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Melvindale Foaming Sewer Area (Melvindale, Wayne County)
EGLE Site Lead: Joseph DeGrazia, DeGraziaJ@Michigan.gov or 586-291-0476. Content last updated: October 21, 2022.
On August 2, 2018, Western Wayne Hazmat Response Team (WWHRT) responded to an incident on Schaefer Highway, approximately 0.30 mile north of the I-75 overpass. Foam was reportedly flowing out of a sewer manhole, down an embankment and along Schaefer Highway where it entered road drains that lead to the combined sanitary/storm water sewer system. The combined sewer system discharges to the Great Lakes Water Authority (GLWA) Wastewater Treatment Plant.
Since this combined sewer system discharges into GLWA's Wastewater Treatment Plant, GLWA is responsible to work with parties to eliminate discharges to their system. EGLE is responsible for discharges to waters of the state. GLWA has been working to systematically identify, reduce, and eliminate discharges of PFAS from industrial users of the sewer system.
- On April 16,2021, GLE’s contractor investigated the area of the scrap pile fire and associated water/foam runoff. Data from soil borings identified PFOS in soils at depths from 1.0 to 9.5 feet below ground surface. PFOS concentrations in soil ranged from <31 ppb to 1,200 ppb – groundwater was not encountered. Surface water was noted, by GLE, to flow westward and not towards the East Drainage Ditch. Water samples were not collected from the East Drainage Ditch due to lack of liquid.
- On August 8, 2022, EGLE staff met to review the investigation and analytical data collected by GLE. Because GLE was not able to sample for groundwater, there doesn’t appear to be a link between groundwater and surface water.
- EGLE will continue to pursue potential PFAS sources upgradient of the previously foaming sewer.
- EGLE is conducting a PFAS Short-Term Storm Water Characterization Study to evaluate discharges. To date there has not been any observed storm water discharges from the site.
- On August 6, 2018, the foam appeared again in the same area. EGLE and WWHRT tracked the sewer to a newly paved asphalt parking lot (approximately 25+ acres in size) owned by Norfolk Southern Railroad located upgradient of the manhole on Schaefer Highway. Upon inspecting the catch basins in the parking lot, foam was observed being produced. A sample of the foam was collected by WWHRT to analyze for PFAS.
- On September 26, 2018, data was received from the August 6, 2018 sampling event. The analytical report identified the following PFAS compounds above water quality standards:
- PFOA: 9,000 ppt
- PFOS: 729,000 ppt
- Norfolk Southern was contacted by EGLE staff and was provided the analytical data. Norfolk Southern agreed to install a defoamer in the storm drain and have a vacuum truck on-site during rain events to intercept foam if needed.
- EGLE contacted Michigan Department of Transportation (MDOT) for assistance in examining asphalt mixtures for potential PFAS sources that may be contributing to the foaming sewer incidents. MDOT did not identify any asphalt mixtures that use PFAS.
- On November 30, 2018, GLWA issued a Violation Notice to Norfolk Southern. In response, Norfolk Southern conducted an investigation and sampling and concluded that the source of the foam was not their parking lot. They had discovered a previously unknown storm sewer pipe from the property to the west owned by Marathon Petroleum and concluded that the discharge from this pipe was the source of the foam.
- On December 20, 2018, GLWA issued a Violation Notice to Marathon Petroleum, stating that they were to attend a conference on January 29, 2019, to show the purpose and use of the storm sewer, provide data to characterize PFAS in the storm water, and provide plans for eliminating future discharges.
- Note that GLWA's Violation Notice to Norfolk Southern will remain in effect until they identify the actions taken to decontaminate the area and infrastructure and demonstrate that future releases will be effectively reduced or eliminated.
- On July 19, 2019, GLWA presented their current investigation findings to EGLE staff. GLWA identified two potential sources of PFAS upstream of the foaming manhole, Marathon Petroleum and GLE Scrap Metal. Marathon Petroleum has historically used PFAS containing Aqueous Film Forming Foam (AFFF) for fire training and emergency response. In June 2018 GLE Scrap Metal had a fire that was extinguished with AFFF by the local fire department.
- On August 12, 2019, EGLE staff assisted the GLWA source investigation by collecting PFAS storm water samples at various locations upstream of the Schaefer Highway manhole. The map illustrates where the samples were collected on site.
- On September 11, 2019, storm water sample results were received from the August 12, 2019 sampling. Results strongly suggested that both the Marathon Petroleum property and the GLE property have PFAS contamination that is likely influencing downstream storm water.
- On September 18, 2019, EGLE staff had a conference call with GLWA staff to review EGLE's August 12, 2019 sampling results and discuss next steps.
- On September 24, 2019, EGLE staff met with GLWA and Marathon Petroleum staff to discuss EGLE's findings. Key points included: Marathon's preliminary PFAS investigation identified PFOS in groundwater and surface water above applicable criteria, conversion of foam in emergency vehicles from C8 to C6 was ongoing, foaming was not documented prior to July 2018, and there are potential contributors of PFAS up- and down gradient of Marathon.
- On September 30, 2019, EGLE sent letters to Norfolk Southern, Marathon Petroleum Company, Shrader Tire and Oil, Evans Distribution Systems, and GLE Scrap Yard. All of these entities are upstream of the foaming manhole. The letters requested the respective entities to conduct investigations of their properties to determine if PFAS containing products and/or materials were used, stored, and/or released on their properties. If PFAS containing products and/or materials were identified, the entities would investigate the extent of PFAS impact on their sites.
- On October 28, 2019, Norfolk Southern responded to the Compliance Communication letter and stated that all the PFAS impact was from upgradient subsurface source(s) and no PFAS contribution was coming from Norfolk Southern's (new) parking lot. In September 2020, EGLE obtained additional information from Norfolk Southern and is reviewing that information.
- On November 21, 2019, in response to EGLE's Compliance communication letter, Marathon submitted a Work Plan to further investigate the fire training area. In January 2020, Marathon began implementing their work plan.
- On September 9, 2020, Marathon Petroleum Company was added as an MPART site. From this point forward, all information related to the Marathon investigation will be reported on that page. Information on this Area of Interest page will focus on other sites related to the foaming sewer incident.
- On June 16, 2020, and September 16, 2020, EGLE contacted Norfolk Southern and GLE Scrap Yard for updates. To date, no additional response has been received from GLE Scrap Yard. Norfolk Southern replied stating all the contamination was underground and not due to the parking lot. Norfolk Southern submitted information on the sealant used which EGLE is currently reviewing.
- On September 28, 2020, EGLE issued a second compliance communication to GLE Scrap Yard. This letter requests GLE to respond to questions contained in the letter within 14 days of receipt.