EPA Superfund Option Details

Recent ACWG Meeting Agenda Items and Update Page

Details from Agenda Entry - January 21, 2016

CARD Discussion of the Option to have the Pall/Gelman 1,4-Dioxane Contamination Become a US EPA Superfund Site

Over the past few months there has been a discussion by Coalition for Action on Remediation of Dioxane (CARD) of the option to propose the Pall/Gelman 1,4-Dioxane contamination be turned into a EPA Superfund Site. This discussion includes public officials and government staff. CARD group has indicated a general support for this option. See the information regarding Pall/Gelman Superfund Site Option below. This information was created by Dan Bicknell with the help of Roger Rayle, both CARD members, and in general the CARD group. Dan Bicknell was the student who discovered the 1,4-Dioxane in Sisters Lake as a Masters student at UM SPH and lived near by. He has gone on be EPA Region 5 health effects staffer among other things and now his own SE Michigan consulting firm Global Environment Alliance, LLC.

Also, MDEQ has not acted on high readings in the southern section of the Prohibition Zone (PZ) that should trigger the redefinition of the PZ southward. This change in the PZ would likely include the North West Supply Well at Montgomery Ave and Bemidji Dr. something that will cause the city more problems as this may cause the well to be an unavailable as back up drinking water well in the event of a major spill on the Huron River up stream of Barton Pond. They have readings at or above 85 ppb at the edge of the southern PZ. Now MDEQ has said they will wait till they get two consecutive months at or above 85 ppb but the MDEQ is not doing split samples with Pall every month now but every quarter. So this trigger may be much harder or impossible to attain without any court involvement in this change.

The Northern PZ has already been enlarged by the Court to the north in 2011.

The MDEQ is also not using the best available technology (BAT) in monitoring the site, because the state’s '85 ppb standard does not require it'.

Yet the US EPA is using 3.5 and .3 ppb in other parts of the US as a drinking water cleanup standard. The US EPA it would seem will be moving toward setting a national drinking water standard based on new studies and modeling to 3.5 ppb for 1 in 100,000 cancer risk and .35 ppb for 1 in M in the next few years. In years past Michigan had used the 1 in M standard but is now using the 1 in 100,000 cancer risk standard.

With the problems of the MDEQ causing and handling of the Flint drinking water crisis it seems more important than ever to be proactive in protecting the drinking water of Ann Arbor and our environment.

The ACWG as part of CARD supports the Superfund option discussion and what will be a request.

Links: Michigan Department of Environmental Quality (MDEQ)-Gelman Project Site; Washtenaw County CARD Site; Scio Residents for Safe Water (SRSW)

Pall/Gelman Superfund Site Option:

Daniel J. Bicknell, MPH

G l o b a l

E n v i r o n m e n t

A l l i a n c e , L L C

Gelman Sciences, Inc – USEPA Superfund Site

How Sites are Placed on the National Priorities List

Sites are first proposed to the National Priorities List (NPL) in the Federal Register. NPL Sites are commonly called Superfund Sites. EPA then accepts public comments on the sites, responds to the comments, and places on the NPL those sites that continue to meet the requirements for listing.

Section 300.425(c) of the NCP, the Federal regulation by which CERCLA is implemented (55 FR 8845, March 8, 1990), provides three mechanisms for placing sites on the NPL:

• • The first mechanism is EPA's Hazard Ranking System (HRS).

  • The second mechanism for placing sites on the NPL allows States or Territories to designate one top-priority site regardless of score.

  • The third mechanism allows listing a site if it meets all three of these requirements:

  • The Agency for Toxic Substances and Disease Registry (ATSDR) of the U.S. Public Health Service has issued a health advisory that recommends removing people from the site;

  • EPA determines the site poses a significant threat to public health; and

  • EPA anticipates it will be more cost-effective to use its remedial authority (available only at NPL sites) than to use its emergency removal authority to respond to the site.