Environmental Clean-up Activities at the Petro-Chem Hazardous Waste Facility in Detroit, Michigan

– [Announcer] Broadcast is now starting All attendees are in listen-only mode – [Jim] All right, good morning, everyone Good morning? Good evening, everyone This is Jim Ostrowski I work in the EGLE’s Environmental Support Division and I’m here with several staff from our department that will be presenting for you this evening on the Petro-Chem Processing Group corrective action cleanup So this is an update webinar Again, that’s me and I’ll be the moderator for this evening We’ve also got Let me go through the housekeeping guidelines First of all, all lines are muted, which means that you can hear us but we can’t hear you If you have a question, feel free to type it into the question box that you have in your GoToWebinar toolbar and we’ll go through questions at the end Also, since we don’t have that many people on the line, if you have a question, also feel free to click the Raise Hand icon, and if you have a microphone I will attempt to unmute you I’ll call your name out and we’ll unmute you so you can ask your question that way as well We’re also recording the webinar, and we’ll post it online as soon as we can It’ll probably be early next week, we’ll send that out as soon as it’s available So here’s our presenters for this evening Dan Dailey’s going to be up first, then Nathan Erber and John McCabe So Dan, that’s all I have for housekeeping Oh, I’m sorry, we also have, read my slides, we also have Jeanette Noechel, Jon Lamb, and Amy Robinson So Jeanette and Jon Lamb are actually off site, who will be able to answer questions, and Amy is right here in the room with us All right, Dan, I’ll turn it over to you, go ahead – [Dan] All right, thank you, Jim So we’re going to cover five areas tonight, starting with a general facility background, and then talk about some of the environmental conditions at the site and our clean-up process, which is called corrective action under our hazardous waste regulations Get into some of the specifics of the corrective actions, and then talk about how you can get engaged and remain engaged So what we have up now is a Google map of the area surrounding the facility And if you can see my pointer here, to the general west, north and east we have industry all around the property And then to the south we have some residential development and some more industry And the facility’s located at 421 Lycaste, in Detroit, Michigan So if we look up here towards the top of the slide, you can see Jefferson Avenue going through the middle of the slide, middle upper portion of the slide, and then the river down here So this is the general area around the facility This is a more close up view, and just want to point out the office building, employee locker room, laboratory, these are the areas where people are most of the time, which’ll become important as we talk about some of the issues later on We’re bounded here on the west by St. Jean, on the east by Lycaste Avenue, and on the south by Freud Street The rest of these areas in the middle, these are where they conduct their hazardous waste storage and fuel blending operations So they’ve been fuel blending and solvent recycling since the 1980s at this facility The solvent recycling has been discontinued, so they no longer do that process The property was previously an oil refinery, and there’s some legacy contamination in the soils and groundwater related to that And there’s also some legacy contamination related to the site since hazardous waste regulation came into being in 1976 So the facility’s been licensed to manage hazardous waste, and so you can see the numbers here, they look like large quantities because they are, it’s commercial hazardous waste management, but this is fairly typical for a licensed facility The facility accepts nearly every kind of hazardous waste for storage and treatment, and then shipment off-site for ultimate disposal Except that reactive waste is not treated at the site So here’s a general facility development timeline We can see in 1923, the original property was developed by Amoco Oil, and they operated until the 1970s when another petroleum company took over And they stopped operating in 1976,

which incidentally was the same time that the Federal Research Conservation and Recovery Act came out and started regulating hazardous waste, and caused the facility to become subject to licensure And so Nortru Incorporated was established in 1979, and so that was the parent company of Petro-Chem, which purchased the property in 1981 And established itself at this location In 1982 they began hazardous waste operations, storage and treatment And so they went through some reorganizations and were issued their current hazardous waste facility operating license in 2012 And under that license, clean-up investigations, technology reviews, and response actions have been implemented, and we’re going to talk about those in more detail tonight, that’ll be the main focus And one thing of note in the second to last era there, vapor intrusion and PFAS became emerging issues at the site, and so there was additional investigation and responses going on related to that So that brings us up to where we are today in 2020, for this webinar With that, I’ll turn it over to Nathan Erber, the project geologist, to talk about soil and groundwater – [Nathan] Thanks, Dan So for this part of the presentation, I’ll cover soil and groundwater conditions that are at the site I’ll cover the types of soil present, how groundwater behaves at the site, and then to kind of sum up we’ll talk about historical contamination that’s been identified through some previous investigation So looking at the slide, you see soil and subsurface materials basically consist of fill material which is predominantly sand and silt There’s also a peat layer, which is organic material, and below that we have a dense clay, which is rather thick and extensive As far as groundwater goes, there’s limited shallow groundwater, and many of the monitoring wells pump dry during sampling This indicates that it’s not very productive And it’s also important to note that groundwater is not used as a drinking water source in the surrounding area It’s predominantly on City of Detroit water, and it’s municipally supplied So this figure is a cross section showing the geology present beneath the site The colors here indicate the types of material found beneath the surface So this blue area is the fill material that I just talked about, predominantly sand and silt And these orange layers are sand and some gravel And this green is the peat layer, it’s rather extensive across the site And then down here is the clay These lines you see here, those are the wells, the soil borings, and the triangles indicate the groundwater surface And it’s interesting to note that the groundwater typically sits at the clay-fill interface So that’s kind of the geology of what’s going on beneath the site This map is a map of the facility and it depicts groundwater flow, I took kind of a generalized approach to this, so groundwater generally flows from the center of the site, where a groundwater divide exists to east and to the west So it’s kind of a radial-ish flow from the center to the boundaries So now we’ll talk about some of the investigation results that have been collected over the years For soil on this slide and the next on the groundwater I think it’s important to note that these results don’t tell us necessarily when any releases occurred, it mostly tells us what the current conditions of the site are today So this figure shows a lot, there’s a lot to look at, but it shows the soil sample locations either taken from the surface or subsurface,

so the samples from basically the surface down to up to 10, 15 feet below the surface The highlighted letters and names indicate an area or a sample that exceeded one or more of EGLE’s clean-up criteria So as you can see, I’ll highlight some areas, the western area, it’s referred to as the western berm area, saw relatively high concentrations and detections And another area was in the southeast, near the container management building These are the two areas on this map Move on to the groundwater conditions, similar markings, the highlighted in yellow indicate areas with exceedences And you’ll note the west berm area here, the mouse here, shows exceedences in this area and also some surrounding the container management building again But it’s important to note on this figure that groundwater south of the site and most of the boundaries are not indicating that groundwater contamination is getting off-site, to the south towards those residences Now I’ll turn it back over to Dan to talk about corrective actions – [Dan] Thank you, Nate So I want to go over the corrective action process and kind of drill down from a general overview to some of the specifics that are going on at the property Corrective action is our hazardous waste clean-up process, and so what we’re after here is to try and take actions that are necessary to protect public health and the environment from a release of hazardous waste So this can include things like investigation, assessment, evaluation, and implementation of clean-up actions And if people are threatened, their health is threatened, we can relocate people as well, and so on Our corrective action authorities are both federal and state Michigan operates a fully delegated corrective action program from the Federal government, and so we operate with that authority The plan of corrective action is laid out step-wise in four steps, with an additional step that can be taken at any given time So normally the process would start out with an assessment where we identify waste management units and potential releases And those are exactly what they sound like Waste management units are areas where waste has been managed systematically and there may have been a routine release from the unit And so we follow up on those to see if there’s any potential impact to soil and groundwater And then other potential releases that may not have come from a discernible unit but are of concern nonetheless, so we usually identify those as areas of concern If we find something in the assessment, then often there’s further investigation needed to determine the extent of impact of that release And in some places at the facility this is where we are now, especially for the emerging issues like vapor intrusion and PFAS investigation So you’ll hear more about that later on I’m going to skip over interim measures for now and go to study, ’cause that would be the next step-wise thing in the program, and that’s where we would identify appropriate clean-up technologies if we had a handle on the extent and impact of the contamination sitewide and if anything is going off-site And then finally, implementation would be the final action to address releases So stepping back to interim measures, these are smaller measures to address specific, time-sensitive needs So these can be taken at any time during this four step process And I have a “This is where we are now” on this because we have a few interim measures that are being taken while investigations are still being completed So at this particular facility, Petro-Chem has an operating license under the hazardous waste regulations, and that operating license has conditions which administer the corrective action process

that we just described And Part Six of the license requires the clean-up for the on-site releases and waste management units So if you wanted to go online to a website we’ll specify later in this presentation, you can go ahead and look at the license and see exactly what they’re required to do So that also includes a requirement to clean-up any releases that go beyond the facility boundary So we’re going to go through that now, we’re going to go through the specific actions that’ve been taken and where they are, give you the current status So I’m going to turn it over to John McCabe to talk about what’s going on with the PFAS investigations first, and then we’ll stepwise through every part of the seven areas and give you further information John? – [John] Thank you, Dan First, I’d like to talk a little bit about the PFAS investigation I’m sure anyone who’s read or listened to anything in the news in the past couple years has realized that these PFAS compounds have kind of burst on the scene as an emerging contaminant that needs to be addressed Well due to the nature of the waste handled at that facility, and also some historical firefighting activities that may have involved PFAS, EGLE required Petro-Chem to investigate if PFAS compounds were released at the site As a first cut on this, Petro-Chem sampled four groundwater monitoring wells for the 28 PFAS compounds that EGLE requested information on Petro-Chem reported the sample results to EGLE on January 22nd of this year, so this data package is all fairly new and we’re still in the process of assessing it Real quickly, the investigation of the results showed, of the four wells sampled, one well was non-detect for any PFAS compounds, one well, on the north side of the site, MW8, had a detection lower than the drinking water standard but there was measurable PFAS on it, and two wells in the southeast corner of the site and on the west side of the site displayed PFAS concentrations above EGLE’s drinking water standards The highest concentrations were at MW9, a little over twice EGLE’s drinking water standard As a result of these findings, EGLE is going to suggest some next steps We’re going to prioritize investigation for any potential for PFAS to move off-site in groundwater, particularly along utility corridors As there is nobody drinking any groundwater anywhere within miles of the facility, our focus is really going to be on the potential for PFAS to discharge, probably through utility corridors, to the Detroit River And we will also be discussing with Petro-Chem additional site groundwater sampling so we can get a better handle on PFAS concentrations in groundwater that’s limited to the site With that, I’m going to give it back to Dan – [Dan] Thank you, John So our next emerging issue is vapor intrusion And so we have an ongoing investigation there So there are three buildings on-site where there’s human habitation by workers at the site that need to be investigated So what we’re looking for is trying to determine whether volatile materials that have been detected in soil and groundwater, like for example, solvents, whether they may be accumulating under the slabs, slab floors to buildings, and potentially getting into the indoor air breathing space where people could be exposed So those evaluations are currently being done under an approved plan, and to try and determine whether and where these chemicals may be migrating in the subsurface

we’re also going to look at utility corridors and because of the way that gas moves in the subsurface we’re also going to be checking to the west of the facility to see if there’s any off-site migration And so these plans for investigations were approved last year, and we’re expecting the results from those to come in, yeah, this year Okay, so this is a really busy slide showing our soil sample results related to vapor intrusion And just to kind of show you what we’re lookin’ at here, this circle is a smaller version of what you saw earlier from the soil results that Nate presented And this is showing exactly where we had exceedences or detections of soil gas or concentrations in soils at levels that might be of concern for soil gas So this area’s also known as the western berm area, which is one of our waste management units that we’ve identified at the site And also this is just a smaller dot showing, again, from earlier that Nate showed, of additional soil contamination that may be an issue with regard to on-site habitated buildings And so once again, we’re showing to the south the sample results that are not shaded yellow here, showing that there was a boundary condition of less than the criteria, the risk-based criteria for vapor intrusion, so we wouldn’t expect soil gas to be migrating in that direction This is a picture to show the building locations that are being evaluated Mainly to the northeast-ish of the site This is the office area, where you would expect people to be working on their computers and doing other office business An employee locker room, and the laboratory, where we expect most of the habitation This is the western berm area, which was one of our source areas, so we’re going to, we’re asked Petro-Chem to move off-site and look at soil gas across St. Jean Avenue to see if there’s any potential for soil gas migration there as well So with that I’m going to turn it back over the Nate to talk about the sitewide groundwater monitoring program – [Nathan] Thanks, Dan So I have a few brief slides on groundwater monitoring that’s required by Petro-Chem’s operating license So Petro-Chem has a network of 12 monitoring wells which are sampled every six months, so twice a year They do statistical evaluation on those results on a well by well basis, so they can So this allows us to see any of a particular parameter is increasing or decreasing compared to previous sampling events within that well And of note is monitoring well 11, in the western berm area, this has historically shown the highest levels of volatile organic compounds, which are the primary driver for the clean-up at this site So this is just a map of their groundwater monitoring locations Should be nice and simple The red are the monitoring well locations, and I just wanted to point out monitoring well 11 here is where, in that western berm area, that they’ve had the highest concentrations of VOCs And now, give it back to Dan to talk about some interim measures going on at the site – [Dan] Okay, thanks, Nate So we have two interim measures going on at the site that work together, and the western berm area is one interim measure where the berm itself was removed ’cause it was a source of trichloroethylene in soils And so that’s a solvent material that we, I had mentioned earlier, that is one of the contaminants of concern in soils and groundwater And so that was removed, and Petro-Chem has installed

and multi-phase extraction system pilot study to look at what’s left and to try and remove that material from the remaining soils and groundwater beneath the berm that was removed So this is a blow up of the location You see that the berm area’s in the southwest corner, and the pilot study is right beneath it And this is just a picture of the removal itself, just so you can see what it looks like So since the removal, the square here is the main target area where we’re looking to remove material You’ll see from monitor well 11 here, which Nate mentioned earlier, which is the highest point of contamination And so the pilot study has been installed in that point to try and see what effect it’s going to have on the remaining contamination There’s one extraction well, there’s a couple vapor monitoring wells in this location to monitor soil vapor, and a couple piezometers in this location to measure water levels And then this pink outline is the stockpile that was removed Any of you science geeks out there who like a lot of detail, I added this slide for you since it’s going to be produced later for your viewing pleasure And this just shows where the monitoring wells are in terms of depth and where the vapor wells are and the other construction But this is what they’re going to look like when you drive by So you may not even see their groundwater monitoring well since it’ll be flush mounted And so this is an example of one of the vapor wells Petro-Chem is also required under its operating license to conduct monitoring of ambient air, which is just a fancy way of saying we want to know what’s in the air outdoors And the latest update to this program was in 2016 They sample every six days at four perimeter fence locations just to make sure that anything from their processes is not impacting air as it leaves the site And they report those results monthly to EGLE in our office here in Lansing So what they have to do, they take those sample results and they compare them to what’s called an Initial Threshold Screening Level Basically, they put out canisters and sample for 24 hours, and analyze that sample and get results, and then they compare it to a number which EPA has established to determine whether or not it’s a risk So if they have an exceedence of that screening level then we say that there’s an impact, and that triggers action in terms of further investigation, analysis of what the cause is, and potential follow up that may include additional engineering controls to their processes, and so on At Petro-Chem, the four perimeter monitoring locations are shown in orange, and we have some interior monitoring locations for sources that I’ve highlighted in green The picture to the left is one of their locations, MS2, which is at the eastern side of the property by Lycaste Avenue, and just added that in there so that you could see the Summa canisters in the buckets, and this is a typical setup for their ambient air monitoring So we have monitoring in the middle of the facility right now because there have been some perimeter concentrations that exceeded screening levels for trichloroethylene and xylenes And so the next step is to see if we can find sources that may be on-site that caused those exceedences at the fence line so there’s an eight-week sampling plan through the end of this month, and they’re taking one sample for worst case scenario right on the roof of their container management building by the fence, and two other samples, one at the loading dock for the containers of 55 gallons or less size, and one sample at the truck unloading pad for their tanker trucks So we should be getting that data back soon and be able to determine what additional actions need to be taken There was a roll-off box fire last year at the property,

and that triggered the need for additional corrective action investigation Fire lasted about 15 minutes, it was in the Super Blender System Dock Storage Area A smoke plume traveled across the site, and hazardous waste processing in the area was stopped that same day After getting reports from the fire, EGLE ordered the area shut down on July 3rd until it could be recertified as capable to safely operate On October 16th, Petro-Chem had an independent professional engineer recertify the area as safe to operate, and EGLE returned the area to service on November 20th So this slide shows, this pink square is approximately where the actual fire occurred And so the Super Blender System Dock Area is just to the left of this, right about where this little hand is And just to the lower right of that So what’s happened so far is we had Petro-Chem do some modeling to determine whether any of the ash from the smoke plume may have deposited on soils And so some did, but not above a risk-based clean-up criteria, so no soil clean-up was required Other things that they have had to do in follow-up to that fire is submit an updated standard operating procedure, which is under EGLE review, for managing their solid hazardous waste in roll-off boxes in that area In addition to that, the facility is upgrading its fire suppression equipment, and that submittal is pending to EGLE and City of Detroit This is a map to show the area of soil deposition that was modeled by the facility And so this is actual deposition area, this is not a smoke plume But so what we looked at, the main constituent of concern was chromium because there were paint filters in the roll-off box And so the facility modeled where the highest levels of deposition would be The pink hexagon there is where the fire occurred The star is the location of highest concentration And so the purple is the area of higher concentration and it goes down to a lower concentration in green after that And so the maximum amount detected was 0.015 parts per million of chromium, which was below the screening level Okay, so overall, stepping back to the overall corrective action process, we have two reports in right now that are under EGLE review One is the semi-annual Groundwater Monitoring Report, which is methyl tert-butyl ether monitoring, that Nate talked about earlier And the second one is the PFAS Assessment Report, which John talked about And so we expect to have those reviews done yet this quarter The quarter ends March 31st, so those are available for review on the website, if you care to go look at that, and we’ll provide that link in a few minutes Also due yet this year are the Soil Gas Investigation and Building Evaluations Report, and the multi-phase Extraction System, MPE Pilot Study and Western Berm Soil Removal Reports So those’ll go up on the website as well as we get them So that’s what’s going on in terms of corrective action at the property right now So you can see there’s a few things going on, a few things yet left to do The department is not currently looking at a final decision on what the final clean-up is going to be until these investigations are completed, but there is an opportunity to communicate with the department And so there’s going to be an in-person public meeting March 5th, at Wayne State University So you’re welcome to come to that, and it’ll be a similar presentation as today, but if there’s any updates in terms of

when we receive additional information, those’ll be posted on the website so that you can take a look at those And at that meeting, we’ll also be available to talk informally in person So when you go to the website, look for the flyer, ’cause that’ll have the most pertinent information as to what’s going to happen at the in-person public meeting And you’ll have the agenda and where you can get more information So for further information you can go to our website, and these are the web links We’d like to call your attention particularly to the EGLE Connect subscription website, because it’ll automatically send you email updates every time we update the website, and then you can go take a look at those If you’d rather, you can also talk to me, you can call me at my cellphone number that’s listed there, or send me an email and I’ll respond That’s the end of the formal presentation If anybody has any questions, we are available to answer them – [Jim] All right, thanks Dan and the team here I’m lookin’ at my question board and we don’t have any questions right now So I know that if somebody does have a question it does take a minute for it to register here Just a reminder, if you have a question, type it into the question box on your GoToWebinar toolbar that you have in front of you, and we’ll answer it as quick as we can If you’re not able to type it in you can also click the Raise Hand icon and I will attempt to unmute your mic and you can try to ask your question that way too While I’m waiting for questions, I just want We’ve got a pretty big team here, I didn’t know if anybody else in the room here wanted to make any comments or clarifications or anything All right, we also have a couple people on in our field offices who are on I just want to check in with Jeanette Noechel and Jon Lamb, if you guys have any comments, feel free to make ’em right now – [Jeanette] Not at the moment – [Jim] Okay, thanks, Jeanette – [Jon] I don’t have anything to add either, at this time – [Jim] Okay, that was Jon Lamb Okay, so it doesn’t look like we have any questions So that’s fine We are recording the webinar and we’ll post it online and get everybody a link to that as soon as it’s available, that way it can be shared with those that couldn’t make it to this webinar I’m going to back up really quick here I just want to remind everybody about the website, Michgan.govEGLEPetro-Chem That’s where we have all the information And then back one more, information about the in-person public meeting on March 5th, 2020 So was that the end of your slides then, Dan? – Yes – All right Well, I want to thank everyone for joining us tonight Hopefully if you have any more questions you’ll join us at the public meeting, or feel free to contact us at the website Thank you all, and have a great evening