ROCKFORD, MI -- Historical records show that Wolverine World Wide once stored toxic chemicals that are polluting the Rogue River in an unpaved area outdoors at the footwear company's former leather tannery complex in downtown Rockford.
A pollution prevention plan from 1981 shows that drums of per- and polyfluoroalkyl substances, or PFAS, were kept outside at the tannery near locations where recent testing has found extremely high levels of the chemistry in the soil and groundwater.
The 1981 document, obtained though the Freedom of Information Act, may not have been provided to either the state or federal governments in response to mandatory record seeking related to an ongoing pollution investigation in Kent County.
Neither the Michigan Department of Environmental Quality nor the U.S. Environmental Protection Agency would definitively say whether Wolverine provided the document in response to a state subpoena and a federal request for information.
Other records obtained through FOIA show that regulators were unhappy with Wolverine's chemical storage at the time, but attempts to cajole changes at Wolverine were rebuffed. Records show that Scotchgard storage was eventually moved indoors.
Academic experts who have independently analyzed records related to Wolverine use of PFAS-laden 3M Scotchgard fabric protector say the outdoor chemical storage could help explain the high contamination levels at the site, which is undergoing extensive pollutant testing this summer under EPA supervision.
"Any spill that occurred in the storage area would certainly go into the groundwater," said Richard Rediske, a Grand Valley State University chemistry professor who first alerted the DEQ last year to Wolverine's historic PFAS usage.
According to the 1981 Pollution Incident Prevention Plan (PIPP), Wolverine kept several varieties of Scotchgard outside near a warehouse at the south end of the manufacturing complex where tanned pigskin hides became iconic shoe brands like Hush Puppies.
Today, the soil and groundwater under the demolished complex and the adjacent river are highly polluted with PFAS, a class of chemicals which gave Scotchgard its waterproofing abilities. Human studies have shown probable links between PFAS exposure and kidney cancer, thyroid disease, pregnancy complications and other illnesses.
Testing confirms PFAS in sediment in the Rogue River and Rum Creek, a tributary that flowed directly underneath the tannery and Hide House buildings where records show that Wolverine stored Scotchgard chemicals indoors.
The Rogue River was formerly the drinking water source for the city of Rockford, which switched to groundwater supply wells in 2000. Experts say the former surface water treatment plant downstream of the tannery would not have removed PFAS.
Wolverine's own data shows the highest concentration of PFAS in the tannery groundwater is along the southwest corner of the property along the White Pine Trail, near a historic low area where upland drainage entered the river near a pump house that Wolverine formerly used to source water for tannery operations.
According to the 2017 testing, the groundwater in that spot is contaminated with 532,000 parts per trillion (ppt) total PFAS -- about 330,000-ppt of which is PFOS, a highly bioaccumulative toxicant that was Scotchgard's key ingredient for decades.
"Everything seemed to drain into that particular spot," said Rediske.
Wolverine blamed the 100-year manufacturing history at the tannery grounds when asked to speculate why there are such high PFAS levels at the site. "Over decades of operations, and not unlike many other industrial operations, it appears some of the materials migrated into the soil," Wolverine said in a statement.
The 1981 pollution prevention plan was obtained by the Concerned Citizens for Responsible Remediation (CCRR) in Rockford, a local watchdog group that petitioned the EPA in 2011 to investigate the tannery. The document is on file with the city of Grand Rapids, which accepted pre-treated Wolverine industrial wastewater at the city's sewage treatment plant on the Grand River until 2008.
The Oct. 21, 1981 document was authored by the Grand Rapids-based engineering firm Fishbeck, Thompson, Carr and Huber, or FTCH.
An MLive review of records provided under FOIA did not locate a copy of the 1981 plan in the thousands of pages Wolverine submitted to the DEQ as part of a subpoena for evidence in a pending federal case between Wolverine, the DEQ and Plainfield and Algoma townships.
The 1981 plan was also not found in records provided to the EPA as part of an investigative information request known as a 104(e) issued in early December. It was also not provided to EPA in response to a similar request in 2012.
The DEQ declined to comment on whether the plan is something investigators would expect to receive as part of state record-seeking.
Wolverine would not confirm it gave DEQ and EPA the 1981 plan, stating that "the PIPP is a document that was continually updated as facts developed at the tannery site."
"Wolverine produced more recent versions of the PIPP to EPA, including in 2012," the company said in a statement, noting that it "continues to supplement its response to those information request as additional documents are located."
The 1981 plan shows other chemicals stored in drums outside with Scotchgard included acetic and muriatic acids, fungicides, machinery cleaners, surfactants, textile lubricants, tanning oils, silicone and volatile organic solvents like methyl isobutyl ketone (MIBK).
The outdoor storage caught the attention of regulators at the time, who expressed concern with keeping hazardous chemicals in areas without pollution containment.
In a Sept. 14, 1982 letter to Wolverine environmental manager Harold Bailey, Michigan DNR water quality specialist John Bantjes wrote that Wolverine should store all "drummed liquids" inside and only keep clean, empty drums outdoors. Bantjes, who had inspected the tannery a few weeks prior, also noted that a tin machinery shed near the warehouse should not also house chemicals, because "drum puncture is a likely event during machinery movement!"
"Lack of secondary containment at that site will result in runoff of spilled material to the ground," Bantjes wrote.
Wolverine responded a couple weeks later by refusing to significantly modify pollution containment at the tannery unless the work happened in conjunction with an expansion project that was stalled by a "depressed market conditions for leather goods."
Until the "present economic climate changes," wrote hired engineer Carl Huber, "no major reconstruction projects are being undertaken by Wolverine World Wide."
The outdoor chemical storage was noted about a decade later in a 1994 Environmental Site Assessment by the DNR, which was considering an easement swap with Wolverine for a railroad right-of-way that crossed lengthwise through the tannery. The deal resulted in construction of the White Pine Trail segment along the river.
Chemical storage had moved inside by 1993, the DNR noted.
Subsequent year pollution prevention plans show Scotchgard was stored on the third floor of the tannery building and the Hide House.
EPA records show that Scotchgard was delivered to the tannery monthly by truck and, according to pollution plan updates in 1990, 1994 and 1996, the chemicals were stored in areas designed to drain spills to the tannery wastewater treatment plant.
The records show Wolverine bought numerous products from 3M over the years, including reflective inks and color dyes as well PFAS products like Scotchgard. The company also used products containing various amounts of fluorochemicals from other sources.
A 2000 tannery hazardous air pollutant summary shows that 16,590 pounds of Scotchgard FC-3573 and 64,409 pounds of Scotchgard FX-3573 were kept on hand.
In the early 2000s, 3M reformulated Scotchgard to remove PFOS after EPA determined the chemistry was toxic to humans, magnifies up the food chain and persists in the environment. Wolverine and 3M met to discuss the matter in 1999.
The new version, Scotchgard PM-4700, was stored in plastic and metal totes at the tannery. The reformulated version's key ingredient is PFBS, a PFOS replacement chemical for which federal health regulators are currently drafting a toxicity risk assessment.
High PFBS levels are also found in tannery site groundwater.
Rediske, who analyzed Wolverine's patented process for treating pigskin leather hides with Scotchgard as part of his initial memo alerting DEQ to the company's usage, said the leather was dipped in Scotchgard at the tannery before drying.
Scotchgard application occurred toward the end of treatment, he said.
Rediske said it's not known how Scotchgard was stored at the tannery prior to 1981. Wolverine began using Scotchgard in Rockford in 1958.
"The plant was there a long time," he said. "Lines and valves break."