Ford Livonia Transmission Plant - Public Meeting
DEQ Response to Comments

August 20, 2018 Public Meeting:  DEQ Response to Comments

Concerns/Comments (in order of frequency subject raised):

1.     Concerned about health issues from Ford Livonia Transmission Plant off-site plume

2.     DEQ should verify Ford's samples

3.     More thorough investigation or more sampling

4.     DEQ needs to be stricter

5.     DEQ response times need to be faster

6.     DNAPL plume not defined

7.     Source control insufficient

8.     No confidence in HCS

9.     Target detection level for groundwater 1

10.    Source characterization is insufficient 2

11.    Reject divided plume. 2

12.    Reject "clean lens" theory

13.    Require immediate mitigation

14.    Wants testing in home

15.    NAPL beneath the transmission plant needs to be investigated

16.    Rejects Ford's position of no impact to neighborhood

17.    Concern Ford drives DEQ decisions

18.    Groundwater concentration variability concern

19.    Requests continuous soil-gas monitoring to correct for weather variability.

20.    Concerned about stormwater rerouted to Rouge River

21.    Concern for plant workers

22.    Deny response activity plans

23.    Not enough samples collected

24.    Mention of former creek

 

1.   Concerned about health issues from Ford Livonia Transmission Plant off-site plume:

For health-related concerns and questions, the Department of Health and Human Services (DHHS), Division of Environmental Health, at 517-335-8350.  The DHHS will conduct primary oversight of indoor air sampling.  Wayne County Department of Health, Veterans & Community Wellness can also be contacted at 734-727-5890.

2.   DEQ should verify Ford's samples  

The DEQ staff will provide random and occasional oversight of sampling procedures and methodology; including split sampling for analysis at the DEQ laboratory.

3.   More thorough investigation or more sampling    

The Remedial Investigation and Vapor Intrusion Evaluation response activity plans (response activity plans), approved with modification, are plans for the performance of a thorough investigation and sampling.  Data to be collected will be expanded based on results collected.  Copies of the response activity plans and the DEQ approval with modifications letters can be found on our website at www.michigan.gov/LivoniaVI.

4.   DEQ needs to be stricter

The consent decree between the DEQ, Department of Attorney General, and Ford requires specific actions from Ford under a specified timeline and under DEQ oversight. A copy of the consent decree can be found at the website indicated above.  The consent decree is a legally enforceable agreement that is under the authority of the court that drives DEQ decisions and oversight for the facility.

5.   DEQ response times need to be faster

The consent decree requires careful adherence to the consent decree under specified timelines.  The DEQ will continue to prioritize the Ford Livonia plant as a high priority, ensure the schedules in the response activity plans are adhered to, and to review future plans and data submitted by Ford carefully to ensure accuracy, efficacy, and a thorough and ultimately protective remediation.

6.   DNAPL plume not defined

The DEQ will continue to require Ford to complete delineation of the dense non-aqueous phase liquid (DNAPL) plume.

7.   Source control insufficient

Ford is operating a hydraulic control structure (HCS) to prevent further off-site migration.  The DEQ requested additional information from Ford to demonstrate that the hydraulic control structure sufficiently accomplishes this.  If Ford cannot demonstrate that the HCS sufficiently accomplishes control of off-site migration, Ford will be required to perform additional actions.  The request for additional information regarding the HCS was included in the DEQ approval of the Remedial Investigation Response Activity Plan with modifications letter.

8.   No confidence in HCS

The DEQ requested additional information from Ford to demonstrate that the HCS is sufficiently preventing further off-site migration of contamination from the on-site source(s).  The DEQ will require additional actions from Ford if this cannot be demonstrated.

9.   Target detection level for groundwater

The calculated site-specific criteria for vinyl chloride in groundwater is lower than the target detection limit (TDL) of 1 part per billion (ppb).  Some labs can estimate concentrations below 1 ppb but setting criteria below the TDL requires the concentrations be quantifiable, not estimated; therefore, the TDL of 1 ppb is used as the criteria for vinyl chloride in groundwater.

10.   Source characterization is insufficient

The response activity plans propose to further characterize the sources.

11.   Reject divided plume

The DEQ is requiring Ford to install additional wells and collect additional data to investigate if the "groundwater divide" plume model is accurate.  This is specified in the DEQ’s approval with modifications letter.

12.   Reject "clean lens" theory

The DEQ concurs that sufficient evidence has not been collected to support Ford's "clean lens" theory.  The response activity plans include installation of additional shallow wells to collect data to allow for further analysis of this theory.

13.   Require immediate mitigation

The consent decree requires immediate mitigation if it has been demonstrated with data that an immediate risk is present.  If the results from data collected from the implementation of the response activity plans detects an immediate risk, such as an elevated indoor air sample above the time sensitive interim response level, Ford will be required to conduct immediate mitigation.

14.   Testing in home

The response activity plans require Ford to conduct sub-slab soil gas testing beneath homes within the plume.  Indoor air samples will be collected if the sub-slab sampling shows a potential issue or in other circumstances where risks may be present and sub-slab samples are not feasible. 

15.   NAPL beneath the transmission plant needs to be investigated     

The consent decree requires defining the extent of and addressing non-aqueous phase liquids (NAPL) for the area of concern.

16.   Rejects Ford's position of no impact to neighborhood     

The DEQ concurs that Ford has not provided adequate information to support their claim of no impact to the neighborhood.  The data collected per the response activity plans will provide the necessary information to make this evaluation.

17.   Concern Ford drives DEQ decisions

The consent decree dictates the actions Ford is required to take and the role of the DEQ in administering and overseeing the actions in the consent decree.  The consent decree is a legally enforceable document under the authority of the court.

18.   Groundwater concentration variability concern    

The response activity plans require Ford to install additional wells to investigate the groundwater and to collect additional samples which will assess variability within the groundwater.

19.   Requests continuous soil-gas monitoring to correct for weather variability      

The response activity plans require Ford's soil-gas samples to be representative of varying environmental conditions, considering HVAC operation, inhabitant activity, seasonal variation, and other factors.

20.   Concerned about stormwater rerouted to Rouge River   

The DEQ is requiring a utility corridor investigation as part of the response activity plans modified approval.

21.   Concern for plant workers   

The Michigan Occupational Safety and Health Administration (MIOSHA) oversees issues of health and safety for plant workers.  The DEQ has requested Ford to ensure they are following MIOSHA requirements.

22.   Deny response activity plans          

The response activity plans will collect additional information required to determine risk, further define the plume, and provide data needed to determine appropriate response activities that may be needed.  The plans are in compliance with the requirements of the consent decree.

23.   Not enough samples collected       

The response activity plans require Ford to install additional wells and collect additional data, and the DEQ modifications require additional data be collected.

24.   Mention of former creek     

The DEQ examined historical maps and identified the former creek and will request Ford to evaluate the potential influence of the former creek on the groundwater and hydraulic conductivity.