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May 2025

ACWG Meetings Will be on an Ad Hoc Basis 

Watershed Issues of Interest and Updates:

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

Recent past information from EPA sources is the Superfund designation would likely be in the Spring 2025. With all the changes with the new federal government it is not clear of the direction the EPA will go with the Gelman Toxic Plume.

We understand they are evaluating the site with the intent of declaring the site a Superfund site. Of course the unexpected election of the Convicted Felon Donald Trump may cause some issues for EPA and their planning.

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. also called shallow groundwater) 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.

EPA commented in recent past that the finding of NSG contamination with potential basement exposure to a large number of West Side homes issues were a big factor in moving to create and implement a Super Fund Site for the Gelman Plume. Vince Caruso (ACWG) asked EGLE to do tests in West Park that turned out to be showing 1,4 Dioxane in NSG. 

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 city and state did not want to do shallow groundwater wells in the park for some reason. This data was a major reason EPA decided to do a Superfund Site for the Gelman Plume. Large pipes carry Allen's Creek flows. Tests are done in dry conditions to get the best samples to analyze for contaminates especially 1,4 dioxane.

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 

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

New information from EPA sources is the Superfund designation will likely be in the Spring 2025.

We understand they are evaluating the site with the intent of declaring the site as a Superfund. Of course the unexpected election of the Convicted Felon Donald Trump may cause some issues for EPA and their planning.

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.

Recent Planning meeting YouTube:  "Agresta Comprehensive Land Use Plan" https://www.youtube.com/watch?v=aji-mBuqB0Y

Vince Caruso also made comment to Planning Commission on the Comprehensive Land Use Plan on 5/13/25 Link. The turnout was significant and supporters of disallowing this proposed plan were equal or better than the supporters.

Link to YouTube video of my comments. and view other comments.

Written Comments Summited to Planning Commission and Council:

Ann Arbor Planning Board Members,

Water supply limits, cost and water quality -  this may be the strongest argument in the issue of Condos Everywhere in Ann Arbor

Can Ann Arbor supply clean drinking water with the home increases proposed?  No, according to the City of Ann Arbor in 2023. See below.

We do not have easy access to large amounts of fresh drinking water in this area. Detroit water, Great Lakes Water Authority (GLWA), is not a viable option for several reasons, not least of which is the very poor water quality that GLWA relies on for what would have been water for Ann Arbor and Scio Twp. The city council roundly rejected the GLWA drinking water source in 2023 after several commented to city council on this issue. Dr. Rita Loch-Caruso (Professor Emeritus U of M SPH and LSA, ACWG, CARD. Michigan Public Health Advisory Council Member) and Dan Bicknell MPH (who first found the pollution at the Gelman Site and long-time follower of Gelman Pollution) and others in ACWG commented.

City utility staff did not support the GLWA switch for Ann Arbor drinking water in reports to City Council yet many on council including the mayor ignored the concerns. 

Black and Veatch Consultant's 2015 Report and the  city staff recent report not to pursue GLWA.

We have high quality drinking water from the Ann Arbor Water Treatment Facility. If we move to the Great Lakes Water Authority, we trade local control of high quality water testing, treatment, and service for water with higher levels of chemical contaminants, greater risk for future contamination, and more unwanted chlorination.

Having control of drinking water is a critical issue for communities. City staff stated that directly at the time.

With potential well contamination of township homes from the Gelman plume we will need to supply water to these residents. Ann Arbor must supply this water due to federal agreements when the treatment plants were built with partial federal funding.

Costs to use GLWA/Detroit water are much higher than Ann Arbor $355 million to connect to Detroit’s water system, and only $110M to upgrade Ann Arbor water plant.

GLWA was chastised by international bodies for cutting off water to low income homeowners in recent years.

Dr. Rita Loch-Caruso (Founding Member of CARD and ACWG, and Founding and Chair Member of City of Ann Arbor's Environmental Commission, founding and 13 year member, and Michigan Public Health Advisory Council Member) commented at the Council Work Session on why we should not switch, with water quality, costs and sustainability issues at the intake of the GLWA for YCUA.

I did discuss these concerns with Brett Lenart, (City Planning Director) and left written comments at the Planning Event at the recent West Gate Library meeting regarding these issues.

More details at ACWG.ORG on Updates Page, search “GLWA” 

Additionally:

Headlee Amendment Tax changes proposed by the city, trying to change state law, will force more folks out of houses, increase taxes, push lower income residents out of the city. Currently generally property tax changes follow the current inflation rate in Michigan. This generally allows folks from being taxed out of their homes as was the case before Headlee. 

Link to March Meeting:  https://www.youtube.com/watch?v=aji-mBuqB0Y

Link to Comments at May 13: Link to YouTube video of my comments.

415 W. Washington Lot Very Dangerous Development Considered for a Long Time for Residential Building, Some Low Income Residents

Comments below should give city leaders and residents pause.

Ann Arbor Observer Nov 16, 2021

'Jerry Hancock sees bigger problems if the building impinges on the floodplain. “If they build there, it will just increase the floodplain in other areas, causing property damage and a safety risk,” he explains. Since the city owns the site, he says, it has an “opportunity to plan a resilient use that mitigates the [existing buildings’] development impact and considers future flood conditions.

Five years later, the city hired architect Marc Rueter to do an evaluation of the main building. Because it’s in the floodplain, it couldn’t be used for housing.'

(bold by us)

A former high ranking knowledgeable city staffer commented to me at a recent meeting that 415 will never have a building on this site due to the major flood hazard for any use except a city park for the long supported Allen's Creek Ann Arbor Greenway.

More details in past entries on 415 unsuitable building site, with FirstStreet up to date flood maps.

Earth Day Booth With Scio Residents For Safe Water, ACWG, and CARD Group

We had great weather for Earth Day at Lesley Science Center. We discussed and answered questions about the Gelman contamination and other drinking water issues with many fair attendees.

Unfortunately, again, we did not see the mayor or council members at the Fair or stop by our booth to discuss Gelman or other issues.

Stormwater Comprehensive Plan (SWAG) Has Recently Begun (First Ever Ann Arbor)

 T(he ACWG has been asked to join the SWAG effort to improve stormwater, protect Ann Arbor from stormwater flooding and pollution. Vince Caruso has been asked to represent ACWG.ORG on SWAG and has had over 40 years working on watershed issues in the area. (our typo corrected)

"This project will incorporate and align all existing plans and studies into a single, comprehensive plan. This plan will provide a cohesive philosophy to guide staff, inform decisions, and incorporate resiliency and climate adaptation strategies as key elements in future decision-making and design.

The goal of the City of Ann Arbor Comprehensive Stormwater Management Plan public engagement is to gather input, raise awareness, and build support for Ann Arbor’s stormwater management initiatives as well as to help in the reprioritization of existing level of service principles, as this needs to be a plan that guides the future growth and advancement for all residences of Ann Arbor.

The City and its consulting team will provide various ways to engage with the plan including: public meetings, working groups, and presentations."  Ann Arbor

The program will run about a year before the reports are released.

The ACWG produced the Allen's Creek Watershed Management Plan adopted by county and city 2001.

Link to SWAG Site: https://engage.a2gov.org/storm-water-comprehensive-plan

Link to a U of M Online Storage of the Allen's Creek Watershed Management Plan 2001: https://public.websites.umich.edu/~sarhaus/creekshed/allens.html

"Gelman site's future is unclear as Trump proposes EPA cuts"; Michigan Public

Michigan Public | By Elinor Epperson

Published May 29, 2025 at 5:00 AM EDT

Top of the story by Elinor Epperson:

"Locals have been pushing for more aggressive solutions to the Gelman plume since a University of Michigan graduate student discovered it in 1984.

But Gelman is not required to clean up the plume. Instead, the state and Gelman manage the contamination through a decades-old legal agreement. Locals don’t have any direct input in what that looks like."

Locals have been pushing for more aggressive solutions to the Gelman plume since a University of Michigan graduate student discovered it in 1984.

But Gelman is not required to clean up the plume. Instead, the state and Gelman manage the contamination through a decades-old legal agreement. Locals don’t have any direct input in what that looks like.

Advocates hoped that intervention from the U.S. EPA would bring the change they had been fighting for. But the agency’s future under Trump’s second administration is unclear."  Elinor Epperson, Michigan Public

This article has extensive reporting on the Gelman plume and the effects it is having on this region. Several members of the community are interviewed as well EGLE and EPA.

Elinor Epperson has two additional articles on Gelman pollution on the same page as the one discussed here.

Great article with lots of details and deep investigation into the Gelman debacle. 

“A really unique aspect of this site is just the community involvement that's been around this site for decades prior to EPA's involvement,” he said. Citizens usually get involved in a Superfund site after it has been added to the National Priorities List, not before, he said." Anthony Mcglown, the EPA remedial project manager for the site

Rita Loch-Caruso PhD professor emeritus of toxicology at the University of Michigan, ACWG, CARD and Michigan Public Health Advisory Council Member was interviewed among other local government officials and citizen scientists.

Links to Elinor Epperson's Michigan Public Articles:

Gelman site's future is unclear as Trump proposes EPA

The Gelman plume: Questions about health effects

Stateside Podcast: The Gelman plume's long legacy of contamination

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. Large pipes carry Allen's Creek flows. Tests are done in dry conditions to get the best samples to analyze for contaminates especially 1,4 dioxane.

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. See previous entries on this site in recent past for more details. Township homes in the Ann Arbor area also have neighborhoods with wet basements and could pose a problem of potential basement exposures.

NSG Tests in West Park Area Nov. 26, 2024:

Results show some lowering and some going higher in the NSG tests EGLE did in late 2024. Seems clear the plume is slowly moving north and west, and likely south as well. The West Park pond has shown contamination in low numbers 2.2 ppb but is significant that it is near the surface and has been increasing. The tests on 8th Street near Slawson Middle School had continually increased now at 22 ppb at the west side street storm drain and near the surface. 

The YALE Toxicology Program continues working on the 1,4 Dioxane from several angles including several health effects studies. The current NIH Funding Grant was cut as was most if not all NIH grants. They will be summitting to the Federal Government for renewed funding. Dr. Rita Loch-Caruso, retired Professor Toxicology at UM-SPH and ACWG, CARD Board Member, is one of many on their External Advisory Board and has attended meetings at Yale to discuss efforts on 1,4 dioxane and advising on issues of toxicology in humans including research suggestions. She will be going out to Yale again this spring to discuss research options.

There has been some discussions on 100 ppb at CARD meeting regarding liquid to vapor intrusion in basements. Analysis is continuing at various levels. We have had 49 ppb in West Park Allen's Creek where there are many homes with wet basements in this area, and other locations near by at lower concentrations. Currently 150 ppb is considered a target value but some toxicologists feel 100 ppb may well be a meaningful limit target for exposure, this with West Park hitting as high as 49 ppb in recent years.

The city of Ann Arbor is still "Dragging Their Feet" on doing testing around the West Park area regarding near-surface groundwater (NSG).  The concern we have and scientist have with contaminated NSG getting into basements and expose residents. The city had said they would do these in home tests east of West Park but did the tests up a large hill to the west, for some reason, where there is much less exposure potential, something we did not support.

EPA commented in recent past that the finding of NSG contamination with potential basement exposure to a large number of West Side homes issues were a big factor in moving to implement a Super Fund Site for the Gelman Plume.

The eventual cleanup of the Gelman/Danaher Toxic Waste site in Scio Township, Ann Arbor Township and the City of Ann Arbor 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 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 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 late 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.

Links:

CARD Meeting January 2025; YouTube;  https://www.youtube.com/watch?v=amoGl7sLUb8  

CARD WC: YouTube link to CARD Meeting videos

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

Scio Twp Gelman Plume Townhall 2-17-2022

https://www.mlive.com/news/ann-arbor/2022/09/ann-arbor-spending-333k-for-more-wells-to-track-polluters-pollution.htmlEWG 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  

Gelman Plume Related Stories by Ann Arbor News/MLive: MLive

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)

EWG Review of 1,4-Dioxane in Tap Water

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

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

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

 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.

Mass Timber Construction Proposed 8-Story Apartment Shelby House on Ann Arbor's west side at 2452 W. Stadium Blvd.

This design for proposed building is a mass timber construction which uses much less major carbon emissions from the use of concrete and steel as we currently have at near about 100% of new buildings in Ann Arbor.

If this was a standard "Bad" construction building plan it would have emitted:  

Just the 8 story concrete and steel building's enormous Carbon Footprint is about 8 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!

Glad to see the use of wood (Michigan wood?) to build lower rise buildings. As we have stated in previous posts, 4 or 5 stories would be much better for the community.

The city needs to standardize to mass timber construction for all new buildings with low rise design.

https://www.mlive.com/news/ann-arbor/2025/01/8-story-mass-timber-housing-development-proposed-on-ann-arbors-west-side.html

August 2024, No Meeting this Month, 

ACWG Meetings Will be on an Ad Hoc Basis  

Watershed Issues of Interest and Updates:

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

No new information from EPA on the status of the Superfund designation. We understand they are evaluating the site with the intent of declaring the site as a Superfund in the next year or so. 

The YALE Toxicology Program is working on the 1,4 Dioxane from several angles including several health effects studies. The current NIH Funding Grant was cut as was most if not all NIH grants. They will be summitting to the Federal Government for renewed funding. Dr. Rita Loch-Caruso, retired Professor of Toxicology at UM-SPH and ACWG, CARD Board Member, is one of many on their External Advisory Board and has attended meetings at Yale to discuss efforts on 1,4 dioxane and advising on issues of toxicology in humans including research suggestions.

There has been some discussions on 100 ppb at CARD meeting regarding liquid to vapor intrusion (LVI) in basements. Analysis is continuing at various levels. We have had 49 ppb in West Park Allen's Creek where there are many homes with wet basements in this area, and other locations near by at lower concentrations. Currently 150 ppb is considered a target value but some toxicologists feel 100 ppb may well be a meaningful limit target for exposure.

The city of Ann Arbor is still "Dragging Their Feet" on doing testing around the West Park area regarding near-surface groundwater (NSG).  The concern we have and scientist have with contaminated NSG getting into basements and expose residents. The city had said they would do these in home tests east of West Park but did the tests up a large hill to the west, for some reason, where there is much less exposure potential, something we did not support.

EPA commented in recent past that the finding of NSG contamination with potential basement exposure to a large number of West Side homes issues were a big factor in moving to implement a Super Fund Site for the Gelman Plume.

The eventual cleanup of the Gelman/Danaher Toxic Waste site in Scio Township, Ann Arbor Township and the City of Ann Arbor 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.

Links:

CARD Meeting October 2024; YouTube; https://www.youtube.com/watch?v=amoGl7sLUb8  

CARD WC: YouTube link to CARD Meeting videos

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

Scio Twp Gelman Plume Townhall 2-17-2022

https://www.mlive.com/news/ann-arbor/2022/09/ann-arbor-spending-333k-for-more-wells-to-track-polluters-pollution.htmlEWG 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  

Gelman Plume Related Stories by Ann Arbor News/MLive: MLive

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)

EWG Review of 1,4-Dioxane in Tap Water

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

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

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

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

"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.

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

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

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

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!

Please Vote In the 2024 November 5th Elections!

Vote including Fair Elections, Nonpartisan vote. 

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 an 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?

CARD WC: YouTube link to CARD Meeting videos

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

Scio Twp Gelman Plume Townhall 2-17-2022

https://www.mlive.com/news/ann-arbor/2022/09/ann-arbor-spending-333k-for-more-wells-to-track-polluters-pollution.htmlEWG 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  

Gelman Plume Related Stories by Ann Arbor News/MLive: MLive

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)

EWG Review of 1,4-Dioxane in Tap Water

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

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

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

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 

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

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  

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

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

CARD WC: YouTube link to CARD Meeting videos

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

Scio Twp Gelman Plume Townhall 2-17-2022

https://www.mlive.com/news/ann-arbor/2022/09/ann-arbor-spending-333k-for-more-wells-to-track-polluters-pollution.htmlEWG 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  

Gelman Plume Related Stories by Ann Arbor News/MLive: MLive

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)

EWG Review of 1,4-Dioxane in Tap Water

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

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

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.

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. 

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!

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

CARD WC: YouTube link to CARD Meeting videos

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

Scio Twp Gelman Plume Townhall 2-17-2022

https://www.mlive.com/news/ann-arbor/2022/09/ann-arbor-spending-333k-for-more-wells-to-track-polluters-pollution.htmlEWG 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  

Gelman Plume Related Stories by Ann Arbor News/MLive: MLive

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)

EWG Review of 1,4-Dioxane in Tap Water

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

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

Glendale Circle Area's FairGlen Neighborhood Owned Woodland, With One of the Few Remaining Open Sections Of  the Allen's Creek, Will Be Getting Long Overdue Upgrades With One Goal to Improve Water Quality  

The city is starting to restore one of the few open sections of the Allen's Creek in the FairGlen Private Commons in our neighborhood on Glendale Circle and Liberty St.

Options to create rain/storm water improved water quality and that is cleaner than what entered the FairGlen Commons will be a major portion of the potential work.

Extensive sediment build up will need to be removed to restore the mechanisms to reduce the current high flows causing erosion in the creek.

A resident in Fair Glen has built and modified a Makeshift retaining wall that city staff commented it "Needs to Come Down". The ACWG has been asking the city for decades to fix this dangerous condition.

The fabric cloth used in the creek with large rocks and chain-link wire sheets was installed backward catching flows and causing excessive erosion not preventing erosion. Obviously city staff and contractor oversite was greatly lacking during the $1/2 Million construction project.

Allen's Creek's Few Open Part sections is in our Neighborhood Private FairGlen Commons, was Buried Costing About $1/2 Million City Tax Payer Dollars. A terrible example of Ann Arbor's ongoing treatment of streams is the upper Allen's Creek which was piped due to very poor planning allowing development just up to the open creek bank on Liberty Road on a very steep slope.

Wendy Ramson a city staffer at the time told me don't worry, that site would never be developed because of the very steep slope and creek location. A development went in anyway. Bulldoze a private woodland and Bury another creek and install a 8'x5' corrugated pipe in Ann Arbor was the result with higher flood hazard and higher taxes because D.W. White Builder did not have to pay for the damage, he had a Ann Arbor City Building Permit, for some reason and tax payers paid the cost. We lost over 7 landmark trees in this project and were told by city staff we would get extra Penalty Trees as a result of the loss of Landmark Trees for the woodland but that never happened. The utility director moved on to Detroit after this project was finished.

USA-EPA states the most effective way to improve streams is to daylight them.

High flows have been lessened with the use of several Swirl Concentrators which capture debris and hold back some water in high flow events.

With significant flows in large rain events flood hazard is a real concern with many homes down stream not much higher than the 100 year floodplain.

With NSG tests in recent years EGLE did include yearly tests in the area including FairGlen Commons in the open section of the creek and found no significant pollution in those tests, ACWG pushed to have these tests with the others like in West Park area.

Porous Pavement Has Great Potential To Reduce Flooding, Protect Ground and Surface Waters; More Use of Porous Would Be Very Beneficial and Cost Savings

Maine has had good results on roadways and parking areas using porous pavement over many years. A 2019 report of their Green Infrastructure States:

"Observations:

o Project holding up well after nine + years of service

o Localized raveling – primarily at construction joints

o Patching around the mall entrance – most likely due to tracking sand / salts onto porous section

o Maine DOT very satisfied with the performance thus far" 

(bold by us)

Portland credited the porous Mall Road as a major reason for quickly restoring a nearby creek that had lost most of its quality. Not long after the road install the creek rebounded and again started to act like a living creek flowing through the city to the Atlantic Ocean.

The city of Ann Arbor and U of M have tried porous pavement on roads and parking lots and generally seem to be holding up well as we have commented on in the recent past. It would be cost effective and environmentally beneficial to use more of this paving technology.

FEMA's (Federal Emergency Management Agency) maps show that areas near rivers, streams and lakes — much of Michigan — tend to have higher risk even before concerns about infrastructure and changing weather patterns, a Detroit News analysis of floodplains shows. DetNews

Links:

https://www.njdottechtransfer.net/wp-content/uploads/2019/06/Luce_Maine_NJDOT-Green-Infrastructure-6-5-2019.pdf

ACWG Benefits of Porous Pavement on our website (https://sites.google.com/site/allenscreekwatershedgroup/benefits-of-porous-pavements-acwg)

https://www.detroitnews.com/story/news/local/detroit-city/2024/03/08/fema-releases-738k-to-study-sewer-upgrades-in-detroits-jefferson-chalmers-area/72899901007/#:~:text=Much%20of%20Metro%20Detroit%20sits,News%20analysis%20of%20floodplains%20shows.

March 6, 2024,  Special Update: 

EPA Announcement:

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

The comment period begins March 7

March 5, 2024

Contact Information

Danielle Kaufman (kaufman.danielle@epa.gov)

312-764-2234

CHICAGO (March 5, 2024) -- Today, U.S. Environmental Protection Agency proposed to add Gelman Sciences Inc., which spans portions of the city of Ann Arbor and Scio Township in Washtenaw County, Michigan, to the Superfund National Priorities List. The NPL is a list of sites throughout the United States and its territories where historical releases of hazardous substances, pollutants or contaminants pose significant threats to human health and the environment. A 60-day public comment period begins March 7."  

“Including the Gelman Plume on the National Priorities List is critical to bringing federal priority and resources to help finally end this decades-long nightmare for the residents of Ann Arbor, Scio Township, and the surrounding communities. "  said Rep. Debbie Dingell.

Link to EPA Full Online Statement:

https://www.epa.gov/newsreleases/epa-proposes-add-gelman-sciences-inc-ann-arbor-michigan-superfund-national-priorities

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

Watershed Issues of Interest and Updates:

City of Ann Arbor, Scio Township and Ann Arbor Township, CARD and ACWG Request Gelman/Danaher National Pollutant Discharge Elimination System - USEPA (NPDES) Permit Cleanup With More Stringent Protection for Drinking Water, Creeks, Wetlands and Huron River 

"The Coalition for Action on Remediation of Dioxane (CARD) has significant concerns regarding NPDES Permit MI0048453 (v8.0) for discharge from the Gelman Sciences/Pall Life Sciences treatment facility. We urge EGLE to address these concerns before authorizing the permit." CARD Group 

This permit can have significant effects on drinking water, creeks, wetlands and the Huron River if EGLE does not strengthen the permit Gelman/Danaher are looking to use for many years to come.

The renewal of this permit has Dragged on for over 4 years and is time to promulgate meaningful protection to the Townships and Ann Arbor.

The NPDES Permit MI0048453 (v8.0) link is shown below  and full text of the CARD comments and demands.

NPDES CARD SUMISSION Feb 22, 2024:

The Coalition for Action on Remediation of Dioxane (CARD) has significant concerns regarding NPDES Permit MI0048453 (v8.0) for discharge from the Gelman Sciences/Pall Life Sciences treatment facility. We urge EGLE to address these concerns before authorizing the permit.

CARD Submission:

Jessica Stiles;  Environmental Quality Analyst; Storm Water Permits Unit; Permits Section | Water Resources Division Michigan Department of Environment, Great Lakes, and Energy

stilesj1@michigan.gov Date: February 22, 2024

Re: Comments on Proposed National Pollutant Discharge Elimination System (NPDES) Permit MI0048453 v8.0 for Discharge from the Gelman Sciences/Pall Life Sciences Treatment Facility 

Dear Ms. Stiles:

The Coalition for Action on Remediation of Dioxane (CARD) has significant concerns regarding NPDES Permit MI0048453 (v8.0) for discharge from the Gelman Sciences/Pall Life Sciences treatment facility. We urge EGLE to address these concerns before authorizing the permit.

Key Concerns:

• No substantive updates despite prolonged EGLE review.  Although EGLE allowed the NPDES permit to expire in 2019 yet remain in effect while under EGLE review for over 4 years, the discharge allowances are unchanged and would allow Gelman to continue discharging 1,4-dioxane into the tributary of Honey Creek at a maximum monthly average 7 μg/L and a daily maximum of 22 μg/L.

• Failure to consider best available technology.  There is no indication that the permit process included a review of best available technology for removal of 1,4-dioxane from extracted contaminated groundwater, including more effective alternative technologies that the parent company, Danaher, has experience with and that reduce concentrations of 1,4-dioxane in extracted polluted water to less than 1 μg/L while eliminating or reducing bromate formation. The permit should be updated to incorporate more effective treatment technology and current risk assessments that are protective of human health and the environment, as detailed below.

• Unfounded industry compliance claims.  Instead of requiring additional and improved treatment operations, EGLE withdrew its initial proposal to limit 1,4-dioxane daily maximum discharge to 9.0 μg/L and retained the current daily maximum discharge limit of 22 μg/L. EGLE’s reversal was based on Gelman's complaint that stricter limits would hinder compliance with the 4th amended consent judgment requirement for more aggressive clean up. Specifically, Gelman argues that new extractions of highly contaminated groundwater have challenged and sometimes exceeded the Gelman treatment facility’s capacity to operate under the discharge limits for 1,4-dioxane and bromate of the current permit. The permit should base discharge limits on protection of drinking water and require that Gelman implement the best available technology to more effectively remove 1,4-dioxane from contaminated water. Minimally, the permit should limit daily maximum discharge of 1,4-dioxane to 9.0 μg/L, as initially proposed.

• Dilution is not the solution. The strategy applied by Gelman to comply with the 4th amended consent judgment and the current permitted daily maximum discharge should not be accepted because it is based on increased withdrawal of less contaminated groundwater to dilute the higher concentrations of 1,4-dioxane being withdrawn in the new extraction well. The permit should require upgrades to the treatment facility to treat extracted polluted water to less than 1 μg/L 1,4-dioxane and require discharge limits protective of the environment and public health. Minimally, the daily maximum discharge should be limited to 9.0 μg/L 1,4-dioxane.

• Insufficient protections for township drinking water wells. The draft permit fails to consider the impact on Scio Township residential drinking water wells from 1,4-dioxane discharged into the tributary of Honey Creek. 1,4-dioxane is detected in the tributary to Honey Creek and in the Honey Creek surface water. In hydrologic terms, Honey Creek is a “losing stream” in some sections, providing a mechanism by which 1,4-dioxane-polluted surface water could infiltrate groundwater aquifers and contaminate residential wells.  To fully protect homeowner wells from any dioxane seepage from Honey Creek and to minimize risks for human health and the environment, the permit should require treatment of 1,4-dioxane to less than 1 μg/L before discharge.

• Insufficient protections for the City of Ann Arbor drinking water intake at Barton Pond in the Huron River. The permitted discharge is into a tributary of Honey Creek and Honey Creek discharges into the Huron River upstream of the City of Ann Arbor drinking water intake at Barton Pond. It is unclear how the permit took into account that the Huron River provides approximately 85% of the City of Ann Arbor municipal water supply and 1,4-dioxane has been detected in Barton Pond and in Ann Arbor’s finished water on several occasions. The permit should provide increased protection of the Huron River as a source of municipal water for the City of Ann Arbor.

• Insufficient exposure and health risk assessment. EGLE fails to account for all potential exposure pathways, raising concerns about public health protection. A USEPA risk assessment indicated that drinking water contaminated with 3.5 μg/L 1,4-dioxane over a 70-year lifetime increases the risk of cancer by one in 100,000. Given the proximity to Honey Creek of shallow residential drinking water wells and the dependence on the Huron River as the major source of municipal water for the City of Ann Arbor, EGLE should limit 1,4-dioxane discharge to the achievable concentration of less than 1 μg/L to provide greater protection from exposure and human health risks.

• Discharge limits adjusted to fit current Gelman treatment capabilities. As we belatedly learned only from this proposed permit’s “Basis for Decision Memo,” EGLE adjusted its proposed 9.0 μg/L daily maximum 1,4-dioxane discharge to 22 μg/L to fit what Gelman's current treatment systems can handle. With the installation of purge well TW-24, Gelman discovered that its current treatment systems could not handle TW-24's high levels of 1,4-dioxane and still meet the existing permit discharge limits without reducing its purging of those higher levels of 1,4-dioxane. In other words, Gelman's current ozone/oxidation treatment technology was overwhelmed by the reality of its 1,4-dioxane problem at the core just like Gelman's original UV/oxidation system at Evergreen 1993-1999 was undersized for the magnitude of 1,4-dioxane that was making its way through Evergreen. In both cases Gelman failed to properly define the scale of the 1,4-dioxane problem and failed to implement changes to its treatment systems accordingly. EGLE should establish the proper 1,4-dioxane discharge limits based upon protection of drinking water and require that Gelman implement the best available technology to attain those 1,4-dioxane discharge limits –not the other way around. 

CARD strongly urges EGLE to revise the draft permit to prioritize public health and environmental protection, improve treatment technology, integrate current exposure and human health risk assessments, and ensure comprehensive protection for all potentially impacted communities. We suggest that by addressing the concerns and incorporating these recommendations, the permit can be strengthened to effectively safeguard public health and the environment.

CARD looks forward to a public hearing on this permit renewal where all aspects of the issue can be discussed.

Respectfully, Roger Rayle, Chair of the Coalition for Action on Remediation of Dioxane (CARD)

ACWG was involved in this submission and also sent supporting comments to EGLE on Feb. 22, 2024 with regards to this submission.

Fresh Drinking Water Is Not in Abundance in this region, We Need To Protect It From The Gelman/Danaher 1,4 Dioxane Plume:

Clearly their is real risk to hundreds of drinking water wells in Scio and Ann Arbor Twps that need to be protected. Barton Pond, which is 85% or more of Ann Arbor drinking water source is also at real risk.

Exposures to homes basements is also an real concern as 1,4 Dioxane has been detected at up to 49ppb in Near Surface Ground Water in Ann Arbor's West Park and also detected near Slauson Middle School and other nearby locations.

This NPDES permit is intended to protect fresh water source and improve the sources from contamination.

We do not have easy access to large amount of fresh drinking water in this area. Detroit water, Great Lakes Water Authority (GLWA), is not a viable option for several reasons not least of which is the very poor water quality the GLWA relies on for what would have been water for Ann Arbor and Scio Twp. The city council roundly rejected the GLWA drinking water source in 2023 after several commented to city council on this issue. Dr. Rita Loch-Caruso (Professor Emetaris UofM SPH and LSA, ACWG, CARD) and Dan Bicknell MPH (who first found the pollution at the Gelman Site and long-time follower of Gelman Pollution) and others in ACWG comment.

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.

Links:

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

CARD WC: YouTube link to CARD Meeting videos

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

Scio Twp Gelman Plume Townhall 2-17-2022

https://www.mlive.com/news/ann-arbor/2022/09/ann-arbor-spending-333k-for-more-wells-to-track-polluters-pollution.htmlEWG 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  

Gelman Plume Related Stories by Ann Arbor News/MLive: MLive

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)

EWG Review of 1,4-Dioxane in Tap Water

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

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

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

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

"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!

Add to this the demolition of Perfectly Good Low-Rise Buildings with their several million pounds Carbon Footprints.

It is more about pressure and campaign funding from developers, real-estate interests and U of M's morbid desire for mega profits building climate changing High-rises at great expense to the city, state and environment.

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.

New Gas Fireplace Mr Mayor?

Major Taylor expounds on how Ann Arbor must change and sacrifice to reduce carbon emissions at all costs. He then admits that he recently installed a gas fire place in his new home. Is it really about lowing carbon or more about pushing for tall buildings that greatly benefit the few out of town developers, real-estate interests and U of M at a great expense to the city.

Strangely Ann Arbor tall buildings are not being built to accepted standards according to reliable sources in and out of city hall. Poor installation of insulation and sealing are just some examples. Ann Arbor needs to Walk the Walk.

Carbon Reductions?

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. Not much of a very meaningful Carbon Reduction Plan.

More carbon emissions mean more rainfall and powerful storms and, disastrous flooding, injury and death.

High-Rises are bad for the tenants and city residents.

7 Reasons Why High-Rises Kill Livability (Smart Cities Dive site):

1. High-rises separate people from the street: Anything and anyone above the fifth floor is definitely out of touch with ground-level events.

2. High-rise scale is not the human scale: High-rises are simply so tall that they make no visual sense to a pedestrian at eye level. You can’t even see the whole building unless you’re in another high-rise. You become lost and engulfed in glass and steel canyons which can be isolating and dehumanizing.

3. High-rises radically reduce chance encounters and propinquity: you are greatly isolated from others.

4. High-rises are vertical sprawl: With high-rises, they take up too much vertical space for something (in this case dense housing) that could be achieved with much less height.

5. High-rises=gentrification and inequality; Low/Mid- rises=resiliency and affordability: Tall buildings offer increased profits for developers. However, the higher a building rises, the more expensive the construction.

6. Are High Rises Even Green? High-rise buildings are built largely of steel and concrete and are less sustainable than low-rise and mid-rise buildings built largely of wood;

7. High Rises are not good for your health: Psychologist Daniel Cappon writes in the Canadian Journal of Public Health that high-rises keep children and the elderly from getting the exercise the extra effort it takes to get outside encourages them to stay at home and flip on the TV.

A report in Fast Company On High-rises:

"According to a new study, a neighborhood of skyscrapers results in about 140% more total emissions than a lower-rise area with the same population, like most Parisian neighborhoods. And he believes that the level of alienation and isolation, things that have been proven to negatively impact health and even shorten people’s lives, increase with the height of the building.

But taller and denser isn’t necessarily better for the environment, according to a new study published in the journal "npj Urban Sustainability - Nature". By studying the full lifecycle greenhouse gas emissions of urban development—from the production and transportation of the building materials to the energy required to use and live in buildings over time—an international team of researchers has found that high-rise cities are actually producing more total emissions than shorter, but still dense, urban areas.

Isolate residents especially children and elderly, disabled..." (bold by us)

Tall buildings are also incredibly inefficient compared to smaller buildings, to about 8 stories. Poor insulation, windows, HVAC and non-window siding if any, most are built with extensive very inefficient low-cost glass windows for siding.

NYC is now taxing tall buildings based on excessive energy use in an attempt to force owners to make the building much more energy-efficient and cut carbon emissions, most building owners say this is impossible to do.

Children not outside as parents can’t see:

A 5-year-old in our neighborhood unlocked his front door and walked away from home. I saw him and took him home before he was able to cross a nearby very busy street. Eyes on the neighborhood can really make a difference.

Tall buildings are not the answer to housing shortages, but are a blight on our community, producing much more pollution and Global Warming Carbon Emissions, that will be with us for decades. This when we are being asked to sacrifice to reduce carbon emissions.

Mayor Taylor and his supporters on council proposed unlimited building heights in the city of Ann Arbor. Developers were ecstatic, not so much city residents.

As we have stated in recent city hall meetings before - Detroit has a tremendous infrastructure and built environment that is underutilized and should not be ignored for more affordable housing with much lower new carbon emissions; Fire Stations, Water, Sewer, Police Stations, ... already built, carbon emissions already emitted.

Limited Ann Arbor Drinking Water Supply:

As we discussed previously on our website - more tall buildings in a city with a very limited drinking water supply from the Huron River is ill-advised and dangerous. Mayor Talyor and some on council wanted GLWA - Detroit water to support more high-rises but it showed that he did not know what he was asking for, not just more water, it was worse water in a major way, hugely expensive, super high energy usage and roundly rejected by the city. With the Gelman/Danaher groundwater contamination, Scio and Ann Arbor Twp are looking to Ann Arbor for more safe drinking water for years to come.

Car Parking for TC1 will be minimal or not at all. Cars will not go away anytime soon and they will be parking up neighborhoods near the high-rises at no cost to developers, one reason why this is happening. This will have a major negative effect on parked-up neighborhoods including devaluation and noise.

Michigan Health Advisory Board: Dangerous Environmental Exposures Will Now Be a New and Significant Area of Effort, To Protect Life Health and Wellness of Michiganders

Local Members of the Michigan Health Advisory Board helped make this happen:

Rita Loch-Caruso PhD - Professor Emmiteris Toxicology SPH U of M Ann Arbor

Kristin Schweighoefer MPh - Environmental Health Director of Washtenaw County Public Health, Food Safety Expert,

With the comments by Dr. Loch-Caruso and Ms Schweighoefer the Board Leader said that the Michigan Health Advisory Board we now will be taking on the dangerous environmental exposures happening in Michigan including 1,4 Dioxane and other dangerous chemicals individuals are exposed. This is new effort for this Board and is a great step in protecting citizens of Michigan.

Polluter Pay was the Law of the Land years ago until the GOP took over the State Government and Gutted the Law. Bills Introduced Oct. 2023 in Senate, House to Hold Polluters Accountable for Cleanups of toxic sites they create. 

Campaign Finance Reform Desperately Needed For Ann Arbor and Michigan

https://votersnotpoliticians.com/

Voters Not Politicians inspired a voter-led, pro-democracy political reform movement that has turned Michigan into a Blue State supporting President Biden.

Campaign Finance Reform

Michigan voters know that special interest and foreign money in politics takes political power out of the hands of the people and instead fuels the power and influence of special interest groups with hidden agendas. We need to advance campaign finance reform to tackle the corruptive influence of dark and special interest money in Michigan.

Playing Fast and Loose our Mayor violated the weak state law on disclosure of contributions in his last campaign. He was sited and fined by the county clerk for this campaign funds non-disclosure.

Join Voters Not Politicians to take back our city.

Clean Elections Clean Candidates:

Clean Elections, used in other states and cities force candidates to refuse large corporate money to run expensive campaigns that out spend opponents 2, 3, or 4 times more money in Campaign War Chests. In Clean Election communities you can not take big contributions and call yourself a Clean Candidate.

In a few years ago an Arizona a State Republican Senator - Clean Candidate "won" his election until he was very quickly removed from office due to violations in his Clean Candidate status as he agreed to run on - taking contributions illegally. He appealed to the state Supreme Court and lost.

Our city elected leaders now routinely take "Chump Change" from those wanting to build mega High-Rises and build out all our green spaces, to run for office and think it is just fine. It undermines the will of the people who live here and pay taxes here, and undermines our democracy.

Very Near Or More Than a 1,000 Year (0.1% chance) Rain September 6, 2023 In Lower Northern MI, Or The Other 1,000 Year Rains in MI, Are Not To Be Ignored

The effects of this storm in Ann Arbor area would be the largest storm on record with extensive flooding and property damage, and likely serious health effects. Building in Ann Arbor, or anywhere in MI, in the currently mapped floodplains is very dangerous.

Ann Arbor has built and is building buildings in floodplains that even Federal Emergency Management Agency (FEMA) states are not a very reliable map of potential flooding. The new MichCon/DTE home development site on the Huron River at 841 Broadway St. mostly in the floodway and floodplain had 15' of water careening across it in the 1968 100 year flood (some say it may have been only a 50 year flood).

The Homeless Shelter was built right up to the floodway which was drawn on the flood maps with a pencil by MDEQ when they were in Ann Arbor to discuss the flood maps. Residents or workers could step out of the building on the west side into the floodway (where rain water is flowing/moving to the River) and potentially drown in a similar or less rain event here.

The Y lost the required FEMA Freeboard (safety zone) in just an mear 1.5 years after built-in a FEMA Letter of Map Revision (LoMR), and is out of state floodplain floodway compliance.

FEMA Low Balling Flood Hazard

FEMA agrees the maps are outdated and they admit it now and are working to try to make them more accurate. They are working with First Street Foundation to update the FEMA maps and are calling it FEMA 2.0 and,FEMA has been shown to be Low Balling floodplain maps by up to 33%.

It is now common for Michigan to get 1,000 year (0.1% chance) rains or more and they will get more common by the year. 

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

Coalition for Action on Remediation of Dioxane (CARD) Group Chose Not Meet in January 2024 Due to New Years Holiday and Travel Schedules 

December 2023 - Issues of Interest and Updates Shown Below In Several Separate Emails Sent Out In December  

December 10. 2023

Special Update: 

Articles In Elsevier Open To The Public - "Current Opinion in Environmental Science & Health" 12-2022

These articles were requested by the editor of the journal Vasilis Vasiliou Ph.D., which only publishes articles from invited authors. This current edition of the journal will investigate 1,4 Dioxane environmental contamination.

These two articles are now available for reading by anyone and are no longer embargoed for the year after publication.  

December 12, 2023

Special Update: 

Published Today - EGLE and State of Michigan Supports EPA Superfund for Gelman Site! 

Great News. Lots of local, state and federal efforts went in to make this happen!

The CARD and ACWG will still be involved as EPA Superfund and EGLE really wants CARD and ACWG to keep meeting and working with them. The local involvement made a big difference in this outcome.

Thanks to everyone who helped in this important effort!

Release: State supports Gelman Superfund status

Michigan Department of Environment, Great Lakes, and Energy sent this bulletin at 12/12/2023 10:01 AM EST

State/EGLE Release Link:

https://content.govdelivery.com/accounts/MIDEQ/bulletins/37f722a

State supports Superfund status for

Gelman groundwater plume in Ann Arbor

Michigan Governor Gretchen Whitmer this week cleared the way for federal Superfund status for the Gelman Sciences contaminated groundwater plume in Ann Arbor, sending a letter concurring with the transfer to the U.S. Environmental Protection Agency.

Groundwater under more than three square miles of Ann Arbor and Scio Township is contaminated with industrial solvent 1,4-dioxane resulting from discharges from Gelman’s manufacturing operations from the 1960s through the 1980s. The site has been managed by EGLE since the discovery of the contamination in 1985.

Local officials and advocates asked that the site be included on the National Priorities List (Superfund) to bring more resources to bear on site monitoring and remediation.

“Placing the Site on the NPL is the most viable alternative for addressing the issues with the source contamination remaining on‑site and the contaminated groundwater on and emanating from the Site,” read Gov. Whitmer’s letter to the EPA.

EGLE Director Phil Roos said the agency has worked closely with EPA on managing the site and will ensure that the transition to Superfund status is seamless and effective.

“We welcome all available resources to address what is a very complex site of legacy contamination,” said Roos, who lives in Ann Arbor. “We’ve listened to the community and concur with their wishes to ask the EPA to make this a priority site. We’ll continue to work with the community and EPA to ensure residents are protected.”

Congresswoman Debbie Dingell, who has worked for years to expedite work on the Gelman site, praised the move.

“Including the Gelman Plume on the National Priorities List is critical to help finally end this decades-long nightmare for the residents of Ann Arbor, Scio Township and the surrounding communities,” Dingell said. “I thank Governor Whitmer for her continued partnership and commitment to getting this site cleaned up.”

Elsevier - Current Opinion in Environmental Science & Health 12-2022

"Michigan's Gelman Site 1,4-Dioxane Groundwater Contamination: Still Spreading Decades after Detection"

Rita Loch-Caruso, Roger Rayle, Vincent P. Caruso, Robert E.Bailey, Elizabeth Collins, Kathleen P . Knol

Link to Abstract for Article:

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

"Atmosphere of Wet Basements as a Novel Route for Potential Residential Exposure to 1,4-Dioxane Vapor"

Robert E. Bailey, Rita Loch-Caruso

Link to Abstract for Article:

https://www.sciencedirect.com/science/article/abs/pii/S2468584422000812

This edition of the journal investigates 1,4 Dioxane environmental contamination.

Vasilis Vasiliou Ph.D. Chair Yale 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.

EGLE Presented Data From Near Surface Groundwater (NSG) Testing Allen's Creek, Scio Twp, and Huron River:

Environment, Great Lakes and Energy (EGLE) continued to do Near Surface Groundwater (NSG) testing of Allen's Creek on the city's west side and, Scio Twp and Huron River assisted by Washtenaw County Water Resources Officials. The main areas of tests are the same as in recent past years, as shown in the image above. On the west side tests were done in West Park, Chapin St. and 8th Street areas. He also tested Scio Twp and the Huron River.

Chris Swoboda PhD Geologist for EGLE commented at the Coalition for Action on Remediation of Dioxane (CARD) Group meeting (Video On YouTube Here) that the results for the Allen's Creek are just a snapshot and should be followed up with more robust tests to get a much finer understanding of the NSG contamination, something CARD and ACWG has commented on many times. It is not clear if EGLE or EPA will do more detailed tests and when.

Link to YouTube Video of the 12-5-23 CARD Meeting; https://www.youtube.com/watch?v=OfCmY4beA1A

November 2023, No Meeting this Month due to  COVID-19 Pandemic Cautions

Watershed Issues of Interest and Updates:

Update From EPA On Superfund Eligibility For Gelman/Danaher Toxic Dump Site November 2023

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

US EPA UPDATE November 2023:

"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.

Updates

November 2023

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 Month:

ACWG has also received notice that the near-surface groundwater (NSG) will have continued monitoring by EGLE starting later this month. 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.

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 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 Water Resources Officials. The main areas of tests are the same as in recent past years, as shown in the image below, West Park, Chapin St. and 8th Street areas. 

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 Action on Remediation of Dioxane (CARD) Group Will Petition EGLE to Monitor Drinking Water Wells Ann Arbor and Scio Townships:

The CARD Group is expected to vote next week on a resolution 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 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.

Links:

CARD Meeting November 2023; YouTube;  https://www.youtube.com/watch?

CARD WC: YouTube link to CARD Meeting videos

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

Scio Twp Gelman Plume Townhall 2-17-2022

https://www.mlive.com/news/ann-arbor/2022/09/ann-arbor-spending-333k-for-more-wells-to-track-polluters-pollution.htmlEWG 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  

Gelman Plume Related Stories by Ann Arbor News/MLive: MLive

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)

EWG Review of 1,4-Dioxane in Tap Water

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

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

The Michigan Legislature Is Soon Expected to Introduce Polluter Pay Legislation

BridgeMichigan: "The Michigan Legislature is soon expected to introduce so-called polluter pay legislation to hold companies accountable for the pollution they create. The measures follow a Bridge Michigan investigation that revealed how the automobile industry has abandoned contaminated properties across the state, with taxpayers routinely left to foot the bill for cleanup." (bold by us)

Michigan had a Polluter Pay Legislation sponsored by Ann Arbor's former Mayor Liz Brader after being elected to the Michigan Senate. John Engler later after getting elected Governor pushed and succeeded in reversing the legislation soon after taking office.

As EPA Superfund had indicated it will likely do a cleanup the Gelman/Danaher Toxic Waste Site in the westside townships and westside of the city and force the polluter to pay for the cleanup.

Link:

https://www.bridgemi.com/michigan-environment-watch/michigan-polluter-pay-bills-coming-following-bridge-auto-industry-probe

Washington Post: "Scientists have found a ‘sleeping giant’ of environmental problems: Earth is getting saltier"

In a recent report by Washington Post Oct. 10, 2023 "Scientists have found a ‘sleeping giant’ of environmental problems: Earth is getting saltier"

"Human activities are making the globe saltier, specifically in our soils, fresh water and air, according to a study released Tuesday in the journal Nature Reviews Earth & Environment.

The excess salt has already caused serious issues in freshwater supplies in recent decades. Saltier water led to brown tap water for months in Montgomery County, Md. It also played a part in creating the toxic lead-laden water in Flint, Mich." (bold by us)

Porous Pavement Uses 75% less salt than conventional pavement:

Using porous (previous) pavements has been shown to be cost-effective, use 75% less salt and pollution-reducing for streets, sidewalks, parking lots and driveways, has much less noise, much less flooding, detoxifies pollution filtering through the pavement, no Black Ice, reduces heat island and will melt up to 2" of ice and snow on the pavement from heat coming up through the pavement pores.

U of M paved its large Fuller Rd Parking Lot with porous pavement to great effect:

    Porous Pavement where cars are parked, Handles 1,300" an Hour (City of Ann Arbor staff tests)!!

Ann Arbor Sylvan St. is one of many streets with porous pavement in Ann Arbor. The city has reduced it's use in recent years for some reason.

MLive 2014 Green Streets:

In its latest attempt to be eco-friendly, the city of Ann Arbor has adopted an official "Green Streets Policy". That essentially means every time a city street is constructed or reconstructed, improved stormwater management will be a top priority. Feb 20, 2014

Link:

https://www.washingtonpost.com/climate-environment/2023/10/31/salt-contamination-pollution-water/

https://www.mlive.com/news/ann-arbor/2014/02/ann_arbor_adopts_new_green_str.html#:~:text=In%20its%20latest%20attempt%20to,will%20be%20a%20top%20priority.

Benefits of Porous Pavements: examples of and link in ACWG.ORG

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

US EPA UPDATE:

"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 Gelman site.

Updates

November 2023

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 To Be Continued By EGLE This Month:

ACWG has also received notice today that the near-surface groundwater (NSG) will have continued monitoring by EGLE starting later this month. 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.

October 2023 - No Meeting this Month Due to COVID-19 Pandemic Cautions

Watershed Issues of Interest and Updates: 

Gelman/Danaher Toxic Waste Dump Flowing Through Near Surface Groundwater in the West Side of Ann Arbor Will Very Very Likely Continue Monitoring By EGLE  

The Coalition for Action on Remediation of Dioxane (CARD) Group ReElected Past and Two New Board Members This Past Month 

Past members were reelected and two new members were also elected. Rita Loch-Caruso PhD Professor Emmiteris Toxocogy SPH U of M and James D'Amour (Vice Chair of Political Committee Siera Club MI, former City of Ann Arbor Planning Commissioner, former Executive Committee Member Sierra Club Huron Valley Group), were added as At Large Members of the CARD Group. Both have been very involved in CARD and will continue to greatly add to the institutional knowledge of the group and help with planning next steps.

New CARD Board:

Chair - Roger Rayle; Vice Chair - Mike Moran; Treasurer - Vince Caruso; Secretary - Beth Collins; Member at Large - Rita Loch-Caruso; Member at Large - James D'Amour; and Executive Director, Jack Eaton (who is appointed by the Board)

CARD Group Will Petition EGLE to Monitor Drinking Water Wells Ann Arbor and Scio Townships:

The CARD Group is expected to vote next week on a resolution 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.

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 October 2023; YouTube;  https://www.youtube.com/watch?

CARD WC: YouTube link to CARD Meeting videos

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

Scio Twp Gelman Plume Townhall 2-17-2022

https://www.mlive.com/news/ann-arbor/2022/09/ann-arbor-spending-333k-for-more-wells-to-track-polluters-pollution.htmlEWG 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  

Gelman Plume Related Stories by Ann Arbor News/MLive: MLive

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)

EWG Review of 1,4-Dioxane in Tap Water

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

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

Gelman Dioxane Plume Community Update Forum, June 28, 2023,

No Comments Regarding Gelman Plume Cleanup/EPA Superfund From Ann Arbor City Government Were Made At This Forum

Main The ACWG did send out a notice ahead of this Community Forum's date and location. There was a large turnout for the Forum as shown in the video.

CARD Members attended including all Board Members, Debbie Dingell (MI=60), Attorney General Dana Nessel, EPA Officials, EGLE Officials, County Commissioners. Local state Senators and Congresspersons wanted to attend but were in session in Lansing. 

The Gelman Dioxane Plume Community Update Forum Video is Available for Viewing on YouTube at https://www.youtube.com/watch?v=-0uH5cMse5c.

Special thanks to Congresswoman Debbie Dingell (MI-6), Henry Nelson Video who took and edited the video of the Gelman Dioxane Plume Community Update Forum and, Roger Rayle Chair of CARD and SRSW for his assistance with the videoing of the meeting, and Elizabeth Nelson videoing as well.