Recent ACWG Meeting Agenda Items and Updates

2023-06-28 GELMAN DIOXANE PLUME - COMMUNITY UPDATE FORUM

https://www.mlive.com/news/ann-arbor/2022/09/ann-arbor-spending-333k-for-more-wells-to-track-polluters-pollution.html EWG https://www.ewg.org/tapwater/reviewed-1-4-dioxane.php

https://www.mlive.com/news/ann-arbor/2021/11/in-letter-to-epa-dingell-calls-latest-ann-arbor-area-dioxane-news-alarming.html

EPA, EGLE and Local Government Joint Session on 3-18-21; YouTube link to the Video

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 details from Barbara Lucas at Dioxane.Org Compilation and WEMU News Program GreenRoom

Washtenaw County CARD Site

Ann Arbor's Environmental Commission discussion with Evan Pratt the Water Resources Commissioner and Dan Bicknell (1-27-22)

https://michiganadvance.com/2023/03/27/energy-clean-water-and-pollution-top-list-of-environmental-priorities-for-house-dems/

See ACWG site pages EPA Superfund Option Details from CARD/ACWG.

Low-Rise Buildings Are Becoming More Popular To Improve Quality of Life and Reduce Very Dangerous Climate Change, Ann Arbor Leadership is Pushing High Rise Buildings With Little Concern

Downtown Ann Arbor, Another Ugly Set of New High-Rise, Major Carbon Emission, Buildings

(ACWG; Rt Clk for Larger)

https://www.google.com/search?q=cities+moving+to+low+rise+buildings&rlz=1C1CHBF_enUS822US822&oq=cities+moving+to+low+rise+buildings&gs_lcrp=EgZjaHJvbWUyBggAEEUYOdIBCTEwNTg5ajBqNKgCALACAQ&sourceid=chrome&ie=UTF-8

From AI Google:

"Low-rise buildings are becoming more popular in some cities for a variety of reasons, including:

Environmental impact
Low-rise buildings can be more environmentally friendly than high-rises because they use fewer materials and are less likely to increase congestion and pollution. A 2021 Bloomberg article suggests that a densely packed city of low-rises, like central Paris, could be the best urban environment for curbing carbon emissions.
Housing shortages
Low-rise, high-density buildings could be a way to increase housing units without sacrificing quality of life. This type of housing emerged in the 1960s and 1970s as an alternative to the "tower in the park" model, and emphasizes community and livable scale.
Community
Low-rise buildings can create a more intimate and community-oriented living experience. Residents may also enjoy more privacy and manageable upkeep."

(bold by us)

The City of Ann Arbor generates about 1/2 M tons of carbon a year, so one 20-story concrete and steel building is equivalent to 40 years of city emissions, so for the next 40 years you will double our carbon emissions just for one building, for what. With many concrete and steel buildings being constructed recently and currently this exposure is dangerously high and our city government is not interested in the enormous health and environmental effects to our community and the climate.

Just the 20 story concrete and steel building's enormous Carbon Footprint is about 20 million pounds of carbon into the atmosphere for just the concrete and steel alone, not including all the actual construction-related carbon emissions, which is also considerable!

The Biden administration recently finalized a policy to ensure that taxpayer-funded projects such as bridges, schools and other public buildings take into account not just past flooding, but the worsening floods that are likely to lie ahead. This must include all new buildings planning.

Council Recently Took a Step to Try To Put High Rise Residential Housing, Including Likely Affordable Housing, At 415 W. Washington, Which Would Be a Major Mistake and Dangerous

Association of State Floodplain Managers 2007 (ASFPM)

"BUILDING IN THE FLOODPLAIN IS LIKE

PITCHING YOUR TENT ON A HIGHWAY WHEN THERE ARE NO CARS COMING!" :

Association of State Floodplain Managers

ASFPM: www.floods.org

(ASFPM; Rt Clk for larger image)

The ACWG does not support this proposal. We communicated this to the Planning Commission and at City Council Meeting.

415 W Washington Flood Hazard; (First Street Evaluation)

(First Street; Rt Clk for Larger)

415 W. Washington Floodplain Map; Floodway in Blue, Floodplain in Green (ACWG)

(First Street; Rt Clk for Larger)

First Street Foundation 30-Year Flood Hazard 0.1% Chance, Probable

(First Street; Rt Clk for Larger)

Hurricane Helene was a clear Wake Up Call to treat Climate Change much more seriously or More Death and Mass Destruction will be worse. Unprecedented effects from Helene could happen much farther into the US then in the past.

ACWG.ORG has made comments to Council and Planning Commission in the recent year both verbally at the meetings and written.

The ACWG does not support this proposal.

Our Allen's Creek Watershed Management Plan adopted by MDEQ, Washtenaw County and City of Ann Arbor and ACWG agrees with Jerry Handcock's comments not to build on this site due to the floodplain covering virtually the entire site.

The First Steet Foundation, with open-source flood modeling, has been closely working with Federal Emergency Management Agency (FEMA) in recent years to update the greatly LowBalling floodplain maps by up to 33%, and FEMA agrees. FEMA is now working on FEMA 2.0 to update the maps they say are not accurate.

Our current City Leaders pretend to plan for Global Warming but propose building, and residential no less, in a very dangerous floodplain location.

For some reason, city officials failed to involve Jerry Handcock in the evaluation of this 415 plan. Planning officials stated “Oh. Our Bad!”

Jerry made comment anyway.

Jerry Hancock, the city’s stormwater and floodplain programs coordinator recently retired, raised concerns about the development proposal, saying putting a large residential structure in a flood zone is inconsistent with the city’s flood-mitigation policies.

Since 2004, the city’s policy has been to look for opportunities to purchase floodplain properties and demolish structures.

Chemicals on the site are said to be planned to be treated, but may float in the floodwater, in addition, the chemicals from the many flooded cars on site parked in the floodplain. These chemicals will migrate into the neighborhoods and contaminate homes in the Old West Side.

415 site was flooded in the 1968 100-year (1% Chance Flood):

The 415 site was flooded in the 1968 100-year (1% Chance Flood) (reliable sources say this was more like a 50-year rain) when a meeting of the city officials, Watershed Council and county officials were meeting there on flood hazard concerns, the soon-to-be Drain Commissioner was in attendance, his car was flooded and was Totaled and they were trapped in the flooded building for some time. They had no idea a very dangerous flood was to happen and were trapped, which tells you how dangerous this site is. Flood Experts were trapped.

The 1968 Flood waters were very close to the train trestle tracks at 415 at 10' 6" above the roadway.

This site in all likelihood has a much larger Floodway due to climate change and FEMA Low Balling Floodplain maps, and be much more dangerous than the maps suggest.

Voters passed an Ann Arbor Affordable Housing Tax Proposal, With a Ban On Fund's Use In Floodplains for a reason. ACWG championed this resolution with our council member at the time.

The floodplain and floodway delineations for this site are arguably outdated and inaccurate and unsafe to unsuspecting individuals.

City passed a $1B plan for Climate Change!! "But pushes to build new building in the dangerous floodplains and likely floodways".

Dr. Missy Stults city's Sustainability and Innovations Manager states at A2Zero Kickoff Meeting in 2020 when asked by the ACWG she responded: "No Building In Floodplain" Period. No discussion, no questions, just NO.

City has Made Major mistakes in this area of the floodplain floodway.

When the Homeless Shelter on Huron St., a block away, was about to start construction the ACWG and others contested building in the floodplain and likely floodway. The MDEQ put a Stop Work Order on the plans and determined the building would be illegally and dangerously in the floodway. The Plans had to be scrapped with ~$1 Million Dollar Loss to the city and redesigned up the hill outside the floodway. Unfortunately, it was built in the floodplain just inches away from the New Penciled In DEQ Floodway designation, very likely in the current larger floodway.

The Y on W. Washington lost the required FEMA Freeboard (open space 1' above the floodplain safety zone) in just 1.5 years after it was built in 2006, in a FEMA Letter of Map Revision (LoMR), and is out of federal and state floodplain floodway compliance!!

Smith Group has commented in a public meeting recently, ACWG attended, that the 2006 Y would 'never get approved today', and this group helped design the building in the floodway. The Y is just across the street from 415.

Y has regular flooding evacuation drills and worries about flood hazard according to a reliable inside source.

The Treeline Conservancy recently commented to the city that they feel the 415 site should be set aside for the Greenway and Downtown Greenspace/Park. The ACWG agrees and has promoted this since 1998.

Long past time to follow the Green Belt mandate by citizen vote and purchase green space inside the city as passed by the voters of Ann Arbor for the Greenway/Tree Line and other Green Park Spaces in 'our fine city', and stop cutting down trees in the very valuable few green spaces left in the city. Green Belt Millage called for 33% green space purchased in the city. Not long ago a council member calculated only 9% was being spent in the city for green space and illegally did not meet the GreenBelt Millage mandate.

Green space in the downtown is a tremendous value and pleasure in our city! This Green Space will greatly reduce flood hazard for the neighbors in this Old West Side area.

President Obama virtually forbids 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.

President Biden reinstated the Obama-era Federal Flood Risk Management Standard the day he took office.

This is one of the most dangerous sites in the City of Ann Arbor for housing or building due to major flood hazard.

Two people drowned in Northern Ohio in recent years trying to get their car out of a parking lot from under their apartment building.

The best use of this site is for the Allen's Creek Greenway/Tree Line pocket park and green trail. Urban Greenways are all the rage, everywhere but Ann Arbor.

The ACWG has proposed, since 1998, an Allen's Creek Greenway and included in the MDEQ adopted Allen's Creek Watershed Management Plan 2001, an Allen's Creek Greenway, the city included a Greenway in 1980 Ann Arbor City Master Plan.

The city and county have polluted this site for decades and have refused to clean it up for decades. Some of the contamination has seemed to moved off-site including into a Day Care Center to the south with TCE contamination issues. They should take responsibility and perform a long overdue cleanup.

More tall buildings in a city with very limited drinking water supply from the Huron River is ill-advised and dangerous. Mayor Tailor and some on council wanted GLWA - Detroit water but it shown that he did not know what he was asking for, not just more water, it was worse water in a major way, hugely expensive and roundly rejected by the city.

415 W Washington Development Plan Would be a Mistake!

Thousand Year Rains/Floods are now common in Michigan and elsewhere in the US with Global Warming causes in weather, and is getting worse every year.

Links:

MLive https://www.mlive.com/news/ann-arbor/2015/09/should_ann_arbor_adopt_new_reg.html#incart_river

MLive https://www.mlive.com/news/ann-arbor/2023/02/toxic-pollution-spreading-at-city-owned-site-in-downtown-ann-arbor.html

FEMA LowBalling floodplain maps by up to 33%

Green Fair 2024 - Members of CARD, SRSW, ACWG Attended and Tabled For the Fair

Green Fair 2024

Roger Rayle, Jack Eaton and Rita Loch-Caruso (Vince Caruso Took Photos)

(ACWG; Rt Clk for Larger)

We had a great evening with many folks stopping by to ask questions and comment on the mess we have with the 1,4 dioxane, and signed up for the CARD Email list.

Water Quality City Staffer did stop by to talk and hand out chocolate candies.

Unfortunately again, and always in recent years, no other city official's stopped by, the mayor quickly did pass by the booth ignoring us.

An Older In Depth Discussion of the Allen's Creek Watershed Issues with Nancy Kaplan's Online YouTube Other Perspectives Show 12 Years Ago, Links Below

Nancy Kaplan's Other Perspectives Show

(Other Perspectives; Rt Clk for Larger)

12 Years ago.

Link to First half and Second Half of the discussion:

https://www.youtube.com/watch?v=qDLsLjbcnxI

https://www.youtube.com/watch?v=7XB44ISzlH8

Vince Caruso and Tom Bletcher (founding members of ACWG.ORG) discuss the Ann Arbor Allen's Creek Watershed Issues

The discussion covers many issues including flooding, development of questionable floodplain locations and dangerous flood hazard, polluted creek waters...

Nancy did many interviews that were very informative and interesting.

Link to First half and Second Half of the discussion:

https://www.youtube.com/watch?v=qDLsLjbcnxI

https://www.youtube.com/watch?v=7XB44ISzlH8

Good to See New, Largely, Wood Low Rise 4 Story Building Going Up On Miller St. Near Downtown

Mostly Wood Low Rise Building, Miller St. Near Downtown

(ACWG; Rt Clk for Larger)

This low rise building is what we need to move to if we want to reduce climate change and reduce dangerous changes in our climate world wide, not just America.

These kinds of largely wood buildings could use Michigan wood and sequester carbon for centuries.

As we have commented on these Low Rise buildings have lots of benefits for the residents, environment and the city.

Vote and Vote For Ann Arbor Fair Elections Not Corporate Donors and PAC's And, Have Non-Partisan Elections;

Vote November 5th Elections!

(ACWG, Rt Clk for larger)

Please Vote In the 2024 November 5th Elections!

Vote including Fair Elections, Nonpartisan vote.

Prop C: Nonpartisan Elections

(https://www.a2future.com/; Rt Clk for Larger)

Prop D: Reduce Influence from Corporate Donors and PACs

(https://www.a2future.com/; Rt Clk for Larger)

This is a movement of Ann Arborites who care about strong democratic participation, fair play, good governance, and Ann Arbor’s future. More than 150 volunteer canvassers and active supporters gathered more than 5,800 qualified signatures for each proposal - and we need your support: https://www.a2future.com/

July 2024, No Meeting this Month,

ACWG Meetings Will be on a Ad Hoc Basis

Watershed Issues of Interest and Updates:

Gelman 1,4 Dioxane is a Real Threat to Wells in the Townships and Basement Exposures in Ann Arbor, City Drags Feet on NSG Tests on our Ann Arbor West Side

From USEPA Gelman Website (https://www.epa.gov/mi/gelman-sciences)

US EPA:

"EPA has determined that the Gelman Sciences site is eligible to move forward as a candidate for inclusion to the National Priorities List due to high levels of 1,4-dioxane.

Background

Gelman Sciences Inc., a former medical filter manufacturer near Ann Arbor, Michigan, left contamination stemming from years of unregulated waste handling on its facility grounds. A plume of 1,4-dioxane has spread through the groundwater in Ann Arbor and Scio Townships, including a western part of the city of Ann Arbor.

In 1992, a county circuit court ordered Gelman to address the plume. Gelman was ordered to contain the plume, prevent groundwater use in contaminated areas, prevent well use within the plume or areas threatened by the plume, connect affected properties to municipal water. Michigan Environment, Great Lakes and Energy is the enforcement lead for the Gelman site.

EPA has determined that the Gelman Sciences site is eligible to move forward as a candidate for inclusion to the National Priorities List due to high levels of 1,4-dioxane. The NPL is a list of known sites throughout the United States and its territories where historical releases of hazardous substances pose significant threats to human health and the environment. 

The site is eligible based on data from a recently completed site inspection and abundant historical data. EPA believes the site should be included on the NPL after analysis showed concentrations of 1,4-dioxane that likely originated from the site were above three times the background levels, or typical levels found in the area. Gelman Sciences operated as a medical filter manufacturer from 1966 until 1986 near Ann Arbor, Michigan. The facility’s waste handling created a plume of the industrial solvent 1,4-dioxane, which has spread and contaminated groundwater in Ann Arbor and Scio Townships.

Before proposing the site to the NPL, it’s EPA’s policy to secure state concurrence. EPA has coordinated with the Michigan Department of Environment, Great Lakes, and Energy throughout the evaluation process and has shared its report with the state agency.

Related Documents (from US EPA)"

From ACWG:

This is great news for the eventual cleanup of the Gelman/Danaher Toxic Waste site in Scio Township, Ann Arbor Township and the City of Ann Arbor, which will be paid for by the Responsible Party Gelman/Danaher.

The ACWG and CARD Groups will stay involved with EPA and the Michigan Department of Environment, Great Lakes, and Energy (EGLE) during the NPL/Superfund Designation process which could take a year or more.

NSG Monitoring on Ann Arbor Westside Have Continued By EGLE this year:

ACWG has also received notice that the near-surface groundwater (NSG) will have continued monitoring by EGLE. Dan Hamel with EGLE did the previous testing at the behest of the ACWG and CARD before he died this past July. See past ACWG website comments on this NSG monitoring. ACWG will observe EGLE taking samples on Ann Arbor's west side including West Park.

The 2024 Scio Township residential drinking water wells sampling by the Michigan - Department of Environment, Great Lakes and Energy (EGLE) and Washtenaw County Health Department (WCHD) shows that the Gelman Sciences, Inc. (Gelman) dioxane groundwater contamination continues to migrate north and has contaminated now at least 45 residential drinking water wells in Scio Township from M-14 northward. Four additional residential drinking water wells were found in 2024 to be impacted by dioxane in this area. The dioxane plume is expanding northward in the subsurface along low topographic areas directly to the Huron River and then Barton Pond. The 4th Amended Consent Judgment between Gelman and EGLE will not stop this dioxane plume northern migration. See below portion of the 2024 Washtenaw County Health Department figure with the location and general dioxane concertation in residential drinking water wells north of M-14.

Comments from Dan Bicknell on township drinking water wells recent test results - contact Dan for additional information:

To further illustrate the limitation and subjectivity of the EGLE dioxane drinking water criterion, if a person consumes drinking water from a groundwater source, the EGLE drinking water criterion is 7.2 ug/L dioxane, however, if a person consumes drinking water from a surface water source, the EGLE drinking water criterion is 3.5 ug/L dioxane. Clearly, the State of Michigan needs to revise the dioxane drinking water criterion to be consistent and protective of public health.

It is disingenuous for knowledgeable public health officials to tell the community that it is "safe" to drinking dioxane at 7.2 ug/L. The USEPA has classified dioxane as one of the few chemicals likely to be carcinogenic to humans.

Daniel J. Bicknell, MPH

President

Global Environment Alliance, LLC

Phone - 248-720-9432

danjbicknell@live.com

Ann Arbor does not have unlimited drinking water to supply other communities outside Ann Arbor. Stopping and cleaning up the 1,4 Dioxane Plume is long overdue and a meaningful much lower cost solution.

Links:

CARD Meeting July 2024; YouTube; https://www.youtube.com/watch?

2023-06-28 GELMAN DIOXANE PLUME - COMMUNITY UPDATE FORUM

https://www.mlive.com/news/ann-arbor/2022/09/ann-arbor-spending-333k-for-more-wells-to-track-polluters-pollution.html EWG https://www.ewg.org/tapwater/reviewed-1-4-dioxane.php

https://www.mlive.com/news/ann-arbor/2021/11/in-letter-to-epa-dingell-calls-latest-ann-arbor-area-dioxane-news-alarming.html

EPA, EGLE and Local Government Joint Session on 3-18-21; YouTube link to the Video

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 details from Barbara Lucas at Dioxane.Org Compilation and WEMU News Program GreenRoom

Washtenaw County CARD Site

Ann Arbor's Environmental Commission discussion with Evan Pratt the Water Resources Commissioner and Dan Bicknell (1-27-22)

https://michiganadvance.com/2023/03/27/energy-clean-water-and-pollution-top-list-of-environmental-priorities-for-house-dems/

See ACWG site pages EPA Superfund Option Details from CARD/ACWG.

City of Ann Arbor, Scio Township and Ann Arbor Township, CARD and ACWG To Request Gelman/Danaher Pay EGLE for Continued Monitoring of Drinking Water Wells for 1,4 Dioxane Contamination;

EGLE Continues to Test NSG on City West Side

EGLE and Washtenaw County Drain Officials Sampling

West Park and Chapen St Allen's Creek Drains (NSG),

Other Locations Were Tested As Well

(ACWG; Rt Clk for larger)

EGLE continues to do Near Surface Groundwater (NSG) Testing Allen's Creek:

Environment, Great Lakes and Energy (EGLE) continued to do Near Surface Groundwater (NSG) testing of Allen's Creek on the city's west side assisted by Washtenaw County Drain Officials. The main areas of tests are the same as in recent past years, as shown in image below, West Park, Chapin St. and 8th Street areas, and an open section of Allen's Creek near Virginia Park also.

These tests NSG tests in West Park were spearheaded by the ACWG with knowledge that the flows through West Park were largely groundwater during low rain periods and would be the next best test as the state did not want to do shallow groundwater wells in the park. This data was a major reason EPA decided to do a Superfund Site for the Gelman Plume.

EPA Superfund will take on the Gelman Toxic Plume, stop the flow to wells, to the Huron River and Barton Pond, west side basements like no other entity we can turn to and Gelman/Danaher will pay for the cleanup and after effects.

150 ppb in Near Surface Shallow Groundwater is a real concern for exposure, and 100 ppb may be an issue with more data and analysis study. West Side has many wet basements that could be an exposure route.

Results to be posted when EGLE reports results to CARD/ACWG.

Below is a map of past NSG tests on the city's West Side.

The Coalition for the Remediation of Dioxane (CARD) Group Will Petition EGLE to Monitor Drinking Water Wells Ann Arbor and Scio Townships:

The CARD Group is expected to have Environment, Great Lakes and Energy (EGLE) supervise the monitoring of drinking water wells in Ann Arbor and Scio Townships and have Gelman/Danaher cover the costs in full. The final Petition will be available on the CARD website.

Ann Arbor and Scio Twps have had more wells with very low levels of 1,4 dioxane in recent years which has precipitated a request from the townships and CARD for EGLE to have Gelman/Danaher monitor the plume migration that seems to be happening now.

It seems like currently, the drinking water wells in the townships are being used as a way to monitor the movement of the plume in the groundwater. This should not be allowed by the county or EGLE. Homeowner wells are not the way monitoring should occur. We need separate monitoring wells that use Method 522 and EGLE should get funding from Gelman/Danaher the responsible party.

EPA and Environmental Working Group: likely human carcinogen:

Environmental Working Group (EWG.ORG): 1,4-Dioxane is a likely human carcinogen that contaminates drinking water in nearly every state across the country. Despite this widespread contamination, there is no federal standard limiting the levels of 1,4-dioxane in tap water. The EPA defined a concentration of 0.35 parts per billion, or ppb, as the amount of the chemical in water expected to cause no more than one additional case of cancer in every one million people who drink it for a lifetime. (bold by us) EWG Review of 1,4-Dioxane in Tap Water

EPA representative at the June CARD meeting it was said that the EPA is moving forward on the Superfund and they are operating as though the Superfund designation will ultimately be approved.

The data collection to date on the Gelman Site shows a Superfund designation is very likely unless something unexpected occurs.

The expected score is predicted to be similar to past scoring which was the highest available. Most reliable sources feel an EPA Superfund designation is very likely, given the past EPA scoring and the fact that EPA will have a Responsible Party to pay for the cleanup of the contamination. The cleanup will likely be the Gelman/Danaher site, groundwater and soil contamination.

Once a Score is given EPA will enter the site to be placed on the National Priorities List (NPL) (link to ACWG SF Listing). Sites are first proposed to the National Priorities List (NPL) in the Federal Register.

NPL Sites are commonly called Superfund Sites. EPA then accepts public comments on the sites, responds to the comments, and places on the NPL those sites that continue to meet the requirements for listing.

EPA will likely force the polluter to pay for a cleanup before the State of Michigan re-instates the Polluter Pay Legislation and go after Danaher (Pall/Gelman), a $180 Billion company, to cover the cleanup costs. This is why EPA Superfund is our best hope of a faster cleanup.

CARD members and others have made comment to EGLE on many occasions that the 7.2 ppb standard for the state is to high and needs to be more in line with EPA and EWG.

The Majority on City Council and Mayor have Shown Little Interest in the Gelman Toxic Waste Plume

The Majority on City Council and Mayor have shown little interest in the Gelman Toxic Waste Plume over decades. The Mayor has never attended a CARD meeting that anyone can remember, and few of his supporters on Council have either. Some past council members attend regularly and do so now after they have left office. YouTube Nov. 5, 2020 video location in City Council when Majority voted to support EPA Superfund, Mayor and his supporters argue against it and lose.

The Mayor and his supporters obstructed the effort to bring EPA Superfund to the Gelman Toxic Plume at every turn for years and his predictors as well. It would seem the UM, developers, real-estate interests who pressured the city to not have the stigma of a Superfund (until they leave office and leave town with big bank accounts) were more important than residents of the community facing the real and present danger from the Plume, leaving Ann Arbor in the Lurch.

Many new exposures are happening now that could have been avoided, with the commensurate health effects.

It is clear that EPA Superfund is the only hope we have to try to deal with this Gelman Toxic Plume flowing in every direction.

EPA Superfund will take on the Gelman Toxic Plume, stop the flow to wells, to the Huron River and Barton Pond, west side basements like no other entity we can turn to and Gelman/Danaher will pay for the cleanup and after effects.

Allowing Gelman to use the Allen's Creek as a conduit for contaminated water to the Huron River creates new exposures to homes and businesses downstream in Ann Arbor and eastward via Vapor Intrusion and or direct contact, and negatively affects property values (Tax Base for Bean Counters!) due to these potential exposures.

MS4 Violation Still Occurring:

The Federal MS4 Violation in Allen's Creek Going on 5 Years and still not even started to be fixed: The CARD Group has unanimously passed a resolution asking for the illicit 1,4 Dioxane pollution flowing into the Allen's Creek Drain to be removed by Gelman. Gelman and EGLE have been notified of this for over 3 years, going back to 2019, with the illicit 1,4 Dioxane pollution levels in the drain generally going up. The ACWG pushed for and also supports the CARD resolution. No resolution of this MS4 violation has been reported at past CARD meetings regarding this US Federal Clean Water Act violation. Without more robust tests, as we have requested for many years, and passed a CARD resolution to that effect "10-5-21, NSG Wells Request, CARD Resolution", these simple tests are all we can get currently from our government officials, for some reason.

Michigan MS4 Permit:

'The MS4 permit is required to halt any illicit discharge into the storm drain. An “illicit discharge” is defined as any discharge to, or seepage into, an MS4 drain that is not composed entirely of stormwater or uncontaminated groundwater except discharges pursuant to an NPDES permit.' (bold by us)

Simple NSG Tests were ad hoc "let's look at see" Now Time to Act-On the Results:

It is our opinion that we support professional monitoring of the eastward migration of the plume through Ann Arbor. Sampling from storm drains was an ad hoc "let's look at see" approach that needs to be replaced by permanent monitoring wells. At a minimum, the wells should monitor at elevations shown to have significant dioxane concentrations upstream. Only then -- with solid data -- should we draw conclusions.

The simple drain tests that turned out to be positive and going up quickly (at least 49 ppb), were "Very Low Cost, Simple and Quick and Dirty" tests that now should be followed up on. EPA will do this in much more detail at some point, we should not wait for that.

All the groundwater seeps coming to the surface on the near west side are the reason why it is called Water Hill, and has Bath, Fountain, Spring Streets, ...

The EGLE prohibition zone does not allow movement of the plume to the surface, which we now have.

City Re-labels and Confuses "Allen's Creek Watershed Group (ACWG)" to "Allen Creek Watershed Association" In City Mailings to Ann Arbor Residents and Local Businesses

Bogus Public Hearing Notice Sent by

City Hall to Ann Arbor Residents

No Such Group Exists

(ACWG; Rt Clk for Larger)

These confusing notices are being sent now and have been for a number of months recently.

This seems to be a deliberate way to confuse residents and elected officials. We were not contacted about this, just found it on mailings about upcoming city meetings generally regarding planning events or other city events. This misinformation should not be originating at our City Hall.

Hard not to think our city government is more interested in confusing issues facing the city like dealing with severe climate and storm issues than

confusing residents.

Is this what our hard earned taxes paying for confusing illogical notices to residents and businesses.

This should be corrected ASAP.

Low-Rise Buildings Are Becoming More Popular To Improve Quality of Life and Reduce Very Dangerous Climate Change, while Ann Arbor Leadership is Pushing Taller Buildings by the Day

Downtown Ann Arbor, Another Ugly New High-Rise Buildings

(ACWG; Rt Clk for Larger)

https://www.google.com/search?q=cities+moving+to+low+rise+buildings&rlz=1C1CHBF_enUS822US822&oq=cities+moving+to+low+rise+buildings&gs_lcrp=EgZjaHJvbWUyBggAEEUYOdIBCTEwNTg5ajBqNKgCALACAQ&sourceid=chrome&ie=UTF-8

AI Google:

Low-rise buildings are becoming more popular in some cities for a variety of reasons, including:

Environmental impact
Low-rise buildings can be more environmentally friendly than high-rises because they use fewer materials and are less likely to increase congestion and pollution. A 2021 Bloomberg article suggests that a densely packed city of low-rises, like central Paris, could be the best urban environment for curbing carbon emissions.
Housing shortages
Low-rise, high-density buildings could be a way to increase housing units without sacrificing quality of life. This type of housing emerged in the 1960s and 1970s as an alternative to the "tower in the park" model, and emphasizes community and livable scale.
Community
Low-rise buildings can create a more intimate and community-oriented living experience. Residents may also enjoy more privacy and manageable upkeep.

Just the 20 story concrete and steel building's enormous Carbon Footprint is about 20 million pounds of carbon into the atmosphere for just the concrete and steel alone, not including all the actual construction-related carbon emissions, which is also considerable!

The City of Ann Arbor generates about 1/2 M tons of carbon a year, so one 20-story concrete and steel building is equivalent to 40 years of city emissions, so for the next 40 years you will double our carbon emissions just for one building, for what. With many concrete and steel buildings being constructed recently and currently this exposure is dangerously high and our city government is not interested in the enormous health and environmental effects to our community and the climate.

The Biden administration recently finalized a policy to ensure that taxpayer-funded projects such as bridges, schools and other public buildings take into account not just past flooding, but the worsening floods that are likely to lie ahead. This must include all new buildings planning.

City of Ann Arbor Climate Change Options

Porous Pavement Recently Put In Use on Vancouver CA Street

(City of Vancouver; Rt Clk for Larger)

City of Ann Arbor, Porous Pavement Bragging Rights, Torn Down Several Years Ago

Porous Pavement Y Lot, City Of Ann Arbor

(ACWG; Rt Clk for Larger)

https://www.washingtonpost.com/climate-environment/2024/07/10/houston-flooding-hurricane-beryl/

The Biden administration recently finalized a policy to ensure that taxpayer-funded projects such as bridges, schools and other public buildings take into account not just past flooding, but the worsening floods that are likely to lie ahead.

The goal, officials said, is to make the nation’s infrastructure more resilient in an era of climate change and to avoid the cycle of repeated floods and rebuilding that has happened in the past.

ACWG has a page of Porous Pavement Benefits that could greatly reduce flooding at much lower cost including, reduced heat island, water pollution, much less noise, better traction, longer lasting, much lower cost when all expenses are included, long lasting, no Black Ice, no cars and trucks sliding down hills, ...

Lessons from a Modern Master of Low-Rise Housing; Environmentally Effective

"Cities looking to boost density and affordability should look to the work of architect Louis Sauer, who designed stylish modernist housing in the 1960s and ’70s."

Bloomberg Mag: https://www.bloomberg.com/news/features/2022-02-14/the-architect-who-mastered-low-rise-high-density-housing?srnd=citylab

Louis Sauer Human Scale Buildings

(ACWG; Rt Clk for Larger)

Wood buildings 4-5 stories, Human Scale, not Out of Town Developer Profits Windfall Scale.

"Huntington Park in California and Somerville in Massachusetts manage to pack in more people per square mile than high-rise-laden cities like San Francisco and Boston, though few buildings rise beyond four stories."

Michigan wood used in buildings can sequester carbon and not emit millions of pounds into the atmosphere.

Low-Rise Paris has well over twice the density of NYC without High-Rise buildings, as we have commented here.

"Cement emits as much CO2 as India (the whole country)" Washington Post June 27, 2023. Ann Arbor is pushing taller concrete buildings as a "Mantra" to Developers, Real-Estate Interests and U of M. with disregard for Climate Change.

From the Washington Post Article:

"The cement industry is responsible for 8 percent of global carbon emissions -- triple the emissions of the aviation industry. And making all that concrete also emits an enormous amount of carbon dioxide.

Not only does the carbon dioxide from the reaction spill into the atmosphere, but cement producers also use huge amounts of coal or natural gas to heat the kiln." (bold by us)

Tall buildings cause excessive Heat Island effects in cities, creating health hazards, and requiring more carbon-producing air conditioner use.

Just the 20 story concrete and steel building's enormous Carbon Footprint is about 20 million pounds of carbon into the atmosphere for just the concrete and steel alone, not including all the actual construction-related carbon emissions, which is also considerable!

Proof Low Rise is More Dense and Low Carbon:

Paris, for example, with its mostly four- and five-story buildings, produces fewer overall emissions than both sprawling exurbs and skyscraper cities given the land required to build tall buildings and the carbon-intense building materials like aluminum and steel it takes to construct them, a neighborhood of skyscrapers would result in about 140% more total emissions than a Paris-like lower-rise area with the same population. Paris is more dense than high-rise cities and better for the residents in many ways.

Low-rise buildings can mostly be built with carbon-capturing wood, high-rises do not currently have this option. This has never been addressed by the city.

The city leaders are more interested in getting funds for campaigns from high-rise developers who make millions of dollars, most don't even live in the USA, on inefficient high-rise buildings and bragging rights on who has the tallest buildings. And U of M pushing for high-rises to handle the recent huge increase of students with no regard for Climate Change effects.

We can build in Ann Arbor and elsewhere with smart and forward thinking ideas.

Climate Change Is Now!

June 2024 - No Watershed Issues of Interest and Updates Due to Vacation and Travel Schedules

May 2024 - No Watershed Issues of Interest and Updates Due to Vacation and Travel Schedules

April 2024, No Meeting this Month due to COVID-19 Pandemic Cautions

Watershed Issues of Interest and Updates:

EPA Requesting Comment for Gelman Toxic Waste 1, 4 Dioxane Dump Site; ACWG and CARD Strongly Support Public Comment for NPL Listing Of This Site

Coalition for Action on Remediation of Dioxane (CARD) and ACWG encourage you to submit a comment. EPA has stated that Personal Comments have a significant impact on their division to make a site a National Priority List (NPL) (SuperFund) Site. Form letters are much less significant.

You can see other's comments on the EPA Site, see below.

The EPA Gelman Plume ACWG Comments summitted was for ACWG and the my CARD Comment was from me as a CARD ExComm member.

Comment Information:

EPA Announcement: EPA Proposes to Add Gelman Sciences Inc. in Ann Arbor, Michigan to Superfund National Priorities List Opens Comment Period

The Comment Period Ends May 6th, 2024

EPA Superfund Contact Information

Danielle Kaufman (kaufman.danielle@epa.gov)

312-764-2234

! Link to Comment Page for EPA Gelman Toxic Dump Site Cleanup for A Comment Entry:

https://www.regulations.gov/commenton/EPA-HQ-OLEM-2024-0067-0001

(Plain Text entry of Comments only; Attachments are allowed)

Link to Comments Submitted:

https://www.regulations.gov/docket/EPA-HQ-OLEM-2024-0067/comments

More details and other links regarding the NPL are on our ACWG web site.

EPA will very likely take over this polluted Gelman site and cleanup the contamination to federal standards and it will be funded by Danaher as the responsible party of record. Danaher does cleanups of 1,4 dioxane in water in other localities, especially Arizona.

At the March CARD meeting I asked an EGLE representative Chris Swoboda PhD Geologist for Environment, Great Lakes and Energy (EGLE), generally how long will it be before EPA takes over this site and starts a full cleanup. He said generally 2-3 years.

EPA will likely force the polluter to pay for a cleanup before the State of Michigan re-instates the Polluter Pay Legislation and go after Danaher (Pall/Gelman), a $180 Billion company, to cover the cleanup costs. This is why EPA Superfund is our best hope of a faster cleanup.

Researchers of the Gelman site have found as much as 210,000 ppb concentrations in the groundwater at/near the Wagner site.

CARD members and others have made comment to elected officials in Town Hall Meetings and EGLE on many occasions that the 7.2 ppb standard for the state is to high and needs to be more in line with EPA and EWG which is .35 ppb.

The Majority on City Council and Mayor have Shown Little Interest in the Gelman Toxic Waste Plume

The Majority on City Council and Mayor have shown little interest in the Gelman Toxic Waste Plume over decades. The Mayor has never attended a CARD meeting that anyone can remember, and few of his supporters on Council have either. Some past council members attend regularly and do so now after they have left office. YouTube Nov. 5, 2020 video location in City Council when Majority voted to support EPA Superfund, Mayor and his supporters vehemently argued against it and the lost the vote.

The Mayor and his supporters obstructed the effort to bring EPA Superfund to the Gelman Toxic Plume at every turn for years and his predictors as well. It would seem the UM, developers, real-estate interests who pressured the city to not have the stigma of a Superfund (until they leave office and leave town with big bank accounts) were more important than residents of the community facing the real and present danger from the Plume, leaving Ann Arbor in the Lurch.

Many new exposures are happening now that could have been avoided, with the commensurate health effects.

It is clear that EPA Superfund is the only hope we have to try to deal with this Gelman Toxic Plume flowing in every direction.

EPA Superfund will take on the Gelman Toxic Plume, stop the flow to wells, to the Huron River and Barton Pond, west side basements like no other entity we can turn to and Gelman/Danaher will pay for the cleanup and after effects.

Allowing Gelman to use the Allen's Creek as a conduit for contaminated water to the Huron River creates new exposures to homes and businesses downstream in Ann Arbor and eastward via Vapor Intrusion and or direct contact, and negatively affects property values (Tax Base for Bean Counters!) due to these potential exposures.

MS4 Violation Still Occurring:

The Federal MS4 Violation in Allen's Creek Going on 5 Years and still not even started to be fixed: The CARD Group has unanimously passed a resolution asking for the illicit 1,4 Dioxane pollution flowing into the Allen's Creek Drain to be removed by Gelman. Gelman and EGLE have been notified of this for over 3 years, going back to 2019, with the illicit 1,4 Dioxane pollution levels in the drain generally going up. The ACWG pushed for and also supports the CARD resolution. No resolution of this MS4 violation has been reported at past CARD meetings regarding this US Federal Clean Water Act violation. Without more robust tests, as we have requested for many years, and passed a CARD resolution to that effect "10-5-21, NSG Wells Request, CARD Resolution", these simple tests are all we can get currently from our government officials, for some reason.

Michigan MS4 Permit:

'The MS4 permit is required to halt any illicit discharge into the storm drain. An “illicit discharge” is defined as any discharge to, or seepage into, an MS4 drain that is not composed entirely of stormwater or uncontaminated groundwater except discharges pursuant to an NPDES permit.' (bold by us)

Simple NSG Tests were ad hoc "let's look at see" Now Time to Act-On the Results:

It is our opinion that we support professional monitoring of the eastward migration of the plume through Ann Arbor. Sampling from storm drains was an ad hoc "let's look at see" approach that needs to be replaced by permanent monitoring wells. At a minimum, the wells should monitor at elevations shown to have significant dioxane concentrations upstream. Only then -- with solid data -- should we draw conclusions.

The simple drain tests that turned out to be positive and going up quickly (at least 49 ppb), were "Very Low Cost, Simple and Quick and Dirty" tests that now should be followed up on. EPA will do this in much more detail at some point, we should not wait for that.

All the groundwater seeps coming to the surface on the near west side are the reason why it is called Water Hill, and has Bath, Fountain, Spring Streets, ...

The EGLE prohibition zone does not allow movement of the plume to the surface, which we now have.

Links:

CARD Meeting March 2024; YouTube; https://www.youtube.com/watch?v=koL2H37fSjY

2023-06-28 GELMAN DIOXANE PLUME - COMMUNITY UPDATE FORUM

https://www.mlive.com/news/ann-arbor/2022/09/ann-arbor-spending-333k-for-more-wells-to-track-polluters-pollution.html EWG https://www.ewg.org/tapwater/reviewed-1-4-dioxane.php

https://www.mlive.com/news/ann-arbor/2021/11/in-letter-to-epa-dingell-calls-latest-ann-arbor-area-dioxane-news-alarming.html

EPA, EGLE and Local Government Joint Session on 3-18-21; YouTube link to the Video

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 details from Barbara Lucas at Dioxane.Org Compilation and WEMU News Program GreenRoom

Washtenaw County CARD Site

Ann Arbor's Environmental Commission discussion with Evan Pratt the Water Resources Commissioner and Dan Bicknell (1-27-22)

https://michiganadvance.com/2023/03/27/energy-clean-water-and-pollution-top-list-of-environmental-priorities-for-house-dems/

See ACWG site pages EPA Superfund Option Details from CARD/ACWG.

Coalition for Action on Remediation of Dioxane (CARD), Scio Residents for Safe Water (SRSW.ORG) and Allen's Creek Group (ACWG.ORG) Had A Booth At the 2024 Earth Day Event at the Leslie Science and Nature Center

CARD Group and ACWG had a booth at the recent Earth Day Event at Leslie Science and Nature Center.

Roger Rayle, Rita Loch Caruso and Vince Caruso staffed the booth Sunday afternoon 1-4pm.

Unfortunately, again, we did not have the Mayor come by or a council member at the Earth Day Event.

Roger Rayle and Rita Loch Caruso Setting Up the Booth

(ACWG; Rt Clk for larger)

Roger Rayle With a UM Graduate Student Working the Booth Showing Earth's Limited Clean Fresh Water Resources

(ACWG; Rt Clk for larger)

Rita with Kids at Our Kids Table to do Some Coloring of the Water Cycle

(ACWG; Rt Clk for larger)

We had lots of folks stopped by. We had a QRCode to hand out that had the link to the EPA Superfund Comment Page and almost all took the QRCode tag to make comment.

Environmental Commission's Presentation of the Gelman Plume and EPA Superfund Options In a Very Succinct Presentation With Rita Mitchel Chair of EC, Resident Dan Bicknell Former US-EPA Superfund Site Manager and Roger Rayle CARD Chair and Scio Twp.

EC Presentation April 25, 2024

Gelman 1,4 Dioxane Toxic Dump Site and EPA Presentation

EC Screen Shot (ACWG; Rt Clk for larger)

Rita Mitchell, Chair of EC, presented Roger and Dan's evaluation of the Gelman 1,4 Dioxane Toxic Dump Site and EPA very likely listing on the NPL. This presentation will give a great idea of the problems we as a community are facing. Lots of detail well done in a short amount of time.

One of the best presentations of our current issues we will need to deal with on the Gelman site and EPA Superfund Process.

See it on YouTube.

Links:

Link to start of Meeting https://www.youtube.com/watch?v=T11KuEAC3sI

Link to the start of the Gelman presentation https://youtu.be/T11KuEAC3sI?t=841

17 Story Church St. Proposal, Another 17 Million Pounds of Carbon Emissions, Isolation of Residents, For Ill Conceived Building, City Planning Votes Against, Follow the Money! Paris Has Over Twice the Density of NYC With Low Rise Buildings!

Proposed 17 Story Building On Church St.

(LV Collective; Rt Clk for Larger)

On May 6th City Council will have a Public Hearing on this building proposal.

Low-Rise Paris has well over twice the density of NYC without huge carbon emitting High-Rise buildings.

Low-Rise Paris, The French capital, has 56,000 people per square mile while NYC, the most densely settled U.S. metropolis, has only 27,000 people per square mile.

Just the 20 story concrete and steel building's enormous Carbon Footprint is about 20 million pounds of carbon into the atmosphere for just the concrete and steel alone, not including all the actual construction-related carbon emissions, which is also considerable!

"Cement emits as much CO2 as India (the whole country)" Washington Post June 27, 2023. Ann Arbor is pushing taller concrete buildings as a "Mantra" to Developers, Real-Estate Interests, U of M and political campaigns. with total disregard for Climate Change.

From the Washington Post Article:

"The cement industry is responsible for 8 percent of global carbon emissions -- triple the emissions of the aviation industry. And making all that concrete also emits an enormous amount of carbon dioxide.

Not only does the carbon dioxide from the reaction spill into the atmosphere, but cement producers also use huge amounts of coal or natural gas to heat the kiln." (bold by us)

Not Much of a Very Meaningful Carbon Reduction Plan

The City of Ann Arbor generates about 1/2 M tons of carbon a year, so one 20-story concrete and steel building is equivalent to 40 years of city emissions, so for the next 40 years you will double our carbon emissions just for one building, for what.

Low-Rise Building will house over twice the number of residents than high rises, cost less, and don't produce enormous amounts of Climate Changing Carbon Emissions, don't isolate residents, don't have huge Heat Island, are not incredibly inefficient!

Well made Low-rise buildings can be made out of Michigan wood and sequester carbon for centuries.

It seems clear this building frenzy is all about Out of Town developers making a lot of money and political campaigns getting lots of money, and totally ignoring Climate Change and our quality of life!

Even the City planning staff and Planning Commission both recommended voting it down!

More details in our ACWG previous Feb. 2024 entry - City of Ann Arbor Pretends to Care About Climate Change and Carbon Emissions, Yet Is Pushing Hard To Support More High-rise Buildings That Each Emit Millions Of Pounds Of Carbon to Build and are Very Inefficient Which is Effecting Climate Change.

On May 6th 7pm City Council will have a Public Hearing on this building proposal.

April 2024, Special Update:

EPA Announcement:

EPA Proposes to Add Gelman Sciences Inc. in Ann Arbor, Michigan to Superfund National Priorities List Opens Comment Period

The Comment Period Ends May 6th, 2024

EPA Superfund Contact Information

Danielle Kaufman (kaufman.danielle@epa.gov)

312-764-2234

Use the information below to enter a comment, we hope, supporting a full EPA cleanup paid for by the responsible party, which we do have in this case.

Generally a personal Comment Entry caries much more weight than lots of form letters. For EPA public Comments do make a big difference.

Thanks to those who have already entered comments and those who will submit comments to EPA.

! Link to Comment Page for EPA Gelman Toxic Dump Site Cleanup for A Comment Entry:

https://www.regulations.gov/commenton/EPA-HQ-OLEM-2024-0067-0001

(Plain Text entry of Comments only; Attachments are allowed on this page also)

Other EPA Gelman Links:

Link to Comments Submitted:

https://www.regulations.gov/docket/EPA-HQ-OLEM-2024-0067/comments

Tips for Effective Comments:

https://www.epa.gov/dockets/commenting-epa-dockets

Link to EPA Gelman Home Page:

https://www.epa.gov/mi/gelman-sciences

Gelman EPA Site With Links to Comments Entered, and Browse Documents:

https://www.regulations.gov/docket/EPA-HQ-OLEM-2024-0067/document

Here is the ACWG Summited Comments and my Personal Comments from CARD on EPA Superfund Option:

Strongly support the proposed Gelman 1.4 Dioxane Toxic Dump Site be added to the US-EPA Superfund National Priorities List as soon as possible!

The Danaher/Gelman 1,4 Dioxane groundwater pollution is degrading our pristine natural freshwater resource and causing health effects, and likely deaths over the many decades due to exposures of 1,4 dioxane.

Contaminated groundwater’s liquid to vapor exposure in basements is a real issue for us. Our article on this

danger is here and elsewhere - https://www.sciencedirect.com/science/article/abs/pii/S2468584422000812

The EPA scoring process does not include VAPOR EXPOSURE with the water intrusion and evaporation to explain why there is the potential for vapor phase exposure, and thus a GREATER HAZARD SCORE . (see article listed above)

Our article recently published “Michigan's Gelman Site 1,4-Dioxane Groundwater Contamination: Still Spreading Decades after Detection” speaks volumes of the toxic dangers.

https://www.sciencedirect.com/science/article/pii/S2468584422000800

150 ppb in Near Surface Shallow Groundwater is a real concern for exposure, and 100 ppb may be an issue with more data and analysis study.

We asked EGLE to test and have found 49 ppb in near surface shallow groundwater in West Park on Ann Arbor west side.

Drinking Water Wells exposed to 1,4D, in past years it has been in the 100,000s ppb.

Groundwater may have 2M ppb in the west Ann Arbor area with very limited data collected, potentially to avoid disclosure. We have asked for test well drilling to go to bedrock with very few wells to bedrock.

Gelman used spray irrigation to try to dispose of the 1,4D which exposed many residents downwind.

Ann Arbor does not have UNLIMITED clean drinking water and is getting closer to the limit with significant development in recent years. We need to protect our local drinking water sources from toxic chemicals like the Gelman Danaher 1,4 Dioxane Plume. We need to protect our local drinking water sources which will save our community Hundreds of Millions in costs to replace it, even if it is available.

CARD members and others have made comments to elected officials in Town Hall Meetings and EGLE on many occasions that the 7.2 ppb standard for the state is too high and needs to be more in line with EPA and EWG.ORG recommendations which is .35 ppb in drinking water.

Recent Allen’s Creek Watershed Group (ACWG.ORG) Meeting Agenda Items and Updates Site. ACWG.ORG active in Ann Arbor since the mid-1990s.

https://sites.google.com/site/allenscreekwatershedgroup/recent-acwg-meeting-agenda-items-and-updates?authuser=0

We have a responsible party in this case and we need the EPA to instruct them to do a Full Cleanup ASAP!

Vincent Caruso, Ann Arbor, MI

Founding and ExCom with Coalition for Action on Remediation of Dioxane (CARD), Founding and Coordinating Member Allen's Creek Watershed Group (ACWG.ORG), Former Sierra Club Huron Valley Group MI ExCom

March 2024, No Meeting this Month due to COVID-19 Pandemic Cautions

Watershed Issues of Interest and Updates:

A Long Overdue EPA Superfund Effort Could Happen in Less Than 2 to 3 Years for the Gelman Toxic Dump Site In Ann Arbor Area Now That the EPA Has Added Gelman Superfund to the National Priorities List (NPL)

Coalition for Action on Remediation of Dioxane (CARD) will not meet in April this year do to travel schedules.

EPA will very likely take over this polluted Gelman site and cleanup the contamination to federal standards.

This much championed EPA action over many decades will now have great outcomes for homes and businesses on well water and help protect Ann Arbor residents from basement exposures of contaminated groundwater in basements with potential health effects! Ann Arbor water source, Barton Pond, will also be positively effected. Along with health effects economic outcomes will be very significant.

Health Effects Studies:

Vasilis Vasiliou Ph.D. Chair Yale University and Lead Scientist of the "Yale EPA Superfund Research Center to Investigate Water Contaminants Linked to Cancer". A new, October 2022, Superfund Research Center (SRC) at Yale will conduct an extensive analysis of emerging water contaminants that have been linked to liver cancer.

"Yale’s research will focus on a contaminant known as 1,4-dioxane (1,4-DX) because of its common occurrence in Superfund sites and drinking water supplies."

Rita Loch-Caruso Ph.D. has been asked, and has accepted an External Advisory Board Member position on the Yale US EPA Superfund Grant. Rita in past decades was the Primary Investigator on a US EPA Superfund Grant on Toxins and Pregnancy Outcomes at U of M SPH Ann Arbor.

At the March CARD meeting I asked EGLE representative Chris Swoboda PhD Geologist for Environment, Great Lakes and Energy (EGLE), generally how long will it be before EPA takes over this site and starts a full cleanup. He said generally 2-3 years.

EPA indicated to CARD in past meetings that the findings 1, 4 Dioxane in the Near Surface Groundwater (NSG) from West Park were a major reason EPA would take over the site if the follow up data of NSG in the West Park Area is found to be consistently contaminated, and it has.

The ACWG pushed hard for NSG tests in West Park because Gelman would not do NSG tests with NSG wells in the area. ACWG knew that West Park had high water flows which we said were almost certain groundwater flows, even in drought conditions. We said that should be tested and Gelman could not object to it. EGLE did the tests during drought conditions, as we asked, and found unexpected high levels of 1,4 Dioxane, up to 49ppb, which was enough for EPA to move to a Superfund effort and approval to ask the Federal Government get involved in the cleanup.

The EGLE Prohibition Zone for the Gelman Toxic Plume does not allow movement of the plume to the surface, which we now have.

We now also have drinking water wells at risk in the townships showing low levels of 1,4 dioxane which also is a major reason for a EPA Superfund cleanup.

As we have said in the recent past Ann Arbor does not have unlimited clean drinking water and is getting closer to the limit with significant development in recent years. We need to protect our local drinking water sources from toxic chemicals like the Danaher 1,4 Dioxane Plume. We need to protect our local drinking water sources which will save our community Hundreds of Millions in costs to replace it, even it is available.

As I commented at the last CARD meeting I said that the Ann Arbor City officials did not approach the CARD Group with planning to do NSG tests in the West Park area. The tests that were done were to far up hill to the west while we have known that much NSG exist in the lower West Park area. More funds wasted unfortunately. City testing home's basements were also to far up hill given our current NSG data.

The CARD group have peer review article on NSG basement exposure showing 100-150ppb in basements is a real concern relating to vapor intrusion inhalation. We have recent NSG tests showing 49ppb in West Park. See publications at the December 2023 ACWG Update Page shown above.

EPA will likely force the polluter to pay for a cleanup before the State of Michigan re-instates the Polluter Pay Legislation and go after Danaher (Pall/Gelman), a $180 Billion company, to cover the cleanup costs. This is why EPA Superfund is our best hope of a faster cleanup.

CARD members and others have made comment to elected officials in Town Hall Meetings and EGLE on many occasions that the 7.2 ppb standard for the state is to high and needs to be more in line with EPA and EWG which is .35 ppb.

The Majority on City Council and Mayor have Shown Little Interest in the Gelman Toxic Waste Plume

The Majority on City Council and Mayor have shown little interest in the Gelman Toxic Waste Plume over decades. The Mayor has never attended a CARD meeting that anyone can remember, and few of his supporters on Council have either. Some past council members attend regularly and do so now after they have left office. YouTube Nov. 5, 2020 video location in City Council when Majority voted to support EPA Superfund, Mayor and his supporters vehemently argued against it and the lost the vote.

The Mayor and his supporters obstructed the effort to bring EPA Superfund to the Gelman Toxic Plume at every turn for years and his predictors as well. It would seem the UM, developers, real-estate interests who pressured the city to not have the stigma of a Superfund (until they leave office and leave town with big bank accounts) were more important than residents of the community facing the real and present danger from the Plume, leaving Ann Arbor in the Lurch.

Many new exposures are happening now that could have been avoided, with the commensurate health effects.

It is clear that EPA Superfund is the only hope we have to try to deal with this Gelman Toxic Plume flowing in every direction.

EPA Superfund will take on the Gelman Toxic Plume, stop the flow to wells, to the Huron River and Barton Pond, west side basements like no other entity we can turn to and Gelman/Danaher will pay for the cleanup and after effects.

Allen's Creek as a Conduit for Gelman:

Allowing Gelman to use the Allen's Creek as a conduit for contaminated water to the Huron River creates new exposures to homes and businesses downstream in Ann Arbor and eastward via Vapor Intrusion and or direct contact, and negatively affects property values (Tax Base for Bean Counters!) due to these potential exposures.

MS4 Violation Still Occurring:

The Federal MS4 Violation in Allen's Creek Going on 5 Years and still not even started to be fixed: The CARD Group has unanimously passed a resolution asking for the illicit 1,4 Dioxane pollution flowing into the Allen's Creek Drain to be removed by Gelman. Gelman and EGLE have been notified of this for over 3 years, going back to 2019, with the illicit 1,4 Dioxane pollution levels in the drain generally going up. The ACWG pushed for and also supports the CARD resolution. No resolution of this MS4 violation has been reported at past CARD meetings regarding this US Federal Clean Water Act violation. Without more robust tests, as we have requested for many years, and passed a CARD resolution to that effect "10-5-21, NSG Wells Request, CARD Resolution", these simple tests are all we can get currently from our government officials, for some reason.

Michigan MS4 Permit:

'The MS4 permit is required to halt any illicit discharge into the storm drain. An “illicit discharge” is defined as any discharge to, or seepage into, an MS4 drain that is not composed entirely of stormwater or uncontaminated groundwater except discharges pursuant to an NPDES permit.' (bold by us)

Simple NSG Tests were ad hoc "let's look at see" Now Time to Act-On the Results:

It is our opinion that we support professional monitoring of the eastward migration of the plume through Ann Arbor. Sampling from storm drains was an ad hoc "let's look at see" approach that needs to be replaced by permanent monitoring wells. At a minimum, the wells should monitor at elevations shown to have significant dioxane concentrations upstream. Only then -- with solid data -- should we draw conclusions.

The simple drain tests that turned out to be positive and going up quickly (at least 49 ppb), were "Very Low Cost, Simple and Quick and Dirty" tests that now should be followed up on. EPA will do this in much more detail at some point, we should not wait for that.

All the groundwater seeps coming to the surface on the near west side are the reason why it is called Water Hill, and has Bath, Fountain, Spring Streets, ...

The EGLE prohibition zone does not allow movement of the plume to the surface, which we now have.

Links:

CARD Meeting March 2024; YouTube; https://www.youtube.com/watch?v=koL2H37fSjY

2023-06-28 GELMAN DIOXANE PLUME - COMMUNITY UPDATE FORUM

https://www.mlive.com/news/ann-arbor/2022/09/ann-arbor-spending-333k-for-more-wells-to-track-polluters-pollution.html EWG https://www.ewg.org/tapwater/reviewed-1-4-dioxane.php

https://www.mlive.com/news/ann-arbor/2021/11/in-letter-to-epa-dingell-calls-latest-ann-arbor-area-dioxane-news-alarming.html

EPA, EGLE and Local Government Joint Session on 3-18-21; YouTube link to the Video

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 details from Barbara Lucas at Dioxane.Org Compilation and WEMU News Program GreenRoom

Washtenaw County CARD Site

Ann Arbor's Environmental Commission discussion with Evan Pratt the Water Resources Commissioner and Dan Bicknell (1-27-22)