5 November 28, 1983 POSEYVILLE LANDFILL-Poseyville Rd. Two Dow workers claim that the remains of the Trichlorophenol building was put in there. Dow capped flowing artesian well about five years ago, behind Bobbie's Party Store. One next to it still being used. Landfill has no clay liner. Dow had told residents that it was not to be used for hazardous material, only saran wrap, etc. Retired Dow worker claims that sludge from wastewater treatment plant was placed in there, as well as asbestos, and barrels at the highest point. Dump has had no regulation by DNR. Natural clay on three sides, nothing on north side. Clay slurry put in, 1980, according to DNR. According to SUE Thayer Dow dumped in open field behind the dump. She grew up in the area, and swam in the pond, that Dow later filled in. Dow tested her parent's water about two years ago. Dow man who talked to her father afterward said he wouldn't drink the water. Her father's name is Clare Beebe,635 fatterson Rd. Hisnhouse backs up to the dump. Others in area have had similiar water problems. Sue claims that the flowing artesian well that is still running tastes like fuel oil. Many people have stopped using it in the past year. The Ashby Drain used to run through the dump. Area in floodplain. MIKE OWENS phone# 689-3981 :Retired Dow worker. Owns junkyard . Skin problems, that have begun to clear up since he left Dow. Has much information about area(Larkin&MillsO) SMITH's CROSSING ROAD Sue Kretz-About two years ago, the Midland County Health Department, did sampling on resident's wells. The residents didn't request this sampling. Six homes were sampled, near River Rd. A Dow worker told me that his son lives on Smith's Crossing Road, and is carrying his water. Don't know exact location. Boseyvillo 241?l, I (killed ltuoty 1 of Wth?f, to run; hinl bl ask him to investigate the Poseyville bump, in Midland. ?e had been told by two wa workers that the Jl?? :triohiorophenol building had been plaCel t? this dump some years ago. 1e were also told that they had a lot of problems a few years bank with spontaneous fires, and had to run a special line into the dump to put them out. 1 was told by a retired Dow worker that How capped a fl?w;?f artosian well about a quarter of a mile doWn the road behind hobbie's larty Store. I ?found that there was uniarte?isnell behind the party store, but it was flowing. was told that there was one nekt to it that was capped. According to neighboor hood resident the flowing well has developed an oily tastv within the past year, and many people halo stopped .sing it. In 1980?81, some of the residents had problems with their private wells~discoloration and odors. A 1980 study revealed that this landfill had he compacted clay liner,and test borings encountered an aquifer within 20 feet of the bottom of the adjacent fill. DNR has met with Dow at least twice since my phone call. It appears that the facility was never licensed, and no sampling has been done on the wells yet. I asked the_unr to ask Now if they capped an artesian well but they forgot to ask the question. A soologist from DNA is now ovaluat? the site. Although Dow put in clay slurry on the Northeast side of the dump, in 198f it was operated for years without proper containment. 1 think an assessmm of the wells in the area should-be done. It is my understanding that ther. are quite a few artesian wells in that area. Dow CHEMICAL USA ?47, 5, Kay's??n? May 31, 1983 DIVISION MIDLAND, ass-so Mr. Hilliam D. Marks Acting Deputy Director RECEIVED 091933 HI Department of Natural Resources aouuwsrexmoe v.0. Box 30023 JUN 1 0 1983 . Lansing, MI 48909 . 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 ?tank. 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"Lame AN OPERATING UNIT OF THE DOW CHEMICAL COMPANY i Hu? un?uqnw 1? moat, Mu ?q I Mr. Nil?liam p. Perks.r 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. - I Following the flushing of the processiequipment 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 Haste 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 U.S. Environmental Protection Agency pursuant to 42 USC 9601 and, derivatively, to the appropriate Michigan authorities under 103 of that statute. i 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 Waste 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 m1: gration of materials associated with this project has occurred. Con- i sidering the combination of the geologic conditions and the cleaning I procedures prior to placement in the landfill, it is reasonable to i conclude there has been no adverse environmental impact. 1 Registered Trademark of The Dow Chemical Company. uobnqauw go smug sq: Aq pID?po. to 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 nuhupnw 'n Il?l'. I'll ?q November 28, 1985 . POSEYVILLE LANDFILL-Poseyville Rd. . Two Dow workers claim that the remains of the Trichlorophenol building was put in there. I I Dow capped flowing artesian well about five years ago, behind Bobbie' Party Store. One next: to it st-illibeing used_ Landfill has no clay liner. Dow had told residents that it waslnot to be used for hazardous material, only. saran wrap, etc. . Retired Dow worker claims that sludge from wastewater treatment plant was placed in there, as well as asbestos, and barrels at the highest point. Dump has had no regulation by DNR.: Natural clay on three sides, nothing on north side.? Clay slurry- put in, 1980, according to DNR. According_to SUE Thayer Dow dumped in open field behind the dump.~ She grew up in the area, and sWam in the pond, that Dow later filled in. Dow tested her parent's water about two years ago. Dow man who talked to her father afterward said he wouldn't drink the Water.' Her father's name is Clare Beebe,655 fatterson Rd. HisnhouSe backs up.t0'the dump. Others in area have had similiar water problems.. Sue claims that the flowing artesian well that is still running tastes like .fuel oil. Many people have stopped using it in the past year. The Ashby Drain used to run through the dump. Area in floodplain. . . EIKE OWENS phone# 689a3981. I iRetired Dow worker. Owns junkyard-. Skin problems, that have begun to clear up since he left Dow. Has much information about SMITH's CROSSING ROAD Sue Kretz-About two years ago, the Midland County Health Department, did sampling on resident's wells. The? residents didn't request this sampling.. Six homes were sampled, near River Rd. A Dow worker told me that his son lives on Smith's Crossing Road, and is carrying his water. Don't know?exaot location. I HOMAS ANDERSON CAROLLO A HOEFL-H I Frauen BJONSMA HtLAn'r SnetL PAUL WENDLER HARRY TO: FROM RESOURCES COMMISSION ATE OF MECHJGAN Kite: JAMES J. BLANCHARD. Governor DEPARTMENT OF NATURAL RESOURCES STEVENS T. MASON BOX 30028 LANSING. Ml 48909 RONALD SKOOG. Dreclor December 2, 1983 Larry C. Holcomb, Executive Secretary Toxic Substance Control Commission Richard 5. Johns, Chief Groundwater Quality Division SUBJECT: Poseyville Dump Near Midland In reaponse 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: 1. 3. runs 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: a. 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. Dow Chemical in a letter dated May 20, 1981, cepy 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. 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. Mr. Holcomb -2- December 2, 1983 4. 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. 5. There are monitoring wells around the site. Our file contains little information on data from these wells. 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. vHarks' inquiry regarding the trichlorOphenol building. Dow in? 6. In a letter of May 1983 Dow Chemical re5ponded to Mr. William dicated that the building, process and product piping, vessels, equipment, heat exchangers and filters were thoroughly cleaned I 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 trichlorOphenol. 7. The landfill has been closed and encapsulated with leachate col? lection. Additional information required to assess this problem are: a. 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. ?1 '1 1 1 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 [/Diane Hebert DOW CHEMICAL USA. May 20, 1981 mmHmAN MIDLAND. MICHIGAN 48640 RECEIVED Mr. Larry Thornton Resource Recovery Division Department of Natural Resources MAY 20 188] P.O. Box 128 ROscommon, MI 48653 Resource Recovery Division Regmn Dear Mr. Thornton: SUBJECT: POSEYVILLE LANDFILL CLOSURE As discussed with you on 4/30/81, I am providing as?built drawings of the leachate collection system for the north, west and south sides of the Landfill. The flow rate from the north sump has been measured at approximately 50 and south sump at approximately 70 gpm. Leachate analysis has been measured as follows: REE Chloride 9,940 TOD 1,320 TOC 680 pH 7.5 Leachate organic analysis have identified and confirmed the presence of six organics at less than 10 for each constituent. A more ex? tensive evaluation would be necessary to determine the key compounds. Inorganic analysis for brine chemical levels have been performed and are consistent with the brine and inorganic chemical residues disposed at the site. Landfill materials have consisted of plastic materials, demo- lition debris, rubbish, latex, waste treatment sludges, fly? ash and Cinders, incinerator ash, asbestos, spill ?yard clean?up solids, FDA products salicylic acid, and and inorganic residues. A further discussion of these ma- terials is enc103ed. Drawings showing the final grades and contour of the site will be forwarded to you as soon as they are completed. Rain has held up survey field activities over the last two weeks. Sincerely, J. D. Wilson Environmental Services 636-5925 i Enclosure 5 AN UNIT OF THE DOW CHEWCAL COMPANY -obuuauw man; an? ?q our-pom. (gr :3 RECEIVED WASTE MATERIALS WW 20 1981 Resource Recovery Division Latex Sludges Latexes are polymer or copolymer particles disthQE? in water. They are important to industry primarily as binders and saturants. Examples are styrene?butadiene latexes and vinylidene chloride latexes., Plastic Molding and Extrusion Materials Dow produces three major types of plastic molding and extrusion materials: styrene?containing, ethylene and chlorine-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: (styrene-acrylonitrile copolymers), ABS cepolymers), and STYRONG polymers). Uses include injection molding, cups, lids, toys, furniture, automotive parts, appliances, etc.. Flocculants 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 for solid! 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. Product Residues cellulose ether products are water- soluble gums having surface?active properties and selective organic solubility. unup?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 properties. Some products are used as food thickeners. Ion Exchange Resins ion exchange resins are produced in four major types. Strong acid cation resins are capable of exchanging cations, or posi? tively charged ions. For example, such resins will exchange sodium (Na) for calcium (Ca) and magnesium as in water softening, or hydrogen for {a mole an? an; peanpom a '3 -2- calcium, magnesium, and sodium, as in "salt splitting". 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 weak resins 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. The Beak acid cation Foaned Product Residues rafts, insulation for residences, etc. Residues resin are used as gel lacquer coatings for bowling pins, and glass bottles; hot~melt strippable coatings and for paper coating, electrical insulation, bronzing, and alkali resistance lacquers. or viscosity modifiers for nitrocellulose 1 release coatings, printing inks, These products generator field coils, paper coatings; lacquers strippable coatings, fabric coatings, They are also employed as binders acquers, glass frits, delayed? varnishes, and pigment print pastes. Inorganic Residues Examples: Calcium chloride CaClg Magnesium hydroxide Magnesium sulfate Mg(804) Potassium bromide Sodium bromide NaBr Asbestos Insulation and Demolition Asbestos FDA Products Salicylic acid residues, SARAN Demolition Debris from Building Demolitions mite ,Trea tment Sludges Flyash - Cinders from Powerhouses RECEIVED MAY20198I Incinerator Ash ?p111 Yard Clean?up Solids Resource Recovery Division Region II tab-qauw 40 am"; am Aq pa )npmu, Dow rerures ECOMM charges '08qu Milk-J3 . By KEITH NAITGHTON ECOMM ALSO CITED an accidental Dailv News staff writer incineration pounds ofthe herbi- cide 2.4.5-T at the Midland plant in Au- gust. 1981. Ro?wley said the incident was re? ported to the EPA in July, 1982. to de? termine if the incident was covered by the rl?oxic SubstanCe Control Act. Dow did not hear from the EPA until May Bil. 1983. when the agency issued a notice of alleged violation and a proposed line. Rowley pointed out the company re- ported the incident publicly in May. Mrs. Wilson said the inciner- ation is 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 journal which said heatofB?UU degrees Fahrenheit is necessary to destroy di- oxin and any temperature below that leVel would actually increase the am- ounts ol'the extremely toxic l'orni ofdi- oxin known as 2.3.7.8-TCDD. . The phenoxy herbicides, which had a low level ollthe 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 incmerator at 1.800 degrees F. Dow studies. as well as other studies. have shown 1.800 isan acceptable temperature to break up di- oxin. towleysaid. An EPA document the group pre- sented Thursday said "there is no cease to make it {the incineration} a major issue because Dow voluntarily admit- ted to an inadVeru-nt disposal and be- cause only a small quantity ofthe mate- rial having low levels contaminationisinvolved." 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-US. 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 ECOMM's 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 ofsources indicating?Dow is involved in nighttime sprayingwhich may be designed 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 ofany nighttime spraying by Dow. ?If somebody had been doing any spraying at nighttime. my Operators would haVe reported it,? Strejcsaid. The city Sprayset night because win is 10w..tempcruturu=s are right, and truf- ECOMM ALSO CHARGED Dow's -. Poseyville Road landfill in Midland ECOMM F?URTHERalleged Dow has contains Wastes from Saran Wrap pro- strong influence over the Environ- duction and carcmogenicashestos. Mrs. mental Protection Agency andthestate? w?ltl?m 5h? h? Department ofNatural Resources. and motion fromla dnll?" by meets with the agencies behind closed and llindo. Ltd. 0' Pennington . s. duaronley said Dow has had just two ??towley verified the landfill contains I meetings with the EPA and gave the Saran scraps ?Pd lm?tl?i?hl?t'b" agency a tour ofthe plant before it star- has winch may haVe lormerly been used ted its dioxin study. . forinsulation. Disposingofashestosina 3??,le also denied-a claim Dow had land?ll is the proper way to handle the been disposing brine in deep wells in carcmogenicsubstaiice.she noted. Midland County. ECOMM believes the However. Mrs. Wilson claims the brine may have been used in chemical study also indicated the land?ll did not processes. have a compacted clay liner. On the brine deposits. Mrs. Wilson Dow commissioned the Neyer. ?l?iseo. said she receivedherinformationfroma and Hindu-study April. 1980? R'Mlcy chart entitled Oil and Gas Field Brine said. That was before the landfill was Disposal By County. which is part ofa- 1981 study by Western Michigan Uni- linenshe ?dd"d- 1 varsity for the EPA. The group also alleged Dow former Mrs. Wilson claims the chart indi- trichlorophenol plant was dismantled cates 24 million barrels were trucked andinay have hem i? the and hauled from the Dow plant to an eyville land?ll. Mrs. Wilsonsaid the unknown location in the. Porter field .group received the information from anddis isedof. one anonymous source. . "'Thdre isn't any information here i re?( that leads us to belieVe the brine was mains are taken into Dow." Mrs. Wilson said. Rowley said the group is interpreting the charts incorrectly.lThe brineEC- OMM is referring to was trucked from oil and gas drilling sites to the plant for usebyth'ecom any.shesuid. .1 1 "Dow has nepver had any disposal op? ?if? ECOMM. erations in Porter Township. but has . Nobody ever calls us on the phone received brine from the area," Rowley and says ?What are your ideas?," Mrs. said. - Wilson said Thursday. - ECOMM held the press conference because the group?s concerns were not being inVestigated hy the EPA or the DNR. Mrs. Wilson complained the agencies do not always ask for input MEMORANDUM STATE or MICHIGAN TOXIC SUBSTANCE CONTROL COMMISSION lensing 00W November 1, 1984 T0: Dave Dennis, Chief Compliance MDNR FROM: Keith G. Harrison, M.A., R.S., Cert. Ecol? Senior Environmental Specialist SUBJECT: Rockwell Road Landfill (Midland County) We wish to obtain an update regarding Dow Chemical Rockwell Road Landfill. In your 6/28/84 memorandum you indicated that you intended to split-sample and again in July or August. Has this done; and if so, what were the results? Secondly, in a 7/20 memorandum from Daniel Schultz, it was indicated that, weather permitting, the needed repair work to the clay wall should be completed by 10/1/84. Has this schedule met? Finally, it was also indicated in Mr. Schultz's memorandum that the Air Quality Division staff was evaluating a request for air monitoring during the construction phase. Has the request favorably considered; and if so, what were the results? Thank you for your assistance in this matter. cc: ,Bfane Hebert Del Rector Larry C. Holcomb Midland County Health Department MEMORANDUM STATE OF MICHIGAN TOXIC SUBSTANCE CONTROL COMMISSION Lansing -November l, l984 I ale: T0: Dave Dennis, Chief Compliance MDNR FROM: Keith G. Harrison, M.A., Eco . Senior Environmental Specialist SUBJECT: Dow Poseyville Landfill (Midland Cbunty) Pursuant to your 9/l4/84 memorandum, you indicated that test results for Hell #25, Dow Poseyville.Landfill; had been resampled and that the test results were to be available in about two weeks. Are you currently in receipt of these results? If you are, could we obtain a copy of them? Secondly, you indicated that Dow was in the process of testing of the keyway and that the results would be available in the near future. Have these tests been concluded? Again, if they have, could we please obtain the results? Finally, your memorandum also indicates that a map showing the locations of the wells and leachate sumps would be transmitted to us. He would appreciate it if you coUld look_jnto this matter for we have not received any maps to date. 1 Thank you for your assistance. cc: Larry C. Holcomb -1?ane Hebert Del Rector Midland County Health Department Water Resource Consultants Full sampiing, lab analysis and environmentai planning CLIENT REPORT services or self-help training programs Wally Fusilier, Charles Cubbage. 9200 Dexter-Chaisea Fld. January 22 1983 826 Sqwre Lane Dexter. Ml 48130 Miiford. Ml 48042 (313) 426-8972 (313) 684-3545 Andrea Wilson 310 E. Ashman Midland, Michigan 48640 Re: Rockwell Road Disposal Site Associated Health risk Evaluation Contact initiated November 23, 1982 Report Summary A number of observations made during the site visit and the available DNR and Dow chemical analyses from the site point to some very important questions about the integrity of the landfill clay liner and to a serious lack of identity for up to 90% of the organic materials measured by the TOC analyses. While the single WQI site sample taken on November 24. 1982 was negative for the tested organics. it should not be inter- preted as a measure of site fitness. Only an expanded sampling program and broadened chemical analyses could do that. The negative results from the analyses for specific organics in the Kern's well water is reassuring and the TOC level was typical for groundwater. The Latest round of samples should help fill in the gaps regarding the unidentified organic compounds. It should also characterize the organic make-up in the residential water supplies. The current uncertainty about the effectiveness of clay liners,coupled with the above concerns.emphasizes the need for continued surveilance in the area. These concerns have been voiced to the Michigan DNR and Public-Health officials as well as to the Toxic Substance Control Commission. Water Resource Consultants Full sampling. lab analysis and environmental planning - estigato rs CLIENT REPORT ?Wes 0? training programs Wally Fusilier. 52:: 9200 Dexter-Chelsea Fid. January- 22 1983 Millordq MI 43042 Dexter. Ml 48130 (3135 684-3545 (313) 425?3972 ROCKWELL ROAD SITE AREA Site Background and Location The site is identified by the Michigan DNR as the Dow Chemical Rockwell Road Disposal Site located in the of the Section 31, T14N-R3E, Williams Township. Bay County. The site lays immediately of Rockwell Road between Milner and Bailey Bridge Roads in Bay County. Rockwell Road forms the Midland-Bay County line in the area. See site map. Historically the site has been used as a landfill for materials referred to as ethyl benzene tars. The terrain for the approximately 7.5 acre "landfill" is quite flat with a wetland of several acres to the and SE.- The topography gradually drops about 30 feet between the site and the Titta- bawassee River which curves to the north approximately 1% mile to the SW. Apparent discharge from the landfill led to WQI's site visit and the limited sampling as well as to the request for a review of the issues defining the possibility of health risks for residents in the area. The following narrative includes a review of the geological data, our laboratory findings, site observations and evaluations, DNR and Dow chemical analyses, and geological concerns. Geological Review The following comments are based on information from the geological surveys by Williams and Works, Michigan DNR Geological Survey staff, area residents. and our own consultation with professional geologists. A profile of geological features is included to show the relationship of the site with area :Tsite lo ation'r. n. .t 3 2: sir} . . gamma EggIVtwWrit-tn} at3:5372'45 . - a" i I [mono-GWEN MAP COUNTY ROADS HIGHWAY MARKERS LOCAL PRIMARY State Trunkline Hard Surface cram HardSurface - .5102 II 3 topography. aquifers and residences. See attached profile, Figure 1. I The disposal site is now a mound. several acres in size, rising about 12?15 feet above the ground level. It's design consists of a clay cap and sides covered by a layer of t0p soil, with the clay extending through 13-15 feet of sandy soil to the underlaying natural clay. The adjacent land is quite flat with a wetland consisting of cattails and standing water. several acres in size also, to the and SE of the mound. A drainage ditch extends from the wetland at the SE corner of the mound. along the side of the mound. to a drainage ditch on the side of Rockwell Road. During the site visit on November 24. 1982 slight flow was noted in the south ditch into the Rockwell Road ditch. To the of Rockwell Road, the sandy soil thins out and the underlaying clay reaches the surface about midway between Rockwell Road and Bus Road. The groundwater in the sandy soil constitutes a perched aquifer, setting on top of the clay. The water table for this aquifer creates the standing water in the wetland and slopes downward to the as indicated by the water level standing in the test wells of Rockwell Road. The westward migration of the water is also noted by the plume observed extending from the landfill as indicated by the data. It is reported that during very wet conditions. groundwater flows downhill to the west through the sandy soil and discharges to the surface of the fields in the area where the clay sur- faces. The drainage then flows into the adjacent ditches. An extensive deposit of clay nearly 150 feet thick, with a band of sand and gravel at the 40?50 foot level extends downward to the underlaying bedrock. The Midland County Health Department records of well logs indicate that at least six residences of the site on Bus Road use the aquifer confined in the sand and gravel layer as a source of potable water. The extent and continuity of this aquifer has not been fully defined. Figure 1. 8 L1 mi =1 West I 1 9 a, East disposal Consumer monitoring Site gowir Pl residential wells 9 wetland uc ear an 11 Tittabawassee we 8 - sandy reigg?_ River - perched aquifer cia 1?7 600' 600' clay .p sand and gravel aquifer I _u_i 1 Approx. 150' ay clay aquifer gradually increasing in brine content with depth. Horizontal scale: 1" 1000' brines Vertical scale: 1" 50' . n4? Laboratory Report As indicated in the attached analytical report from the Environmental Research Group. Inc. of Ann Arbor, Michigan, phenols, toluene, and ethyl benzene were not detected in either of the samples collected - the residential water supply of the Kern's and the surface water collected from the ditch along the south side of the Rockwell Road site. I The numbers in parentheses under the column marked on the analytical report indicate the lowest concen? tration of each substance that can be detected by the technique used at the laboratory. Except for TOTAL (TOG), all compounds could have been detected in the low part per billion (ppb or ug/l) range. It is important to keep in mind that phenols, ethyl benzene. and toluene are specific organic compounds while total organic carbon (T00) analysis is a non?specific test which would measure the concentration of all three specific organics plus any other organic compounds that might be present, withOut identifying them individually. The concentration of TOC would then be the sum of the carbon from all of the specific organics in the sample. When dealing with concentration measurements. it is also important to keep in mind that 1 part per million (ppm or mg/l) is the same as 1000 ppb. The TOC concentration in the Kern's well water was 1 ppm. Normal groundwater levels range from 0.1 to 10 (Cherry and Freeze. 1979). and Michigan DNR geologists familiar with the area have commented that 5 are common. ?ite Observations and Evaluation Several observations made during the November 24. 1982 site visit raise questions about the current integrity of the landfill. A number of inch diameter holes exist on the mound side of the south ditch at or below the water-line. Small (2?h'inch) underwater channels undoubtedly indicate muskrat activity. (See previously supplied photographs). They may have PRDJECT 9181 ANALYTICAL REPORT ENVIRONMENTAL RESEARCH GROUP, INC. 117 N. FIRST ANN ARBOR: 48104 (313) 662-3104 CLIENT PER J3 SAMPLES RECUD: 11-29-82 REPORT: 10197 REFER TECHNICAL QUESTIONS TD: JOHN CLIENT: QUALITY INVESTIGATGHS 82a SOUIRE LANE MILFORD, MI 48042 ATTENTION: c. CUSBA GE 41* CLIENT I.D - #1 Kernfs residential well water ERG SAMPLE MATRIX: METER PARAMETER RESULTS PHENOLS ND (0.004) TOLUENE (2.0) ETHYL BENZENE NO (2.0) CARBON. TOTAL ORGANIC. 1 CLIENT I.D. AKPLE #2 Rockwell Road site surface water ERG SAMPLE 11/08 2523 MATRIX: GROUND NA ER PARAHETER RESULTS PHEIIOLS ND 0043 HO (2. O) ETHYL BENZENE NO SEE FIELD REPORT FOR PESULT NOT APPLICABLE TO TEST REQUESTED NCNDETECTED. DETECTION LIMIT IN SAMPLE SEE REPORT FOR RESULT POSITIVE RESULT BUT A. UNOUANTIFIABLE CONCENTRATION BELON INDICATED LEVEL THANK YOU FOR YOUR BUSINESS PAGE 1 LAST PAGE UNITS mg/L ugfL ug/L mg/L mg/L ug?L ug/L caused the holes or may have taken advantage of already existing ones caused by internal site leakage (note observation given _below). The wetland is an obvious muskrat habitat and any burrow- the side walls of the landfill. The presence of an orange sediment laying in the ditch along some of the "muskrat runs" suggests that the landfill contents may already be leaking (see photographs). mound. The film did not appear to originate from the wetland since the film was on the mound side of the ditch. heaviest where trapped by emergent vegetation. The possibility of already existing leakage mentioned above by Dr. Norman Zimmerman of the TSCC staff. Prior to our site visit on November 1982, following heavy rains, a spring? like bubbling?up was observed coming up from the bottom of the ditch into the water from underneath. This "muddy" spring was located at the far SW corner of the landfill in the Rockwell Road ditch. Because of the flat terrain there is have been due to a build?up of water within the mound. Such a build-up would accelerate erosion of the clay liner through any existing breakthrough. At the time of our WQI vdsit the from the ditch, a broader range of chemical testing is needed to properly characterize the noted surface film. orange sedi- ments. and, if noted again, the springelike flow into the ditch. While a single positive sample may confirm leakage, a neg- ativeresult.does not confirm safety. Proper monitoring would include samples from various surface. groundwater, and interior just outside the base of the ghemical Analyses - DNR and In reviewing the availa portant discrepancy. Over 9 monitoring well samples, as not been identified. The TOC test. as mentio for organic carbon. Monitor contained more than 30 mg/l analyzed for specific organi and toluene) yielded results only some 10% of the organic the inadequacy of organic ch ted to T800 and DNR staff. latest round of sampling ana shortcoming may be cleared be completely identified. It is quite possible th be found for at least part 0 Decaying vegetation from the from the monitoring wells ma perched aquifer which would anlayses could determine the The presence of humus raises research shows unexpected or . mound. In this way any leakage would be excluded from the wetland area and could be easily sampled. This improvement DNR site staff. as already been suggested to the Dow ble test-well data we find an im- 0% of the organics present in the measured by the TOC levels. have ned above, is a non-specific test ing well samples have frequently of TOC. The same samples when compounds (phenols, ethyl benzene. in the ug/l range, identifying materials present. Concern for aracterization has been communica? It is our understanding that the lyses was broadened so that this p. Hopefully, the organics will at a natural source of TOC can the unidentified organics. wetlands which are up-gradient have produced "humus" in the add to the TOC. Only complete extent of such a contribution. another question however. Recent ganic compounds occur as the occurred at the site nor that such compounds pose a threat. but when 90% of the observed organics have not been identified, it may be wise to consider the possibilities when trying to characterize them. Geological Concerns Residents on Bus Road have expressed a concern for the safety of their water supply. drawn from the 40?50 foot aquifer. Unfortunately, the ability of clay, including the natural clay underlaying the Rockwell Road site. to retain organics has not been demonstrated. Actual field experience with pr0perly constructed clay liners has been too short and too limited. Experimental laboratory results are conflicting and techniques have been questioned. The original attractiveness of clay as a liner was based on the very low rate of movement of materials (permeability) through clay, on the order of a few inches per year. Current work indicates that the movement of non?polar or polar organics like those in the mound may move as much as 20 feet per day through clay (TSCC Dec. 1982), although again, the research is being questioned. At another Michigan groundwater contamination site. while_ the situations are not directly comparable because clay is not involved. styrene (very similar to ethyl benzene) was detected more than 40 feet below the water?table when the source was on the surface of the ground. The DNR staff has been unable to account for the presence of the styrene at that depth, given the circumstances of the site. This reinforces the uncertainty regarding the dynamics of groundwater contamination. With this in mind, continued surveilance of the Rockwell Road site and the Bus Road residences would appear necessary. Improbable as it might seem, another potential complica- tion should be noted. Consumer's Power nuclear plant, two miles west and across the Tittabawassee River. is pumping significant quantities of groundwater into the river in a dewatering attempt due to foundation settling. 'Since the extent and continuity of the 40?50 foot aquifer mentioned above has not been fully evaluated, it is conceivable that Consumer's pumping could creat a significant drawdown and accelerate the westward movement of the water in this layer from under the Rockwell Road site past the residential wells on Bus Road. ?dck?vm/ -. Oej Cs ,ler m. A. . . {Bk 1?17 u' PM ?llAc be . 6K316-? A- I .- I Lilkgarl' ?01: +931 I 1-3/1 ?5 L?t*Qiuq at. I . .. i .- bJa' HE I?vsox?T-K L. a. ma 3?1 m. CcmH/x ?2-57 (K >14? L's?3' 5? kwa An? 07? L?s-ax La f\ h} 1&5. ?Id$4er (?01 rylume 3. 0L pk"; hx-CgMLD Lug} it: i cm. *1 Name of Revie Date: MM Genera! descri on the facility- Faclmy name: WW Location: 7? EPA Region: . Parson(s) In charge of the facility: MW Midland 4115124905 (For example: land?ll. surface Impoundment. pile, container; types of hazardous substances; location 0! the contamination route of major concern; types of information needed for rating; agency action, etc.) MW Scores: SM =6.67(Sgw Sa SFE 500 FIGURE 1 HHS COVER SHEET Ground Water Route Work Sheet Ftating Factor Assigned Value (Circle One) Ref. (Section) Multi- plier Max. Score Score Observed Release 45 1 0 45 3.1 If observed release is given a score 01 45. proceed to line B. If observed release is given a score of 0. proceed to line Route Characteristics 3.2 Depth to Aquifer Concern Net Precipitation 0 2 3 1 3 Permeability Unsaturated Zone Physical State 0 1 2@ 1 3 3 Total Route Characteristics Score 9 15 Containment 1 0 3 1 3 3.3 Waste Characteristics 3.4 ToxicityIPersistence Hazardous Waste Quantity Total Waste Characteristics Score /3 26 Targets Ground Water Use Distance to Nearest Served 012Total Targets Score 2?9 49 at line is 45. multiply If line is 0. multiply it 67% 57,330 Divide line by 57.330 and multiply by 100 59w' FIGURE 2 GROUND WATER ROUTE WORK SHEET ?5 Sun?ace Water Route Work Sheet . Assigned Value Multl- Max. Ref. Rating Factor (Circle One) plier Score Score (Section) El Observed Release CED 45 1 0 45 4.1 It observed release Is given a value of 45. proceed to line E. It observed release Is given a value oi 0. proceed to line Route Characteristics 4-2 Facility Slope and intervening 1 2 3 1 3 Terrain 1-yr. 24?hr. Rainfall 1 3 1 2, 3 Distance to Nearest Surface 0 1 3 2 4.. 6 Water Physical State Total Route Characteristics Score 9 15 IE Containment oCDz 3 1 3 4.3 Waste Characteristics 4,4 Toxicitytpersistence Hazardous Waste Quantity Total Waste Characteristics Score a 26 Targets 4.5 Surface Water Use 0 1 3 3 (I 9 Distance to a Sensitive 1 2 3 2 0 6 Environment Population ServedIDistance Water Intake Total Targets Score (I 55 ii line is 45, multiply 702} 54,350 It line [3 is 0. multiply Divide tine by 64,350 and multiply by 100 SW FIGURE 7 SURFACE WATER ROUTE WORK SHEET Air Route Work Sheet Ratin Factor Assigned Value Multi- Score Max. Rel. 9 (Circle One) plier Score (Section) Observed Release 0 45 1 45 5.1 Date and Location: Sampling Protocol: It line is 0, the 5a - 0. Enter on line It line is 45. then proceed to line . Waste Characteristics 5.2 Reactivity and 1 2 3 1 3 Incompatibility Toxicity 0 1 2 3 3 9 Hazardous Waste Quantity Total Waste Characteristics Score 20 Targets 5.3 Population Within 4-Mile Radius 21 24 27 30 Distance to Sensitive 0 1 2 3 2 6 Environment Land Use 0 1 2 3 1 3 Total Targets Score 39 El Multiply 35,100 Divide line El by 35,100 and multiply by 100 sa FIGURE 9 AIR ROUTE WORK SHEET 52 Groundwater Route Score Air Route Score (83) Suricce Waler Route Score (Saw) 0-00 22: ?7 7/ FIGURE 10 WORKSHEET FOR COMPUTING SM 4H- 3.8; ?//o69 [p.67 Fire and Explosion Work Sheet . Assigned Value Multi- Max. Ref. Rating Factor (Circle One) plier Score Score (Section) Containment 1 3 1 3 7.1 Waste Characteristics 7.2 Direct Evidence 0 3 1 3 Ignitability 0 1 2 3 1 3 Reactivity 1 2 3 1 3 Incompatibility 0 1 2 3 1 3 Hazardous Waste Quantity Total Waste Characteristics Score 20 Targets 7.3 Distance to Nearest Population Distance to Nearest 0 1 2 3 1 3 Building Distance to Sensitive 1 2 3 1 3 Environment Land Use 0 1 2 3 1 3 Population Within 2-Mile Radius Buildings Within 2-Miie Radius Total Targets Score 24 Multiply El 3: 1.440 Divide line by 1.440 and multiply by 100 3 FE - FIGURE 11 FIRE AND EXPLOSION WORK SHEET Direct Contact Work Sheet . Assigned Value Multi- Max. Ref. Rating Factor (Circle One) plier Score Score (Section) Observed Incident 0 45 1 45 8.1 is 45, proceed to line Ifllne is 0. proceed to line Accessibility 0 1 2 3 1 3 8.2 Containment 0 15 1 15 3.3 Waste Characteristics Toxicity 0 1 2 3 5 15 8.4 Targets 8.5 Population Withina 1-Mlle Radius Distance tea 0 1 2 3 4 12 Critical Habitat Total Targets Score 32 [a lfline is 45. multiply is 0. multiply 1: El 21.600 Divide line LEI by 21,500 and multiply by 100 Sec .. FIGURE 12 DIRECT CONTACT WORK SHEET ecology and environment, inc. . 23 WESTJACKSON BLVD., CHICAGO, ILLINOIS 60606, TEL. 312-663-9415 International Specialists in the Environmental Sciences 0/535; 0005 721/7: 157/983 7 phadm cammanx?carl/017 M/d/and doum?y ?ea/H7 040709770725 M/d/and, .i ,2 . 5007?}; Quail/?779A: .7 7 7 5" ?zz/7517?s Jane's {a/opo'jmp/ub) 477,2. 7/0/7767: urged 75 3. M2 reg QD/?pard??n Jixine. /07 W52 7 (7760/7 ?rm/ac: Ha 29/271021; W?sfa 5/74: font/27:7 Sgs/csm- A Use/5 Mama/a/ til 5/7 V/kvnmen/a/ Qatari/m Aye/75y. 4. 73m&, 079/717 .4 . 2 Jane. {gamma/7mg 7627'? [2944) 0732772657/ 43.74 En 172?027 mm Sex-wees 7 Mam/77?) i 14/2/0707: 79 ?/ya?mqeo/oq m7 177 ves?ba?bn of #75 ?056sz 62707 4265/77/54; 12/30050/ 5/29 Abr 76/75, Maw/42727 of 7/7/73. $654) @7377ch Compony? 7 Grand gap/7?5 MA: by 00. recycied paper June 28, 1982 1< DOCUMENTATION RECORDS . 6 FOR PL HAZARD RANKING SYSTEM INSTRUCTIONS: The purpose of these records is to provide a convenient way to prepare an auditable record of the data and dOCUmentation used to apply the Hazard Ranking System to a given facility. As briefly as pus-I sible summarize the informa_tion you used to assign the score for each factor "Waste quantity 4, 230 drums plus 800 cubic yards of sludges"). The source of informatib4_ should be provided for each entry and should be a bibliographic-type reference that will make the document used for a given data point easier to find. Include the location of the document and consider appending a copy of the relevant pageCs) for_ease in review. FACILITY NAME: 205211121? 8000? Damp I . LOCATION: Paciwsa good ?ne. mes/-S/ob QF 556172,? 7?74 may: mas/740 52y 300/79 . i I I GROUND HATER ROUTE OBSERVED RELEASE Contaminants detected (5 maximum): No observed rag/ease: . Rationale for attributing the contaminants to the facility: 'k i i 2 ROUTE CHARACTERISTICS I Depth to Aquifer of Concern Namejdescription of aquifers(s) -of concern: 79$ of/ess - me. 07?0?59 5 unfaz- mm?er/a/ Fog/2d0:510 16,? #70/7 5?0 )m051? r/ mfg. we. raaw?er ?aon 629/37. and coa/ bar/n 5/0 #73. 0639/ zha?z?a?z 9/30/1357? *h/ctness of a (xx/er ma?a/70 Occurs baa/ow A90 Fv?. #5?29'3' Depth(5) from the ground Surface to the highest seasonal level of the saturated zone [water table(s)] of the aquifer of concern: A pn'vafe, cue?? x'n fhe, area. has 19?s we? Saree/7 as! befween 370/70? 42- @rmfasr? dope/7 of confam/nmLca: agar/Fer as" 01? A819. Dfpv?h may vary beg/Tween 2,479. 000? 29 FH. ?3 cream Depth from the ground Surface to theilowest point of waste disposal} storage: E7776 #73. mow/500m 4610/77 off/73 [Dara/76d OQu/f?r- lee/erenca #51 HH- i Net Precipitation Mean annual or seasonal precipitation (list months for seasonal): it App?coximaraly 29 mam-s . ecfarencc. *3 . Mean annual lake or seasonal evaporation (list months for seasonal): Approximala/y 29 Mahala. Eafarencaa? . i Net precipitation (subtract the aboveifigures): 1 (29*1931hchas 0? Permeability of Unsaturated Zone 1 Soil type in unsaturated zone: Cfay. subs+ra+um . . 6' and reaped/Va 190ij 1035 Permeability associated with soil type: 7.65 Jo?Em/sac. . . Reference. p. 5 and. reapaoz?zvaparmaabx/n?y resume . Physical State N. Physical state of substances at time of diSposal (or at present time for generated gases): ?Fang, boHom Siudgas from T?ha pmducho?n 0F army! bangana by mziiwhg H16. S/Udya 1h+o +175. sandy 50(75 0?1? 2778. Sire. Reference if5'. Phys/Cal 5+a+a [a 535*{9nad a. va/uc, 0753 150/- 0K905. tea/arenas #31 3 CONTAINHERT - Containment Method(?) of waste or leachate containment eqaluate 0/5505;de w/r?h c/doy SUbs?aM/v?) 05 9' Wort? repon70/77/556. Par #85 mama/M ?mega/M7 0F 4 /0'5z ma/arm/A?S ?70013?? 3/ farmed/3A5 par #85; Method with highest 5: modem #c?y panhaa can 2?0 no men Scores on assgneg? va/ue 0252. 4 WASTE CHARACTERISTICS 1' Toxicity and Persistence Commando) evaluated; I Bangs/75 3 Tea/Hen C. . 2, Eh?ay/ene, bcnjeha Compound with highest score: (156 banjana wh?h a. ?0X/b/?y 0F 3 and 6b pars/5 #ancc or? #25 Eaferance. ?5 -- thy/7557? Score; /2 . Hazardous Haste Quantity . . . . Total quantity of hazardous substances at the fac111ty, excluding those . with a containment score of 0 (Give a reasonable estimate even if quantity is above maximum): as from ?ve sluo? . . 53/ 7?56 57/1096. ?7:40 #75 50nd); 50/75 of?vig. 5x245. Adz/a/ 99/0/7797? unanow. 13.2515 of estimating and/or computinggwasCe quantity: .. Sznice, ?ve. 0/ hagam?oas. was As Unknown bur? observed #75 para/750? OQu/far; 055/;9/7 wash, a. Va/ag. a a . a. 5 TARGETS Ground Water Use k? Use(s) of aquifer(s) of concern within a 3-mi1e radius of the facility: Dn'nK/fy wm?er. Eefaranca cue/I {035. Eeference i Distance to Nearest Well Location of nearest well drawing from aquifer of concern or occopied building not served by a public water supply: A prkvafc. we// /0c0?e.d scuff? 01? Bus 9000? from Mx/naxi ?00? Mx/h er 8000?. Pa fare/me. ,br/vafa wa? by . - Distance to above well or building: Loss 200015;. 77%; chem/w/ 54/057423 on ?ve. .svfe, are. 0?5 fee/? b/a 7976 para/730? 0 was a Behave? 8000?. fan M27 boa/7:707: 02? 0cfad/5/71e . Population Served by Ground Water Wells Within a B-Mile Radius Identified water-supply well(s) drawing from aquifer(s) of concern within a 3-mile radius and populations served by'each: AppromMak/y 25' we? My .5 c/ao?aa? zea??renca w/v my? o?xclafe. #czr-Supp/y axe/As From me 0 (xx/er of cancer/7 . Approx/McKay add/:4 arm/we?s soc/#2 07/3/42, . Computation of land area irrigated by. supply we11'(s) drawing aquifer(s) of concern within a 3?mile radius, and conversion to population (1.5 people per acre): I Opp/r?o?/e. - Herrera/76? 59/. Total populatibn served by ground water within a 3?mile radius: /75' wall-5 3-8 Pdo/D/?/w?w ??fafmca 45+ 3, 5 I I i SURFACE WATER ROUTE 1 OBSEBVED RELEASE Contaminants detected in surfade water at the facility or downhill from it (5 maximum): 1 N0 observed reg/ease, . Rationale for attributing the contaminants to the facility: 2? ROUTE CHARACTERISTICS Facility Slepe and Intervening Terrain- Average slope of facilit in percent:' - Curran .. slap; of ?ve? wcopsy/a/ea? damp 5/7467 Has from pozhv? 7?0 pox/22?, (wage Mir 1% a eshma?o?yraa #esf s/ope. Is ?ve range of six parser)!- . Ea fare/762:. . Name/description of nearest downslopelsurface water: Nearasf- '43 0/7 anyomaa? drag/I5? - which /3 Mao/e #75 NE ?-af 555190;? 7) 773 N: 225 M/d/qn'q? Coanr?y. _?e/aranca . T776 092? map #73. Vi??a?vwaasee 22 var Average slope of terrain between facility and above?cited'surface water body in percent: pram/Maia Ssze mo .3519 AD .2500 H. . Assume /ess 21/7ch ,edfgr?m? Is the facility located either totalhy or partially in Surface water? - .app/x'cab/15 the facility completely Surroundedlby areas of higher elevation? area, 8/0/03, /5 p. Mammy #78. 1773/0bw055ac?. E/i?er. 1-Year ZQ-Hour Rainfall in Inches ApprOX/mar?e/y 2.1mm?. (Ba/ween _/nc/7?s of ram has an assigned vo/ae 0F 2.. Eta/arena; I Distance to Nearest DounsloPe SurfaceIWater ApproY/inavle/y .1500? H. Eeferance. Par #25 manuah assigned val/Lac, 0F 2. . Physical State of Waste I Tani: bo?om s/udgesi 25mm #76 produdmn? of e?hy/ bygm/y/ny .s/uo?ye [?7199 WM, 50/75 02? 517%,. Kai/"arenas. *5 - 3 CONTAINMENT Containment I OFM amt Method(s) of waste or leachate cootainment evaluated: . - Our/h Hm when ?ve wafer adv/a /s h, mac 0F we d/Van?ad r? a daze/7 and ponds From where/:1 002? ?s away as surface. wafer. {83/8/75/765 at 2/10. ,4 pens/260? Method with highest score: - alga/Far lay/?5715 under 7% 5/120, and 049563/?1/861 coanthIr/?n 7029/70 7? 5 5/713, cpl/dank Conszb?ar/h #76256 7? com?mx?vmem? H76. .5723 GODS/dared U?sound S/n'c mot/eme/h? ew?o?enf an assgnao? 1/0/46 02? 2. an For ?ve. Con/Q/hmenf ache. was %as 7 A WASTE CHARACTERISTICS . Tox1city and Fers1stence Compoun?fs) evaluated Banger?; 3- Toluene. . I Ev?hy/cno [De/75mm - a, Compound with highest score: (153. [panama w/i/?h fa. 0/?3 and a. pars/memos. of From #85 marl/7y; p.49, Reference. #3 -- hf?ih?g?s" Score . Hazardous Waste Quantitx Total quantity of hazardous substances at the facility, excluding those with a containment score of 0 (Give a reasonable estimate even if quantity is above maximum): Tank. bor?fom s/c/a?gies [mm #26; 0/ ezl/Jy/ bangs/mo, by ?7/me #75 Wag/?e, mm ?ne sandy sax/5 52"7?6 45*00/ gamn?niy anthown Ba51s of estimating and/or computing waste quantity: 5255:, guanr?My 02? ?ee. bags/?ows wasr?a unknown ,buf observed 7?77: para/75d aqu/Ver, 055/327 wasv?e. guonv?x'ry a yea/axe. of 5 TARGETS Surface Water Use Use(s) of surface water within 3 miles of the hazardous Substance: . There, are. 1107? any <3Uffoce war?er mJ?azes 61/0/73 unnamed dram 0r H76. W?ab?wassaa Ezv?x Lama/'2 1566. draft? emp?es' #2710. Eefererzac, as Score. surface wm?er use, on recrear?mn. 15 there tidal influence? N01l app/(Cable. . Distance to a Sensitive Environment Distance to S-acre (minimum) coastal Getland, if 2 miles or less: Nof app/I'cabia. EcFeranca . I Distance to 5-acre (minimum) fresh-water wetland, if 1 mile or less: Noe app/1'60 b/a . Eel/arenasDistance to critical habitat of an endangered spec1es or national wildlife refuge, if 1 mile or less: I i No! appn??ab/a. charem-a 1* .. Population Served by Surface Water Locati0n(s) of water-supply intake(s) within 3 miles (free-flowing bodies) or 1 mile (static water bodies) of the hazardous substance and p0pulation served by each intake: Zero. The wafer [or Mid/and anal Sarrouna?my areas are a/w?har Supp/Ied from 7052/05 Michigan . where. 2% x52 [Bum/02?. 0m! 02? Late, #uron 0r supp/(ad, by grbundwaq?er . Eafarenice. Computation of land area irrigated b; above- cit ed intakeCs) and . ponversion to population (1.5 people per acre): N04 app/(cable. . Total pepulation served: Zero (0). Name/description of nearest of above Neares+ wear- body I I 'u 5 water bodies: /5 ?ve. szer. No+ used For airmen?)3 wear can News :20 Used Fecre ghpneg/ agrp p225; :_Di5tance to a @ove- app/(dab/e, - .. 10 measure in stream miles. .. .. . -. - AIR i OBSERVED RELEASE Contaminants detected: No obserVadre/eos e, . I Date and location of detection of contaminants Methods used to detect the contaminants: . .- . .1 . Rationale for attributing the contaminants to the Site: I 2 WASTE CHARACTERISTICS Reactivity and Incompatibility . Most reactive compound: Most inCOmpatibie pair of compounds: 1.. 1? - -.. - Toxicitz a Most toxic compound: Hazardous Waste Quantity .Total quantity of hazardous waste: Basis of estimating and/or computing waste quantity: 3 TARGETS . Population Within A-Mile Radius 3 v- I Circle radius used, give poPulation, and indicate how determinedDistance to a Sensitive Environment I Distance to Snacre (minimum) coastal'wetland, 1f 2 miles or less: i I I I ?1 Distance to S-acre (minimum) fresh-water wetland, if 1 mile or less: I I I 12 .. i 1 Distance to critiCal habitat of an enQangered speCies, if 1 mile or less: 1 - 4.3 - Land'Use Distance to commercial/industrial area, if 1 mile or less: DiStance to national or state park, forest, or wildlife reserVe, if 2 miles or less: Distance to residential area, if 2 miles or less: Distance to agricultural land in production within past 5 years, if 1 mile Or leSs: 1 . 1 Distance to prime agricultural land in productidn within past Sayears, if 2 miles or less: Is a historic Oralandmark site=(National Register or Historic Places and National Natural Landmarks) within the view of the site? 13: 4-.- . .l Nowember '83 Linda Kerns-1374 Bus Rd.-ph# 496?2393 Water Problems Esther Grell-4819 E. Bailey Bridge Has been unable to drink her water since the spring. Oily taste and smell. No sampling done yet. South of Dow Rockwell mi.) Mrs. Sugar 48T9 E. Bailey Bridge Rd.-ph# 496-2783 Unable to drink water. Black sticky substance that settles to the bottom, and odor. South-ofDDowRRockwell Dump. Bus Rd. West of Dow Rockwell Rd. Intermittant water problems. Recently water has black material that settles to the bottom of a glass. Mary Ellen Noack- 1726 Fieldcrest- ph# 496-3226 September 27, 1983-Noack's changed their water filter, and found a black tarry substance. They change the filter every 2 months, and have never seen anything like this. They are on the Mapleton Community Well, which serves 29 families. They are also about a mile Southwest of the Dow Rockwell Dump. No sampling done yet. N233: None of these families trust the MIdland County Health Department to do sampling on their wells. Linda Jerry Kerns ?1374 Bus Rd. Chemicals found in their sump in July '83. Pentachlorophenol, 2-Chloropheno They are west of Dow Rockwell Dump. Note: Chemicals also found in surrounding ditches, and in a pond on Saginaw Rd., southwest of Dow Rockwell Dump. MARTIN MARIETTA Saginaw Rd., near Salzburg Rd. New monitoring wells between Dow Stakes across the road in the river with balbons, were removed just before EPA came in. WALDO RD.-3rd house before Milner Rd. Dow bought house a few years ago. They tore it down 3-4 weeks ago, and put in a monitoring well behind the tree. -House-was in good shape. Neighbor, James Trout, may have more details. Phone# 496-3718 WALDO RDspast Milner, over railroad tracks According to Linda Kerns area was wet about the same time Salzburg closed down. There had been no recent rain, and surrounding area was dry. WARREN POND- Saginaw Rd.?Mapleton Pentachlorophenol found here by DNR, July '85. DEXTER AMES PLACE- corner Bailey Bridge Rd. Bus Rd. Dow Observation well. Dow has paid Mr. Ames, $900./yr. to use this well, for some years now. Recently, Mr. Ames refused to accept their n'h (3?on 9&1? HMQOCJC by game! mm 2 SM) @028 1&1. 1.61841? a 3'3 ngvia (Lama QMAMJ wL 0.2chch ?(6:243 ?ndaaf?c?- 3 (Lem fag Stow/Lack-tvmn 89. m1 rad? 26/ a Oboe: i405 MIL. ?u cafes?f- H?w?z am ??5er chQ?g? hem Afar-:1 afld?Qf/ICE?J a 69?, Kc? 4f . Mm,- par/6512 162/ gm/ Mac/Jay 9 lg?b?w 5? 45:21.2; 9722 69// ?lg/09,2164 i9,? 5/4;sz Q7 Mia-a We hean? ro?/em ?a?rd? maoeo? ant WW I <96 qr Aea? Ma?ac/C Agile/7 4 age 70 6 6/ 814/], rr 066?; ?17 A If ?ne/JV lg? [/07 5/751? [if ?/7425 Agra?r Mac/C 97/3. 5 g?nI/e] 5n<3? #90? f9? 2/46/er a 4 I (we, 0 - . vam? Wag/C 5. 6614,61, I . 7 02?? i We; 331.4%: by?? Am 1; 4/02, 2 6 . ?d e: Z?f Wig/7 599/; aA/o?as [Mad K?wm ?ow 772 (fix/67 ?53 76am WA 7m wag/w 8 I5 pact/51M A =6 9/7 I $ng MWUCA d/d/Cy 91759 yaw rid macaw/2%. in? .7. 5* 163 A Harris THOMAS BLESSINO. JR. 1 JOHNSON WILLIAM G. MILLIKEN. Governor 31"- ALaem Boaxm LAIMLA . . WILLIAM A. CILLUFFO "r mum DEPARTMENT OF NATURAL RESOURCES ?m HY H. WHITELEY - PAMELA A. FRUCCI ?4 L. HARD A. LTANNER. Durecm . has a YOUNGLOVE JOHN. W. LAYMAN STUART B. PADNOS September 7 1979 ROGER msmussen mama WALKINGTON RESOURCE RECOVERY DIVISION SECONDARY COMPLEX BOX 30023 LANSING, Ml {89139 Mr. Jeff Nielsen Dow Chemical Company Midland, Michigan 48640 1 1 i I. 511-322-1315 Re: Rockwell Drive Landfill, Bay Coun?y I Dear Mr. Nielsen: I A review of the plan submitted turned up. the followingwgoncerns which were either-left off the plans and spec1fications or which must be_ defined: 1. The plans and specifications shall contain an engineering seal. 2. The plans should contain a North arrow. locational plan and the legal description. - 3. The pond area to the Southeast side and the ditch alongn_the south side of the site must be cleaned, with the material deposited?hithin the diked area. A. Some assurance must be made 2 foot by 2 foot French drain will have the design capabilities to limit the ground? water head to a five (5) foot maximum at the clay barrier. 5. The French drain outlets should be detailed and their locations clarified to eliminate possible washouts and provide an acceptable monitoring station. Also, explain the drainage plan for the southeast corner of the site, and the pond due north of Well 6; no air qualit1_permit.will be required for the venting of the landfill: This requirement will not interfere with the com- .mencement of construction. The contractor must not allow the temporary holding pond to 5 overflow. He may have to modify "Section with a higher dike as heavy winds could allow escape from the pond containment. ?-hh?h?nl? - Ex NNIURAL COMMISSION (fl?[lb SE 121979 RESOURCE RECOVERY COMHISSH gJacoB A mouse moms J. gem 1 JOHNSON WILLIAM G. MILLIKEN. Governor RES-.IECOVHY in. :1 M. . mum DEPARTMENT OF NATURAL RESOURCES "m ?5 HARRY H. WHITELEY PAMELA A -- HOWARD .A- TANNEFI. Dirac: or i c. ERNEST KEMP Younotove .. .. . . . JOAN L. WOLFE JOHN LAN-MN B. PADNOS September 7 19 79 noaen msuussau I I i I MICHAEL waucmorou I . I I nesou'nce necomv omsaon . Jeff Nielsen secouoanr comets: am: 30023 Dow Chemical Company I ?55mg. ??3909 Midland, Michigan 48640 I . sir-3224315 Re: Rockwell Drive Landfill, Bay County - I Dear Mr. Nielsen: A review of the plan submitted turned_ up the fallopingnconcerns which were either left off the plans and specifications or which must be defined: l. The plans and specifications shall contain an engineering seal. 2. The plans should contain a North arroa, locational plan and the legal description. 3. The pond area to the Southeast side and the ditch south side of the site must be cleaned, with the material d?posited?within the diked area._ 4. Some assurance must be made that the 2 foot by 2 foot French drain will have the design capabilities to limit the ground? water head to-a five (5) foot maximum at the clay barrier. 5. The French drain outlets should be detailed and their locations clarified to eliminate possible washouts.and provide an acceptable monitoring station: Also, explain the drainage plan for the southeast corner of the site, and the pond due north of well 14-1. I . An air quality_pe.rmit..will be required for the venting of the - . landfill. This requirement will not interfere with the com- mencement of construction. 7. The contractor must not allow the temporary holding pond to . overflow. He may have to modify "Section with a higher dike as heavy winds could allow escape from the pond containment810266 MFR 30%? dea?y Ev?zm :3 .w ONmrh 1.01.3?.33 038.32 4:36. TV Qw? Egmg a my Eb sd?a angst?) v\ fakovMb .W ELM W: ?5.qu 43 am ?ms. athUme 719v. 10m. 2.0330 gaohm 3 Mom; vm? qua. ?din?r?uc? i ?3.,me nm?zu dechO. ?ix? 3 ?w . M3 F. Wig {tam ?w Wd?q Tow 40% vm?im MEMORANDUM i STATE MICHIIGAN November 24 T0: Del Rector :7ngd?ilivf FROM: Larry c. Holcomb Chat/W SUBJECT: Dow Rockwell Pit I Citizens at Midland requested TSCC to investigate the Dow Rockwell Pit. I have talked to Ted Ilgenfritz of Dow and we would like to meet in my office on Wednesday, December 1, 1982, at l:30 p.m. I understand from Ted that Lansing DNR staff involved in review of the pit were Jim Janizek and Rich Sadowski. I would like Jimlto be present at the meeting if possible. Larry Thornton and Fred at the Roscommon office have also been involved and I probably will be visiting with them by telephone. 1 On November 12, Dr. Zimmerman met with concerned citizens in Midland re? garding the Midland/Rockwell Pit. Previous contact with DNR (Messr. Got? tschalk) suggested that this is a closed pit posing no threat to the citizens and thus no further testing of citizen wells occurred. Dr. Zim? merman has visited the site area. The TSCC would like to have answers provided by DNR and/or Dow on the following: 1. What is the history of the site? 2. What is the natural hydrogeology of the pit and the surrounding area? 3. What chemicals were placed in the pit? 4. Has a thorough analysis been done on A. leachate in the pit? B. contaminated groundwater outside the site? a What do analyses show? 5. What is the current design for containment? Will the leachate in the pit be drained out and what is the plan for removing it? 6. What is the program and/or plan for prevention of movement of contaminated groundwater toward the residences west of the pit? 1982 Del Rector . November 24, 1982 - - . Page Two I 7- the plume Since 't?e'plume is moving to thefwest and citizens homes are located to the west, how can DNR be certain that citizens-wells will not be affected? 8. The citizens were told by Harry Washington of Dow that studies were done.of benzene degradation in the plume and that Dow de? termined that based upon these studies there was no concern that the compound could reach citizen wells. Has DNR been.made aware of these studies? Have they been analyzed? 9. A former worker with a Industrial Waste Haulers claims.that in April to June, 1982, took pumper trucks to monitoring wells about 35' deep on the site. The workers were instructed to wear goggles, rainwear and gloves. Scott Mancroni who works for Dow took monitoring samples. The liquid from the wells was yellowish, had a pungent odor and was apparently a The liquid (about 800 lb/wk) was hauled to a pond on Dow's property. DNR claims the liquids present-were benzene, toluene, xylene, and None of these compounds has the characteristiCs of the liquids being pumped. ;Is DNR aware of these pumping operations? Has the liquid been analyzed? What were the results? . 10. The former worker from also claims that in February, l982, he worked on an operation for skimming Lingle Drain'adjacent to the pit. He claims Chuck Selander of Dow told him that the drain- was contaminated with styrene. The workers were told to wear rain- wear-and goggles. Children playing in the area were told to leave. Is DNR aware of this incident? Is styrene present in the pit? '11. In summer, 1980, Vicente Castellanos took pictures of excavations occurring on the site. aware of such excavations? What was the purpose? 12. Dr. Zimmerman observed what appeared to be some sort of leachate flowing into a canal adjacent to the site. Is DNR aware of this? Has any sampling been done? What are the results? Any written materials, analyses from:leachate and groundwater,-diagrams and photos would be helpful. Thank you ?n advance for your-cooperation. cc: Ted Ilgenfritz I James Janizek Larry T. Thornton 'w'I DOW CHEMICAL U.S.A. MICHIGAN DIVISION MIDLAND. MICHIGAN 48640 Hr. Jerry Fore Toxic Waste Section Resource Recovery Division HI Department of Natural Resources Secondary Complex P.O. Box 30028 Lansing, MI ?8909 Dear Mr. Fore: As discussed at our meeting on June 29, l97q in Roscommon, I am en- closing a copy of Dr. R. E. Bailey's letter to me concerning the wastes buried at Dow's Rockwell Drive Landfill. The Landfill is located in Williams Township of Bay County, along Rockwell Drive. The enclosed letter should cover general concerns about the biodegradable nature of the waste hydrocarbons at that site. We are conducting Further work to characterize degradation of the organics in the ground water west of the site. Sincerely, .757. ?4.43; \7 Environmental Servi 628 Building 636-h620 CS Enclosure cc. L. RECEIVED . . 79 JUL Ulg ucovm no.1: AN OPERATING UNIT OF THE DOW CHEMICAL COMPANY DOW CHEMICAL U.S.A. - MIDLAND. 48640 June 25; 1979 E. M. Ileenfrit: Environmental Quality 628 Building LEACHATE FROM OLD TAR LANDFILL ?7 ?cars ago, a quantity OF tar was land- filled. Until recently, there were Few visible effects from movement or leachine of this material. In the last Few years, tar was observed in a drainage ditch around the north and east sides of the site. In addition, water just under the surface, west of the site, has an odor of hydrocarbon waste. Annarently rain and melt water are inducing movement of some commonents of the tar both as dissolved organics and as vis- cous liquid. The comnonents of this waste annarently have a very low toxicity to nlants. Trees. shrubs, and grass are growing in the area with contaminated water and even on too of the landFill itself. SurFace water, less than 18? above the contaminated water, sunnorted manv snecies of anuatic invertebrates including Danhnia, generally quite sensitive to chemicals. Analysis of contaminated water samnles From the landfill area show the presence of benzene, toluene, and thiophene. The biodegradability of these comnounds has been studied here at Dow as well at many other laboratories (Sugiyama, et al. 1972). Our biochemical oxygen demand (BOD) values areOPERATING UNIT OF THE DOW CHEMICAL COMPANY M. IQgenfritz June 25, 1979 Page Two BOD as of theoretical 5 Bars 10 Days 20 Davs Benzene 46 50 Toluene Spreading of oily wastes on soil to facilitate biodegradation has been practiced for years by the petroleum industry. The soil environment provides surfaces for bacterial to live on and facilitates dispersion of the oil to allow water, air and supplementary nutrients to be intimately mixed. Degradation rates of hundreds of tons per acre per year have been reported (Phung, et a1, 1978). For example, a sandy site in Southern California has been used for the disposal of oily wastes since 1955. The original loose sand at the California site has been transformed into a dark, silty sand by microbial decomposition of the oil and by the presence of large volumes of waste drilling muds in the input waste. Soil is more consolidated in the dis- posal area and supports scattered vegetation as allowed by dozer activity. Those portions of the site that have been idle for several years show no signs of oil in the soil and have no hydrocarbon odor. E. M. Ilgenfritz June 25, 1979 Page Three The environmental degradation of polynuclear aromatic com- pounds similar to those which are present in the tars has been observed. Bacteria have been shown to utilize aromatic hydrocarbons as a carbon source for growth. Evidence summarized by Budding, et al. (1976) suggest that bacteria can degrade these compounds much more completely than mammals. The metabolism of benzene, naphthalene, phenanthrene and anthracene is accomplished by a broad spectrum of bacteria, and pathways for these processes have been reported by Zobell (1946) and Ribbons (1965). By contrast, however, there is not much known about bacterial metabolism of other aromatic hydrocarbons. Common enrichment?culture techniques cannot be used to obtain organisms able to grow on the larger aromatic hydrocarbons as sole carbon sources since these compounds are essentially insoluble in water and will either not support growth or growth may be extremely slow (Barnsley 1975). This problem has been some what overcome by using other carbon sources to stimulate (or induce) bac- terial production. Sisler and Zobell (1947) were able to isolate bacteria which were grown on other carbon sources that degraded 1,2?benzanthracene and 1,2,5,6?dibenzanthracene; Poglazova 23 31. (1967) and Lorbacher 23 al. (1971) achieved similar results with benzo(a)pyrene. The?maximum rate of disappearance of benzo(a)pyrene in cultures of Escheria coli calculated by Barnsley (1975) from the data of barbacher ?l _1 et 31. (1971) is about 0.02 pm hr or 0.2 10 pmol hr mg bacterial protein. The maximum rate of metabolism of benzo(a)- pyrene by Pseudomonas 9816 observed by Barnsley (1975) was 0.13 uh hr or 0.9 10 umol hr mg bacterial protein. This rate is intermediate between those computed from the results of other workers (Barnsley 1975). Radiolabeled benzo(a)pyrene was evaluted in laboratory model ecosystems for fate, degradation pathways, bio- concentration, and food chain accumulation by Lu et al. (1977). Two types of model ecosystems (microcosms) experimEnts were performed; a closed model aquatic ecosystem and a terrestrial- aquatic model ecosystem. A detail description of these model ecosystems is provided by Lu and Mutcalf (1975) and Metcalf (1974). In the terrestrial~aquatie model ecosystem, 0.2 mg of benzo(a)pyreue was topically applied in an acetone solution to Sorghum vulgare seedlings at the terrestrial end to simu? late atmospheric fall out. The plants were then consumed by E. M. Ilgenfritz June 25, 1979 Page Four salt marsh caterpillar larvae (Estigmen acrea) and the 14C- labeled products entered the terrestrial and aquatic phases as fecal products, leaf frass, etc. The food chain organisms were Plankton, filamentous green algae (Oedogonium cardiacum), daphnia (Daphnia manna), mosquito larva (Culex pipieus), snail \0ht i j, and mosquito fish (Gambusia affinis). The radioactive products were allowed to interact in the sys? tem over a 33?day period at 26.7 with a 12?hr diurnal cycle and 5,000 ft. candle illumination. Water samples were collected and the radioactivity monitored throughout the experimental period by liquid scintillation. At the conclusion of the experi- ments 1 liter of water was extracted and the orgagisms homo- genized, the extract was then concentrated, the content evaluated, and relative amounts of degradation products deter- mined hy various analytical techniques (Lu 33 a1. 1977). The 33?day terrestrial-aquatic model ecosystem provided for a degradation period and food chain transfer. The amount of benzo(a)pyrene in the aquatic phase reached a maximum level of 0.005 (determined by radioactivity and expressed as equivalents) after 14 days and declined to 0.00344 at the conclusion of the experiment at 33 days. The parent4 comprised 7.1% of the total extract? able in fish (ecological magnification, E.M. of 30), 10% snail (E.M. 4860), 32% in algae (E.M. 31610) and 34% in mosquito larvae (E.M. 2120). Lu et al. (1077) found traces of several unknown degradation products although most were found as polar products. In both microcosms, the in vivo degradation of benzo(a)pyrene was by hydroxylation and conjugation to produce highly polar derivatives. I believe that the hydrocarbons and other compounds presently contaminating the area outside the landfill will biodegrade. This could perhaps be speeded up by the addition of fertilizer and treatment to increase overall biological activity in the soil of the area. The use of lime to adjust the pH in any areas where it is abnormally low will also facilitate biological activity. Should any tar be left unencased, cultivation to mix it with the soil and fertilization will increase its rate of biodegradation. 9 E. M. Ilgenfritz June 25, 1979 Page Five I i 1 In Summary, natural biddegradativc processes in the soil around the old tar dump site are expected to decompose_that material which has migrated from the original Site. . Robert E. Bailey, . Environmental Sciences Research 1702 Building 636?3654 1' Attachment u. - REFERENCES Barnsley, E. A. 1975. The bacterial degradation of fluor- anthene and benzo(a)pyrene. Can. J. Microbial. 21:1004-1008. Loxljaclner, 11., Ii. 1). Inuils, 1V. Stallipktnater. .1971. Storage and metabolism of bonzo(a)pyrene in microorganisms. Zentralbl. Bakterial. Parasitenk. Hyg., Abt. l:Orig., Reiho Lu, P., R. L. Mctcalf, N. Plummer, and D. Handel. 1977. The environmental fate of three carcinogens: benzo(a)pyrene, benzidine, and vinyl chloride evaluated in laboratory model ecosystems. Arch. Environ. Contam. Toxicol. 6:129?142. Lu, P. and R. L. Mctcalf. 1975. Environmental fate and biodegradability of benzene derivatives as studied in a model aquatic ecosystem. Environ. Health Perspect. '10:269. Metcalf, R. L. 1974. A laboratory model ecosystem to evalute compounds biological magnification. Essays In Toxicol. 5:17. Phung, T., L. Barker, D. R005, and D. Baver. 1978. Land Cultivation of Industrial Wastes and Municipal Solid Wastes: State of the Art, Vols. I and II, Poglazova, M. N., A. Ya. Khesina, G. E. Fedoseeva, M. N. Meisel, and L. M. Shabad. 1972. Destruction of benzo(a)pyrene in waste waters by microorganisms. Dokl. Akad. Nauk Radding, S. F., T. Mill, C. W. Gould, D. H. Liu, H. L. Johnson, D. C. Bomberger, and C. V. Fojo. 1976. The environmental fate of selected polynuclear aromatic hydrocarbons. U.S. Environmental Protection Agency, (Office of Toxic Sub.), Wash.. D.C. 122p. (EPA Ribbons, D. w. 1965. The microbial degradation of aromatic compounds. Ann. Rep. Progr. Chem. Chemical Soc. London 62:445?468. Sisler, F. D. and C. E. Zobell. 1947. of carcinogenic hydrocarbons. gScience Sugiyama, T., K. Oba, and K. Fujiwara. Microbial utilization 1972. Biodegradation data Of various organic compounds, Ann. Rept. Inst. Food .Microbiol., Chiba Univl, gg 41. Zobell, C. E. 1946. Action of microorganismS'on hydrocarbons. Bacteriol. Rev. 10:1?49. I 1 I . STATE OF MICHIGAN . fr 5,1 I . JAMES J. BLANCHAFID. Governor DEPARTMENT OF PUBLIC HEALTH 3500 LOGAN PO, BOX 30035. LANSING. MICHIGAN 48909 GLORIA B. SMITH. M.P.H.. F.A.A.N.. May 17, 1983 Andrea K. Wilson, Director Environmetal Congress of Mid-Michigan P.0. Box 1494 Midland, Michigan 48640 Dear Ms. Wilson: I want to take this opportunity to respond to your March 25, 1983, letter in which you expressed concern about the Rockwell Road Landfill. Before respond- ing, we wanted to have the opportunity to discuss with you the results of past sampling efforts. As you know, we had Mr. Adrian Oudbier and Mr. Jim Lahti participate in a meeting for this purpose on April'25 in Midland at which Ms. Hebert, Mr. Castellanos, and yourself were present. From that meeting and as documented in Mr. Gary Guenther's May 10 letter to you, we have been advised that the Michigan Department of Natural Resources will be collecting surface water samples along with each quarterly sampling of monitoring wells at the site. They also have agreed to collect sump samples from basements and indicated a willingness to split samples as per your request. You have been provided the last results of private well samples analyzed by the Michigan Department of Public Health in January, 1983. These results did not indicate any evidence of contamination and a wide range of contaminants were screened by that test. As agreed at the April 25 meeting, repeat sampling of private wells would be done if a significant increase in contamination of monitoring wells occurred. I 1 Ms. Andrea K. Wilson May 17, 1983 I I I We must keep each other informed of any new information received regarding possible human exposures 'to toxic substances in the -Midland area. Following the press conference on May 4, we extended an offer to Ms. Hebert and Mr. Costellanos for ECOMM to visit our Department to your concerns and information in more detail. I am personally renewing that invitation directly to you to call for an appointment at your convenience. We have proceeded toward development of a protocol for a case-control study of soft-and-connec- tive tissue cancers in Midland County. Your input will be useful to us toward planning that study._ - Sincerely, John L. Hesse, Acting Chief Center for Environmental Health Sciences cc: Dr. Gloria R. Smith, Director, MDPH . Mr. Gary Guenther, DNR - . Mr. Jim Janiczek, DNR - Mr. RiCh Powers, DNR Mr. Art Bloomer, MDPH Mr. George Van Amburg, MDPH Dr. Kenneth Wilcox, MDPH 1 Dr. Larry Holcomb, TSCC Mr. Donald Albosta, Congressman irPl? am). am Id. 946/. Frag L.dt/ ?3:5 ffdd/4/I .0 g/N?/pj 547/1250 @44 6/ ?ab/74x7 ?355.13 M51: (jg/9664" ?r ?7/35 ?ma: . 643/615 Hag/4724: mfg/M/7ah? V0. I: 305.. . ?1 I??wf 4w ICC 64.. ?4ch ?4231247427 91 a 5 rmooc?d x44? '46? I9 ?0 MW 6709734, #1971; w?/a?o 2040!. _Q?d . Fae/122% ?bah/gay: 961233 - W5 44 44%? - .. 6 Deana, Emil/)6 E. 8674M ??xdjc??d? Etc/42? 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Knee/and M/C/v/g?di/ Lila} I 29? fmp/oyma/zf Mast-9a; PC ?361 ?66/ 57%176; . 4;;3 :Mmig?rob/em .r 3a.! 04 24 911422 -. - >50 5:3 jag; 3; -- ?g Km?, :3 WW: - J: 5-me _gaggw?n/w iw 59/7713 mg; a Bax/a, 6nd);2? ?ed _m/ah/g 32; :13 - .- 312/. . f7: 5/41/24 ?ll/4 743 5?9 2, H, ?3.42: A Ml in?zLijc. - . 35.15.. 3?6440 ignor?pLT_?mm I F/Cg/d/ga/iT/Zi 152%21 5154.23 - 7 ?.mmdq 107/ - x/z: 1 l_ .[6417 a ?044? ?it/Mr mam/67 Bad Era/?nd 9M3.- -- Exp/oymmf' {4.6 02/ Fr, 3:541? ud_p_LO 12/519125. 1.11.1A3.?.1.u1?. xi?! 11.. I. HUEQQ QB HuuVth 1% ?mwumq . .11 .E. 11\uvkh\._ -1 3113 19W1W111mx . 11 0 1 u. So?. N111 . 1? 31119-! um? - p-15 . . ilk . . .n ind .tlu "a men JUN: 43 1963 Leakage no threat Dow to laUnch investigation of landfill seepage BY SUSAN BENKELMAN News Staff Writer Water leakage at Dow Chemical Co.? 5 landfill on Rockwell Drive in southwest Bay County has posed no threat to sur- rounding groundwater supplies thecompany reported Tuesday. 1weeks ago. Dow reported that company workers had found some discolored soil during a rou- tine inspection at the facility. which meant that water con? taminated from the landfill had - leaked out of the dump. Dow inspects the dump weekly. said company spokeswoman Sarah Rowley. An investigation by Dow and the Michigan Department of Natural Resources concluded that some material had migrated from the landfill through an area between the dump?s clay liner and clay cap. - "But we found no evidence of material migrating through the clay walls themselves. other than at that seam point," said Ms. Rowley. After the leakage was detected two weeks ago. local environmen- talists were concerned. mostly be- cause cancer-causing benzene and ethyl benzene had been dumped at the landfill in the late 19505. The landfill was capped with clay in 1979. DNR water quality specialist Dan Schultz said the agency was collecting samples of the seepage material to determine what it contained. Schultz said Dow's plans to re- seal the seam should be adequate to revent further leakage. Dow wil reconnect the clay liner with the Cap. plans which have been approved by the DNB, Ms. Rowley said. Schultz said DNR officials be- lieved that the seam had somehow been damaged. Ms. Rowley said the company planned to conduct an intensive 00* investigation to make sure leak- age could not occur anywhere else. Dow is in the process of install. ing a system to pump water out of the landfill. The company says that water in the landfill is trapped rainwater, and that even- tually the de-watering system will dry up the landfill. The company has monitoring wells around the perimeter of the landfill to test groundwater to de- termine if any materials from the landfill have migrated into the un- derground water aquifer. No detectable levels of conta- minants were found in samples from those wells. Ms. Rowley said. Group says it will keep Jul Ii} LURIESIIANE liaily News staff writer -. A local environmental group "keep a real close watch" on events at Dow ("hemical Co's Rockvi'ell Drive landfill. according to a group member who sit id she doesn't think the company is telling area residents enough about landfill activities. Utane Hebert. 135th} East Sugnet, said Friday she lieliet'es Dow has not told area residents enough about what's going on at the landlill. where it ?as recently that tainted water had M't?fh? out ofthe facility. Mrs. Hebert is a member ol'the l-Jn- vii'oninental ('ongress of Mid- Michigan. a local group which has said it is conci-rned about past and reCent problemsat the Rockwell facility. DOW DISCOVERED THE seepage during a routine inspection. and later determined that liquid contaminated \vith seeped out of the facility at the seam where the landfill's clay wall meets its clay cap. The company plans to ?x the problem by re-sealine. the wall to the cap. The land?ll contains tarry wastes from production which were dumped there more than :30 years ago. MRS. HEBERT SAID she is con- t't'l?ned that fumes could escape from the facility while the work is done. She said she and tire other people experienced burning sensations in their eyes and throats when they "went down to the gate to see what was going on" at the land?ll Thursday. When she returned later that day. hOWever. she did not experience similar sensations. hl'lt'mlld. She also said she saw a "nasty film? the water in a drainage ditch near the landfill site. She returned to the spot the next day. but it "looked cleaned up." she said. TWO MICHIGAN Department of Natural Resources of?cials who visited the site Thursday said they did not ex- perience the physical Mrs. llebert described. though they also pointed out they were there later in the day. "Durini.t the times] was at the site. i didn't see any problems" with fumes escaping. Michael Jury. a resource spe. cialist with the air quality division. said in a telephone interview Friday. Dan Schultz. a waterquality special- ist with the groundwater quali- ty division. said in a separate interview that. he "would not view fumes being released as a problem." Mrs. Hebert has questioned whether Dow should he required to have an air quality permit before doing the fix-up work. . Jury said that would depend on how state rules are interpreted. Paraphras- int: i hose rules. he said a company can't do any reconstrUction which may be a shame ofan air contamination. The Michigan Air Pollution Control Commission. however. has never re- quired air quality permits for landfills. Jury said. It generally lets other areas within the DNR such as the hazar- dous waste diVisioii take the lead in licensing landfills. Dow did recently obtain a permit to control air emissions as part of its plans to dewater the. landfill. Jury said. That is a separate activity from the lix-up Work. The dewatering involves pump- int.r contaminated water out ofthe land- fill into a storage tank, then trucking it to the company?s wastcwater treat~ inent plant. on Rockwell landfill. ?333 Oauilut ms The permit calls for installing it car- bon adsorption filter system on the tank to take care ot'any escaping odors or forms. Jury said. SCHULTZ HAS REVIEWED the company's fix-up plans and said he will continue the facility at va- rioustimesduringthe work. He said the will sample surface water from the ditch where Mrs. Hebert saw the film. Schultz said he wanted to take some samples from the face of the land?ll while he was there Thursday. but was notullowed to do so. A Dow of?cial told him he would need authorization from Gary Veurink. Dow's section manager of environmental services. Schultz said. "it was a matter of us contacting Mr. Veurink and going that route." Schultz said. "That's what we intend todo." The DNR already has taken some soil and liquid samples at the facility, but results were not available Friday alternuon. Uow aiso has taken samples at the .site. Its results shOWed the presence of hydrocarbons in the liquid which escaped from the land?ll. No contami- nants have been found in the ground- water monitoring wells which sur- round the land?ll, however. leading Dow and the DNR to believe the liquid has not traveled uthhe site. mur- liid Ddgiliaw ?u I'd tutuiviouAY JUNE 4:5 19:53 Leakage no threat . . i .12. evtsusm BENKELMAN News Staff Writer Water leakage at Dow Chemical Co.? 5 landfill on RockiVeli Drive in southwest Bay County has posed no threat to sur- munding groundwater_ supplies theeompany reported Tuesday. . two weeks ago. Dow reported that company workers had found some discolored soil during arou- tine inspection at the facility, which meant that water con- taminated from the landfill had - leaked out of the dump. Dow inspects the dump weekly said company spokeswoman Sarah Rowley. An investigation by Dow and the Michigan Department of Natural Resources concluded that some material had migrated from the landfill through an area between the dumps clay liner and clay cap. . ?But we found no evidence ?of material migrating through the clay walls themselves other than at that seam .point," said Ms. Rowley. After the leakage was detected two weeks ago, local environmen? talists were concerned. mostly be- cause cancerucau'sing benzene and ethyl benzene had been dumped at the landfill in the late 19505. The landfill was capped with clay in 1979. DNR water quality spedialist Dan Schultz said the agency was collecting samples of the seepage material to determine what it contained. Schultz said Dow's plans to re- seal the seam should be adequate revent further leakage. Dow an? reconnect the clay liner with the cap. plans which have been approved by the Ms. Rowley said. Schultz said DNR officials be- lieved that the seam had somehow been damaged. Ms. Rowley said the company planned to conduct an intensive Dow to launch investigation of landfill seepage investigation to make sure leak- age could not occur anywhere else. Dow is in the process of instali~ ing a system to pump water out of the landfill. The company says that water in the landfill is trapped rainwater. and that even- tually the de-watering system will dry up the landfill. The company has monitoring wells around the perimeter of the landfill to test groundwater to de- termine if any materials from the landfill have migrated into the un- derground water aquifer. No detectable levels of conta- minants were found in samples from those wells. Ms. Rowley said. Midland Daily iNews, Midland, Michigan Tuesday, July 21, 1981 Page 3 Excavation helps . Dow clean-up of g. i t? By PAUL RAU Daily News staff writer Work to clean up benzene in the ground west of Dow Chemical Co.'s Rockwell landfill also includes digging a hole to accomplish natural destruc- tion of the benzene. at Dow official said today. The hole. 10 feet deep and roughly 100 feet by 750 feet. will be allowed to fill with rain water and will remain open until the end of summer, said Larry J. Washington Jr., manager of environmental services at Dow's Mich- igan Division. He said excavating the earth that is contaminated with benzene "will re-. move the_heart (if any potential prob- lem." Then. remaining traCes of the benzene "plume" Will migrate to the surface in the hole and be biodegraded by the sun's ultraviolet radiation and natural soil bacteria. Washington said. He said this clean?up program should be finished by October. and has the approval of the state Department of Natural Resources. Dow has also in- vestigated inoculating the soil with bacteria to destroy the benzene. Washington said Dow eXperimented last fall and winter with natural de- gradation in small trenches near the landfill. on Rockwell Road in 9 RockWelI landfill Bay County. ?As long as there was no ice on the pond. we get real good degradation of the material (henzene)." he said. He added that monitoring wells in the plume show benzene in the low part- per-millipn range. The excavated hole has been fenced to prevent entrance by area children. ?The fencmg is a safety-type measure: you wouldn?t want to dig a hole to feet deep and just have it. sitting there." Washington said. ?We think the problem will take care of itself over a long period of time even if we did nothing. This will just acct-let?ate it. don?t think there's any reason for concern now; there will be even less reason for concern when this project is done." he added. The hole will be filled in this fall. Washington said if the water in the hole is free of benzene. it will be pumped into nearby ditches. If it still contains benzene. the water will be trucked to the division waste water treatment plant. Washington said. The benzene leaked from the Rock- well facility after produc- tion tars were placed there by Dow in the 19505. The site has since been en- capsulated in clay. Issue complaints EPA will study Dow dump BY JAMES KATES News Staff Writer MIDLAND An investigating committee of the us. Environmental Protection Agency is scheduled to discuss 3 Midland County chemical dumpsite which nearby residents say could be responsible for a 20-year history of health problems. The dump, located near the intersection of Bay-Mid- land County Line and Milner roads. was the site of tar disposal by the Dow Chemical Co. in the late 19505. An EPA spokeswoman has confirmed that an inter- agency committee known as the Hazardous Materials Enforcement Response Program will discuss the site at its weekly meeting Tuesday in Chicago. A spokesman for the state Department of Natural Resources, meanwhile, has said the DNR might re? .quire Dow to ?clean up? a chemical plume which has moved off the site over the past 20 years. Dow and the DNR are scheduled to discuss the problem at a meet- ing Oct. 21. Earlier, an area resident had written state officials to inform them of an ?unusual incidence" of cancer cases and glandular problems in the immediate area. Benzene, a known cancer-causing agent, has been found in trace amounts in shallow-lying water west of the site. But officials of the DN and the state Department of Public Health have repeatedly stressed that any con- nection between leakage from the dumpsite and health problems in the area would be tenuous. Tests of well- water at area homes have failed to reveal chemical contamination. (Please See DUMP, Page Group says it will keep Jul By LORIE SHANE Daily 1News stal?l?writer . A local environmental group will "keep a real close watch" on events at Dow (?hemical Co's Rockwell Drive .landfill. according to a group member who said she doesn?t think the company . is telling area residents enough about landfill activities. Diane Hebert. 2505 East Sugnet. said Friday she believes Dow has not told area residents enough about what's going on at the land?ll, where it was discrivei'ed i?ecentiy that tainted water had seeped out ot?the facility. Mrs. Hebert is a member of the En- vironmental Congress of Mid- Michigan. a local group which has said it is concerned about past and recent problems at the Rockwell facility. DOW DISCOVERED THE seepage during a routine inspection, and later determined that liquid contaminated with hydrocarbons seeped out of the iacilit at the seam where the landfill's clay wall meets its clay cap. The company plans to for the problem by re-sealing the wall to the cap. The land?ll contains tarry wastes from production which were dumped there more than 20 years ago. MRS. HEBERT SAID she is con- cerned that fumes could escape from the tacility while the work is done. She said she and other people experienced burning sensations in their eyes and throats when they ?went down to the gate to see what was going on" at the land?ll Thursday. When she returned later that day. however. she did not experienCe similar sensations. she said. She also said she saw a ?nasty ?lm" covering the water in a drainage ditch near the landfill site. She returned to the spot the next day. but it "looked cleaned up." she said. TWO MICHIGAN Department of Natural Resources officials who visited the site Thursday said they did not ex~ perience the physical Mrs. Hebert described. though they also pointed out they were there later in the day. "During the timed was at the site. I didn't see any problems" with fumes escaping. Michael Jury. a resource spe. cialist with the air quality division. said in a telephone interview Friday. Dan Schultz. a water quality special- ist with the DNR's groundwater quali? ty division. said in a separate interview that he "would not view fumes being released as a problem." Mrs. Hebert has questioned whether Dow should he required to have an air quality permit before doing the fix-up work. Jury said that would depend on how state rules are interpreted. Paraphras- ing those rules. he said a company can't do any reconstruction which may be a sou rec ol'an air contamination. The Michigan Air Pollution Control Commission. however. has never re- quired air quality permits for landfills. Jury said. It generally lets other areas within the DNR such as the hazar- dous waste division take the lead in licensing landfills. Dow did recently obtain a permit to control air emissions as part of its plans to dewater the land?ll. ury said. That is a separate activity from the fix-up work. The dewatering involves pump- ing contaminated water out ofthe land- lill into a storage tank. then trucking it to the company's wastewater treat.- ment plant. .- . on Rockwell landfill lat} ms The permit calls for installing a car- bon adsorption filter system on the tank to take care of any escaping odors or fumes.Jury said. SCHULTZ HAS REVIEWED the company?s lix-up plans and said he will continue to-inspect the facility at we rious times during the work. He said the DNR will sample surface water from the ditch where Mrs. Hebert saw the film. Schultz said he wanted to take some samples from the face of the land?ll - while he was there Thursday. but was not allowed to do so. A Dow of?cial told him he would need authorization from Gary Veurink. Dow?s section manager of environmental services. Schultz said. "it was a matter of us contacting Mr. Veurink and going that route." Schultz said. "That's what We intend to do." The DNR already has taken some soil and liquid samples at the facility. but results were not available Friday afternoon. Dow also nas taken samples at the .site. Its results showed the presence of hydrocarbons in the liquid which escaped from the land?ll. No contami- nants have been found in the ground- water monitoring wells which sur- round the landl?ill. howwer, leading Dow and the DNR to believe the liquid has not traveled oil'thc site. ??nxf Lond?uleoks not to blame 9 says Dow ??szw?e? By PAUL RAU Daily News staff writer tars which have leaks! in the past from 3 Dow Chemical Co. landfill southeast of Midland cannot be linked medically ,or scientifically to health problems suffered by persomf living in that area. Dow's Michigan Di- vision medicai director said today. Dr. Robert Kolesar said. "There is no medical linkage between the Dow landfill and health problems in the area. I empathize with the individuals' concerns but I want to allay their fears." Kolesar made his comments in reac- tion to a Saginaw News story Thursday which said the state Department of Natural Resources will investigate the possibility that health problems. in- cluding cancer. suffered by persons living near the landfill in Mapleton were caused by leaking Waste from the chemical dump. The landfill is located east of Mapl- eton near the intetsection of Milne and the Midland-Bay County Line Road. The site was used in the 19503 by Dow . ?to dispose of tars. The landfill began leaking its con- tents last year. and was repaired by Dow by enclosing it with clay. Mon. itoring wells also were installed. Kolesar prefaced his reassurance by saying. ?i am not a pawn of (Dow) management. I practice medicine within the dictates of my own con- science." He said his first reaction af- ter reading the News article was ?Oh fiddle.? The News story listed several health complaints among residents living near the landfill. including a death due to leukemia and diagnos- ed cases of lung cancer cervical can- cer and uterine cancer. It noted ben- zene. which causes cancer in animals and is suspected to cause it in humans. was found in a shallow well near the Dow landfill.- Kolcsar said there are many Bus- pccted causes for the cancers noted inI the story. and that the" material in the landfill is not a car-I cinogen. He said the benzene found in the well could havecome from waste motor oil dumped into a nearby ditch. or from a variety of solvents. He said if benzene did separate from its ethyl component while migrating off the site, it would have been.in min- ute quantities and would only appear in' 'ultrashallow" drinitlng wells in the area Kolesar said the case of leukemia could be caused by benzene. but also by latent viruses present in a person?s system. Cancer of the uterus. he said. is not caused by benzene. Es-? trogens and on the other hand. are known causers of ute- rine cancer. he said. "People should be placated; there is no reason for concern. and there is no link between the leakage from the .landfili and the health pgohletns stated in the paper.? ?Kolesar said. ?At times. you might say the news is sensationaily covered. and at the same . time groundless allegations are made without scientific substantiation." he added. He said this is one of. those in- stances. The Occupational Saiety and Health Administration has set the safe level for benzene exposure at 10 parts per million. and the level for at 100 ppm. Koleser said even if the one well test which showed benzene at 2.2 was accurate. still see no causal relationship to the cancers or deaths in that immediate'erea." Repeated tests by Dow. the Depart- ment of Public Health and the DNR have shown nobenzene or zene above what could be expected normally in the water near the Dow landfill. DPH tested l0 wells in October 1979 and found none of the two compounds: Dow took 28 surface water samples in March through May of this year and found no. levels above normal; and DNR tests conducted at the same time also reached the same conclusion. Kolesar said most benzene or ethyl- benzenc leaking from the landfill would evaporate if it reached the sur- face. or be biologically degraded if it remained in the soil. thus making woll contamination unlikely. The News story quoted the DNR's John Hesse as saying he may assign an epidemiologist to study the health of area residents. Kolesar said such a study has not been shown to be neces- sary. ?Truthfully. I feel attempting a sci- entific epidemiological study on such small numbers (of persons) wouldn't reveal any more than is revealed now. An epidemiological study at this time is not indicated.? Koiesar said. lGroup says it will keep an on RockWell landfill LORI ZSHANE Daily News staffwriter A local environmental group Will ?keep a real close watch" on events at Dow ("heinical Co's Rockwell Drive landfill. accordmg to a group member who said she doesn?t think the company is telling area residents enough about landfill actiVIt ies. Diane Hebert. 23505 East Sugnet. said Friday she believes Dow has not told area residents enough about what's going on at the landfill. vvhere it was dIscoVereIl recently that tainted water had seeped out ol?the facility. Mrs. Hebert is Ii member ol'the lin- Congress of Mid- E?IlIchIgan. a local group which has said it is concerned about past. and recent pI'IIl'Ilen'Is at the Rockwell facility. DOW DISCOVERED THE seepage during a routine inspection, and later determined that liquid contaminated with hydrocarbons seeped out of the facility at the seam where the landfill's clay wall meets its clay cap. The company plans to fix the problem by re-sealing the wall to the cap. The land?ll contains tarry wastes from production which were dumped there more than 20 years ago. MRS. HEBERT she Is Con- cerned that fumes could escape from the facility while the work is done. She said she and two other people experienced burning sensations in their eyes and throats when they ?Went down to the gate to see what was goianr on" at the land?ll Thursday. When she returned later that day. however. she did not experience similar sensations. she said. She also said she saw a "nasty film" covering the water in a drainage ditch near the landfill site. She returned to the spot the next day, but it "looked cleaned up." she said. TWO MICHIGAN Department of Natural Resources of?cials who visited the site Thursday said they did not ex- perience the physical Mrs. Hebert described. though they also Outlaws pointed out they Wei I: there later In the day. ?During the timtsl was at the site, I didn't see any problems" with fumes escaping. Michael Jury. a resource spec cialist with the air quality division, said in a telephone interview Friday. Dan Schultz. a waterquality special- ist. with the DNR's groundwater quali- ty division. said in a separate interview that he "would not view fumes being released as a problem Mrs. Hebert has questioned whether Dow should be required to have an air quality permit before doing the fix-up work. Jury said that would depend on how state rules are interpreted. Paraphras- ing those rules. he said a company can?t do any reconstruction which may be a source ofan air contamination. The Michigan Air Pollution Control ommission. however. has never re- air quality peimits l0I landfills Jurv said. It generally lets othei aieas within the DNR such as the hazar- dous waste division take the lead in licensing land?lls Dow did recently obtain a permit to control air emissions as part of its plans to dewater the. land?ll. Jury said. That is a separate activity from the fix-up work. The dewatering involves pump- ing contaminated water out ofthe land- fill into a storage tank, then trucking it to the company's wastewater treat. ment plant. The permit calls for installing a car- bon adsorption ?lter system up the tank to take care of any escaping odors or fumes. Jury said. SCHULTZ HAS REVIEWED the company fix-up plans and said he will continue to inspect the facility at va- rious timesduringthework He said the DNR will sample surface water from the ditch When: Mrs. Hebert saw the. ?lm. Schultz said he wanted to take some samples from the face of the land?ll while he was there Thursday. but was not allowed to do so. A Dow official told him he would need authorimtion from Gary Veurink. Dow?s section manager of environmental services. Schultz said. ?It was a matter of us contacting Mr. Veurink and going that route,? Schultz said. ?That's what we intendto do." The DNR alieady has taken some soil and liquid samples at the facility. but results were not available Friday atteI noon. Dow aiso nas taken samples at the .site. its results showed the presence of hydrocarbons in the liquid which escaped from the land?ll. No contami- nants have been found in the ground- water monitoring wells which sur- round the landlill, however. leading Dow and the DNR to believe the liquid has not traveled olfthe site. uw WV mm..nr.nuu..u. Mp? :l gug. 59.5.21; Dow to reseal wall at Rockwell landfill By LORIE SHANE Daily News staff writer The Dow Chemical Co. will fix the spot where contaminated water seeped out ofits Rockwell Drive land?ll by re- scaling the land?ll?s wall to its cap at that point. a company spokeswoman said Wednesday. Dow discovered wet spots and dis- colored soil 0n the face of the land?ll earlier this month. leading to specu- lation by area residents and the Michigan Department of Natural Re- sources that the land?ll was leaking. Dow's investigation showed water from inside the hazardous waste facility has "migrated" out through the seam where the clay wall and the clay top of the land?ll meet. Dow spokeswoman Sarah Rowley said. Dow does not be- lieve any water leaked through the clay wall itself. Samples of wet soil taken at the site contained water contaminated with hydrocarbons. she said. The inactive land?ll contains tarry wastes from eth- ylbenzene production which were dumped there more than 20 years ago. Dow will fix the spot where the seepage occured by re-sealing the clay wall of the land?ll to its clay top. Ms. Rnwley explained. The company also is checkingthe rest ol'the landfill to make sure a similar incident did not occur at another spot. she said. THE DNR HAS approved the com- pany?s plans. and the work isexpectedto be done inJuly. she said. Dow and DNR officials both said they do not believe contaminated water traveled oll'the immediate site. "Based on the soil. it looked like the seepage was stopped." said Dan Schultz. water quality Specialist. ?If something has gotten outside. it should show up" in the groundwater monitoring wells which surround the land?ll. Tests of those wells have been con- ducted and have shown no con- taminants,Ms. Rowley said. Schultz said the DNR is doing its own tests of soil and water samples, with re- sults expected by the end of the week. "It looks likeitwasdetectedin time. It was obviously a slow seep.? he said. ?We don?t know exactly why the seep occurred." he said. but speculated Dow could have inadvertently affected the integrity of the land?ll?s wall when its was doing excavation work in the area in 1981. At that time Dow was digging up soil contaminated with benzene in order to place it in the land?ll. Schultz described the interface be- tween the wall and the cap as a "tongue and groove. trench is constructed in the top ofthe wall. and part ofthe cap is ?tted into that groove. Schultz said 3 Midland resident has asked him about the posmhilityofl'umes escaping from the landfill during the fix-up work. He said "there should be no problem with that" because about four to six inches of the cap will remain in place during the work. Dow has said that area residents can expect to see construction activities at the landfill site throughout the summer. because it also is installing two new wells to help dewuter the facili- ty. nesluents Issue complaints EPA will study Dow dump BY JAMES KATES News Staff Writer MIDLAND An investigating committee of the US. Environmental Protection Agency is scheduled to discuss 3 Midland County chemical dumpsite which nearby residents say could be responsible for a 20-year history of health problems. The dump, located near the intersection of Bay-Mid- land County Line and Milner roads, was the site of ethyibenzene tar disposal by the Dow Chemical Co. in the late 19505. An EPA spokeswoman has confirmed that an inter- agency committee known as the Hazardous Materials Enforcement Response Program will discuss the site at its weekly meeting Tuesday in Chicago. A spokesman for the state Department of Natural Resources, meanwhile, has said the DNR might re- .quire Dow to ?clean up? a chemical plume which has moved off the site over the past 20 years. Dow and the DNR are scheduled to discuss the problem at a meet- ing Oct. 21. Earlier, an area resident had written state officials to inform them of an ?unusual incidence" of cancer cases and glandular problems in the immediate area. Benzene. a known cancer-causing agent, has been found in trace amounts in shallow-lying water west of the site. But officials of the DNR and the state Department of Public Health have repeatedly stressed that any con~ nection between leakage from the dumpsite and health problems in the area would be tenuous. Tests of well- water at area homes have failed to reveal chemical contamination. (Please See DU MP. Page A-2)