Rockford Tannery (Rockford, Kent County)

• The tannery was demolished in 2010 and 2011. During and subsequent to the demolition, EGLE received complaints from a citizen group alleging several violations of the state environmental statute including nuisance air emissions, storm water violations, hazardous substance releases, solid waste violations, and violations of water quality rules.
• In response to the allegations from the citizen group beginning in June 2010, EGLE staff from the Waste Management and Radiological Protection Division, Water Resources Division, Air Quality Division, Remediation and Redevelopment Division, and the Office of Criminal Investigations took numerous calls, met with representatives of the citizen group, conducted site inspections and followed up with representatives of Wolverine.  EGLE was unable to find substantive violations at that time.
• In June 2011, the citizen's group petitioned the United States Environmental Protection Agency (USEPA) under the Comprehensive Environmental Response Compensation and Liability Act (CERCLA) to perform a preliminary assessment (PA) of the site.  The PA was completed in June 2012 and the USEPA referred the site to EGLE for further investigation. 
• Wolverine conducted a post-demolition environmental investigation of soils and groundwater in 2011.
• Soil, groundwater and sediment samples were collected at the Tannery Site by Wolverine and by EGLE's Superfund Section and were analyzed for Volatile Organic Compounds (VOCs), Semi-Volatile Organic Compounds (SVOCs), metals, ammonia, nitrites, chloride, phosphorous, sulfate, sulfide and/or cyanide.  VOCs, SVOCs, metals, ammonia and cyanide were detected above criteria and/or sediment screening levels.
• Wolverine conducted additional investigations in 2012, 2013, 2014, and 2016 to better define the extent of contamination.  Buried hides and leather scraps were discovered during these investigations.
• In the Fall 2016, the citizens group shared with Wolverine that a fish advisory had been issued for the Rogue River for per- and polyfluoroalkyl substances (PFAS) and that Wolverine may have used products in their leather processing that contained these compounds.  
• Wolverine sampled groundwater and surface water for PFAS in Summer and Fall 2017.  PFOA and PFOS were detected in the groundwater and surface water at up to 490,000 ppt and 12 ppt respectively.   Total tested PFAS concentrations detected in groundwater were up to 532,399 ppt.
• December 2017 Wolverine conducted additional on-site investigation work and submitted a work plan for an off-site investigation.
• January 2018, EGLE filed a legal complaint against Wolverine under the federal Resource Conservation and Recovery Act (RCRA) and state law, including Part 201 (Environmental Remediation) in the United States District Court for the Western District of Michigan.  In the complaint, the state seeks orders that Wolverine institute protective measures to mitigate risks to public health, continue environmental investigations, address PFAS contamination in ground and surface water and pay for the state's past and future costs associated with enforcement of state clean up laws. 
• January 2018, the USEPA issued a Unilateral Administrative Order (UAO) against Wolverine to conduct further assessment of non-PFAS contamination and potential cleanup work at its former tannery and at the House Street Disposal locations.
• January - April 2018, Wolverine installed additional on-site monitoring wells at the Tannery Site, collected groundwater samples, and collected surface water samples from the Rogue River. This sampling data was provided to EGLE in June 2018.
• June 2018, The Kent County Health Department and Michigan Department of Health and Human Services issued a health advisory warning people to avoid consuming the floating foam on top of the water of the Rogue River due to high PFAS levels.  This was issued based on results from foam samples collected by EGLE.
• May 2018, EGLE requested Wolverine analyze for PFAS at all sampling locations being completed under the USEPA UAO. This sampling was conducted in Summer and Fall 2018.
• June 29, 2018, Wolverine submitted a workplan for off-site PFAS groundwater investigation at the Tannery Site. EGLE provided comments back to Wolverine on this sampling plan in August 2018.
• Early November 2018, Wolverine completed all sampling for the USEPA UAO, including the PFAS sampling for EGLE.
• November and December 2018, Wolverine installed five new off-site monitoring wells as part of their PFAS investigation for EGLE.  An additional monitoring well location on the west side of the Rogue River will be installed once access is finalized.   
• A status update factsheet was released by the USEPA and EGLE in late November 2018 providing residents an update on the investigation and announcing a January 2019 town hall meeting.

• January 10, 2019, EGLE issued a press release announcing that due to the federal government shutdown, the joint USEPA and EGLE Wolverine Townhall meeting, originally scheduled for January 23, 2019, at the Rockford High School, was postponed until further notice. This meeting will be rescheduled.
• January 11, 2019, Wolverine submitted the Final Tannery Summary Report to the USEPA.
• On March 26, 2019, the USEPA and EGLE held a joint Town Hall at the Rockford High School Fine Arts Auditorium at 4100 Kroes Street NE, Rockford MI 49341. The Open House was from 6:00 - 6:30 pm, the Public Meeting from 6:30 - 8:00pm and time for questions held between 8:00 - 8:30pm. This meeting was originally scheduled for January 23, 2019, but was rescheduled due to the federal government shutdown.
  • March 26 Town Hall presentation
• In February 2019, GZA completed a round of groundwater monitoring well sampling and installed three groundwater extraction wells on the Tannery property associated with a groundwater capture and treatment system. The three extraction wells were developed the week of April 1, 2019 and a pump test was completed in May 2019.
• Results from the summer/fall 2018 EGLE fish sampling activities completed in northern Kent county can be found on the MPART Fish PFOS Guidelines Page.  MDHHS releases Eat Safe Fish Guides annually in the Spring, and emergency advisories as needed. Fish across the state are tested for PFAS in addition to other chemicals such as mercury, as all fish have some amount of mercury. As new guidelines are set as a result of elevated levels of PFOS, Michigan is releasing those advisories outside of the annual Eat Safe Fish Guides update.
• On April 29, 2019, the USEPA sent Wolverine a letter detailing the required time-critical cleanup CERLCA actions at the Tannery site. 
• As requested by EGLE and USEPA, in May 2019 Wolverine began installing informational signs along the Rogue River, with informational kiosks installed in June and July 2019.
• In August 2019, Wolverine completed their third-quarter of groundwater monitoring well sampling.
• In August 2019, Wolverine obtained their permit from the North Kent Sewer Authority (NKSA) for NKSA to accept the treated groundwater from the proposed groundwater interceptor treatment system.
• On August 15, 2019, the Wolverine Community Advisory Group (CAG) held their first public meeting at the Rockford Freshmen Center. EGLE presented at this meeting. 
• On September 19, 2019, the Wolverine CAG held a public meeting at Plainfield Charter Township Hall.  EGLE participated in this meeting.
• On October 17, 2019, the Wolverine CAG held a public meeting at Plainfield Charter Township Hall. EGLE participated in this meeting.
• On November 21, 2019, the Wolverine CAG held a public meeting at Plainfield Township Hall.  EGLE and DHHS participated in this meeting.
• On December 10, 2019, it was announced that a tentative agreement had been reached between the State, Plainfield & Algoma Townships, and Wolverine.
  • Press release: AG Nessel Outlines PFAS Settlement Framework for State, Plainfield & Algoma Townships, and Wolverine Worldwide
• On December 19, 2019, the Wolverine CAG held a public meeting at Plainfield Township Hall. EGLE and DHHS participated in this meeting.
• In December 2019, Wolverine completed the fourth-quarter groundwater sampling of environmental monitoring wells which we acceptable during the onsite construction activities. 

• On February 3, 2020, the Michigan Attorney General announced the filing of a settlement document (consent decree) in the case against Wolverine Worldwide Inc.  A public comment period will be held until February 13, 2020, to allow the affected community an opportunity to review and comment on the proposal prior to finalizing the settlement terms in court.
• Press Release: MI AG Nessel Announces PFAS Settlement for State, Plainfield & Algoma Townships with Wolverine Worldwide
• On February 10, 2020, Michigan Attorney General Dana Nessel and EGLE held a Consent Decree Public Comment Session at the Rockford High School Auditorium.
• On February 19, 2020, the proposed Consent Decree between the State of Michigan (Plaintiff), Plainfield and Algoma Townships (Intervening Plaintiffs) and Wolverine (Defendant) was approved by U.S. District Court Judge Janet T. Neff of the United States District Court for the Western District of Michigan. The Consent Decree became effective on February 19, 2020 and serves as the framework for all future response activities performed by Wolverine at the House Street property and surrounding area identified as the "North Kent Study Area".  Wolverine will conduct these activities under EGLE oversight, and the Consent Decree includes tools that ensure that the required work is completed.
  • Final signed Consent Decree, along with all appendices.
• On March 20, 2020, Wolverine submitted its "Tannery Interceptor System Conceptual Design" report as required under Section 7.7b(i) of the Consent Decree. This technical memorandum describes the goal, technical approach, and conceptual design for Wolverine's interim remedy which was in progress prior to the effective date of the Consent Decree.
• On April 16, 2020, the Wolverine CAG held an online zoom meeting. EGLE and USEPA provided project updates during this virtual meeting.
• On April 30, 2020, Wolverine submitted their 2020 First Quarter Progress Report as required under the Consent Decree.
• Wolverine completed the USEPA time-critical actions at the Tannery which included removal of impacted soils and buried leather scraps on the site and along the Rogue River, and continued site restoration activities as set forth in the settlement agreement between USEPA and Wolverine found on USEPA’s website. On May 14, 2020, Wolverine's Former Tannery Restoration Plan was finalized for USEPA. 
• On May 21, 2020, the Wolverine CAG held an online zoom meeting. EGLE, MDHHS, and Plainfield Township provided project updates during this virtual meeting.
• On May 26, 2020, EGLE hosted an Online Public Meeting for Wolverine's Filter Operation and Maintenance Response Activity Plan from 6:00 to 7:00 PM.
  • Recording of the May 26, 2020 Online Public Meeting for Wolverine's Filter Operation and Maintenance Response Activity Plan
• On May 27, 2020, EGLE hosted an Online Public Meeting for Wolverine's Groundwater-Surface Water Interface (GSI) Response Activity Plan from 6:00 to 7:00 PM.
  • Recording of the May 27, 2020 Online Public Meeting for Wolverine's Groundwater-Surface Water Interface (GSI) Response Activity Plan
• On June 18, 2020, the Wolverine CAG held an online zoom meeting. EGLE and MDHHS provided project updates during this virtual meeting.
• On June 23, 2020, EGLE hosted an Online Public Meeting for Wolverine's Residential Well Resampling Response Activity Plan from 6:00 to 7:00PM.
  • Recording of the June 23, 2020 Public Meeting
• On July 16, 2020, the Wolverine CAG held an online zoom meeting. EGLE provided project updated during this virtual meeting.
• On July 31, 2020 Wolverine submitted their 2020 Second Quarter Progress Report as required under the Consent Decree

Historical Sampling Table: PFOS + PFOA Only

Data is reflective of criteria prior to August 3, 2020. This table reflects data received before August 3, 2020.

*Groundwater results are compared to the previous EGLE Part 201 Criteria of 70 ppt PFOS+PFOA. 
*Surface water samples are compared to Rule 57 non-drinking water values of 12 ppt for PFOS and 12,000 ppt for PFOA. 

Sampling notes

• On August 3, 2020, new Part 201 Criteria went into effect. 
• Other PFAS analytes were detected in samples. There are no federal or state standards for these analytes.
• Sediments, pore water, surface water foam, and soil samples have also been collected from this site. PFAS was detected in all types of samples. There are no criteria for these media.
• A "Do Not Eat the Foam" advisory was issued by the Kent County Health Department in June 2018 for the Rogue River near the tannery.

• On August 18, 2020, EGLE hosted an Online Public Meeting for Wolverine's Area 5, Area 6, Area 11 & 12, and Area 19 Groundwater Investigation Response Activity Plans from 6:00 to 8:00pm.
  • Recording of the August 18, 2020 Wolverine's Area 5, Area 6, Area 11 & 12, and Area 19 Groundwater Investigation Response Activity Plans Online Public Meeting
• On September 16, 2020, MDHHS hosted two online webinars for the North Kent County Exposure Assessment; Preliminary Report Findings.
  • Summary of the North Kent County Exposure Assessment: Preliminary Report Findings
• On September 17, 2020, The Wolverine CAG held an online zoom meeting. EGLE and MDHHS provided project updates during this virtual meeting.
• On October 6, 2020, EGLE hosted an Online Public Meeting for Wolverine's Perimeter Monitoring Groundwater Investigation Response Activity Plans from 6:00 to 7:00pm. 
  • Recording of October 6, 2020, Wolverine's Perimeter Monitoring Groundwater Investigation Response Activity Plans Public Meeting
• On October 15, 2020, The Wolverine Community Advisory Group (CAG) held an online zoom meeting. More information can be found on the CAG's website: WolverineCAG.org/
• On November 9, 2020, MDHHS announced the launch of the Michigan PFAS Exposure and Health Study (MiPEHS) and the Multi-Site Study (MSS), which will take place in Parchment, Cooper Township, and the Belmont and Rockford areas of Kent County. Information on these studies can be found at Michigan.gov/DEHBio.  All eligible participants in Parchment, Cooper Township, Belmont and Rockford are scheduled to receive an enrollment packet in the mail from MDHHS by November 30, 2020. If you think you are eligible and do not receive an enrollment packet by that date, please call MDHHS' study partner, RTI International, at 855-322-3037 to see if you qualify.
• On November 19, 2020, the Wolverine Community Advisory Group held an online zoom meeting. EGLE provided project updates.

• On January 21, February 18, March 18, and April 15,  2021, the Wolverine Community Advisory Group held an online zoom meeting. EGLE provided project updates.
• On February 19, 2021, As outlined in Section 7.7(b)(i) of the Consent Decree, Wolverine submitted a Draft Response Activity Plan for the Tannery interceptor system (including any proposed modifications or expansion(s) of the currently installed/planned interceptor system) to EGLE for its review and approval.
• On February 19, 2021, Wolverine submitted the Draft Tannery Interceptor System Response Activity Plan. EGLE hosted a public meeting on May 5, 2021.The comments that EGLE received during the public comment are summarized and addressed in EGLE’s responsiveness summary document below:
  • Tannery Interceptor Responsiveness Summary Document
  • Draft Tannery Interceptor System Response Activity Plan
  • Recording of May 5, 2021 public meeting
• On August 17, 2021, EGLE sent Wolverine a response letter summarizing EGLE's denial/disapproval of the draft Tannery Interceptor System Response Activity Plan.
• On November 1, 2021, Wolverine submitted for EGLE review a revised Tannery Interceptor System Response Activity Plan.  
  • Revised (draft) Tannery Interceptor System Response Activity Plan

• On February 10, 2022, EGLE sent Wolverine an approval with conditions letter of the revised November 1, 2021, Tannery Interceptor System Response Activity Plan.
• On March 31, 2022, Wolverine submitted the final Tannery Interceptor Response Activity Plan.
  • Final Tannery Interceptor System Response Activity Plan
• On September 8, 2022, Wolverine informed EGLE that implementation of the Tannery Interceptor Response Activity Plan was behind schedule due to the results of pump testing conducted in May 2022.
• On October 19, 2022, EGLE issued Wolverine a Violation Notice regarding the implementation of the Schedule included in the Tannery Interceptor Response Activity Plan.
  • Violation Notice Regarding the Tannery Interceptor System Response Activity Plan
• On December 1, 2022, Wolverine submitted the draft Tannery Interceptor Response Activity Plan Addendum.
  • This Addendum was submitted due to further modeling and on-site pump testing conducted by Wolverine in 2022 which led them to modify the design of the proposed interceptor/extraction system. The modified system design consists of nine (9) shallow trenches, two (2) shallow extraction wells, and four (4) deep extraction wells.
  • Draft Tannery Interceptor System Response Activity Plan Addendum
  • EGLE accepted public comments on the draft Tannery Interceptor System Response Activity Plan Addendum through Friday, January 27, 2023. 
  • EGLE hosted an Online Public Meeting for the draft Tannery Interceptor Response Activity Plan Addendum on Tuesday, January 10, 2023, from 6:00 to 7:30 PM.  A recording of the meeting can be found here: Wolverine World Wide’s draft Tannery Interceptor System Response Activity Plan Addendum - 1/10/23 - YouTube

• On March 10, 2023, EGLE sent Wolverine a response letter summarizing EGLE's denial of the draft Tannery Interceptor System Response Activity Plan Addendum.
  • EGLE Response to the Tannery Interceptor System Response Activity Plan Addendum
• On March 29, 2023, EGLE finalized the Summary of Public Comments and EGLE Responses document for the draft Tannery Interceptor System Response Activity Plan Addendum.
  • Public Responsiveness Summary
• On May 9, 2023, Wolverine submitted the draft Revised Tannery Interceptor System Response Activity Plan.
  • Revised Tannery Interceptor System Response Activity Plan
  • EGLE accepted public comments on the draft Revised Tannery Interceptor System Response Activity Plan from May 25, 2023, through June 30, 2023. 
  • EGLE hosted an Online Public Meeting for the draft Revised Tannery Interceptor System Response Activity Plan on Tuesday June 6, 2023, from 6:00 to 7:30 PM. Meeting Recording: Wolverine World Wide’s draft Revised Tannery Interceptor System Response Activity Plan - 6/6/23
• On July 31, 2023, EGLE sent Wolverine a response letter summarizing EGLE's approval with conditions of the draft Revised Tannery Interceptor System Response Activity Plan.
  • EGLE Response to the Revised Tannery Interceptor System Response Activity Plan 
• On August 2, 2023, EGLE finalized the Summary of Public Comments and EGLE Responses document for the draft Revised Tannery Interceptor System Response Activity Plan.
  • Public Responsiveness Summary
• On September 20, 2023, Wolverine submitted the Final Revised Tannery Interceptor System Response Activity Plan
  • Final Revised Tannery Interceptor System Response Activity Plan 

• In 2024, Wolverine began implementation of the Final Revised Tannery Interceptor System Response Activity Plan, including the installation of nine groundwater interceptor trenches along the Rogue River and Rum Creek.

• On March 19, 2025, the groundwater interceptor system began operation.  Groundwater from the trenches and extraction wells is treated in an on-site intermediate water treatment system and discharged to the Rogue River under a National Pollutant Discharge Elimination System (NPDES) permit.