EPA Superfund Petitioners Response 11-10-17
For Immediate Release:
November 10, 2017
Ann Arbor Charter Township, Scio Township and the Sierra Club Response to USEPA Decision to Suspend Process to Designate the Gelman Site as a Federal USEPA Superfund Site
Ann Arbor, Mich. – The United States Environmental Protection Agency (USEPA) announced on November 7, 2017 that it will suspend the process to designate the Gelman Science, Inc. (Gelman) site located in Scio Township, MI as a federal USEPA Superfund Site. Ann Arbor Charter Township, Scio Township, and the Sierra Club – Huron Valley Group petitioned USEPA in November 2016 to conduct a Preliminary Assessment for the Gelman Site to become a federal USEPA Superfund Site.
The USEPA Response Letter to the Petitioners states that it will allow the Michigan Department of Environmental Quality (DEQ) to continue with the remedy provided under the current Consent Judgment between Gelman and the DEQ. The USEPA Preliminary Assessment was completed and concluded that “…the Gelman Facility qualifies for further investigations and next steps in the National Priorities List [Superfund] listing process.” Following the normal Superfund Site designation process, the USEPA should conduct a Site Inspection/Investigation (SI) on the Gelman Site to independently verify the DEQ data and obtain additional information to fill any data gaps, see attached Superfund Site Assessment Flow Diagram. However, at the request of DEQ, the USEPA will instead implement a monitoring of the situation approach with the DEQ providing routine reports to USEPA. USEPA reserves its option to pursue federal enforcement actions against Gelman.
“The USEPA decision to stop the work towards having the Gelman Site become a federal Superfund Site is a very negative development for our community. Local governments and community groups have worked for many years with the Michigan Department of Environmental Quality (DEQ) on remediation options for the Gelman Site that protect human health and are consistent with USEPA policy. Unfortunately, DEQ has been unwilling or unable to obtain a protective cleanup which save-guards the Ann Arbor Charter Township drinking water supply. USEPA should move forward with the Superfund designation process as it would normally do and perform the Site Inspection/Investigation”, said Michael Moran, Supervisor – Ann Arbor Charter Township.
“Many Scio Township drinking water wells have been contaminated with dioxane, yet the DEQ remedy has not prevented the dioxane plume from expanding towards other residential wells in the Township. We understand that the USEPA has indicated that if the Gelman Site was a USEPA Superfund Site, as a first priority, it would extend (at a Gelman cost) the municipal drinking water supply to any resident which is directly impacted by the dioxane groundwater plume. This lack of federal action to move the Gelman Superfund Site designation process forward will not help protect our residents and their properties from further dioxane contamination.” said Jack Knowles, Supervisor – Scio Township. The group believes that the USEPA cleanup will provide better protection than the DEQ approach as they have been told that the USEPA will restore the polluted aquifer to a drinking water criterion, provide a Contingency Plan for Barton Pond which is the main City of Ann Arbor water supply, provide alternative potable water supplies to impacted homes, and utilize a scientifically sound drinking water criterion.
The Gelman Site today is owned by PALL Life Sciences, Inc., a wholly owned subsidiary of Danaher Corporation, and there are no active plant operations. Historically, the plant manufactured filter devices and used dioxane as a solvent. It is estimated that 800,000 pounds of dioxane was used between 1966 and 1986 with most being discharged to soil, surface water, and groundwater through seepage lagoons, land spray irrigation, and direct discharges at the site. Wastewater disposal practices at the former Gelman plant located near Ann Arbor contaminated on-site and off-site groundwater with the known carcinogen 1,4-dioxane (dioxane). The dioxane groundwater plume, which currently is about four miles long and one mile wide, has polluted local lakes, creeks, residential drinking water wells, and a City of Ann Arbor municipal water supply well.
“The Sierra Club is disappointed with the USEPA decision to keep the Gelman Site in the State of Michigan cleanup program. We have been concerned about a lack of follow-through in the DEQ’s monitoring and data collection. As in Flint, we need the federal government to assist the local community with this large groundwater contamination problem which presents an imminent and substantial endangerment to public health and the environment. The USEPA should review its decision to not continue the normal listing process” said Nancy Shiffler, Sierra Club – Huron Valley Group – Chair.
In a July 25, 2016 meeting between USEPA and local government representatives, the USEPA – Region 5 Office indicated that, based upon federal USEPA Superfund sites similar to the Gelman Site, the main benefits of a Gelman USEPA Superfund Site would include:
Active restoration of the aquifer to a protective drinking water criterion, regardless of whether the dioxane plume is in a Prohibition Zone or not, at a Gelman cost;
As a first USEPA priority, extend the municipal drinking water supply to any resident who may be potentially adversely impacted by the dioxane groundwater plume at a Gelman cost;
Halt the expansion of the dioxane plume and treat the source and outer margins of the dioxane plume with an active remedial technology like groundwater extraction and treatment at a Gelman cost;
The active remedial action would prevent the potential dioxane contamination of Barton Pond, so no additional Contingency Plan would be required to protect Barton Pond; and
The USEPA will require that Gelman pay for residential well sampling and dioxane analysis at homes immediately down-gradient of the dioxane plume.
The dioxane plume continues to migrate in all directions with no effective off-site hydraulic control. Numerous Scio Township and Ann Arbor Charter Township private residential drinking water wells are down-gradient of the plume. The City of Ann Arbor’s main drinking water supply comes from the Huron River at Barton Pond, which potentially could be impacted as the dioxane plume expands. As the shallow dioxane plume migrates through the City, it may adverse impact: homes through building vapor intrusion; and utility workers who come into contact with the contaminated groundwater. A large portion of the off-site dioxane plume is greater than 1,000 ug/L (parts-per-billion) dioxane, while the USEPA dioxane drinking water criterion is 0.35 ug/L at a 1 in 1,000,000 excess lifetime cancer risk level.
Michael Moran - Ann Arbor Charter Township – Supervisor – 734-663-3418
Jack Knowles - Scio Township – Supervisor – 734-369-9400
Nancy Shiffler - Sierra Club – Huron Valley Group – Chair – 734-971-1157
Attachment – Superfund Site Assessment Flow Diagram (vpc: see site page: EPA Superfund Option Details)