White Lake 29 CPF Incident Response Support

Global Environmental’s environmental engineering team supported the response to an incident at a Central Processing Facility (CPF) in southeast Michigan where a produced water tank exploded, and the contents of an adjacent crude oil tank were released into a secondary containment area, subsequently catching on fire. CPFs are regulated locations where production equipment (storage tanks, vessels, compressors, treatment equipment) are used to handle produced hydrocarbons. 

This CPF is surrounded by security fencing and includes the oil producing well and tanks that hold produced water (brine) and crude oil. The tanks are surrounded and underlain by a secondary containment system – as seen in the figure below. Secondary containment is a safeguard that prevents seepage of tank contents into the surrounding soils, surface water, and groundwater by creating a diked/bermed area around the tanks that is lined with impervious material.

At the White Lake CPF, the secondary containment was designed with an additional liner that covered the bottom of the system. Based upon site inspections, the first layer of this liner burned during the fire; however, the lower most liner is believed to have remained largely intact. No fluids appeared to have breached the bermed area surrounding the tanks and the crude oil burned within the secondary recovery area until it was extinguished. Out of an abundance of caution, because of hydrogen sulfide potential, the local fire department evacuated approximately 30 residences during this fire. Multiple fire agencies responded to this fire and were on the scene for several hours. No injuries or property damage (beyond that of the CPF) were reported, and area residents were permitted to return to their homes the following day.  

The exact cause of the fire remains unknown and is currently being investigated. Based upon field screenings and observations during cleanup operations, the OGMD did not believe that there was an impact to groundwater and/or surface water. The oil producing well at this location was then shut-in and the flow lines were purged and capped. 

Additional site clean-up and environmental testing continued from the November incident date through the end of February. In collaboration with EGLE, Global Environmental’s engineering team collected groundwater and soil samples for hydrocarbon indicator compounds and chlorides, and where necessary, conducted additional excavation activities to remove additional source area. The team also conducted an in-depth analysis of the potential for the firefighting foam utilized to contain PFAS and PFAS precursors. As of February 29th, Global Environmental has submitted documentation to close out the site.

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Timeline of Global Environmental actions:

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December 15, 2023

• Groundwater sampling was conducted by Global Environmental on December 6-7, 2023 at three existing groundwater monitoring wells immediately surrounding secondary containment dikes. Samples were to be delivered to Merit Laboratories for analysis.

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December 21, 2023

• Global Environmental was onsite on December 12, 2023, to collect floor samples of the soil from the excavated area. Six samples were collected from the base of the excavation and sent to a 3rd party laboratory for analysis.

• Global Environmental collected a sample of the Fire Fighting Foam to be analyzed at an accredited laboratory. Global Environmental has been working with EGLE staff to confirm that correct analysis and methods are used for this testing.

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January 5, 2024

• EGLE staff working with Hound Resources to schedule tactical excavation of limited impacted soils. During the initial soil sampling, several small areas, within the former containment, were discovered with petroleum odor and minor staining. Under the direction of EGLE and Global Environmental, soils will be excavated, and underlying soils will be sampled to verify that they meet regulatory standards.

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January 26, 2024

• Global Environmental was onsite on 1/22/2024 to complete verification sampling from the excavated areas. Soil samples were collected and taken to a 3rd party laboratory for analysis. Expected results in early February 2024.

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February 9, 2024

• Results of the 1/22/2024 sampling in the excavated areas by Global Environmental and 3rd party laboratory analysis indicate:some text
  • No Hydrocarbon Indicator Parameters were found above laboratory detection limit in any of the collected samples and are all below Part 201 Residential Soil Cleanup Criteria. 
  • Chlorides were detected at low levels at several locations, but all samples are below Part 201 Residential Soil Criteria for Residential Drinking Water Protection Criteria.
• Global Environmental conducted research on the fire-fighting foam used during the incident and found documentation from several studies that PFAS compounds and breakdown chemicals associated with PFAS are not found in the brand of fire-fighting foam used. Samples of the source material have been collected and are being analyzed to verify the claims in the studies. Additional analysis is being completed and the final laboratory report is expected soon.

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February 29, 2024

• PFAS impact analysis has been completed by Global Environmental and has been reviewed by Michigan PFAS Action Response Team (MPART) Specialists. The analysis of the firefighting foam indicated that the parameters were non-detect for total PFAS and total oxidizable precursor PFAS and through previous work done by the Massachusetts Department of Environmental Protection (MassDEP) and the Connecticut Department of Energy and Environmental Protection (CTDEEP) of various PFAS-free/fluorine-free firefighting foams. Based upon the information gathered from these sources, including laboratory analyses, manufacturer specifications, and evaluations by authoritative bodies, the results consistently support the absence of PFAS, including precursors, in the firefighting foam used during this incident. Global Environmental will be providing additional documentation summarizing remedial efforts at the site including a separate update from the lab.

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Project details provided by EGLE: https://www.michigan.gov/egle/about/organization/oil-gas-and-minerals/incidents/white-lake