BOOKS

There are many books related to environmental health, however we want to bring to your attention seven related to the PBB accident, health consequences, and the efforts to remediate sites contaminated by Velsicol:

Rachel Carson, Silent Spring (Boston: Houghton Mifflin, 1962) NOTE: Velsicol Chemical targeted Rachel Carson for attack, threatening a major lawsuit if Silent Spring were published.

Edwin Chen, PBB: An American Tragedy (Englewood Cliffs, NJ: Prentice Hall, 1979)

Thomas H. Corbett, Cancer and Chemicals (Chicago: Nelson Hall, 1977), pp. 121-145

Joyce Egginton, The Poisoning of Michigan (New York: W.W. Norton, 1980) [republished by Michigan State University Press in 2009]

Frederic Halbert and Sandra Halbert, Bitter Harvest (Grand Rapids: W.B. Eerdmans, 19y8)

Jane Keon, Tombstone Town (Creative Space, 2015)

Edward Lorenz, Civic Empowerment in an Age of Corporate Greed (East Lansing: Michigan State University Press, 2012)

FILMS

There are several films that focus on the PBB accident [we have found all of these can be viewed on the Web]:

Bitter Harvest (Charles Fries Production, 1981)

The Poisoning of Michigan (Thames Television, 1977)

Slaughter (an episode from November 1978 of the Lou Grant Show on CBS)

ENVIRONMENTAL BOOKS FOR YOUNG PEOPLE, PARENTS, AND TEACHERS

We want to suggest some books, often in electronic editions, that can help prepare young people to put the environmental and health challenges of the region into perspective. We hope teachers and parents will try to have youth read these, so they are prepared to help confront the problems we have left for them:

Michael Foreman, One World (London: Andersen Press, 2012)   Grades 2-4

Laurie Lawlor, Rachel Carson and Her Book That Changed the World (New York: Holiday House, 2014)   Grades 1-4  NOTE: Velsicol Chemical targeted Rachel Carson for attack, threatening a major lawsuit if Silent Spring were published.

Julian Lennon, Heal the Earth (New York: Sky Pony Press, 2018)  Pre-school-K

Julian Lennon, Touch the Earth (New York: Sky Pony Press, 2017)   Pre-school -K

Stephanie Sisson, Spring After Spring: How Rachel Carson Inspired the Environmental Movement (New York: Roaring Brook Press, 2018)   Grades 1-2     NOTE: Velsicol Chemical targeted Rachel Carson for attack, threatening a major lawsuit if Silent Spring were published.

Dr. Seuss, The Lorax (New York: Random House,1971)   Grades K-4

YOUNG ADULT ENVIRONMENTAL NOVELS AND BIOGRAPHIES

Karen Ball, Hazardous Homestead (Wheaton, Il: Tyndale House, 1992)  Grades 4-6

Chris Barry, Mosquito Point (New York: Royal Fireworks Press,1996)   Grades 7-9

Virginia Bergin, H2O (Naperville, IL: Sourcebooks, 2014)   Grades 8-12

Varda Burstyn, Water, Inc. (Brooklyn: Verso, 2005)   Grades 9-Adult

Mark, Delaney, Misfits, Inc. No. 4: The Kingfisher’s Tale (Atlanta: Peachtree, 2000)   Grades 5-9

Gail Gauthier, Saving the Planet & Stuff (New York: G.P. Putnam, 2003)   Grades 7-9

Jean Craighead George, The Case of the Missing Cutthroats (New York: Harper Collins, 1999)  Grades 3-7

Diane Haynes, Flight or Fight (Toronto: Walrus Books, 2006)   Grades  7-11

Greta Thunberg, One Too Small to Make a Difference (New York: Penguin Books, 2019)  Many formats

PHOTOS

Please visit the photos page.

NAMES AND TERMS

We have a Glossary with explanations and definitions of names and terms you may not be familiar with unless you live in St. Louis or work on other remediations. 

DOCUMENTS

First, we list some documents for which we are in the process of adding links.  These are documents that are permanently important to understanding our work and mentioned elsewhere in the website.  In a subfile called our Document Archive are actual copies of documents from the first 12 years of the Task Force’s work.

US EPA maintains a website with much current past information, including many documents related to their work in St. Louis and at other sites across the nation related to Velsicol. For documents related to the plant site in St. Louis, go to: VELSICOL CHEMICAL CORP. (MICHIGAN) | Superfund Site Profile | Superfund Site Information | US EPA

The Clarke Historical Library at Central Michigan University and the Alma College Library Archives have many documents related to the topics in theis website. Often copies in the libraries may be more readable than scanned documents linked here.

There is a collection of health studies at the PBB Registry’s website on the Emory University, Rollins School of Public Health system. To access these reports, go to: Research (emory.edu)

Below in chronological order are some documents [especially older ones] we think may help understand the issues addressed in this website. We’d urge you to do your own research in the archives at Clarke Historical Library and Alma College and not stop with this website. Many are referenced if you have reviewed the Timeline page on this website.

Pre-PBB Crisis Contamination and Health Warnings - 1935-1972

Saginaw City Council from 1935 expressing concern with Pine River pollution if Michigan Chemical begins operation.

University of Michigan 1935 study of Death of Fish in Pine River in response to Saginaw City Council resolution (above).

St. Louis Leader in September 1941 reported that 121 citizens of St. Louis complained about Michigan Chemical’s contamination of the river. This is another example of the early knowledge of problems from the company, even opposed locally.

New Yorker 1945 story about dangers of DDT use. Also contains a 1986 story from Environmental Science and Technology by Gene Kenaga about the struggle to regulate pesticides. Dr. Kenaga was a long-time DOW Chemical scientist and DDT expert.

New Republic 1946 story about DDTs dangers.

Journal of Pharmacology 1947 story on problems of DDT use

American Medical Association 1949 journal article warning of DDT impacts on dogs.

Michigan Department of Natural Resources 1955 Biological Survey of the Pine River warns of problems

Michigan State University ornithologist George Wallace in the late 1950s and 1960s conducted studies of DDT impacts on birds, this article MSU’s magazine in 1989 reviewed the history of Wallace’s confrontation with the University and state politicians.

Rachel Carson’s Silent Spring was published by Houghton Mifflin in September 1962. On the eve of publication, Velsicol threatened Houghton Mifflin with a liable suit if they published the book. Carson’s book documented many problems with a number of Velsicol pesticides. This file contains documents from the Yale University Archives where Rachel Carson’s papers are housed. Forgive the poor quality of the images; the originals were of this quality. The file contains excerpts from a book published i 1972 by Paul Brooks, (The House of Life) Rachel Carson’s editor and the person who decided to defy Velsicol’s threats. Note the message from the University of California editor who told Paul Brooks how the university threatened him for undermining agriculture in California. At the end is a hard to red copy of the initial legal threat from August 2, 1962, written by Velsicol’s General Counsel, Louis McLean..

Reviews of Silent Spring: In late 1962 there was a controversial campaign, the first of many, to attacked Rachel Carson, with some scientists coming to her defense. Note that the AMA review, which was negative was purposely written by a female physician.

Michigan Audobon Society 1962 Annual Meeting at Alma College raises objections to pesticide use. Two key players at meeting were Gene Kenaga, DDT expert at Dow Chemical and Audobon in-coming President and Alma College Professor Lester Eyer, Conference Chair. The Task Force in 2008 would name the International DDT Conference hosted at Alma College for Dr. Kenaga, who died the previous year, but encouraged holding the conference.

The Michigan Water Resources Commission in 1967 conducted a study of pollution coming from Michigan Chemical into the Pine River .In the late 1960s

Following up on the 1967 study, in 1970 the Water Resources Commission conducted a study of the entire Pine River watershed, this one exposing both Michigan Chemical impacts and chromium 6 contamination from Lobdell Emery (later Oxford Automotive) manufacturing in Alma and the Alma Total Refinery. [Note because of poor copies, this report is in three parts, the title page, most of the report and as good a copy as possible of a core pages 1- 8.]

PBB Crisis (1973-1980s):

In 1973 Michigan Chemical made a terrible shipping error, mistakenly delivering to animal feed supply facilities a flame retardant composed of polybrominated biphenyls (PBB) instead of salts.

In 2019 leaders of the Pine River Task Force and experts from Emory University in Atlanta were invited to make a presentation to Michigan legislators in Lansing on the Lessons of the PBB Crisis for more recent environmental-health issues, specifically PFAS contamination. This set of copies of posters from that event summarizes the PBB Crisis, including a basic timeline, summary of the health effects of PBB exposure, a summary of the PBB Oral History project, a map of farms quarantined in the 1970s because of contaminated farm animals.

One of the early participants in the effort to understand the error and the consequence was George Fries at the U.S. Department of Agriculture. In 1985 he wrote this long discussion of the PBB crisis.

After the PBB Accident became known, researchers at Henry Ford Hospital began a study of the impacts on children. here is a rough copy of their project.

For a summary of the public health work on PBB in the 1970s, there is a summary in the American Journal of Public Health in 1983.

In 1975 the Michigan Department of Public Health began to create the Michigan PBB Registry, that still is a focus of our research by Emory University into the impacts of PBB exposures. For a review of the process of creating the PBB Registry see this report. This report includes a copy of a 1979 initial study of what was known of health impacts of PBB exposures.

Breckenridge Cancer Cluster:

As the PBB Crisis was unfolding, reports began to appear about a cancer cluster in Breckenridge, Michigan less than seven miles east (downwind) from Velsicol’s St. Louis plant, Also, much closer to Breckenridge was the Michigan Chemical nuclear waste dump on Madison Road’s crossing of Bush Creek. Here is a copy of a paper presented at the 1976 meeting of the American Federation for Clinical Research by three physicians at the University of Michigan in Ann Arbor: Dr. Richard Schwartz, Dr. Jeffrey Callen and Dr. Joseph Silva [here is a link to their paper]. Schwartz, Callen and Silva speculated the cancers resulted from exposure to navy bean dust from grain elevators in Breckenridge. Some Breckenridge residents, believing the bean dust theory silly, feared the bean dust theory grew from fears the cancer cluster would be blamed either on Velsicol or the Total Petroleum refinery in Alma, ten miles up-wind. In 1976-77, Dr. Mattew Zack conducted a study [here is a link to Zack’s paper] looking at cancer rates in other communities with bean elevators. Here is his 1977 paper refuting the bean dust theory. Typically, o responses in the era to Velsicol impacts on human health, nothing more was done by state officials to determine an environmental exposure link to the Breckenridge cancer cluster. The cluster faded away after Velsicol ceased operation in St. Louis.

Velsicol Settlement; In 1982, after three years of negotiation, Velsicol reached a settlement with the U.S. EPA and Michigan Department of Natural Resources to be freed of future liability if the company paid for demolition of the old factory (closed in 1979) and moved and buried all contamination from the Velsicol Burn Pit to the old plant site. The legal settlement we call the Consent Decree or Consent Judgment, approved by the federal courts. Here are  newspaaper stories about that settlement from the New York Times, Washington Post and Christian Science Monitor in late 1982 and 1983. Disputes related to the settlement led to the jailing of the Superfund Director Rita Lavelle and the firing of EPA Administrator Anne Gorsuch (mother of Supreme Cour Justice Neil Gorsuch).

1988 ATSDR Report an early warning of possible problems with the early 1980s containment

1993 ATSDR Review: A report from ATSDR that more specifically than the 1988 preliminary report warned of problems with the Velsicol site

In 1995 lobbyists succeeded in getting the new Congress elected in 1994 as an anti-regulatory and anti-EPA agenda repealed the Superfund Tax that paid for clean-ups when no responsible party could be made to pay. This National Geographic report describes this process. The Superfund trust fund ran out of money by 2003. The tax was only restored in 2021 in the Infrastructure Act. For a 2021 review of Superfund Tax history go to this report from the Congressional Research Service.

The Pine River Task Force ERA (1997-present)

In October 1997, the US EPA and state Department of Natural Resources held a well-attended public meeting in St. Louis to inform the community the agencies had found high levels of DDT in Pine River fish and that the river would need to be remediated. Because the meeting lasted several hours, with heated criticism of the 1982 Consent Judgment EPA officials suggested the community might want to form a Community Advisory Group (CAG) to advise EPA on clean-up. People took advantage of that offer and at a December 1997 meeting the attendees agreed to form the Pine River Superfund Citizen Task Force, which was incorporated in early 1998 (called below the Task Force or the CAG).

In 1998, the EPA Remedy Review Board described the process for addressing again (after the company led clean-up in the early 1980s) of the contamination problems in ST. Louis adjacent to the plant site.

As a community advisory group, the Task Force was entitled to apply for a $50,000 Technical Assistance Grant (TAG) to support it hiring experts to give a second opinion related to EPA decisions. The Task Force sent this letter in December 1998 asking for a TAG. We have had continuous TAG support sine 19to regulators about this concern.99.

Once the Task Force started, we worried about special deals being made by Velsicol or Fruit of the Loom which we learned owned the Velsicol Superfund sites in town. Here is a copy of our letter

In 1999, Fruit of the Loom, the name for the former parent company of Michigan Chemical/Velsicol filed for bankruptcy. The Task Force immediately filed a claim in federal bankruptcy court for $100 million dollars, to protect assets for the remediation in St. Louis. In 2002 a settlement of that suit, which included Velsicol (by then a separate company). Here is the legal settlement with Velsicol that provided funds for the former Velsicol plant site in St. Louis, as well as for the Breckenridge low level radioactive waste dump. [see below for 2011 concluding report on remediation of the Breckenridge Nuclear Waste Dump.]

in the midst of starting the Task Force, Ultramar Dimond Shamrock, which had purchased the Total Refinery on the Pine River in Alma announced it was closing. We knew the refineries in Alma were the source of hydrocarbon wastes on the sediment downriver in St. louis. We had hoped the refinery would remediate their wastes, especially in Horse Creek a tributary of the Pine River that ran behind the refinery. When we learned that the US Department of Justice had brought a pollution lawsuit against Ultramar Diamond Shamrock, we wrote this letter protesting being exclude from the proposed settlement.

After the Department of Justice held a hearing at Alma College, we asked that instead of fines that would go into general revenue they be converted into what are called a Supplemental Environmental project (SEP). Here is the ruling of the federal courts approving our SEP where the refinery agreed to clean Horse Creek.

In August 1999, the Task Force learned there was an opportunity to secure funds through the National Institute for Environmental Sciences (NIEHS) to study contamination impact on health. Accordingly, we received help from Dr. Wilfried Karmaus at Michigan State University to submit the grant proposal. Here is the text of the Task Force letter of support for the grant. Here is the core part of the grant describing the Ttask Force community involvement plan for the research. When two grant proposals were rejected, the second for lack of community involvement, here is the Task Force complaint letter to NIEHS. In general, the Task Force was upset that, as so often in research funding, it was not available to people with concerns in communities, but rather went to elite university research programs, some without real community engagement,

In early 2000, the Task Force learned that Fruit of the Loom had filed for bankruptcy protection in late 1999. Knowing the river sediment remediation on-going at the time, was estimated to cost at least $100 million, and that Fruit of the Loom had taken out a $100 million environmental insurance policy with AIG insurance, the Task Force filed a claim in bankruptcy court (see here). The Task Force also wrote to the national community engagement coordinator met at a CAG conference asking for approval to spend TAG fuds on our bankruptcy challenge. Accordingly, while awaiting a response, the Task Force reported the bankruptcy work in our September 2001 TAG Report. Finally, the Task Force received free legal help from the University of Michigan Law School to draft a letter asserting the need to seek funds from the insurance policy to reimburse the government for the loss of natural resources.

In May 2002, the lawsuit by the federal government to recover funds resulted in a settlement with Fruit of the Loom for seven highly polluted sites, including the former Velsicol Plant Site in St. Louis and the Breckenridge Michigan radioactive waste dump. Here is the EPA summary of the settlement. Note: The EPA webpage on the settlement includes many links to other related documents.

.Oxford Automotive Claim by Task Force 2005: The Task Force did not file a claim for river contamination until Oxford announced it was closing the Alma factory and laying off all employees.

Oxford Automotive bankruptcy settlement 2005 for dumping chromium 6 in Pine River won by Pine River Task Force.

In 2005, the Task Force and residents of St. Louis learned that pCBSA (Para chlorobenzene sulfonic acid), a by-product of DDT production was found in drinking water of St. Louis municipal drinking water system. This finding, led to a lawsuit to force the Velsicol and Fruit of the Loom environmental insurance to pay for a new water system. The U.S. Justice Department opposed the St. Louis litigation because it wanted to revise the Fruit of the Loom bankruptcy settlement of 2002 (see above). St. Louis received legal help from Sher-Leff, a California law firm that specializes in water law. In 2011, St. Louis won its lawsuit against Fruit of the Loom, Velsicol and the U.S. government, creating a new regional water system based in the upriver Alma municipal water plant. Here is the 2010 court ruling that allowed the case to go ahead, despite U.S> government objections. Here is the 2011 settlement. Over the next decade, the new Gratiot Area Water Authority drilled new wells west of Alma, and installed other infrastructure to supply clean water to St. Lous.

Also in 2005, there was a settlement between Velsicol’s insurance and the U.S. government. See here for the text.

In 2008, the Task Force became engaged in an international campaign by petrochemical industry lobbyists to undermine the Stockholm Convention on Persistent Organic Pollutants, which initially focused on limiting exposures to the twelve worst pollutants, called the “dirty dozen.” The “dirty dozen included five products patented by Velsicol (aldrin, chlordane, DDT, dieldrin, endrin, heptachlor). In addition, the “dirty dozen” included DDT made by Michigan Chemical. The international anti-Stockholm campaign, led by a “non-profit” front organization, Africa Fighting Malaria, used the argument that first world environmentalists were restricting the use of DDT that they claimed was desperately needed by African children dying of malaria exposure. Fearing the lobbying might succeed in stopping regulation and clean-up of DDT, including in the Pine River, the Task Force sponsored the Eugene Kenaga International DDT Conference on the Alma College Campus four miles southeast of St. Louis. The conference was named for the global DDT expert, Gene Kanaga, a Task Force member who died the previous year. The conference brought together scientists from as far away as South Africa. Here is a link to the summary of conference concerns, what has come to be called The Pine River Statement, published in Environmental Health Perspectives. The keynote address at the conference was delivered by Dr, Chris De Rosa, a senior toxicologist at the Centers for Disease Control, and emphasized the need to observe the precautionary principle as developed by Bernardino Ramazzini (1633-1714), the ‘father’ of occupational medicine. Ironically given the lobbying of Africa Fighting Malaria, Dr. Ramazinni had developed one of the earliest treatments for malaria. Dr. De Rosa as well as Dr. Brenda Eskenazi, who was the prime author of the “Pine River Statement” were members of the Collegium Ramazzini, the international health organization founded by Dr. Irving Selikoff, one of the first physicians who helped with PBB health research at the start of the PBB Crisis. At the time Dr. De Rosa was being attacked by politicians and regulators supportive of major polluters (see here)

In 2010 the Velsicol Burn Pit was readded to the Superfund National Priorities List at the request of Governor Granholm. The Task Force had lobbied to have this done. The site, originally created during the 1982-83 legal settlement (see consent judgement responsibilities of Velsicol), was “de-listed” from Superfund before being listed, an exceptional process, when Velsicol claimed it had oved all contaminants from the site and buried them at the former plant site. While added back to the National Priorities List, the site received minimal attention until early 2022 when Congress renewed the Superfund Tax in the Infrastructure Act passed in November 2021.

Michigan Chemical/Velsicol Breckenridge Nuclear Waste Dump remediation report 2011

In 2012, U.S. EPA announced its Record of Decision related to full remediation of the former Velsicol Plant Site in St. Louis, a process costing possible a half billion dollars and extending over decades.

In 2013, the Task Force made contact with experts at the Rollins School of Public Health at Emory University who were following up on people exposed to PBB n the 1970s. Here is an example of notifications in fall 2013 of the first PBB screening in St. Louis, focused on former chemical workers and their families. More than 200 people came to the screenings in December 2013.

In 2014, the continuing concern with the causes of bird deaths in St. Louis, especially in the neighborhoods near the old Velsicol plant, finally for national media attention, tigering a removal action by US EPA to take contaminated soil from around 90 homes in St. Lous. Check US EPA website for more document of look on the web for news stories, such as this one.

In 2016, responding to the continuing concerns with the consequences of exposures of younger generations both through parental exposures or the water and soil contamination found to have continued into the second decade of the 21st Century led to the CAG sponsoring another human health conference. The conference secured the collaboration of PBB partners from Emory University, support from scientists associated with the International Joint Commission, and other scientists with the various Superfund Research Programs. Alma College and the City of St. Louis provided sites to hold meetings of the Intergenerational Risk Conference. For a summary of the conference see here.

In 2018, U.S. EPA began thermal destruction process for most dangerous volatile contaminants at the former Velsicol plant site in St. Louis. That process continued for different sections of the site. For a description of the process through 2021 (see here). This document also descibes other recent remediation work, especially work on the downriver flood plain, added to the Velsicol site.

In 2018, Brittany Fremion, Task Force Secretary and history professor at Central Michigan University launched the PBB Oral History Project, recording the reflections of people engaged in the PBB Crisis in the 1970s. The PBB Oral History Project is a collaboration between community partners, Central Michigan University, Emory University, and the University of Michigan and was funded by the National Institute of Environmental Health Sciences,

In November 2021, Congress restored the Superfund Tax (see report here) freeing funds for expedited clean-ups, including of the Velsicol Burn Pit in St, Louis. (see story here).

On February 15, 2022, the Pine River Superfund Health Map Support Group released their report (see report here).

In July 2022 the U.S. EPA released a proposal related to remediation of contamination in the Pine Rover flood plain below the St. Louis Dam, an area called operable unit 3 or OU3. (see proposal here)

On August 25, 2022 the US EPA released the Five-Year Review of clen-up effort in St. Louis at the former Velsicol plant site. Thi i a goo summary of the EPA perpective on the status of remediation efforts in the community. (see Five-Year Review here)

DOCUMENT ARCHIVE

On the U.S. Environmental Protection Agency website, there are many documents related to the Superfund sites in St. Louis. Here is the address of that site: VELSICOL CHEMICAL CORP. (MICHIGAN) | Superfund Site Profile | Superfund Site Information | US EPA

As a result of the litigation of the City of St. Louis against Velsicol’s insurers to fund a new water system, the city received 40 boxes of Velsicol records extending back many years. Here is a list by box of these document

Box 1 of 40

Drawings:

·         Velsicol Chemical Corporation 1981 --  All Velsicol Burn Pit

·         Various UIC (underground injection) reapplications – has brine pipe lines to various wells

·         Vesicol Chem. – miscellaneous

·         Plant site, St. Louis, Mi. 1984 – Containment wall profile

·         Plant site disposal areas 1991

·         Plant site 1983 – on site disposal area – oil contamination – barrier wall – shows radioactive site – pipeline to the north

·         Vel. Chem. Corp. St. L. 1981 – has maps – one is of radioactive locations on the plant site – others of buildings and tanks

·         Vel. Chem. Corp. St. L – containment wall profile prints

·         Securement of plant site, St. L. 1984 – variety of blue prints.

 Box 2 of 40

·         Binder on Smith Farm Site

·         Binder on Golf Course Site

·         Binder on Class 1 Disposal Well (Crumbaugh Well)

·         Binder on Golf Course Site (says Compounds)

·         Report on radioactivity on plant site

·         Report on Marsh fire in New Jersey

·         Report on burial of railroad tracks on plant site

·         Map of Burn Pit area –1982 – Conestoga Rovers

·         Report that mentions Gratiot County Landfill and disposal well

·         Mention of city storm sewer

·         Binder on Disposal well #2

·         Binder on Smith Farm Site by Memphis Environmental – 1988

·         Binder on Deep Well leachate samples

·         Binder on Supplemental Funding Request, Chuck Hansen, water disposal

·         Binder on General Correspondence (lots of radioactive tests)

 Box 3 of 40

·         Vol. I of VIII:  Text – Remedial Investigation of OU-1 (Full write-up of 2006 RI-OU-1) (speaks to Former Plant Site, Velsicol Burn Pit, and Adjacent and Nearby Properties) by Weston, Nov. 2006

·         Vol IV of VIII:  Figures

·         Eco Solutions, Inc. (for Memphis Environmental) Disposal Well #2, Bethany Twp. (surface construction report) June 1997

·         Final Containment System Assessment Report.  Prepared by Memphis Environmental for NWI Land Management October 1997

·         File #9 contains correspondence on:

Downgradient wall

1980-1983 miscellaneous

Ø  Eastman clay pit on Riverside Drive

Ø  Railroad tracks

Ø  Monument

Ø  Purchases/delinquent purchases

Ø  Former MCC employee

Ø  Compliance Schedule

Ø  Pit Closure Schedule

Ø  Velsicol/EPA contact report

1983 file

            Granite marker information

FAO34-4610S.3

Ø  Smear tests for radiation on equipment

Ø  Items leaving plant site

Ø  Railway ownership (between MCC and Railway)

Ø  Sale of Velsicol’s inventory

Folder 1907

Ø  Well injection activities and hazardous waste

·         Post Closure Maintenance and Monitoring Plan

·         Communications and Correspondence folder

Ø  Superfund and Gratiot County Landfill

Ø  Groundwater Flow Modeling

 Box 4 of 40

·         Vol. I of 1  Remediation Investigation OU-1 January 2009, Addendum Report, Weston

·         Vol V of VIII:  Figures November 2006 (on-site related maps)

·         Vol. II of VIII:  Tables November 2006 (soil borings, sample results)

·         Vol. III of VIII:  Figures  Nov. 2006, (groundwater, sw, contours, cross sections, maps)

 Box 5 of 40

·         Vol.VI RI OU-1 November 2006 (groundwater concentrations, maps, potential pathways)

·         Vol. IV:  Figures Nov. 2006 RI OU-1 (soil samples, aquifer samples, gw samples, maps)

·         Vol. II:  Tables Nov. 2006 RI OU-1 (shows lots of exceedences) (sample locations, lab results)

 Box 6 of 40

·         Binder on Hydraulic Modeling (plant site)

·         Binder on Year 2000 Cleanup River Site (EPA)

·         Binder on Slurry Wall (attempts to find it)

·         Another binder on Slurry Wall – with conclusions

 Box 7 of 40

·         1987 Inspection Reports (plant site)

·         1988 Inspection Reports (plant site)

·         St. Louis plant site account book – incurred bills

·         1990 Inspection Reports (plant site)

·         1989 Inspection Reports (plant site)

 Box 8 of 40

·         Groundwater seeps Vol. 1 of 2  (May 2002) (pgs. 3-4 thru 3-16, purple flagged)

·         Conclusion and recommendations (4-1 thru 4-7)

·         Book 1 of VIII Text Nov. 2006, Section 6: Conclusions and recommendations (cap, slurry wall, till unit)

 Box 9 of 40

Notebook 1:

·         Payment record to Sevenson (Seven Sons) Construction – 1982

·         Bill to Sevenson’s for cleanup of Burn Pit --  $1,077,367.50

·         Bills from Conestoga-Rovers

·         Golf Course/Burn Pit bills and changeovers

Notebook 2:

·         Correspondence and 1991 Weekly Inspection reports

·         Deep well #2 reports

·         Post Closure inspection reports

Notebook 3:

·         2005 Final Source Migration report

Notebook 4:

·         DNR cleanup guidance documents (1990-1993)

Notebooks 5, 6 and 7:

·         Correspondence 1992, 1993, 1994 and Weekly Inspection reports

·         Deep well #2 reports

·         Post closure inspection reports

 Box 10 of 40

Notebook 1:

·         1995 correspondence and reports (Velsicol NPDES permit to discharge water into the Pine River

·         1995 Work Plan by Memphis Environmental to “assess the containment system integrity and activate deep injection well

·         History highlights on the Mill Street substation and the former mill race

·         Radiochemical results letter on water samples

·         1994 Special inspection report by Nuclear Regulatory Commission of storage facilities for radioactive materials on the plant site.

·         1994 letter saying radioactive discharge waters into sewer

·         1994 letter and groundwater collection system drawings

Notebook 2:

·         Memphis Environmental reports at plant closure time

·         Reports on deep well disposal (1998)

Notebook 3:

·         1996 Weekly Inspection reports

·         Deep well readings

·         Post closure inspection reports

Notebook 5:

·         1995 Weekly Inspection reports

·         Deep well readings

·         Post closure inspection reports

 Box 11 of 40

 File 1:

·         Files on Crumbaugh Injection Well

·         Files on Permit Application for injection well, and correspondence

·         Spiral exhibit on process for permit

·         Velsicol application for RCRA permit

·         Correspondence regarding Velsicol wanting to dump plant site water in Pine River

·         Mineral well documents and permits

·         About deep injection well (Crumbaugh, Disposal Well #2)

·         Duplicates of permit correspondence

·         Documents on Unloading Shed at Crumbaugh farm

File 2:

·         Correspondence between John Hock (Memp. Env.) and Bob Aker (mowing)

·         Correspondence with Crop Services (fertilizer)

·         Letter from Conestoga-Rovers about contract for securement of waste burning and disposal area (Burn Pit).

·         Correspondence between John Hodk and Lapham and Associates and CEC, groundwater monitoring

File 3:

·         Day by day list of activities regarding plant site tear down (June 13-Dec. 18, no year)

Ø  NRC inspectors on site July 23

Ø  Sugar beet ware house vacuumed prior to demolition

Ø  Creamery Warehouse property excavated, clean fill brought in (map)

Ø  Letter about areas to be demolished

Ø  Letters from iron and metal scrap haulers – no selling, melting only

·         Agreement between Velsicol and Edgewood Hills golf course to clean up 60,000 cy

·         Correspondence about leachate hauled by truck from Edgewood to plant site for disposal in a deep well on the plant site

·         People lawsuit against Velsicol regarding Edgewood – case dismissed

·         6 copies of Golf Course Site Contract document and specifications for bids

File 4:

·         Velsicol letters and notes (1986) about sending reports to comply with Consent Judgment

·         4 copies of Consent Judgment

·         2 copies of Consent Decree

File 5:

·         Tax bills – Bethany and Pine River Townships

·         1981 surveys of plant site for Velsicol by Ayres and Asso.

·         1998 Taxpayer Guide

·         Blank application form for Water Pollution Control

·         1989 tax receipts for plant site

·         Survey of plant site

·         List of herbicides, volatiles and other toxins

·         Formal document (1986) requesting exemption from groundwater monitoring requirements (includes geological cross sections)

·         Record of Decision document for site in Muskegon (2 copies)

·         Papers on lawsuit – Hugh Eastman (clay pit) suing Velsicol to pay for clay not needed or used

·         Letters of Credit (1992-93) for EPA from Union Underwear

·         Document from DNR – Administrative Rules for Michigan Environmental Response Act

File 6:

·         NWI Land Management – anticipated costs

·         NWI tax bills from St. Louis

·         NWI assessments

·         NWI tax bills 2001

·         NWI tax bill – Breckenridge Site

·         Mineral well assessment report

·         NWI personal property statement

·         Notice of assessments (city and township)

·         Copy of 1966 Easement for Crumbaugh Disposal Well #2

·         Map of pipeline from Golf Course/BurnPit to Crumbaugh well

·         Letter from Shell to Michigan Chemical – oil and gas lease and disposal well

·         Oil and gas lien, 1997, Robert and Marcelle Crumbaugh/NWI

·         Letter from Goggin & Baker to lawyer for Huge and Ruby Eastman

·         Amended Agreement between Velsicol and Eastmans

·         Mortage: Eastman and Velsicol

·         Lease Agreement letter – Disposal Well #2

·         1971 Agreement Crumbaugh well

·         1973 letter – paving areas on St. Louis plant site

·         Copies of property cards and ledgers about paved areas plant site

·         1966 Title Opinion Holton vs. Michigan Chemical Corporation (disposal well site)

 File 7:

·         CAG comments on SEP (Pine River Superfund Citizen Task Force Community Advisory Group on a Supplemental Environmental Project -- $9 million, pending consent decree between Total Refinery, Alma, and the US Department of Justice.

·         1998 Consent Judgment – State of Michigan and Chippewa Tribe vs. General Motors

·         Consent Decree – Total Refinery

·         Letter about complaint – Chippewa Tribe v. GM

·         CAG comments on Total decree

·         1998 Administrative Order for EPA an MDEQ to have access to the Velsicol plant site

·         Copy of complaint from the Chip. Tribe v. GM

·         Civil Action – State of Michigan v. GM

·         Legal answer to River Band Indians v. State of Michigan

·         Draft paperwork for incorporation of PRSFCTF into a Community Advisory Group

·         1998 letters about Velsicol not letting EPA or MDEQ on site – EPA is prepared to issue an order

·         1998 letter about access – want liability release

·         Copies of proposed access agreement

·         Blank access agreement form

·         Access authorization for Tennessee site—NWI Land Mgt.

·         1976 Northwest industries stock split

·         1969 minutes of NWI Board of Directors

·         NYSE company manual copied pages

·         1998 from EPA attorney – need the signed agreement in 5 days!

·         March, 1998 from EPA Project Manager Beth Reiner to Joe Phillips, Mem. Env., requesting access to former plant site

 Box 12 of 40

 Unfiled papers:

·         Survey of plant site

·         Letter about deed restriction

·         Legal description

·         DNR guidance documents for contaminants

·         1992 documents on Fruit of the Loom/Velsicol connection

·         1987 joint agreement for Disposal Well # 2 (Crumbaugh)

·         Letter about Eastman agreement

·         Agreement about tearing down the Sugarbeet company warehouse, drawing of soil removal

·         1981 Contract with Eastman – clay pit

·         Dames and Moore agreement and letters

·         1980 Dames and Moore contract

File 1:

·         Contract and bid specifications for a 1988 Chicago project

·         Legal document 1999 – Accessing plant site

·         Page 1 of 2002 MOA between MDEQ and EPA, attached to 1996 drums being removed from site (non-hazardous)

·         Proposal for transporting groundwater

·         Miss Dig documents

File 2:

·         Hooker Chemical consent decree

·         Draft consent judgment – Velsicol

·         Velsicol Consent Judgment (3 copies)

·         Copies of appendices to Consent Judgment, containing lots of Conestoga –Rovers drawings

·         Compliance Schedule for Consent Judgment

·         Copy of ↑ with 1984 notes on progress/completion

File 3:

·         Contract documents—Conestoga –Rovers

·         Securement of Plant Site Phase II – 1983

·         Securement of Plant Site Phase I – 1983

·         Combined document Sec. of P.S. I & II – 1983

·         Demolition of Plant Site – 1981 (2 copies)

File 4:

·         Contract documents

·         Conestoga-Rovers/Collection & Disposal of Oil-Contaminated Soil and Groundwater – Plant Site, 1983 (3 copies)

·         1983 letter to DNR submitting documents (oil and securement)

·         Work contract forms—Velsicol and Dames and Moore

·         Unbound bid document – Securement of Plant Site

File 5:

·         Copies of Consent Judgment

·         Memphis Environmental Center proposed changes to Consent Judgment draft

·         Analysis by Velsicol of EPA/MDNR proposal, with comments

·         Memo about Mill Street substation contamination

·         1995 letter from Beth Reiner about Velsicol’s proposed changeds to C.J. document

·         Letter from US DOJ to Velsicol about their proposed amendment – needs three- party agreement

·         Velsicol lawyer to Reiner – no comments from you and no copy of EPA amendment

·         1995 draft amendment US District Court, Eastern/Northern

·         1994 Velsicol letter about Reiner writing amendment

·         Copy of amendment

·         Letter from Vesicol lawyer to Memphis Environmental about contacting Atty. General Stuart Freeman about putting plant site water into the Pine River

·         1993 letter from Velsicol to Memphis Environmental about water to river

·         Revised amendment to Consent Judgment

·         1993 – copies of revised amendment ↑ sent to DNR and EPA

·         1994 letter from Reiner about the amendment to CJ.

·         Collection of material from all above topics – copies

File 6:

·         Copy of Consent Judgment with highlights

·         Unbound copy of complete CJ with appendices

·         Copy of final CJ with appendices and chart of submittals

·         Administrative order to allow access – 1999

·         EPA to LePetomane Trust president, Jay Steinberg, letting him know history of site, why Velsicol is not responsible for “unforeseen leaks” and the Trust’s liability. Attached is a copy of the Consent Judgment

·         2 copies of the Consent Judgment

·         Broker agreement, 2005

·         Oct. 2005, MDEQ to David Heidlauf, Environ – hazardous waste rules

·         Broker letter for hazardous waste

·         3 copies of the Administrative Order to access the plant site

File 7:

·         1994 letter about rules for hazardous waste management

·         Copy of amendment to Consent Judgment

·         RCRA Land Disposal restrictions

·         1994 Waste Analysis and Record Keeping for hazardous waste

·         Outline of Velsicol/Memphis Environmental meeting on hazardous waste

·         Federal Register on CERCLA off site transfer

·         1993 memo about MDNR wastewater discharge permit

File 8:

·         1994 letter to Velsicol lawyer about GM lawsuit, Saginaw Band

File 9:

·         Operating and Monitoring Plan for Disposal Well #2

·         DNR putting wastes from Gratiot County Landfill cleanup down Disposal Well #2

·         Drawings for manhole and slurry wall, etc.

·         Peerless Environmental drawings, AKT?

 Box 13 of 40

 File 1:

·         St. Louis Re-Use Committee

·         Morning Sun article on the Breckenridge Site

·         CAG comments on the 2002 Fruit of the Loom bankruptcy settlement

·         Correspondence to David Heidlauf, Environ, about trailer on site with leftover chemicals

·         Minutes from Pine River Superfund Citizen Task Force meeting

·         Collected critiques of 1982 Consent Judgment

·         Chart of Community Involvement at Superfund Sites

·         Papers on installation of drainage pipe – 2000

·         Papers – Spicer Engineering to John Hock, Memphis Environmental

·         Papers – Long and Wetzel operation an maintenance at plant site

·         Contractor insurance policies, 1980, 1981, 1991

·         1999 GIS Services Aerometric

·         CMD drafting

·         NWI Mgt. contracts – water disposal, trying to find containment wall

·         1998 Service agreement GEO Dynamics Services – water hauling.  Aslo 1997 faxes from GEO

·         1992 contract with Eugene Geers (sp.) for mowing, etc.

File 2:

·         1997 letters and court proceedings, Crumbaugh well, Disposal Well #2

·         Oil and gas lien, Crumbaughs

·         Chronology of events leading up to Crumbaugh litigation (1995-1997)

File 3:

·          1998-2000, Crumbaugh litigation against Velsicol, Michigan Court of Appeals. Includes 1996 court decision declaring the 1971 contract between MCC and Crumbaugh null and void

·         Memphis Env. Will explore disposing of plant site waste water through the EPA water treatment set-up (big white tent), or the St. Louis water treatment facility.

·         Numbered document includes copy of 1971 lease

·         1984 letter to Bob and Marcelle Crumbaugh about a structure to be built to control spills

·         Letter from attorney Chuck Fortino—other than phone call with Chuck

·         Velsicol to EPA – nothing has been done by Velsicol about using EPA water treatment facility

·         Velsicol attorney to Memphis Environmental – excellent description about the water situation at the plant site, the EPA and the community talks to reuse the plant site

·         2000 letter from Velsicol, saying it assumes it will lose the appeal in the Crumbaugh litigation. Talks of appeal to Michigan Supreme Court.

File 4:

·         Site Access documents – 1998

File 5:

·         Contracts Tri-Matrix and Weston

File 6:

·         Costs and estimates of Disposal Well #1, Creamery, plant site, Pine River EPA water treatment for waste water from plant site (1992-1999)

·         Plans and proposals (1978-1981

·         1980 Dames and Moore reports

·         EPA list of sites of concern in Gratiot County

·         NRC approval letter for testing for radioactivity and the plant site

·         1980 letter from Velsicol to DNR – downgradient wall not needed

·         Conestoga-Rovers proposal to test the mechanical integrity of Well #2 (Crumbaugh)

·         Activity Plan for Securement of Plant Site – Velsicol’s report

·         Estimated cost to rehabilitate the cap over the plant site

 Box 14 of 40

 File 1:

·         Golf Course/Burn Pit site – groundwater transport notice, 1982

·         Edgewood Hills Golf Course agreements with Velsicol ( copies), 1982

·         Conestoga-Rovers cost estimate and schedule: excavation and disposal of golf course soil, 1981

·         Lanscaping estimated and bills for Golf Cours site, 1983

·         Permit for new farm pond on Eastman property, 1982

·         GC ponded water sample results, 1982

·         Collection/disposal of ponded water, 1982

·         Weather/meteorlogical report, April 1982 for GC/Burn Pit

·         Field report for total suspended particulates, April 6, 1982

·         Velsicol Status Report #4 (weather, excavation, and monitoring) March 18, 1982

·         Weather/Meteorlogical Report, Jan.-Feb, 1982

·         Velsicol proposed water main estimate at Landfill, March 1982

·         Equipment log, Jan.-March, 1982

·         Status Report #3, Feb. 24, 1982, with summary and response to resident complaints

·         Correspondence to residents regarding odor, dust, Feb. 1982

·         Status Report #1, Jan. 22, 1982

·         Groundwater Removal/Transport Control Jan. 12, 1982

·         Corrosivity, Radioactivity, and Ignitability Analysis for GC/ Burn Pit site, soil samples Jan. 4, 1982

·         Cost calculations for removal of sludge leachate holding tank Nov. 9, 1981

·         Geohydraulic investigation correspondence with Conestoga-Rovers Sept. 9, 1981

·         Cost estimates and updates, 9/81-11/82

·         Engineering Services proposal, CRA June 2, 1981

·         Velsicol correspondence with Golf Course owners regarding drilling April 23, 1980 (piezometers/carbon copy of Velsicol purchase order after 10/22/80

·         GC bid estimates and summary, CRA

·         EPA correspondence to Velsicol regarding groundwater monitoring and reporting to MDNR Aug. 6, 1980

·         Dames and Moore proposal and recommendations for Phase II July 25, 1980

·         Sidley and Austin memo to plant management regarding cost of Phase II proposal and how to handle Oct. 6, 1980

·         Dames and Moore revised proposal May 1980

·         Velsicol memos about GC RCRA hazardous waste issue, recommendation, discussion via legal department, plus communication with USEPA and MDNR Nov. 1981 (includes survey of Section 25, T.12N-R.3W, and railroad tracks July 31 1997

·         Velsicol correspondence to EPA regarding heavy spring rain and injecting leachate vs. storing excess water in tanks on plant site, and planned demo (May 1981

File 2:

·         Subfolder #1 -- Equipment and waste leaving the plant after Sept. 1, 1978 – inventory lists, disposal site, contracts, cost; radioactive waste repackaging and employee training (1980); asbestos insulation (piping in PHT-4 building) 1980; cleaning procedure for surplus tanks/vessels 1980; waste shipment clean-up incident report from Arkansas Aug 22, 1979

·         Subfolder #2 -- Phase I plant demo data, air monitoring and dust control, suspended particulate monitoring and control plans 1981.

·         Phase II construction plan, cost estimates March 30, 1981

·         Phase III collection and treatment of site leachate, disposal of rare earths and overages 1980

·         Budget estimates for plant demo with list of structure to remain 12/3/1979

·         Preliminary Design and Concept Cost Estimate for former plant site 1979

·         Change orders 1/1978-3/1980 regarding remedial investigations

·         Original quotes and estimates for plant demo

·         Subfolder #3 -- 1982-1983 plans, cost estimates for oil spill remedial action; plant site (?); Gratiot County Landfill Closure Plan; sugar beet warehouse demo (1981); Eastman farm mortgage debacle (1981); Consumer sub-transmission line relocation (1981); VCC St. Louis Plan Investment Recover (recoup costs with contractor negotiations and equipment (inventory sales) 1981

·         Subfolder #4 – Updated cost analysis plant site construction oil spill, funding analyses, financial commitments (1983); visualization of expenditures for Phases I and II (4/1983); Velsicol Chemical Corporation cash flow; 1982 Conestoga-Rovers Plant site Engineering Budget; Summary of cash commitment 183 with visualizations

·         Subfolder #5 – Plant site lawn care/maintenance receipts 1987-1989; NWI Land Management and CRA rates, receipts 1989; Chemical Waste Management notice of increase in costs with RECR re-authorization 1984-1985; Disposal/treatment/processing/transport fees, costs, programs 1985; confidential cost estimates for plant site 1984 remedial construction; Eastman borrow pit quantities, spreadsheets, liability 1983; Phase I (1983) and Phase II (1984) Engineer Estimate Summaries; AFE Cap and final closure 9/9/1982; CRA Oil Spill Remedial Action Plan 2/2/1983

File 3:

·         Memphis Environmental Accounting Site Detail 12/1996-12/1997

·         Sub-folder #1 – Peerless Environmental Services soil sample results from private residence on North Street to NWI Land Management, 1999; Eco Solutions to Memphis Env. Feasibility Study for waste management options 1997; Eco Solutions to Mem. Env. Re-entry into Disposal Well #1 or drilling new well 1997; BBL consult regarding Pine River sediment/fish study for Memphis to produce white paper for natural recover 9/23/1996; City Preliminary Environmental Investigation of Proposed Electrical Substation 10/1991; AWARE Survey Design for Assessment of Compounds in Pine River and St. Louis Reservoir 8/6/1981

File 4:

·         Correspondence 5/3/1984 Conestoga-Rovers can use county roads with trucks

·         6/27/1984 EPA considers plant site waste water non-hazardous

·         6/?/1984 Morning Sun newspaper article One Million Gallons of Contaminated Water to be Trucked to Detroit

·         4/94 City of St. Louis Remedial Investigation Work Plan for soil and groundwater contamination at the Electric Department

·         3/9/1994 Work estimate by Long and Wetzel Well Services to replace valve on well at Disposal Well #2 (Crumbaugh)

·         9/1993 Draft work plan water level maintenance at plant site

·         4/1993 Same as above, but marked “reviewed by DNR 4-9-93”

·         5/12/1992 Work Estimate by Long and Wetzel for cement test of Disposal Well #2

·         9/1991 Two copies of work plan Replacement of monitoring Wells 1,5, and 12 at plant site

·         6/1990 Final Work Plan Velsicol Vol. I Technical Scope of Work “remedial Planning Activities at Selected Uncontrolled Disposal Sites” EPA contract (good history on Introduction page)

·         No Folder—Loose – Correspondence Operating and Monitoring Well #2 during inactive periods 11/24/1986; Proposal for Post Closure, Plugging and Abandonment of Class 1 Injection Well, 2 copies 11/14/1986; Waste analysis Plan Disposal Well #2 10/17/1986 (has good schematic diagram showing distance of 5 miles to the well; Proposal to exempt groundwater monitoring 10/17/1986; Velsicol Inter Office Memo to have plant site taken off National Priority List 5/30/1986

·         Road Maintenance – CRA to County Road Commission about resurfacing Riverside Drive 6/13/1984; Repairing Riverside Drive (several copies); CRA to Road Commission about hauling 130,000 cubic yards of clay down Riverside Drive 3/13/1984; Hauling 300,000 cubic yards of clay down Riverside Drive 7/24/1983; Repair of River road 10/17/1983

·         Fabrication of gas vents for air sampling 11/1982; Geo-Con Strata Services promotional material on injection wells (2 copies) 5/1982; Collection and Disposal of Oil Contaminated Soil and Water 5/1982; Plans for cleanup, including air monitoring, disposal of scrap metal, hauling clay from Eastman farm 6/1981

·         Waste Analysis Plan for Disposal Well #2 11/1986; Monitoring Well Replacement Work Plan prepared for Memphis Environmental Center for Velsicol Chemical Corporation (3 copies); Same as above, but bound with appendices; White Lake Aquifer sampling (?)

·         Outline of work plans to assess containment system integrity 1/1995

File 5:

·         Survey of metal building next to railroad tracks between Tyrell and Washington, along Pine River, 1999

·         Proposals/quotes for transport/disposal of water, 1998

·         EPA emergency removal action memo 6/11/1998

·         Final Work Plan, Post-Closure Cap Maintenance plant site 12/10/1997

·         MDEQ/EPA correspondence regarding Crumbaugh disposal and cap issues 1997, Memphis Feasibility Study for Well #1

·         Eco Solutions communication to Memphis Env. Regarding surface treating facility at waste disposal well #2 3/6/1997

·         VCC legal memo regarding Well #2 strategy (Crumbaugh) July 1997

·         Marketing Survey regarding Well #2 ( Memphis communication June 1997

·         Project Manual for groundwater treatment systems, Gratiot County Landfill 6/1997

·         Inland Waters Pollution Control, Inc. Statement of Qualifications and Experience

·         Construction schedule for upgrading Disposal Well #2 ( Crumbaugh) Dec. 1996

·         Proposed Water Balance Evaluation to determine integrity of slurry wall Nov. 1996

·         Eco Solutions Response to EPA questions on Disposal Well #2 Oct. 1996

·         Proposals for sedimentation experts to write a white paper showing attenuation of DDT in sediments.

·         Letter from MDEQ about a sampling plan in river sediment with EPA April 17, 1996

·         Plan for trucks to pump into Disposal Well #2

·         Memphis Env. response to questions from MDEQ regarding Disposal Well #2 Nov. 12, 1996

·         Mem. Env. Responses to EPA Region 5 questions Oct. 23, 1996

·         Closure Plan for Disposal Well #2 July 1996

·         Deep well activation; Velsicol Permit Requirements for Operation; Velsicol to DNR and EPA about No Migration Petition Scope of Work Jan. 1995

·         Comments on No Migration Petition plant site; Agenda for meeting on No Migration and Eco Solutions report; handwritten notes on groundwater from Gratiot County Landfill July 22, 1995

·         Two copies Preliminary Evaluation of Artificial Penetrations (deep wells) revise; in house memo about ↑

·         EPA review of Prelim. Eval. Of Art. Pene.; handwritten notes mention Gratiot County Landfill Aug. 30, 1995

·         Eco Solutions Pollution Incidence Preventative Plan Nov. 13, 1995

·         Responses to comments on Monitoring Well Replacement Plan and Containment System Assessment, sent to Beth Reiner (EPA) and Kim Sakowski (DEQ) Dec. 21, 1995

·         Eco Solutions Project Memorandum Disposal Well #2 (lots of documents clipped together) 12/09/1995

File 6:

·         Plant site water table allowances

·         Letter regarding pollutants and possible discharges; questions on treatment prior to river release Nov. 2, 1993

File 7:

·         Illegal removal of scrap

·         Details as of May 1981 on plant demolition

·         Brine well purchase by Michigan Chloride Sales from Michigan Chemical (Wells 10 and 11)

·         Soil sampling (Creamery)

·         Velsicol exit responsibilities

·         July 15, 1980 letter on Edgewood Farms (potential contamination and Velsicol’s lack of responsibility)

·         Plant Manager Chuck Touzeau’s letter on Burn Pit/Edgewood history

·         Communications and correspondence on Gratiot County Landfill; cleanup costs and sampling; Edgewood golf course; fish kill (1980) and possible recontamination

·         Crorespondence on Bentonite containment wall; bentonite testing for slurry wall; Grant Colthorp letter and hiring application; Post Construction Maintenance and Monitoring Plan

·         Total Petroleum/pipeline easement

·         Revisions to Technical Appendix

·         Maps: Upgradient Containment Wall and storm sewer

            Downgradient Containment Wall

            Site groundwater elevation control

            Particulate monitoring stations

            Location of equipment decontamination station

            Plant site disposal area

            Clay cap

            Pipeline eastment (railroad)

            Containment wall durability testing (upgradient slurry wall)

Folder 8:

·         CEC proposal

·         Clay cap failure information

·Box 15 of 40

File 1:

·         Gratiot County Landfill – Letter to Velsicol – “your company may be a responsible party” March 15, 1982

·         Response ↑ from Velsicol to “Superfund Task Force” no admission as to facts or guilt April 7, 1982

·         Memo about V. meeting with DNR/EPA. V. wants to help design a remedy for Gratiot County Landfill March 13, 1982

·         Conestoga-Rovers (CRA) discussions with MDNR about oil spill – a matter between Total Refinery and Velsicol Feb. 25, 1983

·         EPA Notification of Hazardous Waste Site – Edgewood Farms golf course – includes descriptions of wastes 1981

·         Creamery Warehouse – CRA to EPA – excavate soil in 50-foot sided squares in CW2 and CW5.  Some areas 1 foot deep, some 3 feet, some 4 feet.  Soil to go to plant site July 31, 1981

·         CRA to Memphis Environmental Ctr. – disagrees with MDEQ that the wall is leaking – rather, it is leaking only out the bottom Aug. 29, 1997

·         EPA to V. – have reviewed Post Closure Plan for plant site – corrections in wording Feb. 20, 1985

·         EPA to V. Post Closure Plan – additions and changes Nov. 26, 1984

·         Packet of letters – Velsicol cannot leave the site until they have a maintenance plan in place 1982-1984

·         CRA sends MDNR copies of permit, waste analysis plan etc. for Disposal Well #2 (Crumbaugh) Nov. 24, 1986

·         Folder, MDNR:  1982-1983 correspondence on Disposal Well #2; containment wall; gas vent monitoring; Post Closure Plan; annulus tests; demobilization; radioactivity;

transferring liquids by truck; oil spill; maintenance plan; notification to V. from DNR about non-compliance in submitting reports; and an Aug. 1983 letter from EPA to V. complimenting them on the final cleanup

·         Folder: 1981-1982 gas vent info; storm sewer construction; power poles to wells on State Rd. and Wells Rd.; air monitoring during demolition; railcars of scrap metal to Ohio; analysis of scrap metal for PBB, TRIS, HBB, DDT; creamery warehouse excavation; asbestos disposal; V. letter to Uranium Licensing, NRC

·         Folder:  1980-1981 NRC survey (Velsicol did not have a license for 20 barrels of uranium and thorium; also, radiation levels so high in storage building, a person in there continuously for 7 days would receive a dose exceeding 100 millirems); liquid outfall samples from Bush Creek (levels 10 times higher than background); elevated levels at plant site and Mill Street bridge; Letter from V. describing wastes at Landfill, Smith Farm site, etc.; DNR against disposal of Golf Course Leachate in Disposal Well #2, then approved it thru Nov. 1, 1980; 300,000 lbs. of radioactive waste; list of sites in county of suspected radiation contamination

·         Folder:  1980-1995 Correspondence between St. Louis and EPA; 1980 conceptual plan; 1995 letter from EPA to V. lawyers transporting 1.5 million gallons of groundwater; 1995 proposed amendments to Consent Judgment

·         Folder: 1980 EPA Region V to St. Louis; detailed requirements to V from EPA March 25, 1980; detailed notes on meeting of Velsicol, EPA, DNR March 11, 1980; Plugging of Dundee and Sylvania brine wells in Gratiot and Midland counties; unknown rare earth samples analyzed; V to EPA -- groundwater samples taken improperly; about the conceptual plan

·         Folder: 1979-1980 About disposing of Golf Course leachate to Disposal Well #2; Toxic Substances Control Committee to tour plant site, along with senators Richard Allen and Gary Randall; long letter V to EPA about contamination at each site; extension of use of Disp. Well #2; EPA response to V –Conceptual Environmental Security Plan; DNR to V about citizen complaint – removing drums of rare earth; water wells on V. property drilled in 1956, now capped; about Hazardous Waste Mgt. Act, Michigan; strong 1979 DNR letter to V. about contaminated groundwater; 1979 letter from DNR about deficiencies in V. report; 1979 detailed letter from plant manager Chuck Touzeau to DNR –sites and known contaminants

·         Folder: 1980-1981 EPA list of known information on Velsicol sites; safety inspection NCR; EPA hazardous waste site -- Gr. Co. Landfill;  to get letter of credit – Memphis Env.; Legal description (?); Drawing of location of Disposal Wells 1 & 2; Agendas for discussing sites (1997, or 8 or 9?); Hazardous Materials information

File 2:

·         Folder: 1982 Edgewood Hills – water in Holes 2 & 6 (from Burn Pit); 1989 letter Edgewood regarding stock

·         Folder:  Ed Dangler (owner) to Memphis Env. Regarding lost certificate for 7,000 shares issued; 1996, Memphis Env. Agrees to sell 7,000 shares contingent upon Edgewood releasing NWI from any and all environmental liability at the golf course; MDEQ plans to resample river sediments

·         Folder: CRA – road maintenance—muddy roads; CRA disposal of golf course waste into dredge pond on plant site; CRA – time studies of tarping and untarping trucks; haul routes; water main under golf course; dust and odor control notices taped to residents’ doors

·         Folder:  Dames and Moore Correspondence, 1981, golf course and radiation

·         Folder: 1980-1981 Deep well disposal of golf course wastes; liquid hauling license needed; renew permit; deep well correspondence and truck permit; lots of golf course correspondence

File #3:

·         1994 – State health department to MDNR, city wells not contaminated; MDNR to St. Louis, Mill Street substation remedial investigative work plan; DNR to V.—appeal to conduct remedial study (V. said it is not responsible for contamination at substation); Packet of material on Mill St. substation; 1993 DNR letter to City – work plan not approved

·         1998 – Access to plant site question – attached to 1996 Vel. Comments/response to 1996 MDEQ staff report on St. Louis Impoundment; Letter to CAG (Pine River Superfund Citizen Task Force) from Rep. Dave Camp about dredging; lots of correspondence on access to plant site

·         1999 – Access to plant site; information on Chippewa Tribe treaties and reservations; letter from Gary Smith, CAG member, to Mem. Env. Requesting site maps and information; Joe Phillips (NWI) memo about CAG meeting after talking with Kim Sakowski (MDEQ); EPA request for Time-Critical Removal Action

·         1999 – Access order for removal action; EPA invitation to consensus building session; Velsicol president Chuck Hanson intends to call chief of Chippewa Tribe (Tribe’s Treaty of Saginaw to be discussed); V. lawyer letter to V. from Tribe – natural resource damages; Memo mentioning Murray Borrello (CAG member) student river study; V. memo on EPA response team; access correspondence (V. doesn’t want dredging); EPA newsletter; Complaint document Crumbaugh v. Velsicol; correspondence to V. from lawyers about RIFS (Remedial Investigation and Feasibility Study)

·         1996 – Lawyer to Mem. Env on deep well, sampling of Pine River, well replacement program, containment system, water levels, going to court to modify Consent Judgment; Concerns about PBB adsorption at Gratiot County Landfill; 1981 Velsicol debating to address sediments in river or not

File #4

·         CRA to EPA – list of all reports and drawing sent to MDNR Apr. 1983

·         V. to NRC – letter about soil samples from Creamery warehouse 1981

·         CRA to Mem. Env. About post construction monitoring

·         Drawings of Creamery excavation, asbestos disposal area on plant site and radioactive burial on plant site 1981

·         1980-1990 – Correspondence, large packet, includes Final Work Plan (June 1990) prepared for EPA by Weston; permeability testing of clay till by Dames and Moore; 1980 Dames and Moore computer modeling of groundwater at plant site; NRC asking V. for wording on monument (tombstone) 1982 and 1983; Radiation correspondence; oil spill correspondence 1987; Storm sewer for Watson St and part of plant site 1982; NRC tells V. the monument must state that the site contains radioactive material; about deep well and RCRA permit

·         1983-1991 – Gratiot Co. Landfill soil boring maps; 1981 Elia contractors to Wreckers, Inc – their equipment buried; 1981 Michigan Chloride Sales – telephone poles; 1981 agreement to demolish Sugar beet warehouse; 1981 5 rail cars of scrap metal are ready to go to Ohio; 1981 Shunk’s worker’s claim against Velsicol denied; 1981 Air Sampling Protocol; 1981 State of Michigan v. NWI, Velsicol about PBB $50,000,000; 1981 no more monitoring for PBB; 1981 demolition of Sugar beet warehouse plan; 1981 Should we demolish Sugar Beet Factory?; 1981 asbestos waste disposal site drawing; 1981 two rail cars of scrap metal to Ohio; 1981 packet of corres. About purchased equipment, likely buried on site; 1981 letter and report on “wipe tests” for Consumers Power; 1991 handwritten notes, deep well; 1994 shipping water to City Environmental; 1994 disposal of water; 1994 V. lawyer to Mem. Env., disposal of water and UIC Permit chart; 1992 CRA letter about St. Louis plant site; 1992 Smith Farm site correspondence; 1993 Work Plan –water level maintenance – checked for radioactivity; 1993 Edgewood Farms financial statement; 1993 V. Supplemental Funding Request – deep well? 1993 Site Review and Update—State health department

·         1986-1990  GTE; Laethem; Grant Colthorp’s letter requesting reimbursement for maintaining portion of Velsicol property 1989; lease payment on Disposal Well #2, 1988; lab report on air sample 1988; Question for George Harvell 1987; Statutory restrictions on deep injection well 1987; UIC permit for deep well 1986; Several documents on deep well 1986; Eastman lawsuit against Velsicol 1987

File #5

·         1995 – Monitoring Wells and Containment System work plan; Velsicol’s proposed Consent Judgment amendment; outline – containment integrity and deep well

·         1994 – New Federal Rules on Hazardous Waste; U.S. and Michgan v Velsicol (amendment to Consent Judgment); Mill street substation (will they excavate? Contain in place?)

·         1987-1997  Memphis Environmental correspondence

·         1996 – Information documents on injection wells

·         1997 – MDEQ internal review of containment system; testing Disposal Well #2; Eco Solutions plan for Disp. Well #2; Containment system assessment; water to be transported to Romulus from plant site; water level exceedance; letter to Mich. atty general Stewart Freeman; Disposal well; Monitoring well replacement; monitoring well abandonment; FOIA request from Sidney and Austin lawyer to EPA

·         1998 – water level maintenance letter; access agreement letter

·         1999 – DEQ report on final containment assessment report; water re-development grant program; injection well requirements; Crumbaugh vs. Velsicol documents; water shipped to Romulus; deep water well can go to Disposal Well #2; water level maint.; Access to site by EPA; Request for Time-Critical Removal Action (impoundment); water level pumping

·         1993 – water level maintenance; Mill St. substation; site inspection report (5 year); City lawyers to MDNR (detailed, a 307 site); oil spill; Disposal well #2

·         1991 – requirements for hazardous waste disposal

·         1987 – No injection activity reports; gas vent sampling reports; remove plant site from NPL; vinyl chloride in gas vent sampling; City asks Vel. To reimburse for landscaping

File # 6

·         1997 – replacement of monitoring wells

File #7

·         1998 – groundwater level maintenance; water disposal; Crumbaugh judge decision; transporting of water; lots of Crumbaugh litigation documents

·         2005 – Summary of documents related to St. Louis Site, sent to AIG from Environ; documents from 1995-1997 about plant site and Crumbaugh Disposal Well #2; about Edgewood Hills golf course stock; St. Louis Electric Mill St. substation

·         2000 – Disposal well #2; abandon and plug well #2; Crumbaugh litigation (throughout file); Golf Course site; low-level radioactive site – Disposal Well #1, clay tile; Total Refinery does not want waste water; water level exceedences; Grant Colthorp property; Eastman 1997 letter saying he owns the land

·         1997 – Spicer Engineering tells St. Louis to not accept Velsicol water in their sewage treatment facility

·         1999 – Joe Phillips to John Hock (NWI) about Michigan Chemical site; Chuck Hanson to NWI PRP Groups for Smith Farm site

·         1996 – Edgewood Farms to Memphis Env. Crumbaugh litigation

·         1999 – NWI assumed responsibility for former plant site; letter from CAG; Bush Creek drain (radioactive site)

·         1998 --  High direct contact levels at residence (DDT, DDE, DDD); terminate Crumbaugh litigation?; Velsicol concern about Chippewa Tribe litigation; packet of Joe Phillips writing what Kim Sakowski told him about CAG meeting; Philips to Mem. Env (talk about CAG and river)

File #8

·         2005 – Letter from MDEQ to Environ and list of reports on Velsicol site

·         1994-2004 – Group of letter MDEQ to several with Phase 3 RI document; Group of letters on sites, including CAG letter offering to be the citizen group for Total Refinery cleanup; revoking of Velsicol NPDES permit

·         2001 – Pine River Sediment Survey (upstream from Velsicol); To John Hock, member of Mineral Well Board from MDEQ; notice the John Hock will be the contact person for NWI; Epa comments on MDEQ work plan (slurry wall investigation) Letter from City refusing to take water from Velsicol sites into their sewage treatment facility

·         2000 – Creamery building (on North and Mill) to be torn down – October; NWI application for disposal of water in St. Louis treatment facility

Box 16 of 40

File #1

·         Rail routes and roadways in the transport of radioactive materials from the Creamery (Washington Street/M-46); building and soil samples

·         Radiation conclusions and recommendations

·         Building maps and contamination results

·         Sampling reports

·         Creamery and PBB detection

·         Letter on compliance for possible contamination spread areas A, B-1, and B-2

·         Details on removal of buildings and exit strategies for contaminated vs. non-contaminated areas of the plant site (May 7, 1981)

·         Creamery and radioactive levels ( Fall, 1980); soil sampling for PBB and DDT

·         Survey of H.L. Holcomb addition, Parcels 12, 13, 14

·         Inter-office correspondence on PBB levels in buildings; river samples; fish toxicology report, 1979, DDT in St. Louis soil samples; river water various site testing, golf course lab report; impoundment of tuck and hauling of liquid industrial waste

·         Radiation levels (1980) – St. Louis Test Data file

·         Letter from Pat Lincoln on PBB in river levels (1980); list of chemicals produce at Michigan Chemical Corporation

·         Survey for property line points

·         June 5, 1980 NEIC site sampling

·         Demolition of Sugar beet warehouse, scrap metal to Gratiot Iron an Metal; golf course remediation; Gratiot County Landfill

File #2

·         Packet of information and photos of 1996 sediment sampling

·         Chart of polybrominated biphenyl discharge (1974-1977) at different outlets; chart of PBB samples at various locations

·         Review of Information Concerning the Contamination of Sediments in the Pine River, prepared by Associated Water and Air Resources Engineers (AWARE) (hired by Velsicol), and principally looking at PBB; gives chemical make-up of FireMaster BP6 and FireMaster FF-1 1980

·         1975 copy of letter from V. to Water Resources Commission about sediment study, and that natural attenuation is best; Biological Survey of the Pine River 1974-1978 (DNR report)

·         Copy of Bio Survey ↑ ; National Sediment Quality Survey – report to Congress, submitted to Chemical Manufacturer’s Association; National Sediment Contaminant Point Source Inventory (submitted to Chem. Manu. Asso.); drawings of contamination in sediment DDT, HBB, PBB; 1981 letter to EPA from V. about Golf Course site, and Conceptual Environmental Security Plan St Louis Plant Site;  1980 report Clarification of Env. Securement Plan (Dames and Moore); copy of NPL list St. Louis Plant

·         Jan. 1992 – Environmental investigation of Mill St. substation (chemical smell, losts of chemicals in soil borings, lots of VOCs, pesticides) (Study by Prein and Newhof);1994 letter from P & N to MDNR

·         June 1993 – Tables – draft Technical Assistance Investigation Report for Velsicol Chemical Corp. Site

·         1994 – Special radioactivity inspection conducted of former Michigan Chemical Corp. site (examination of records, observations, independent measurements, and interviews with personnel (says capping the site is good enough)

·         Oct. 1980 – Pine River Contamination Survey (June 2-6, 1980) (finds that samples indicate remedial action needed.  Recommendation to Velsicol: propose alternative method

·         1979 – Copy of Bio. Survey of Pine River 1974-1978, DNR

·         1982 – summary of Pine River Reservoir sediment Sampling Survey, EPA Enforcement Counsel

·         1992 – DNR report – Bio. Survey of Pine River and Honeyoye Creek (no evidence of nuisance plant growth ***pre-CAFO***)

·         1984 -- pumping log

·         1980 – Pine River Sediment sampling data

·         May 22, 1996 – Sediment sampling data Pine River and St. Louis Reservoir

File #3:

·         Gratiot County Landfill – Feasibility Study of Control Measures for the Containment of PBB and Other Contaminants; existing landfill leachate conditions; recommendations, summary and corrective measures

·         Fish toxicities, 1979

·         Vinyl chloride in Air Analysis

·         Disposal wells

·         Golf course site – DNR letter for potential disputes with Velsicol

·         Gratiot County Landfill – 3 booklets on hydrogeological investigation

File #4

·         Feb. 17, 1982 – minutes from Conestoga-Rovers Safety meeting

·         Feb. 16, 1982 – minutes from CRA Site meeting

·         Feb. 3, 1982 – minutes from On-Site Co-ordination meeting with Michigan DNR

·         Jan. 20, 1982 – agenda for CRA Scheduling meeting

·         Jan. 18, 1982 – minutes of Health and Safety Contingency Planning Securement of Waste Burning Disposal Area

·         Jan. 31, 1992 – Consent Decree documentation from Wyandotte, Michigan

File #5

·         Aug. 27, 2002 – Trust Scope of Services to hire Environmental Consultant; handwritten list of chemical processes in each building o the plant site

·         July  – Handwritten notes on meeting between DNR and Dames and Moore contractors;

Handwritten notes attached to Memphis Env. stationery

·         March, 1994 Memos – are they responsible for radioactivity in river sediment?; 1982 about the granite marker; NRC letter to V. about including radiation warning on tombstone

·         Outline: St. Louis Meeting; 1981 EPA letter said no monitoring needed of downgradient wall; VCC will not accept inclusion of Pine River in Consent Judgment; St. Louis Plant issues, agenda

·         Feb. 23, 1998 – Attorney Work Project Prepared in Anticipation of Litigation (VCC wants to form its own citizen group

·         1997 – List of “problems” with St. Louis site, including government attitude and tactics

·         1997 – Drainage Board meeting – Bush Creek Drain

·         1997 – Fruit of the Loom minutes, St. Louis mentioned

·         1997 – Valuation of Impaired/Contaminated Property; Eco Solutions memos; No Migration petition meeting agenda; handwritten notes (what is going into the well?)

·         Agenda St. Louis Michigan site; handwritten notes from meeting 1995

·         Handwritten notes – Containment System Assessment 1995

·         May & June 1995 – Handwritten notes

·         March 1995 – Letter from DNR to Mem. Env. Attached to handwritten notes, June 1995

·         June 1994 – Handwritten notes Mem. Env. Ctr.

·         April 1994 – Mem. Env. Memo to V. regarding Golf course, Breckenridge Disposal well, marsh area south of St. Louis (Smith Farm site)

·         1993 – Handwritten notes UIC permit for Disposal well

·         1991 – Handwritten notes Smith Farm site

·         1991 – Handwritten notes deep well re-application

·         1987 – EPA letter UIC deep well

·         1986 – sampling of school indicates PBB, DDT – health dept. informed (handwritten)

·         1986 – Handwritten notes – deep well

·         1983 – CRA minutes Slurry Wall Informational Meeting

·         1982 – Gratiot County Landfill meeting in Lansing

·         1981 – Memo about radioactivity at plant site

·         1980 – typed notes from meeting with DNR and EPA/Velsicol

·         1979 – Dames and Moore to V. about work assignments

·         1979 – Detailed notes about Vel/DNR meeting

·         1983 – Notes from CRA Progress meeting

File #6

·         Letters on pCBSA

·         Correspondence with NWI on costs and liability current and future

·         Letter on land re-ue

·         Handwritten meeting notes May 19, 2004

·         1982 critiques on containment, quotes from various newspapers and magazine, criticizing EPA

·         Bankruptcy court and Oxford Automotive

·         Velsicol Superfund expenditures

·         Correspondence relating to “waste generator”

·         Meeting notes July 21, 2004 and April 21, 2004

·         Letter requesting health assessment

·         Comments from consultant, Fred Brown, from FLB services

·         Letter regarding Inactive Waste Disposal pipeline

·         Upgradient containment wall

·         Chemical analysis of soil samples

·         Drilling and Lab services

·         Upgradient Containment Wall reports

File #7

·         DNR approval letter on storm sewer

·         Approval of plans and specifications

·         Securement of Plant Site plan

·         Progress meeting 3/21/1983

·         Plant Site Securement contract

·         Post Closure Maintenance and Monitoring plan

File #8

·         2001 correspondence with St. Louis

·         Jan. 2002 MEDQ Final Work Plan Evaluation of Slurry Wall

·         Feb. 2001 Draft work plan ↑

·         1993 St. Louis comments on Velsicol NPL score (city wants more done and higher score

·         2000 Chad Doyle to John Hock/Memphis Env./NWI requesting soil analysis along M-46 area

·         Superfund guidelines

·         Handouts from trip to Wyandotte superfund site

·         City intends to apply for redevelopment grant; letter from NWI

·         Application for EPA Superfund Redevelopment pilot grant

·         Deep injection well information

·         Questions from NWI for documents (to CRA?)

Box 17 of 40

File #1:

·         Suspended particulates (high volume sampler) 1983 and 1984

File #2:

·         Cecil Allen and the People vs Vesicol Chemical 1980, 1981,1982

Ø  Contents hauled from Golf Course/Burn Pit didn’t match what Velsicol said

Ø  Remedy for Golf Course to clean and correct leaching

·         Breckenridge Site Phase I Study – radioactive wastes 1980

·         Comprehensive radioactivity Survey Plan 1980

·         Golf Course soil samples 6/1980

·         Golf Course leachate results 2/1981

·         Golf Course 1975 map (shows elevations, water bodies and wells)

·         Golf Course 1981 map

·         Eastman pit, 1981 letter from Golf Course about 60,000 cy dirt and high water

·         Plant site soil testing negotiation/sampling

·         Sub drain construction Burn Pit 1984

·         Kalkaska animal burial 1978

·         Comprehensive Radiological Survey, plant site, Dec. 1982

File #3

·         Ambient air monitoring 1983

·         Contract documents and specifications 1983

·         Post Construction quarterly monitoring report  plant site 12/1984

·         Additional gas vent monitoring post closure plant site 1985

File #4

·         Northern Ordinance Plant

·         Permeability and durability testing plant site 1983

·         Well construction, contract agreement for Disposal Well #2

Ø  Status report 2/1982

·         Eastman borrow pit stuff

·         Density and permeability study (samples from borrow pit) 1983

·         Radial Corp, filters, suspended particulates 1983

·         Letter about interring empty bags on site (wall) June 1983

·         Bentonite wall construction, testing

·         Summary reports Jan. 1983-March 1984

·         Vinyl Chloride

·         Slurry wall collapse and reconstruct letter 1983

File #5:

·         CRA Project #1113 Oil spill investigation

·         Presearch Inc., 1982, oil spill, pipes on east railroad, plant site

·         Gratiot County Landfill water samples, wells

·         Document labeled wrong – it is for Marshall Illinois, not here (Clark Co.)

·         Gratiot Co. Landfill hazard ranking system

·         Upgradient containment wall, soil sample analysis 1982

·         Groundwater sampling and analysis, Gr. Co. Landfill 1982

·         Radiation Screening Survey, plant site, final 1982

·         Groundwater sampling and analysis, Gr. Co. Landfill, final 1982

File #6:

·         Alma Iron and Metal Co. sampling results 1982

·         Golf Course air monitoring results 1981-1982

·         Velsicol equipment sale to Commercial Metals Corp, chemical results 1981

·         St. Louis Plant status report 1981

·         Particulate and meteorological sampling Nov. 1981 plant site

·         Estimated costs for monitoring Aug. 1981

·         Various air monitoring, water samples

·         Chemical analysis upgradient wall 1982

·         Groundwater analysis Gratiot County Landfill 1982

·         St. Louis Status Report Feb. 1982

·         Supplemental Radiation Surveys, plant site 1981

·         Radiological stuff for plant site

File #7:

·         Contract documents, demo of plant site 1981

·         Contract documents and specifications, storm sewer 1982

·         Permeability and durability testing, soil/wall, plant site 1983

·         Upgradient containment wall chemical analysis 1982

·         Sampling program downgradient wall plant site 1982

·         Exploratory subsurface investigation plant site 1982

·         Demolition of Sugar Beet Warehouse 10/1981

·         Comprehensive radiological survey plant site, installing cap, creamery survey 1981

·         Procedure for building decontamination and installation of working cap

·         NRC safety inspection of site, plant site 9/1981

·         Activity plan, plant site

Box 18 of 40

File #’s 1-5

·         High volume charts 1983

Box 19 of 40

File #1:

·         Lab reports – air monitoring, gas vents, permeability of clay, weekly inspections, borrow pit 1983-1985

File #’s 2-5:

·         High volume charts 1983-1985

Box 20 of 40

File #1:

·         Water depth and pressure readings – Disposal Well #2

File #2:

·         Radioactive water results slurry wall and dump area

·         Nuclear reporting

·         Pesticide results

·         Slug test data – well GWM-1

·         EPA list of 16 sites of concern, Aug. 10, 1994

Ø  Plant site

Ø  Golf course

Ø  Gratiot County Landfill

Ø  Madison Road (Breckenridge)

Ø  Smith site

Ø  Bethany township

Ø  St. Louis Landfill

Ø  Breckenridge dumps (2)

Ø  Hartley and Hartley

Ø  Culligan site

Ø  3 sites of 5-8 acres where Velsicol has brine source wells

Ø  1 site (40 acres) where 2nd brine disposal well is located

Ø  1 site in Jasper Twp. Dump where owner/operator took anything

File #3:

·         Lab reports

Ø  1993 pesticide/herbicide/PCB reports

Ø  Radioactive risks in drinking water

Ø  Risk associated with discharge water in sewer

Ø  Deep well inspections

Ø  Mill St. substation results (location sample results)

File #4:

·         Mill St. substation contamination (letter dated May 4, 1992)

·         Attorneys Scholten and Fant – city’s liability for contamination

·         Lab reports

·         Substation maps – contaminant and concentration, levels/site scoring sheet

·         City of St. Louis Electric Dept. – results on environmental contamination

·         Grant pre-application summary

·         Letter from DNR informing Velsicol they are a potentially responsible party for contamination (Smith Farm site?}

·         Diesel spill letter April 6, 1992 and March 9, 1993

·         Correspondence between Fruit of the Loom and EPA regarding financial responsibilities on Disposal Well #2

·         Multiple lab reports

File #5

·         Slurry wall sampling (Nov. 18, 1986

·         Disposal Well #2 correspondence and testing

·         Gas vent and air sampling reports

·         Quit claim deed from Velsicol to NWI ($10.00) done Oct. 22, 1986

·         1989 Gratiot County Landfill groundwater sampling results

·         1989 Smith Farm site soil samples

·         1989 groundwater well elevations

·         Underground Injection Control Permit: Class 1 Hazardous and compliance instructions

·         Plant site letter “repair of slopes”

·         Disposal Well Repair report

·         Plant site summary

Box 21 of 40

File #1:

·         Gratiot County Landfill lab reports

·         Climatological data report (1994)

·         Gratiot County Landfill data

·         Water sample analysis and summaries

·         Analysis date sheets: Pesticide/PCB/PBB

·         PBB results

·         Water Level (Manhole sampling)

·         Correspondence on water level maintenance

·         Fish contaminant monitoring

·         Various analyses reports: PBB, metals and alkalinity; volatile organics

File #2:

·         Injection Well #2

·         Handwritten notes: containment system evaluation

·         Manholes -- invert elevation readings

·         Lab Analyses: Former Plant Site and Gratiot Co. Landfill

·         Toxicological Profile for Mirex and Chlordecone

·         Monitoring Well Replacement Work Plan

·         Correspondence on Disposal Well #2

·         Various tables on VOCs

·         Lab results on VOCs, BNA, Cyanide, Pesticides, metals, mercury

File #3:

·         Lab reports

·         Letter on transporting groundwater

·         Radioactive tracer surveys

·         Expense sheets

·         Radiological Scoping Survey

·         Surveyor information

·         Lithologic logs

·         Disposal Well #2

File #4:

·         Radiological surveys and sample collections

·         Breckenridge disposal site, Michigan Chemical Plant, Creamery

·         1997 groundwater analytical data

·         Gratiot County Landfill

·         Hugh Eastman correspondence (1997

·         Package detailing perimeter insulation

·         Water sample summary

File #5:

·         Well water sampling results/pesticides

·         Soil sampling

·         Professional Service Fee proposal

·         Sampling Program information

·         Water Level Maintenance sampling results

·         Chronology of Crumbaugh lawsuit

·         Velsicol/ potential discharge (City of St. Louis)

·         Cap leakage

·         Inspection report/Injection Well #2

·         Post Closure Monitoring Program

·         Inspection of Disposal Well #2

·         Emergency Response cleanup

·         Bush Creek drain

·         Information from Memphis Environmental on wells

·         Funding (draft) for plant site

File #6

·         1998-1999 Turbidity monitoring

·         1998 State health department opinion on DDT in residential soils

·         1998 Packet of letters to residents about DDT levels in their yards

·         1999 Peerless report on soil sampling residential yards

·         Folder with contents about ↑

·         Quantera SOP Gas Chromagraph

·         1998 Tribal Fishing report

·         1998 Draft Feasibility Study for OU-2 (impoundment cleanup)

Box 22 of 40

File #1:

·         Four dial graph data recordings

·         Hydrogeologic Investigation Gratiot County Landfill and drawings

·         Pile of drawings – CRA for plant site

Ø  Groundwater monitoring graphs

Ø  Proposed financial

Ø  Storm drain along M-46

·         1980 Parameters used in groundwater flow modeling – Dames and Moore – includes drawings

·         1998 Drawings of coffer dam in river

·         1981 Field data reports – Dames and Moore

·         1987 Drawing of flower beds along M-46

File #2:

·         1991-1997 Water Level Maintenance sampling results

·         1998 Groundwater Level Maintenance

·         Well water reports – Coe Township

File#3:

·         Cap sampling data

File #4:

·         Analytical data, including Smith Farm site

File #5:

·         1993 Groundwater sampling data – Velsicol

·         1992 data

·         Residential wells data (Riverside and Union)

·         Smith Farm site data

File#6:

·         Smith Farm Site soil sample data

Box 23 of 40

File #1:

·         Oil spill area investigation (southeast side of plant site) May 1982

·         Investigation of potential contamination plant site Apr. 1 1979

·         EPA investigation for hazardous waste contamination plant site Oct. 1980 (lists everything made by Velsicol)

File #2:

·         Fox River Wisconsin stuff

·         VCC Pine River Impoundment focused investigation/FS June 1998

·         Ecology and Environmental, Inc. report for USEPA (on the river/impoundment)

·         Sediment contamination samplings and results from 1981-1997 (document dated 1998 – includes fish sample results)

·         Post-dredging sediment sampling of Manistique Harbor 1998

·         Innovative sediment remediation experiences at Manistique Harbor 1998

·         Draft VCC Pine River/St. Louis Impoundment Focused RI/FS 1998 (2 copies)

·         Draft Feasibility Study report of Pine River July 1998 (also food pathway by ingesting fish)

·         ROD (Record of Decision) for OU-2 (impoundment)

·         The Effects of Alma St. Louis Metropolitan Area on Benthic Organisms of the Pine River by John Giesy Jr/ Alma College 1970

File #3:

·         Hexabromobenzene process information (includes PIDs)

·         Mill St. substation analytical matrix

·         Water Level Elevations – St. Louis plant

·         VCC Injection Well Control Program (UIC permit MI-057-1w-0001) Sept. 1986 (Goes to Disposal Well #2

·         Deep well analysis report

·         Soil sampling survey results Burn Pit, Former Plant Site and Gratiot County Landfill

·         GWM-1-14 depth and time

·         Handwritten estimates of cost plant site

·         Mineral well (brine) information (injection, tests, samples) 1985

·         Summaries written by Velsicol about their success in cleanup activity

·         TRIS information (ALL YOU EVER WANTED TO KNOW)

·         Velsicol written description of how well they are doing environmentally on cleanup back when

·         Groundwater monitoring and well slug tests

·         St. Louis soil sampling final report

File #4:

·         Log books with water monitoring measurement and pictures of post demo plant site

File #5:

·         Investigation of potential contamination by Dames and Moore 1979

·         Wastewater report forms and instructions

·         EPA Public Notice Register – sending waste to Disposal Well #2 Sept. 1986

·         Final Status Report, closing and winterization of St. Louis plant for 1980

·         Plant site update on 7/3/1980 – report by Velsicol

·         Plant site closing – inter-office correspondence June 17, 1980

·         Inspection and initial evaluation of Alma sewage treatment plant 1979

·         Summary of surface soil chemical analysis Feb. 1999

·         Hexbromobenzene lab results

·         Studies of disposal of effluent bring from magnesium hydroxide settler Oct. 1966

File #6:

·         Weekly observation logs (John Hock,) 2002

·         Memphis Env. – letter about maintenance of clapy cap to MDEQ (Sakowski)

File #7:

·         Final Technical Assistance Investigation Report Oct. 1993

·         Appendix ↑ A→I 1992

·         Remedial Planning Activities at Selected Uncontrolled Disposal Sites 1992

Box 24 of 40

File #1:

·         Summary of Investigation

Ø  Radiation survey

Ø  Field Procedures

Ø  Mutagenicity Study

Ø  Chemistry Methods

Ø  Chemistry Quality Control

Ø  Toxic Data Compilation Methods

·         Phase I Report Hydrogeologic Evaluation of Inactive Industrial Waste Burning Site (Burn Pit)

·         Chronology of events involving NRC and Michigan Chemical Corporation

·         Various correspondence regarding cleanup

·         Demolition of sugar beet warehouse

File #2:

·         Gratiot County Landfill containment of PBB etc.

·         Re-melt of scrap structural steel 1981 from plant site

·         Demolition of sugar beet warehouse

·         Hugh Eastman topsoil stripping and map

·         Report on deep boring

·         Procedure for building decontamination and installation of working cap booklet

·         Radiation screening surveys

File #3:

·         Velsicol Plant Site and Inactive Burning Area, preliminary draft

File #4:

·         Radiation surveys 1981

·         Maps

·         Soil sample tables

·         Physical Plant survey

·         Health Physics Controls

·         Various open grid soil surveys

·         Petroleum-based soil samplings (booklet, 1982)

·         Radioactive pant site survey

File #5:

·         Letter on replacing City’s water system

·         City of St. Louis vs. Velsicol (regarding water) 2 copies

·         Scott Cornelius letter on ground contamination

·         Gratiot County Golf Course (NPL)

·         Velsicol Superfund Site pCBSA trend evaluation

·         More in pCBSA

·         Re-use planning report

·         pCBSA in drinking water

·         Much groundwater correspondence/drinking water

·         Morning Sun and Midland Daily News articles on contamination

·         DEQ article

·         Human Health Risk Assessment

·         Soil lab results

·         Plant site chronology

File #6:

·         Securement of Waste Burning and Disposal Area – Golf course

File #7:

·         Containment Wall construction

·         Permeability and Durability testing of soil

·         Health and safety

·         Chemical analysis

File #8:

·         Sampling and physical testing

·         Clay soil for capping material

·         Plant closure and monitoring plan

·         Water level maintenance work plan

·         Air monitoring program

·         Particulate sampling

·         Final Plant Closure report

Box 25 of 40

File #1:

·         Post Closure Week Inspection reports Nov.-Dec 1984, Jan. 1985

File #2:

·         1984 Velsicol Disposal Well #2 (No upward pressure)

·         VCC response to EPA regarding Gratiot County Landfill June 1985

·         Landfill liquid going to disposal well

·         Types of liquid allowed at Disposal Well #2

·         Site screening for Mill St. substation June 1993

·         Chemicals found at substation

·         Long list

·         Well locations

·         Groundwater modeling (slurry wall)

·         The need for drainage ditch downstream from slurry wall

·         Runoff of water from 3,400 gal to 34 gal with ditch installed

·         Location maps

File #3:

·         Post Closure Maintenance and Monitoring Plan Sept. 1986

·         Post Closure Weekly Inspection reports Sept 1986 and June thru Sept. 1988

File #4:

·         Post Closure Monitoring Reports 1985-1986

File #5:

·         Post Closure Monitoring Reports July 1985-Dec. 1985

File #6:

·         2002 Work Plan Phase I Evaluation of Slurry Wall

·         1995 Monitoring Well Replacement Work Plan – Velsicol

·         1985 Post Closure Maintenance and Monitoring Plan

·         2000 Revised Post Closure Maintenance and Monitoring Plan – NWI

Velsicol Records

Box 26 of 40

File #1:

·         Post Closure Inspection reports Jan.-June 1985 plant site

File #2:

·         Post Closure Inspection reports Jan.-June 1986

File #3:

·         Post Closure Inspection reports June-Dec. 1986

File #4:

·         2002 Five-Year Review report – EPA

·         1998 Summary Final Streamlined RI/FS report

·         1997 Final Containment Assessment report

·         1996 Velsicol’s response to MDEQ report on the St. Louis Impoundment

·         1996 Status of St. Louis Impoundment – MDEQ

·         1986 Summary of Post-Closure Containment Wall

File #5:

·         Post Closure Inspection reports 1987

File #6:

·         Post Closure Inspection reports 1988-1990

File #7:

·         Post Closure Inspection reports 1990-1992

Velsicol Records

Box 27 of 40

File #1:

·         Post Closure Monitoring Program reports 1991-1993

File #2:

·         1993 Site review and update by ATSDR (2 copies)

·         1992 Superfund site final closeout report

·         1990 Final Work Plan for EPA (Weston)

·         1992 Quality Assurance Project Plan

·         1998 Action Memo – Time Critical Removal Action

·         1999 ROD for OU-2

·         1997 Velsicol response to Interim Containment Assessment report (CRA)

File #3:

·         Oct. 1993 United States Environmental Protection Agency

·         Feb. 1993 Michigan Department of Natural Resources

·         June 1993 Screening Site Inspection Report

File #4

·         Well and monitoring of groundwater reports April-Sept. 1994

·         Well and monitoring of groundwater reports Jan., March, June, Oct. 1995

·         Letter to EPA from Mem. Env. Oct. 19, 1994

·         Lawyer letter of well reports Sept. 27, 1994

·         Legal reports

·         Site monitoring reports Jan, March, June 1995

File #5:

·         June 1995 Containment System Assessment work plan

·         July 1982 Upgradient containment wall

·         Aug. 1982 Sampling program

·         Dec. 1982 Radiation Screening Survey Final

·         Oct. 1982 Field Investigative Program

·         Oct. 2002 Cap and DNAPL Collection Trench in river

·         July & Oct. 2001 Michigan Department of Environmental Quality

File #6:

·         Drawings and charts water level inside plant site 1994

·         Hand drawings of the containment system assessment, various stations

·         EPA injection well guidelines

·         Drainage outfall drawings

·         Weekly Observation Logs 2001-2002

File #7:

·         Work Plan Post-closure Cap Maintenance Dec. 1997 (2 copies)

·         Containment System Assessment Work Plan Dec. 1995

·         NWI Land Management Jan. 2000

·         Community Involvement Plan Jan. 1998

·         2004 Final Cleanup Status Report June 2005

·         File #8:

·         EPA report to MDEQ Site Monitoring Oct. 1996

·         MDEQ report Jan. 1997

·         EPA 5 Year Report 8/27/1997

·         National Remedy Review Board Briefing (how deep to remove sludge from riverbed)

 File #9:

·         Post-Construction Quarterly Monitoring Report April 1999

Velsicol Records

Box 28 of 40

File #1:

·         Final rule on license termination

·         Remediating Great Lakes Contaminated Sediments

·         The ERIIS Report

·         Michigan Recovery Systems, Inc.

·         Long and Wetzel Co.

·         Monitoring Well Replacement Report Nov. 1996

·         Hazardous Waste report 1999

·         Eco Solutions, Inc.

·         Michigan Chemical Well #1 driller’s log

·         MCC Disposal Well #2

·         Michigan’s Mineral Well regulations

File #2:

·         NWI Land Management maintenance and monitoring plan Dec. 8, 1999

·         Memphis Environmental Center Feb. 5, 1999

·         Post Closure Inspection reports Sept 4, 1999 and March 31, 1998

·         NWI site monitoring Jan. 1, 2001

·         Site contour maps Oct. 10, 2000, July 10 2000

·         DEQ waste water removal yearly 2,000,000 2001

·         Water levels Oct. 3, 1999

·         NWI monitoring wells June 2 and April 1 1997, and Oct. 13 1995

File #2:

·         Quarterly monitoring report Oct. 1996

·         Groundwater contour map July 1996

·         Well location July 1996

·         Monitoring well reports June, July 1994, March, June 1995

File #3:

·         Post closure inspection reports 1999-2000

File #4:

·         2000 Removal Summary Report ( Ecology and Environment) (2 copies)

File #5:

·         2002 Cleanup Status report – Phase I

·         2002 Cleanup Status memorandum – OU-2

·         2003 Final Cleanup Status report –OU-2

·         2005 Cleanup Status report

File #6:

·         Removal Summary Report July 2000

·         Fruit of the Loom, Inc. 2001

·         USEPA Year 2002 Cleanup Status Memorandum

·         Confirmatory sampling log

·         Appendix B Photolog

·         RAC

·         NAPL Sample results Aug. 2002

·         Appendix F test trench photo log

·         Lab report

·         Test trenching photolog Appendix H

Velsicol Records

Box 29 of 40

 File #1:

·         Inspection reports ( plant site

File #2:

·         Slurry Wall Work Plan

·         Velsicol Site – OU-1

·         Joint Sample and Analysis Plan

File #3:

·         2003 NAPL Investigation Summary report

·         2002 (second) EPA 5-year Review Velsicol Site

File #4:

·         Pictures, site history, remediation

File #5:

·         Environmental Site Assessment (former Creamery site on M-46)

·         Phase II Site Investigation Report

·         Environmental Risk Mgmt. information

File #6:

·         2004 Peerless Env. Site Assessment Phase I and Phase II (Creamery) (two vacant parcels)

·         Peerless Phase II Investigation report

·         Peerless sampling plan

File #7:

·         Final Source Migration Investigation

File #8:

·         Copy 2 ↑

File #9:

·         Final 2005 Cleanup Status report Phase 2 (2 copies)

Velsicol Records

Box 30 of 40

File #1:

·         2004 Ongoing cost at the Velsicol Chemical

·         Cost summary of salaries, fringes, FICA

·         Main Human Resource system

·         Cost summary of travel expensed

·         Supplemental coding information

·         Cost summary of contractual services

·         9/30 2003 State cleanup program year-end close report

·         Weston Solutions of Michigan

·         DEQ an equal opportunity employer

·         Weston Solutions

·         Worthy Electric, Inc.

·         Mobile Facility Engineering, Inc.

·         A Thyssen Krupp Materials NA company

·         General Ledger Report 2003

File #2:

·         Mem. Env. Accounting report for 1986-1992

File #3:

·         Lawyer comment letter on rent refusal payment for disposal well on Crumbaugh farm 1998

·         Mowing billings for plant site and Breckenridge site Sept. 14, 1998

·         Misc. billings to outside vendors for services

·         Billings and unit designs for injection well

·         Vendor billings for site equipment

·         Vendor billigs for services and waste water

·         Operational costs

File #4:

·         Edgewood Farms financial statements 1993

·         Dames and Moore invoices 1980-1981

·         Walker Wells invoices 1980

·         Dames and Moore revised proposal for hydrogeologic at Edgewood/Burn Pit 1980

·         EPA review of Dames and Moore proposal

File #5: (1989-1990)

·         Hollywood Dump invoices and numbers

·         Memphis Env. Ctr invoices

·         CRA changeout rates

·         Recap of purchased orders – CRA

·         Purchase of air monitoring equipment

·         Correspondence on storm sewer on Watson and width of road

·         Assorted correspondence

·         Hollywood Dump receipts

File #6:

·         Dec. 1966 Shaw Construction Co.

·         Schlumberger Well Services

·         Cecil Allen Excavating

·         1980 Conestoga-Rovers and Associates

·         1981 Velsicol Chemical Corporation

·         1981 CRA Consulting

·         1980 Walker Wells, Inc.

·         1980 Dames and Moore

·         1984 Final Cost Summary

File #7:

·         Cleanup DVDs 2005-2006

·         Cleanup report book Oct. 10 2006

·         Cleanup report book Dec. 28, 2006

Velsicol Records

Box 31 of 40

File #1:

·         Pine River Downstream Summary Report

·         Invoices

·         Salaries, fringes, FICA and retirement

File #2:

·         Expenses

File #3:

·         Expenses

File #4:

·         Expenses

·         Superfund contract for remedial activities

File #5:

·         Itemized cost summaries

File #6:

·         Itemized cost summaries and detail documentation

File #7:

·         Hazardous Waste manifest

Velsicol Records

Box 32 of 40

File #1:

·         Post Closure Maintenance and Monitoring Plan (multiple copies)

·         Map of test wells

·         Some test results

File #2:

·         Post Closure Maintenance ad Monitoring Plan (multiple copies)

·         Summary of Post Containment Wall Monitoring Dec. 1986 (containment wall samples (permeability test results)

File #3:

·         Air monitoring booklets and results (1983 & 1984)

·         Offsite/on site lab testing letter

·         Air monitoring correspondence

File #4:

·         1983 Monthly Total Suspended particulate Chemical Analysis and Meteorological Data

·         Invoices

·         Uniform Hazardous Waste manifest

·         Correspondence:  Water elevation exceedance, permit

File #5:

·         1980 inter-office correspondence on disposal of various wastes and equipment

·         Monthly plant oeration cost summary

·         More information on removal of equipment

·         Memo on sale of plant site steel (Mar. 1980)

·         Proposed schedule for plant cleanup and building removal

·         Correspondence removal of liquid waste

·         Edgewood Golf Club electrical transfer and Vesicol right of way

·         Removal of purchased equipment

·         DNR and EPA with Geiger counters

·         Progress Report 10/31/79 thru 11/16/79 (on waste disposal – scrap piping and steel sent to Texas)

·         Cleanup – securing buildings and equipment

·         Cleaning #6 fuel oil, 207 tank farm

·         Permits, drumming, equipment cleaning

·         Abstract

·         More of same ↑ Oct. 19, 1979-Dec. 7, 1979

·         Investigation of groundwater gradients

·         Plant Progress reports Feb. 1981-Nov. 1982

·         Maps of railroad spur

·         2 booklets on “Exemption Request from Groundwater Monitoring Requirement”

·         Progress meeting notes march 28, 1983

File #6:

·         PSI monthly reports

·         Reassessment of Chemical Parameter Monitoring Program for suspended particulate samples

·         Field Investigation Program

·         Upgradient containment wll

·         1983 Monitoring Wells Installation and Sampling

·         St. Louis Soil Sampling Survey

·         Monthly Progress reports relating to construction activities at plant site

File #7:

·         Progress report Jan.-Dec. 1981

·         Final Report Air Monitoring Program June 1982 (duplicates)

·         Mineral Well Permit and correspondence

Velsicol Records

Box 33 of 40

 File #1:

·         Weekly Inspection reports 1984-1995

·         A standard form with items: perimeter fence, gates and locks, signs, landscaped cap area and status check off cone by Eugene DeGeer, custodian

File #2:

·         Fish Contamination Monitoring Program, DNR (various chemicals and heavy metals) (single page reports for various years in 1980s and 1990s)

·         5 copies inspector reports by Gene DeGeer 11/2/1984

·         Annual pressure test results Disposal Well #2 12/20/1996

·         EPA Final permit for injection well at plant site 10/8/1986

·         ABB Environmental Services report of sampling at Gratiot C. Landfill,  to MDEQ 9/27/1996

·         ABB Environmental Services draft technical memorandum about ↑ to MDEQ 12/27/1996

·         Eco Solutions bound report to EPA “well rework and mechanical integrity” Injection Well #2 6/2/1997

·         Weekly and monthly well #2 monitoring reports Oct-Dec 1998

·         Michigan Fish Contaminant Monitoring Program Annual Report (for all locations in state) (Pne River below dam is on pages B-211→B-215

·         Folder labeled Velsicol Correspondence with only about 5 letters/notes in it

·         Velsicol Final Report Gas Vent Post-Closure Monitoring by Conestoga-Rovers Jan. 1988

·         Loose copies of correspondence submitting gas vent sampling reports

·         Summary of Post Construction Containment Wall Monitoring, CRA Dec. 1983-Sept. 1986

·         Operating and Monitoring Plan Disposal Well #2

·         CRA letter to Gene DeGeer (instructions on completing inspection letter)

·         Six pages St. Louis Monitoring Wells Elevations 1984

·         DNR bound report Deep Well Injection of Hazardous Waste in Michigan (8 member committee to review the practice of) (the intro and history pages have a good history of this practice

File #3:

·         MDEQ Authorization to Discharge Pollution

·         St. Louis UIC permit 1992

·         Disposal Well #2 – final letter authorizing (5 copies)

·         Industrial and Commercial Wastewater Discharge 1994

·         NPDES permit 1994 (2 copies)

·         Letter from US Dept. of Justice about deep well disposal 1995

·         Deep Well Injection permit Stipulations 1997

·         Packet of documents Memphis Environmental Center

·         Wastewater Discharge Permit 2001

·         Inspection report for Ferndale (?) 1997

·         Folder on Disposal Well #2 1998

·         Deep well injection reports 1987-1997

·         UIC permit Well #2 1992

File #4:

·         No injection into Well #2 April 1996

·         Post Closure Maintenance and Monitoring reports

·         Weekly observation logs for April 15,18, 29 2000

·         Site reports for Well 2 4/22/2000

·         No injection May 1995

·         Post-Clos Maint. and Mon. report May 1995

·         Post Closure Inspection Reports

Ø  March 31-May 4 1996

Ø  Jan. 1-Dec. 9 1995

Ø  Dec. 31, 1992-Dec. 31, 1994

File #5:

·         Agendas and minutes from meetings of Pine River Superfund Citizen Task Force 1998-2002

File #6:

·         5 bound copies of Post-Closure Monitoring Plan 1985

·         Letter to EPA and DNR with enclosed copy of ↑ 1985

·         Post-Closure inspection reports Nov. 1997-Sept. 1998

·         Letters to EPA and copies of Post-Closure Inspection report Oct. 1998 and Feb. 2001

Velsicol Records

Box 34 of 40

File #1:

·         River Sediment Core Sampling report (multiples)

·         Fish Contaminant Monitoring report

·         “On-site” mineral well letters

·         Contamination Site sample comparisons

·         Post Closure Monitoring

File #2:

·         Containment System Assessment—permeability analysis

·         Test method literature and reports

·         Containment System Assessment Final Report (duplicates)

·         Various test results

File #3:

·         Disposal Well #2 permits, testing, various correspondence

·         Post Closure quarterly monitoring reports

·         Various reports on different chemicals/results

·         Mineral Well Regulatory Fee Assessment report

File #4:

·         Well inspection reports

·         Monthly piezometer well inspection report

·         Plant site maps

·         Well monitoring data

File #5:

·         Post Closure Monitoring reports

File #6:

·         Phase I (notebook) evaluation of slurry wall

·         Plant Site Weekly Observation Logs

·         Plant Site Monthly reports

·         Estimated cost for plugging and restoration of Disposal Well #2

Velsicol Records

Box 35 of 40

File #1:

·         Permit application for Deep Well #2 – 6 mile radius Vols. 1 &2 1991 (2 copies)

·         Final shutdown drawings (warning and shut-off system, injection well) 1987

·         Well water survey – Isabella County

·         Well water survey – Midland County

File #2:

·         Letter from attorney to NWI and article on GM pollution in Saginaw Bay

·         Articles on casinos, Chippewa Tribes and casinos

·         Explanation of 1836 Treaty of Washington 1999

·         Summary of Agreement General Electric – Housatonic River sites

·         Kalamazoo site articles

·         Grand Rapids Press article on rivers – mentions Pine River and DDT

·         Articles on Saginaw Chippewa Tribe

·         Article on Dredging Research

·         Office of Great Lakes Activity Report 1998

·         Housatonic River document 1998

·         Articles on St. Louis, river and plant site

·         Articles on pumping water (taken to Detroit)

·         Article: EPA to decide on dredging river 1997

·         Community Involvement vs. Big Oil report 2000

·         Hazard Evaluation Handbook – a Guide to Removal Action

·         EPA report on Grand Calumet River, Indiana Harbor

·         EPA Superfund Week newsletter 1998

·         Manistique river and Harbor Site Fact Sheet 1998

·         Lots of articles about Pine River and news photos of Jane Keon and Ed Lorenz

File #3:

·         Polar Environmental promotional folder (2 copies)

·         Paul Lapham and Asso. brochure

·         Samtest Testing Services brochure

·         Folder on information on injections Wells (note on it: use it to educate Crumbaughs)

·         Folder Geodynamic

·         Folder Palco Liners

·         Folder Oil Recovery, Inc.

·         Folder ITT Barton flow computer

·         Booklet Digitilt DataMate and DMM Software

·         Effective Landscaping brochure – Twin City

·         Plant site inspection sheet and drawing

·         Brochure on Circular Chart Recorders (2 copies)

·         Letter and information on Filter Resources, Inc.

·         Information on Environmental Geotechnical Construction

·         Digitilt Inclinometer Probe information

·         Information from Midwest Engineering Services

·         Brochure and Regreen information, landscaping

File #4:

·         Notebook Crawford and Asso. Company Profile

·         Petroleum promotional material

·         Thermo Nutech promo material

·         Envirogen promo material

·         Fibertec promo

·         Envirocorp promo

·         Geodynamic Industries promo material

File #5:

·         Article on pollution Mission Creek (Isabella Co.) 1979

·         Article on PBB at Komperda farm 1980

·         Article on 450,000 chickens buried at Gratiot County Landfill 1980

·         Folder of dozens of PBB articles, some plant site, one on DBCP used as a pesticide in California

·         Umpteen articles on PBB, Landfill and radiation

·         Another folder of news articles on PBB and plant site 1981-1982

·         Letter and data Dames and Moore (isotopic samples)

·         Mention of St. Louis Task Force, headed up by David Wade

·         Mention of NIEHS report linking PBB to cancer in animals.

·         Disposal Well #2 document

·         1998 Clean Michigan Initiative

·         Oil and gas lien – Crumbaugh

·         News articles – Crumbaugh Disposal Well #2

·         Article and photo (pumping water out of plant site) 1996

·         Crumbaugh trial begins 1998

·         RCRA rules, abandoning wells

·         Federal Register – National Oil and Hazardous Substances Contingency Plan

·         Journal article by Ed Lorenz, 1993, Environment History Review

·         La Motte Chemical Test Equipment Digest

·         News article – Velsicol completes plant cleanup early 1984

·         Proposed article for Michigan Contractor and Builder Magazine 1983

·         Article – two workers sue Velsicol

·         EPA Administrator Record index of reports, plant site 1992

·         SDMS (documents) FRC collection index 1039, 1040, 1041

·         EPA Admin. Record index Vesicol plant site 1998

·         Region V (EPA) Superfunds Records Management

·         Records transmittal receipts 1998

·         EPA CD-ROM User Guide 2002

·         EPA Proposed to Drop Velsicol Plant from Hazardous Sites List 1986

·         Long, typed press release from Atty Gen. Frank Kelley about 38.5 million settlement with Velsicol 1982

·         Letters and article about casinos 1999

Velsicol Records

Box 36 of 40

File #1:

·         2006 Draft RI on DVD

·         Weston DVD Alternative Array Document (Velsicol Chemical)

·         Superfund Redevelopment Pilot Project

·         Power Points 2002, 2004 (lots of pictures of river dredging)

·         Chronological list RD/RA work plan type component document Apr. 1979→ Dec. 2004

·         St. Louis reports list Nov. 1984 through Sept. 2002, plus 2 copies Final 2004 Status Reports

·         Correspondence regarding containment system assessments (list March 1994-Feb. 1996

·         Letter from Velsicol attorney (Steketee) marked confidential (request for water level exceedences at plant site March 1994

·         MDEQ (Sakowski) directing Memphis Environmental to lower water levels May 1994

·         EPA letter to Velsicol president Chuck Hanson regarding violation of Consent Decree May 1994

·         Mem. Env. letter to Sakowski explaining and requesting meeting on exceedences May 1994

·         More communication with MDEQ on exceedences June 1994

·         Mem. Env. Letter to Sakowski explaining alternatives, treating waste water June 1994

·         DNR formally accepting temporary interim action to correct violations of Consent Judgment (20,000 gallons a day to Detroit Sewer System) and run through treatment system June 1994

·         Mem. Env. Starts hauling water to Detroit Dec. 1994

·         EPA formal acceptance to interim action for disposal of water to Detroit Dec. 1994

·         EPA letter to Mem. Env. –site water level due to other recharge sources and not well heads July 1995

·         Mem. Env. Letter to EPA – GWM 1 & 5 had highest water level, but others still high

·         EPA to Mem. Env – reviewing work plan for monitoring well work

·         EPA to Mem. Env – water level maintenance, more water withdrawal is warranted Feb. 1995

·         Mem. to EPA – GW maintenance, permission to pump and haul to waste site (City Environmental, Inc. in Detroit) Jan. 1995

·          Mem. to EPA – outline of work plan to assess containment system and activate deep wll

·         EPA to Mem – requesting confirmation of ↑

·         Love Canal – Niagara Falls—Velsicol

File #2:

·         Public relations file – John Hock (NWI)

File #3:

·         Fail to pay article, AIG 100,000,000

File #4:

·         EPA site information: Proposed Plan, various reports 1996, 1997, 1998

File #5:

·         Edgewood Farms file:

Ø  All shareholders as of 9/27/1988

Ø  Financial records 1993

·         Map of golf course

·         Set of drawings – Securement of Waste Disposal and Burning Area

·         Borrow Pit drawing

File #6:

·         Drawings of Former Plant Site and #2 Well

File #7:

·         Drawings of St. Louis Wastewater Treatment Plant

·         Upgrade/downgrade bore hole drawing

·         Emergency Removal drawings (Fred’s pond)

·         Phase II Evaluation of OU-1 2002

File #8:

·         Letter from Rita Jack (Sierra Club) to Stephanie Ball, EPA (requesting Emergency Action, river cleanup

·         Future RA in Mill Pond – presentation Nov. 2004

·         City of St. Louis hopes and dreams – reuse of plant site property

·         Mem. Env. Letter to Steve Mepham (St. Louis waste water) outlining wastewater streams wishing to send

·         Morning Sun article studying ways to clean Pine River Oct. 1997

·         Morning Sun article, chemicals in St. Louis aquifer an 3,000 gallons of material shipped Aug. 2002

·         Someone’s notes from meeting of CAG Aug. 2002

·         CAG’s effort to get the M-46 bridge raised – presentation

·         Public Notice – MDEQ propsed reissue of discharge permit for Gratiot County Landfill Aug. 2004

·         City Council minutes Oct. 1997

·         Public Hearing sign-in sheets

·         National Remedy Review Board briefing package, Pine River Sediments March 1998

·         Ultramar Diamond Shamrock – Consent Decree – 9.9 million settlement

·         Record of Decision (ROD) for OU-2

·         Department of Energy sent George Kubin (mayor) letter stating Michigan Chemical did not have authority to perform remedial action at the site Apr. 1995

·         Velsicol Compensation Schedule 2005

·         Sediment RA 2005

·         St. Louis School letter pCBSA

·         Morning Sun article – city council wants EPA to inform them

·         EPA letter to city – claims damages for not maintaining dam and river level – it flooded removal cells – by EPA lawyer Gaylene Vasaturo

·         Fruit of the Loom bankruptcy 2002

·         Plat map 1937 St. Louis

·         Economic data City of St. Louis 1982

·         Contract agreement -- Velsicol and City to construct storm sewer

·         Joe Scholtz letter to city inviting them to tour the site

·         Letter from Vel. President Chuck Touzeau to City – fire alarm testing 1972

·         Letter from City Clerk Kenneth Barnum to Velsicol praising them 1973

·         Michigan Chemical letter to mayor Bill Dennis to order refuse containers 1970

·         Mich. Chem. Letter to mayor inviting him to inauguration of new research and development facility 1970

Velsicol Records

Box 37 of 40

 File #1:

·         Location of animal traps and species trapped

·         Piezometer locations map

·         Sample locations map

·         General Potentiometric Surface map

·         Site Drainage

·         Drainage basins to Pine River

·         Fax to Optamin to buy property for house

·         Waste water map, treatment, 1998

·         Waste water side view map ( treatment) 1998

·         Wastewater treatment plant culvert map 1998

·         Wastewater treatment plan basin map 1998

·         Concrete pad diagrams, 4 pages 1998

·         Extra copies of 1-6 maps of site

·         Site Reuse plan start from Mem. Env. Sept 1998

·         Full plant site closure plans from CRA engineers Apr. 1982

·         6 copies plant site map from Mem. Env. Ctr. April 1985

·         Maps of Velsicol sites in mid-Michigan (5 maps) July 1997

·         Blue print layout map of St. Louis w/ plant site 9/28/1965

·         Abrams Aerial Survey 6  plant maps 1976

·         Demolition map (CRA) (2 copies)

·         Storm sewer maps (CRA) 1980, 1981,1982

·         Containment wall map 1982

·         Drainage areas 1981

·         Storm drain pliem map 1980

·         Subdrain map 1982

·         Perimeter sub-drain map 1982

·         Plant site collection 1982

·         Plant site containment wall 1982

·         Plant site subdrain misc. details 1982

·         Plant site contours 1982

·         Storm sewer construction 1982

·         Containment wall borehole locations 1982

·         Oil contaminant remedial action 1983

·         Subsurface oil contamination 1983

·         Groundwater and oil collection pleim map, no date

·         Storm sewer construction Watson St. 1983

·         Storm sewer construction M-46 1983

·         Storm sewer construction details 1983

·         Misc. details plant site pliem map 1983

·         Backfill detail plant site pliem map 1983

·         Containment wall details plant site, no date

·         Storm sewer map, no date

·         Storm sewer easement areas, 1982

·         Storm sewer drainage areas 1981

·         Elevation map of plant area, no date

·         Abram Aerial Survey contract ( Velsicol) 1/4/1980

·         Proposed financial commitment area CRA 1983

·         Blueprint map of Dundee geo. structure ( shows brine wells and oil wells) (covers east/west Breckenridge to Riverdale, north south Shepherd to Ithaca, 1966

·         Blueprint map of MCC company wells (includes underground vertical drawings ) 1966

·         Blueprint map of proposed pipeline and proposed disposal wells 1 &2 1966

·         Map of groundwater collection and containment system 1982

·         Map of storm sewer construction Watson St. 1981

·         Map of storm sewer construction Washington St. ( M-46) 1981

·         Storm drainage areas 1981

·         Storm sewer construction plant perimeter 1982

·         Aerial Survey drawing of plant site (5 copies)

·         CRA to DNR – letter and copies of storm sewer construction, 1982

·         CRA to Vel. – letter and map showing bore holes in the containment wall, 1982

·         Drawing of boring locations Gratiot County Landfill

·         Bound report Estimate of Cost – Vel. 1984

·         Map – Securement of Plant site 1983

File #2:

·         Civil and Environmental Consultants, Inc. water table contour map 2001

·         Groundwater elevations measured (maps) 2002

·         Water table contour map 2002

·         Land Management Spicer Group 1999

·         St. Louis vent monitoring equipment catalog 1985

·         Termination of vehicle 1984

·         Inspection receipt

·         Rupp Rental and Sales Corp

·         Securement of Plant site

·         Phone book 1985

·         St. Louis, Michigan Plant Site 1987

·         NWI Land Management Corp. check for $600.00

File #3:

·         NWI site plan – Spicer Group engineering (2 copies)

·         Foot contour interval mappig

·         CRA Consulting Engineers

·         Arrow Swift Central Insurance

·         Vesicol #

·         Twenty-eighth Annual Report

·         Memphis Environmental

·         Gas vent sampling pumps calibration log

·         Quarterly inspection log sheet

·         Weekly inspection log sheet

·         Color-detector tubes

·         Bethany Twp. Map

·         Inclinomters

·         Karst consultants

·         Clean-Hands Technique for water sampling of mercury

·         Monthly operating report Deep Well injection

·         Gratiot County map – oil and gas regulations, DNR

·         Federal Regulations – Table of contents

·         EPA Administrative Record index

File #4:

·         County Road Association 1986

·          Record Book May 28-July 28 1994

·         NWI Well #2 1999

·         VHS Deep Well #2 injection

·         VHS Segmented gate skystem

·         Complete list of transporters who are licensed in Michigan to haul hazardous waste

·         Lead Acid Battery reclaimers

·         Fedex copies: Memphis Environmental Center, Velsicol Chemical, MDNR

·         Mem. Env. Laboratory task order form

·         Site o34 – St. Louis Plant

·         Cal Gas

·         Federal Express Shippers Certification for Hazardous Materials

·         Deep Well #2 Start up plan

·         Myers Pressure Regulating Relief Valve

·         Notice of Public Hearing

·         Corporate headquarters

·         Detroit City map

·         CRA Consulting Engineers

·         Land Atlas Plat  book

·         Chain of custody record

·         Soil test

·         PBB products produced by Michigan Chemical Corporation

·         Michigan Department of Labor

·         DEQ Uniform Program

·         Spriggs and Hollingsworth, attorneys

·         Peter W. Steketee attorney at law

·         NWI Land Managerment Co.

·         Miss Dig System, Inc.

·         George R. Harvell EPA Superfund Reforms

·         June 18, 1997 Geodynamic Industries, Inc.

·         1995 St. Louis Michigan Plant Site

·         Oct. 12, 1994 Memphis Environmental Center, Inc., inter-office memo

·         Groundwater Quality control book

·         Personnel files records retention

·         Memphis Environmental Centr

·         Sidley and Austin

Velsicol Records

Box 38 of 40

File #1:

·         EPA Fact Sheet on plant site

·         Well Sampling results (city and sentry)

·         Site pCBSA Trend Evaluations

·         5-year Review report for plant site

·         City of St. Louis/Velsicol litigation letter on city’s water

·         Water quality report for St. Louis, 2009

·         Draft of Water System Master Plan/City of St. Louis

·         Water well and pump records

·         Maps of proposed study areas

·         Correspondence: replacement of well field

·         Water well records and cost comparisons, and recommendations

·         Evaluation of pCBSA in drinking water

·         Mediation – City of St. Louis and Velsicol (duplicates)

File #2:

·         City files suit over drinking water

·         Toxicological Assessment pCBSA

·         City of St. Louis wells (and pump records)

·         Remedial pictures of plant site

·         List of contaminants in drinking water and potential health risk

·         Delinquent Tax records (LePetomane III, Inc.)

·         Morning Sun article on St. Louis water (copies)

·         Toxicology assessment (pCBSA)

File #3:

·         CAG minutes and agenda 2006 and DDT literature

·         RI completion schedule and reports

·         Twin City Landscape contract

·         Information on pCBSA in drinking water and well sampling results

·         pCBSA toxicological assessment

·         Legal correspondence on St. Louis well field for settlement purposes

·         DEQ newsletter (Spring 2006) on remedition and redevelopment

·         Sentry Well Plan

·         City Wells analytical results

·         Ventron/Velsicol Superfund Redevelopment Site 2010

·         Jan. 21, 2008 expert report on pCBSA

File #4:

·         Draft of delisting decisions

·         Post Closure quarterly Monitoring report July 2002

·         CH2MHill DVD on Final Joint Sampling and Analysis Plan

·         Someone’s calendar 1999 and detail of environmental management

File #5:

·         Books (4) detailing plant site

·         Copies of deeds

·         Ordinance book

Velsicol Records

Box 39 of 40

File #1:

·         MDEQ Analytical Target Detection Level Guidance for Vinyl Chloride May 5, 2003

·         Environmental Division Environ Jan. 12, 2001

·         Phase II Environmental Site Assessment Sampling Plan for two vacant parcels 2004

·         Miss DIG System, in verification of member information 2005

·         Former Creamery property Phase II detected analytical parameters in soil 2004

·         David Heidlauf, property south of M-46 2004

·         D. Heidlauf Environ Clayton Group Services 2004

·         Table 1, 2, and 3 former Creamery property Phase II detected analytical parameters in groundwater

·         Environ D. Heidlauf former Creamery site Nov. 9 2004

File #2:

·         Superfund National Remedy Review Board April 1998

·         DEQ Contaminant Transport pathways and groundwater flow – current conditions 2004

·         D. Heidlauf, geologist SMI Environ Corp.

·         Pine river sights and sounds photos

·         Long list of reports – Post Closure Inspection

File #3:

·         Deep Well #2 pumping pressures 1994

·         Monitoring wells groundwater levels 1995

·         Cost of plugging well #2 $35,000 7/25/86

·         Misc. water levels plant site 1991-96

·         Containment wall bottom wall elevation 5/16/95

·         Preliminary Hydraulic cals. 1996-2006

·         Binder: Itemized ledger of cost summary outline – all the cost expenditures in the integrated financial management system for Velsicol Chemical, Michigan site.

File #4:

·         DEQ to Environ, 2003

·         Weston – property transaction geoprobe investigation former plant site 2003

·         EPA Brownfield Pilot

·         Sidley and Austin to Mem. Env. 1998

·         Pine River Superfund Task Force agenda

·         Property access and indemnity agreement

·         Reusing Superfund sites guide

·         EPA Reuse – commercial use where waste is left on site

·         Reuse Assessments: A Tool to Implement the Superfund Land Use Directirve

·         EPA Reuse of CERCLA Landfill and containment sites

File #5:

·         Velsicol cost summary 12/2004-4/2005

·         Letter from lawyer of site Trust Sept 19, 2005

·         MDEQ itemized cost July 25, 2005

·         Fax’s from EPA to site contractor 2004-2005

·         Cost summary for labor and vendors, 2003, 2004, 2005, 2006

File #6:

·         EPA cost summary report, 2005

·         St. Louis cost tables, 2005

·         Weston, MDEQ and Misc. vendors cost summaries 2005-2006

·         Cost total for 2005-2006 (large file)

Velsicol Records

Box 40 of 40

File #1:

Landfill groundwater remediation maps, March 20 1997

Ø  Engineer’s map 1997

Ø  Eng. Map symbols and abbreviations

Ø  Eng. Map existing conditions plan

Ø  General site Plan

Ø  Detailed Site Plan

Ø  Extraction and effluent pipeline profile

Ø  Effluent pipeline sections

Ø  Extraction and Monitoring well details

Ø  Civil details (road bed and other)

Ø  Building details

Ø  Foundation and structural (details and buildings)

Ø  Piping and instrumentation symbols

Ø  Piping Plan

Ø  Heating and ventilating

Ø  Electrical Legend

Ø  Single line an elementary diagrams and schedule

Ø  Power, lighting instrument grounding plans

Ø  Logic diagrams

Ø  Wiring diagrams

Ø  Electrical plan

File #2:

·         Maps, cross sections of St. Louis plant site (13 maps)

File #3:

·         Final cross section maps of clay cap on plant site, April 1983 (17 maps)

·         Pit Management Plan

·         Final cross section maps of borrow pit (9 maps)

File #4:

·         Velsicol Plan 33AB miscellaneous details

·         Velsicol Plan 32AB plant site clay cap

·         Velsicol Plan 33AB final cover contours

·         Cross sections of clay cap (17 maps)

·         Borrow Pit Management Plan

·         Cross section maps of clay pit management (8 maps)

File #5:

·         1984 Site Securement plans/maps – Conestoga-Rovers

Ø  Site key as built

Ø  Subsurface oil contamination

Ø  Oil contamination Remedial

Ø  Miscellaneous details

Ø  Oil contaminatin wall as built

Ø  Watson rear yard sections (4 maps)

Ø  Source of backfill

Ø  Surface contours

Ø  Upgradient containment wall

Ø  Containment wall profile (4 maps)

Ø  Storm sewer construction, Watson St. and M-46 (6 maps)

Ø  Groundwater collection

Ø  Sub-drain laterals

Ø  6” clay subdrain

Ø  Subdrain misc.

Ø  Downgradient containment wall (5 maps)

Ø  Final cover contours