The Michigan Department of Environment, Great Lakes, and Energy (EGLE) has issued a Violation Notice to Wolverine Worldwide, following the discovery that the company is months behind on the implementation of several items mandated in the Tannery Interceptor System Response Activity Plan for the Rockford Tannery, which was approved on March 31, 2022.
The Notice of Violation, issued on Oct. 19, cites ten activities Wolverine has not completed, some with deadlines extending back to May. EGLE determined that the required timelines had not been met following notification from the company that the pump tests for the approved interceptor system yielded insufficient withdrawal volumes to prevent PFAS contaminated groundwater from impacting the Rogue River.
Reporting on the matter at the October meeting of the Wolverine Community Advisory Group (CAG), EGLE Environmental Quality Analyst Leah Geis said Wolverine notified the agency in September that they were behind schedule on the interceptor system at the tannery site.
“They weren’t getting the amount of groundwater through their system that they needed to stop groundwater from going into the river,” Gies said. “They’re redesigning the system, and they need to submit us a modified plan by December 1st.”
Members of the CAG expressed concern that not only is Wolverine so far behind on the deliverables mandated by the response activity plan, but redesigning the system could set the project back by another year. During this time, PFAS contaminated groundwater will continue to enter the Rogue River and damage the natural resources it provides to the community and the environment.
The final Interceptor System Response Activity Plan approved in March included several action items and deadlines. Wolverine was to have completed the final design of the interceptor system in May and finalized the specifications in June. Permitting, contract preparation, and bids for the project were required to have taken place in July, with contractor selection and equipment ordering due in August and September.
The Violation Notice, signed by EGLE District Supervisory Karen Vorce, indicates that EGLE only became aware of the failure to meet deadlines when Wolverine reported that pump tests conducted six months ago showed the proposed system would not be effective in preventing historical PFAS contamination on the site from reaching the Rogue River.
The Notice of Violation letter states:
“EGLE was made aware that the activities … had not yet been completed in accordance with the Schedule due to the results of the pump tests completed at the Tannery property in May 2022, which indicate that the design of the interceptor system presented in the approved March 31, 2022 (Response Activity Plan) requires significant modification to capture the targeted amount of groundwater at the site.”
Gies said Wolverine is currently not being fined for the violations.
“We’re not trying to rush them, but we do want to make sure that they’re still moving on it,” Gies said.
Wolverine has until Dec 1, 2022 to respond with a revised plan. Members of the CAG will lead the community response and urged the community to also take action. Concerned citizens are encouraged to attend CAG meetings or contact the CAG at firstname.lastname@example.org.
More information about the tannery response activity can be found at the Michigan PFAS Action Response Team (MPART) and the Wolverine CAG website.
The Wolverine Community Advisory Group serves as a community advocate throughout the Wolverine Worldwide PFAS contamination response at the Rockford tannery and House Street sites.