrogeological information on the site is a report volumes I and II by Neyer, Tiseo, and Hindo, Ltd. dated April 1980 and received July 1981. This report was reviewed and a draft "Consent Agreement" drawn up which addressed several items including those pertinent to the site hydrogeology. The consent agreement was not signed by Dow. There are monitoring wells around the site. Our file contains little information on data from these walls. The N, T, report contained some static water level and chloride data. The draft schedule of compliance required sampling and an expanded parameter test but this apparently was not done. In July 1983, staff re- quested Dow to provide sampling of the wells. A meeting is set for December 8, 1983, with Dow and the Midland County Health Department to consider this matter. In a letter of May 1983 Dow Chemical reaponded to Mr. William Harks' inquiry regarding the trichloroPhenol building, Dow in- dicated that the building, process and product piping, vessels, equipment, heat exchangers and filters were thoroughly cleaned prior to placing same into the landfill. The building was dis- mantled in 1967. The cleaning liquids were injected into deep well No. 5. A leachate sample collected July 15, 1981, by DNR staff did not show the presence of trichlor0phenol. The landfill has been closed and encapSulated with leachate col- lection. Additional information required to assess this problem are: 8. Dow Chemical to provide monitoring well data including an initial annual testing for organic chemical scans. Bi?annual sampling has been requested for at least 5 years; b. Sampling of the leachate flow; and c. Staff of the Groundwater Quality Division are requesting Split sample with Dow Chemical on selected monitoring wells and the leachate flow. The Midland County Health Department may assist in this regard. Please contact us if we can be of further assistance to you. to game Enclosure: Dow May 20, 1981 letter CC: Del Rector, Chief, HWD Dave Dennis, GWQD Saginaw District, GWQD D. Diak, Midland County Health Department D. Dempsey Senator Engler Representative Hayes Lgbiane Hebert 5? l? J. 1 I kLT?,DOW CHEMICAL USA. a: '5 May 31 1983 MICHIGAN DIVISION MIDLAND. MICHIGAN 48640 i- Mr. Hilliam D. Marks JUN 09 Acting Deputy Di rector 1983 HI Department of Natural Resources v.0. Box 30028 JUN 1 01983 . Lansing, MI 48909 g, I - ?r .1 GOD-COMPLIANCE 2 . . Dear Mr. Marks: In response to your letter of March 29, 1983, the old trichlorophenol process at 199 Building was dismantled in late 1967. ,Because we gen- erally have not retained records from that date, and due to the length of time which has passed since then, most of the data which you have requested was obtained through discussions with Dow employees who were involved with the actual planning and execution of the project. In all cases the information received is, to the best of their memory, both truthful and factual. A common consideration, apparent from all discussions concerning the demolition of 199 Building, was the degree of concern for industrial hygiene and environmental safety. Stringent safety procedures were formulated and enforced concerning protective and personal clothing requirements, equipment and tool cleaning methods, equipment removal methods, and personal hygiene practices. Following is a summary of the events taken from the discussions. Liquids associated with this project fall into three categories: those compounds remaining in the process since it had been last operated, those liquids used in flushing and cleaning the internal parts of the equipment prior to removal, and liquids used to wash the dismantled equipment and building walls, floors, etc.. The process piping associated with the plant was modified so that the contents of all plant vessels were pumped through a single line into one Itank. This tank will be referred to as the north tank. All the process vessels were first emptied, then extensively washed. Following is the wash-out process listed in!chronological order: 1. A mild caustic solution (approximately 15%) was recirculated through all vessels, heat exchangers, pumps, filters and process piping. This liquid was pumped to the north tank via the same pipeline as the re- maining process liquid. AN UNIT OF THE DOW CHEMICAL COMPANY Mr. l-lilliam D. Marks( I.) May 31, 1983 Page Two 2. Item 1 above was repeated using 15% hydrochloric acid solution. 3. Item 1 above was repeated using solvent. This was followed by a hot rinse of soap and water. All liquids were pumped to the north tank and injected into Deep Hell No. 5. This deep well extends to a depth of 4,269 feet into the Dundee vugular rock formation. This formation is over 3,800 feet below any drinking water aquifers. Following the flushing of the process equipment the entire building area was washed with high pressure soap and water from roof to floor, includ- ing the exterior of all equipment. This water was then received and treated at the Waste water Treatment Plant. After the extensive clean?out procedure described above, the equipment remaining in 199 Building was classified into two categories: p.eces of equipment which had, and those which had not, come in contact with pro- cess raw materials or products. All equipment that had contacted product or process raw materials was placed in an on-site landfill. Recognize that each of these pieces of equipment had been cleaned as previously described. Large equipment was cut into smaller pieces prior to transfer to the landfill. The landfill is contained within the Midland Plant site. Its existence was reported to the 0.3. Environmental Protection Agency pursuant to 42 USC 9601 and, derivatively, to the appropriate Michigan authorities under 103 of that statute. In August of 1980 the landfill was closed with a cap of greater than two feet of clay on the top and sidewalls. Leachate is collected and for- warded to the Haste Water Treatment Plant. The entire site was seeded for erosion control. Because the equipment from the 199 Building demolition was so thoroughly cleaned, due to industrial hygiene consideratiOns, there is very little _likelihood of hazard or negative environmental impact associated with it when it was landfilled. Disposal into an on?site landfill was an extra measure of environmental safety. The geologic formation of the landfill consists of a clay bottom and clay sidewalls and, although no monitoring data specific to this landfill exists, it is highly improbable that mi? th this project has occurred. Con- sidering the combination of the geologic conditions and the cleaning procedures prior to placement in the landfill, it is reasonable to conclude there has been no adverse environmental impact. Registered Trademark of The Dow Chemical Company. \l unbuqmw go now, cg; Aq Mr. William 0. Marks?" '1 May 1983 Page Three In conclusion, the data gathered from discussions with the people involved with the demolition and subsequent burial of certain equipment from 199 Building shows that the entire project was completed with full regard to industrial hygiene and environmental safety. Considering the fact that it was completed long before today's regulatory climate, the conscientious and responsible program exhibited during the project is quite impressive. Sincerely, G. R. eurink, Manager Environmental Services Building 628 (517) 636-2646 CS urnhlu'nw ?10 3 Dl'l ?q Day?l? Md._ _wall and the final '-of their,agteement rv-aApril 198a Don Sohultz,.5agioav District bffice Leonard Lipinaki,?Geologi8t Compliance Lansing ISUBJECT: Dow?Poeeyville Rood Landfill - -Site Containment . 1 . I. - Aeouming that the.slutry wall and key way were preperly constructed, containmeot of this site oppoaro adequate. However, I don't feel that 'the quality control testing woe-eufficieht to guarantee this. Thereforel Dow should obtain damples from the slurry wall and key way for permeability. testing.' These temples should be obtained by Shelby Tube at two depths_ from locations listed below. These sampling depths should be near the -baoe of the.olurry wall or key way end then about hal way up from the bottom. 'The testing locations ohbuld be: Clay Key Wn?: 1n Hort?_aide of Bite 1000 feet east of the west tence. Y. North side of site 1600 feet west of the I east fence. I . .3. South aide of site 120U feet west of the I 'eust fence. Slurr? Wdll:- 1. The northeast corner of?the slurry ooll. 2. North aide pf site 800 feet west of the east _fence, the test reou1t3.indicote a permeability of greater than 1 10 Cmfsec., then further testing and pouaibly remedial action will be During our meeting?with Dow in February; they indicated that they would no a set of aowbuilt ehgineering plane for the key way and slurry We also requested a c0py of the compatibility study on the ulotry mix specifications. Perhaps we ohould remind them to send this iniormation. Bend walls. fb (ac?i 5 Dow refutes ECOMM- By KEITH NAUGHTON Daily News staff writer Dow Chemical Co. Friday refuted several allegations made recently by a local environmental group that the company may have been involved in various chemical contamination inci- dents. At a press conference Thursday. the Environmental Congress of Mid- Michigan also alleged Dow was in- volved in a massive cleanup designed to alter findings of the U.S. Environ- mental Protection Agency?s dioxin study. Dow spokeswoman Sarah Rowley de- nied the allegation. Any cleanup work the company is doing is part of routine maintenance,she added. . . Rowley specifically responded to question as to whether Dow is involved in nighttime spraying in Midland to neutralize chemical con- tamination. "Dow has not done any nighttime spraying either inside or outside the plant.? Rowley said. ECOMM Director Andrea Wilson said the group received unconfirmed reports from a small number of sources indicating Dow is involved in nighttime spraying which may bedesigned to neu- tralize chemical contamination. Mrs. Wilson declined to identify the sources. Midland Supervisor of Forestry and Pest Control Robert Strejc said the city sometimes sprays at night for pest con- trol. Strejc said he is not aware of any nighttime spraying by Dow. ?If somebody had been doing any spraying at nighttime, my operators would have reported it,? Strejc said. Thscity?preraatniahtbecause wind is low, temperatures are right and trafi {wivlos?treseii - .. - ECOMM FURTHER?alleged Dow has strong influence over the Environ- mental Protection Agency and the state' Department of Natural Resources. and meets with the agencies behind closed doors. - Rowley said Dow has had just two meetings with the EPA and gave the agency a tour of the plant before it star- ted its dioxin study. - - - Rowley also denied a claim Dow had been disposing brine in deep wells in Midland County. ECOMM believes the brine may have been in chemical processes. 0n the brine deposits. Mrs. Wilson said she received her information from a chart entitled Oil and Gas Field Brine Disposal By County, which is part-of a- 1981 study by Western Michigan Uni.- versity for the EPA. Mrs. Wilson claims the chart indi- cates 24 million barrels were trucked and hauled from the Dow plant to an unknown location in the Porter ?eld and disposed of. . ?There isn?t any information here that leads us to believe the brine was taken into Dow." Mrs. Wilson said. Rowley said the group is interpreting the charts brine EC- OMM is reierring to was trucked from oil and gasdrilling sites to the plant for use by the company, she said. ?Dow has never had any disposal op- erations in Porter Township but has . recgived brine from the area: Rnwley ECOMM ALSO CITED an accidental incineration of 880 pounds of the. herbi- cide at the Midland plant in Au- gust. 1981f Ro?wley said the incident was re- ported to the EPA in July. 1982, to de- termine if the incident was covered by the Toxic Substance Control Act. Dow, did not hear from the EPA until May 23. 1983, when the agency issued a notice of alleged violation and'a proposed ?ne. Howley pointed out the company re? ported the incident publicly in May. Mrs. Wilson said the inciner- ationis significant because the heat of Dow?s incinerator is not hot enough to combust the dioxin contained in the herbicide and eliminate it. Mrs. Wilson cited a report in an EPA journal which said heat of2,500 degrees Fahrenheit is necessary to destroy di- oxin and any temperature below that level would actually increase the am- ounts of the extremely toxic form ol'di- oxin known as 2.3.7.8-TCDD. . The phenoxy herbicides. which had a low leVel oilthe extremely toxic form of dioxin known as 2.3.7.8-TCDD, Were incinerated at temperature lower than 2,500 degrees. Mrs. Wilson claims. Rowley said Dow runs its incinerator at 1.800 degrees F. Dow studies. as well acceptable temperature to break up di- oxin, Rowley said. An EPA document the group pre- sented Thursday said "there is no cause to make it (the incineration} a issue because Dow voluntarily admit- ted to an inadt'ertent disposal and is:- cause only a small quantity of the mate- rial having low levels of contamination is invoked.? as other studies. have Shown 1.800 is an 96'" ECOMM ALSO CHARGED Dow's Poseyville Ltoad l'a?n?dfi?ll in Midland co'ii't??i?ETVastes from S'ar'z'in Wrap pro- duction and carcinogenic asbestos. Mrs. Wilson said she received her infor- mation from a study done by Neyer. and Hindo, Ltd. of Farmington i Is. )Rowley verified the land?ll contains Saran Wrap scraps and tos which may have formerly been used for insulation. Disposing of asbestos in a land?ll is the proper way to handle the carcinogenic substance. she noted. llOWever. Mrs. Wilson claims the study also indicated the land?ll did not have a compacted clay liner. Dow commissioned the Neyer. Tiseo, and Hindo study in April.1980.Rowley said. That was before the land?ll was closedand cappedwithacompactedclay liner, she added. The group also allegedDow?s former trichlorophenol plant was dismantled and may. have been dumped in the Pos- eyville landfill. Mrs. Wilson said the ,group received the information from one anonymous source. ECOMM held the press conference because the group's concerns were not being investigated by the EPA or the DNR. Mrs. Wilson complained the agencies do not always ask for input from ECOM M. . "Nobody ever calls us on the phone and says ?What are your ideas'," Mrs. Wilson said Thursday. I 1 charges Minus-co mu: Wool re! smears relic-tied Jill.- Septe by? 1934 TO: Keith 3. ?arrjacn, Senior Specialint Toxin Coutto! Cowmiaaiwn FPOI: Bavid Eau?irn 2 Grnu??water Uu?!ity Diviaiow I 'i 9 1: SUBJECT: Dow Foaeyvilla Tund?ill (?idlanl County) Wells 52?, 28. 29 and 30 yurqe cells Luatolled in a ptnme of contamivartan which left the alto prevLous to encapqulation. Since thin crntamination nh?uired previous tn encap?uIntion. 1t haa no impact upon our evaluation of the effectivnnasn of that oncapnulatior. Hell #25 has hoan renauplcd, since the rtsulzq from Dow's Lab did un? Verify the contuminatinn detected by the BER Lab. Thu teat h=au1ts rhnn1? b? available within a few Hacks. I am copies of tun mumoh ky Lennard Lipinphi discussing the site cacapautn:1au. An you can ere Wt. Liplnahl fuels the encapsulation is adequate it keycay and alurry,wail were nrnperly constructnd. The testing requested upon the keyway as boing undertaknn by Dow and we expect t? receivr those rceulta in the near future. I will b; forwarding a map showing the Focations of the'xclla avd iwachatw numna within a ?aw days. ac: ?Uan Schultz Lipinnk} . thc?- - REMOVAL, Oi? PROCESS EQUIPMENT AT 100 BUILDING Mr. Harold Bosscher and Mr. C. Stoehling have asked for a plan to remove the old Trichlorophenol process equipment from 199 Building. This would include clean-up, decontamination, wipe tests, and would specify equipment. that can be salvaged or disposed of. Much of the"'? equipment will have to be buried. This plan will also include. a cost estimz'te, a way to do it safely, and recommend who will do it. The first meeting was held on September 29., 1967. I?ve-stunt were: Bill I?Ieritier; Ber Argyle, Larry Silverstein, Biocht?m. Item-arch Rudy Waste Control Greg 'J?Crr'yzih, Earl Loilt?iit?, Dick Colbry, Safety Engineer Jim Wallace, Safety Engineer Don Croope, IVSUEFI Ross ??nltzer, Plastics Ralph Rose, Aromatics: Plant Don Dunkelbai'ger, "Mr. ?Dunkelharger opened the meeting by explainng the process equip? ment. Each man has a flow sheet of the equipment. Noies: were made on the ?ow sheets of contaminated equipment. A clieeussimi was; held on equipment that could be salvaged :md urluipimsut that should he buried. Mr. tool: the group on may tlirruigfh tiw 'l'richlorophenol Plant. Don pointed out the equipment, what it was: used for, and whether or not it is contaminated?i Mr. Novak and Mt?. .Tei'i'ynh that November, or the winter months, would be the best time to bury equipment. Mr. Novel; said more dikes will have to be built at the pond. TH 15:11: r?mhl they Could handle piping and small equipment this: NUt'mllin-r, 1.067. Don :1pp0illif:fl a committh to make this; Illn'itiei? will find out about the equipment?clr-anin? and removal. Safety testing; will (Ecnnr- ll} inn-y Silvl-r'steizi and. Dick Colbr'y. -2- Disposal and burying of contaminated equipment will be handled by Rudy Novalt. Earl Lolirkc will have a cost estimate and weights of equipment for Waste Control. A second progress meeting will be held on October 18, 1967, 1:00 p. m. at 199 Building lunchroom. . Ileritier had a meeting with "the Medical Department. 1? will write a letter setting forth medical requirements for this job. He stated that we should use all necessary safety precautions while removing this equipment. He said, too, that tests should be run on the men before going on the job, and again after completing the job. "ls-said a meeting should be held with Bud Collins on labor relations. Earl Lohrke and lleritier have reviewed the prints: and equipment. Earl has come up with a good set of prints of the equipment. Ken llorton and Bill lleriticr have out lln- c'lt-r-h-icnl purl of the Triehlorophenol process. lien reeonn?nemted that we di::cmme(:l :ell 440V lines by the switehroom wall. All electrical equipment is connected to the South switch except for one pump. This includes pumps, and inns. The 110V can be tie-energized at the enclosed room and at. the pane]. board. An electrical tag number lint and will be in the job folder. f? - It is recommended we use Dow electricians to do the disconnecting. A word of caution: in our electrical survey we found two 440V switches and two different pumps of equipment with the same Numl'irm 83 tag. We suggest that the conduit be traced beforeany disconnecting is done on 533. We are looking into two plans of manpower for removal 01' this: equipment. One is to use contractors with Ralph Hose and llill Iteriticr to watch this job. I Number two would be to title Dow personnel with three crew leaders. A full time Safety Engineer will be required. 1t meeting was held on October 18, 1967 on the Triehlorophenol equip- ment removal. Don Dunkelbarger went through the list of equipment noting items that will be saved, destroyed, or in doubt. Silver-stein stated we need samples and wipe testn? Ilr-ritier will get samples from the 20' 20' tank. Two feet of product is; left in this tank; also, phenate tanks will be checker: and taken. Larry Silverstein will run tests on these samples and report on the contamination of these tanks. Dick Colbry of the Safety Department said when we start removing equip? ment, we will have a full time Safety Engineer. Rudy Novak stated it will take 50% of 000 [or \Vaste Control's part. The next meeting will be held on Wednesday, November 1:3, 190?, A meetng was: held with l'lud Collins on Oclnlic'i' 25:, 1987, on the labor relations: part of Hm: job. Also in were Don Dunlcelbarger, Dick l'losqnet, llravl Argyle, l-anl Lohz'izrr, and ,Bill Iieritier. Heritier opened the eating with a short review of the ?Chlor?acne at 199:}:luilding, and raised theqnestion, are our labor relations ?problems when we start removing this 'l'richlorophenol process equipment?" Collins stated that peeple cannot refuse to work in 199 Building without a Medical Department release. Dr. Holder and the Safety Department will clear people to work in 199 Building. Three plans for manpower were discussed at this meeting: 1. three Dow Journeymen as; crew leaders, hiring, 13- new Laborers with Rigger-s. 2. CCP to talzc this job. Dick lionqne?. thought wnM-l nrn.? wmn? it, 3. Contractor??Collins will meet with Jim Ham?s: of the Legal Department to see if we can contract this job. ('ollin:: will llii?t'i with tln- Union and Shep about the labor a ?m1plcs by l-leritier and sent to Larry Silver-stein at B_io Chem. le-search, . - We found 2' of product in the 20' 20' storage tank (4700 gallons), blow down tank 20? (850 gallons), south phenate tank 24" (247:3 gallons), batch tank 10" (675 gallons), big deeanter 40" (700 gallons), little decanter 560 gallons, with a total of 10, 185 gallons of contaminated products: Samples were also given to Waste Control. I On November? 15, 1957. 11:00 a. a meeting was: held at 190 Building; llerluer stated he had found over 10.030 gallons of triehlorophenol in different tanks. It was decided that this equipment would have to he dumped out before moving. It was decided this product could be to one tank. ludy Novak of Waste Control stated that the.contuhliugtortproduct could be pumped to the well syn: em a permd ot time, It was decided at this meeting to try to have this job through engineering by December 20, 1967. Also, waste control should have their ready for an estimate. Next meeting will be on December 20, 1967. llcritier and Lohrke met with Bill Barker of the Dow legal Department- Mt". Barker stated that job 71790 could be contracted without any . liability to the Dow Chemical Company. The job should be written up to state all hazards, what is 'eontaz'ninatcd .- precautions are necessary, health "and - I cleanliness. Equipment should he numbered. and each piece of equipment should have a write?up on how it should he removed; also whether we can burn with a torch, and what protective equipment is needed. This write-u; should contain information on how the equipment is going to be handled and wh are it is going 10 he ?1)urifgd_ A How will lJe__present at all times while this equipment is beingf moved. A meeting was held on November 251, lilii'f, in l-larl Lohrlze's'oftice in 222 Building._ Rudy?oval-c and Merl; Kr'ienlce of Waste Control were present. This meeting was held to clarity what Waste Control wanted for money to bury the and what it would cost in no the waste Ti?i-Telilor?oElEI-ml ~in'.o the well it was: decided to Dump thc'wastc T. C, directly to the well svstem.? Weill-'1? T511253. ltudy stated that Jim Wilson had done some on me dikes. REQUEST SHEET 1111214154111 am 0: 1491191111 9553;3555 szamsnm 11150911111111 1 2 23:: - 3903 91101 GC 5051 iaty?p? 25153511 a: DATE Iie?uu? -- 1:011: CENTER -- n11: - him magmas:qu: I . OLLECIED TRANSFERED . p. .1115 1 I 0.4. $11.11--.. 'SEND 195511115 10 6 . ?mus --1 "11111115 1. sacrmm - ILAB 115E 01111 .I 4! FIELD ID DR DESCRIPIIUI- .I 59.11911 INFURHATIUN 1111:1111 1 137781101! "/{3522' 3. 2377831031 A v. 2 1 1 137?7841041 '37?788'05u7788 1091 110' 1 1 I 0115111111: 1115mm BENERAL 0151115199 I 9111 91 CA 115111; 1' ..1 :3 451: 7119 10 1111 11159 1111111111111? 12345675919 1413 11.990191 ..1 45678910 -- as mm? 10 1995-111: 031193 CHLEIRIHATED 11c. - SE 5113111111 .. RES-01:12:51, qua-(WI; 1o 55 111111113111 ..1 2 34 5 14 9199 GIHERS (CIRCLE1 BOD TUT FE..12345673910 90051119350911.12545578910 391111-3111 ..1234567E910 - 12345678910 1:345473910 FURNACE?345678?1453414112 I 10 as 1311 1. 2 5 4 5 1: 11511111111 11 19..1 - . 9 1a 1111 11'. 11.4111?Lknus-HM ..1 2. 455711910 -- Clio12345974911: ..1234557a91o 345478910 .221456?Bil? I134557391o .. ..103111 12345673910 ., 5910 5150999 123456712910 -- 1214511959121 :11 9co:.- 3 4515711910 ..123453r991-I 12345678910 ENVIRONHENTAL LABORATORY HICHIEAN DEPT OF NATURAL RESOURCES 5 1107577 011517515 REQUEST sum 2791 1110 71105 1:057 RECEIVED DATE :0 Q) L009 "329-? -- c005 0mm 1911-5-- 90 07 L110 1an 3-7-1375! 711 1000711771 9 701111579150 53.9.1! -- BY -- SAMPLE SEND RESULTS 70 11511011115 --1111111? 5 1105 USE 01117 .I HELD 117 017 17550911771071 I SAHPLE 11170115071011 9171111105 1111:1111 I I3773m01 I I I 7377321021 100110! I I I I 1110190111110 GENERAL 011571157711 3: 10 11110111151701; ..12395570910 1:0 1:0 011 111 919 1117 0 9 1o 10 110 111519017119 ..12555570910 071 0-17 1102- -- 05 RES-NF 17171193011100111117E0110.709 10 55 39 1? 555?? "WuNPCBIDEPEST..789IO 5501171110111 ..123 570910 12315570910 .5 7 0 9 10 OTHERS 1011715151 900 7177 500770910 115 11L 011 95 co 7542515570910 00170511050111.12545570910 111111110719 ..12515570910 12345570910 12515570910 12115570910 FURNACE- 511000 5 570910 01110 ..70910 70910 -- L05 5113071071. 1 2195 5.7 a 9 10 71054102 775101110 11 79011 0051550111104 1111911FLUURIDE. ..12515570910 -- CHM12345570910 11003-005: .. ?72315570910 059550170015512305579110 -- 12515570910 12515570910 -- 707111 12545570910 1100010510191151 12315570910 a I I I a -. 12315570910 I511: 111203- 1205=..1 2515570910 12315570910 EYYBID 37781D 37781D E7782 37782D SYYBED 57782D 37782D 377BED 577BED E77BED a. n? m- u? -..-. m- . 3??83 3?783 37783 37783D K7783D 37783D ?7?830 i??83D CHLORIDE SULFATE ALUMINUM RRSENIE CADMIUM CHRUMIUM COPPER IRON MERCURY NICKEL LEAD SELENIUM ZINC QLHALINITY CHLORIDE SULFQTE ALUMINUM QRSENIC CADMIUH CHRUMIUH CBPFER IRON MERCURY NICKEL LEQD SELENIUH ZINC CHLORIDE EULFHTE I UM QHBENIC CQDMIUM COPPER IRUM MERCURV NICKEL LEQD QELENIUM ZINC L08 o?uI .. .. .u .. EEULTB MICHIGAN DEPT OF NATURQL RESOURCES UNIT ND: 3009 200.0 359.0 35.9 . 1:1 C1 a 61 20.0 59,0 20a0 0 a 531:1. 5C3 . Cl U.5 8.50 . 1?0.0 200u0 140.0 8?70.0 0.3 20,0 50.0 .70 .. 0 13900033 33003010a0 20.0 50 .. 0 20.0 501-30 . 0 0,3 30.0 50,0 14:310TUTAL DISSULVED DISSULVED DISSULVED DISSOLUED cum-u..? MQTRIK. RATER NATER RRTER RRTER NRTER HATER RATER NRTER WATER RRTER - RUN 24 24 24 00330 3?2 00330 00330 .00330 00330 479 00330 00330 02 00330 TOTAL TUTQL DISSULVED DISSULVED DISSULVEH DIBSULVED DISSULVED DISSULVED TOTAL DISSDLUED DIEEDLVED DIBSULVED DISSULVED DISSULVED NQTER WATER WQTER NHTEH NQTER MQTEH NQTER NQTER NQTER NQTEH WQTEH MATER I WATER NQTER WATER NQTER HQTER NQTER WATER NQTER WQTER NQTER NQTER WATER METER. WATER Mn 24 2 24 00330 00330 00330 00330 00330 417*? 00330 00330 02 00330 24 24 04 00330 .1. g: J.- 00330 00330 00330 00330 479 00330 Ci 0 (J 02 00330 i ENVIRONMENTQL LREURQTURY a ?Lang 3909 . I 11BHIGQN DEPT OF NGTURQL HEQHURCEQ INDRGANIC UNIT I LOB NU: MATRIX HUN RESULTS . .. Hw?mwumum I i -I- 0? a. unu- nu- In In. Il? o-o7va4j 7784 7784 II II E?u? ALHALINITY CHLORIDE SULFATE ME M8 M5 TOTAL NATEH 5 NQTER meER 34 24 34 392 0033a 90330 00330 GLEEO 7784B QLUMINUM ARSENIC CADMIUM COPPER MERCURY NATEH meER . WATER DIESULVED meER DIBBULVED DISSOLUED HATER WATER 13300.9 lab EQ.Q EQHG 9,5 NICKEL US DISSULVED WQTER 00330 T784D LEQD I S?u? UB NQTER Q0336 SELENIUN US I NQTER 92 ZINC US I WATER ,00330 - 3Y7B4 .. .. L. L, W. L- m. EOQLO MGE TOTAL HATER I 24 ?785 CHLORIDE 25G.0 NGTER E4 a7?85 SULFQTE 58.0 MG- NQTEH E4 QLUMINUM NQTER QOEEG QRSENIC En? UGI WQTER 392 CADMIUM COPPER UBI 77BED 29.0 SOLD EOLO DISEDLVED WATER DISSULVED WQTEH (I) (I) :53: {1330 NQTER l? 7785D ZINC US I DISSULVED NQTER [31:13.30 IRON EEQ.Q US: NHTER $0330 MERCURY I 3.5 U?lf NQTER 77853 NICKEL EQLU DISSULVED NQTER OGEEG LEAD SOHO US I WATER I 00330 77850 EELENIUH 6.3 US I WATER 92 I 37785 um. um n- m? up. ?no an.- ?736 El?g? MB TUTRL WQTER 24 7?u& CHLORIDE 240,0 MB TUTQL NQTER 24 ??86 QULFATE $1.9 ma TDTAL WATER 24 ALUMINUM 1000.0 ua meER 1 00330 QRBENIC 0L3 ua;x NQTER 392 77855 CQDMIUM BUFFER IHUN 20.0 50,0 QG.D 00330 00330 09330 00330 Umi/ U13 L. US U6 3 DISSULVED NQTER WATER DIEBULVED WATER DISEDLVED Cl .. ?3 I SBOLVED NQTER 4279? MICHEL 30.0 U8 DISSULVED Q0330 LEQD 50.0 US I DISSULVED WQTEH 06336 ?pull-Ftp.? 377350 PARAMETER m-awmm-n-m SELENIUH ZINC Inna LUE ND: 3909 RESULTS 1? C) . ..J ICHIBAN DEPT OF NATURAL RESOURCES INURBANIB UNIT 150.0 ENVIRONMENTAL LABU EXAMINER. ANALYSIS "match?HOW? MATRIX WATER HATER RATURY I RUN manna?mu? 92 -.. u? .- ou? n?n wen. 37787 37787 377B7D 377B7D 37787D 377870 E77B7D 377B7D 5Y7B7D 377B7D m. n? .- a?u. n? - 0-D- .m .m 3Y788D 37788D 37788D 37788D 37788D ALHALINITY CHLORIDE SULFATE ALUMINUM ARBENIC CADMIUH CHRUMIUM EURPER IRDN MERCURY NICKEL LEAD SELENIUM ZINC ALHALINITY CHLORIDE SULFATE ALUMINUM ARBENIC CADHIUM CHRUMIUM COPPER IRUN MERCURY NICKEL LEAD BELENIUM ZINC 210n0 340.0 61.0 1000.0 0.5 20.0 00.0 20.0 EDEHO 0.3 50.0 5 C) . 19Q50 220.0 59.0 34000.0 0,5 20.0 11090 80.0 78500n0 0,0 80.0 00rr?r'r TOTAL TDTAL TOTAL DISSOLUED DISBULVED DISSULVED DISSULVED DISSULVED DIESULVED TOTAL DISSULVED DISSULVED DISSDLUED DISSOLUED DISSULVED DISSULVED DISSULVED NATER WATER WATER WATER WATER WATER HATER NATER NATER WATER HATER WATER WATER WATER WATER HATER WATER WATER WATER WATER WATER NATER WATER WATER WATER HATER WATER WATER 24 34 00330 392 00330 00330 00330 00330 479 00330 00330 02 00330 n?00330 392 00330 00330 0 330 00330 00330 00330 92 00330 n. .7. cm. n-a. u-u. m. can. 3?789 3?789 37789 37789D 377B9D 37789D ALKALINITY CHLURIDE SULFATE ALUMINUM ARSENIC CADHIUH CHRUMIUM COPPER IRGN 230,0 75.0 1?200,0 0.5 20.0 00.0 30.0 18800TDTAL TOTAL TOTAL DISEDLVED DISSULVED DISSULVED DISSULVED WATER WATER NATER NATER HATER WATER WATER WATER WATER 24 24 24 00330 '392 00330 00330 00330 00330 ?791 7791 7791 7791B 7YR1D .77R1D 7791D -7791D 7791B DEPT UF NATURAL RESOURCES PARAMETER MERCURY NICKEL LEAD EELENIUM ZINC EHLURIDE EULFQTE QLUMINUH QRSENIC BADMIUN EHRUHIUM COPPER IRON MERCURY NICKEL SELENIUM ZINC LOG NDINORGANIC UNIT Q, 30. 3700. 100G. 0. ED. 50. SD. 33100? 0. SO. 56, 0. 15?, 3909 ENVIRONMENTAL LHBURRTUHY . . . . . DISSULVED TUTHL TUTQL DISSULVED DISSULVED DISSULVED DISSULVED HQTRIX NQTER HATER NQTER WATER WATER NQTER NRTER WATER NQTER NRTER WRTER WATER NQTER WATER NQTER METER WATER WHTER RUN -.-. on.? up.- 479 00330 $0330 @2 00330 m. ..- u-u -. 25 ?:un E4 Q0330 392 00330 00330 00330 ?9 00330 Q0330 ODEEO w. n? nu- ?n F. mn. a-u-u l-I- on- tr- In. nm In? I-n-l .- u?u -- an. m? un- -?792 7792 -7792D 7792B 7TRED 7792B 77RED IV792D 77RED 77R2D ??93 ?793 7?93 Y7930 7793B .7793D RLHALINITY CHLORIDE EULFATE RLUMINUM ARSENIC BADMIUM COPPER IRON MERCURY NICKEL BELENIUM ZINC QLHALINITY RULFQTE MLUMINUH QRRENIC RQEMIUH 52 xx xx xx 510.: 3300.: 1000. 6. 50. RRSQ. Q, 30, 30" On 13009" 130. IDOQ. 0 4-1 .- 42kTOTAL DISSULVED DISBULVED BISSDLUED DISSULVED DISSOLUED DISSOLUED DISSULVED TOTAL TUTQL DISEDLUED DISBULVED WATER NQTER WATER NQTER NQTER NQTER NQTER NQTER HRTER WQTER NQTER NQTER NQTER WATER NRTER WATER NRTER HQTER NQTER NQTER 2? 2% 00330 r) -.1- at. 00330 00330 00330 00330 00336 $0330 92 C) 24 35 ng5 Q0330 I11: F.) 90330 i I EEPT OF NATURQL HESGURCEB ENVIRONMENTQL INORGANIC UNIT . . L08 ND: 39o? PQHAHETEH REEULTS T3 HUN i I: a: u?H NQTER $3330 HATER 00330 DISEULVED NQTEH 479 NQTER $0330 DIBBULVED NQTER OQEEO DISBULVED NQTEH GE DISSDLUED WATER 00330 U8 COPPER 99,0 UG IRON 4100Qu0 US MERCURY 0?3 US F. I ?7?39 MICHEL SQHO UG LEQD EORO U8 1.. I SELENIUH UG KIND US uh I ..-. ..-. NQTER NQTER ES NQTER 35 DISSULVED NQTER $0330 NRTER 392 DISSOLUED METER Q3336 WATER 90330 WATER GOSSQ NQTER . 479 NQTER I 00330 DISSULVED HQTER $0330 DISSULVED WGTER 92 WATER QQEEG 7?94 a2?,0 MG CHLORIDE 2190.0 MB Y794 SULFATE 10930 NE 7794B ALUMINUM um QRSENIC us 7794p UADMIUM E?u? um gong um .7vq4n COPPER E?u? US IRON us ?77940 MERCURY 0.3 we 37794D MICHEL 56.0 US 30.0 US- 7794B EELENIUM D.B um ZINC 55.9 um i? - i ll.- u-u-u um um- pn- mu nu. ann- H- In" m- Ian- out ur- um u? ?795 MB IDE .. 77795 EEULFQTE 1 1 .. MB . TUTQL 3:36) ?7953 QLUMINUM U5 NQTER $0330 TUTQL NQTER 2a I I 77959 QRSENIC we DIBEULVED . 392 TUTQL NQTER 25 CQDMIUM 3020 U3 DISGULVEH NQTER Q0339 SOHQ UB SUPPER 26,0 UG 51) I F: 1-323 E3 0 C1 . MERCURY Qu? US I HQTER 479 77WSD NICKEL EQHO U8 NQTER DDHEU 77QED LEGB 39.0 U6 NQTER GQEED 77WED SELENIUM 0.6 US I WATER @2 ZINC 50.0 UG HQTER I 00330 DISSOLUED NHTEH Q0330 WATER OQEEQ DISSULVED NQTER 5 OQEEO 1&0090 ME I TOTAL MQTEH Rb 5000.9 ME I WATER 25 7?9? SULFQTE 2&Ou? ME I TUTQL NQTER RE IIGQN DEPT OF NATURQL ENVIRONMENTAL LRBURQTURY .-. - .n u? UNIT . . . LUB ND: 3909 AB RESULTS ANALYSIS MQTRIX RUN -7796D HLUMINUH 1000u0 DISSULVED NQTER 00330 7796B RHEENIC in? US i DISSOLUED WATER 7796D CQDMIUM E0u0' U8 DISSULVED NATER 00330 -7796D 50,0 US NATER 00330 7796:) 3C1 . 0 LIB I SSUL-VED LIJQTEFI 00330 7796D IRON 71000.0 UG DISSULVED NATER 00330 7796B MERCURY 0.5 US 3 NQTER 479 7796D NICKEL 30.0 US NQTER 00330 '77q?D LEQD EOHD US I HATER 00330 7793B SELENIUM ln? US I NQTER QR ZINC 50.0 UG DISSULVED NQTER 00330 3?793909 . . . . . u. ..- .-..- lI-a- n-o-u .mp- an. HIGH DHR LHE UREHHIE RESULTS FUR LHB L05 #3939 1. 5' 1 '3 NE 1.98 Detection limit this run 3??31 SEHH . . . . 5.UU Detention limit this run 3??31 a CDMMEHTS EH 1 Detectiaq limit molar Pesticides Detention limit Lu 1'43 :1 $121 I u; I. SEHH I EUHHEHTS arma1 ELK HE ELK HE.5 Detection limit thia run f$31841: Hme SLHH CUHMEHTS 5.18 Detectiomllimit this run I SFTHI UHWL SEHH 3&4 CUHHEHTS al? Detectinn limit . Detectimn limit all others i umIL EEHH 1 CUMMEHTS lu?? Dmtectium limit this run - EFFEE umEL SEHH EUHHEHTS 5.8H Detection limit this run LHB L06 #3939 un?t? H?mm?Mm?u?n?nH??n??n?u?m EEHH CUHNEHTS 8u4? EH Detection limit palar aesticides lug?; Eetectinn limit mhthulutez uwa SEHH r? EUNMEHTS 5 ELK H3 1 I ELK K2.5 '1 lu?? Detectimn limit this run 1 s?uHB# UQXL 33am 3 Sula Detectimnllimit this run 3??83 a?fL BERN 3&4 i CUMMEHTS I .16 DEtEGti?h limit Detectimnilimit all mthera SFFSE uaxL SEHH 1 EDMNEHTS 1uma Detectimnllimit thia run a .l ?4 HJ HWWL SCHH - CUHHEHTS a 1.. ;3 Detection limit thiS run 1 I BCHH 6 EDHHEHTE- a) ra ELK K5.5 .35 Detection limit nmlur mesticides lu?? Detectimm limit phthalutea uwa SEHH EDMHEHTSE i ELK HE ELK HE.E 1?33 Detection limit thig run LHB LUG #3939 cant. I ??m?nmm?u??p?u?c?"n?u?umw HafL SCHH 8 EDMHEHTS i Detentimh limit this run I 3??83 SCHH 3&4 EUMMEHTS i ?13 Detection limit Hrmulurs .55 Detection limit all nthers 3??34 maxL SEHH 1 I COMMENTS i lu?? Datagtiom limit this run 3FF34 maEL SEHH CUHMEHTS Elam Detectioh limit this run 3??84 ume scan 5 . EDHHEHTE Bu?? EH .35 Detection limit mulur pesticides Detectiad limit mhthaluteg STFB4 ?uqu SEHH EDHMEHTS ELK KB I ELK H2.5 in?t Detection limit this run arrat umHL scam a Eu4? Detectioh limit this run w? EFFEE 3??85 EFFBE i' I 1] I LII EFFBE i?p?ll?? - HQKL 1.83 ugKL u; .53 umKL luEB Hme ume g3 1:1 umHL :1 13': LHB LDE #3989 cant. I Detection SCHH 1 Detection SCHH Detectinm EEHH limit limit limit limit Hroclors all athert thia run this run Detection EEHH limit limit .1 Dmtemtinm SCHH 'Detectinm SEHH 3&4 limit limit limit limit EUHHEHTE COMMENTS 1 CUMMEHTQ EDHHEHTS ELK H5.5 [331310. ill; mhthulutea tmia run this run Hraclora all ELK H2 BLH KE.5 CUHHEHTS LHB L06 #3939 cont: HEEL SEHH 1 EUHHEHTS lu?? Detentinm limit this Fun EFFEE ume SEHH 3 5.38 Detection limit this run I F36 HQHL SEHH 6 9.Detection limit mulmr Destl?ld?? DE SE Detectimn limit UgfL SCHH EDHHEHTS ELK K2 ELK HE.5 lu?? Detectiam limit thia run um?L SEHH EB Deteutiom limit this run UgfL SCHH 3&4: BUMMEHTS Dmtmutimn limit Detectimm limit all others ume SCHH 1 EUHNEHTS I. n5] 1' I 1nma Dmtemtimm limit thia run EFFET uaHL EEHH BUMMEHTS: 5.3u Detectiamilimit this run I I BERN CDHMEHTS Fu?? EH ?etamtidm limit mmlar mestimidet ?mtemtiwm limit mhthalatet umIL SEHH CDHHEHTS ELH H2- ELK KE.5 Detectiam limit this run 37mm? uaxL scan a CUMMEHTQ 5?28 Detectiom limit thia run umXL ECHH 3&4i EUHHEHTS n18 Detectinm limit .35 Detentimm limit all umHL SEHH 1 1 . CDHMEHTS 1.86 Detectium limit this run ETTEB ume SEHH - EUMHEHTS Et?? Detection limit thia run 3??38 uaHL SEHH 6 EDHHEHTS ELK K5.E Detectimm limit masticidem 1 1.83 Detectimm limit mhthulates EFFEE ume SCHH EUHNEHTS ELK m2 ELK H2.5 D-tectiom limit thig rum ITI :r?ae I. ?1-1 I LI L?at 3??39 3??89 3m?ma PS3 LHB LUG #3989 canto SCHH 8 i CUHHEHTS I Dmtemtim? limit tmim run 3&4 COMMENTS Detection limit Hroclors Detection limit all athers i SEHH 1 .EDHHEHTS HE Detectiantlimit this run EGHH EDNNEHTS Detectimm limit this run SEHH CUHMEHTS EH Detectiomllimit Detectimm limit SEHH Detection limit Detection limit mmlar peatiuides mhthalmtes QDHHEHTS ELK HE ELK K1.5 this run EQMHEHTS this run LHE #3989 Gm?tn .. u: nun?mumnmm?upu?n?n?u?mmu? SCHH 3&4 COMMENTS HIE Detectimn limit Datactiom-limit all uthera SFF93 ume SBHH 1 EDMMEHTS Dgtectimn limit thia rum i??MBtt 3FF9E1 w:le :52 FE Detentimmilimit this run I 3??99 a?fL SCHH i CDMMEHTE ?nm? Heteutimmilimit thia run umHL SEHH 1 COMMENTS ?51 3 UC US EEHQE Datectimm ?imit thi? rum 3??91 HEEL SCHH CUMMEHTS BEHEEME DH El?n?? TDLUEHE 5.38 Detectimm limit thig run ?vwil UMNL SCHH I I Saga Detectimm limit mmlar neaticidea 166.39 Detectimm limit mhthulates ?mun?uu?a?u?n?nu?q?u?w?n?nw?? UQEL ECHH EUMHEHTS ELK K2 1.33 ?etectimn limit thia rum .4 ?91 UHHL 3 CUHHEHTE 3 923.88 PEHTHEHLUHUPHEHHL i i 51.53 limit thii run ume 3&4 I CUHNEHTS Detectium limit Dmt?ctimm limit all mthera HarL SCHH 1 EUHNEHTB EQH.EB CHLURUBEHZEHE UE Wm Datectiam limit this run 3FFQE ume SEHH I EUHMEHTS BEHEEHE 4 TDLUEHE 3F.EE EE.EE Dmtectiom limit this rum ume CUHHEHTE 35.89 BK "53 limit pmlur llu?? Dmtectimm limit mhthulmtm? QFFBE UQEL SEHH EDHHEHTS ELK HE 1.13 Detectiam limit this rum LHE LDG #3939 somtu? ?u?nwmn?amu?un?I?n?n??a?u?mn SCHH 8 CDHNEHTS 54nan 25 Datautimm limit this FUN ume SEHH 3%4 CDHHEHTS 31.68 Detection limit 11.38 Detection limit all athers MQHL SEHH 1 EDNHEHTS LU 3 my UE Fgu?? EHLDRUEEHZEHE HE 15.39 Detectiam limit this run SEHH HUMMEHTS .23 53:: 35,33 BEHEEHE LJ HE Detention limit thi? FUH UQEL SEHH 6 EUHHEHTS Elu?? Dmtem?imm limit pestimidma Detectinm limit mhthalutes - I {53 5.4. a a IT: I'l? SEHH CDHHEHTS ELK HE ELK H2.5 i E- lul? Detentimn limit this run 1 1E Detection limit this run LHE LDG #3939 cont. umHL SEHH 3&4 - EUHHEHTS Detention limit Dmtemtimn limit all mthera HM Hid 12-2! IE 3FF94 Hme SEHH 1 EUHMEHTE 95.93 UE 138,66 UE Dmtemtimm limit thia rum HEEL SEHH 3 I CDHHEHTE u-u?j '43 i t1mnmm BEHEEHE 339.9a TDLUEHE i 299.39 m=+t $rk$ . . . . limit thla run I 1 EFF94 ume SCHH a 1 Detamtimn limit malar masticidem Detectim? limit mhthulmtea MEI 41-. umKL SEHH i EUHHEHTS ELK HE.E 1.93 Detentimn limit thia run 33mm BUMMEHTE .4 ?43 Eu 3 Sg?n?? SEHEE Detectiun limit this run SCHH 3&4 I CDHMEHTE 3. 3 ?4 .LI. Detectimn limit Hraulmra Detaatimm limit all athar? LHE LUE #398 "mun-mm an 3??95 ume mumm 1 EDHMEHTE us 4 EHLURUEEHEEHE UE 15in '4 5E.BE Detection limit thia run EFFEH HEEL SCHH 2 COMMENTS BEHZEHE m; EQB.EE TDLUEHE m' 333.83 ETHTLEEHEEHE 5.63 ?mtectiam limit this run UHEL SEHH EUHHEHTE SHIE Dmtactiom limit mular memticidmm 18E.BB Dmtectiam limit mhthulutem 1 3??95 ume SEHH CUHHEHTS ELK H2 ELK HE.5 lu?? Dmtectinm limit this run EFFQS mafL SEHH a 3 COMMENTS mim.ma I 51.aa Dmtectiam limit this run 3??95 UgfL SEHH 3&4 EUNHEHTE 51.36 Dmtmatian limit all mthert Hetectiom ldmit Hraclars 1 ugfL SCHH 1 CUHHEHTS '4 .13 IT. 21E.EE US i 48E.GE UE I ESE.EB US I: Ill "97 Detection limit thiE run 5? LHB L05 #3939 umJL BEHH CDHHEHTS EFBE.EE EEHEEHE DR TULUEHE EEHEE Detection limit thia run ume EEHH EDHNEHTS 5.16 Detection limit pnlur pesticides 196.33 Detaatiom limit mhthalutes I umrL COMMENTS ELK HE ELK HE.5 lama Detectinm limit thi? rum 3??96 HEEL SEHH 8 i CUHMEHTS PHEHUL i i i I ?anaa Detectimm limit thia rum 1 3??95 UQHL scam 3&41 EUHHEHTS Eln?? Datemtim? limit Hrmalmrs EEHHB Dmiectiam limit all mthera Umlmaa noted above under CDHHEHTS: wera merimrmed For th? mm uttatmhed aumm 115i? arm ruumded t0 2 figuWE?a .JUN251984 ?re d?ae ?24 7f? d; I a 0'7 (3, arm/5 ?more? /Wcmd@5c?1?om? 3?4? 8 50WVXUH49 Oq n04 fund 446 f?hlmy 636'} 65514993 or" ware 4uhdia?74 5: ?(?tmng mow/wax: Ms:- ?gem/g arm-Maury [amt 140+ frank 14.29%. '7 SCAN I Brouubiich? ~ruum? Brnmofnzm Carhnn tetravh? Chlurubswz-nu Uhloroform Dihromochluromethanc 302;; 3 I: '1'1?2 3cm.- "3 -- (iindunr' 3*Cniurau3thhul 1 L'iz'i] r' Aroclur Arorlor Ald*i" Mme (I?Bl?f? a?C?alnrd-r. . I. . iy?g_? lf. _Lu :5 ORGAN I L: LA r. MATRIX: LLST lfAjliR ?was (cis l,3*DiCAlurOhr0prnu ?faLh3'lawlc Evtrachloroethene 1,1,1-Trichloroethdne 1,1,3-Txithlorutthauv 'l'richlm?uathen? (Cis Tolu:nv isomers (J. In, and p) arQOhn -x3cidr.1nbnr:L1icne ?ginrhlorocycio;entenu Pvnruuhloronitrgbanzcne Iy 1 ?rl a 2 L1 '11- Pas: ?1de ii- 11 (inzit vaabromabcnxan4 H?t? Cpuxide xvthor D1er-x chloride (request unly) at; wi-nnurrvl andt?ntuli'nn I ?1 7] Him I: pig! . I I Swa 1X7, iLdam-11- 4:14" )m r. . 1'11] 7m): Hz." (311nun! wivltw xv: ll 1 4 LA ?1 IL). 5303..? - . r- (in? I '4 71-3?; 7.1.1: 13L: Pox? ?k Supronlur 19? m: mu: 6. Harrison. Senior Environ-anal Specular Toxic Substancu Control 00.1.3101: nan Davild Dunn, Chic! Coupnanco Suction 2 Quality Division 8m: Dov Poocyv?lo Landfill (ludhnd County) Haul f27. 28. 29 and 30 are purge Hell.- installed in a plus of contuinattan which loft ch: 01:. previous to ucapouhuon. 81m. thin consultation Mon: to congratulation, 1: ha ?timer?. our ?valuation of tho ?heaven-u of that map-mum. v.11 125 In. hon rel-p106. Inc. the ruulu fro. Doc'- th did not ur?y tho men-tun. dotoctod by the on Lab. In. rat maul:- ahould ho availablo within a la wants. 1 an ?clout; min of tin: am) by Leonard Lip-buck: mam-1n; the ?to Matilda. Ll you con so. hit. uptuki tools tho Walnuts: 10 odoquatc 1! ch. koyuy and slurry n11 worn properly cmtmud. Tho tooth. toque-nod upon tho byway as being anagram by Don and w. ?you to main than noqu in the our tuturo. I be forwarding a up chain: the location- of tho well.- and luchatc sump. within a tall days. cc: 30811, Schultz Len Lipinlki April 25. 1934 TO: Dan Schultz, Saginaw District Office PROH: Leonard Lipinski, Geologist Compliance Lansing SUBJECT: Dov Poseyville Road Landfill Site Containment Assuming that the slurry wall and key way were properly constructed, containment of this site appears adequate. However, I don't feel that the quality control testing was sufficient to guarantee this. Therefore, Dow should obtain samples from the slurry wall and key way for permeability testing. These samples should be obtained by Shelby Tube at two depths from locatiOns listed below. These sampling depths should be near the base of the slurry wall or key way and then about half way up from the bottom. The testing locations should be: Clay Key Way: 1. North side of site 1000 feet east of the vest fence. 2. North side of site 1600 feet west of the east fence. 3. South side of site 1200 feet west of the east fence. Slurry Wall: 1. The northeast corner of the slurry wall. 2. North side of site 800 feet west of the east fence. If the test results indicate a permeability of greater than 1 10 -7 cm/sec., then further testing and possibly remedial action will be necessary. During our meeting with Dow in February, they indicated that they would send us a set of ss-built engineering plans for the key way and slurry walls. We also requested a copy of the Compatibility study on the slurry wall and the final mix specifications. Perhaps we should remind them of their agreement to send this information. lb If July 31. 198:. (x/ll' TO: Den Schultz, Beginev District Groundwater Quality Division Leonard Lipineki, Geologiet Groundwater Quality Division SUBJECT: Doe Poeeyville Roed Lendfill Site Contein-eut The additional infatuation eubnitted by Dow in reference to the slurry well he. been This includee the D'Appolonie report on the per-eebility of the beckfill mixture end the quelity control teet reeulte fro- ae-teet. upon the edditionel inforletlon, I no longer feel it ie to obtain ee-plee of the slurry well for testing. DOW CHEMICAL, U.S.A. . May 31-, 1983 MICHIGAN- . . . I MICHIGAN 43540 William 0. Marks 9 Acting Deputy Director . 0 1983 H1 Department-of Natural Resources . - -, P.0-. Box 30028. . 01983 - i 'Lansing,_HI 48909 . I, GOD-COMPLIANCE 2 'Dear Mr. Marks: .In response to your letter of March 29, 1983, the old trichlorophenol process at 199 Building was dismantled in late 1967. ,Because we_gen- erally have not retained records from that date, and due to the length of time which has passed since then, most of the data which you have requested was obtained through discussions with Bow employees who'were involved with the actual planning and execution of the project. 'ln all cases the informatiOn received is,.to the best of their memory, both truthful and factual. A common consideration, apparent from all discussions concerning the demolition of 199 Building, was the begree of concern for industrial hygiene and environmental safety. Stringent safety prOCedures were formulated and enforced concerning protective and personal clothing I {requirements, equipment and tool cleaning methods, equipment removal methods, and personal hygiene practites. ,Following is a summary of the events taken from the discussions. Liquids associated with this projectifall into three categories: .those compounds remaining in the process s?nce it had been last operated, those liquids used in flushing.and cleaning the internal parts of the equipment prior to removal, and liquids used tb wash the dismantled equipment and building walls, floors, etc.. - A The process piping associated with the plant was modified so that the contents of all plant vessels were pumped through a single line into_one _tank. This tank will be referred toias the north tank.. I All the process_vessels were first emptied, then extensively washed. Following is the-wash-out process listed in_chronological order: 1. A mild caustic solution (approximately 15%) was recirculated.through' all vessels, heat exchangers, pumps, filters and precess.piping. This liquid was pumped to the north tank via the same pipeline as the re- maining process liquidOPERATING UNIT OF THE DOW CHEMICAL-COMPANY 10 "out, It? lq pl?l: Mr.i~li11iam 0. Marks( . May 31, 1983 - Page Two 2. item 1 above was repeated using 15% hydrochloric acid soTution. 3. Item 1 above was repeated using soivent. This was foiiowed_by.a hot rinse of soap and water. All liquids were pumped to the north tank and injected into Deep No. 5. This deep weTT extends to a depth of 4,269 feet into the Dundee vuguTar rock formation. This formation is over 33800 feet beTow any drinking water aquifers. FoTTowing the fiushing of the process equipment the entire budeing area -was washed with high pressure soap and water from roof to fToor,'inc1ud- ing the exterior of a1] equipment. This water was then received and treated at the Waste Water Treatment Plant. Aften the extensive cTean?out procedure described above, the equipment remaining in 199 Buiiding was cTasstfied into two-categories: p.eces of. equipment which had, and those whic? had.not. come in contact with pro- . cess raw materials or products.- 'l . A11 equipment that had contacted'prdduct or process raw mateniaTs was pTaced in an on-site TandfiTT. Recognize that each of these pieces of equipment had been cTeaned as previousiy described. Large equipment was cut_ihto smaTTer pieces prior to transfer to the Tandfiil. . I he TandfiTT is contained within theiMidTand Plant site. Its existenCe was reported to the U.S..Environmentbi Protection Agency pursuant to . 42 USC 9601 and, derivativeiy, to the appropriate Michigan authorities. under 103 of that statute. 2 i . in August of 1980 the TandfiTT was closed'with a cap of greater than two feet of cTay on the top and sidewaiis. ?Leachate is coTTected and_for- warded to the Haste'Hater Treatment Piant. The entire site was seeded for erosion controT. 1 - Because the equipment from the 199 Budeing demoiition was so thoroughly cieaned, due to industriai hygiene cbnsiderations, there is very Tittle _Tike1ihood of hazard or negative env?ronmenta] impact associated with it. when it was TandfiTied. Disposai into an on-site TandfiTT was an extra, measure of environmentai safety. The geologic formation of the consists of a cTay bottom and cTay sidewaits and, aTthough no monitOring data specific_to this TandfiT] exists, it is highiy improbable that m1- . gration of materiais associated with this project has UccUrred. Con-' sidering the combination of the geoTogic conditions and the cieaning proCedures prior to placement in the-Tandfili, it is reasonabie to i conciude there has been no adVerse environmentai impact. i . I - Registered Trademark of The Dow ChemicaT Company. I uob-qa-w .0 alone It? lq pompo. Mr, William - Hay.31. 1983 . I Page Three - . . '6 In conclusion, the-data gathered from discussions with the people involved with the demolition and subsequent burial of certain equipment from 199 Building shows that the entire project was completed with full regard to industrial hygiene and environmental safety. Considering.the fact that it was completed long before today's regulatory climate, the Conscientious -and responsible prOgram exhibited.during the project is quite impressive; Sincerely,_ rink, Manager Environmental'Servioes Building 628? (517) 636-2646 CS .u 'If" um?unlw Ln ?q rum" m1- STATE OF MICHIGAN DEPARTMENT or NATURAL ersounces GROUNDWATER QUALITY EVALUATION REPORT 1 SANITARY LANDFILL: TYPE TYPE OTHEH . ME OF FACILITY NO. DOW CQL CATION. Mom Road-s? Section No. Township City - County MALLE??oiwtnuo AMDLAMD HE OF OPERATOR NAME OF LICENSEE Wank Open 8. Licensed Closed Inspecting Unlicensed STRICTIONSISTIPULATIONS TO CONSIDER DURING INSPECTION Compliance (N) Noncompliance Does Not Apply u?r A. Protection ol Surface Waters REMARKS: 3 Hazardous Material/Liquids/Sewage Some observations made: Malena?; Pwh'bned for-D'sposa' 1. A drilling rig had recently plugged a salt well 0, Surface water Drainage located at the north and central perimeter of the i area. D. Period and Adequacy of Cover Id The perimeter security fence has been moved farther E. Completion of Area/Final Coverage out on the North and West: end of the site. F. Compaction 3. A new access road has been installed around the majority (approx. 75%) of the site. G. Leachate ControlfManagement Engineering Plans. Hydroge'glo ic 4. We monitoring wells were flowing at the North Evaluation 8. Construction Certification centra1 portion of the site. I 0 erations_ Contorm to Plan at Lcense Stipulations 5. 0n the Scuth Side of the landfill itself and toward the West end, a series of large sump cleanouts were installed to connect with existing leachate K. Blowing Debris. Dust Odor Control collection lines to assist in cleanout of leachate. collectlon systems. Vermin Control/Bird Control L. Gas Migration Fire Protection and Restriction of Burning . . . This Slte 15 currently undergOLng further analy51s N- Eqmpmem Adequacy by DNR geologists, etc. and further discussion regarding proposed monitoring well program will resume in the near future. 0. Restricted Access/Attendant P. Traffic Flow