Washtenaw County, Ypsilanti, RACER Willow Run

Updated: November 15, 2019

636 40th Street East MapBackground

RACER Willow Run began in 1941 as a bomber plant developed by Ford for the Department of the Army. Operations at this location primarily included machining, cleaning, painting, and assembly of metal parts and products for war armaments and automotive transmissions. It is located at 2930 Ecorse Road in Ypsilanti Township. Since 1980, the Site has been regulated as a facility under the Resource Conservation and Recovery Act (RCRA). PFAS was sampled according to Ypsilanti Community Utility Authority (YCUA) industrial pre-treatment program.

Recent Accomplishments

  • On October 18,  2019, EGLE presented  remedial treatment alternatives to treat groundwater collected by the French Drain system at the Great Lakes Environmental Remediation and Redevelopment conference.
  • RACER continues to report updates to YCUA regarding the wastewater discharge.

Next Steps

  • RACER Trust and EGLE continue a study of water discharged to YCUA to identify possible PFAS treatment alternatives.  This study will continue until a treatment solution is determined.

Residential Well Testing/Alternate Water Information

  • Surrounding residents are on municipal water, however, there are some residential drinking water wells located north (up-gradient) of the facility. No residential or commercial drinking water wells have been identified to be threatened by groundwater contamination.
  • There are current restrictive covenants for the facility which prevent groundwater from being used as a source for drinking water on-site.
  • EGLE has tested all municipal water supplies for PFAS. The city of Ypsilanti and YCUA are the municipal water for the area.  The City and YCUA purchase water from the Great Lakes Water Authority (GLWA). View the results for GLWA.
    • RACER discharges water to YCUA's Industrial Pretreatment Program.
    • YCUA has been approved by EGLE.
    • YCUA's program is regularly audited by EGLE to verify it complies with the appropriate regulations. 

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 

Mar 2018 - Apr 2019 44 44 3 18 23
Surface Water Nov 2018 - Apr 2019 7 7 0 7 0

Cumulative

  51 51 3 25 23

*Groundwater results are compared to EGLE Part 201 Criteria of 70 ppt PFOS+PFOA.
*Surface water results are compared to Rule 57 surface water quality values of 12 ppt for PFOS and 12,000 ppt for PFOA.


Sampling notes

  • Other PFAS analytes were detected in samples. There are no federal or state standards for these analytes.

RACER Willow Run Historical Timeline

Revitalizing Auto Communities Environmental Response Trust, also known as RACER Trust or just RACER, was created in March 2011 by the U.S. Bankruptcy Court, to clean up and position for redevelopment properties and other facilities owned by the former General Motors Corporation before its 2009 bankruptcy. The RACER Trust is one of the largest holders of industrial property in the United States and is the largest environmental response and remediation trust in United States history.

The RACER Willow Run (former GM Willow Run Powertrain) is located at 2930 Ecorse Road in Ypsilanti Township in Washtenaw County, Michigan (Site). The Site consists of approximately 315 acres of land surrounded by industrial, commercial, and residential development.  The Site is immediately west of Willow Run Airport.

Operations began at the Site in 1941 as a 4.8 million square foot manufacturing area supporting a bomber plant developed by Ford for the Department of the Army. There were various process operations over the years, including machining, metal cleaning, metal plating, painting, and assembly of metal parts and products for war armaments and automotive transmissions. The Site has been regulated as a Treatment, Storage and Disposal (TSD) facility under RCRA and Michigan’s Part 111, Hazardous Waste Management, since 1980.

GM has operated at the Site since the 1950s. GM filed bankruptcy in 2009, and in 2011, the bankruptcy courts made RACER Trust responsible for managing the environmental contamination on the property. In 2014, the Yankee Air Museum purchased approximately 145,000 square feet of the southeast portion of the building and approximately 17 acres of the Site. In 2016, the Willow Run Arsenal of Democracy, LLC purchased the remaining 298 acres.

Restrictive Covenants prohibit drinking groundwater, installing groundwater extraction wells on the property, relocating soil, and constructing buildings without EGLE review and approval.

Residential drinking water wells are located north of the Site; no residential or commercial drinking water wells have been identified to be threatened by groundwater contamination.

A French Drain groundwater collection system was installed onsite in 2016 to collect contaminated groundwater. The groundwater collected from the French Drain is discharging via a sanitary sewer to the YCUA) under an industrial discharge permit.

The existing storm water conveyances installed in 1941 were bulk headed in 2017 to prevent contaminated groundwater reaching Willow Run Creek.  Prior to 2017, groundwater and storm water was conveyed to YCUA.

  • On March 16, 2018, EGLE requested RACER sample the French Drain discharge to YUCA to comply with the Industrial Pretreatment Plan. RACER also sampled six monitoring wells located upgradient (west/north) from the French Drain.
    • Groundwater collection discharge had detections that ranged from 370 - 428 ppt PFOS+PFOA and 933 – 1,400 ppt Total Tested PFAS.
    • The six monitoring wells sampled had detections that ranged from 0 - 35 ppt PFOS+PFOA and 23 – 124 ppt Total Tested PFAS.
  • In May 2018, RACER collected a second sample from the French Drain discharge to confirm the March 2018 results. RACER also sampled five monitoring wells down gradient (east) of the French Drain, the individual sumps and corresponding cleanouts in order to evaluate if the equipment inside the stainless-steel sumps are contributing to the PFAS detections.
    • PFOS and PFOA were detected in the French Drain discharge with very similar levels to the March sampling results (414 ppt). Total Tested PFAS detected in the French Drain discharge was 933 ppt.
    • PFOS and PFOA were detected in one monitoring well at 164 ppt; that was the highest result for PFOS+PFOA out of the five monitoring wells. Total Tested PFAS ranged from 210 to 1360 ppt.
    • PFOS and PFOA were detected in two sumps, 113 and 214 ppt. Total Tested PFAS in the four sumps ranged from 72 to 402 ppt.
    • PFOS and PFOA were detected in one cleanout at 76 ppt. Total Tested PFAS in the four cleanouts ranged from 40 to 535 ppt.
    • PFAS is present on both sides of the drain prior to being collected by the French Drain
    • Between the March and May sampling events, the number of EGLE PFAS analytes tested for increased. Therefore, these additional parameters were added to the May and later events.
  • On June 14, 2018, EGLE received PFAS analytical results from the French Drain that were collected by RACER Trust. The highest result was 410 ppt PFOS+PFOA.
  • In June 2018, RACER and EGLE met with YCUA to discuss PFAS detections and the Industrial Pretreatment Plans -- Industrial User PFAS Screening and Evaluation Survey, which RACER had received in May 2018.
  • In June 2018, a groundwater sample was collected from an open pit/excavation in the vicinity of the French Drain and soils that were known from the previous investigation to be contaminated with things other than PFAS.
    • PFOS+PFOA was 55 ppt. Total Tested PFAS was 399 ppt.
  • In July and August 2018, investigation continued of the French Drain system components, including testing of equipment installed such as Teflon lined flow meters and other instrumentation. Where equipment could not be isolated, samples were collected before and after that point in the system (i.e. active pumps). Soil samples were collected adjacent to wells where PFAS was detected to evaluate soil concentrations near the French Drain. Groundwater that had accumulated in the historical bulk headed storm sewer system and groundwater from background monitoring wells were sampled and to see if PFAS was present within the larger groundwater area at the Site. 
    • Low levels of PFAS (less than 5 ppt) in equipment blanks and inconsistent results between pieces of equipment did not show that the pumps, flow meters, or instrumentation were significant sources of PFAS compared to the concentrations detected in the groundwater and French Drain discharge. 
    • PFOS and PFOA were not detected in the background monitoring wells. Total Tested PFAS ranged from 0.23 - 3 ppt.
    • PFOS and PFOA were detected in the bulk headed sewer samples and ranged from 39 - 74 ppt. Total Tested PFAS ranged from 334 - 760 ppt.
    • PFOS and PFOA detections ranged from 0 - 11,000 ppt in the soil samples. Total Tested PFAS ranged from 70 - 13,000 ppt.
    • Concentrations at the French Drain discharge point are consistent with previous results, which is expected with a steady-state groundwater collection system.
  • In November 2018, RACER submitted a PFAS pollution reduction plan to YCUA which involved further monitoring of PFAS and evaluating potential treatment options and reduction/eliminating PFOS and PFOA. YCUA requested quarterly PFAS sampling from the discharge.
  • In November 2018, the American Center for Mobility, the operator of the site, collected storm water samples from Outfalls 03, 04 and 05 for PFAS at the request of the Washtenaw County Water Resources Commissioner.  PFOS samples were 5, 9.4, and 3 ppt respectively and PFOA results were 2.3, 8.9, 6.4 ppt. None of the samples exceeded the Water Quality Standard of 12 ppt for PFOS.  In addition to PFAS, the surface water sampling included metals, volatile organic compounds and semi-volatile organic compounds, PCBs, pesticides, oil and grease, and phosphorus.
  • In December 2018, RACER initiated the onsite pilot study to determine the effectiveness of reducing PFAS concentrations using advanced oxidation and ultraviolet light. RACER also started a bench scale laboratory study, testing alternative PFAS removal technologies, including granular activated carbon, and ion exchange resins.
  • In February 2019, RACER met with EGLE and presented the December 2018 pilot study findings.
  • In March 2019, RACER provided a memorandum of pilot study findings to YCUA and EGLE that included a high-level update on the Site PFAS treatment methods evaluation. 
  • In April 2019, RACER and EGLE met with YCUA to discuss progress of the PFAS pilot study activities conducted at the Site.
  • On April 29, 2019, EGLE collected surface water samples from Willow Run Creek.
  • On May 21, 2019, EGLE received the results from the April surface water sampling. Samples collected near outfalls from the RACER Trust properties did not exceed water quality standards.
  • In May 2019, EGLE collected surface water samples from Willow Run Creek (Washtenaw County) on April 29, 2019 and reported the results on May 21, 2019. Samples collected near outfalls from the RACER Trust properties did not exceed HNV.  Concentrations of PFOS did exceeded the HNV in Willow Run creek at two locations, WR0010 and WRW0100. WR0010, located near the I-94 service drive, had a similar concentration to a previous surface water sample collected in 2018. There may be potential sources of PFAS in Willow Run creek upstream of the I-94 Service Drive, in the west tributary of Willow Run, and at the Willow Run Airport outfall WROF002. PFOS in outfall surface water sample WROF002 on main stem of Willow Run Creek was 92 ng/L and exceeded the HNV. 
  • In June 2019, EGLE contacted public officials regarding the May sample results and held a public meeting. RACER continues to evaluate remedial treatment alternatives for groundwater contamination.
  • On June 20, 2019, EGLE staff participated in a public meeting hosted by Representative Ronnie Peterson.  The meeting was to provide an update on the RACER Willow Run site. 
  • On September 25, 2019, EGLE and YCUA received a report from RACER regarding PFAS Treatment Methods Evaluation Summary.
  • On October 18, 2019, EGLE presented PFAS Treatment Methods summary at the Great Lakes Environmental Remediation and Redevelopment conference.
  • On November 15, 2019, EGLE, RACER, YCUA and Ypsilanti Township meeting to discuss a number of ongoing Issues pertaining to PFAS.