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Rouge Manufacturing Complex (Dearborn, Wayne County)

EGLE Site Lead: Joseph Rogers, RogersJ5@Michigan.gov or 517-599-5312 Webpage last updated: May 17, 2021.

Background

The Schaefer Road Area Wastewater Treatment Plant and the Rouge Manufacturing Complex (RMC) are contiguous properties located at 3001 Miller Road. This site is undergoing remedial investigation under a Corrective Action Consent Order (CACO) issued by EGLE to Ford Motor Company (Ford) and AK Steel Dearborn Works (AK Steel). The RMC is a jointly owned automobile and steel product manufacturing facility, which has been in operation for nearly a century. Due to historic manufacturing and waste management activities at both properties, EGLE requested an initial investigation of the nature and extent of PFAS in groundwater and storm water at both properties. It should be noted that the investigations at the Schaefer Road Area and the main Rouge Manufacturing Complex are being conducted separately under the CACO.

Geology across the RMC can be grouped into three general natural units that, from the surface downward, include: an intermittently present native sand layer; an underlying site-wide regional silty clay layer; and a bedrock layer. In addition to the natural layers, the surface layer consists of fill materials generally ranging from 7 to 10 feet in depth. Groundwater at the RMC is intermittently present in the fill or native sand perched on the clay layer. Due to the discontinuous nature of the groundwater in the shallow sand/fill layer, there is no consistent flow direction or gradient. Once a low point in the clay surface is filled with perched groundwater, the water will migrate horizontally until it finds an outlet: typically, a storm sewer discharging to the Rouge River. Groundwater flow at the Schaefer Road Area also typically flows to the Rouge River.

Rouge Manufacturing Complex Map

Recent Accomplishments

  • In December 2020, sampling was conducted as part of the next phase of the investigation at the Schaefer Road Area. Results are expected in March 2021.
  • On January 22, 2021, EGLE received a response to our comments from November 5, 2020 regarding the next phase of the investigation at the Rouge Manufacturing Complex, including a work plan. The response is currently under review by EGLE.
  • On May 6, 2020, EGLE provided a comment letter to the facility responding to their January 22, 2021 letter and work plan. A response is required within 30 days.

Next Steps

  • EGLE is preparing a response to the March 11, 2020, PFAS Report for the RMC to request supplemental PFAS investigations.
  • Ford and AK Steel are working to develop a corrective measures study to address potential off-site movement and discharge to the Rouge River.

Residential Well Testing/Alternate Water Information

  • The area surrounding the RMC is a mixture of industrial, commercial, and residential land use with municipally supplied water. No residential wells are expected to be impacted. The closest residential area is approximately one-half mile southeast of the facility. No drinking water wells have been identified within one-half mile from the facility boundary.

Upcoming Community Engagement

  • None currently planned.

Sampling Results Summary

This table was updated to include all seven PFAS criteria effective 12/21/2020.

Type of Sample

Date Sampled (or Range)

Number of Sample Results Received

Number of Samples Above PFOS Criteria

Groundwater Monitoring Wells

May 2019 - July 2020 34 18
Surface Water  July 2019 - July 2020   18  5

* 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

  • 14 out of the 15 surface water samples were storm water samples and were all collected at the RMC. Of the two storm water samples which exceeded the 12 ppt PFOS standard, one was collected from a stagnant detention basin and may not be representative of PFOS concentrations discharged to the Rouge River. Both storm water samples exceeding 12 ppt PFOS were wet weather samples. Two additional groundwater samples from the Schaefer road area may exceed the PFOS drinking water criteria but cannot be confirmed due to documented field cross contamination. Three wells in the Schaefer Road Area and five wells in the RMC exceeded the PFOS surface water quality criteria of 12 ppt. Based on the lack of residential wells in the area and the site Conceptual Site Model, the GSI pathway is expected to be the main pathway of concern at the site.

Historical Timeline

    • In June and July 2019, GHD on the behalf of Ford and AK Steel performed PFAS sampling of select groundwater monitoring wells and storm water at both the RMC and Schaefer Road Area. Follow-up wet weather storm water sampling was conducted in October 2019.
    • On August 30, 2019, EGLE received a report summarizing groundwater PFAS sampling results for the Schaefer Road Area. 21 monitoring wells were sampled: 2 were above the previous Part 201 drinking water criteria of 70 PFOA + PFOS combined; and 10 were above the new Part 201 drinking water criteria for PFOA and/or PFOS. Three monitoring wells were above the PFOS groundwater to surface water interface (GSI) criteria of 12 ppt.
    • On March 11, 2019, GHD on the behalf of Ford and AK Steel submitted a report summarizing the groundwater and storm water PFAS sampling at the RMC. 11 monitoring wells were sampled: three were above the previous Part 201 drinking water criteria of 70 PFOA + PFOS combined; and five were above the new Part 201 drinking water criteria for PFOA and/or PFOS. Five wells were above PFOS GSI criteria. The RMC also sampled storm water; see the sampling notes.
    • On November 26, 2019, EGLE met with GHD, Ford, and AK Steel for a semi-annual corrective action meeting.
    • On March 30, 2020, EGLE accepted the August 30, 2019, Schaefer Road Area PFAS report and requested a workplan to further delineate the nature and extent of PFAS contamination present at the site, as well as investigation for potential for off-site movement or discharge of PFAS to the Rouge River.
    • On June 2, 2020, EGLE met with GHD, Ford, and AK Steel for a semi-annual corrective action meeting.
    • On September 15, 2020 this site investigation was discussed during a virtual MPART PFAS Regional Informational Webinar for the Southeast Michigan Region.
    • Access to Southeast Michigan Regional Webinar Recording
    • Access to Southeast Michigan Regional Webinar Presentation
    • On October 12, 2020 an additional virtual public information meeting for the Rouge and Marathon sites was held.
    • On October 29, 2020, EGLE sent a letter in response to the March 11, 2020 PFAS Report, requesting RMC to conduct supplemental PFAS investigations.
    • On November 5, 2020, EGLE sent an email conditionally approving the next phase of investigation at the Schaefer Road Area as defined in the facility's September 30, 2020 revised Work Plan.