Livingston County, Howell, Diamond Chrome Plating (DCP)

Updated: March 10, 2020

PFAS Groundwater Detection Summary Phase I & II - Diamond Chrome PlatingBackground

This site is located at 604 S. Michigan Avenue and has operated as a chrome plater since 1953. PFAS surfactants were used to suppress vapors resulting from the chrome plating operations. Diamond Chrome Plating (DCP) began sampling for PFAS in their groundwater, treated storm water, and sanitary sewer discharge to the City of Howell Wastewater Treatment Plant in the Spring of 2018 using granulated activated carbon to capture PFAS prior to discharge.

Recent Accomplishments

  • On January 10, 2020 a newly discovered residential well was sampled.  Sample results indicated no detections of PFOS or PFOA.  The sampling frequency for this residential well will be increased because a variety of non-regulated PFAS was detected at 5.5 ppt.

Next Steps

  • DCP continues to monitor for PFOS and other PFAS in its storm water and industrial discharges to the city of Howell Wastewater Treatment Plant. DCP monitors its storm water treatment system for PFAS at two outfalls.  DCP presently treats PFAS contaminated groundwater at its on-site wastewater treatment plant using 5 vessels of granulated activated carbon.  
  • EGLE has engaged with DCP to complete PFAS sampling for all its monitoring wells and request performance monitoring to document PFAS groundwater cleanup.
  • All 5 residential wells to be re-sampled for PFAS prior to April 1, 2020.
  • Enforcement actions relating to DCP's consent decree and a stipulated order to address PFAS releases to the storm water system are in progress.

Residential Well Testing/Alternate Water Information

  • Five residential wells have been tested by EGLE and all are non-detect for Total Tested PFAS in two sampling events.
  • Biannual sampling of the 4 residential wells set in a deeper aquifer not known to be contaminated with PFAS. No PFAS detections in residential wells to date.
  • Re-sampling of residential wells for PFAS scheduled for March 2020

Upcoming Community Engagement

  • None scheduled at this time.
Sampling: PFOS and PFOA Only

Type of Sample

Date Sampled

# of Samples

# of Results Received

# of Non-detects

# Between Non-detect and standard*

# > Standard

Groundwater

Sep 2018 - 
Jan 2020

19 19 4 6 9
Drinking water (residential wells) Nov 2018 - Jan 2020 9 9 9 0 0
Cumulative   28 28 13 6 9



*Groundwater results are compared to EGLE Part 201 Criteria of 70 ppt PFOS+PFOA.
*Residential well results are compared to the EPA Lifetime Health Advisory Level of 70 ppt PFOS+PFOA.    

Sampling notes

  • Other PFAS analytes were detected in samples. There are no federal or state standards for these analytes.
  • Samples collected by DCP only report PFOS and PFOA; no other analytes. Samples collected by EGLE report additional analytes.

Historical Timeline

This site is located at 604 S. Michigan Avenue in Howell and has operated as a hard chrome plater since 1953.  PFAS surfactants were used to suppress vapors. This facility has had multiple releases of hexavalent chromium, cadmium, cyanide, lead, chlorinated Volatile Organic Compounds (VOCs), petroleum VOCs and other contaminants to the storm and sanitary sewer systems and into the groundwater. In July 2006, DCP entered a legal compliance agreement with EGLE, which was amended in July 2015. DCP completed response activities to address numerous releases, including lining/sealing portions of the sanitary and storm sewers. DCP began sampling for PFAS in their groundwater, treated storm water and sanitary sewer discharge to the City of Howell Wastewater Treatment Plant in the Spring of 2018.

DCP continues to have numerous compliance issues – including PFAS exceedance in the groundwater – which they are currently addressing through the compliance agreement with EGLE:

2018

  • On May 24, 2018, DCP sampled untreated and treated storm water discharging to the city of Howell storm sewer.  Analytical results for the untreated storm water was 12,000 ppt PFOS and the treated stormwater was 6,900 ppt PFOS. The treated storm water travels approximately 2/3 of a mile prior to discharging to the Marion-Genoa Drain which is a tributary to the south branch of the Shiawassee River. 
  • On May 28, 2018, DCP sampled the storm water outfall to the Marion-Genoa drain and found PFOS at 57 ppt which exceeded water quality standards.
  • On May 22, 2018, DCP sampled their sanitary sewer discharge as part of EGLE’s Industrial Pretreatment Program (IPP). Results from this sample were 2,000 ppt PFOS. To address this, DCP added carbon to its wastewater treatment to bring PFOS levels down to compliance levels.
  • On July 23, 2018, DCP collected samples from five selected groundwater monitoring wells for analysis of PFOS and PFOA and found concentrations above drinking water criteria for two of the monitoring wells:  one well was 25,009 ppt and another was 560 ppt.  Groundwater in the shallow and deep aquifers flow in a southerly direction. 
  • On November 26, 2018, EGLE collected two residential samples from homes southwest of DCP that are not connected to municipal water. These two homes have been monitored by EGLE for other contaminants in the past.
  • On December 3, 2018, EGLE received PFAS analytical results for City of Howell Well #1 and #7 did not detect PFAS above the reporting limits.
  • On December 6, 2018, DCP collected groundwater samples from five additional groundwater monitoring wells and resampled a monitoring well with the highest concentrations of PFOS.  The analytical results found PFOS+PFOA above drinking water criteria in five of the six monitoring wells, including a deep monitoring well, which was resampled on January 9, 2019, by DCP with a EGLE split sample.
  • On December 27, 2018, EGLE received results from the two residential samples taken in November. Both samples were Non-Detect for Total Tested PFAS. The homeowners were notified within 24 hours of receipt of the results.

2019

  • On January 2, 2019, EGLE staff collected a split sample from DCP’s deep sentinel monitoring well to determine if previous sample results above drinking water criteria were due to cross-contamination.  Analytical results indicate shallow well PFAS cross-contamination to the deep well sample. Resampling indicated that PFAS was not present above reporting limits in the deep well. 
  • On January 6, 2019, DCP resampled a deep monitoring well due to suspected cross contamination from a shallow monitoring well. Cross-contamination resulted in false positive of180 ppt PFOS in the deep well that showed PFOS at 1.6J (below reporting limit). 
  • On February 6, 2019, DCP collected five additional groundwater samples from five different monitoring wells; the highest result was 30,000 ppt PFOS. This specific sample came from the well located near DCP’s southeast property line.
  • In February 2019, the Michigan Department of Environment, Great Lakes, and Energy (EGLE), in cooperation with the Livingston County Health Department, conducted a residential well survey in the area and found two additional residential wells to be sampled for PFAS and other parameters.
  • On February 21, 2019, EGLE scheduled the sampling of two additional residential wells discovered during the well survey for March 26, 2019.
  • On March 26, 2019, EGLE staff collected two residential well samples located ½ mile south of DCP on Michigan Avenue.
  • On April 15, 2019, EGLE received the results for the two residential wells sampled in March; results showed no detectable levels of PFAS.
  • On April 23, 2019, DCP’s notice of migration included updated groundwater monitoring well PFAS analytical sample results. DCP has sampled 17 of its monitoring wells for PFAS. Additional sampling of other monitoring wells for PFAS are still pending.
  • As of June 6, 2019, DCP continues to treat captured groundwater for PFAS and other contaminants. DCP monitors its PFAS discharge to the City of Howell wastewater treatment plant. DCP’s treatment of contaminated groundwater is limited by its permitted discharge volume.
  • By letter dated July 2, 2019, DCP was notified to complete PFAS groundwater sampling under its plant and in off-property monitoring wells not yet sampled.
  • EGLE's July,2 2019 request to sample additional monitoring wells was not completed by DCP. Follow-up request and/or exercising enforcement options pending.
  • On July 8, 2019, there was a multi-site PFAS Livingston County informational session sponsored by Congresswoman Elissa Slotkin from 6:30 to 8:00 PM at Tasch Performing Arts Center 2100 E. M-36, Pinckney 48169.  EGLE staff were available to answer questions regarding this and other PFAS facilities in Livingston County.
  • On July 26, 2019, EGLE met with DCP.
  • On September 3, 2019, DCP installed three additional off-property monitoring wells not yet sampled for PFAS.
  • On September 4, 2019, DCP resampled MW-2 where 160 ppt PFOS detected (previous concern for cross-contamination), per EGLE’s request.  DCP did not sample the other monitoring wells EGLE requested in the July 2, 2019 letter.
  • On September 11, 2019, EGLE and MPART staff completed a review of Diamond Chrome Plating’s proposed PFAS wastewater treatment plan and are drafting a reply that does not support the current proposal.
  • On September 13, 2019, MPART Technical Review Team reviewed DCP’s proposal to substitute un-proven PFAS wastewater treatment technology.  MPART and EGLE issued questions for DCP to answer to justify changing its PFAS treatment technology. 
  • On September 17, 2019, EGLE staff re-sampled 4 residential wells for PFAS.   Laboratory results indicate that PFAS was not detected at 1.9 ppt reporting limit.
  • In November 8, 2019, a sentinel monitor well sampled for PFAS – 11 ng/l PFOS; 2.0 ng/l PFAS which is below current regulatory thresholds.
  • In late fall, 2020, an additional residential well was discovered within ¼ mile of the PFAS groundwater contamination.  Permission to sample the well for PFAS obtained in early January, 2020.
  • Sample results from the newly discovered residential well did not indicate PFAS or PFOA.  The presence of a non-regulated PFAS at 5.5 ng/l (FOSA) will prompt more frequent sampling of this residential well.
  • On November 6, 2019, DCP was issued a violation notice for exceeding water quality standards for PFAS for its treated storm water.  DCP was notified that PFOS exceeded 20 ppt targeted water quality limits to the city of Howell storm water system on 18 occasions from November 2018 to September 2019.  Maximum PFOS concentrations released to the storm sewer for this period is 3,900 ppt.
  • On November 21, 2019, a public meeting was held at Parker High School in Howell due to a non-PFAS public health order issued to DCP to cease emissions of a volatile organic compound (trichloroethylene) beyond its property line.  EGLE staff answered questions relating to PFAS contamination at this facility.
  • On December 11, 2019, DCP was sent a letter to inform them that their contamination investigation for the groundwater pathway which includes PFAS groundwater sampling has not been completed.