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Allen's Creek Watershed Group, Ann Arbor, MI >
Recent ACWG Meeting Agenda Items and Updates >
Click to view Older Agenda Items and Updates Page 2 >
Click to view Older Agenda Items and Updates Page 3 >
Proposed Agenda and Updates:
November 21, 2019
Danaher/Pall/Gelman 1,4-Dioxane Plume Near-Surface Groundwater Tests Requested by CARD ACWG
August 2019; No Meeting this Month Due to Vacation and Travel Schedules
Watershed Issues of Interest and Updates:
Danaher/Pall/Gelman 1,4-Dioxane Plume EPA Superfund Joint Session September 12
Recent data show some movement outside the PZ at low levels with the monitoring of existing drinking water wells. Gelman has some monitoring wells but not enough.
Judge Shelton blocked more monitoring wells installation in past years, as requested by MDEQ (now Michigan Department of Environment, Great Lakes, and Energy (EGLE) ), stating the new wells were not needed and would be too costly for Gelman. This is Gelman's plume they need to do monitoring with their own wells not use homeowner's wells.
City, County and Townships plan a follow up Joint Session on September 12 to discuss EPA Superfund for Gelman Plume. Time and location TBA.
This joint session could result in an affirmative vote for Full Superfund Evaluation of the Gelman Plume.
With all the work the Coalition for the Remediation of Dioxane (CARD) group, city and county has done the EPA will have a head-start on this effort. The score of the partial Superfund Evaluation was very high for Superfund Listing with a minimal evaluation.
Concern was again discussed at the recent Coalition for the Remediation of Dioxane (CARD) Group meeting that the EGLE - Environment, Great Lakes & Energy regarding no current Near-Surface Groundwater (NSG) monitoring. The need for permanent wells was again commented on by ACWG and CARD members.
I and other CARD members discussed and did go out last week and check for seeps and elevations of seeps on the westside of the city. During this seep tour it was noted large flows of water were in the Allen's Creek pipe in South West West Park entrance with very dry conditions, seeming to indicate high groundwater flows in the pipe as has been described previously. Seeps are said to be in many areas of the city on the west side including higher elevations. The elevations of found seeps will help determine risk to homeowners through potential contaminated water infiltrating into the basement and evaporating with 1,4 Dioxane into the air of a confined basement space. Many westside homes have wet basements, some from groundwater infiltration. See the previous neighbor survey of the Glendale Virginia St. areas in past agenda items. Two homes recently built where this map covers had the basement areas fill with water less than a week after being dug.
The Ann Arbor Township, Scio Township, Washtenaw County Board of Commissions, Sierra Club Huron ValleyGroup (SCHGV), the Coalition for the Remediation of Dioxane (CARD) and Allen’s Creek Watershed Group (ACWG) all voted in supported a petition to the US EPA for Full Preliminary Assessment of the Gelman 1,4-Dioxane groundwater contamination.
Governor Whitmer would be much more approachable than our previous Republican Governor.
Still no comment on a real plan of action on the NSG exposure potential and permanent well monitoring, not simply more minimal tests. Dan Bicknell's GEA Comments on the DEQ Shallow Groundwater Work Plan and his proposed plan is posted in the November 2016 Agenda. Dan had a very well and logical plan laid out for dealing with the initial investigation of the NSG issue which seems to be clearly a problem that needs addressing.
The ACWG and CARD Groups has asked for permanent monitoring of NSG wells on the near west side of the city with no indication of action on this.
Links:
Aug 6, 2019 Coalition for the Remediation of Dioxane (CARD) Group Meeting Video - Taped by Roger Rayle, Chair CARD
Ann Arbor is at a pivotal point with Gelman dioxane plume MLive Ryan Stanton
Dioxane detected in Ann Arbor drinking water from Barton Pond for first time: Mlive Martin Slagter
Dioxane test results for Allen Creek raise more questions: MLive Ryan Stanton
Ongoing discharges may be to blame for dioxane in Ann Arbor drinking water: MLive Ryan Stanton
Environment, Great Lakes & Energy (formally MDEQ)-Gelman Project Site; Washtenaw County CARD Site; Scio Residents for Safe Water (SRSW)
Lots of stores by Ryan Stanton in Ann Arbor News/MLive including this recent article 'EPA holding off on Superfund designation for Gelman dioxane plume'
Lots of details from Barbara Lucus at Dioxane.Org and WEMU News Program GreenRoom
See ACWG site pages EPA Superfund Option Details
Click here to view and/or sign in support of Superfund Designation
DTE Energy Top 10 Worst Water Polluters in USA; Recent Discussions of Development of Polluted DTE Site at Depot St and 841 Broadway St In the FW FP - No Real Cleanup Proposed'
DTE Site, Mostly Floodway
(City of Ann Arbor GIS Web Site; Click for Larger Image)
Coal Tar (highly toxic) found at the DTE Site and shown by DEQ at river's edge at the site, the pollution at the river's edge subsequently cleaned up in recent years (WUOM) but is still leaching into the Huron River
DTE Energy rated top 10 worst Water Polluter in the USA.
'Researchers at the University of Massachusetts Amherst have published three lists detailing the 100 worst air, water and greenhouse gas polluters in the country.
The lists — the Toxic 100 Air Polluters Index, Toxic 100 Water Polluters Index and Greenhouse 100 Index — rank industrial polluters based on complex “right-to-know” data released annually by the federal Environmental Protection Agency. The set of researchers at the university’s Political Economy Research Institute, or PERI, have been producing the first two lists for about 15 years.' - Sierra Club MI Leaders Forum EMail
DTE Energy is rated in this list as a one of the top 10 worst Water Polluter in the USA.
Coal Tar from the DTE 841Broadway St site is leaching into the Huron River and the groundwater is said to be contaminated. This site is the site of old Huron River Riverbed pre early 1900's.
The proposed building in and near contaminated soil will be dangerous and make future cleanup by responsible leaders trying to protect the environment nearly impossible. This contamination are up to 30 feet down on the site. Special construction techniques will need to be used to build on top of the contaminated soils according to comments from the developer and city staff at public meetings.
Flood hazard is getting worse, not better with Global Warming. This site is in the site of the old Huron River riverbed, just downstream of two dams both of which were breached in the 1968 100-year (1% chance) flood, that had 15 feet of water flowing over this site. The 1968 flood is more like a 50 year (2% chance) flood of today by most accounts. See recent reports below.
They are planning a Brownfield partial cleanup with about $25M from taxpayers, and about $12M from the developer.
This will not be a full cleanup as they say this is not required in the current very weak MI Part 201 statute.
DTE, a $26B company, should be doing a cleanup of this site as the Responsible Party Legal Owner, not taxpayers. Polluter Pay legislation has been introduced in Lansing this year.
If done right could be a nice park close to the city center. When it floods hose it off and go back to being a park, like many progressive (and non-progressive) cities are doing.
All of the other outcroppings in the Huron River near Ann Arbor and beyond are parks due to the flood hazard associated with them.
Link to article: https://www.gazettenet.com/UMass-researchers-list-country-s-top-water-air-greenhouse-gas-polluters-27421770
12" Rain Hits Manistee County July 20th, with Major Flooding; New Normal for Michigan
US 31 - Manistee, MI; Edward Bradford Weather.Gov
'Heavy rain accompanied the thunderstorms with the hardest-hit areas across portions of Manistee, Mason, and Lake counties in northwest lower Michigan on July 20, 2019.' : NWS
12" rain in 24 hours caused flooding and severe erosion in the area. These types of historic rains are the new normal for Michigan and other parts of the nation, the 1,000-year June 2018 rain in the MI UP and 10,000-year April 2016 “Tax Day” rain in Houston for example.
CityLab - MapLab: The Hidden Risks in U.S. Flood Maps; July 31, 2019
Several Buildings Recently Approved, and Built or Being Built,
in the Floodplain Near W Kingsley St and N First St on the City Westside
(City of Ann Arbor GIS; Click for Larger Image)
While the city of Ann Arbor approves more homes in and near the floodplain and near the floodway FEMA is accused of "low balling" the federal Floodplain Maps used by communities like Ann Arbor.
During a July 4th, 2019 1.5" rainfall over in 1/2 hour, as described in the previous ACWG agenda, the streets leading to these sites shown above were impassable and had major flooding with manhole covers flying off.
Some of these new homeowners will be parking their cars in the floodway in the floodplain on top of a massive Allen's Creek storm drain.
“[The current FEMA flood maps] leaves out critical risk factors, including how climate change has changed storm patterns and sea-level rise, or where new development has covered up permeable surfaces with pavement and concrete.
”That has led numerous researchers to conclude that FEMA underestimates flood risk, by a long shot. According to a study from 2018, 41 million Americans are at risk of experiencing a 100-year flood, nearly triple FEMA’s official count.” (bold by us): CityLab.
Link CityLab
https://www.citylab.com/newsletter-editions/2019/07/maplab-hidden-risks-flood-maps/595126/
August 2019; No Meeting this Month Due to Vacation and Travel Schedules
Watershed Issues of Interest and Updates:
Danaher/Pall/Gelman 1,4-Dioxane Plume EPA Superfund Joint Session September 12
Recent data show some movement outside the PZ at low levels with the monitoring of existing drinking water wells. Gelman has some monitoring wells but not enough.
Judge Shelton blocked more monitoring wells installation in past years, as requested by MDEQ (now Michigan Department of Environment, Great Lakes, and Energy (EGLE) ), stating the new wells were not needed and would be too costly for Gelman. This is Gelman's plume they need to do monitoring with their own wells not use homeowner's wells.
City, County and Townships plan a follow up Joint Session on September 12 to discuss EPA Superfund for Gelman Plume. Time and location TBA.
This joint session could result in an affirmative vote for Full Superfund Evaluation of the Gelman Plume.
With all the work the Coalition for the Remediation of Dioxane (CARD) group, city and county has done the EPA will have a head-start on this effort. The score of the partial Superfund Evaluation was very high for Superfund Listing with a minimal evaluation.
Concern was again discussed at the recent Coalition for the Remediation of Dioxane (CARD) Group meeting that the EGLE - Environment, Great Lakes & Energy regarding no current Near-Surface Groundwater (NSG) monitoring. The need for permanent wells was again commented on by ACWG and CARD members.
I and other CARD members discussed and did go out last week and check for seeps and elevations of seeps on the westside of the city. During this seep tour it was noted large flows of water were in the Allen's Creek pipe in South West West Park entrance with very dry conditions, seeming to indicate high groundwater flows in the pipe as has been described previously. Seeps are said to be in many areas of the city on the west side including higher elevations. The elevations of found seeps will help determine risk to homeowners through potential contaminated water infiltrating into the basement and evaporating with 1,4 Dioxane into the air of a confined basement space. Many westside homes have wet basements, some from groundwater infiltration. See the previous neighbor survey of the Glendale Virginia St. areas in past agenda items. Two homes recently built where this map covers had the basement areas fill with water less than a week after being dug.
The Ann Arbor Township, Scio Township, Washtenaw County Board of Commissions, Sierra Club Huron ValleyGroup (SCHGV), the Coalition for the Remediation of Dioxane (CARD) and Allen’s Creek Watershed Group (ACWG) all voted in supported a petition to the US EPA for Full Preliminary Assessment of the Gelman 1,4-Dioxane groundwater contamination.
Governor Whitmer would be much more approachable than our previous Republican Governor.
Still no comment on a real plan of action on the NSG exposure potential and permanent well monitoring, not simply more minimal tests. Dan Bicknell's GEA Comments on the DEQ Shallow Groundwater Work Plan and his proposed plan is posted in the November 2016 Agenda. Dan had a very well and logical plan laid out for dealing with the initial investigation of the NSG issue which seems to be clearly a problem that needs addressing.
The ACWG and CARD Groups has asked for permanent monitoring of NSG wells on the near west side of the city with no indication of action on this.
Links:
Aug 6, 2019 Coalition for the Remediation of Dioxane (CARD) Group Meeting Video - Taped by Roger Rayle, Chair CARD
Ann Arbor is at a pivotal point with Gelman dioxane plume MLive Ryan Stanton
Dioxane detected in Ann Arbor drinking water from Barton Pond for first time: Mlive Martin Slagter
Dioxane test results for Allen Creek raise more questions: MLive Ryan Stanton
Ongoing discharges may be to blame for dioxane in Ann Arbor drinking water: MLive Ryan Stanton
Environment, Great Lakes & Energy (formally MDEQ)-Gelman Project Site; Washtenaw County CARD Site; Scio Residents for Safe Water (SRSW)
Lots of stores by Ryan Stanton in Ann Arbor News/MLive including this recent article 'EPA holding off on Superfund designation for Gelman dioxane plume'
Lots of details from Barbara Lucus at Dioxane.Org and WEMU News Program GreenRoom
See ACWG site pages EPA Superfund Option Details
Click here to view and/or sign in support of Superfund Designation
DTE Energy Top 10 Worst Water Polluters in USA; Recent Discussions of Development of Polluted DTE Site at Depot St and 841 Broadway St In the FW FP - No Real Cleanup Proposed'
DTE Site, Mostly Floodway (City of Ann Arbor GIS Web Site; Click for Larger Image)
Coal Tar (highly toxic) found at the DTE Site and shown by DEQ at river's edge at the site, the pollution at the river's edge subsequently
cleaned up in recent years (WUOM) but is still leaching into the Huron River
DTE Energy rated top 10 worst Water Polluter in the USA.
'Researchers at the University of Massachusetts Amherst have published three lists detailing the 100 worst air, water and greenhouse gas polluters in the country.
The lists — the Toxic 100 Air Polluters Index, Toxic 100 Water Polluters Index and Greenhouse 100 Index — rank industrial polluters based on complex “right-to-know” data released annually by the federal Environmental Protection Agency. The set of researchers at the university’s Political Economy Research Institute, or PERI, have been producing the first two lists for about 15 years.' - Sierra Club MI Leaders Forum EMail
DTE Energy is rated in this list as a one of the top 10 worst Water Polluter in the USA.
Coal Tar from the DTE 841Broadway St site is leaching into the Huron River and the groundwater is said to be contaminated. This site is the site of old Huron River Riverbed pre early 1900's.
The proposed building in and near contaminated soil will be dangerous and make future cleanup by responsible leaders trying to protect the environment nearly impossible. This contamination are up to 30 feet down on the site. Special construction techniques will need to be used to build on top of the contaminated soils according to comments from the developer and city staff at public meetings.
Flood hazard is getting worse, not better with Global Warming. This site is in the site of the old Huron River riverbed, just downstream of two dams both of which were breached in the 1968 100-year (1% chance) flood, that had 15 feet of water flowing over this site. The 1968 flood is more like a 50 year (2% chance) flood of today by most accounts. See recent reports below.
They are planning a Brownfield partial cleanup with about $25M from taxpayers, and about $12M from the developer.
This will not be a full cleanup as they say this is not required in the current very weak MI Part 201 statute.
DTE, a $26B company, should be doing a cleanup of this site as the Responsible Party Legal Owner, not taxpayers. Polluter Pay legislation has been introduced in Lansing this year.
If done right could be a nice park close to the city center. When it floods hose it off and go back to being a park, like many progressive (and non-progressive) cities are doing.
All of the other outcroppings in the Huron River near Ann Arbor and beyond are parks due to the flood hazard associated with them.
Link to article: https://www.gazettenet.com/UMass-researchers-list-country-s-top-water-air-greenhouse-gas-polluters-27421770
12" Rain Hits Manistee County July 20th, with Major Flooding; New Normal for Michigan
US 31 - Manistee, MI; Edward Bradford Weather.Gov
'Heavy rain accompanied the thunderstorms with the hardest-hit areas across portions of Manistee, Mason, and Lake counties in northwest lower Michigan on July 20, 2019.' : NWS
12" rain in 24 hours caused flooding and severe erosion in the area. These types of historic rains are the new normal for Michigan and other parts of the nation, the 1,000-year June 2018 rain in the MI UP and 10,000-year April 2016 “Tax Day” rain in Houston for example.
CityLab - MapLab: The Hidden Risks in U.S. Flood Maps; July 31, 2019
Several Buildings Recently Approved, and Built or Being Built,
in the Floodplain Near W Kingsley St and N First St on the City Westside
(City of Ann Arbor GIS; Click for Larger Image)
While the city of Ann Arbor approves more homes in and near the floodplain and near the floodway FEMA is accused of "low balling" the federal Floodplain Maps used by communities like Ann Arbor.
During a July 4th, 2019 1.5" rainfall over in 1/2 hour, as described in the previous ACWG agenda, the streets leading to these sites shown above were impassable and had major flooding with manhole covers flying off.
Some of these new homeowners will be parking their cars in the floodway in the floodplain on top of a massive Allen's Creek storm drain.
“[The current FEMA flood maps] leaves out critical risk factors, including how climate change has changed storm patterns and sea-level rise, or where new development has covered up permeable surfaces with pavement and concrete.
”That has led numerous researchers to conclude that FEMA underestimates flood risk, by a long shot. According to a study from 2018, 41 million Americans are at risk of experiencing a 100-year flood, nearly triple FEMA’s official count.” (bold by us): CityLab.
Link CityLab
https://www.citylab.com/newsletter-editions/2019/07/maplab-hidden-risks-flood-maps/595126/
Proposed Agenda and Updates:
July 18, 2019
Danaher/Pall/Gelman 1,4-Dioxane Plume Monitoring Using Residential Wells
Concern discussed at the recent Coalition for the Remediation of Dioxane (CARD) Group meeting that the EGLE - Environment, Great Lakes & Energy is using existing drinking water wells as sentinels for the Plume migration into new areas outside the Prohibition Zone (PZ). Monitoring Wells need to be installed to track the Plume, not homeowner's wells.
Recent data show some movement outside the PZ at low levels with the monitoring of existing drinking water wells. Gelman has some monitoring wells but not enough.
Judge Shelton blocked more monitoring wells installation in past years as requested by MDEQ, now EGLE, stating the new wells were not needed and would be too costly for Gelman. This is Gelman's plume they need to do monitoring with their own wells not use homeowner's wells.
No change on the suspension of an Action Plan for Well 103s with high readings at the edge of the PZ. At the March CARD Meeting the DEQ presented a letter written on March 1, '19 where Dana Nessel wrote to Gelman (copy available) indicating that while there are Confidential Negotiations with plaintiffs on the Consent Judgment on the Gelman Plume management the recent two 85 ppb readings at Monitoring Well 103s at Glendale and Abbott do not trigger the past agreement that an MDEQ/Gelman Action Plan should be undertaken to deal with the possibility that outside the Prohibition Zone 85 ppb may occur in a short time which was prohibited. Well 103 is near the edge of the PZ.
The Ann Arbor Township, Scio Township, Washtenaw County Board of Commissions, Sierra Club Huron Valley Group (SCHGV), the Coalition for the Remediation of Dioxane (CARD) and Allen’s Creek Watershed Group (ACWG) all voted in supported a petition to the US EPA for Full Preliminary Assessment of the Gelman 1,4-Dioxane groundwater contamination.
Governor Whitmer would be much more approachable than our previous Republican Governor.
Still no comment on a real plan of action on the NSG exposure potential and permanent well monitoring, not simply more minimal tests. Dan Bicknell's GEA Comments on the DEQ Shallow Groundwater Work Plan and his proposed plan is posted in the November 2016 Agenda. Dan had a very well and logical plan laid out for dealing with the initial investigation of the NSG issue which seems to be clearly a problem that needs addressing.
The ACWG and CARD Groups has asked for permanent monitoring of NSG wells on the near west side of the city with no indication of action on this.
Links:
July 2, 2019 Coalition for the Remediation of Dioxane (CARD) Group Meeting Video - Taped by Roger Rayle, Chair CARD
Ann Arbor is at a pivotal point with Gelman dioxane plume MLive Ryan Stanton
Dioxane detected in Ann Arbor drinking water from Barton Pond for first time: Mlive Martin Slagter
Dioxane test results for Allen Creek raise more questions: MLive Ryan Stanton
Ongoing discharges may be to blame for dioxane in Ann Arbor drinking water: MLive Ryan Stanton
Environment, Great Lakes & Energy (formally MDEQ)-Gelman Project Site; Washtenaw County CARD Site; Scio Residents for Safe Water (SRSW)
Lots of stores by Ryan Stanton in Ann Arbor News/MLive including this recent article 'EPA holding off on Superfund designation for Gelman dioxane plume'
Lots of details from Barbara Lucus at Dioxane.Org and WEMU News Program GreenRoom
See ACWG site pages EPA Superfund Option Details
Click here to view and/or sign in support of Superfund Designation
Recent Discussions of Development of Polluted DTE Site at Depot St and 841 Broadway St In the FW FP - No Real Cleanup Proposed
DTE Site, Mostly Floodway in Blue (City of Ann Arbor GIS Web Site; Click for Larger View)
Coal Tar (highly toxic) found at the DTE Site and shown by DEQ at river's edge at the site,
the pollution at the river's edge subsequently cleaned up in recent years (WUOM)
but is still leaching into the Huron River
At public meeting for this project I attended, but ACWG was not invited to for some reason, the developer described the materials buried on site as 'Inert', which I challenged. Coal Tar is not Inert as we wrote last month and commented on earlier this month before Council's Meeting with Public Hearing for this project.
“Inert waste is waste which is neither chemically nor biologically reactive and will not decompose. Examples of this are sand and concrete. This has particular relevance to landfills as inert waste typically requires lower disposal fees than biodegradable waste or hazardous waste.”
This Coal Tar is leaching into the Huron River and the groundwater is said to be contaminated. This site is the site of old Huron River Riverbed pre early 1900's.
At a CARD meeting years ago discussion of the Ann Arbor City Apartments at Washington and First came up regarding the below-ground parking 2 stories below grade. The ACWG and others asked about potential groundwater contamination with 1,4 Dioxane issues with this city-owned parking garage below in the path of the plume, deep into the water table. Soon thereafter we learned the city did a stop-work order to make changes the soon to be started building, to raise the building a full 2 stories up to avoid this issue. The city explicit requirement not to have parking on the street level was quickly thrown out the window. At the DTE site we know we have major pollution below the surface and yet feel OK with building residential above it very close to the dangerous pollution.
Flood hazard is getting worse, not better with Global Warming, see citations below. This site is in the site of the old Huron River riverbed, just downstream of two dams both of which were breached in the 1968 100-year (1% chance) flood, that had 15 feet of water flowing over this site. The 1968 flood is more like a 50 year (2% chance) flood of today by most accounts.
They are planning a Brownfield partial cleanup with about $25M from taxpayers, and about $12M from the developer.
This will not be a full cleanup as they say this is not required in the current very weak MI Part 201 statute.
DTE, a $26B company, should be doing a cleanup of this site as the Responsible Party Legal Owner, not taxpayers. Polluter Pay legislation has been introduced in Lansing this year.
If done right could be a nice park close to the city center. When it floods hose it off and go back to being a park, like many progressive (and non-progressive) cities are doing.
All of the other outcroppings in the Huron River near Ann Arbor and beyond are parks due to the flood hazard associated with them.
Climate Change Fuels Wetter Storms
Manholes blown off in Ann Arbor July 4th in a Just a 1.5" Rain Event, This one quickly replacing by a nearby resident as floodwater recedes
to avoid cars falling into it on Murry Ave. Just one example of why not to drive down flooded streets. See more below.
(ACWG; Click for Larger View)
Ann Arbor 100 year, 1% chance, storm is about 4.75 inches of rain in 24 hours. In the March 15, 2012 Dexter Tornado Rain Event Lawton neighborhood got 5-6 inches according to NexRad estimate, and ACWG spotter rain data, in about 2 hours.
* Update: Evan Pratt (Washtenaw County Water Resources Commissioner) pass along the latest 100 year, 1% chance, NOAA estimate for Ann Arbor is 5.11 inches in 24 hours.
Larger and heavier rains are happening now due to Global Warming's effects.
Climate Change Fuels Wetter Storms
A study published last year found that hurricanes including Katrina, Irma and Maria are dumping about 5 to 10% more rain than they would have if global warming wasn't happening.
"Increasing precipitation, especially heavy rain events, has increased the overall flood risk,"according to the most recent National Climate Assessment.
There is an "uptick in the number of extreme rain events in many parts of the U.S. as the earth gets hotter." (Bold by us)
Even as Floods Worsen, Midwest Towns Plan New Riverfront Development
Association of State Floodplain Managers 2007 (ASFPM)
(Click for larger image)
"BUILDING IN THE FLOODPLAIN IS LIKE PITCHING YOUR TENT
ON A HIGHWAY WHEN THERE ARE NO CARS COMING"!
ASFPM: www.floods.org
Washington Post Report July 13
'This year’s historic floods throughout the Midwest caused billions of dollars in damages; washed out highways, bridges and dozens of levees; swamped crop lands and cities; sent residents fleeing for their lives; and left a death toll in several states.
“It’s lunacy,” said David Stokes, executive director of the Great Rivers Habitat Alliance. “They’re continuing to build in places where Mother Nature intended water to go. And there’s no end to it.”
“We’re dealing with a problem that doesn’t seem to want to go away,” said Gerald E. Galloway, a retired brigadier general in the Army Corps of Engineers and now a professor of engineering at the University of Maryland.
“What was yesterday’s high water is now much higher,” said Galloway, lead author of the federal report.
What’s more, the National Flood Insurance Program has not kept up with development and climate change, experts say, with outdated mapping of flood-prone areas and slow-to-come buyout payments for homeowners who want to move.
“Our building codes and zoning need to keep pace and account for growing risk,” said Carolyn Kousky, director of the Wharton Risk Management and Decision Processes Center at the University of Pennsylvania.' (Bold by us)
In just a 1.5" rain in 30 minutes on this July 4th a quick perusal of the westside showed several streets, some with new developments in the floodplain, had flood waters blowing off manhole covers and flooding streets and cars, as shown below.
Cars driving thru deep floodwater with water geysering out of a
blown manhole onW Kingsley St. (ACWG; Click for Larger View)
Kingsley Manhole Geysering Midstorm* (ACWG; Click for Larger View)
An unattended car being flooded on N Ashley in mid-storm.
(ACWG; Click for Larger View)
Proposed Agenda and Updates:
June 20, 2019
Danaher/Pall/Gelman 1,4-Dioxane Plume EPA Superfund Discussions, Local Government Official Have 3 Months to Decide to Ask Governor Whitmer to Ask EPA for Superfund Full Evaluation and Assistance, June 6, 2019.
Joint Session Gelman Superfund Discussion (Ryan Stanton | The Ann Arbor News)
Click photo to view MLive Video
A joint session of the Ann Arbor City Council, Washtenaw County Board of Commissioners, and Scio and Ann Arbor township boards met to discuss EPA Superfund Support. Members of the Coalition for the Remediation of Dioxane (CARD) Group attended the meeting with U.S. Rep. Debbie Dingell, County Health Dept., Michigan Department of Environment, Great Lakes, and Energy (EGLE) (former MDEQ), other elected officials and residents. About 150 people attended according to MLive's Ryan Stanton.
CTN recorded the meeting and posted on their web site.
Ryan Stanton with MLive has a report and video of part of the meeting.
Here is also a video of the June 4th CARD meeting by Roger Rayle on Youtube - https://www.youtube.com/watch?v=IY6IW-ArMf8https://www.youtube.com/watch?v=HWYcdNVt_EU
EPA has indicated they will pull away from the Gelman monitoring unless they get a message from Governer Whitmer that she is willing to let EPA continue to a Full Evaluation and potential Superfund.
The Joint Session of city, county and Scio Twp leaders agreed to try and get some significant motion from Gelman until September 12 this year, the next Joint Meeting. If Gelman is not forthcoming they will likely petition the Governor to ask EPA for a full Superfund Evaluation.
City of Ann Arbor City Council voted to work with Interveners:
RESOLVED, That the City Council directs the City Administrator, by July 1, 2019, to take all reasonable steps to convene a meeting with the other State-Lawsuit interveners to explore requesting EPA’s active involvement with the Gelman site and its listing as a “Superfund” site under CERCLA by, among other things, soliciting a concurrence letter from the Governor;
The Ann Arbor Township, Scio Township, Washtenaw County Board of Commissions, Sierra Club Huron Valley Group (SCHGV), the Coalition for the Remediation of Dioxane (CARD) and Allen’s Creek Watershed Group (ACWG) all voted in support of a petition to the US EPA for Full Preliminary Assessment of the Gelman 1,4-Dioxane groundwater contamination.
Governor Whitmer would be much more approachable than our previous Republican Governor.
Still no comment on a real plan of action on the NSG exposure potential and permanent well monitoring, not simply more minimal tests. Dan Bicknell's GEA Comments on the DEQ Shallow Groundwater Work Plan and his proposed plan is posted in the November 2016 Agenda. Dan had a very well and logical plan laid out for dealing with the initial investigation of the NSG issue which seems to be clearly a problem that needs addressing.
The ACWG and CARD Groups has asked for permanent monitoring of NSG wells on the near west side of the city with no indication of action on this.
Links:
Ann Arbor is at a pivotal point with Gelman dioxane plume MLive Ryan Stanton
Dioxane detected in Ann Arbor drinking water from Barton Pond for first time: Mlive Martin Slagter
Dioxane test results for Allen Creek raise more questions: MLive Ryan Stanton
Ongoing discharges may be to blame for dioxane in Ann Arbor drinking water: MLive Ryan Stanton
Michigan Department of Environmental Quality (MDEQ)-Gelman Project Site; Washtenaw County CARD Site; Scio Residents for Safe Water (SRSW)
Lots of stores by Ryan Stanton in Ann Arbor News/MLive including this recent article 'EPA holding off on Superfund designation for Gelman dioxane plume'
Lots of details from Barbara Lucus at Dioxane.Org and WEMU News Program GreenRoom
See ACWG site pages EPA Superfund Option Details
Click here to view and/or sign in support of Superfund Designation
Recent Discussions of Development of Polluted DTE Site at Depot St and 841 Broadway St In the FW FP - No Real Cleanup Proposed
DTE Site, Mostly Floodway (City of Ann Arbor GIS Web Site, Click for Larger Image)
At Coal Tar (highly toxic) found at the DTE Site and shown by DEQ at river's edge at the site,
the pollution at the river's edge subsequently cleaned up in recent years (WUOM)
but is still leaching into the river
We are told that the site is leaching some contaminated Groundwater from the site but also has bio walls to prevent leaching. The city should have a high standard for Huron River contamination. Even if there is a barrier it still is leaching into our Huron River. The lack of continuous monitoring for leaching is also unacceptable. This site is the location of the old Huron River bed pre-1900 (see the image in previous ACWG entries). Old river beds are where groundwater generally likes to flow.
Also, my understanding from staff is the developer is using old rain data and inaccurate GIS information for its flood modeling.
The old rain data is no longer used by the city. The new data used by the city is much higher rainfall potential and flood potential than is being used by the developer.
The berm is not accurately delineated as it shows the berm level throughout the area when in fact is drops precipitously to the east to almost nothing at the Amtrak station on Depot St. This will have water spill over the berm from Depot in a major rain event, 100 year 1% chance. or maybe less given the larger rains we are getting with Global Warming. The 1968 flood 100-year rain is more like a 50 or less year rain today I am told by knowledgeable local sources.
The 1968 flood breached all the dams and broke some of them. All the dams needed major work. Argo was very close to being lost due to breaches which were undermining the base of the dam. This DTE site was underwater in the flood.
In a major flood 15' feet of water will careen across this site with potentially little warning. The buildings may be built to handle this but who will warn the hotel guest or condo owners or those doing an AirB&B in the condos?
The dams do not need to be destroyed for major flooding downstream including this site, as was the case for the 1968 flood where Argo was breached but not destroyed.
In a major flood the pollution on site will be swept into our Huron River and into Lake Erie.
Putting residential next to or on top of Coal Tar, as far as 30' down in the soil, would be dangerous. Petoskey had to evacuate condos recently due to vapor intrusion (VI) into condos built on top of a pollution site with volatile organics, what is in Coal Tar. The CARD Group was instrumental in getting MDEQ now EGLE to include VI in its environmental standards recently, which 1,4 Dioxane is now classified. The CARD Group forced MDEQ to evaluate 1,4 Dioxane VI into homes which is a concern with the compound found at and near the surface on the west side of town.
The coal gasification process produces a bi-product called coal tar. Coal tar is a mixture of volatile organic compounds such as benzene, and a class of compounds known as polynuclear aromatic hydrocarbons (PAHs) which include compounds such as naphthalene and benzo(a)pyrene. These compounds are rated as possible and known carcinogens and are very dangerous to humans and other life forms. Some PAHs, Benzene and benzo(a)pyrene are a Group 1 carcinogens.
They are planning a Brownfield partial cleanup with about $25M from taxpayers, and about $12M from the developer. This will be a very marginal cleanup as they say this is all that is required with the very weak MI Part 201 statute.
DTE is a $26B company and should be doing a cleanup of this site as the Responsible Party Legal Owner, not taxpayers. Polluter Pay legislation has been introduced in Lansing this year.*
If done right could be a nice park close to the city center. When it floods hose it off and go back to being a park like many progressive (and non-progressive) cities are doing.
All of the other outcroppings in the Huron River near Ann Arbor and beyond are parks due to the flood hazard associated with them.
Wettest 12 Months in U.S. History—Again; and Wettest January-to-May Period in U.S. History - Floodplain Overlay Zoning Proposal Revisit Needed
NOAA/NCEI (Click for Larger Image)
Weather Underground reports June 6, 2019:
"Propelled by a two-week siege of widespread severe weather and heavy rain in late May, the contiguous U.S. has once again broken its record for the wettest year-long span in data going back to 1895. According to the monthly U.S. climate summary released Thursday from the NOAA National Centers for Environmental Information,..."
"The year to date also ranks as the wettest January-to-May period in U.S. history." (bold by us)
Michigan's climate: Models project 30% increase in rain and snow, plus rising temps.
' "In general, what we're seeing is the Midwest and the Northeast getting more precipitation than in the past, and more of that coming in larger events, particularly in the winter and spring," said Don Wuebbles, professor of atmospheric science at the University of Illinois.
“That's just pure, statistical analysis of the past data. If we look forward, we're expecting that trend to continue.” ' Free Press June 14, 2019 (bold by us)
Time to reconsider the Floodplain Overlay zoning proposal the U of M Ford School graduate students and Ann Arbor City Staff spent 2 years drafting, the ACWG help with and strongly supported, and previous city council declined to adopt in 2017, but commented they would reconsider at a later time. Placing new homes in dangerous locations is not the right thing our city should be involved in with the current state of knowledge on Globel Warming, unless of course you don't believe in Globel Warming and the clearly shown effects on our weather.
CARD, SRSW and ACWG Had a Table at the June 14, 2019 Ann Arbor Green Fair With an Informal Tally of Supporters for EPA Superfund
2019 City of Ann Arbor
The Table displayed a poster which fairgoers could vote for an EPA Superfund effort for the Gelman/Pall/Danaher 1,4-Dioxane contamination.
We had many visitors asking about the Gelman Plume and EPA Superfund Option.
We got lots of questions on the migration of the Plume and risk to drinking water inside and outside the city and, many who stopped by gladly voted.
Support EPA Superfund Status Results were 61-YES, 0-NO as shown below.
Informal Poll at Green Fair 2019 (ACWG)
Thanks to all who helped out and stopped by the booth.
We also had a great turnout at the Earth Day Fair at our booth this spring with lots of questions asked and concerns expressed.
CARD/SRSW and ACWG Booth at the Earth Day Fair, Spring 2019 (ACWG)
312 Glendale Memory Care (MC) Proposal Has Just Recently Started Construction Almost 2 1/2 Years After Approval and Attempted Reconsideration - Council Needs to do a Reconsideration of this Vote Due to Misrepresentations:
Results of residents neighborhood survey of Water Issues; (ACWG)
Site is to left in dark olive tone with Legend, stormwater flow to the right (Click for Larger Image)
Council approved plans for the MC at 312 Glendale on April 3rd 2017 in a 6-3 vote.
A Council member or members need to bring this vote up for reconsideration before Council to fully discuss the issues that were falsely or misleadingly presented to City Council and/or Planning Commission including the Water Resources Commissioner’s Office (WRCO). This may have lead to votes without full knowledge of the issues facing the neighborhood. The WRCO Staff, presenting at the meetings, did mention he was at the last minute standing in for someone in the office.
False or misleading statements by staff that may have helped this to get passed by City Council in a very close vote:
WRCO: The curb will block the huge flows off unmitigated Hillside Terrace (HT) from all major rain events onto this site.
This is not true it will overwhelm the stormwater (SW) system for the MC in a 10 or 20-year event overwhelming the MC SW system causing more flooding downstream. These types of street curb flood conditions in Ann Arbor have been discussed extensively in city meetings repeatedly, that I have attended in the past 20 years.
WRCO: The neighborhood really is not one of the few target neighborhoods for SW mitigation.
This is not true as shown in the $2M “Ann City of Ann Arbor Stormwater Model Calibration and Analysis Project”, June 1, 2015 section ‘C, viii. Glendale/Charlton, page 62’.
In this study they propose detention upstream of Glendale, which clearly could be the orchard.
Greenbelt funds should be used for projects like these, only about 9%, not the promised and voted on 33%, is spent in the city for green space.
WRCO: The orchard has sheet flow and no rainfall runoff infiltration now, this will be mitigated by the development.
This is not true as the orchard, where this proposed building will go, captures much if not all the unmitigated runoff from HT. We have videos and eye witness to attest to this. This will be lost with this development making flood hazard worse for the neighborhood and overwhelm the MC SW system.
WRCO: ‘Vince Caruso did a survey of neighbors’. As a lead in to question its results.
This is not true. I was not involved in the survey, and this seems to be an attempt to ‘tar’ and ‘belittle’ the extensive and important effort. The city took it seriously enough to do 100’s of hours of work in the neighborhood to mitigate the flood hazard since the survey was first presented unblocking 3 sewer lines in the neighborhood.
This new development will improve SW handling we were told. We have been told for over 30 years that new development like this will be the major way we improve SW handling in Ann Arbor.
Not true as this proposal will make it worse causing more flooding downstream into an overtaxed neighborhood.
See previous entries on this site for more details; search site option is at top of these pages.
Proposed Agenda and Updates:
June 20, 2019
Danaher/Pall/Gelman 1,4-Dioxane Plume EPA Superfund Discussions, Local Government Official Have 3 Months to Decide to Ask Governor Whitmer to Ask EPA for Superfund Full Evaluation and Assistance, June 6, 2019.
Joint Session Gelman Superfund Discussion (Ryan Stanton | The Ann Arbor News)
Click photo to view MLive Video
A joint session of the Ann Arbor City Council, Washtenaw County Board of Commissioners, and Scio and Ann Arbor township boards met to discuss EPA Superfund Support. Members of the Coalition for the Remediation of Dioxane (CARD) Group attended the meeting with U.S. Rep. Debbie Dingell, County Health Dept., Michigan Department of Environment, Great Lakes, and Energy (EGLE) (former MDEQ), other elected officials and residents. About 150 people attended according to MLive's Ryan Stanton.
CTN recorded the meeting and posted on their web site.
Ryan Stanton with MLive has a report and video of part of the meeting.
Here is also a video of the June 4th CARD meeting by Roger Rayle on Youtube - https://www.youtube.com/watch?v=IY6IW-ArMf8https://www.youtube.com/watch?v=HWYcdNVt_EU
EPA has indicated they will pull away from the Gelman monitoring unless they get a message from Governer Whitmer that she is willing to let EPA continue to a Full Evaluation and potential Superfund.
The Joint Session of city, county and Scio Twp leaders agreed to try and get some significant motion from Gelman until September 12 this year, the next Joint Meeting. If Gelman is not forthcoming they will likely petition the Governor to ask EPA for a full Superfund Evaluation.
City of Ann Arbor City Council voted to work with Interveners:
RESOLVED, That the City Council directs the City Administrator, by July 1, 2019, to take all reasonable steps to convene a meeting with the other State-Lawsuit interveners to explore requesting EPA’s active involvement with the Gelman site and its listing as a “Superfund” site under CERCLA by, among other things, soliciting a concurrence letter from the Governor;
The Ann Arbor Township, Scio Township, Washtenaw County Board of Commissions, Sierra Club Huron Valley Group (SCHGV), the Coalition for the Remediation of Dioxane (CARD) and Allen’s Creek Watershed Group (ACWG) all voted in support of a petition to the US EPA for Full Preliminary Assessment of the Gelman 1,4-Dioxane groundwater contamination.
Governor Whitmer would be much more approachable than our previous Republican Governor.
Still no comment on a real plan of action on the NSG exposure potential and permanent well monitoring, not simply more minimal tests. Dan Bicknell's GEA Comments on the DEQ Shallow Groundwater Work Plan and his proposed plan is posted in the November 2016 Agenda. Dan had a very well and logical plan laid out for dealing with the initial investigation of the NSG issue which seems to be clearly a problem that needs addressing.
The ACWG and CARD Groups has asked for permanent monitoring of NSG wells on the near west side of the city with no indication of action on this.
Links:
Ann Arbor is at a pivotal point with Gelman dioxane plume MLive Ryan Stanton
Dioxane detected in Ann Arbor drinking water from Barton Pond for first time: Mlive Martin Slagter
Dioxane test results for Allen Creek raise more questions: MLive Ryan Stanton
Ongoing discharges may be to blame for dioxane in Ann Arbor drinking water: MLive Ryan Stanton
Michigan Department of Environmental Quality (MDEQ)-Gelman Project Site; Washtenaw County CARD Site; Scio Residents for Safe Water (SRSW)
Lots of stores by Ryan Stanton in Ann Arbor News/MLive including this recent article 'EPA holding off on Superfund designation for Gelman dioxane plume'
Lots of details from Barbara Lucus at Dioxane.Org and WEMU News Program GreenRoom
See ACWG site pages EPA Superfund Option Details
Click here to view and/or sign in support of Superfund Designation
Recent Discussions of Development of Polluted DTE Site at Depot St and 841 Broadway St In the FW FP - No Real Cleanup Proposed
DTE Site, Mostly Floodway (City of Ann Arbor GIS Web Site, Click for Larger Image)
At Coal Tar (highly toxic) found at the DTE Site and shown by DEQ at river's edge at the site,
the pollution at the river's edge subsequently cleaned up in recent years (WUOM)
but is still leaching into the river
We are told that the site is leaching some contaminated Groundwater from the site but also has bio walls to prevent leaching. The city should have a high standard for Huron River contamination. Even if there is a barrier it still is leaching into our Huron River. The lack of continuous monitoring for leaching is also unacceptable. This site is the location of the old Huron River bed pre-1900 (see the image in previous ACWG entries). Old river beds are where groundwater generally likes to flow.
Also, my understanding from staff is the developer is using old rain data and inaccurate GIS information for its flood modeling.
The old rain data is no longer used by the city. The new data used by the city is much higher rainfall potential and flood potential than is being used by the developer.
The berm is not accurately delineated as it shows the berm level throughout the area when in fact is drops precipitously to the east to almost nothing at the Amtrak station on Depot St. This will have water spill over the berm from Depot in a major rain event, 100 year 1% chance. or maybe less given the larger rains we are getting with Global Warming. The 1968 flood 100-year rain is more like a 50 or less year rain today I am told by knowledgeable local sources.
The 1968 flood breached all the dams and broke some of them. All the dams needed major work. Argo was very close to being lost due to breaches which were undermining the base of the dam. This DTE site was underwater in the flood.
In a major flood 15' feet of water will careen across this site with potentially little warning. The buildings may be built to handle this but who will warn the hotel guest or condo owners or those doing an AirB&B in the condos?
The dams do not need to be destroyed for major flooding downstream including this site, as was the case for the 1968 flood where Argo was breached but not destroyed.
In a major flood the pollution on site will be swept into our Huron River and into Lake Erie.
Putting residential next to or on top of Coal Tar, as far as 30' down in the soil, would be dangerous. Petoskey had to evacuate condos recently due to vapor intrusion (VI) into condos built on top of a pollution site with volatile organics, what is in Coal Tar. The CARD Group was instrumental in getting MDEQ now EGLE to include VI in its environmental standards recently, which 1,4 Dioxane is now classified. The CARD Group forced MDEQ to evaluate 1,4 Dioxane VI into homes which is a concern with the compound found at and near the surface on the west side of town.
The coal gasification process produces a bi-product called coal tar. Coal tar is a mixture of volatile organic compounds such as benzene, and a class of compounds known as polynuclear aromatic hydrocarbons (PAHs) which include compounds such as naphthalene and benzo(a)pyrene. These compounds are rated as possible and known carcinogens and are very dangerous to humans and other life forms. Some PAHs, Benzene and benzo(a)pyrene are a Group 1 carcinogens.
They are planning a Brownfield partial cleanup with about $25M from taxpayers, and about $12M from the developer. This will be a very marginal cleanup as they say this is all that is required with the very weak MI Part 201 statute.
DTE is a $26B company and should be doing a cleanup of this site as the Responsible Party Legal Owner, not taxpayers. Polluter Pay legislation has been introduced in Lansing this year.*
If done right could be a nice park close to the city center. When it floods hose it off and go back to being a park like many progressive (and non-progressive) cities are doing.
All of the other outcroppings in the Huron River near Ann Arbor and beyond are parks due to the flood hazard associated with them.
Wettest 12 Months in U.S. History—Again; and Wettest January-to-May Period in U.S. History - Floodplain Overlay Zoning Proposal Revisit Needed
NOAA/NCEI (Click for Larger Image)
Weather Underground reports June 6, 2019:
"Propelled by a two-week siege of widespread severe weather and heavy rain in late May, the contiguous U.S. has once again broken its record for the wettest year-long span in data going back to 1895. According to the monthly U.S. climate summary released Thursday from the NOAA National Centers for Environmental Information,..."
"The year to date also ranks as the wettest January-to-May period in U.S. history." (bold by us)
Michigan's climate: Models project 30% increase in rain and snow, plus rising temps.
' "In general, what we're seeing is the Midwest and the Northeast getting more precipitation than in the past, and more of that coming in larger events, particularly in the winter and spring," said Don Wuebbles, professor of atmospheric science at the University of Illinois.
“That's just pure, statistical analysis of the past data. If we look forward, we're expecting that trend to continue.” ' Free Press June 14, 2019 (bold by us)
Time to reconsider the Floodplain Overlay zoning proposal the U of M Ford School graduate students and Ann Arbor City Staff spent 2 years drafting, the ACWG help with and strongly supported, and previous city council declined to adopt in 2017, but commented they would reconsider at a later time. Placing new homes in dangerous locations is not the right thing our city should be involved in with the current state of knowledge on Globel Warming, unless of course you don't believe in Globel Warming and the clearly shown effects on our weather.
CARD, SRSW and ACWG Had a Table at the June 14, 2019 Ann Arbor Green Fair With an Informal Tally of Supporters for EPA Superfund
2019 City of Ann Arbor
The Table displayed a poster which fairgoers could vote for an EPA Superfund effort for the Gelman/Pall/Danaher 1,4-Dioxane contamination.
We had many visitors asking about the Gelman Plume and EPA Superfund Option.
We got lots of questions on the migration of the Plume and risk to drinking water inside and outside the city and, many who stopped by gladly voted.
Support EPA Superfund Status Results were 61-YES, 0-NO as shown below.
Informal Poll at Green Fair 2019 (ACWG)
Thanks to all who helped out and stopped by the booth.
We also had a great turnout at the Earth Day Fair at our booth this spring with lots of questions asked and concerns expressed.
CARD/SRSW and ACWG Booth at the Earth Day Fair, Spring 2019 (ACWG)
312 Glendale Memory Care (MC) Proposal Has Just Recently Started Construction Almost 2 1/2 Years After Approval and Attempted Reconsideration - Council Needs to do a Reconsideration of this Vote Due to Misrepresentations:
Results of residents neighborhood survey of Water Issues; (ACWG)
Site is to left in dark olive tone with Legend, stormwater flow to the right (Click for Larger Image)
Council approved plans for the MC at 312 Glendale on April 3rd 2017 in a 6-3 vote.
A Council member or members need to bring this vote up for reconsideration before Council to fully discuss the issues that were falsely or misleadingly presented to City Council and/or Planning Commission including the Water Resources Commissioner’s Office (WRCO). This may have lead to votes without full knowledge of the issues facing the neighborhood. The WRCO Staff, presenting at the meetings, did mention he was at the last minute standing in for someone in the office.
False or misleading statements by staff that may have helped this to get passed by City Council in a very close vote:
WRCO: The curb will block the huge flows off unmitigated Hillside Terrace (HT) from all major rain events onto this site.
This is not true it will overwhelm the stormwater (SW) system for the MC in a 10 or 20-year event overwhelming the MC SW system causing more flooding downstream. These types of street curb flood conditions in Ann Arbor have been discussed extensively in city meetings repeatedly, that I have attended in the past 20 years.
WRCO: The neighborhood really is not one of the few target neighborhoods for SW mitigation.
This is not true as shown in the $2M “Ann City of Ann Arbor Stormwater Model Calibration and Analysis Project”, June 1, 2015 section ‘C, viii. Glendale/Charlton, page 62’.
In this study they propose detention upstream of Glendale, which clearly could be the orchard.
Greenbelt funds should be used for projects like these, only about 9%, not the promised and voted on 33%, is spent in the city for green space.
WRCO: The orchard has sheet flow and no rainfall runoff infiltration now, this will be mitigated by the development.
This is not true as the orchard, where this proposed building will go, captures much if not all the unmitigated runoff from HT. We have videos and eye witness to attest to this. This will be lost with this development making flood hazard worse for the neighborhood and overwhelm the MC SW system.
WRCO: ‘Vince Caruso did a survey of neighbors’. As a lead in to question its results.
This is not true. I was not involved in the survey, and this seems to be an attempt to ‘tar’ and ‘belittle’ the extensive and important effort. The city took it seriously enough to do 100’s of hours of work in the neighborhood to mitigate the flood hazard since the survey was first presented unblocking 3 sewer lines in the neighborhood.
This new development will improve SW handling we were told. We have been told for over 30 years that new development like this will be the major way we improve SW handling in Ann Arbor.
Not true as this proposal will make it worse causing more flooding downstream into an overtaxed neighborhood.
See previous entries on this site for more details; search site option is at top of these pages.
Proposed Agenda and Updates:
May 16, 2019
Danaher/Pall/Gelman 1,4-Dioxane Plume EPA Superfund Discussions, EPA to Pull Away Unless Whitmer Asks for Superfund Full Evaluation and Assistance
Wide Angle Shot of Meeting (ACWG, click for larger image)
At a meeting to discuss EPA Superfund Status members of the Coalition for the Remediation of Dioxane (CARD) Group attended a meeting with U.S. Rep. Debbie Dingell, City Council, Ann Arbor, Scio Townships, County Board, County Health Dept., EGLE (former MDEQ) and residents.
Roger Rayle recorded the meeting and posted on Youtube - https://www.youtube.com/watch?v=0W_nz3VVZrQ
Ryan Stanton with MLive has a report and video of part of the meeting.
Here is also a video of the May 7th CARD meeting by Roger Rayle on Youtube - https://www.youtube.com/watch?v=IY6IW-ArMf8
EPA has indicated they will pull away from the Gelman monitoring unless they get a message from Governer Whitmer that she is willing to let EPA continue to a Full Evaluation and potential Superfund.
City of Ann Arbor City Council voted to work with Interveners:
RESOLVED, That the City Council directs the City Administrator, by July 1, 2019, to take all reasonable steps to convene a meeting with the other State-Lawsuit interveners to explore requesting EPA’s active involvement with the Gelman site and its listing as a “Superfund” site under CERCLA by, among other things, soliciting a concurrence letter from the Governor; and,
The Ann Arbor Township, Scio Township, Washtenaw County Board of Commissions, Sierra Club Huron Valley Group (SCHGV), the Coalition for the Remediation of Dioxane (CARD) and Allen’s Creek Watershed Group (ACWG) all voted in supported a petition to the US EPA for Full Preliminary Assessment of the Gelman 1,4-Dioxane groundwater contamination.
Governor Whitmer would be much more approachable than our previous Republican Governor.
Still no comment on a real plan of action on the NSG exposure potential, not simply more minimal tests. Dan Bicknell's GEA Comments on the DEQ Shallow Groundwater Work Plan and his proposed plan is posted in the November 2016 Agenda. Dan had a very well and logical plan laid out for dealing with the initial investigation of the NSG issue which seems to be clearly a problem that needs addressing.
The ACWG and CARD Groups has asked for permanent monitoring of NSG wells on the near west side of the city with no indication of action on this.
Links:
Ann Arbor at pivotal point with Gelman dioxane plume MLive Ryan Stanton
Dioxane detected in Ann Arbor drinking water from Barton Pond for first time: Mlive Martin Slagter
Dioxane test results for Allen Creek raise more questions: MLive Ryan Stanton
Ongoing discharges may be to blame for dioxane in Ann Arbor drinking water: MLive Ryan Stanton
Michigan Department of Environmental Quality (MDEQ)-Gelman Project Site; Washtenaw County CARD Site; Scio Residents for Safe Water (SRSW)
YouTube of CARD/DEQ Regular Meeting 5-7-19, by Roger Rayle Chair of CARD (https://www.youtube.com/watch?v=AInaA9T7H3g) Other videos are under CARD WC in Youtube.
Lots of stores by Ryan Stanton in Ann Arbor News/MLive including this recent article 'EPA holding off on Superfund designation for Gelman dioxane plume'
Lots of details from Barbara Lucus at Dioxane.Org and WEMU News Program GreenRoom
See ACWG site pages EPA Superfund Option Details
Click here to view and/or sign in support of Superfund Designation
City Staff Working on Stormwater Unapproved Pipes and Flows Were Added to Two Public Wooded Natural Areas With City Notification, One Woodland is Owned by AAPS, Flood Threat to Neighborhood
First Martin newly installed Illegal 10" SW Pipe flowing into the Neighborhood FairGlen Woodland Commons (ACWG; Click for larger image)
Illegal SW Pipe flowing into Eberwhite Woods, Eberwhite School, Eberwhite Woods Committee, AAPS (Circled in Red) (ACWG; Click for larger image)
The pipe into the FairGlen wooded Commons is a threat to the Gabions, just below the illegal 10" pipe outlet, that was placed when the 5x8' pipe was installed. It is likely to undermine the Gabions causing very large blockages in stormwater flows in a major rain event causing massive flooding in the neighborhood. Gabions were installed to armor against heavy flows through the Commons in this open section of Allen's Creek and could be compromised in a major flow through the commons.
The city installed Gabions protecting the stream bank are just beyond the outlet of this pipe in the upper photo.*
This needs to be addressed before a major rain event hits the community.
The effect of this Illegal Stormwater pipe on this open section of the Allen's Creek is a clear and present danger to the community.*
We have had two cases now where illegal (as determined by city staff in both email and phone calls) stormwater pipes and stormwater flows added to natural areas on the west side recently.
Link: AAPS
Treeline Community Presentation and Update
The Treeline Conservancy (Click for link)
There was a Treeline meeting on Tuesday that the Treeline Board discusses Updates and premiered a video of the plans for the Treeline. See link to view video and web site; https://treelinea2.org/.
The ACWG supports this effort and commented that for the early effort for a Greenway in the late 1990s flood hazard mitigation was a major goal of the Greenway. I made this point again last night. Comment from a Board Member was they are working to include this in the plans.
Currently, the Treeline is focused on the N Main portion as a starting point hoping to build on its successful completion.
When I ask it seems to them that there is no change on the U of M position on the Greenway along the tracks near campus. U of M at the Greenway Master Planning meetings originally suggested support than pulled back support without serious reasons being presented. U of M has a lot to gain with many fans walking illegally down the tracks to sporting events. The Treeline would be logically along this route and have thousands of users from the day it is open. Large numbers of users like this would help grant funding tremendously.
We support the creation of a Greenway that will create a buffer area for flooding, sparing potentially thousands of home from catastrophic flooding
The Allen's Creek Watershed is particularly at risk with very steep slopes, very flashy runoff, overbuilt environment
We have 100's if not 1,000's of homes and businesses at risk of flooding
The ACWG has worked with the city to do some important improvements but more is needed, and a Greenway would provide much-needed flood hazard reductions on the West Side. In years past discussions with the Drain Office the ACWG was told the Greenway if done correctly should reduce flood hazard in the Allen's Creek Valley.
The city should consider a Citizens Taskforce to assist the Conservancy in the planning of the Treeline, something to be discussed with council members. A group of knowledgeable and interested citizens would ensure the effort stays on track to be as effective use of funds and meaningful set of goals as is reasonable.
CARD, SRSW and ACWG Will Have a Table at the June 14, 2019 Ann Arbor Green Fair
City of Ann Arbor
Green Fair on Main Street
Friday, June 14, 2019 from 6–9 p.m.
"Ann Arbor's downtown Main Street will be closed to through traffic between Huron and William streets, remaining open for pedestrians, Green Fair guests, displays of sustainability information, "green" products, live music and general enjoyment of the urban outdoor environment. Information, entertainment, and hands-on activities for all ages will be provided."
Proposed Agenda and Updates:
April 18, 2019
Danaher/Pall/Gelman 1,4-Dioxane Plume - CARD Presentation at City Council Work Session
Vince Caruso presenting at City Council Work Session on Gelman (City of Ann Arbor)
Member of the Coalition for the Remediation of Dioxane (CARD) Group were asked to present before a Working Session of the City Council on latest issues facing the Gelman 1,4 Dioxane Ground (and Surface) Water contamination.
Roger Rayle (Chair CARD and SRSW), Dan Bicknell (GEA, CARD Member) and Vince Caruso (Board Member CARD, CM ACWG) presented.
City of Ann Arbor Video Page of the Work Session. Link: https://a2ctn.viebit.com/player.php?hash=g5ttQRaI8cq3
The presentation and discussion start at 00:58:47 on the video and runs about 25 minutes.
Here is a link to the slides of the presentation on the city web site. (http://a2gov.legistar.com/View.ashx?M=F&ID=7148735&GUID=4635F628-0CC5-407C-BBF6-C3141A5F8A1D)
Presentation and discussions centered on Superfund option, Near-Surface Groundwater (NSG) issues and DEQ history with this every expanding plume over the years. Dan does a great job presenting the Superfund Option in detail and its clear benefits.
With new leadership in Ann Arbor and in Lansing and with help from the state NGO's we need to petition the new Governor to have EPA proceed with Superfund evaluation and potential Superfund Designation with a Responsible Party in the owner Danaher.
State legislators Yosif Rabie and Jeff Irwan have introduced legislation to have Michigan Polluters pay for the cleanup of their contamination. It requires that the polluter clean up the pollutant as much as technically possible.
The Ann Arbor Township, Scio Township, Washtenaw County Board of Commissions, Sierra Club Huron Valley Group (SCHGV), the Coalition for the Remediation of Dioxane (CARD) and Allen’s Creek Watershed Group (ACWG) all voted in supported a petition to the US EPA for Full Preliminary Assessment of the Gelman 1,4-Dioxane groundwater contamination.
Governor Whitmer would be much more approachable than our previous Republican Governor.
Still no comment on a real plan of action on the NSG exposure potential, not simply more minimal tests. Dan Bicknell's GEA Comments on the DEQ Shallow Groundwater Work Plan and his proposed plan is posted in the November 2016 Agenda. Dan had a very well and logical plan laid out for dealing with the initial investigation of the NSG issue which seems to be clearly a problem that needs addressing.
The ACWG and CARD Groups has asked for permanent monitoring of NSG wells on the near west side of the city with no indication of action on this.
Links:
Dioxane detected in Ann Arbor drinking water from Barton Pond for first time: Mlive Martin Slagter
Dioxane test results for Allen Creek raise more questions: MLive Ryan Stanton
Ongoing discharges may be to blame for dioxane in Ann Arbor drinking water: MLive Ryan Stanton
Michigan Department of Environmental Quality (MDEQ)-Gelman Project Site; Washtenaw County CARD Site; Scio Residents for Safe Water (SRSW)
YouTube of CARD/DEQ Regular Meeting 4-2-19, by Roger Rayle Chair of CARD (https://www.youtube.com/watch?v=AInaA9T7H3g) Other videos are under CARD WC in Youtube.
Lots of stores by Ryan Stanton in Ann Arbor News/MLive including this recent article 'EPA holding off on Superfund designation for Gelman dioxane plume'
Lots of details from Barbara Lucus at Dioxane.Org and WEMU News Program GreenRoom
See ACWG site pages EPA Superfund Option Details
Click here to view and/or sign in support of Superfund Designation
Attorney General Dana Nessel Rules Gelman (Pall/Danaher) Do Not Need To Follow Past Regulations on the Gelman Plume While in Confidential Negotiations with Plaintiffs on the Consent Judgement
Michigan AG Dana Nessel (Dana Nessel)
At the March CARD Meeting the DEQ presented a letter written on March 1, '19 where Dana Nessel wrote to Gelman (copy available) indicating that while there are Confidential Negotiations with plaintiffs on the Consent Judgment on the Gelman Plume management the recent two 85 ppb readings at Monitoring Well 103s at Glendale and Abbott do not trigger the past agreement that an MDEQ/Gelman Action Plan should be undertaken to deal with the possibility that outside the Prohibition Zone 85 ppb may occur in a short time which was prohibited. Well 103 is near the edge of the PZ.
The question CARD is asking is - are all the regulations on this Plume in limbo now. If this Action Plan is not required then other rules may also be set aside.
We have not gotten an answer on this to date.
Confidential Negotiations with Plaintiffs in the Consent Judgement have now gone on for over two years, some months or many months without meetings, and no word on any progress.
Gelman has delayed and misrepresented its position on this plume over the years when it said 65,000 pounds of 1,4 Dioxane were used at the site when over that amount has already been removed. DEQ feels 850,000 pounds were used at the site and may be contaminating the aquifer.
Gelman should be held to the old rules in the Plume management and we need to move to have EPA Superfund management that will work to clean up the aquifer not allow it to migrate through the city contaminating homes and businesses and potentially the Huron River at Barton Pond.
Gelman, the polluter, should not be allowed to dictate how this contamination is cleaned up. This is our aquifer and is protected by the State's Public Trust Doctrine.
New Tunnel for Storm Water and Bike/Ped Access to B2B Trail Under RR Tracks at Depot St. to be Started this Summer, Pollution Issues Under Site Need Addressing
Tunnel for SW and Bike/Ped Access to B2B Trail Under RR Tracks at Depot St.
City of Ann Arbor, Click for larger image)
Coal Tar found at the DTE Site and shown by DEQ at river's edge at the site,
the pollution at the river's edge subsequently cleaned up in recent years (WUOM)
I spoke at public comment at the CC Work Session listed above (near the end of the recording) regarding the existing and recognized pollution under this project at the DTE site at Depot St.
I attend all the meetings related to this Tunnel project and strongly commented that this is a very valuable project and needed to include bike and pedestrian access as well as the much-needed flood hazard reducing SW opening to the river. Flood hazard will be greatly reduced with the outlet to the river in big storm events. Bike and pedestrian access will be a great addition to the B2B AA trail.
Recently city staff presented this proposal's proposed start but have not indicated a cleanup program for the site. The DTE site is very heavily polluted with coal tar and other contaminants which have polluted the groundwater below the site, likely the Huron River below the site, and pollutes this proposed site for improvement. DTE has said the groundwater below the site is polluted, according to public comments by the developer for DTE, but not indicated they have tested if the pollution is leaving the site.
Still, No Action After Over a Year - Stormwater Pipes and Unapproved Flows Were Added to Two Public Wooded Natural Areas With City Notification But Without City Action, One Woodland is Owned by AAPS
First Martin Illegal 10" SW Pipe flowing into the
Neighbohood FairGlen Woodland Commons (ACWG; Click for larger image)
Illegal SW Pipe flowing into Eberwhite Woods, Eberwhite School,
Eberwhite Woods Committee, AAPS (Circled in Red) (ACWG; Click for larger image)
We have had two cases now where illegal (as determined by city staff in both email and phone calls) stormwater pipes and stormwater flows added to natural areas on the west side recently, without action by the city to have them removed.
This sets a very bad precedent for Ann Arbor.
Link: AAPS
The CARD and ACWG Will be Hosting a Table at the Earth Day Event at Lesley Science Center & Nature Center April 28th, Starting at 12 pm
City of Ann Arbor
The Earth Day Festival is at Lesley Science Center & Nature Center
April 28
From 12 pm to 4 pm
1831 Traver Road Ann Arbor
Proposed Agenda and Updates:
March 21, 2019
Danaher/Pall/Gelman 1,4-Dioxane Plume - 1,4 Dioxane in Finished Water, More Found in NSG
PLS, Annotated by Dan Bicknell of GEA and CARD (Click for larger view)
Recent tests of the city finished drinking water showed 0.030 ppb 1,4 Dioxane. State standard is 7.2 ppb currently, US EPA has no standard currently, but US EPA dioxane drinking water criterion is 0.35 ppb. No definitive word on the reason for this new finding but it would seem Gelman's not full treatment of the contaminated groundwater emptied into Honey Creek which flows into Barton Pond may be the source of this low reading. The DEQ allowed Gelman to change from a treatment system that cleaned to about 0 ppb to a different method which only cleans to about 7 ppb to save money.
New Near-Surface Groundwater (NSG) tests made by the MDEQ in Allen('s) Creek on the west side in about 8 locations upstream of West Park showed about 15 ppb in the West Park area.
Pall's (bought Gelman) own geo maps from 2006 show the potential for groundwater coming out at West Park. The stormwater pipes there pick up groundwater as designed to stop the seeps from undermining the homes and roadways nearby. The Allen('s) Creek is a very steep watershed and as it falls away to the river it is like a slanted cut into a layer cake, exposing layers of the glacial till that is Ann Arbor. Some of the exposed layers have high groundwater flows in them that come out of the hillsides as seeps seen all over the west side even before it gets as low as West Park. The new action level for Near-Surface Groundwater should not be the 1,900 ppb MDEQ set, but at least as low as 280 ppb the new standard of groundwater flowing into surface water standard, if not lower. May need to be 100 ppb action level to protect from vapor intrusion basement exposures.
With 1,000 ppb at Vet's Park in recent years, it may not be long before it is at 100 or 280 ppb at West Park. With all the wet basements (lots of wet basements) on the west side, it is not prudent to allow this to migrate into them unabated.
Past recent tests of NSG at West Park showed 19 ppb, 400% increase from 8 months prior. The NSG tests were not in the MDEQ plans till the ACWG and CARD Groups insisted on tests be made.
With new leadership in Ann Arbor and in Lansing and with help from the state NGO's we need to petition the new Governor to have EPA proceed with Superfund evaluation and potential Superfund Designation with a Responsible Party in the owner Danaher.
State legislators Yosif Rabie and Jeff Irwan have introduced legislation to have Michigan Polluters pay for the cleanup of their contamination. It requires that the polluter clean up the pollutant as much as technically possible.
Knowledgeable sources have indicated that $50M and in 10 years we could potentially clean up the plume and save Barton Pond, many private wells and homes from contamination.
Back in 1990 I am told from a reliable source that (also on record) Gelman representatives indicated to county, city and MDEQ at a public meeting, that she attended, that the Plume is headed north down Wagner Rd. and will hit Barton Pond in about 17 years. It has not hit Barton yet but it has moved north causing a movement of the Prohibition Zone North about 1 year after Judge Shelton established it and affect many residential wells to the North.
The Ann Arbor Township, Scio Township, Washtenaw County Board of Commissions, Sierra Club Huron Valley Group (SCHGV), the Coalition for the Remediation of Dioxane (CARD) and Allen’s Creek Watershed Group (ACWG) all supported a petition to the US EPA for Full Preliminary Assessment of the Gelman 1,4-Dioxane groundwater contamination.
It was disclosed that the Superfund Designation for the Gelman site would have proceed for next step in the evaluation if the governor had not stopped it according to EPA Superfund manager Michael Berkoff. The site met the standard for next step in evaluation without doing most of the obvious evaluation which would have put it even higher standing.
We have new State and city leadership after the November election. We need to move to pressure them to support a continued Superfund Designation.
Governor Whitmer would be much more approachable than our previous Republican Governor.
280 ppb is the limit for contaminated flows into surface waters yet 1,900 ppb allowed in homes basements. No comment on plans to deal with this threat to homes and businesses in its path. Just 11 blocks upstream we have had readings of close to 1,000 ppb at Vet's Park area.
If homeowners have over 250 ppb in their basements and have a sump pump discharging it they will not be in violation of State Law currently which limits it to below 251 ppb as a special case, may not be true for businesses*. The VI issue in basements is still real and may be much lower than currently set. Initially it was 29 ppb then changed to 1,900 ppb and may need to be closer to 100 ppb.*
Still no comment on a real plan of action on the NSG exposure potential, not simply more minimal tests. Dan Bicknell's GEA Comments on the DEQ Shallow Groundwater Work Plan and his proposed plan is posted in the November 2016 Agenda. Dan had a very well and logical plan laid out for dealing with the initial investigation of the NSG issue which seems to be clearly a problem that needs addressing.
The ACWG and CARD Groups has asked for permanent monitoring of NSG wells on the near west side of the city with no indication of action on this.
Links:
Dioxane detected in Ann Arbor drinking water from Barton Pond for first time: Mlive Martin Slagter
Dioxane test results for Allen Creek raise more questions: MLive Ryan Stanton
Ongoing discharges may be to blame for dioxane in Ann Arbor drinking water: MLive Ryan Stanton
Michigan Department of Environmental Quality (MDEQ)-Gelman Project Site; Washtenaw County CARD Site; Scio Residents for Safe Water (SRSW)
YouTube of CARD/DEQ Regular Meeting 3-5-19 , by Roger Rayle Chair of CARD (https://www.youtube.com/watch?v=1BSSRTCTH9I) Other videos are under CARD WC in Youtube.
Lots of stores by Ryan Stanton in Ann Arbor News/MLive including this recent article 'EPA holding off on Superfund designation for Gelman dioxane plume'
Lots of details from Barbara Lucus at Dioxane.Org and WEMU News Program GreenRoom
See ACWG site pages EPA Superfund Option Details
Click here to view and/or sign in support of Superfund Designation
City to Consider Development for City-Owned Land at 721 N Main, Mainly Floodplain and Floodway, Affordable Housing Suggested
Map of 721 N. Main Area from City Website in March 2019 (City of AA; ACWG; Click for larger view)
The 721 N Main site is largely floodway and floodplain, see current city map above. We hope the city does not propose to put affordable housing in and near these sites. Maybe the far North section outside the floodplain up the hill would be safe but most of the rest of the site is in real danger of flooding.
The floodway and floodplain are very flat areas with little leeway between flood and no flood scenarios. The northern site is on top of a steep slope as noted in the 2' contours on the map.
Blocking flows with buildings or buildings on stilts with parking below will be dangerous and cause greater flooding upstream in areas not normally at risk of flooding.
City staff has clearly stated in public discussions during a tour of this site, during the City lead North Main Tour, the floodplain map is not very well calibrated. With climate change heaver rain events it will only get less reliable.
Ann Arbor has a long and sorted history of putting disadvantaged in harm's way. This needs to end. The homeless shelter almost was built in the floodway until the ACWG and other residents stopped the city, county and state from building an illegal un-inhabitable shelter in the floodway, illegal. The illegal scraped plans in the floodway cost us taxpayers to waste $1M. And this was not the only recent error with low-cost housing in the floodway the city was involved in that was scrapped due to poor planning. There's the Avalon Housing across the street on Main St. that was also scrapped not too long ago due to floodway and floodplain issues.
This flood-prone area should be park space and greenway space with that it will do much more for the economy and environment than shabby flood-prone affordable housing will ever do. Will also reduce flood hazard in this portion of the city.
Some of our city leaders ‘go on’ about climate change yet encourage nonprofit and for-profits to build in and around very dangerous flood-prone locations. Not good planning or protective planning.
Link to Mlive Article:
3 new affordable housing proposals coming to Ann Arbor city council: 3-12-19 Mlive
https://expo.mlive.com/expo/news/g66l-2019/03/e15376b23f5380/3-new-affordable-housing-proposals-coming-to-ann-arbor-city-council.html#vf-9204400018404
March 2019 Midwest 'Bomb Cyclone' Causes Major Flooding to Occur in Midwest with Colorado Having a Record Low Barometric Reading, Hurricane Force Winds
Cat 6 WU (Click for larger view)
In the Midwest it was reported by the National Weather Service: “In some locations it’s the worst flooding on record on many of these river gauges.” Then "the National Weather Service in Omaha reported Friday that it had to evacuate its offices because of rising waters."
19 locations in the Midwest have set new flood crest records, said weather.com meteorologist Jon Erdman. Overall, more than 300 river gauges were in flood stage in the central United States, the National Weather Service reported. USAToday.Com 3-15-19
Global Warming is causing record dangerous weather including flooding and wind storms. The effects require a "Business as Usual" approach to community planning be dramatically modified to reduce the risk to life, health and property.
Update: Article and Video of Clean Water Town Hall On March 7, 2019
WideAngle image of Clean Water Town Hall, Overflow Crowd (ACWG, Click for Larger)
Organized by Rep. Donna Lasinski at Scio Township Hall
Roger Rayle (SRSW.ORG and CARD) video taped, the meeting, posted on YouTube and and wrote the description below.
Link: https://www.youtube.com/watch?v=rVKHVqzEL74
MLive Article Ryan Stanton: PFAS, dioxane top concerns at clean water forum in Scio Township
https://www.mlive.com/news/ann-arbor/2019/03/pfas-dioxane-top-concerns-at-clean-water-forum-in-scio-township.html
ACWG attended and did make comment at the meeting.
Clean Water Town Hall
Organized by Michigan State House rep Rep. Donna Lasinski, 52nd District
From PFAS to Dioxane, we have seen no shortage of threats to our drinking water in Washtenaw County and around the state. Rep. Donna Lasinski and a panel of local experts discuss water quality issues and policy solutions, and answer questions about how we can protect drinking water across the Great Lakes State.
Panelists:
Dan Brown, Huron River Watershed Council;
Kristen Schweighoefer, Washtenaw County Health Department;
Gerald Tiernan, MDEQ Remediation & Redevelopment Division;
Lisa Fischer, MDHHS Toxicologist
Proposed Agenda and Updates:
February 21, 2019
Danaher/Pall/Gelman 1,4-Dioxane Plume - EPA Superfund Meeting Oct 30th, Previous Governor Stopped Superfund Designation Full Evaluation; 19 ppb Now at West Park; City of Ann Arbor Needs to Petition EPA and Request the Governor Also Do So
WideAngle low-resolution image of EPA Superfund manager Michael Berkoff, Congresswoman Debbie Dingell, MDEQ
and other Stakeholders meeting 10-29-18 (ACWG, right click for larger view )
The Coalition for Action on Remediation of Dioxane (CARD) members attended the EPA and Congress Women Debbie Dingell meeting on Monday, Oct. 29th to discuss progress/or lack thereof on the Gelman Plume.
Link to the great video of this meeting courtesy of Roger Rayle.
With new leadership in Ann Arbor and in Lansing and with help from the state NGO's we need to petition the new Governor to have EPA proceed with Superfund evaluation and potential Superfund Designation with a Responsible Party in the owner Danaher.
State legislators Yousef Rabhi and Jeff Irwin have introduced legislation to have Michigan Polluters pay for cleanup of their contamination. It requires that the polluter clean up the pollutant as much as technically possible.
Knowledgeable sources have indicated that $50M and in 10 years we could potentially clean up the plume and save Barton Pond, many private wells and homes from contamination.
Back in 1990 I am told from a reliable source that (also on record) Gelman representatives indicated to county, city and MDEQ at a public meeting, that she attended, that the Plume is headed north down Wagner Rd. and will hit Barton Pond in about 17 years. It has not hit Barton yet but it has moved north causing a movement of the Prohibition Zone North about 1 year after Judge Shelton established it and affect many residential wells to the North.
New data on Near-Surface Groundwater (NSG) tests at West Park showed 19 ppb, 400% increase from 8 months prior. The NSG tests were not in the EGLE (MDEQ) plans till the ACWG anhttps://sites.google.com/site/allenscreekwatershedgroup/home/benefits-of-porous-pavements-acwgd CARD Groups insisted on tests be made.
New tests are being made in Allen('s) Creek on the west side in about 8 locations upstream of West Park.
280 ppb is the limit for contaminated flows into surface waters yet 1,900 ppb allowed in homes basements. No comment on plans to deal with this threat to homes and businesses in its path. Just 11 blocks upstream we have had readings of close to 1,000 ppb at Vet's Park area.
If homeowners have over 250 ppb in their basements and have a sump pump discharging it they will be in not be in violation of State Law which limits it to below 251 ppb for homeowners. What is a homeowner or business to do about this pollution? No comment from our state, county or city leaders when asked at this meeting.
It was disclosed that the Superfund Designation for the Gelman site would have proceeded for next step in the evaluation if the governor had not stopped it according to EPA Superfund manager Michael Berkoff. The site met the standard for next step in evaluation without doing most of the obvious evaluation which would have put it even higher standing.
We have new State and city leadership after the November election. We need to move to pressure them to support a continued Superfund Designation.
Governor Whitmer would be more approachable than our previous Republican Governor.
Still no comment on a real plan of action on the NSG exposure potential, not simply more minimal tests. Dan Bicknell's GEA Comments on the DEQ Shallow Groundwater Work Plan and his proposed plan is posted in the November 2016 Agenda. Dan had a very well and logical plan laid out for dealing with the initial investigation of the NSG issue which seems to be clearly a problem that needs addressing.
The ACWG and CARD Groups has asked for permanent monitoring of NSG wells on the near west side of the city with no indication of action on this.
Links:
Link EPA Dingell Oct 30 Meeting (https://www.youtube.com/watch?v=q4XNtTqLZHc&t=939s)
Michigan Department of Environmental Quality (MDEQ)-Gelman Project Site; Washtenaw County CARD Site; Scio Residents for Safe Water (SRSW)
YouTube of CARD/DEQ Regular Meeting 2-5-19 , by Roger Rayle Chair of CARD (https://www.youtube.com/watch?v=1BSSRTCTH9I) Other videos are under CARD WC in Youtube.
Lots of stores by Ryan Stanton in Ann Arbor News/MLive including this recent article 'EPA holding off on Superfund designation for Gelman dioxane plume'
Lots of details from Barbara Lucus at Dioxane.Org and WEMU News Program GreenRoom
See ACWG site pages EPA Superfund Option Details
Click here to view and/or sign in support of Superfund Designation
Planning Commission to Consider Development of Very Polluted DTE Site at Depot St and 841 Broadway St Largely in the Floodway and Floodplain - Wed Feb 20, City Council Chambers 7pm
City Web Image of FW FP of Proposed Mixed Use Development (ACWG)
Coal Tar found and shown by DEQ at river's edge at the site subsequently cleaned up in recent years (WUOM)
There was a developer lead public meeting on 8-8-18 to discuss the proposed Mixed Use Development on the DTE site on Depot St.
The developer stated that they are seeking changes in the floodplain floodway map of the site through a Letter Of Map Revision FEMA (LoMR) with their consultants Smith Group. This seems like a not a sure thing, and they say if not, plans will need to be changed.
The site is mainly floodway (FW) not floodplain (FP) as was stated at the meeting. A HUGE difference. FW is where floodwater is flowing, very dangerous.
This site flooded in the 1968 flood with water covering most of the site.*
The Argo dam was breached on the north side in the 1968 flood.
In the 1968 flood many of the area dams were heavily damaged and, some breached and over topped.
They stated that tests show the Groundwater below the site is contaminated.
Contaminated Groundwater tests need to be made to see if it is leaving the site, the site of the old Huron Riverbed.
At a public meeting for local residents at the Smith Group building on Sept 5, 2018, I was told
They will be doing modeling for a FEMA LOMAR.
This model will NOT include the new opening in the RR Berm across from the site which may increase flood hazard on this site.
The funding for the tunnel in the RR Berm will very likely be accepted by council this week.
The model will NOT include Global Warming effects now being felt in Michigan, 1,000-year (.1% chance) storm this summer in the UP.
Will not take into account the very poorly calibrated flood maps used for this site.
They are planning a Brownfield partial cleanup with about $24M from taxpayers, and about $12M from the developer.
This will not be a full cleanup as they say this is not required in the current MI Part 201 statute.
DTE should be doing a cleanup of this site as the Responsible Party Legal Owner, not taxpayers.
The site is very polluted and in the old river bed as shown by their own presentation photos (also shown in the photo below), with a very high water table would be very likely if not certain.
Vapor Intrusion (VI) is a real issue being faced by many sites which were built over old dump sites. In Petoskey MI recently 11 of 14 condos were evacuated due to VI issues from building in an old dump site.
The pollution maps produced by DTE and the city are not accurate. At the Allen's Creek Outlet on the west side of the site clearly there are significant black coal tar deposits visible when the sheet pile was installed, all the way down as far as they dug. This is not at all on the pollution maps.
The pollution on site should not be left in place to create a VI exposure risk, pollute the groundwater and river, and be left for future generations to deal with.
If done right could be a nice park close to the city center. When it floods hose it off and go back to being a park like many progressive (and non-progressive) cities are doing.
Old Image showing DTE is in the Old River Bed (AADL Holdings)
One Version of the Draft Proposal
Dr Larissa Larsen an Associate Professor in the School of Architecture and Planning U of M stated clearly as her first comment, as an invited panelist, at the AA-Sponsored Climate Discussions a few years ago, 'first don't build in the floodplain' which the ACWG commented on previously and does completely agree.
Link MLive recent article: DTE unveils plan for $75M riverfront redevelopment in Ann Arbor
Report: "THE GROWING THREAT OF URBAN FLOODING: 2018" a Global Warming Warning
Mary St. Ann Arbor' 2015 - Under 2" Rain Event
Report By:
The University of Maryland, College Park A. James Clark School of Engineering Center for Disaster Resilience
Texas A&M University, Galveston Campus Center for Texas Beaches and Shores
Two main findings of this report:
"In much of the United States, urban flooding is occurring and is a growing source of significant economic loss, social disruption, and housing inequality. Extensive suburban development that creates higher flood flows into urban areas, aging and frequently undersized infrastructure in older sections of communities, an inability to maintain existing drainage systems, increases in intense rainfall events, and uncoordinated watershed management all contribute to these increases in urban flooding.
The growing number of extreme rainfall events that produce intense precipitation are resulting in—and will continue to result in—increased urban flooding unless steps are taken to mitigate their impacts." (bold by us)
Ann Arbor needs to stop building in our floodplains and floodways putting more people in harm's way and start moving to opening up these channels to the river and reducing flood hazard with much more green treatments like the Green Streets Policy the ACWG was instrumental in writing and adoption. The Greenway was one of the methods accepted by many and promoted for this and other reasons, which the ACWG has been a leader in for over 15 years.
The 2012 5"-6" rain that flooded south Ann Arbor is the kind of rains we will see more of and we need to prepare, "pound of cure".
Link: https://cdr.umd.edu/sites/cdr.umd.edu/files/urban-flooding-report-online.pdf
Rescheduled - Free Film Screening and Discussion U of M SPH on PFAS - "The Devil We Know", a film about PFAS in a West Virginia community, 2-19-19
Rescheduled due to weather - Arctic Vortex
Sponsored by U of M School of Public Health:
Center for Occupational Health and Safety Engineering (UM-SPH COHSE)
Michigan Center on Lifestage Environmental Exposures and Disease (UM-SPH MLEEaD)
All are welcome to attend this free screening. The film will be screened on Tues. February 19, 2019 at 5:30 pm in 1755 SPH I. The film runs for an hour and a half and will be followed by a short Q&A panel with experts on PFAS. Pizza and beverages will be provided.
SPH I is the building to the North of the 'SPH Tunnel' off Washington Heights.
Register at the following link so we know how much food to order (registration is free; with reschedule this seems to be not updated last checked; you may attend even if not registered): https://www.eventbrite.com/e/the-devil-we-know-film-screening-tickets-54599222745
Description of the film: When a handful of West Virginia residents discover DuPont has been pumping its poisonous Teflon chemical into the air and public water supply of more than 70,000 people, they file one of the largest class action lawsuits in the history of environmental law. As the citizens of Parkersburg rise up against the forces that polluted their town, the story builds out to dozens of other American cities. In fact, as many as 110 million Americans may be drinking water tainted with PFAS chemicals. Exposure to this class of chemicals has even become a global phenomenon, spreading to places like Italy, the Netherlands, and China. For more, visit https://thedevilweknow.com
Proposed Agenda and Updates:
January 17, 2019
Danaher/Pall/Gelman 1,4-Dioxane Plume - With 19 ppb Now at West Park Plans for a MDEQ 6 Month Test of Allen's Creek Pipes
Coalition for Action on Remediation of Dioxane (CARD) meeting this month again we discussed the clear need for Near-Surface Groundwater (NSG) plan to monitor NSG exposures.
MDEQ has a new plan to test for the next 6 months many manholes on the west side up from West Park. We have been given the map of the proposed sites.
This is not the plan we had hoped to see but after over 2 years of pressure from ACWG and CARD it is a start.
The Water Resources Commissioner is pushing for storm sewer pipe tests as that is his responsibility with regards to fresh rainwater runoff (stormwater) contamination. A more detailed and expanded test program is what's really needed and has been requested.
Dan Bicknell had proposed a meaningful study to the MDEQ, which in principle has strong support from many in the CARD group, that maybe we can get implemented next to protect homeowners and business from exposure to contaminated groundwater. See Past Agenda Items on our web site.
It was again noted that 280 ppb is the limit for contaminated flows into surface waters yet 1,900 ppb allowed in homes basements. No comment on plans to deal with this threat to homes and businesses in its path. Just 11 blocks upstream we have had readings of close to 1,000 ppb at Vet's Park area.
If homeowners or businesses have over 250 ppb in their basements and have a sump pump discharging it they will be in violation of State Law which limits it to below 251 ppb. What is a homeowner or business to do? Again No Comment from our state, county or city leaders when asked at this meeting.
85 PPB 1,4 Dioxane found at Glendale in a Monitoring Well:
This was disclosed at the CARD meeting. This will trigger more testing to determine which way this higher concentration is moving. It is on the edge of the Prohibition Zone, where the compound is proposed to be kept inside of this zone.
Superfund Revisit:
Our new city council needs to revisit and vote to support the USEPA Superfund Petition the previous council passed on. Join with and support AA Twp, Scio Twp and SCHVG in this petition. The initial evaluation for the Gelman site can only be described as 'Off the Charts' and if not for the replaced and discredited former Governor stopping it, it would have very likely gone to a USEPA Superfund Full Evaluation.
1,4 dioxane and PFAS issues unregulated by EPA or federal oversite:
The outgoing Governor signed Lame Duck bills that would force the state to use EPA stated exposure levels and not allow the state to set and enforce exposure levels of compounds. At the meeting, the officials said we need to wait for the new state leadership to study these changes and deside if they will be enforced or modified. Let's hope they are modified. For 1,4 Dioxane and PFAS, very important to Ann Arbor area, EPA has no standard currently.
MLive :"Two lame-duck bills signed by Snyder, HB 4205 and SB 1244, are undergoing review by new state attorney general Dana Nessel. Together, the bills limit the science that regulators could use to set toxic cleanup standards and prohibit state regulations from being stricter than federal ones."
The state legislator and Federal legislators have introduced bills that would force the setting of standards for these compounds that would be protective of health and safety.
On January 14, 2019 Representatives Debbie Dingell (MI-12), Fred Upton (MI-6), and Dan Kildee (MI-5) introduced bipartisan legislation that designates all PFAS chemicals as hazardous substances and allows the Environmental Protection Agency (EPA) to clean up contaminated sites in Michigan and across the country.
New Council New Governor New AG New SS New DEQ Leadership, Gerrymandering Voted Down, New Members of City Council, we have some hope for meaningful change.
Links:
Link EPA CW Dingell Oct 30 Meeting
Michigan Department of Environmental Quality (MDEQ)-Gelman Project Site; Washtenaw County CARD Site; Scio Residents for Safe Water (SRSW)
YouTube of CARD/DEQ Regular Meeting January 2019, by Roger Rayle Chair of CARD (https://www.youtube.com/watch?v=eOvNlpjj1io)
Lots of stores by Ryan Stanton in Ann Arbor News/MLive including this recent article 'EPA holding off on Superfund designation for Gelman dioxane plume'
Lots of details from Barbara Lucus at Dioxane.Org and WEMU News Program GreenRoom
See ACWG site pages EPA Superfund Option Details
Once again city officials are Proposing Affordable Housing and Other Housing in the Floodplain
415 West Washington (ACWG; Click for larger image)
Association of State Floodplain Managers 2007 (ASFPM)
(Click for larger image)
"BUILDING IN THE FLOODPLAIN IS LIKE PITCHING YOUR TENT
ON A HIGHWAY WHEN THERE ARE NO CARS COMING"!
ASFPM: www.floods.org
Again 415 West Washington was discussed this month by city administrator as a potential site for housing and other business uses. This site is virtually all floodplain and floodway. In a major storm, like Michigan is now getting on a regular basis, this site may have several feet of floodwater, with the parts in the floodway will be rushing water toward the Huron River. It only takes 8" of rushing rain water runoff to move a full-size car.
Greenway and park location is the best and most viable use of this site. Reduce flooding, greatly increase tax base for the area, provide alternative transportation and create a green space close to city center that connects to the city center, and protect existing homes and businesses from flooding with Global Warming threats the city has purported to care about.
As we asked before and FOIA'ed the DDA - we would like to see the FTCH Study:
The DDA's FTCH $1/4 to $1/2M budgeted consultants study of the watershed, just upstream of this site. should also be made available to the public. The ACWG FOIA'ed the study but was just given a copy of the raw data used to do models but the report was never offered. FTCH said the DDA had to agree to make it available which they never did.
2013 Reuter Report commissioned by the city indicates it can be up to nearly 9-foot floodplain on this site.
The city map of this site shows a 3-foot, not 9'.
The LOMR for the YMCA site across the street, just 1 1/2 years after construction showed a change of 33% from the 3' as built to 4' which obligated the 'Free Board' (1-foot free space below the building to the floodplain) the building was permitted with.
The Y also creates a near full floodway dam with the fencing installed, which the DEQ allowed construction, contrary to ACWG protests. Chain Link Fencing is like a solid wall in hydrological models as it gets clogged up very quickly in a flood event. This has put many more non-floodplain homes at risk upstream and they do not even know it or have the warning to get flood insurance. It also very negatively effects the tax base of the area with this unnecessary flood risk.
President Obama vitrually forbid using federal funds for building in the 100-year (1% chance) floodplain and virtually forbid the use of federal funds for building any critical structures in the 500-year (.2% chance) floodplain due to Global Warming effects causing more intense rain events.
City of Ann Arbor Hazard Mitigation Plan 2017
Free Film Screening and Discussion U of M SPH on PFAS - "The Devil We Know", a film about PFAS in a West Virginia community
Sponsored by U of M School of Public Health:
Center for Occupational Health and Safety Engineering (UM-SPH COHSE)
Michigan Center on Lifestage Environmental Exposures and Disease (UM-SPH MLEEaD)
All are welcome to attend this free screening. The film will be screened on January 31, 2019 at 5:30 pm in 1755 SPH I. The film runs for an hour and a half and will be followed by a short Q&A panel with experts on PFAS. Pizza and beverages will be provided.
SPH I is the building to the North of the 'SPH Tunnel' off Washington Heights. (Click for larger view)
Register at the following link so we know how much food to order (registration is free): https://www.eventbrite.com/e/the-devil-we-know-film-screening-tickets-54599222745
Description of the film: When a handful of West Virginia residents discover DuPont has been pumping its poisonous Teflon chemical into the air and public water supply of more than 70,000 people, they file one of the largest class action lawsuits in the history of environmental law. As the citizens of Parkersburg rise up against the forces that polluted their town, the story builds out to dozens of other American cities. In fact, as many as 110 million Americans may be drinking water tainted with PFAS chemicals. Exposure to this class of chemicals has even become a global phenomenon, spreading to places like Italy, the Netherlands, and China. For more, visit https://thedevilweknow.com/
FROM US-EPA - https://www.epa.gov/pfas/basic-information-pfas:
Per- and polyfluoroalkyl substances (PFAS) are a group of man-made chemicals that includes PFOA, PFOS, GenX, and many other chemicals. PFAS have been manufactured and used in a variety of industries around the globe, including in the United States since the 1940s. PFOA and PFOS have been the most extensively produced and studied of these chemicals. Both chemicals are very persistent in the environment and in the human body – meaning they don’t break down and they can accumulate over time. There is evidence that exposure to PFAS can lead to adverse human health effects.
PFAS are Teflon related chemicals that are called the 'Wonder' 'Forever Chemicals'.
Links:
"Per- and Polyfluoroalkyl Substances (PFAS) Webinar: May 16 2018" M-LEEaD
Here is the link to the full Video of the talk posted by Michigan Center on Lifestage Environmental Exposures and Disease (M-LEEaD) on an Updated Jun 25, 2018 Post YouTube https://www.youtube.com/watch?v=OkDdq9i1Qg8
City of AA PFAS site https://www.a2gov.org/departments/water-treatment/Pages/PFAS-Information.aspx
MLive, Ryan Stanton: Dec 18; At least 7 types of PFAS in Ann Arbor’s drinking water, reports show https://www.mlive.com/news/ann-arbor/2018/12/at-least-7-types-of-pfas-in-ann-arbors-drinking-water-reports-show.html
Still, No Action After Over a Year - Stormwater Pipes and Unapproved Flows Were Added to Two Public Wooded Natural Areas With City Notification But Without City Action, One Woodland is Owned by AAPS
First Martin Illegal 10" SW Pipe flowing into the Neighbohood FairGlen Woodland Commons (ACWG; Click for larger image)
Illegal SW Pipe flowing into Eberwhite Woods, Eberwhite School,
Eberwhite Woods Committee, AAPS (Circled in Red) (ACWG; Click for larger image)
We have had two cases now where illegal (as determined by city staff in both email and phone calls) stormwater pipes and stormwater flows added to natural areas on the west side recently, without action by the city to have them removed.
Residents, AAPS and natural area stewards should not be forced to bend over backwards or go to court to get relief from illegal actions by folks at companies who probably don't even live in our city which are causing harm.
Or have the MDEQ come to town and directly order the city of Ann Arbor to take action as they have done in the recent past on the Beal Building on Kingsley St. deliberately blocking the Allen's Creek floodway and like we forced the MDEQ from allowing the city and county to build the $1M plan for the Homeless Shelter in the floodway.
These actions have a clear effect on Life and Property.
Link: AAPS
Proposed Agenda and Updates:
December 20, 2018
Danaher/Pall/Gelman 1,4-Dioxane Plume - 19 ppb Now at West Park Yet Still Very Minimal Plans to Determine Its Effect on the West Side Homes and Business
Coalition for Action on Remediation of Dioxane (CARD) meeting this month we discussed the clear need for Near-Surface Groundwater (NSG) plan to monitor NSG exposures. A few additional tests were proposed by the DEQ. This is not what we have asked for given the potential exposure to residents and homes.
DEQ proposed some meaningless "NSG" tests that we asked they not do to save the effort and money for the other few meaningful ones they did propose.
It was again noted that 280 ppb is the limit for contaminated flows into surface waters yet 1,900 ppb allowed in homes basements. No comment on plans to deal with this threat to homes and businesses in its path. Just 11 blocks upstream we have had readings of close to 1,000 ppb at Vet's Park area.
If homeowners or businesses have over 250 ppb in their basements and have a sump pump discharging it they will be in violation of State Law which limits it to below 251 ppb. What is a homeowner or business to do? Again No Comment from our state, county or city leaders when asked at this meeting.
Knowledgeable city staff now openly state the plume is 'going to Barton' in recent months. This has been stated by CARD members for many years with little support from the city and some county officials in the past. Professor Larry Lemke comments in past years is this it is moving toward Barton and is a downhill run once it passes M14. There is a preferred path in an ancient creek-bed running into Barton from the south.
The New Gelman Well Planned at the Core Needs to go to Bedrock (will not happen!):
DEQ commented that Gelman needed to re-bore a well at the Core due to failure. CARD group asked for this new well go to Bedrock. A well at this location to bedrock would be a great means to determine contamination at the core. The DEQ has said they asked but Gelman is not interested in doing it and the DEQ is afraid to force them as it may allow Gelman to drag its feet in doing the installation. We have no data on lower levels of the aquifer of 1,4 Dioxane that would greatly help models predict its flow, which is seemly now moving in all directions from the Core.
USEPA Superfund would just do the well and charge Gelman. We have very little data for the lower level aquifer concentrations that should have been done decades ago.
Superfund Revisit:
Our new city council needs to revisit and vote to support the USEPA Superfund Petition the previous council passed on. Join with and support AA Twp, Scio Twp and SCHVG in this petition. The initial evaluation for the Gelman site can only be described as 'Off the Charts' and if not for the, soon to be replaced and discredited, Governor stopping it, it would have very likely gone to a USEPA Superfund Full Evaluation.
New Council New Governor New AG New SS New DEQ Leadership, Gerrymandering Voted Down, we have some hope for meaningful change.
Links:
Link EPA CW Dingell Oct 30 Meeting
Michigan Department of Environmental Quality (MDEQ)-Gelman Project Site; Washtenaw County CARD Site; Scio Residents for Safe Water (SRSW)
YouTube of CARD/DEQ Regular Meeting November 2018, by Roger Rayle Chair of CARD (https://www.youtube.com/watch?v=udW-qFyFTJY)
Lots of stores by Ryan Stanton in Ann Arbor News/MLive including this recent article 'EPA holding off on Superfund designation for Gelman dioxane plume'
Lots of details from Barbara Lucus at Dioxane.Org and WEMU News Program GreenRoom
See ACWG site pages EPA Superfund Option Details
Click here to view and/or sign in support of Superfund Designation
Fingerle Sale to U of M Is a Potential Flood Hazard Disaster Waiting to Happen, Majority of the Site is in the Floodway, the Most Dangerous Area in a Flood, Global Warming is Making Floods More Frequent and More Dangerous
Some Fingerle Property Sites (ACWG, Click for larger image )
City Of Ann Arbor Athletic Campus Flood Hazard, 2017;
Yellow .1%, Orange is .2% chance is Athletic Campus Floodplain ACF
(Annotations on map in Black ACWG; Click for larger image)
Flooding Just Upstream of Fingerle Sites on Mary St. in recent years, in under a 2" Rain
Mary St. Polling place Block Building to left (Click for larger image)
Association of State Floodplain Managers 2007 (ASFPM)
(Click for larger image)
"BUILDING IN THE FLOODPLAIN IS LIKE PITCHING YOUR TENT
ON A HIGHWAY WHEN THERE ARE NO CARS COMING"!
ASFPM: www.floods.org
U of M bad presidents for floodplain floodway (FP) management: The U of M commissioned its own FP evaluation and found no FP on the Athletic Campus. The city did its own reevaluation and found it still had significant FP concerns, see City of Ann Arbor's own 2017 map above.
From the 2017 Report: "Allen Creek south of Hill Street (Figure 4.20) – On the effective FEMA DFIRM, the area of Allen Creek located south of Hill Street is not included in the 1.0 percent annual flood chance area (it is included in the 0.2 percent annual chance flood area). Using the InfoSWMM model data, the floodplain delineation would extend south through Hoover and S. State Street." (1.0% is 100-year chance flood - floodplain, 0.2% is 500-year chance flood, bold by us)
The U of M has continued to develop in the contested floodplain in this area creating more flood hazard upstream of this site. It is clear people in these homes upstream of this area may not know they are in the floodplain or know they should have flood insurance. Homeowners insurance does not cover overland flood damage, FEMA does, if you know you need it and get it in time, there is a waiting period. FEMA Flood Insurance is increasing at very high rates due to several factors including Global Warming effect on rainfall amounts.
Floodplains are for flooding according to experts like U of M Planning Professor and ASFPM.
Greenway and park location is the best and most viable use of this site. Reduce flooding, greatly increase tax base for the area, provide alternative transportation and create a green space close to city center that connects to the city center, and protect existing homes and businesses from flooding with Global Warming threats the city has purported to care about.
President Obama virtually forbid using federal funds for building in the 100-year (1% chance) floodplain and virtually forbid the use of federal funds for building any critical structures in the 500-year (.2% chance) floodplain due to Global Warming effects causing more intense rain events.
City of Ann Arbor Hazard Mitigation Plan 2017
Ann Arbor Solar Tax Needs to Stop; Carbon Emission Reducing Energy Will Stop Global Warming and Mega Rain Events that will Follow; City of Ann Arbor Solar Panel Rebates
Ann Arbor's Mark Clevey and Nancy Fenton LARATT case that they lost; (ACWG; Click for larger image)
The State may change State Law to not include in the property tax a tax on solar panels on the homeowner who installs them, but will tax the next owner for the value of the solar panels. We need to have no property tax on solar panels like the vast majority of cities in Michigan.
The ACWG has proposed the city can use a Rebates as they do with Stormwater to encourage beneficial actions of its residents.
If you install Rain Gardens, Rain Barrels, Bio Swales or other specific rain capture devices you can sign up for a rebate or discount on your Stormwater Fees. The ACWG working with the Water Committee of the Env. Comm. were instrumental in getting these discounts enacted years ago when the ACWG had a 16 year Charter Member on the EC.
Solar Panel Rebates are an easy solution for a city that purports to support reductions in carbon emissions and community resiliency.
City of Ann Arbor is one of the few places in Michigan that Taxes Solar Panels on homes. Long past time to put a stop to this.
MLive: 'Cities can raise your property taxes for adding solar panels, Tax Tribunal rules' Ann Arbor Residents contest Ann Arbor's Solar Tax, 4-16-18. Mark Clevey and Nancy Fenton Ann Arbor residents will 'take it to the Supreme Court' if necessary; Clevey's attorney, Samuel Field.
New Council Seems to Have a Better Attitude About Water and the Need to Protect Our Water Sources and Reduce Flood Hazard
New City Council Members Event Card
Proposed Agenda and Updates:
November 15, 2018
Danaher/Pall/Gelman 1,4-Dioxane Plume - EPA Superfund Meeting Oct 30th, Governor Stopped Superfund Designation Full Evaluation; 19 ppb Now at West Park
Wide Angle Image of EPA Superfund manager Michael Berkoff, Congresswoman Debbie Dingell, MDEQ
and other Stakeholders meeting 10-29-18 (ACWG, click for larger view )
The Coalition for Action on Remediation of Dioxane (CARD) members attended the EPA and Congress Women Debbie Dingell meeting on Monday, Oct. 29th to discuss progress/or lack thereof on the Gelman Plume.
Link to the great video of this meeting courtesy of Roger Rayle.
Unlike the last EPA SuperFund meeting, this meeting was open meeting did not omit critical stakeholders.
With new leadership in Ann Arbor and in Lansing and with help from state NGO's we need to petition the new Governor to have EPA proceed with Superfund evaluation and potential Superfund Designation with a Responsible Party in the owner Danaher.
Knowledgeable sources have indicated that $50M and in 10 years we could potentially clean up the plume and save Barton Pond, many private wells and homes from contamination.
New data on Near-Surface Groundwater (NSG) tests at West Park showed 19 ppb, 400% increase from 8 months ago. The NSG tests were not in the MDEQ plans till the ACWG and CARD Groups insisted on tests be made.
280 ppb is the limit for contaminated flows into surface waters yet 1,900 ppb allowed in homes basements. No comment on plans to deal with this threat to homes and businesses in its path. Just 11 blocks upstream we have had readings of close to 1,000 ppb at Vet's Park area.
If homeowners or businesses have over 250 ppb in their basements and have a sump pump discharging it they will be in violation of State Law which limits it to below 251 ppb. What is a homeowner or business to do? No comment from our state, county or city leaders when asked at this meeting.
It was disclosed that the Superfund Designation for the Gelman site would have proceeded for next step in the evaluation if the governor had not stopped it according to EPA Superfund manager Michael Berkoff. The site met the standard for next step in evaluation without doing most of the obvious evaluation which would have put it even higher standing.
We have new State and city leadership after the November election. We need to move to pressure them to support a continued Superfund Designation.
Governor-Elect Whitmer would be more approachable than our current term-limited Republican Governor.
Still no comment on a real plan of action on the NSG exposure potential, not simply more minimal tests. Dan Bicknell's GEA Comments on the DEQ Shallow Groundwater Work Plan and his proposed plan is posted in the November 2016 Agenda. Dan had a very well and logical plan laid out for dealing with the initial investigation of the NSG issue which seems to be clearly a problem that needs addressing.
The ACWG and CARD Groups has asked for permanent monitoring of NSG wells on the near west side of the city with no indication of action on this.
Links:
Link EPA Dingell Oct 30 Meeting
Michigan Department of Environmental Quality (MDEQ)-Gelman Project Site; Washtenaw County CARD Site; Scio Residents for Safe Water (SRSW)
YouTube of CARD/DEQ Regular Meeting October 2018, by Roger Rayle Chair of CARD (https://www.youtube.com/watch?v=cujtejRg2q0&t=2710s)
Lots of stores by Ryan Stanton in Ann Arbor News/MLive including this recent article 'EPA holding off on Superfund designation for Gelman dioxane plume'
Lots of details from Barbara Lucus at Dioxane.Org and WEMU News Program GreenRoom
See ACWG site pages EPA Superfund Option Details
Click here to view and/or sign in support of Superfund Designation
Stormwater Pipes and Unapproved Flows Were Added to Two Public Wooded Natural Areas With City Notification But Without City Action, One Woodland is Owned by AAPS
Fairglen Fst Martin Illegal 10" SW Pipe (ACWG; Click for larger image)
Illegal SW Pipe into Eberwhite School, Eberwhite Woods Committee, AAPS (Circled in Red) (ACWG; Click for larger image)
We have had two cases now where illegal (as determined by city staff in both email and phone calls) stormwater pipes added to natural areas on the west side recently, without action by the city to have them removed.
Fairglen:
One is in the Fairglen Commons Nature area, between Liberty and Glendale streets, where First Martin added an unpermitted 10' stormwater pipe without a city permit from Manchester West Apartments on Liberty St. The ACWG provided photos and map to show the offending installation. We received communication from city staff that this was not a permitted stormwater pipe and is illegal but have yet received notice that they have forced its removal. City staff did inspect the installation of the pipe. First Martin's workers who were doing the work said it was a replacement pipe they were installing. Not true by city and ACWG own checking of existing pipe location on 'As Built' stormwater pipe plans for the area. There was not a pipe to the Fairglen Wooded area at that location.
This additional unpermitted stormwater flow will cause more flooding issues for an overtaxed natural and residential area. Many homes are near the FEMA 2004 designated floodplain near the wooded commons and have had flooding in their backyard nearly up to their back doors.
We have worked successfully with city staff over the past 10 years to get flows reduced going into this neighborhood, reducing flood hazard and excess fast-food street trash filling up the woodland. Excessive erosion is a constant issue still in this woodland, causing silt clogged stormwater pipe maintenance issues, extensive tree loss and flood hazard, which negatively effects the tax base and livability of the neighborhood.
The city does not have a permit to store large amounts of stormwater in this wooded commons, up to 6' deep at times, causing real flood hazard and reducing livability, property values, wooded natural area and the tax base.
Eberwhite School Eberwhite Woods Committee AAPS:
The other is a ~8" stormwater pipe added to Eberwhite Woods added by a developer of new homes on Liberty next to Eberwhite Woods. This has been reported to city staff over a year ago as indicated to me by the Eberwhite School Eberwhite Woods Committee AAPS. They contacted the ACWG for information on this new pipe and asked if developers on Liberty to the east can just add a 8" stormwater pipe into the Eberwhite Woods without a permit. We advised them it would not be legal and they should contact the city staff. They were told by city staff that it was not a permitted stormwater pipe and the extensive stormwater erosion from the pipe would stop as they were requiring the pipe be removed. Over a year later the pipe is still sending stormwater into the woods and eroding one of the pedestrian paths and destroying vegetation in the Nature Area the volunteers of the EWC are trying hard to restore.
Residents, AAPS and natural area stewards should not be forced to bend over backwards or go to court to get relief from illegal actions by folks at companies who probably don't even live in our city which are causing harm.
Council Should Reconsider the Floodplain Overlay Planning That Was Voted Out of the City 2017 City Budget by Majority on City Council, Then They Approved over 110 New Homes in the Floodplain
June 14, 2015 - Major Flooding on Mary St. - U of M Athletic Campus Area - in Central Ann Arbor After Just Under 2" Rain
Floodplain Management Overlay Ordinance with over 4 years of work by staff and U of M Graduate Students needs to be Reconsidered by our new City Council in an effort to protect the residents in Ann Arbor.
Current city council shot down the Floodplain Management Overlay Ordinance then goes on to approve over 110 new homes in the floodplains of Ann Arbor.
The cost to produce this plan it very high when you consider the U of M graduate students time and city staff time in the 4-year effort to research and put this together.
Council Members Jack Eaton, Sumi Kailasapathy and Jane Lumm had brought a resolution for Floodplain Management Overlay Ordinance at the first Council meeting in July 2016.
This Resolution has been postponed twice by majority vote of our City Council and then voted down.
This was a resolution worked on by city staff with graduate students and faculty from UM who did considerable research and work to its end, and whose help had been requested by city staff.
Comments by the opposing council members indicated they would consider adding to the 2017 City budget which would be more appropriate avenue to take.
Unfortunately, the option to include it in the 2017 budget was not supported by the majority on council.
This same majority went on to approve over 110 new homes in the floodplains of Ann Arbor.
Adopting this ordinance would have been part of the effort to meet the Federal Community Rating System (CRS). The CRS ranks cities according to their compliance with federal flood management requirements. Currently, Ann Arbor does not fully participate in the CRS. Ann Arbor rates 6 of 10 with 1 being the best score fully engaged*. With each improvement in our local flood management plan, City residents and businesses become eligible for larger discounts on flood insurance which is predicted to increase greatly for at least the next decade according to city staff and council comments and, published reports.
Update 10-29-18:
NSG found at large jump from 4.4 to 19 ppb 400% increase 1,4 Dioxane at West Park Allen's Creek groundwater flows during very dry period with high pipe flows (assumed groundwater, NSG), according to MDEQ reported today at the EPA, local public and government meeting. This up from the last test at 4.4 ppb about 8 months ago.
It was also disclosed at this meeting that a Superfund site could/would have been declared by US EPA if EPA took the next steps for evaluation for the Gelman Site if Governor Rick Snyder had allowed it. He said no.
From the meeting:
Wide Angle Image of EPA Superfund manager Michael Berkoff, Congresswoman Debbie Dingell, MDEQ
and other Stakeholders meeting 10-29-18 (ACWG, click for larger view )
Proposed Agenda and Updates:
October 18, 2018
Update: Jeff Hayner for Ward 1 City Council Democratic candidate is now also endorsed by the ACWG, see voting below.
Danaher/Pall/Gelman 1,4-Dioxane Plume - EPA Superfund Proposed Meeting Oct 29th*
The Coalition for Action on Remediation of Dioxane (CARD) has been told that the EPA and Congress Women Debbie Dingell have scheduled a meeting for Monday, Oct. 29th to discuss progress/or lack thereof on the Gelman Plume.
EPA Superfund Stakeholder Meeting
Monday, Oct. 29th
Scio Township Hall, 827 North Zeeb Road
Unlike the last EPA SuperFund meeting we are assured by the EPA, it will be an open meeting and not omit critical stakeholders, which they note was not the intention of the EPA.
No progress on new monitoring wells or meaningful long-term plans for Near-Surface Groundwater (NSG) tests:
Still no comment on the need for more monitoring wells, the DEQ and CARD asked for in the past, be installed in the northern area where there are few now, and Judge Shelton in the past dismissed them as unnecessary so Gelman did not need to add them. We have a new judge in charge and need to submit this request. No response from DEQ on this request.
Still no comment on a real plan of action on the NSG exposure potential, not simply more tests. Dan Bicknell's GEA Comments on the DEQ Shallow Groundwater Work Plan and his proposed plan is posted in the November 2016 Agenda. Dan had a very well and logical plan laid out for dealing with the initial investigation of the NSG issue which seems to be clearly a problem that needs addressing.
The ACWG and CARD Groups has asked for permanent monitoring of NSG wells on the near west side of the city.
There is a Confidentiality Agreement (CA) amongst some of the Stake Holders in the Gelman Plume.
I ask to have an Agenda item added to the CARD Oct. meeting to discuss the CA Group but we ran out of time before we could discuss it.
CA Group was arranged and agreed to by a subset of Stake Holders and then approved by Judge Connors.
We were told it was a Court Ordered Group, not true, after pressure from CARD members it was later stated the judge approved the self-selected group of stakeholders.
EPA is not included in this CA Group.
When CARD members asked to see the CA Group agreement we were denied, until a CARD Board member threatened to FOIA it.
This group has been "meeting" for well over a year.
Comments from members of the CA Group is it has not met very often.
No word on any potential agreements or discussions or deadlines.
This CA Group does not involve major critical stakeholders like SRSW, EPA Superfund, Ann Arbor Twp, Sierra Club Huron Valley Group, ACWG and others.
Seems time to open up this discussion and include the folks who are going to pay the cost of this non-cleanup Remediation. Their voices need to be heard and attended to. This issue is much too important to keep behind closed doors.
CARD members voted in the October meeting to keep the current Board for the next upcoming yearly term.
Links: Michigan Department of Environmental Quality (MDEQ)-Gelman Project Site; Washtenaw County CARD Site; Scio Residents for Safe Water (SRSW)
YouTube of CARD/DEQ Regular Meeting October 2018, by Roger Rayle Chair of CARD (https://www.youtube.com/watch?v=cujtejRg2q0&t=2710s)
Lots of stores by Ryan Stanton in Ann Arbor News/MLive including this recent article 'EPA holding off on Superfund designation for Gelman dioxane plume'
Lots of details from Barbara Lucus at Dioxane.Org and WEMU News Program GreenRoom
See ACWG site pages EPA Superfund Option Details
Click here to view and/or sign in support of Superfund Designation
Major Climate Report Describes a Strong Risk of Crisis as Early as 2040 - NYT
MLive - MI Upper Peninsula 1,000 Year Rain June 2018 (click for larger image)
'A landmark report from the United Nations’ scientific panel on climate change paints a far more dire picture of the immediate consequences of climate change than previously thought and says that avoiding the damage requires transforming the world economy at a speed and scale that has “no documented historic precedent.”
The report, issued [last] Monday by the Intergovernmental Panel on Climate Change, a group of scientists convened by the United Nations to guide world leaders, describes a world of worsening food shortages and wildfires, and a mass die-off of coral reefs as soon as 2040 — a period well within the lifetime of much of the global population.': NYT (bold by us)
Ann Arbor and other communities need to Lead and work to avoid these historic changes in climate.
We should not be building out our floodplains, the 2007 City of Ann Arbor Flood Hazard Mitigation Plan clearly stated the city should not be building in the current floodplain and work to remove existing buildings in the floodplain (see below).
We need to make sure the floodways are not obstructed like what ACWG opposed but was allowed to occur at the Y and potentially building in the floodplains which may really be the floodway next year as was the case for the Affordable Housing on N Main. This project was blocked when the maps changed the year after the plan was submitted to the city showing it was now in the floodway.
The U of M needs to work with the city to reduce unmitigated runoff main campus and other properties
Create a Greenway that will create a buffer area for flooding, sparing potentially thousands of home from catastrophic flooding
The Allen's Creek Watershed is particularly at risk with very steep slopes, very flashy runoff, overbuilt environment
We have 100's if not 1,000's of homes and businesses at risk of flooding
The ACWG has worked with the city to do some important improvements but more is need
The ACWG were leaders in Ann Arbor and county in the use of:
Blocking the Homeless Shelter plans to build in the Floodway
Tried to block building the Y in the floodway
Green Streets, working with the Water Committee of the Environmental Commission and city staff and local consultants, whereby Green Streets, many already installed, will capture and infiltrate all the water on them from the road sidewalks and adjacent buildings
Rain Barrel and Rain Garden use and fee rebates, reducing runoff, pollution and heat island effects
Porous Pavement, already on many streets and parking lots in Ann Arbor (including U of M) which allow runoff to capture and infiltrate all the water on them detoxifying pollutants naturally as it infiltrates through the Rice Cake like pavement, greatly reduce heat island and noise
West Park Flood Mitigation improvements
Writing the Allen's Creek Watershed Management Plan, unlike with the other plans, with no external funds or assistance, was adopted by city, county and state government.
Working with the Water Committee of the Environmental Commission and city staff to get a Flood Hazard Mitigation Plan passed in 2007
Preservation of Green parks and other Green landscapes
Championing the Allen's Creek Greenway for over 20 years which will greatly reduce flooding and polluted floodwaters into city neighborhoods, not to mention all the other real benefits
Championing additions to the CIP for funding for flood hazard reduction efforts
Link: NYT article
https://www.nytimes.com/2018/10/07/climate/ipcc-climate-report-2040.html
Adopted City Of Ann Arbor Flood Hazard Mitigation Plan 2007 - Should Not Be Ignored
City of Ann Arbor
The ACWG working closely with the Water Committee of the Environmental Commission helped write and get past this plan in 2007. Many of the major objectives have not been followed in recent years. Working closely with developers to develop new homes and businesses in flood-prone properties is not a recommendation of this plan.
The city has added over 110 new homes in the floodplain and many of the people in these homes may not know they are in the floodplain or know they should have flood insurance.
Some of the Major Objectives of the Plan:
"Public acquisition and management of flood prone properties.
Permanent relocation of flood prone structures to areas outside the floodplain.
Establish clear and consistent government policy for public owned land in the floodplain aimed at preventing public buildings in the floodplain.
Create Allen['s] Creek Greenway in floodplain area"
Regular data collection and modeling to update flood hazard maps
Decrease Flood Insurance Rates by meeting FEMA required flood hazard mitigation recommendations
A 2017 Hazard Mitigation Plan, which now includes the Flood Hazard Plan, has been produced and accepted. This plan, according to city staff, has many of the same aims as the 2007 Flood Hazard Mitigation Plan version.*
Link: Flood Hazard Mitigation Plan 2007
https://www.a2gov.org/departments/systems-planning/planning-areas/water-resources/floodplains/Documents/FloodplanMitigationPlan_Mar07.pdf
Please VOTE November 6th, 7am-8pm
Watershed friendly candidates include:
Jeff Hayner for Ward 1 endorsed by the Sierra Club Michigan Chapter and Sierra Club Huron Valley Group; also endorsed by the ACWG*
Kathy Griswold for Ward 2 endorsed by the Sierra Club Michigan Chapter and Sierra Club Huron Valley Group
Elizabeth Nelson for Ward 4 endorsed by the Sierra Club Michigan Chapter and Sierra Club Huron Valley Group
Jeff Irwan for State Senate endorsed by the Sierra Club Michigan Chapter and Sierra Club Huron Valley Group
Yousef Rabhi for State House endorsed by the Sierra Club Michigan Chapter and Sierra Club Huron Valley Group
Proposed Agenda and Updates:
September 20, 2018
Danaher/Pall/Gelman 1,4-Dioxane Plume - EPA Proposed Meeting In September, Not Scheduled Currently
The Coalition for Action on Remediation of Dioxane (CARD) has been told that the EPA has proposed a meeting in September but no notice has been given to date. Some issues with scheduling have been given for past and present delays in giving early notice for EPA SuperFund meetings on the Dioxane Plume.
Unlike the last EPA SuperFund meeting we are assured by the EPA, it will be an open meeting and not omit critical stakeholders which they note was not the intention of the EPA.
At our last CARD meeting, I asked again for more monitoring wells, the DEQ and CARD asked for in the past, be installed in the northern area where there are few now, and Judge Shelton in the past dismissed them as unnecessary so Gelman did not need to add them. We have a new judge in charge and need to submit this request. No response from DEQ on this request.
Still no comment on a real plan of action on the NSG exposure potential, not simply more tests. Dan Bicknell's GEA Comments on the DEQ Shallow Groundwater Work Plan and his proposed plan is posted in the November 2016 Agenda. Dan had a very well and logical plan laid out for dealing with the initial investigation of the NSG issue which seems to be clearly a problem that needs addressing.
The ACWG and CARD Groups has asked for permanent monitoring of NSG wells on the near west side of the city.
Links: Michigan Department of Environmental Quality (MDEQ)-Gelman Project Site; Washtenaw County CARD Site; Scio Residents for Safe Water (SRSW)
YouTube of CARD/DEQ Regular Meeting September 2018, by Roger Rayle Chair of CARD (https://www.youtube.com/watch?v=cujtejRg2q0&t=2710s)
Lots of stores by Ryan Stanton in Ann Arbor News/MLive including this recent article 'EPA holding off on Superfund designation for Gelman dioxane plume'
Lots of details from Barbara Lucus at Dioxane.Org and WEMU News Program GreenRoom
See ACWG site pages EPA Superfund Option Details
Click here to view and/or sign in support of Superfund Designation
Recent Discussions of Development of Polluted DTE Site at Depot St and Broadway St In the FW FP
City Web Image of FW FP of Proposed Mixed Use Development (Annotated ACWG)
Coal Tar found and shown by DEQ at river's edge at the site
subsequently cleaned up in recent years (WUOM)
There was a developer lead public meeting on 8-8-18 to discuss the proposed Mixed Use Development on the DTE site on Depot St.
The developer stated that they are seeking changes in the floodplain floodway map of the site through a Letter Of Map Revision FEMA (LoMR) with their consultants Smith Group. This seems like a not a sure thing, and they say if not plans will need to be changed.
The site is mainly floodway (FW) not floodplain (FP) as was stated at the meeting. A HUGE difference. FW is where floodwater is flowing, very dangerous.
The developers stated that test show the Groundwater below the site is contaminated.
Contaminated Groundwater tests need to be made to see if it is leaving the site, this is the site of the old Huron River bed.
At a public meeting for local residents at the Smith Group building on Sept 5, 2018, I was told
They will be doing modeling for a FEMA LOMAR.
This model will NOT include the new opening in the RR Berm across from the site which may increase flood hazard on this site.
The model will NOT include Global Warming effects now being felt in Michigan, 1,000-year (.1% chance) storm this summer in the UP.
Will not take into account the very poorly calibrated flood maps used for this site.
They are planning a Brownfield partial cleanup with about $24M from taxpayers, and about $12M from the developer.
This will not be a full cleanup as they say this is not required in MI Part 201 statute.
DTE should be doing a cleanup of this site as the Responsible Party Legal Owner, not taxpayers.
The site is very polluted and in the old river bed as shown by their own presentation photos (also shown in the photo below), with a very high water table would be very likely if not certain.
Vapor Intrusion (VI) is a real issue being faced by many sites which were built over old dump sites. In Petoskey MI recently 11 of 14 condos were evacuated due to VI issues from building in an old dump site.
The pollution maps produced by DTE and the city are not accurate. At the Allen's Creek Outlet on the west side of the site clearly there are significant black coal tar deposits visible with the sheet pile was installed, all the way down as far as they dug. This is not at all on the pollution maps.
The pollution on site should not be left in place to create a VI exposure risk, polluting the groundwater and river, and be left for future generations to deal with.
If done right could be a nice park close to the city center. When it floods hose it off and go back to being a park like many progressive (and non-progressive) cities are doing.
Shots of the presentation projected screenshots "changeable site plan", that were not distributed:
Draft Proposal (Photos and Annotations ACWG)
Old Image showing DTE is in the Old River Bed
(AADL Holdings)
City-Owned 415 West Washington Site In Recent City Discussions for Park Space or Development
415 W. Washington off city site (Annotated ACWG)
2013 Reuter Report commissioned by the city indicates it can be up to nearly 9-foot floodplain on this site. This report should be made available and details of this floodplain height statement.
The DDA FTCH $1/4 to $1/2M budgeted study of the watershed, just upstream of this site. should also be made available to the public. The ACWG FOIA'ed the study but was just given a copy of the raw data used to do models but the report was never offered. FTCH said the DDA had to agree to make it available which they never did.
The city map of this site shows a 3-foot, not 9', floodplain last we checked and were informed of.
The LOMR for the Y site across the street, just 1 1/2 years after construction showed a change from the 3' as built to 4' which obligated the 'Free Board' (1-foot free space below the building to the floodplain) the building was permitted with.
The Y also creates a near full floodway dam with the fencing installed, which the DEQ allowed construction, contrary to ACWG protests. Chain Link Fencing is like a solid wall in hydrological models as it gets clogged up very quickly in a flood event. This has put many more non-floodplain homes at risk upstream and they do not even know it or have the warning to get flood insurance. It also very negatively effects the tax base of the area with this unnecessary flood risk.
Discussions regarding the future of this site need to consider:
The floodway and floodplain cover 99% of the site
The floodway is already greatly harmed by past practices and flood hazard reduced not increased by poor planning.
City staff have commented at public meetings in the past that these flood maps are very poorly calibrated with very little data used to create them.
This should be an anchor park in the Greenway/Tree Line as has been promoted by many in the city, including high ranking city officials.
The buildings should go
The chimney should be kept as a major nesting area for Chimney Swifts, which are a protected species
"The birds are protected by the Migratory Bird Treaty Act. A federal permit is needed to remove chimney swifts and their nests during the nesting season." : Washington Post 2017
Global Warming is clearly now creating a much more dangerous floodplain
The economic benefit, preservation of existing tax base and the protection of public health are clearly at risk with the development of this site.
Let it be a much needed near downtown park, when it floods, and it will flood, it protects, and hose it off and let it go back to being a Greenway Park Space.
Dr Larissa Larsen an Associate Professor in the School of Architecture and Planning U of M stated clearly as her first comment at the AA-Sponsored Climate Discussions a few years ago, 'first don't build in the floodplain' which the ACWG would completely agree.
Link - Recent MLive Article on the proposed development
One Potential Effect of Floodplain/Floodway Buildings, Drownings
Versailles Condos in Hudson Ohio (ACWG TEB)
Two people died in 2003 in Versailles Condos in Hudson Ohio, just south of Cleveland, built in the floodplain with parking below the building.
A 100 year (1% chance) hit. While one man was trying to get his car out of a lower parking area another tried to help him and both drowned.
We have many videos from Ann Arbor on YouTube showing people trying to get cars out of parking areas in the floodplain/floodway, some below buildings, out of the floodwaters with great danger.
With the effects of Global Warming, even homes outside the floodplain can be at risk, especially if you have poorly calibrated maps and have new development in the existing floodplain and potentially real floodway, like unfortunately, we have here in Ann Arbor.
Like in Hudson Ohio, most folks do not realize they are living or parking their car in a floodplain/floodway till it floods and it is too late.
August 2018; No Meeting this Month due to Vacation and Travel Schedules
Watershed Issues of Interest and Updates:
Danaher/Pall/Gelman 1,4-Dioxane Plume - MDEQ Agrees to do Additional Spot NSG Tests on Westside Early This Fall, But We Need a Plan
UPDATE: Mayor not Aware
The ACWG was at the Green Fair SRSW/CARD/ACWG Table on June 8th this summer when the Mayor stopped to discuss the Gelman Plume. When asked he said he was not aware of the over-year-long issue with the DEQ in getting any Near-Surface Groundwater tests and a plan in place. We would hope our city leaders were more aware of these issues and stepping up to help resolve them. He did not stay long and did not offer to lend support in this effort. We hope this changes.
Changes in city council members in this last election may lead to a much better response to this contamination crisis facing the community.
Well Graphs with Logs Near West Park Area (GEA; See details ACWG April 19, 2018 entry; Click for larger image)
At the last DEQ and Coalition for Action on Remediation of Dioxane (CARD) meeting August 7th the CARD Group again asked the DEQ to work up a plan to monitor Near-Surface Groundwater (NSG) tests and monitoring.
The homes and businesses on the city west side should not be left in the dark as to the potential or actual exposures to their homes and businesses. In 2017 the CARD Group ask for this and we are still waiting for details of this program for monitoring.
The MDEQ has said they will do additional NSGs in similar and the same locations a previously including West Park and 8th Street in early fall. These are spot checks and do not include, as of this last meeting, permanent NSG wells.
Dan Bicknell and CARD have commented, as shown in our 5-19-18 entry, the reasons for NSG monitoring and danger to the community. This is not what Judge Shelton had in mind when he instituted a Prohibition Zone (PZ) to comply with the very weak MI Part 201regulations, to prevent exposure to the compound, without the need to do a cleanup of the compound.
No report on Danaher NSG sampling at the Gelman Site shown in Google aerial photos (as shown in 1-18-18 entry), not disclosed to CARD by Danaher. These were found by chance by Roger Rayle on Google Earth and now are not visible online.
The ACWG and CARD Groups have real concern for the potential for Vapor Intrusion (VI) and other exposures with NSG. The state has a new standard for Groundwater to Surface Water Interface (GSI) at 280 ppb (GW flows into creeks and the river) yet the standard for action level for VI near homes is 1,900 ppb. 280 ppb for the river but 1,900 for homes seems hard to explain.
Also, Sump Pumps can pose a real issue if up to 1,900 ppb is allowed near homes with sump pumps pumping contaminated groundwater into the city rainwater overflow (stormwater) system, they will be in violation of the 280 ppb GSI. No comment from the DEQ on this issue at the last CARD meeting.
We need a plan of action on the NSG exposure potential, not simply more tests. Dan Bicknell's GEA Comments on the DEQ Shallow Groundwater Work Plan and his proposed plan is posted in the November 2016 Agenda. Dan had a very well and logical plan laid out for dealing with the initial investigation of the NSG issue which seems to be clearly a problem that needs addressing.
The ACWG and CARD Groups has asked for permanent monitoring of NSG wells on the near west side of the city.
Links: Michigan Department of Environmental Quality (MDEQ)-Gelman Project Site; Washtenaw County CARD Site; Scio Residents for Safe Water (SRSW)
YouTube of CARD/DEQ Quarterly Meeting August 7, 2018, by Roger Rayle Chair of CARD (https://www.youtube.com/watch?v=cujtejRg2q0&t=2710s)
Lots of stores by Ryan Stanton in Ann Arbor News/MLive including this recent article 'EPA holding off on Superfund designation for Gelman dioxane plume'
Lots of details from Barbara Lucus at Dioxane.Org and WEMU News Program GreenRoom
See ACWG site pages EPA Superfund Option Details
Click here to view and/or sign in support of Superfund Designation
Recent Discussions of Development of Polluted DTE Site at Depot St and Broadway St In the FW FP
Update: On Sept. 5th at a developer public meeting at the Smith Group JJR offices, I asked the developer if the groundwater has been tested. I was told is was and it is contaminated. I also asked if the groundwater was tested to see if it is moving off site. They said it is not moving off site. As this site is the location of the old Huron River bed (see below) it is very likely to have a very high water table that could be getting contaminated.
Then will ask for about $24M Brownfield and pay about $12M of their own funds for a cleanup 'where needed'.
I asked about the LOMR they are seeking and if they are including the berm opening in the modeling, and they are not. I also commented on the effects of Global Warming and that also needs to be included in the modeling, and they did not comment on that.
I also commented on the issue of Vapor Intrusion (VI) on this site if not fully cleaned up, into the new structures. Michigan has now move to include VI in its site evaluations. In Petoskey the DEQ has evacuated 11 condos, built about 5 years ago on top of an old brownfield site, due to VI and potential mitigation requirements.
City Web Image of FW FP of Proposed Mixed Use Development (ACWG)
Coal Tar found and shown by DEQ at river's edge at the site, subsequently cleaned up in recent years (WUOM, Click for larger images)
There was a developer lead public meeting on 8-8-18 to discuss the proposed Mixed Use Development on the DTE site near Depot St. and Broadway St.
The developer stated that they are seeking changes in the floodplain floodway map of the site through a Letter Of Map Revision FEMA (LoMR) with their consultants Smith Group. This seems like a not a sure thing, and if not plans will need to be changed.
The site is mainly floodway (FW) not floodplain (FP) as was stated at the meeting. A HUGE difference. FW is where floodwater is flowing, very dangerous.
Note that Smith Group was the same group that erroneously told the city and Allen's Creek Watershed Group that the 1992 FEMA map was made with 1992 data when in fact, verified by DEQ and FEMA, it was 1968 data (big 100-year flood data) during the New Homeless Shelter planning and public meetings. The city "leaders" chose to ignore this erroneous statement.
As shown below the site is in the old River Bed of the Huron River which was moved for a Coal Gasification Plant on the site. Having a dump site in the old river bed is not logical.
Also, Smith Group and city were forced to redo the Shelter plan as the ACWG and a resident hired consultant showed it was in the floodway, not legal. A $1M mistake and, threat to life and health.
They moved the shelter up the hill, still in the FP with some emergency exits into the FW (where floodwaters would be flowing, floodway), a very bad plan.
Smith Group is now in the Depot St. Fst Martin building in the floodplain where they are flooded often and cars destroyed in the below building parking/flooding area. See YouTube videos for many videos of flooded cars that are NSFW with lots of $%$&, Ann Arbor - not in a good light.
If the FP map does not change this plan will have big changes or not be done at all, as major parts are in the current FW.
Globel Warming is not considered by them to be an issue, even with more flooding for SEM by all reasonable accounts.
They are not proposing a cleanup from what I heard, even when I asked direct questions they were vague.
The site is very polluted and in the old river bed as shown by their own presentation photos (also shown in photo below), with a very high water table would be very likely if not certain.
Vapor Intrusion is a real issue being faced by many sites which were built over old dump sites. In Petoskey MI recently 11 of 14 condos were evacuated due to VI issues from building in an old dump site.
I commented this site is a disgrace to potentially be polluting the river and groundwater without real tests and city officials have looked the other way for too long.
The pollution maps produced by DTE and the city are not accurate. At the Allen's Creek Outlet on the west side of the site clearly there are significant black coal tar deposits visible with the sheet pile was installed, all the way down as far as they dug. This is not at all on the pollution maps.
DTE is the Responsible Party (RP), as I commented, and should clean up the site. To which they, seemed to me, to be very clear DTE did not plan to do a cleanup.
They hinted they will work to get a Brown Field: the public would pay the cost of cleanup.
We need to require them to do testing of the GW and river to finally get a full cleanup of this site.
We could petition EPA for Superfund if they are not willing to deal with this polluted site in our Huron River.
They commented about all the meetings on this with city stakeholder groups, but not with the ACWG or SCHVG, for some reason.
The city RR Track berm opening just upstream, coming next year, will add more floodwaters to this site than historically and currently as the berm acts like a dam holding back water and flooding many homes upstream. This is not considered it would seem.
If done right could be a nice park close to the city center. When it floods hose it off and go back to being a park like many progressive (and non-progressive) cities are doing with floodplain flood-prone areas.
Shots of the presentation projected screenshots "changeable site plan", that were not distributed:
Draft Proposal (Photos and Annotations ACWG)
Old Image showing DTE is in the Old River Bed
(AADL Holdings; Click for larger images)
Exposure to coal tar or coal-tar pitch is associated with an increased risk of skin cancer. Other types of cancer, including lung, bladder, kidney, and digestive tract cancer, have also been linked to occupational exposure to coal tar and coal-tar pitch.*
City of Ann Arbor Purchases Twelve New Sewer Flow Gauges as Part of the Sanitary Manhole Rehabilitation Project
Example of a Smart Wireless Flow Gauge (Civil + Structural Engineer Magazine)
City staff have recently communicated to ACWG that they now have purchased 12 of our own sewer flow gauges on July 30. 2018, see message below.
As commented here before the ACWG has been advocating for Smart Sewers for years. We sited in our May 17, 2018 Agenda, and posted on our site, an NPR national story on how effective they can be and at low cost in a city similar to size as Ann Arbor.
As noted in an NPR May 8, 2018 report "These Smart Sewers Are Part Of A Growing Trend Connecting Infrastructure To The Internet" and, in South Bend Indiana "According to city officials, the sensors save the city a ton of money, more than $500 million."
The city and county over the years have paid to install temporary gauging for many studies, at great expense, many cases in the recent past at close to $10K each, then they are removed. This is for both sanitary and stormwater flows.
With permanent gauges will save money, and changes in development could have more accurate predictions of flood potential with proposed added flows. Additionally, the data would be invaluable in modeling efforts to show the most 'bang for the buck' in our city and county sanitary and stormwater upgrade planning and upgrades to the floodplain map.
From Nick Hutchinson, P.E. City Engineer - Public Services Area - Engineering, July 30. 2018:
'Construction will be starting soon on the Sanitary Manhole Rehabilitation Project, which will install gasketed manhole covers and make other manhole repairs with the aim reducing infiltration into the Sanitary Sewer system. The project will work on approximately 300 manholes in flood-prone areas throughout the City. Construction costs for the project are approximately $1.08 million, and it will be funded from money collected from the Developer Offset Mitigation Program.
A revision to “Table A” of the design flow rates is about to be issues. This is a little down into the weeds, technically speaking, but it was one of the recommendations that came out of the SSWWE Report.
Of the 6 project areas identified in the SSWWE Report – Preliminary engineering is complete (or near complete) for 4 of the areas. Final design/construction will be programmed for these project into Capital Improvements Plan this Fall. We are continuing to monitor (with flow meters) the final 2 areas (First/Miller and State/Hoover areas) which is necessary in order to understand what improvements are needed in these areas.
The City has purchased 12 of its own flow meters which we are currently being used to monitor the system in key locations.
The City is taking a proactive approach to managing the sanitary sewer collection system by developing an Asset Management Plan (AMP) which is anticipated to be completed at the end of this year.'
Beal Building at Kingsley St. Now Without Lock Down, Required Swing Up Flood Hazard Prevention Fencing
Beal Building Kingsley St. 07-29-18
(Removed Locks on Fencing, ACWG; Click for Larger Image)
City staff were notified and indicated to ACWG that the locks holding down the swing up flood hazard fencing have been removed as requested by staff, as now shown in the photo.
These fence under the elevated building were not to be locked down to prevent flood hazards for homes upstream do to a much higher floodplain as the locked down fencing would cause blockage to flows to the river.
Fencing clogs up quickly in a flood and acts like a cement wall in blocking flood water flow causing more unnecessary and dangerous flooding upstream.
This is the second time this has happened in recent years.
The first time the city was notified by the ACWG it took many months and an ACWG request to the MDEQ, and a special visit from the MDEQ, to force the city leadership to get the fences unlocked.
Clearly, there needs to be protections for upstream residents from unnecessary and dangerous flood hazard.
Not clear if a fine or other action was taken for this second egregious infraction.
PFAS Issues Discussed in Recent WEMU Issues of the Environment, July 25 2018
With Per- and Polyfluoroalkyl Substances (PFAS) (Toxic Teflon related compounds) found in our drinking water and now fish in the Huron River wanted to pass along a new source of information that may be of interest from PFAS toxicology scientist at UofM WEMU interview on PFAS from Professor Rita Loch Caruso PhD and her U of M SPH M-LEEaD Center
WEMU; Click for larger image
Environmental Health in Michigan:
Per- and Polyfluoroalkyl Substances (PFAS)
Wed July 25 2018
INTERVIEW: “Issues Of The Environment: PFAs Contamination Throughout Michigan
And In Washtenaw County” with Rita Loch-Caruso, PhD (SPH University of Michigan, Ann Arbor)
July 2018; No Meeting this Month due to Vacation and Travel Schedules
Watershed Issues of Interest:
Danaher/Pall/Gelman 1,4-Dioxane Plume - MDEQ Agrees to do Additional NSG Tests on Westside, But We Need a Plan
At the last Coalition for Action on Remediation of Dioxane (CARD) Meeting July 10th the MDEQ has said they will do additional Near-Surface Groundwater (NSG) tests in similar and the same locations a previously including West Park and 8th Street.
The ACWG and CARD Groups have real concern for the potential for Vapor Intrusion (VI) and other exposures with NSG. The state has a new standard for Groundwater to Surface Water Interface (GSI) at 280 ppb (GW flows into creeks and the river) yet the standard for action level for VI near homes is 1,900 ppb. 280 ppb for the river but 1,900 for homes seems hard to explain.
Also, Sump Pumps can pose a real issue if up to 1,900 ppb is allowed near homes with sump pumps pumping contaminated groundwater into the city rainwater overflow (stormwater) system, they will be in violation of the 280 ppb GSI. No comment from the DEQ on this issue at the last CARD meeting.
We need a plan of action on the NSG exposure potential, not simply more tests. Dan Bicknell's GEA Comments on the DEQ Shallow Groundwater Work Plan and his proposed plan is posted in the November 2016 Agenda. Dan had a very well and logical plan laid out for dealing with the initial investigation of the NSG issue which seems to be clearly a problem that needs addressing.
The ACWG and CARD Groups has asked for permanent monitoring of NSG wells on the near west side of the city.
Links: Michigan Department of Environmental Quality (MDEQ)-Gelman Project Site; Washtenaw County CARD Site; Scio Residents for Safe Water (SRSW)
YouTube Video of the CARD Meeting 5-1-18, by Roger Rayle (https://www.youtube.com/watch?v=C9g7_I1xqrg&t=31s)
Lots of stores by Ryan Stanton in Ann Arbor News/MLive including this recent article 'EPA holding off on Superfund designation for Gelman dioxane plume'
Lots of details from Barbara Lucus at Dioxane.Org and WEMU News Program GreenRoom
See ACWG site pages EPA Superfund Option Details
Click here to view and/or sign in support of Superfund Designation
Beal Building at Kingsley St. Again Found with Lock Down Swing Up Flood Hazard Prevention Fencing by ACWG
Beal Building Kingsley St. 6-10-2018 (Click for larger image)
(Some of the Removed Locks circled, ACWG; Right Click for Larger Image)
City staff were notified and indicated to ACWG that the locks holding down the swing up flood hazard fencing have been removed quickly as requested by staff.
These fences under the elevated building were not to be locked down to prevent flood hazards for homes upstream due to a much higher floodplain, as the locked down fencing would cause blockage to flows to the river.
Fencing clogs up quickly in a flood and acts like a cement wall in blocking flood water flow, causing more unnecessary and dangerous flooding upstream.
This is the second time this has happened in recent years.
The first time the city was notified by the ACWG it took 1 1/2 years and an ACWG request to the MDEQ, and a special visit from the MDEQ, to force the city leadership to get the fences unlocked.
Clearly, there needs to be protections for upstream residents from unnecessary and dangerous flood hazard.
Not clear if a fine or other action was taken for this second egregious infraction.
Great Lakes Now: Michigan’s Upper Peninsula 1,000 Year Storm (.1% chance): “the new normal”
MLive - UP 1,000 Year Rain (click for larger image)
On June 17 a historic 1,000 Year Storm (.1% chance) brought up to 10 inches of rain on portions of the MI UP causing millions of dollars in damage.
Scientists now say this is the 'New Normal' with Globel Warming effects on Michigan.
'Scientist says many in area lack a “sense of urgency”
Is the extreme weather that wreaked havoc on parts of Michigan’s Upper Peninsula this week a storm event that can be set aside as an aberration?
[MTI Professor of Environmental History Nancy] Langston told Great Lakes Now that following similar historic storm events in 2012 and 2016, the 2018 version “should be considered the new normal.”
Michigan Tech’s Langston says she is worried about the slow pace of planning for a future where extreme weather is the new normal. '
More Extreme Precipitation Events Great Lakes Region:
Great Lakes Integrated Sciences + Assessments (GLISA; Ann Arbor, MI):
'There are several possible causes for the observed increase in extreme precipitation events over the last century. Perhaps the most prominent hypothesis is that rising global surface temperatures have increased evaporation and added water vapor to the atmosphere. With more heat and more moisture, two of the key ingredients for storm development are now more abundant, leading to an increase in extreme precipitation.
[In the Great Lakes Region] Precipitation falling during heavy, multi-day wet periods has also increased dramatically.
The observed increased in heavy rain events across the region is already contributing to more storm water management problems.'
GLISA - 440 Church Street, Dana Building, Ann Arbor, MI; GLISA is a partnership between the University of Michigan and Michigan State University, housed in the University of Michigan School for Environment and Sustainability (SEAS).
Great Lake Now - https://www.greatlakesnow.org/2018/06/michigans-upper-peninsula-storm-the-new-normal/
MLive - https://www.mlive.com/news/index.ssf/2018/06/photos_show_michigans_up_devas.html
Great Lakes Integrated Sciences + Assessments
VOTE on August 7th Primary Elections For ACWG, Sierra Club Endorsed and, Environmentally and Watershed Friendly Candidates
Please VOTE Aug 7th
The ACWG has endorsed Jack Eaton for Mayor, he also is endorsed by the Sierra Club Michigan Chapter and Sierra Club Huron Valley Group
Other Watershed friendly candidates also include:
Jeff Hayner for Ward 1 endorsed by the Sierra Club Michigan Chapter and Sierra Club Huron Valley Group
Kathy Griswold for Ward 2 endorsed by the Sierra Club Michigan Chapter and Sierra Club Huron Valley Group
Alice Liberson for Ward 3 endorsed by the Sierra Club Michigan Chapter and Sierra Club Huron Valley Group
Elizabeth Nelson for Ward 4 endorsed by the Sierra Club Michigan Chapter and Sierra Club Huron Valley Group
Jeff Irwin for State Senate endorsed by the Sierra Club Michigan Chapter and Sierra Club Huron Valley Group
Yousef Rabhi for State House endorsed by the Sierra Club Michigan Chapter and Sierra Club Huron Valley Group
Proposed Agenda and Updates:
June 21, 2018
Danaher/Pall/Gelman 1,4-Dioxane - EPA Meeting May 17 Error in Invitations Omits Many Critical Stakeholders
US EPA Region 5 had a stakeholder meeting in Scio Township on May 17 to discuss the Danaher/Pall/Gelman 1,4 Dioxane plume, but many critical stakeholders were not invited.
Major stakeholders were not effectively notified or invited to attend and make comment on the current and past progress, or lack thereof, in the testing and cleanup of the groundwater contamination.
Members of the EPA Superfund petitioners Sierra Club Huron Valley Group, Coalition for Action on Remediation of Dioxane (CARD) board members and others were not given effective or any notice.
I find this unacceptable and contrary to any public engagement effort of this magnitude.
It is most unfortunate we have a, questionably legal, "Public Officials' Self-imposed Confidentially Agreement" among some of the critical stakeholders and in addition this restricted access to public meetings.
Michael Berkoff (EPA Region 5) who is watching this site for EPA has emailed that there was a mixup and he had hoped all interested parties would attend like the last meeting with the EPA.
He writes '... moving forward is that the invitation list is at least as broad as that December meeting. I would be happy to work with everyone on finding the appropriate venue for EPA’s participation. Whatever that will be, the invitation list will be open to all interested stakeholders.'
Unfortunately, Gelman and MDEQ are still dragging their feet on Near-Surface Groundwater (NSG) monitoring. Permanent wells are needed to monitor this exposure potential. Just 11 blocks from the NSG values of 4 to 2 ppb in 3 tests at West Park and 8th Stree Vet's Park is over 1,000 ppb. The DEQ was not forthcoming in doing NSG tests and needed extensive pressure for ACWG and CARD.
Contingency plans for drinking water well contamination in Scio Twp. is also, still not being addressed, this with some wells in Scio Twp. now up to 4 ppb with the new MI drinking water standard at 7.2 ppb.
Roger Rayle's Youtube Video of te last CARD June 5th meeting where this was discussed - https://www.youtube.com/watch?v=Hc5DViq6Flc&t=657s
Links: Michigan Department of Environmental Quality (MDEQ)-Gelman Project Site; Washtenaw County CARD Site; Scio Residents for Safe Water (SRSW)
YouTube Video of the CARD Meeting 5-1-18, by Roger Rayle (https://www.youtube.com/watch?v=C9g7_I1xqrg&t=31s)
Lots of stores by Ryan Stanton in Ann Arbor News/MLive including this recent article 'EPA holding off on Superfund designation for Gelman dioxane plume'
See ACWG site pages EPA Superfund Option Details
Click here to view and/or sign in support of Superfund Designation
2018 Ann Arbor Green Fair - SRSW, CARD, ACWG Staffed a Table
Rita and Shana at the Table at 2018 Green Fair Table (Click or Right Click for Larger Image; ACWG)
Lots of folks stopped by and asked a lot of questions, and signed up to be on the CARD email list. Roger Rayle (Scio Residents for Safe Water - SRSW, CARD), Rita Loch Caruso (UM SPH, CARD, ACWG), Shana Milkie (CARD) and I were staffing the table again this year.
Many folks still are surprised this plume is still growing and a cleanup is not taking place, just a containment effort to let it flow to the Huron River.
Two women in front of the table facing the camera were some of the organizers for the UM SEAS Galaxy 2018 1,4 Dioxane Cherrette who invited Rita, Roger and I, among a few others, to be experts the same weekend of the Green Fair. Expecting more results and videos from this Cherrette in weeks to come.
Visit to the Atlanta BeltLine Greenway - More Successful than Anyone Though in Just a Few Years
Atlanta BeltLine Spring 2018 (Click or Right Click for Larger Image; ACWG)
In a visit to the Atlanta BeltLine Greenway in the spring of this year, it was clear it has turned a rundown part of Atlanta into a major gathering place for residents and visitors. Even with it only about 50% complete it has huge numbers of walkers and bikers using it daily.
Stores along the BeltLine are opening main entrances in the former back of the store for BeltLine folks. Large numbers of new stores are opening in renovated and new buildings along the BeltLine. Many of these stores were very crowded on this Saturday in the spring.
Folks are walking and biking to downtown Atlanta for work and play just off the BeltLine which is planned to circle the city when finished. A major center of Atlanta is only a few blocks from the BeltLine.
Property along the BeltLine has gone up in value and, new apartments and condo buildings are being built.
Much like the potential Allen's Creek Greenway/Tree Line, this could be a very similar outcome for Ann Arbor, an economic, environmental and social success.
In discussion with a BeltLine planner consultant working in Ann Arbor on Protected Bike Lanes and improved streets currently, she said they are working to preserve affordable housing along the western side of the Beltline with a tax freeze program for eligible apartment buildings and homes. This is an issue facing Ann Arbor with gentrification as the Greenway develops.
Link: Atlanta BeltLine // Where Atlanta Comes Together.
Link: Ann Arbor Tree Line Link to Master Plan
Proposed Agenda and Updates:
April 19, 2018
Danaher/Pall/Gelman 1,4-Dioxane Comments Regarding Recent Quarterly Report From MDEQ
Below is Dan Bicknell's Comments to the EPA and DEQ in response to the last Gelman Quarterly Report issued by MDEQ March 2018.
Dan has been working with the Scio Twp, Ann Arbor Twp and Sierra Club Huron Valley Group on an EPA Superfund Petition for the Gelman Plume.
The ACWG supports these comments and suggestions, and would like the EPA to evaluate and suggest remedies or most preferably to take over the full cleanup of the site to its original status before Gelman started using the site. EPA unlike the state of Michigan will do a full cleanup if it is designated an EPA Superfund Site and force the Responsible Party to cover the cost.
Daniel J. Bicknell, MPH
President
Global Environment Alliance, LLC
geallc.org
Dan's Excerpted Comment to EPA's Michael Berkoff, Remedial Project Manager, Superfund Division, EPA Region 5:
Residential Well Sampling and Future Residential Well Sampling.
There was no DEQ discussion to address the current and future contamination of residential wells. At the November 2017 Stakeholder Meeting, State Representatives discussed the requirement to get ahead of the expanding dioxane plume towards Scio Township residential wells, including establishing a strategy to provide safe drinking water to residential wells which become contaminated above the dioxane drinking water criteria. As there are currently residential wells contaminated with dioxane outside of any future planned municipal potable water system and the dioxane plume is moving towards numerous other residential wells, it is only prudent to prepare contingency plans to provide a safe water supply to wells which will become contaminated under the current DEQ dilution remedy.
Additionally, the community has long requested that the DEQ analyze residential drinking water wells with the most reliable and sensitive analytical method – Method 522 which has a detection level of approximately 0.07 ug/L dioxane, for example see CARD Response Letter to PALL Life Sciences Corporation & Michigan Department of Environmental Protection Dioxane Analytical Methods – June 2015. The normal analytical method used by the DEQ laboratory has a dioxane detection limit of approximately 1 ug/L. Method 522 is the preferred USEPA analytical method for dioxane in residential well water. By using Method 522 for residential drinking water well dioxane analysis: the public and agencies will have better tracking of the dioxane plume path; allow residences to protect themselves from any exposure to dioxane; and assist in the forward planning of an alternant water supply system.
Monitoring Well Sampling. There is no DEQ discuss about the adequacy of the current Monitoring Well Network. In February 2015, Gelman provided DEQ with a formal document requesting modification to the Groundwater Monitoring Program, which included the reduction in many monitoring well sampling frequencies. CARD reviewed the Gelman document and provided to DEQ a formal response, which was provided recently to USEPA - CARD Response Letter to PALL Life Sciences Corporation – Groundwater Monitoring Program February 2015 – May 2015. The CARD Response Letter included a comprehensive monitoring well strategy with locations of new monitoring wells to address the current Monitoring Well Network deficiencies. DEQ has never provided a formal response to the Gelman or CARD technical documents. As presented in the Petition Requesting a Preliminary Assessment – Supplemental Information Document, the current Monitoring Well Network deficiencies include: having northern Boundary Well MW-129 cover a 0.375 mile distance immediately up-gradient of potentially impacted Scio Township residential wells, see below figure; and allowing the distance between the key northern Boundary Monitoring Wells MW-120 and MW-135 to be approximately one mile. Currently, DEQ is using Elizabeth Road residential wells to track the dioxane plume which has gone past the last northwestern monitoring wells MW-133 and MW-121, see below figure. Clearly, additional monitoring wells are required to track the extent and magnitude of the dioxane plume.
Current Remediation Activities. There is no discussion on the effectiveness of the limited groundwater extraction to contain the dioxane plume or eliminate the source of the dioxane plume; only information on how much groundwater is extracted over the reporting period. There is no discussion of the fact that the remedy allows the dioxane plume to migrate in all directions under what DEQ has described in City and County public meetings as a “dilution/dispersion” remedy. The reporting period data demonstrate that the source area plume continues to expand off of the Former Gelman Property and the outer margins of the plume are dispersing in all directions.
Surface Water and Sewer Sampling. The DEQ Report only provides data generated over the reporting period. There is no discussion on what the data show. For example, the Allen Creek Drain December 2017 water sample from the southwest corner of West Park detected 4.4 ug/L of dioxane. This is the same sensitive heavily populated Old West Side area where DEQ found in 2016 that the shallow groundwater ranged from 1.9 ug/L to 3.3 ug/L dioxane. These DEQ storm sewer results near West Park indicate that the Gelman dioxane shallow plume may be at a higher concentration than found in the past 2016 DEQ / Gelman temporary soil boring work. There needs to be a full extent and magnitude of dioxane contamination investigation done in the shallow groundwater about the Old West Side of Ann Arbor /West Park Area. The receptors include construction and utility workers and residents in buildings. The Virginia Department of Environmental Quality has established an approximately 80 ug/L dioxane criterion protective of a worker in a trench in contact with shallow groundwater. USEPA Headquarters Staff has referenced this Virginia DEQ value, as there is no USEPA or Michigan DEQ criterion protective of a worker in a trench route of exposure. It should be noted that any dioxane contaminated shallow groundwater infiltrating the Allen Creek Drain would be diluted by storm water, therefore, the surrounding dioxane contaminated shallow groundwater is likely significantly higher than the detected 4.4 ug/l dioxane in the storm water.
Stakeholder Issues
Risks posed by soil and sediment contaminated with dioxane stemming from the Former Gelman Plant. DEQ indicates that Gelman has collected additional soil and groundwater samples at the Former Gelman Plant and will provide a report to DEQ in the future. There is no mention by the DEQ that the Former Gelman Plant property is undergoing significant changes, including the construction of a large church on the property, thereby, creating exposure pathways to construction workers and church attendees not covered in the current risk evaluation. As presented by the Petitioner in the August 2017 document – Current & Future Routes of Exposure to the Gelman Sciences, Inc. Site Dioxane Contamination, inhalation is the most common route of human exposure to dioxane and dioxane readily evaporates from soil. The USEPA Regional Screening Level (RSL) for a worker exposure to soil is 24 mg/kg dioxane based primarily on an inhalation risk. There is no DEQ established dioxane criterion for worker soil exposure covering all relevant routes of exposure. As the USEPA Preliminary Assessment identified, there is a very large data gap in what is the concentration of dioxane in the residual soils due to a lack of recent on-site soil data. The older, but most recent, available on-site soil data show that the dioxane soil concentrations ranged over 1,000 mg/kg. The receptors at the site are changing and require a more detailed risk study which has not been done by DEQ or Gelman.
Clearly define the groundwater migration pathways and how does the past data characterize the deep aquifer plume. In response to this question, DEQ simply refers USEPA to “numerous reports on file”. There is no DEQ discussion on whether it agrees with the Gelman groundwater report conclusions on file; nor what the DEQ view on the groundwater migration pathways are for the dioxane plume. There is no groundwater model for the dioxane plume. As part of the DEQ oversight of Gelman and the CJ, DEQ needs independently to evaluate the dioxane plume migration.
In the DEQ referenced reports, Gelman has been continually incorrect on what is the direction of the dioxane plume migration.
· Gelman stated in the Gelman 2007 Phase 2 Report that “The predicted pathway of the plume is well within the existing Prohibition Zone”, which was wrong causing the loss of numerous Evergreen Area domestic water wells. A northern Expanded Prohibition Zone was created in March 2011.
· Gelman stated that the dioxane plume would not move beyond the southern PZ boundary; which was wrong. The plume is beyond the southern boundary and has contaminated the City Northwest Supply Well.
· Gelman stated that the Ann Arbor Cleaning Supply Well western area would not have dioxane above 85 ug/L past April 2014, which was wrong. This quarter’s data show the concentration above 85 ug/L dioxane.
The reporting period groundwater quality data show that both the deep and shallow portions of the glacial till aquifer are migrating in most every direction unabated by the limited groundwater extraction. This includes flowing towards Scio Township residential wells along Elizabeth Road and Rose Drive.
The Ann Arbor Cleaning Supply Well data collected during the reporting period show an increasing concentration above 85 ug/L dioxane, which may indicate a continued migration from the Former Gelman Plant source area. Over the past few years, Gelman has significantly reduced groundwater extraction rates at the Former Gelman Plant property.
Concerns that analysis of the plume at 465 DuPont may not adequately characterize the behavior of the plume. DEQ response to USEPA on this item is “Again, there are multiple reports on file…” and DEQ has asked Gelman to provide a summary on investigations in this area. There is no DEQ review and evaluation of this very important matter. Despite Gelman past claims that the plume in this area is not moving to the northwest towards Scio Township wells, all of the data show that the dioxane plume is migrating to the Scio Township wells and has already reached the homes along Elizabeth Road. The below figures show the concentrations of the dioxane plume, the high dioxane concentration at and about 465 DuPont Circle, and the PLS/Gelman isoconcentration plot showing a strong northwest flow component towards Scio Township residential wells. As readily evident by the existing concentrations of dioxane in monitoring wells and residential wells, the dioxane is moving at high concentrations towards residential wells in Scio Township. As part of the DEQ oversight of the CJ and Gelman technical work, DEQ must conduct an independent review of where the dioxane plume is going and the likely receptors impacted by the plume migration.
Dioxane contamination in near surface groundwater can pose a risk through exposure pathways other than drinking water. Status of shallow groundwater sampling and characterization. The DEQ response summarizes the Shallow Groundwater Investigation Report prepared by Gelman in 2016 on the shallow groundwater study which installed temporary soil borings. This work included borings about the Old West Side of Ann Arbor. Dioxane was detected in the Old West Side shallow groundwater in two borings ranging from 1.9 ug/L to 3.3 ug/L. DEQ compares these results to: the proposed DEQ 1,900 ug/L dioxane building vapor intrusion screening level; the USEPA Regional Screening Level of 4.6 ug/L dioxane; the USEPA RSL of 11 ug/L for inhalation of groundwater protection; and USEPA RSL of 2,300 ug/L for skin contact. Based upon comparison to these criteria, DEQ concludes that no further investigation is required at this time of the shallow groundwater about the Old West Side.
As detailed in the CARD Response Letter to Michigan Department of Environmental Quality Emergency Rules on Dioxane Criteria & Vapor Intrusion Follow-up Work – July 26, 2017 and Gelman Report – Gelman Sciences, Inc. - GEA Comments on DEQ Shallow Groundwater Work Plan & Report to Support a Building Vapor Intrusion Evaluation – October 2016, which were recently provided to USEPA, the deficiencies in DEQ Shallow Groundwater Work Plan and results of the Gelman work demonstrate that there is shallow groundwater dioxane contamination in the Old West Side area but the extent and magnitude of the contamination is not known. What is known is that the samples collected by Gelman from the lower topographic areas detected dioxane in the shallow groundwater, but samples from the upper topographic locations did not find dioxane. Further study in the lower topographic areas is required to identify the area and concentration of the dioxane contamination in the shallow groundwater about the Old West Side of Ann Arbor. The dioxane concentrations in the shallow dioxane plume about the Old West Side are likely higher than the 1.9 ug/L to 3.3 ug/L range observed in the rudimentary Gelman 2016 soil boring work.
Concerning the comparison criteria used by the DEQ, DEQ is applying a building vapor intrusion criterion which has not been established by DEQ. DEQ references an existing USEPA RSL of 4.6 ug/L for dioxane, which is near the 1.9 ug/L dioxane and 3.3 ug/L dioxane values observed in the 2016 Gelman work. The fact that the DEQ Work Plan study was designed to gather only preliminary results using only a handful of soil borings in the Old West Side and that the results are close to the USEPA RSL criterion referenced by DEQ, lead to the reasonable conclusion that a permanent monitoring well network to identify up-gradient and down-gradient dioxane contamination in the shallow groundwater about the Old West Side is required to ensure the protection of the public health. The historical dioxane shallow plume 2,800 feet up-gradient of the Old West Side demonstrates that significant dioxane contamination is moving into the Old West Side/West Park neighborhood shallow groundwater, see below figures.
At recent public meetings, the DEQ has stated that no further shallow groundwater investigation is required in the Old West Side, because seep and pond data do not show elevated levels above applicable groundwater criteria and these surface water data are “representative” of shallow groundwater quality. The DEQ position that Old West Side surface water samples have the same dioxane concentration as local shallow groundwater is without technical merit. Groundwater monitoring wells are required to determine the extent and magnitude of the shallow dioxane plume.
Potential risks posed to construction workers by contaminated shallow groundwater within the prohibition zone. The shallow groundwater impacted with dioxane about the Old West Side presents a complete exposure pathway to construction and utility workers who contact the dioxane contaminated shallow groundwater. In response to the question, DEQ acknowledges the existing dioxane shallow groundwater contamination found in the 2016 Gelman work, but then compares the observed values to a DEQ Groundwater Contact Criteria (GCC) of 1,700,000 ug/l dioxane which was eliminated from use by the DEQ in 2013. This GCC was based upon an outdated dioxane toxicity constant (as was the recently replaced DEQ dioxane drinking water criterion) and an exposure equation and factors which were technically flawed. The Virginia DEQ has established an approximately 80 ug/L dioxane criterion protective of a worker in a trench in contact with shallow groundwater. This Virginia DEQ criterion includes all the relevant routes of exposure, such as dermal contact, inhalation, inadvertent ingestion, etc. USEPA Headquarters Staff has referenced this Virginia DEQ value, as there is no USEPA or Michigan DEQ criterion protective of a worker in a trench route of exposure.
A permanent monitoring well network, which can be sampled routinely to track the dioxane plume, needs to be established to determine the extent and magnitude of the shallow groundwater quality about the Old West Side, thereby, protecting residences from dioxane build vapor intrusion and construction/utility workers from exposure to dioxane contaminated shallow groundwater.
Provide the status of the risk evaluation posed by the Groundwater to Surface Water (GSI) pathway. While this issue relates mainly to surface water impacts, DEQ does not discuss the risks posed by misapplying the GSI to this site. The CJ applies a remedial criterion of 2,800 ug/L dioxane east of Wagner Road based upon the DEQ dioxane Groundwater-Surface Water Interface (GSI) value of 2,800 ug/L. However, a GSI is intended to be used only in situations where the plume is immediately next to a water body and there are no receptors between the contaminant plume and the water body, which is not the case with the Gelman Site, see below DEQ generic GSI figure. For the Gelman Site, there are sensitive exposure receptors between the dioxane groundwater plume and the Huron River. These receptors include: residential flooded basement exposure; residential and commercial building vapor intrusion exposure from the volatilization of dioxane contaminated shallow groundwater and subsurface contaminated soil; construction and utility worker exposure to contaminated shallow groundwater; and residential well drinking water exposure at Ann Arbor Charter Township homes west of the Huron River. This misapplication of the GSI creates the situation where a dioxane plume of up to 2,800 ug/L can migrate freely towards sensitive receptors before reaching the Huron River, see below figure with Ann Arbor Charter Township wells. The misuse of the GSI criterion creates potential adverse risks to the public health and needs to be replaced by a Drinking Water criterion.
Other issues not covered in the DEQ Quarterly Report
Gelman violation of Consent Judgment (CJ) terms and conditions.
The CJ has numerous technical requirements to ensure the protection of public health and compliance with the CJ remedy. DEQ did not discuss Gelman compliance with the CJ terms and conditions. Over this reporting period, Gelman had CJ violations of trigger levels requiring additional work and investigation (e.g., exceedances of Ann Arbor Cleaning Supply Well triggers, boundary well trigger exceedances, etc). The CARD Response Letter to April 17, 2014 Michigan Department of Environmental Quality Letter to PALL Life Sciences Corporation – Conceptual Site Model About the MW-103 Area – March 21, 2016 details the exceedance of southern boundary CJ requirements for further site investigation which has not been done by Gelman, thereby, violating the CJ. The Ann Arbor Cleaning Supply Well was above the CJ 85 ug/L dioxane trigger level in this reporting period, thereby, requiring addition groundwater extraction to contain the plume, but Gelman has taken no action.
DEQ did not review Gelman compliance with CJ objectives and criteria or compliance with CJ Verification Plans, Monitoring Plans or Down-gradient Investigations. Based upon this reporting period data, Gelman is not in compliance with Down-gradient Investigations.
As part of the DEQ Quarterly Report to USEPA, DEQ should discuss Gelman compliance with the CJ technical terms and conditions, including attaining CJ objectives.
WUOM Environment Report Today: Michigan Part 201 Partial Cleanups Like Zombies Rising Up
Like the Gelman Plume partial cleanups are not good enough and the state with the largest freshwater resource in the world is not doing its job.
"In 1994, Michigan OK’d partial pollution cleanups. Now we have 2,000 contaminated sites.
What’s kind of a like a zombie rising from the grave is these buried contaminants that are now showing up in people’s homes, in their air, specifically. That was not envisioned by the science at the time; if you left chemicals in the ground they could actually migrate up through even impervious surfaces and affect people’s health.
Dempsey is talking about a phenomenon called vapor intrusion. That’s when contamination underground seeps into buildings through the air.
Like time bombs left in the ground."
Link: http://michiganradio.org/post/1994-michigan-ok-d-partial-pollution-cleanups-now-we-have-2000-contaminated-sites
March 2018; No Meeting this month due to Illness
Pall/Gelman/Danaher 1,4-Dioxane: Sierra Club Huron Valley Group Discussion PDF of PowerPoint Slides Posted - NSG Numbers Unclear
Rita and Mike during the talk (ACWG)
Gelman Discussion at the Sierra Club's Huron Valley Group (SCHVG) General Meeting PowerPoint sides posted:
Prof. Rita Loch Caruso PhD, Mike Moran Ann Arbor Township Supervisor and Vince Caruso gave an invited talk and took questions about the status of the Gelman Plume, toxicity and EPA Superfund Status at the General Meeting of the SCHVG on February 20 and now has been posted on the ACWG Site:
DEQ Not Clear on very important NSG standard:
Roger Rayle reports that the MDEQ recently reported to EPA Superfund manager that the near-surface groundwater (NSG) action level standard is 1,000 ppb, not the 1,900 ppb communicated to CARD. This is apparently a tough number to pin down. The mayor reported it being 29,000 ppb recently which would seem an order of magnitude or more too high.
Links: Michigan Department of Environmental Quality (MDEQ)-Gelman Project Site; Washtenaw County CARD Site; Scio Residents for Safe Water (SRSW)
YouTube Video of the last CARD Meeting, by Roger Rayle (https://www.youtube.com/watch?v=lKyxxNjwD10)
Lots of stores by Ryan Stanton in Ann Arbor News/MLive including this recent article 'EPA holding off on Superfund designation for Gelman dioxane plume'
See ACWG site pages EPA Superfund Option Details
Click here to view and/or sign in support of Superfund Designation
SCHVG has a General Meeting open to the public every 4th Tuesday of the Month at Matthaei Botanical Gardens (U of M) at 7:30 pm, check SCHVG web site for updates and Speaker Lists
February 2018; No Meeting this month due to Travel Schedules
Pall/Gelman 1,4-Dioxane Near-Surface Groundwater (NSG) MDEQ Tests at West Park Show 4.4 ppb
Approximate Location of NSG Tests West Park (Right Click for larger image; Annotation by ACWG)
Near-Surface Groundwater Tests Done at West Park Results - 4.4 ppb 1,4 Dioxane found in stormwater pipe:
DEQ commented at a recent Town Hall meeting that they now will be continuing near-surface groundwater (NSG) tests on the near west side of town. DEQ tests were done at West Park shown above.
Results published earlier this month show 4.4 ppb found in what is in all likelihood are NSG flow. At the 2-6-18 CARD meeting, Mitch Adelman MDEQ did comment that the DEQ will need to reevaluate the NSG issues with this new finding.
We need a plan of action on the NSG exposure potential not simply more tests. Dan Bicknell's GEA Comments on the DEQ Shallow Groundwater Work Plan and his proposed plan is posted in the November 2016 Agenda. Dan had a very well and logical plan laid out for dealing with the initial investigation of the NSG issue which seems to be clearly a problem that needs addressing.
The ACWG and CARD Groups has asked for permanent monitoring NSG wells on the near west side of the city.
The flows in the Allen's Creek at this location collect a lot of NSG springs and seeps just upstream. During a drought high flows can be heard flowing through this system through the access gates on this path. When this storm drain was installed it was designed to capture upstream NSG flows to reduce undermining of surface structures, like homes and the roadway.
The ACWG and CARD Groups have real concern for the potential for Vapor Intrusion (VI) exposures with NSG.
Just 11 blocks upstream from this test is now well over 1,000 ppb.
VI action level for this compound is 1,900 ppb in NSG, not 29,000 ppb as recently reported by the Mayor.
Paul Life Science/Gelmans own NSG 2006 maps show potential flows of NSG in the West Park area.
It is not clear if DEQ will start installing these wells this winter or spring.
Home basement exposures through contaminated NSG is a major concern and needs to be tested regularly till the plume is cleaned up.
Many homes on the city westside have NSG in wet basements.
Flows into basements will cause evaporation of the NSG and 1,4 dioxane into a confined space. Exposures will include inhalation and dermal contact, and much less so ingestion. At a recent DEQ public presentation in 2017 to discuss new MI Part 201 proposed changes, I asked if these exposures are currently considered Vapor Intrusion Exposures and was told yes.
Gelman Site, Scio Twp; Roger Rayle SRSW/CARD (Right Click for larger image; Annotation by ACWG)
Undisclosed Well and Soil Tests at Gelman Site?
Roger Rayle (SRSW, CARD) found signs of what seems like a temporary setup for well drilling/soil sampling in the marshy area of the Gelman site, by chance, on recent Google Arial View images, shown above. Google aerial view does not show this setup now.
The ACWG and CARD Groups are very interested in this undisclosed testing results and would like the MDEQ to do its own tests. The last soil tests in the 90's estimated up to 2M ppb in soils on the Gelman site area.
The ACWG and CARD Groups have asked for over a decade now, and Scio Residents for Safe Water for longer, soil test be done in the Gelman site area. We have commented that high levels of 1,4 dioxane could be recontaminating the groundwater that is being cleaned up.
Tens of dump truckloads of contaminated soil were removed from this site in the early days of the site remediation, and still very high levels seem to still exist there.
Gelman Discussion Sierra Club's Huron Valley Group (SCHVG) General Meeting;
Vince Caruso, Prof. Rita Loch Caruso PhD and Mike Moran Ann Arbor Township Supervisor will be giving an invited talk and be taking questions about the status of the Gelman Plume, toxicity and EPA Superfund Status at the next General Meeting of the SCHVG:
Date: Tuesday, February 20; 7:30 pm
Location: Matthaei Botanical Gardens; 1800 North Dixboro Rd, Ann Arbor; Matthaei metered parking fees go to support the Botanical Gardens.
Sierra Club Huron Valley Group meetings are held every third Tuesday of the month, are free and open to the public
Links: Michigan Department of Environmental Quality (MDEQ)-Gelman Project Site; Washtenaw County CARD Site; Scio Residents for Safe Water (SRSW)
YouTube Video of the last CARD Meeting, by Roger Rayle (https://www.youtube.com/watch?v=lKyxxNjwD10)
Lots of stores by Ryan Stanton in Ann Arbor News/MLive including this recent article 'EPA holding off on Superfund designation for Gelman dioxane plume'
See ACWG site pages EPA Superfund Option Details
Click here to view and/or sign in support of Superfund Designation
City Officials, Again Last Night, Discussing Affordable Housing in Floodplain on City Owned Lots
Association of State Floodplain Managers 2007 (ASFPM)
(Right Click for larger image)
"BUILDING IN THE FLOODPLAIN IS LIKE PITCHING YOUR TENT
ON A HIGHWAY WHEN THERE ARE NO CARS COMING"!
ASFPM: www.floods.org
City officials again at the Working Session last night discussed the sale of city-owned property in the floodplain. These sites were said by city leaders in recent years to be used as anchors for the Greenway. Keeping these sites open for the Greenway will make it a much more beneficial greenway and will reduce flood hazard. It will also make it Green with Park Space Plantings. These open sections can be used to have green open space in the near downtown and, place benches and tables, and potentially Public Art Spaces.
From Ann Arbor Flood Hazard Mitigation Plan proposes:
"The City of Ann Arbor takes a multi-faceted approach to floodplain management, working to protect natural floodplains and to mitigate flooding problems where the floodplain has already been developed...
Maintains an extensive park and greenway system in the floodplain along the Huron River, and has numerous other parks in the floodplain areas of the creeks flowing to the Huron River." (bold by us)
Unfortunately, Ann Arbor has a long and sorted history of placing less fortunate of city residents in affordable housing in the floodway and floodplain, and many still exist, including the current Homeless Shelter in the floodplain with some of the emergency exits into the floodway.
The two sites discussed again, last night, were 415 W. Washington and 721 N. Main are both almost entirely in the floodplain and largely in the floodway and along the proposed route of the Tree Line/Allen('s) Creek Greenway.
Doing flood mitigation in conjunction with the creation of the Greenway will allow the city to obtain grant funding as has occurred in the past. An example was when the ACWG pushed for stormwater mitigation in the West Park renovation, a large federal grant was used to do the forward-thinking SW portion of the renovations.
The Master Plan passed Planning Commission they also commented on and supported grant opportunities the ACWG mentioned at the Public Hearing, related to SW mitigation.
ACWG past discussion in past years with then Drain Commissioner Janis Bobrin and her staff, they agreed that opening up the floodplain and floodway would greatly reduce the number of homes facing flood hazard and costly flood insurance. Many homes in the Near and Old West Side have real flood hazard especially with Globel Warming effects on rainfalls and droughts. It is predicted, and is happening now by some respected accounts, that we will suffer much larger rainfall events. We will also suffer more severe droughts with greater flood hazard with very dry soil and very heavy rains with much higher fresh rainwater runoff, stormwater, and flooding.
The city staff has commented in previous public meetings that the FEMA Floodplain Maps are very loosely calibrated with very little real data used in the drawing of the maps. Even the FEMA consultants at StanTec drawing the maps have made similar statements when the maps were presented to the city.
The DDA commissioned a $1/4 to $1/2M sub-watershed study for this area from FTCH Consultants in the recent past but never asked for the results of this study. Time to see these results to more effectively plan for these sites.
Just before groundbreaking the Homeless Shelter initial $1M plan was scrapped due to it being shown by ACWG and others to be illegally in the floodway. Just before groundbreaking the North Main Affordable Housing Avalon Housing plan, which the ACWG did not support, was scrapped because new floodplain maps showed it was also in the floodway. The new Y building (which the ACWG did not support) Free Board (1' safety zone above the Floodplain Required for Construction Approval) was lost with a Letter of Map Revision 1 1/2 years after construction, with an increase of 33% higher floodplain at this location; 415 W. Washington is across the street.
Building in and up to the floodplain and floodway should not be something our city should be allowing to happen.
Link to City of Ann Arbor The Treeline-Allen Creek Urban Trail Master Plan Project Web Page
Link to Allen Creek Greenway Conservancy/Allen Creek Tree Line ACGC
December 2017 No Meeting this month due to Holiday and Travel Schedules
Watershed Issues of Interest:
Pall/Gelman 1,4-Dioxane Near Surface Groundwater Tests at West Park
US EPA
US EPA and Representative Dingell Gelman Plume Superfund Discussion 11-13-17
(ACWG; Right Click to View Larger)
Near-Surface Groundwater Tests Done at West Park:
DEQ commented at a recent Town Hall meeting that they now will be continuing near-surface groundwater (NSG) tests on the near west side of town.
They did a test today at West Park (results in a few weeks). We are glad they have said they will continue doing these tests. We would like to see tests they agreed to do this past summer before they stopped testing, eg: flows in the Allen's Creek, and additional locations.
Flows into West Park in the Allen's Creek pipe have high levels of groundwater which will be a valuable and quick test of NSG. The City, when asked by the ACWG, has agreed to help with this test
The ACWG was instrumental in getting these NSG tests done. DEQ, County and city did not request these tests till the ACWG and CARD groups requested them.
The CARD and ACWG Groups have asked for permanent monitoring NSG wells on the near west side of the city.
It is not clear if DEQ will start installing these wells this winter or spring.
Home basement exposures through contaminated NSG is a major concern and needs to be tested regularly till the plume is cleaned up.
Links: Michigan Department of Environmental Quality (MDEQ)-Gelman Project Site; Washtenaw County CARD Site; Scio Residents for Safe Water (SRSW)
There is just posted a YouTube Video of the 11-13-17 meeting by Roger Rayle and it should be available on his website at a later time, SRSW)
Lots of stores by Ryan Stanton in Ann Arbor News/MLive including this recent article 'EPA holding off on Superfund designation for Gelman dioxane plume'
See ACWG site pages EPA Superfund Option Details
Click here to view and/or sign in support of Superfund Designation
Allen('s) Creek Greenway/Allen Creek Tree Line Master Plan Adopted by City Council; Discussions of Sale of City Properties Along Greenway Path
A screenshot of a presentation slide from CAC #3 Meeting, City of Ann Arbor
The ACWG is glad to see council adopt the plan for a Greenway/Tree Line. The ACWG, Sierra Club Huron Valley Group and many others have been pushing for a greenway plan for over 20 years. ACWG and SCHVG members participated in the Greenway CAC and various public hearings and meetings in the recent years.
Some local and other communities have had great success with Greenways:
Kalamazoo Arcadia Creek Greenway: $400-500K in new tax receipts, 600% increase in revenues with $12M/yr festival revenue; From Backwater to one of the Hottest locations in town; Can handle beyond a 500 year storm now where it flooded almost every year.
Flints Gilkey Creek - Daylight and Greenway: In its first year prevented flooding in 100 year rain; Revitalized portion of city with daylighted and restored Gilkey Creek.
NYC High Line Greenway: elevated green space; 8th Wonder of the World; More visitors every year than the 7th Wonder of the World the Sphinx in Egypt; $2B in new investments in the area.
With the city talk of developing the city-owned properties in the floodplain and floodway along the proposed Greenway/Tree Line Trail, we should have a better understanding of the flood risk to the community.
The DDA commissioned a subwatershed study upstream of the city-owned 1st and William site when proposing a parking garage on this site which is in the floodway. FTCH was commissioned to do this study with a DDA budget of $1/4 to $1/2M. The Allen’s Creek Watershed Group (ACWG) FOIA'd the DDA for the results of this study but the DDA was not able to produce the report.
From the FOIA the ACWG was given the 'modelling results dataset' from the FTCH modelling runs but not the report.
It is time to produce the report to fully understand the flood hazard of these properties proposed to be sold and developed that are all in the floodway and floodplain. We have very little data to judge flood hazard, this study is valuable information that is not available to the public.
The FTCH indicated they could only release the report to the DDA, but DDA did not request it. They also indicated that the results were surprising to them enough to check with a local expert to discuss the findings.
The DDA proposed 1st and William Parking Garage did not move forward at that time.
With larger storms caused by Global Warming, the city should be taking this real opportunity to create a Greenway and reduce flood hazard as is recommended in the city adopted Flood Hazard Mitigation Plan. Ann Arbor has 100's of homes at risk of flooding in and near the floodplain with those in the floodplain paying higher flood insurance each year.
City officials are now discussing the sale of city-owned property in the floodplain that should be used as anchors for the Greenway. Keeping these sites open for the Greenway will make it a much more beneficial greenway and will reduce flood hazard. These open sections can be used to have green open space in the near downtown and, place benches and tables, and potentially Public Art Spaces.
Doing flood mitigation in conjunction with the creation of the Greenway will allow the city to obtain grant funding as has occurred in the past. An example was when the ACWG pushed for stormwater mitigation in the West Park renovation, a large federal grant was used to do the forward-thinking SW portion of the renovations.
When the Master Plan passed Planning Commission recently they also commented on and supported grant opportunities the ACWG mentioned at the Public Hearing, related to SW mitigation.
The city staff has commented in previous public meetings that the FEMA Floodplain Maps are very loosely calibrated with very little real data used in the drawing of the maps. Even the FEMA consultants drawing the maps have made similar statements when the maps were presented to the city.
Building in and up to the floodplain and floodway should not be something our city should be allowing to happen.
UM needs to work more with the community to make a meaningful Greenway. They initially indicated they would work with the city on a Greenway near the Athletic Campus, then at the next meeting, they pulled back.
When the UM is pushing for a Fuller Park Parking Garage in our city park for use by UM medical staff and not able to 'give an inch' on the Greenway, there is truly something that needs to change.
A person in attendance indicated that at a recent UM Medical Town Hall a speaker commented they thought they had solved the Parking Problem on 'The Hill' but now it is not a sure thing, with reference to the potential 1,300 car Fuller Park Parking Structure, and attached small train station.
Reliable sources indicated to us very little of the UM property would be affected if any, maybe a few parking spaces, with the Greenway adjacent to the Athletic Campus as originally proposed.
An old RR turntable is next to the Athletic Campus with over 150' wide area that could be a small pocket park in the greenway the owner has said could be used.
Game traffic on tracks will be on the Greenway the first day open with 1,000s of users, which will help grant options, and will be good advertising by word of mouth. This Greenway will connect people with nature, neighbours and, near and downtown businesses. It will also be a great connection to the B2B trail and Huron River.
Link to City of Ann Arbor The Treeline-Allen Creek Urban Trail Master Plan Project Web Page
Link to Allen Creek Greenway Conservancy/Allen Creek Tree Line ACGC
More Green Space in the City of Ann Arbor
Proposed Two blocks of Ontario St. Cleveland to close to traffic and open the space to more grass and green (wksu.org; Right Click to View Larger)
The parks millage has only spent about 9% of the funds for city parcels this year.
The parks millage has only spent about 23% in the city since its inception.
The parks millage states it should be spending 33% a year on green space in the city.
We should be obtaining more green space in the city not selling it off.
This, when we are proposing to sell off parcels along the path of the Greenway and, portions of Fuller Park for a Parking Garage and Train Station which once built will "necessitate" taking more of the Fuller Park for transit oriented development.
Green space in the urban center will help reduce heat island, polluted freshwater rain runoff and be a needed refuse from all the hardscape.
A UM study, done partially in Ann Arbor, showed walking in a green space like wooded areas is as good as antidepressants (or better).
New York Times “Front” Web Page Today (12-19-17): "Lake Erie Giant Algal Blooms"
NYT Front Page Image 12-19-17 (NYT; Huron River Arrow added by us; Right Click to View Larger)
NYT Photos of the Year: Lake Erie Giant Algal Bloom, 2017
"Lake Erie experienced one of the worst algal blooms in recent years, turning the lake bright green and alarming residents and local officials. At its peak, it stretched for miles south of Detroit, from Toledo to the shores of Ontario."
This appeared as a “Front” Web Page Headline with link to series of memorable 2017 aerial photos and captions.
Huron River flows to Lake Erie and the urban runoff contributes much to the algal bloom problem now plaguing the lake much more often than ever, and some predict with Global Warming and very weak runoff standards it will happen almost yearly. Dangerous levels of the algal bloom toxin caused Toledo Ohio, to shut down the drinking water supply of a half-million residents for three days in summer of 2014.
Close to 20 Million people in US and Canada use Lake Erie a drinking water source.
Algal blooms can render the water toxic and hard to decontaminate as well as kill off wildlife, affect residents living near the lake.
The pollution flowing into Lake Erie is rendering it a spoiled freshwater critical natural resource for Michigan, Ohio, NY and Canada.
NYT Web site - New York Times; NYT Photos from Above of 2017
Proposed Agenda and Updates:
November 16, 2017
UPDATE: Roger Rayle's YouTube video of CARD meeting is now available, see second agenda item below.
US EPA Superfund Gelman Plume Does Score High Enough for Full Superfund Evaluation, Currently Put On Hold
US EPA and Representative Dingell Gelman Plume Superfund Discussion 11-13-17 (ACWG; Right Click to View Larger)
US EPA and Representative Dingell held a meeting (thanks to Roger Rayle for taping the meeting and making available on YouTube) on Monday to discuss EPA Superfund designation for the Gelman Plume and take public comment, especially from the three Petitioners to the EPA for Superfund designation.
Scio and Ann Arbor Townships and, Sierra Club's Huron Valley Group filed a petition to list the site as a Superfund Site.
Many elected officials, Ann Arbor Administrator, Scio and Ann Arbor Township Managers, CARD members and others were in attendance.
It was communicated (Link to PDF of letter to Scio Township from EPA on PA Status saved on this site) the site does meet the 28.5 point standard for Superfund Status further evaluation. The state agrees with this analysis and scoring.
EPA will not currently do a site evaluation which is normally the next step, which would clearly push the score much higher than it is now, which is not reported other than at least 28.5, if and until a full Superfund designation is made.
EPA has decided to classify the site as "Other Cleanup Authority - State Lead" to allow the MDEQ to continue work with EPA oversite.
An EPA Scientist is now assigned to the site and will oversee MDEQ operations in dealing with the plume.
EPA can designate the site for further Superfund evaluation and designation if they so choose later, depending on MDEQ progress on protecting the environment and community.
When the ACWG and others asked for a list of "Bench Marks" the MDEQ must meet and by which date, we were told that process is not currently being used, to which the ACWG stated that was not good.
The CARD group may propose Bench Marks that MDEQ must meet to keep the site off the Superfund National List.
"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."
See full press release statement on our site here
If the majority on City of Ann Arbor City Council and Washtenaw County had joined in the Petition (the county passed a good resolution but it was never sent out*) the outcome may have been different, as the petitioners hoped to present a united front for full Superfund Designation and full cleanup.
We may still get a full cleanup of the site as EPA originally proposed with Superfund Designation and MDEQ may adopt but it will take longer and cost countless families heartache with loss of property value, higher cost of living, and potentially health effects and health effects not addressed.
Petitioners have issued a statement after the recent EPA announcement. Here is a partial Text of statement from Petitioners:
Links: Michigan Department of Environmental Quality (MDEQ)-Gelman Project Site; Washtenaw County CARD Site; Scio Residents for Safe Water (SRSW)
There is just posted a YouTube Video of this meeting by Roger Rayle and it should be available on his website at a later time, SRSW)
Lots of stores by Ryan Stanton in Ann Arbor News/MLive including this recent article 'EPA holding off on Superfund designation for Gelman dioxane plume'
Roger Rayle's video tape of meeting he posted on YouTube https://youtu.be/aXLRvudvOmo
Link to PDF of letter to Scio Township from EPA on PA Status saved on this site and in the site Navigation Page Links
See ACWG site pages EPA Superfund Option Details
Click here to view and/or sign in support of Full EPA Superfund Designation
Pall/Gelman 1,4-Dioxane - Near Surface Groundwater Tests Now Planned Again
Near-Surface Groundwater Tests are now Planned: DEQ commented at a recent Coalition for Action on Remediation of Dioxane (CARD) meeting (thanks to Roger Rayle for taping the meeting and making available on YouTube) that they now will be continuing near-surface groundwater (NSG) tests on the near west side of town but there is no date when these tests will start but should be in the next month or so. The ACWG pushed the DEQ for these tests at the meeting, which they said they would do previously but then back away from that. We are glad they have said they will continue doing these tests. We would like to see more tests eg: West Park Ground Water flows in the Allen's Creek, and additional locations.
They have agreed to do a test in West Park NSG flows next. ACWG, I, offered to help if needed and they may ask us to help. Flows into West Park in the Allen's Creek pipe have high levels of groundwater which will be a valuable and quick test of NSG. The City, when asked by the ACWG, has agreed to help with this test.
MDEQ has made a special case of 1,4 Dioxane mainly because of exposure threats in Ann Arbor and the heightened concern for this compound in the regulatory community including US EPA.
It was commented on by MDEQ at the recent CARD meeting that residents exposed to the compound at the near and surface waters does not seems to violate Prohibition Zone (PZ) Environmental standards in Michigan for this Gelman Consent Case unless the exposure is greater than the action level for the compound and the route of exposure, eg: 1,900 ppb for vapor intrusion, 7.2 ppb for drinking water. Dermal contact may be an issue with much higher levels of exposure if they are found in NSG. The setting of a Prohibition Zone in the city was to isolate the compound and allow it to flow under the city to the river and dilute out on its way to Lake Erie.
Lots of stores by Ryan Stanton in Ann Arbor News/MLive including this recent article 'DEQ signals shift in thinking about threats posed by dioxane'.
Roger Rayle's video tape of meeting he posted on YouTube https://youtu.be/DkOJYcFZOvg
Links: Michigan Department of Environmental Quality (MDEQ)-Gelman Project Site; Washtenaw County CARD Site; Scio Residents for Safe Water (SRSW)
More information about CARD, including the meeting calendar and a copy of the bylaws, is available on the CARD website by going to card.ewashtenaw.org. The CARD Group is working on setting up its own website to make access to information easier.
Allen('s) Creek Greenway/Allen Creek Tree Line - More Talk of Potential City Owned Property Sales - More Data Needed
Greenway Announcement Meeting, City of Ann Arbor
At a city council working session on Tuesday this week, again the city officials discussed the sale of city-owned property in the proposed Greenway Route, land mainly in the floodplain.
With the city talk of developing the city-owned properties in the floodplain and floodway along the proposed Greenway/Tree Line Trail, we should have a better understanding of the flood risk to the community.
The DDA commissioned a sub-watershed study upstream of the city-owned 1st and William site when proposing a parking garage on this site which is in the floodway. FTCH was commissioned to do this study with a DDA budget of $1/4 to $1/2M. The ACWG FOIAed the results of this study when the DDA was not able to produce the report.
From the FOIA the ACWG was given the 'modeling results dataset' from the FTCH modeling runs but not the report.
It is time to produce the report to fully understand the flood hazard of these properties proposed to be sold and developed that are all in the floodway and floodplain.
The FTCH indicated they could only release the report to the DDA, but DDA did not request it. They also indicated that the results were surprising to them enough to check with a local expert to discuss the findings.
The DDA proposed 1st and William Parking Garage did not move forward at that time.
With larger storms caused by Global Warming, the city should be taking this opportunity to create a Greenway and reduce flood hazard. Ann Arbor has 100's of homes at risk of flooding in and near the floodplain with those in the floodplain paying higher flood insurance each year.
City officials are now discussing the sale of city-owned property in the floodplain that should be used as anchors for the Greenway. Keeping these sites open for the Greenway will make it a much more beneficial greenway and will reduce flood hazard. These open sections can be used to have green open space in the near downtown and, place benches and tables, and potentially Public Art Spaces.
Doing flood mitigation in conjunction with the creation of the Greenway will allow the city to obtain grant funding as has occurred in the past. An example was when the ACWG pushed for stormwater mitigation in the West Park renovation, a large federal grant was used to do the SW portion of the renovations.
The Master Plan passed Planning Commission last week and they also commented on and supported grant opportunities the ACWG mentioned at the Public Hearing, related to SW mitigation.
The city staff has commented in previous public meetings that the FEMA Floodplain Maps are very loosely calibrated with very little real data used in the drawing of the maps. Even the FEMA consultants drawing the maps have made similar statements when the maps were presented to the city.
Building in and up to the floodplain and floodway should not be something our city should be allowing to happen.
UM needs to work more with the community to make a meaningful Greenway. They initially indicated they would work with the city on a Greenway near the Athletic Campus, then at the next meeting, they pulled back.
When the UM is pushing for a Fuller Park Parking Garage in our city park for use by UM medical staff and not able to 'give an inch' on the Greenway, there is truly something that needs to change.
A person in attendance indicated that at a recent UM Medical Town Hall a speaker commented they thought they had solved the Parking Problem on 'The Hill' but now it is not a sure thing, with reference to the potential 800 car Fuller Park Parking Structure, and train station.
Reliable sources indicated to us very little of the UM property would be affected if any, maybe a few parking spaces, with the Greenway adjacent to the Athletic Campus as originally proposed.
An old RR turntable is next to the Athletic Campus with over 150' wide area that could be a small pocket park in the greenway the owner has said could be used.
Link to City of Ann Arbor The Treeline-Allen Creek Urban Trail Master Plan Project Web Page
Link to Allen Creek Greenway Conservancy/Allen Creek Tree Line ACGC
Eberwhite Woods Committee Has Contacted the City to Have an Illegal Storm Sewer Pipe Removed from the Woods; Contaminated Creek Water an Issue
Eberwhite Woods, AAPS (Google Maps; Right Click for Larger View)
Last month the members of the Eberwhite Woods Committee have contacted the city regarding what seemed to be an illegal SW pipe draining into the park. They were told that is was indeed an illegal SW pipe that should be removed by the installer. The pipe was installed when new homes were built recently next to the northeast of the park.
They will be asking for payment for damages to the flora and the path caused by the excessive flows from the pipe into the park.
There are ongoing discussions on the options to reduce the excessive flows into the woods that is causing tree loss and habitat destruction.
Committee members commented that children are routinely in the creek in the woods. I commented this is not advisable as the creek waters may be contaminated according to city and county officials past comments to the ACWG. We agreed this contamination should be addressed and the creek cleaned up so contact of the waters is not a health hazard. Keeping kids out of the open creek is not an option.
We have children routinely in the open sections of the creek in the woodland between Liberty and Glendale and have commented on the contamination issues to officials in the recent past.
We agreed to meet with the full committee to discuss the potential options. They also will have discussions with U of M forestry staff.
These woods are the largest woodland on the west side of town and a real gem to the community and wildlife and, need to be preserved in as natural a state as possible.
Click to View Recent ACWG Meeting Agenda Items and Updates >
Click to View Older Agenda Items and Updates Page 2 >
Click to view Older Agenda Items and Updates Page 3 >
(*Some agenda items may have been corrected for typos and include follow up updates when posted here.)
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