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Former Keeler Brass - 32nd Street (Kentwood, Kent County)

EGLE Site Lead: Jason Poll, PollJ@Michigan.gov or 616-446-1263. Webpage last updated August 27, 2021.

Background

Located at 2929 32nd Street, this facility was owned by Keeler Brass from the 1960s through 2016. Processes at this location included automotive parts washing and metal plating. There are two known contaminant plumes: the central plume, primarily impacted with trichloroethylene (TCE) but also PFAS, and the western plume, primarily impacted with metals and PFAS from the plating operation. The release of plating fluids (western plume) was identified at the facility in the 1980s, which initiated an immediate cleanup and groundwater investigation and response, including the installation of a groundwater remediation system. There is a tributary to Plaster Creek present along the western boundary of the facility and residential homes present to the south of the facility, therefore, groundwater collection trenches were installed to prevent contaminated groundwater from migrating offsite in those locations. 

In 2018, as part of the Industrial Pretreatment Program (IPP), the City of Grand Rapids conducted a PFAS survey. PFAS was found at elevated levels in the wastewater generated at the former Keeler Brass facility. The wastewater is pretreated groundwater derived from the remediation systems, and additional treatment has been installed to address PFAS in the wastewater.

Former Keeler Brass 32nd Street Fig 1 PFAS Site Map Oct 2019

Recent Accomplishments

  • On July 19, 2021, EGLE received a letter documenting the collection of 45 groundwater samples from the facility on April 26-27, 2021 and May 4-6, 2021. Groundwater samples were collected from both known plumes at the facility and the results appeared consistent with those previously reported for the wells. Based on updated information, additional work is needed at the facility since the existing monitoring wells do not define the extent of the PFAS contamination. 

Next Steps

  • PFOS was detected in the surface water at concentrations above surface water quality standard, therefore, additional work is warranted to assess water quality in the tributary.
  • EGLE has contacted the consultant to request additional remedial actions, notification to off-site property owners (as warranted), and further investigation.
  • EGLE has commenced escalated enforcement activities at this and other former Keeler Brass facilities to compel additional investigation and compliance with Michigan’s environmental laws.

Residential Well Testing/Alternate Water Information

  • There are no known drinking water wells in the area.
  • Nearby residences to the south and non-residential developments to the west are on municipal water; drinking water in the area is municipal from the city of Grand Rapids.
  • The Michigan Department of Environment, Great Lakes, and Energy (EGLE) has sampled all municipal water supplies for PFAS. View the results for the City of Grand Rapids. 

Upcoming Community Engagement

  • None scheduled at this time.

Sampling Results Summary

Type of Sample

Date Sampled (or Range)

Number of Sample Results Received

Number of Samples above Criteria*

Groundwater Monitoring Wells

April - May 2021 45 30

* 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

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. 

Historical Timeline

    • On May 22, 2019, based on the facility’s history and established presence of a groundwater collection trench for environmental remediation, EGLE sent a letter requesting that Keeler Brass develop a work plan to assess the presence of PFAS contaminants in the groundwater.
    • On June 28, 2019, Keeler Brass’ consultant responded to EGLE’s initial inquiry with a letter, wherein they refused to conduct an additional PFAS assessment, because their previous and ongoing work to delineate and remediate the plume for metals would also address PFAS and because they were installing additional pretreatment for PFAS in the wastewater.
    • On July 24, 2019, EGLE issued a violation notice further requesting a work plan for additional investigation, and following an October 23 meeting, the company’s consultant will be submitting a PFAS groundwater investigation plan. 
    • On October 23, 2019, EGLE met with Keeler Brass’ attorney and consultant to discuss the July 24, 2019 Violation Notice and discuss, in general terms, the scope of the requested workplan.
    • On November 3, 2019, EGLE received a laboratory analytical reports that were previously on file with the city of Grand Rapids Wastewater Treatment Plant.  The reports included results of additional groundwater treatment system influent and effluent PFAS sampling conducted as a requirement for IPP permit compliance and PFAS reduction requirements.  The sampling chart has been updated to reflect the additional samples.
    • On November 8, 2019, EGLE received additional information from the Kent County Health Department further confirming the absence of water wells in the area of PFAS investigation
    • On November 26, 2019, EGLE received a work plan which outlined a number of groundwater wells to be sampled for PFAS downgradient of the western and central plumes.
    • On December 17-19, 2019, groundwater sampling was conducted from a select number of wells onsite.
    • On March 23-25, 2020, surface water and groundwater sampling were conducted.
    • On May 4, 2020, EGLE received a report summarizing the findings of the December 2019 and March 2020 sampling events.  Based on this information, groundwater containing PFAS was detected downgradient of the existing groundwater capture systems at concentrations greater than the Part 201 Drinking Water and Groundwater Surface Water Interface Cleanup Criteria. The capture trench does not appear to have prevented the migration of PFAS (namely PFOS) offsite, additional work is needed. 
    • On May 8, 2020, EGLE notified the liable party that additional work was needed to complete delineation of PFAS in both plumes, provide Notices of Migration to offsite property owners, and further assess PFAS in the creek.
    • On June 4, 2020, EGLE received notification from the consultant that additional work to address PFAS would be halted for 90 days due to financial hardships caused by the COVID-19 pandemic.
    • Sampling Data Summary: PFOS and PFOA Only

      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

      July 2018 - March 2020 32 32 5 1 16
      Surface Water March 2020 3 3 0 0 3
       Cumulative   35 35 5 11 19

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

       

      • July 2018 through October 2019 data summary table provided to EGLE by the city of Grand Rapids as part of the IPP survey. At that time, groundwater treatment system influent, intermediate (as needed), and effluent sampling was conducted, however, only groundwater influent samples have been included in the table above since they represented facility groundwater concentrations.