White Lake 29 CPF incident

Clean-up operations and verification sampling have concluded at the White Lake 29 Central Production Facility as it relates to the November 24, 2023, incident. Based upon review of the data, EGLE staff agree that the remediation activities have resulted in a reduction of hydrocarbons and chlorides in soil and groundwater to below relevant Part 201 Generic Residential Cleanup Criteria as indicated within the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. Therefore, no further clean-up or response activities are considered necessary.  Additional approvals from EGLE will be required in order to re-activate the well and re-build the facility at this location and to date the operator has not submitted any plans to do this work.

The Oil, Gas, and Minerals Division has reviewed the final report from Global Environmental and the site is moving towards closure. Hound Resources has an upcoming semi-annual sampling event of the existing monitoring wells near the tank battery and if these sample results are below clean-up criteria a “No Further Action” letter will be drafted, and the clean-up related to the spill and incident will be closed.

• PFAS impact analysis has been completed by Global Environmental and has been reviewed by Michigan PFAS Action Team (MPART) Specialists. The analysis of the firefighting foam indicated that the parameters were non-detect for total PFAS and total oxidizable precursor PFAS and through previous work done by the Massachusetts Department of Environmental Protection (MassDEP) and the Connecticut Department of Energy and Environmental Protection (CTDEEP) of various PFAS-free/fluorine-free firefighting foams. Based upon the information gathered from these sources, including laboratory analyses, manufacturer specifications, and evaluations by authoritative bodies, the results consistently support the absence of PFAS, including precursors, in the firefighting foam used during this incident. Global Environmental will be providing additional documentation summarizing remedial efforts at the site including a separate update from the lab.

• Results of the 1/22/2024 sampling in the excavated areas by Global Environmental and 3^rd party laboratory analysis indicate:
• No Hydrocarbon Indicator Parameters were found above laboratory detection limit in any of the collected samples and are all below Part 201 Residential Soil Cleanup Criteria. 
• Chlorides were detected at low levels at several locations, but all samples are below Part 201 Residential Soil Criteria for Residential Drinking Water Protection Criteria.
• Global Environmental conducted research on the fire-fighting foam used during the incident and found documentation from several studies that PFAS compounds and breakdown chemicals associated with PFAS are not found in the brand of fire-fighting foam used. Samples of the source material have been collected and are being analyzed to verify the claims in the studies. Additional analysis is being completed and the final laboratory report is expected soon.

• Hound Resources contracted M.L. Chartier to excavate and truck remaining impacted soils from the former secondary containment area. Excavated soils were directly loaded into trucks and disposed at Eagle Valley Landfill in Orion Township, MI. The soils were excavated around the perimeter of the containment area to remove any soils that may have been exposed to fire-fighting foam and petroleum impacted soils. Additionally, soils were excavated from two locations from the floor where elevated chlorides were found during the initial soil sampling event.
• Global Environmental was onsite on 1/22/2024 to complete verification sampling from the excavated areas. Soil samples were collected and taken to a 3^rd party laboratory for analysis. Expected results in early February 2024.
• Hound Resources provided verbal indications that PFAS data collected from the groundwater monitoring wells and the initial soil sampling had no detections of PFAS compounds. Additional analysis is being completed and the final laboratory report is expected soon.
• Hound Resources completed removal of tank lid on 1/23/2024 after getting approval from landowner to enter property.

 

• No Hydrocarbon Indicator Parameters were found above laboratory detection limit and were all below Part 201 Residential Soil Cleanup Criteria. 
• Chloride was below Part 201 Residential Soil Criteria for Residential Drinking Water Protection Criteria at all sample locations.
• Chloride exceeded Part 201 Residential Soil Criteria for direct contact standards at two locations. Additional excavation will occur at the two areas with elevated chlorides and additional samples will be collected to verify cleanup.
• Hound Resources continues to wait for analytical results for soil and groundwater samples collected for PFAS compounds analysis.  
• Hound Resources has scheduled additional excavation and verification sampling for the week of January 22nd, 2024. EGLE staff will be on location during these activities.

• Hound Resources completed shipping of wastes to two approved landfills on January 5, 2024. A total of 16 roll off boxes of soil/waste have been disposed. A total of 4 sludge boxes have been disposed.
• Sludges were disposed at Waste Management in Lennon, MI
• Soils were disposed at Waste management – Eagle Valley in Orion, MI
• Global Environmental was onsite on December 12, 2023, to collect floor samples from the excavated area. Six samples were collected from the base of the excavation and sent to a 3^rdparty laboratory for analysis. Expecting results on January 5, 2024.
• EGLE staff working with Hound Resources to schedule tactical excavation of limited impacted soils. During the initial soil sampling, several small areas, within the former containment, were discovered with petroleum odor and minor staining. Under the direction of EGLE and Global Environmental, soils will be excavated, and underlying soils will be sampled to verify that they meet regulatory standards.
• Global Environmental collected a sample of the Fire Fighting Foam to be analyzed at an accredited laboratory. Global Environmental has been working with EGLE staff to confirm that correct analysis and methods are used for this testing. Still awaiting results from analysis.
• EGLE staff walked nearby wetlands and surface water on January 5, 2024, to visually inspect conditions. Surface water has a thin ice layer, but no discoloration, sheen, oil, or foam was observed. EGLE staff also observed conditions from Whispering Meadows Drive to gain a wider and elevated view and found no evidence of impact.

• Hound Resources began shipping wastes to two approved landfills. A total of 16 roll off boxes of soil/waste are ready for disposal. A total of 4 sludge boxes are ready for disposal.
• Sludges were disposed at Waste Management in Lennon, MI
• Soils were disposed at Waste Management – Eagle Valley in Orion, MI
• Global Environmental was onsite on December 12, 2023, to collect floor samples of the soil from the excavated area. Six samples were collected from the base of the excavation and sent to a 3rd party laboratory for analysis.
• EGLE staff conducted additional evaluation of the excavation using a Photoionization Detector. Several locations, along the perimeter of the excavation, showed signs of impacted soils. Petroleum odor and oil staining were observed in limited quantities. Hound Resources is working with M.L. Chartier to schedule additional excavations in these areas to remove the impacted soils. Following the additional excavation, soil samples will be collected to confirm that the remaining soils meet regulatory standards.
• Global Environmental collected a sample of the Fire Fighting Foam to be analyzed at an accredited laboratory. Global Environmental has been working with EGLE staff to confirm that correct analysis and methods are used for this testing.
• Lab results from groundwater sampling conducted on December 6 and 7, 2023 (at the three on-site monitoring wells) came back this week. Chlorides were detected in one sample that were below regulatory standards and consistent with previous sampling and no hydrocarbon indicator compounds were detected.
• EGLE continued discussions with numerous residents and concerned citizens on the incident, potential environmental impacts, and oil and gas operations.

• Hound Resources continues cleanup operations with M.L. Chartier at White Lake CPF 29. Field observations for the cleanup appear to be promising.
• Groundwater sampling was conducting by Global Environmental on December 6-7, 2023 at three existing groundwater monitoring wells immediately surrounding secondary containment dikes. Samples were to be delivered to Merit Laboratories for analysis.
• Soil sampling is expected to take place on December 12, 2023. EGLE will be onsite to observe sampling procedures and locations.
• M.L. Chartier excavated multiple roll-off boxes of potentially impacted soils from below the secondary containment liner. Approximately 10-12” of sand fill and sandy loam soils were excavated across the entirety of the diked area (65’ x 65’) and placed in lined roll off boxes onsite prepared for disposal.
• EGLE staff evaluated the soils after excavation and observed sand to sandy loam soils with no staining and a very slight petroleum odor. EGLE used a Photoionization Detector (PID) and collected approximately 70 readings across the excavation. Maximum PID reading observed was 11.8 ppm. EGLE also did field testing at three locations to check for potential elevated chlorides in the soil. No elevated chlorides were observed during field testing.
• Hound Resources received approval from two landfills and will begin disposal processes this week. A total of 16 roll off boxes of soil/waste are ready for disposal. A total of 4 sludge boxes are ready for disposal.
• Sludges will be disposed at Waste Management in Lennon, MI
• Soils will be disposed at Waste management – Eagle Valley in Orion, MI
• EGLE continued discussions with numerous residents and concerned citizens on the incident, potential environmental impacts, and oil and gas operations.

• Hound Resources continues cleanup operations with M.L. Chartier at White Lake CPF 29.
• Hound Resources has contracted Global Environmental to conduct groundwater sampling on Wednesday, December 6, 2023. EGLE will be onsite during sampling activities.
• EGLE visually inspected nearby surface waters (small creek in the wooded area adjacent to the facility, wetlands to the south, and tributary to Lake Neva) and no impacts were observed.
• Last week brine and other fluids were removed from the secondary containment area and disposed at Aevitas Specialty in Detroit, MI.
• Thick crude oil and other wastes from the containment area were removed and placed in sludge boxes and are awaiting disposal.
• The liner was steamed, and fluids disposed at Aevitas Specialty in Detroit.
• Tank hatches were removed, and tanks cleaned. Tanks were removed from containment and placed on liner while awaiting disposal.
• Flow lines that were damaged in the incident were flushed, cut, and capped. Lines were placed on liner and covered while awaiting disposal.
• The secondary containment liner was removed from the tank battery and placed in 3 lined and covered roll off boxes.
• Soils below liner are a fine sand fill. Limited impact was observed (slight to moderate petroleum odor, no free product, and no stained soils were observed) and is believed to be very localized. Additional excavation and investigation will be conducted. Dike walls with charred liner were scrapped back and placed on plastic liner within excavation. Entire excavation area is covered with a plastic liner.
• Hound Resources is still awaiting landfill approval for sludges and soil disposal. Expected landfill for disposal is C & C Landfill in Marshall, MI. Hound Resources would like to direct load into trucks once they received landfill approval.
• Areas outside of containment where firefighting foam was used have had free liquids/foam removed. Additional excavation may be required.
• Hound Resources is removing top layer of soil/vegetation on the perimeter of the facility that had minor burning from the incident.
• EGLE had discussions with numerous residents, concerned citizens, and the Oakland County Health Department on the incident, potential environmental impacts, and oil and gas operations.