RACER Willow Run (Ypsilanti, Washtenaw County )

• 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.
• RACER continues to report updates to YCUA regarding the wastewater discharge.
• On November 15, 2019, EGLE, RACER, YCUA and Ypsilanti Township meeting to discuss a number of ongoing Issues pertaining to PFAS.

Sampling: PFOS and PFOA Only

Sampling Notes

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