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Electro Chemical Finishing - Remico (Wyoming, Kent County)

Electro Chemical Finishing - Remico (Wyoming, Kent County)

EGLE Site Lead: Jason Poll, PollJ@Michigan.gov or 616-446-1263. Content last updated January 13, 2020.

Background

This site is located at 2610 Remico Street SW. The Electro Chemical Finishing (ECF) facility had a release sometime before December 11, 2014, when a discharge of plating wastewater to Roys Creek was observed coming from a stormwater outfall. The origin of the release appeared to be a breach in the floor where plating water entered the ground, flowed beneath the concrete floor to a point where a roof drain elbow and pipe were separated, and into the storm sewer system.

Following the repair and resolution of this breach, ECF conducted an investigation to determine the extent of the plating wastewater impact. A plume of contaminants other than PFAS was discovered extending to the north. ECF installed a groundwater extraction system for on-site treatment and discharge to the sanitary sewer. As part of EGLE’s Industrial Pretreatment Program (IPP), the City of Wyoming sampled ECF’s wastewater. Due to the results of the wastewater testing, and the facility’s history as a plater, EGLE requested ECF to create a workplan and begin sampling.

The Grand River is located about 1.8 miles downgradient from the site. There is a small private pond about 600 feet northeast of the groundwater extraction well on the property. Groundwater flow is primarily to the north, parallel to Roys Creek.

Electro Chemical Finishing Company Remico Aerial Map

Recent Accomplishments

  • On September 22, 2021, EGLE was notified of onsite work for the purpose of groundwater and surface water sampling being conducted by ECF at select locations.
  • On October 12, 2021, EGLE sent a Notice of Insufficient Information letter to ECF following review of the August 20, 2021, Response Activity Plan Evaluation Plan. Based on EGLE’s review, there was not adequate information in the report or the file to complete the review. EGLE requested additional information related to the conceptual site model (the hydrogeology of the site and other information), the use of existing wells for monitoring, and provide laboratory data.
  • On December 1, 2021, EGLE was briefed on the detection of PFAS in several monitoring wells sampled at the Spartan Chemical site to the north. Based on preliminary review of data, this may be from the EFC site since PFAS use was not established at the Spartan Chemical site.
  • On December 9, 2021, ECF submitted a Status Report presenting the findings of the sampling conducted on September 22, 2021.Seven wells were sampled, and one surface water sample was collected from the nearby ornamental pond at the Arbor Lakes Condominium and Apartment complex.
  • On December 14, 2021, the Kent County Health Department visited the plume area to verify that no previously unidentified wells were present; none were identified.
  • On December 15, 2021, EGLE and ECF participated in a conference call to discuss recent analytical results and ongoing need for additional sampling and delineation.
  • On December 15, 2021, EGLE notified ECF that signage was necessary at the pond located at the Arbor Lake Apartment/Condominiums to prevent the consumption of fish from the pond. EGLE also reminded ECF of their obligation to notify the owner of the migration of contamination and that the pond water should not be used for irrigation.
  • On December 16, 2021, EGLE participated in a meeting with local governmental officials to discuss the detection of PFAS at the nearby Spartan Chemical site and the ECF facility.

Next Steps

  • EGLE will continue to work with ECF as they complete investigation and delineation of the PFAS plume.
  • EGLE’s Superfund group will perform PFAS testing of groundwater at the Spartan Chemical facility, which is a downgradient site of contamination, concurrent with planned remediation activities at that location.  This information will be used in conjunction with additional information gathered by ECF in the coming months to support the expansion of a groundwater use ordinance in the area following appropriate citizen engagement.
  • ECF will expand their existing wastewater treatment facility to remove PFAS and increase treatment capacity to provide additional groundwater extraction and remediation capacity.

Residential Well Testing/Alternate Water Information

Upcoming Community Engagement

  • None scheduled at this time.

Sampling Results Summary

This chart reflects data received after August 3, 2020. Data prior to August 3, 2020 is reflected in the timeline below.

This table was updated to include all seven PFAS criteria effective December 21, 2020.

Type of Sample

Date Sampled (or Range)

Number of Sample Results Received

Number of Samples above Criteria*

Groundwater

 April 17, 2019 - September 22, 2021 31 28
Surface Water October 1, 2020 - September 22, 2021 2 2
 

* Residential well and groundwater monitoring well results are compared to EGLE Part 201 criteria for 7 PFAS compounds:  PFOS (16 ppt), PFOA (8 ppt), PFNA (6 ppt), PFHxS (51 ppt), PFHxA (400,000 ppt), PFBS (420 ppt), and HFPO-DA (370 ppt).
* Surface water samples are compared to Rule 57 non-drinking water values of 12 ppt for PFOS and 12,000 ppt for PFOA. 

Sampling Notes

  • On August 3, 2020, new Part 201 Criteria went into effect. Historical sampling data compared to Part 201 Criteria >70 is captured in the historical timeline below.
  • Other PFAS analytes were detected in samples. There are no federal or state standards for these analytes.
 

Historical Timeline

    • On February 13, 2019, ECF’s environmental consultant collected one sample from the on-site purge well system (a groundwater treatment system) at the northeastern portion of the property.
    • On March 8, 2019, EGLE was informed of the sampling results. The result was 2,000.33 ppt PFOS+PFOA and 4,364.63 ppt Total Tested PFAS.
    • On April 16, 2019, EGLE and ECF reached an agreement on a multi-step work plan to assess and investigate PFAS impacts to groundwater.
    • On May 16, 2019, EGLE was provided a Status Update Report which included the results of the November 2, 2018 PFAS sampling conducted on groundwater collected from the extraction well.
    • Groundwater samples (including supply wells) were collected on April 17-18, 2019 and presented to EGLE in a report dated May 29, 2019.  Results demonstrated that all eight groundwater monitoring wells and three water supply wells contained detectable concentrations of PFAS; an area of groundwater impacted with PFAS was demonstrated in the same area as the previously established metals plume but additional delineation is needed.  Seven of the monitoring wells and one supply well contained PFOA+PFOS at concentrations greater than 70 ppt (this supply well is not in use and the location was connected to city water in 2017, the other supply wells are not used for drinking). 
    • ECF continues to work with EGLE to investigate the presence of PFAS in the subsurface in accordance with Part 201 concurrent with the investigation and monitoring of previously-identified contaminants in the groundwater.
    • ECF’s consultant completed a records investigation of the water supply for all parcels downgradient in the direction of the plume migration and determined that all parcels are on Wyoming municipal water or have no water supply. There are no known private wells downgradient of ECF other than the ones already sampled.
    • ECF’s efforts have been focused on PFAS minimization in their effluent to Wyoming POTW.  Concurrently they are investigating alternative wastewater treatment processes to replace or supplement their existing batch treatment process to capture PFAS from their effluent and increase their overall throughput capacity for expanded groundwater remediation.
    • ECF and its consultant are working through a plan to implement an areawide groundwater use restriction to address the chromium, nickel, and PFAS impacted area.
    • An additional round of groundwater samples was collected in December 2019; results are expected in February 2020.
    • On March 19, 2020, EGLE received a status update report containing the results and findings of additional groundwater sampling conducted in December 2019.
    • On March 30, 2020, EGLE hosted a conference call between ECF stakeholders and the environmental consultant to conceptualize a work plan for the additional work needed to delineate the extent of PFAS contamination.

    Historical Sampling Chart: Data is reflective of criteria prior to August 3, 2020,  PFOS and PFOA Only

    This chart reflects data received prior to August 3, 2020.

    Type of Sample

    Date Sampled (or Range)

    Number of Samples

    Number of Results Received

    		 Number of Non-Detects  Number Between Non-detect and Standard*  Number Greater Than or Equal to Standard 

    Groundwater

    		November 2, 2018 - December 3, 2019 17 17 0 5 12
     Cumulative
    		17 17 0 5 12
     *Groundwater results are compared to EGLE Part 201 Criteria of 70 ppt PFOS+PFOA.
    • Due to the COVID-19 pandemic, investigation progress was slowed in 2020.  EGLE worked with ECF over the months of June to September to develop an interim sampling work plan to further assess the groundwater plume with regard to Roys Creek to the west and an ornamental pond at apartments to the east.
    • On September 30, 2020, EGLE reviewed and approved an interim sampling plan for further investigation of the groundwater and surface water in the area of concern.
    • October to December 2020, ECF conducted groundwater, surface water, and process wastewater sampling.
    • On December 22, 2020, ECF submitted details regarding the facility's conversion from PFOS-containing chemicals to alternative non-PFOS chemicals in their plating fluids.
    • On January 8, 2021, ECF’s consultant provided a supplemental report detailing the results of sampling conducted at the facility in October-December 2020.Based on this information, it did not appear that the PFAS plume was interacting with Roys Creek in a significant way. Additionally, a surface water sample was collected from the ornamental pond at the Arbor Lake Apartment complex; results of this sampling confirmed concentrations of PFOS at 15 ppt which is above the surface water quality standard of 12 ppt.
    • On August 20, 2021, EGLE received a Response Activity Plan Evaluation Plan detailing work proposed by ECF to further investigate the PFAS plume to the north, northeast, and east.