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):
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.
The DEQ staff will provide random and occasional oversight of sampling procedures and methodology; including split sampling for analysis at the DEQ laboratory.
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.
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.
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.
The DEQ will continue to require Ford to complete delineation of the dense non-aqueous phase liquid (DNAPL) plume.
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.
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.
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.
The response activity plans propose to further characterize the sources.
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.
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.
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.
The consent decree requires defining the extent of and addressing non-aqueous phase liquids (NAPL) for the area of concern.
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.
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.
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.
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.
The DEQ is requiring a utility corridor investigation as part of the response activity plans modified approval.
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.
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.
The response activity plans require Ford to install additional wells and collect additional data, and the DEQ modifications require additional data be collected.
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.