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Lacks Industries - Airlane (Kentwood, Kent County)

EGLE Site Lead: Jason E. Poll, CPG, PollJ@Michigan.gov or 616-446-1263. Content last updated January 14, 2022.

Background

Lacks Industries-Airlane (Lacks), located at 4260 Airlane Drive SE, is an active chrome plating facility.  In 2000, Lacks conducted an investigation into the release of plating fluid from their facility.  Several monitoring wells were installed and sampled for various metals (hexavalent chromium, copper, nickel) and other contaminants, and contamination was discovered in shallow groundwater near the facility and to the west.  A groundwater collection system was installed, and contaminated groundwater was pumped from the west side of the building to an onsite treatment system.  Treated water was discharged to the municipal wastewater system for final treatment. 

Lacks voluntarily tested groundwater collected from existing monitoring wells and the groundwater capture system beginning in October 2018.  The maximum concentration of PFOS measured was 11,000 ppt which came from the southern groundwater capture system sampled in October 2019.  The highest groundwater sample contained PFOS at a concentration of 7,000 ppt and was collected from monitoring well TW-28 in November 2020.  The groundwater capture system remains in operation at the facility and the wastewater treatment system was modified to provide filtration to remove PFAS from the wastewater effluent prior to discharge to the sanitary sewer system.

A new release of plating fluid was discovered at the facility on April 5, 2021, which also contained various metals and PFAS from the current plating mist suppressant, which included PFOS, 6:2 FTS, and other PFAS.  Plating fluid leaked from the facility's spill containment system and below the building where it then flowed underground, into the storm water collection system, and then into the onsite storm water retention pond.  As of August 2021, work was ongoing to further assess this new release and capture contaminated groundwater from below the building.

Based upon investigation work conducted at the facility in the early-2000's, a shallow, perched groundwater aquifer exists below the site and appears to flow to the west-northwest toward onsite wetlands and unnamed seasonal tributaries to Plaster Creek which is located less than one quarter mile west of the site.  Based on recent studies, Lacks believes that all contaminated water can be captured and treated before it can migrate off-site.  Additional investigation has been proposed to assess groundwater at the site and near the storm water retention pond.

Lacks Industries - Airlane Map

Recent Accomplishments

  • On October 14, 2021, EGLE received a Status Update Report from Lacks which presented the results of additional groundwater sampling at the facility including the results of PFAS sampling near the factory. Based on the information provided, the highest concentration of PFOS was present in the monitoring well TW-28 at a concentration of 7,000 ppt (November 11, 2020) and in water collected from the southern groundwater remediation capture trench at a concentration of 9,700 ppt (August 18, 2021).This report also provided some updated figures depicting wells at the site and improved resolution geological cross-sections to better understand the site hydrogeology.
  • On November 4, 2021, the DHHS transmitted the results of a residential well water sample that was collected from 3960 Shaffer Avenue SE, west of the Lacks Airlane investigation area; the samples did not contain detectable PFAS.
  • On November 10, 2021, Lacks submitted a brief email summary of the investigation work that was conducted in the vicinity of the storm water retention pond as well as the results of the metals sampling conducted on October 26, 2021.PFAS results were not yet available.
  • On December 21, 2021, EGLE received a Remedial Investigation Report dated December 16, 2021.This report summarized the work conducted Lacks to investigate the ground near the storm water retention pond. In addition to providing a better understanding of the geology in the vicinity of the pond; the report confirmed that the pond was leaking metals and PFAS contaminated water into the subsurface. PFAS was present in groundwater sampled from all of the new wells and in the surface water. The highest measured concentrations in the groundwater included: PFOS- 4,000 ppt (21-MW-01, 10/26/2021), PFOA- 13 ppt (21-TMW-01, 10/26/2021), and PFBS- 680 ppt (21-TMW-01 and 21-MW-03, both on 10/26/2021).These results exceed the drinking water and groundwater surface water interface cleanup criteria (no GSI criteria are available for PFBS).
  • On around December 28, 2021, EGLE sent a flyer to residents along and near Mesa Verde Court to the west of the investigation area notifying them of the ongoing investigation. This area is serviced by municipal water and there are no known drinking water or irrigation wells.

Next Steps

  • Additional work is needed to assess onsite groundwater in the vicinity of the plating facility to assure delineation and compliance with Part 201 and other environmental laws.
  • Additional work is needed to assess the groundwater near the storm water pond and prevent the migration of contamination offsite and into Plaster Creek.
  • Sampling of Plaster Creek is necessary to assure that this creek is not affected by this release. Results of outfall sampling conducted on April 5, 2021 indicated that PFAS was released into the creek at that time.
  • Lacks continues to capture groundwater from below the building and pump it to the onsite wastewater treatment system to remove metals and PFAS prior to discharge to the sanitary sewer system.
  • Lacks continues to assess the plating system to locate and repair leaks and has implemented additional operation and maintenance activities to prevent future releases from the plating line; furthermore, intensive inspections are planned during planned plant shut-downs in the future.

Residential Well/Alternate Water

  • No residential well sampling has been conducted because no residential or other water supply wells are present within a half-mile of the site.  EGLE worked with Kent County Health Department to confirm that there were no nearby wells.

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

October 2018 - October 2021 37 34
Surface Water TBD N/A N/A
*Groundwater monitoring well results are compared to EGLE Part 201 criteria for 7 PFAS compounds effective 12/21/2020:  PFOS (16 ppt), PFOA (8 ppt), PFNA (6 ppt), PFHxS (51 ppt), PFHxA (400,000 ppt), PFBS (420 ppt), and HFPO-DA (370 ppt).

Sampling Notes

  • Only PFOS and PFAS were reported by Lacks for samples collected by in 2018-2020.
  • A sample of the water contained in the storm water pond was collected on April 13, 2021, and this water contained 7,500 ppt PFOS, 41,000 ppt 6:2 FTS, 1,800 ppt PFBS, and other PFAS as well as metals related to the plating fluid release at the facility discovered in April 2021.

Historical Timeline

    • On April 12, 2021, EGLE was notified of the possible release of plating fluid from the Lacks Airlane north facility based on the observation of discolored storm water in onsite catch basins and the storm water retention pond.  Work commenced by several EGLE divisions to arrange an onsite inspection and meeting to discuss the release.  Lacks had already hired an emergency spill cleanup company to assist in the response efforts.
    • On April 14, 2021, EGLE notified Lacks of their statutory requirement to locate the source of the release and stop ongoing releases.  EGLE also requested updated information pertaining to any groundwater sampling that was conducted from 2016 and later since no information was in the file since that date.
    • On April 16, 2021, Lacks met with EGLE to understand the nature of the release and determine next steps.  The primary concern was locating and stopping the release and preventing storm water contact to the spill and contaminated groundwater.
    • On April 19, 2021, Lacks provided EGLE with groundwater analytical results for samples collected from various monitoring wells onsite pertaining to the release that was discovered in the 2000's, this data included PFAS sampling results and Safety Data Sheets for chemicals currently used at the facility which may have been released.
    • On April 19, 2021, EGLE sent Lacks Industries a Request for Additional Information pertaining to storm water and groundwater sampling conducted at the facility from 2018 and later.
    • On April 20-23, 2021, Lacks provided EGLE storm water and groundwater and sampling results, these results confirmed that PFAS was present in the release discovered in 2021.
    • On April 27, 2021, EGLE received the results of a water well search from the Kent County Health Department.  Based on the information provided, there are no drinking water wells downgradient of the release and the area is serviced by municipal water. (One well appearing to the south of the facility was not mapped in the correct location.)
    • On May 5, 2021, EGLE sent Lacks a Compliance Communication in follow-up to the meeting on April 16, 2021.
    • On May 5, 2021, EGLE was provided additional information about the storm water system at the site which suggested certain portions of the onsite storm water system were not installed as previously understood for the site.  Lacks confirmed this information and provided clarification to EGLE; these storm water discharges were sampled, and the results were pending.
    • On May 27, 2021, EGLE issued Lacks a Violation Notice related to the unpermitted discharge of wastewater on April 5, 2021, failure to report the unpermitted discharge within required timeframes, and failure to conduct required quarterly storm water inspections.  The Violation Notice also outlined additional work that was to be conducted at the facility to address the spill and return to compliance with their permit.
    • On June 7, 2021, EGLE visited the site to inspect the facility and discuss a plan to segregate contaminated groundwater from the storm water system for treatment and disposal.
    • On June 15, 2021, EGLE had a meeting at Lacks to discuss investigation requirements under Part 201, Michigan's Environmental law and inspect the ongoing efforts to capture and treat contaminated groundwater.
    • On June 25, 2021, EGLE received a written response to the violation notice issued by the detailing activities to be conducted to comply with the permit and statute.
    • From June to August 2021, Lacks installed a storm water and groundwater separation structure to enable them to collect contaminated groundwater and prevent it from accessing the storm water system and worked to obtain approval to discharge treated wastewater and groundwater collected during the emergency response and ongoing activities.
    • On August 17, 2021, EGLE and Lacks corresponded regarding a draft work plan for groundwater investigation activates around the storm water retention pond.
    • On August 19, 2021, EGLE transmitted a Compliance Communication describing Lacks' responsibilities under Part 201.
    • On August 23, 2021, EGLE issued a permit which provided authorization to discharge properly treated storm water to the nearby surface waters of the state. This permit was only for water captured and stored following the discovery of the release in April 2021 and subsequent emergency response.
    • On August 30, 2021, EGLE sent Lacks a request for additional information pertaining to the status and location of existing monitoring wells, the groundwater pump and treatment system, and other topics.
    • On September 1, 2021, EGLE approved a draft work plan to investigate the groundwater in the vicinity of the storm water pond to determine whether contaminated water leaked from the pond and is impacting the groundwater in that area.