Recent ACWG Meeting Agenda Items and Updates
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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.
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
Open Section Of Allen's Creek Coming Into Fair Glen Commons
With a Neighbor's dangerous MakeShift Failing Retaining Wall in the Bend in the Creek Directing Flow
(ACWG; Rt Clk for Larger)
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
Amassing Porous Road Water Absorption Demonstration Video Shoot
(PBS; Rt Clk for Larger)
Porous Roadway 4 lanes
Mall Road Portland ME, 2019, 9 Years After Install Still In Good Shape
(ME MDOT; Google Maps)
City of Ann Arbor, Porous Pavement Bragging Rights,
Torn Down Several Years Ago, and Stopped Installing Cost Effective Porous Pavements
This Is the Old Y Site With Porous Pavement Parking Lot
(ACWG; Rt Clk for Larger)
University of Michigan Fuller Rd Parking Lot, Ann Arbor, 2020
Used Porous Pavement where cars are parked, Handles 1,300" an Hour (city staff tests)
The access area in the center is not porous and shows cracks fixed
(Google Maps; ACWG; Rt Click for Larger)
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:
ACWG Benefits of Porous Pavement on our website (https://sites.google.com/site/allenscreekwatershedgroup/benefits-of-porous-pavements-acwg)
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:
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.
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, 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.
(Google Maps; RtClk for larger)
NYC
(Google Maps)
Here Is a Low-Rise Desirable Five Story Building On Main St Ann Arbor Slated To Be Replaced By a High-rise Building
5 Million Pounds of Carbon To Build (just for the concrete and steel) This Building and Now Proposed To Be Demolished
5 Million Pounds of Carbon is the Same As all of Ann Arbor Carbon Emissions for Over 10 Years
(It Will Take an untold Amount Of Carbon Just to Demolish the Building and Move the Debris To a Landfill)
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):
High-rises separate people from the street: Anything and anyone above the fifth floor is definitely out of touch with ground-level events.
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.
High-rises radically reduce chance encounters and propinquity: you are greatly isolated from others.
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.
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.
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;
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
(MI Logo, State of Michigan)
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
League of Women Voters of Maine
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
MLive Major Historic Rainfall Sept 6, 2023
(RtClk for larger)
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.
Graphic Abstract To R. Loch-Caruso's Article
Graphic Abstract to R. Bailey's Article
(Rt Clk for larger)
December 6. 2023
Special Update: Near Surface Groundwater Tests Results From EGLE
EGLE Near Surface Groundwater Tests Presented 12-5-23 At CARD Meeting
(EGLE; Rt Clk for Larger)
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 and Washtenaw County Water Resources Officials Sampling
West Park and Chapen St Allen's Creek Drains (NSG),
Other Locations Were Tested As Well
(ACWG; Rt Clk for larger)
EGLE continues to do Near Surface Groundwater (NSG) Testing Allen's Creek:
Environment, Great Lakes and Energy (EGLE) continued to do Near Surface Groundwater (NSG) testing of Allen's Creek on the city's west side assisted by Washtenaw County 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.
NSG Tests City's West Side
(Dan Bicknell GEA; Rt Clk for larger)
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.
The Michigan Legislature Is Soon Expected to Introduce Polluter Pay Legislation
Gelman/Danaher Toxic 1,4 Dioxane Plume Virtually Uncontrolled Moving to
the East Out of Gelman Site into Scio and Ann Arbor Twps, and Ann Arbor;
Plume is Now well Past West Park in Ann Arbor
(Image Roger Rayle, SRSW/CARD; RtClk for larger)
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"
Sylvan St. Ann Arbor, Full Dept Porous Pavement
(ACWG, Google; Ri Clk for larger)
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.
City of Ann Arbor, Porous Pavement Bragging Rights, Torn Down Several Years Ago, and Stopped Installing Cost Effective Porous Pavements This Is the Old Y Site With Porous Pavement
(ACWG; Rt Clk for Larger)
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/
Benefits of Porous Pavements: examples of and link in ACWG.ORG
Special Update November 2023
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.
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.
Here is a link to the start of my comments at the Forum. I commented on the need to lower the state standard for 1,4 Dioxane in Drinking Water from 7.2 ppb to align with EPA and EWG at .35 ppb for EPA nonbinding health advisory level and EWG recommended level of 0.3 ppb one in a million cancer risk. (Former Governor Engler pushed up the level from 3 ppb to 85 ppb. Soon thereafter the state also changed the health effects exposure timeline from one in a million to one in a 100,000.)
Here is a link to Rita Loch-Caruso's PhD Professor Emmiteris Toxocogy U of M and Card Board Member Comments.
Here is a link to Kathy Griswald, former City Council Member and CARD Member Comments.
Here is a link to Rita Mitchel, Chair of the AA Environmental Commission, and CARD Member.
No City Council Members or Mayor made comments regarding the Gelman Plume Cleanup or EPA Superfund Option, the Mayor and only one Council Member were in attendance.
Yale University: New 'Yale Superfund Research Center to Investigate Water Contaminants Linked to Cancer';
1, 4 Dioxane Will be the Main Focus
Yale University
"A new Superfund Research Center (SRC) at Yale will conduct extensive analysis of emerging water contaminants that have been linked to liver cancer.
The National Institute of Environmental Health Sciences recently awarded Yale a $7.35 million grant to support the research program over the next five years. The multidisciplinary center - one of 25 university-based Superfund Research Centers around the country - will be led by scientists at the Yale School of Public Health (YSPH) and Yale School of Engineering & Applied Science. Researchers from the Yale School of Medicine and Yale School of the Environment also will be involved.": Yale (bold by us)
"The center brings together four Yale Schools - Public Health, Medicine, Engineering & Applied Science, and the Environment - and five Yale Centers - Green Chemistry & Engineering, Analytical Sciences, Statistical Genomics & Proteomics, Medical Informatics, and Environmental Law & Policy - Vasilis Vasiliou said.
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.": Yale (bold by us)
"The specific mechanism through which 1,4-DX may cause cancer of the liver in animals and humans is currently unknown as is its interaction with co-occurring toxic chlorinated solvent contaminants...": Yale (bold by us)
Yale is proposing tests in the Ann Arbor area of current and past exposures to study the health effects of 1,4 dioxane.
A local scientist Dr. Rita Loch-Caruso PhD Toxicologist, Professor Emerita, School of Public Health and LS&A, U of M Ann Arbor, and CARD Board Member and ACWG Founding Member is an Outside Advisor for this SRC.
Comments on Proposed TC1 Plymouth Road and TC1 Zoning in General: ACWG does not support.
120', 12 Stories Not 4 Stories As Shown
This is a Misleading Caption of a 120' Building in the TC1 Corridor Proposal
Parking Not Really Discussed (likely very little parking)
(Image - City of Ann Arbor)
Public hearing Nov 1, 7pm On TC1 Plymouth Rd, City Hall 2nd Floor
ACWG Comments submitted Oct 11, 2023
"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, RealEstate 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 highrise 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.
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.
7 Reasons Why High-Rises Kill Livability (Smart Cities Dive site):
High-rises separate people from the street: Anything and anyone above the fifth floor is definitely out of touch with ground-level events.
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.
High-rises radically reduce chance encounters and propinquity: you are greatly isolated from others.
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.
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.
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;
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)
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 highrises 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.
Links:
"Cement emits as much CO2 as India (the whole country)" Washington Post June 27, 2023.
September 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
NSG Testing on the West Side Ann Arbor Tests Will Continue, It Seems:
Environment, Great Lakes and Energy (EGLE) has indicated to ACWG and Coalition for Action on Remediation of Dioxane (CARD) that continued monitoring of the Gelman/Danaher Toxic Waste Dump Flowing Through the Near Surface Groundwater (NSG) on the West Side of Ann Arbor Will Very Very Likely Continue Monitoring. Dan Hamel at EGLE was the geologist who did all the previous NSG West Park Area tests until he unexpectedly died recently.
West Park area and nearby parts of the Allen's Creek creek pick up a lot of groundwater, you can stand on top of the grates in West Park walking path and you can hear it gushing even in a major drought condition, generally agreed, even EGLE, it is high groundwater flows. EGLE did the latest tests during a low rainfall time, as they have in the past, to obtain better data on groundwater contamination. EGLE has detected 1,4 dioxane in West Park groundwater, West Park pond and Allen's Creek Drain, Chapen St., 8th St in front of Slauson Middle School. Others have tested contaminated Near-Surface Groundwater (NSG) in West Park. Past tests, during extreme drought conditions, of the West Park Allen's Creek showed no 1,4 Dioxane Positive tests just upstream yet positive in West Park. 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.
The concern here is that with lots of homes on the West Side with wet or very wet basements, from NSG, "vapor intrusion" of contaminated groundwater could be a concern. This groundwater is near-surface and as such could be a violation of the Prohibition Zone which is said to protect against exposure to 1,4 dioxane from the Toxic Dump Site. Very minimal tests of basement intrusion of contaminated groundwater have been done in the city, which has been questioned by CARD and ACWG.
US-EPA commented to us that the NSG tests were a major reason to consider a Superfund Site for the Gelman/Danaher 1,4 Dioxane Toxic Waste Plume.
High-ranking EGLE officials commented to CARD /ACWG that public involvement in this Gelman/Danaher 1,4 Dioxane Toxic Waste Plume was a major reason for a change to seek EPA involvement.
Reading Rita and Bob's Peer Review Elsevere's recently published article, listed below, a careful reading of the data indicates 100 parts per billion would be a health concern for a wet basement even though he has 150 ppb in the article the data indicates 100 ppb would be a real concern.
I got a call back from Chris Swoboda Geologist for EGLE, assigned to Gelman Contamination, after I called him and left a message after seeing that the last CARD meeting, which I had to miss, had no real comment on this.
Chris said he thinks it is very very likely that EGLE will continue NSG tests as Dan Hamel at EGLE had in the past, in the first two weeks in November when a dry period is present.
I did discuss with him the concerns we have about Liquid to Vapor Intrusion (LVI) in West Side homes which have lots of wet basements.
We did discuss Dr. Robert E. Bailey and Dr. Rita Loch-Caruso's article on Liquid to Vapor Intrusion in the first ever Peer-Reviewed article showing this exposure to chemicals near basements and will likely be incorporated in many environmental studies and cleanup efforts. See the ACWG Web site for Updates for more details. This and another article about Gelman were submitted to Elsevier Journals and were accepted and published. Articles were available for personal use during the 50-day Free Access till January 13th, after which is embargoed till the one-year Embargoed date from November 24, 2022. Scientists generally can request copies anytime. More details at our website, and just search Elsevier for details.
Rita has said that if you look closely at the data in the article 100 ppb is likely to be the threshold of concern for LVI health effects. We had 49 ppb in West Park in recent years, see detailed map below.
West Park Area 1,4 Dioxane Historical NSG Data Map:
Dan Bicknell recently sent comments and a Map of 1,4 Dioxane flowing through Ann Arbor's West Side with West Parking having NSG contamination as high as 49 ppb in recent years sent in an email in recent days:
"As you know, there has been a consistent level of dioxane in the stormwater ever since dioxane sampling of the Allen Creek Drain stormwater began, see below summary.
Dan Bicknell, GEA
Gelman Dioxane Plume & EGLE-WRC Allen('s) Creek Drain Storm Water Sampling Location with 2019 Average Dioxane Valude and 2020, 2021 & 2022 Dixane Values in ug/L (ppb)
Map of Gelman NSG Tests
(Dan Bicknell GEA; Rt Clk for Larger)
"The Allen Creek Drain storm water in upstream locations has an unpolluted flow before entering the area where the shallow dioxane plume intersects and infiltrates into the Allen Creek Drain. For example, see drain upstream sampling locations with no detectable levels of dioxane but a flow, such as Maryfield - Wildwood Park and Maple Ridge - Arborview. This means that in the downstream sampling locations like West Park - Southwest and Chapin where dioxane was found in the storm water, the dioxane contaminated groundwater seeping into the drain is diluted by the upstream uncontaminated storm water flow. As a consequence, the dioxane in the shallow groundwater seeping into the Allen Creek Drain, because of upstream dilution in the drain, must be at a higher dioxane concentration than that observed in the Allen Creek Drain storm water."
These articles listed below were requested by the editor of the journal Vasilis Vasiliou Ph.D. SPH, Yale Univ. which only publishes articles from invited authors. This current edition of the journal will investigate 1,4 Dioxane environmental contamination.
Articles Published in International Invitation Only Journal:
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
These articles were requested by the editor of the journal Vasilis Vasiliou Ph.D., which only publishes articles from invited authors. This edition of the journal will investigate 1,4 Dioxane environmental contamination worldwide.
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.
Groundwater 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 WC: YouTube link to CARD Meeting videos
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.
FamilyHandyMan.Com: "What Is Permeable Pavement and How Can It Prevent Flood Damage?"
Yes Even "Family Handyman" Gets Permeable Pavement, Not So Much Ann Arbor
On Porous Pavement
Porous Pavements
(familyhandyman.com; Rt Clk for Larger)
The ACWG and many others locally and nationally have been promoting Porous (Permeable) Pavement as an efficient, lower cost, safer way to greatly reduce - flooding, pollution, heat island radiation, accidents, erosion, heat islands, Black Ice, and other benefits.
The ACWG has a page on Porous Pavements on our website in the quick links on the left side of the Updates Page. We have been promoting Porous Pavement for decades.
Even the Michigan Concrete Association Promotes Porous Pavements, see below!
Even mainstream publications agree with us that Porous Pavement is a great environmental and cost-saving product.
City of Ann Arbor did try some porous pavement on many city streets and parking lots at the ACWG pushing. Even the U of M has used it on several parking lots in recent years. Older ACWG.ORG entries show some examples.
Ann Arbor Green Streets Initiative Being Ignored, For Some Reason
City Council passed a Green Streets Initiative in recent years but had Lost the Religion, for some reason! Rita Loch-Caruso Chair and Founding Member of the City of Ann Arbor Environmental Commission working with the ACWG, city staff and local experts produced the Green Streets Initiative and got it past the City Council. The city has walked away from reducing flooding, pollution and saving city money.
Rain Gardens were also originally promoted by ACWG with the help of a U of M professor decades ago, in fact our house was one of the first sanctioned Rain Gardens in Ann Arbor and one of the first to obtain utility discounts for it.
Michigan Concrete Association Promotes Porous Pavements:
Michigan Concrete Association (MCA) Porous Parking Lot. Lansing MI
(Google Map; Rt Clk for Larger)
ACWG's Tom Bletcher and I attended the Michigan Concrete Association (MCA) Annual Meeting some years ago where they had a porous concrete pavement demonstration parking lot done and explained the method as it was being done on-site. The MCA avoided about $35,000 connection fee to the storm sewer and yearly user fees, with this new porous parking lot project. About 40-50 people were in attendance and most watched the project progress. MCA said they saved money and other environmental benefits using porous pavement,
Minnesota DOT Found Porous Pavement Was Cost-Effective:
When all costs are considered many communities find it is less expensive to install porous. In a recent study, Minnesota DOT found porous highway installations would be very cost-effective, as 20-30% of conventional highway construction is used to design, build and manage rainwater runoff.
From Family Handy Man:
"Instead of water soaking into the ground and nourishing the soil, it streams away. You can’t always see where it goes, but it often ends up swelling waterways and collecting in low-lying areas.
Now imagine this happening on a massive scale in American cities, and ask yourself what happens to all that water. That’s right: It causes major erosion and flooding problems in rainy places around the Gulf of Mexico, along the Atlantic seaboard and elsewhere.
Statistics suggest pavement occupies as much as 40% of the land surface in some urban areas. When it rains, all the water falling on the pavement runs off into storm drains and sewers, introducing pollutants into treatment plants and slowly contaminating the water supply. Excessive runoff also creates erosion problems and flood damage."
Benefits of Permeable Pavement:
As an ecological alternative to the conventional pavement for parking lots, driveways, patios and walkways, permeable pavement has a number of upsides:
- Helps prevent flooding
- Prevents ice formation
- Controls mosquitoes
- Nourishes the water table
- Reduces the heat island effect
(bold by us)
Links
: https://www.familyhandyman.com/article/permeable-pavement/
Leading Change in Michigan, USA: City of Ann Arbor Adopts ‘Green Streets’ Policy; 2014
City of Ann Arbor Some Past and Current Electeds Seems to Ignore the Voice and Vote of the People
(City of Ann Arbor)
The city Electeds have ignored the will of the people of Ann Arbor. Millages and votes by previous City Councils have been ignored.
Green Belt - 1/3 to be Spent On Green Space on City Property
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 council member Jane Lumm calculated only 9% was being spent in the city for green space and illegally did not meet the GreenBelt Millage mandate. Green Belt Millage called for 33% of funds for green space purchased in the city.
Text of the Greenbelt Millage (posted on ACWG Site) City Council voted for and no vote of Council has changed the Millage.
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.
Center of the City - City Park - Next to Ann Arbor Libary https://a2centralpark.org/
Ann Arbor Voters approved an amendment to our city Charter that set aside land in the Center of the City to create a Central Park, as is the case for most thoughtful towns, as a gathering place, events space, and a place you can sit visit with others without being required to spend money for the amenity.
From the Library Green Conservancy
Library Green Conservancy, a group of Ann Arbor residents working to create an urban park and civic center next to the downtown branch of the Ann Arbor District Library.
The Ann Arbor community still has a unique opportunity to shape what will become the primary public space in the heart of downtown Ann Arbor. In November 2018, Ann Arbor citizens voted to amend the City Charter by adding this language:
“…the City-owned public land bounded by Fifth Avenue, and William, Division and Liberty Streets shall be retained in public ownership, in perpetuity, and developed as an urban central park and civic center commons known as the ‘Center of the City.’”
This vote kept the public land for public use and allowed for the creation of a town center and commons for public assembly and discussion of ideas, a new Downtown cultural and recreation space for all of Ann Arbor to use and enjoy.
Green Streets Initiative - Passed by City Council
Reduce flooding, pollution, noise, Black Ice, salt use on roadways, accidents, less salt in waterways, reduce heat island, beautify city streets with Rain Gardens and plantings,
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 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.
City of Ann Arbor Green Streets Resolution. The impacts of climate change are growing increasingly noticeable, and that can be expected to continue.- Green Streets could be a cost-effective means to reduce flooding and pollution in waterways- Benefits of Porous Pavements: examples of and link in ACWG.ORG
Green Streets Policy passed by the council, is now totally ignored by City government, not unlike voter-approved GreenBelt's required purchases in the City, (1/3 spent in City of Ann Arbor) is also ignored. Just pave the roads like is 1950.
The ACWG pushed to develop the Green Streets Effort and presented it to the Environmental Commission which was accepted and produced. After many years of work including discussions with invited consultants from around the US it was produced and submitted and adopted.
With Climate Change causing more rainfall and flooding, the city of Ann Arbor has greatly reduced efforts to mitigate flooding and is actually promoting building out our existing unreliable and very dangerous floodplains.
Washington Post: "White House defines ‘zero-emission’ buildings, hoping more get built"
Library Center Of The City Site, Proposed/Rejected 17 Story Proposal
The Center Of the City Park is Still In Limbo
(ACWG; Rt Clk for Larger)
"The Biden administration on Thursday will define what amounts to a “zero-emission” building, establishing a new national standard in an effort to tackle one of the biggest contributors to climate change in the United States.
From a climate perspective, the stakes are high. Commercial and residential buildings account for nearly a third of U.S. greenhouse gas emissions, according to calculations by the Environmental Protection Agency that include the emissions from their electricity use."
Ann Arbor is pushing much taller buildings in the city for some reason. Developers, RealEstate Interests, Investors and U of M are all pushing for this with big donations to electids (why we desperately need campaign finance reform).
"Cement emits as much CO2 as India". Washington Post June 27, 2023:
"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)
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!
Tall buildings (about 20 stories) emit CO2 equivalent to 20 years of Ann Arbor's CO2 emissions, 2.1 million metric tons of carbon dioxide equivalent emissions annually.
Ann Arbor's water supply is very limited, why Taylor pushed for Detroit Water (Great Lakes Water Authority), but was not supported by council or residents after the facts of very high cost, excessive energy use and carbon emissions, excessive fees, and poor water source, were brought to light by Rita Loch-Caruso PhD Toxicologist and Dan Bicknell MPH and others.
Links:
https://www.washingtonpost.com/climate-solutions/2023/09/28/zero-emission-buildings-biden/
August 2023 - No Meeting this Month Due to COVID-19 Pandemic Cautions
Watershed Issues of Interest and Updates:
Gelman/Danaher Toxic Waste Dump, More Wells Effected, Basement Exposure Needs More Attention
EGLE and WCHD Well Testing for 1,4 Dioxane in Drinking Water Wells Map
(EGLE, WCHD; Rt Clk for Larger)
Environment, Great Lakes and Energy (EGLE) with the Washtenaw County Health Department, Environmental Health Division in August 2023 tested drinking water wells in the northern portion of Ann Arbor and Scio Townships. Results showed from Not Detected to 7.3 ppb or above. Not detected means no chemical was detected above the reporting limit. Despite a 'not detected' result, 1,4-dioxane may be present at a level less than the reporting limit.
I commented to EGLE regarding the very high 1,4 Dioxane allowable exposure of the current MI human exposure standard of 7.2 ppb is not acceptable and not protective of Public Health. Finding amounts over an EPA suggested limit of .35 ppb and an Environmental Working Group (EWG.ORG) stated dangerous level of .3 ppb these numbers are not acceptable and much more needs to be done ASAP. Residents should not be drinking over .3 PPB, and pregnant mothers and young children are at even higher risk of harm. Others have made similar comments including Rita Loch-Caruso Professor Emeritus UM SPH, Recipient of several US Superfund Federal Grants and recently appointed to the State of Michigan Department of Health Advisor - Toxicologist.
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 Coalition for Action on Remediation of Dioxane (CARD) 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.
West Park area and nearby parts of the Allen's Creek creek picks up a lot of groundwater, you can stand on top of the grates and you can hear it gushing even in a major drought condition, generally agreed is high groundwater flows. Environment, Great Lakes and Energy (EGLE) did the latest tests during a low rainfall time, as they have in the past, to obtain better data on the groundwater contamination. EGLE has detected 1,4 dioxane in West Park groundwater, West Park pond and Allen's Creek Drain, Chapen St., 8th St in front of Slauson Middle School. Others have tested contaminated Near-Surface Groundwater (NSG) in West Park. Past tests, during extreme drought conditions, of the West Park Allen's Creek showed no 1,4 Dioxane Positive tests just upstream yet positive in West Park. 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.
The concern here is that with lots of homes on the West Side with wet or very wet basements, from groundwater, "vapor intrusion" of contaminated groundwater could be a concern. This groundwater is near-surface and as such could be a violation of the Prohibition Zone which is said to protect against exposure to 1,4 dioxane from the Toxic Dump Site. Very minimal tests of basement intrusion of contaminated groundwater have been done in the city, which has been questioned by CARD and ACWG.
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.
Groundwater coming to the surface on the near west side are the reasons 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 WC: YouTube link to CARD Meeting videos
Scio Twp Gelman Plume Townhall 2-17-2022
EWG https://www.ewg.org/tapwater/reviewed-1-4-dioxane.php
https://www.mlive.com/news/ann-arbor/2021/11/in-letter-to-epa-dingell-calls-latest-ann-arbor-area-dioxane-news-alarming.html
EPA, EGLE and Local Government Joint Session on 3-18-21; YouTube link to the Video
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.
Another 500 Hundred Year Rain/Flood (.2% Chance) In and Around Ann Arbor August 24th
SE Michigan Weather Radar August 24
(CBS Detroit; Rt Clk for Larger)
Just West of Willow Run Airport
(MLive; Rt Clk for Larger)
Rainfall Amounts Metro Ann Arbor, in Inches of Rainfall
August 24, 2023
(WonderMap.Com; Rt Clk for Larger)
Belleville area in Wayne County received a reported 7.3 inches as of 7:45 a.m Mlive
"A 6-inch rain was considered a 100 Year Rain (1% chance) in SE MI. This kind of rain event is getting very common now.
WASHTENAW COUNTY, MI - Nearly five inches of rain fell on some parts of eastern Washtenaw County in just a few hours as storms swept across the area Wednesday night, Aug. 23.
The unusually heavy downpour qualifies as a “500-year” storm for a three-hour time period, meaning such an event has a 0.2% chance of happening at any given time, according to the Washtenaw County Water Resources Commissioner’s Office.
Belleville area in Wayne County received a reported 7.3 inches as of 7:45 a.m Mlive.
https://www.mlive.com/news/2023/08/massive-rains-in-southeast-michigan-spur-activation-of-state-emergency-operations-center.html
With Climate Change we clearly have a new normal and these large rain events in SE Michigan and elsewhere and the danger should not be ignored by our city government charged with protecting life and health of the citizens.
Building in the "floodplain" is dangerous, many are right up against the "floodway" the area where flood waters are very dangerous flowing through the city. Just 8" of moving water in a floodway can float and move cars and small trucks.
Link: https://www.mlive.com/news/ann-arbor/2023/08/parts-of-washtenaw-county-get-almost-5-inches-of-rain-in-3-hours-during-500-year-storm.html#:~:text=The%20unusually%20heavy%20downpour%20qualifies,County%20Water%20Resources%20Commissioner's%20Office.
MLive: "Record tornados, heat waves, wildfires: Climate disasters increasing everywhere including Michigan"
And Ann Arbor Building in Floodplains is Dangerous
MLive:
Climate science experts said the barrage of frequent news about natural disasters across the U.S. and Canada in recent weeks is just the beginning. The impacts of climate change are growing increasingly noticeable, and that can be expected to continue.
“I would say that more people are being impacted and are experiencing the direct effects of some of these events and also, the severity of these events is much stronger,” said Sue Ann Bell, an assistant professor at the University of Michigan and a disaster preparedness expert.
Ann Arbor has continued to plan to build out our very dangerous floodplains in the city. In some cases low low-income residents will be placed in our floodplains, many will not even know they are in very dangerous locations.
Jerry Hancock, the city’s stormwater and floodplain programs coordinator Recent Comment:
"Jerry Hancock, the city’s stormwater and floodplain programs coordinator, 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." (bold by us)
Association of State Floodplain Managers 2007
"BUILDING IN THE FLOODPLAIN IS LIKE PITCHING
YOUR TENT ON A HIGHWAY WHEN THERE ARE NO CARS COMING"!
(ASFPM; Rt Clk for Larger)
Ann Arbor City Adopted Green Street Policy Are Not So Grean Anymore!
4th Ave 2014 Rock Bed Rain Water Infiltration Bed Under Street for Cost-Effective Rain Water Mitigation
to Reduce Flooding, Pollution and Last Much Longer, Promoted by ACWG
(ACWG; Rt Clk for Larger)
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
City of Ann Arbor Green Streets Resolution.
The impacts of climate change are growing increasingly noticeable, and that can be expected to continue.
- Green Streets could be a cost-effective means to reduce flooding and pollution in waterways
- Benefits of Porous Pavements: examples of and link in ACWG.ORG
Green Streets Policy passed by the council, now totally ignored by City government, not unlike voter-approved GreenBelt's required purchases in the City, (1/3 spent in City of Ann Arbor) is also ignored. Just pave the roads like is 1950.
The ACWG pushed to develop the Green Streets Effort and presented it to the Environmental Commission which was accepted and produced. After many years of work including discussions with invited consultants from around the US it was produced and submitted and adopted.
With Climate Change causing more rainfall and flooding, the city of Ann Arbor has greatly reduced efforts to mitigate flooding and is actually is promoting building out our existing unreliable and very dangerous floodplains.
The First Steet Foundation, with open-source flood modeling, has been closely working with the 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 very dangerous floodplain locations.
Examples of successes the ACWG pioneered to reduce flooding and pollution in a flood-prone city:
Including - Studying and Installing Rain Gardens, Porous Pavement Roadways and Parking lots, City Utility Credits for Reduced Imperiousness, Rain Gardens, Rain Barrels, Porus Pavement Support Preservation of Existing Trees and Tree Planting, Preservation of Woodland and Wetlands, Preservation of Private Park Woodlands, Protection of Allen's and Other Creeks in the City, Promote Porous Pavement, Lead Public Discussion on these issues.
City of Ann Arbor, Porous Pavement Bragging Rights, Torn Down Several Years Ago,
and Stopped Installing Cost Effective Porous Pavements
(ACWG; Rt Clk for Larger)
July 2023 - No Watershed Issues of Interest and Updates Due to Vacation and Travel Schedules
Update July 7, 2023:
The Gelman Dioxane Plume Community Update Forum Video is Now 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.
June 2023 - No Meeting this Month Due to COVID-19 Pandemic Cautions
Watershed Issues of Interest and Updates:
Gelman/Danaher Toxic Waste Dump, EPA Comments At June CARD Meeting Superfund Very Likely With Final Scoring Comming Soon
Congress Woman Debbie Dingell had a Town Hall meeting this past Thursday about the Gelman Toxic Waste Site Cleanup or Lack There Of. The meeting was taped and when published we will add the link to our web page. EPA, EGLE and the state AG all attended and made comments. Generally, EPA is moving forward and feels that a Superfund would be a likely outcome.
At the June 29th EPA Town Hall the EPA commented that Fall 2024 would be a likely time for EPA to officially file for Superfund Status for the Gelman/Danaher Toxic Waste Site. Congresswoman Dingell commented that after decades involved in US Congress (her husband and she) this is the fastest she has seen to bring a Superfund Status to a polluted site in the US.
Report from EPA at the on Superfund Score for the Gelman/Danaher Toxic 1,4 Dioxane Waste Dump Site in and around Ann Arbor was expected in March according to EPA documents. No word yet on the EPA Score on the site as of the date of this Update sent.
EPA representative at the June Coalition for Action on Remediation of Dioxane (CARD) 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.
July 1, 23 Email Comment On Unacceptable Very High 1,4 Dioxane Cleanup Standard (7.2 ppb), from Daniel J. Bicknell, MPH President Global Environment Alliance, LLC and Decades-Long Private Monitor of the Plume:
I believe that it was Vince Caruso who suggested that the dioxane drinking water criterion should be reduced to values similar to other states and what USEPA would find protective of residential exposure. The main difference between what most states do and USEPA does and what Michigan does relate to the level of protection against cancer. Most states and the USEPA regulate residential cancer-causing chemicals exposure to a 1 in a 1,000,000 excess lifetime cancer risk level (ELCRL), while Michigan regulates to a 1 in 100,000 ELCRL. In the past, Michigan set the acceptable level of protection at 1 in 1,000,000 ELCRL but changed it to 1 in 100,000 ELCRL. This results in cleanup levels for carcinogenic chemicals like dioxane being 10 times higher in Michigan than in most states. The higher the level of protection, the lower the drinking water criterion. To make the dioxane drinking water value similar to most states and USEPA residential levels, Michigan would have to change the ELCRL to 1 in 1,000,000. Such a change would also provide additional protection for the other cancer-causing chemicals which Michigan residents are exposed to by reducing their cleanup levels by a factor of 10. (bold by us)
My main point in the meeting was that the 4th Amended Consent Judgment does not halt the dioxane plume from contaminating drinking water supplies.
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.
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
West Park area and nearby parts of the Allen's Creek creek picks up a lot of groundwater, you can stand on top of the grates and you can hear it gushing even in a major drought condition, generally agreed is high groundwater flows. Environment, Great Lakes and Energy (EGLE) did the latest tests during a low rainfall time, as they have in the past, to obtain better data on the groundwater contamination. EGLE has detected 1,4 dioxane in West Park groundwater, West Park pond and Allen's Creek Drain, Chapen St., 8th St in front of Slauson Middle School. Others have tested contaminated Near-Surface Groundwater (NSG) in West Park. Past tests, during extreme drought conditions, of the West Park Allen's Creek showed no 1,4 Dioxane Positive tests just upstream yet positive in West Park. 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.
The concern here is that with lots of homes on the West Side with wet or very wet basements, from groundwater, "vapor intrusion" of contaminated groundwater could be a concern. This groundwater is near-surface and as such could be a violation of the Prohibition Zone which is said to protect against exposure to 1,4 dioxane from the Toxic Dump Site. Very minimal tests of basement intrusion of contaminated groundwater have been done in the city, which has been questioned by CARD and ACWG.
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.
Groundwater coming to the surface on the near west side are the reasons 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 WC: YouTube link to CARD Meeting videos
Scio Twp Gelman Plume Townhall 2-17-2022
EWG https://www.ewg.org/tapwater/reviewed-1-4-dioxane.php
https://www.mlive.com/news/ann-arbor/2021/11/in-letter-to-epa-dingell-calls-latest-ann-arbor-area-dioxane-news-alarming.html
EPA, EGLE and Local Government Joint Session on 3-18-21; YouTube link to the Video
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.
NYT 6/26/23: "Intensifying Rains Pose Hidden Flood Risks Across the U.S."
MLive - MI Upper Peninsula Another 1,000 Year (0.1% chance) Rain
June 2018, Massive Historic Flooding, Towns Destroyed
(Mlive; Rt Clk for Larger)
New York Times 6/26/23: Intensifying Rains Pose Hidden Flood Risks Across the U.S.
As climate change intensifies severe rainstorms, the infrastructure protecting millions of Americans from flooding faces growing risk of failures, according to new calculations of expected precipitation in every county and locality across the contiguous United States.
The calculations suggest that one in nine residents of the lower 48 states, largely in populous regions including the Mid-Atlantic and the Texas Gulf Coast, is at significant risk of downpours that deliver at least 50 percent more rain per hour than local pipes, channels and culverts might be designed to drain.
“The data is startling, and it should be a wake-up call,” said Chad Berginnis, the executive director of the Association of State Floodplain Managers, a nonprofit organization focused on flood risk.
The new rain estimates, issued on Monday by the First Street Foundation, a nonprofit research group in New York, carry worrying implications for homeowners, too: They indicate that 12.6 million properties nationwide face significant flood risks despite not being required by the federal government to buy flood insurance.
Biden Build Back Better Plan will spend Billions yet “First Street’s calculations suggest that many of these projects are being built to standards that are already out of date. (bold by us)
Pushing to build in Floodways all across the city, hundreds of residents' housing built or are being built. Our city “leaders” hope they will be out of office when the big storm comes.
The city has been promoting buildings in and around the floodway for many years now with real danger of these buildings being in the floodway which would be very dangerous for the occupants and the city legally.
The latest data indicates that Federal Emergency Management Agency (FEMA) is LowBalling the actual Floodplain and Floodway designations for decades, putting people in harm's way.
1,000-rear (.1% chance) rains are hitting Michigan in recent years, not to mention the 100 and 500-year (.2% chance) rains as well.
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 Steet Foundation to update the FEMA maps and are calling it FEMA 2.0.
https://www.nytimes.com/2023/06/26/climate/rainstorms-hidden-flood-risk.html
FEMA LowBalling floodplain maps by up to 33%
After Years of Work By the Allen's Creek Watershed Group and Many Other Ann Arborites, Allen's Creek Greenway, (Or Any Greenway), No Way!
415 W. Washington 2022,
(ACWG; Rt Clk for Larger)
Here is a photo shot of the Greenway the city has been Slow Walking for decades to keep out of the way of developers and real estate interests.
The ACWG and others have tried to get the Allen's Creek floodplain and floodway set aside as a Greenway to greatly reduce flood hazard and create, what most progressive towns are doing for decades, create a pedestrian and bike off-road path in the city.
The city had decided that a meaningful Greenway is in the way of helping developers and real estate interests and more campaign funds for our politicos.
The 415 W. Washington site would be a great pocket park on the Greenway and create a safer watershed, not a building in the likely floodway and floodplain.
The Allen's Creek Greenway was in the city 1980 Master Plan!
Current data clearly indicates that the 415 site is very dangerous with a much larger Floodway than shown on the outdated FEMA flood maps. FEMA is in the process of updating, flood maps, which they agree are outdated and in need of major revisions.
Dr. Missy Stults, Manager City of Ann Arbor Sustainability Office at A2Zero KickOff Meeting to ACWG question: 'I do not support city building in the floodplain (period).'
Jerry Handcock has commented at public meetings, as a Floodplain Manager, he would not like to see ANY building in the floodplain.
What does Kalamazoo know that we don't? A lot!
Kalamazoo Greenway, City's Proud PostCard
( ACWG; Rt Clk for Larger)
Even Kalamazoo has a wonderful Arcadia Creek Greenway for many years, which greatly reduced flood hazard in the downtown and has created a more vibrant and revenue-generating in a previously flood-prone, run-down area.
The old buried Arcadia Creek area flooded often, now daylighted it does not and is a major green amenity for the city.
Kalamazoo took a blighted part of the city along the Arcadia Creek and created a Gem (over 20 years ago): the Arcadia Creek Greenway. It greatly reduces flooding, is a green park gathering space and, is a large performance and fair venue in the downtown. The DDA in Kalamazoo spearheaded this effort.
Kalamazoo Arcadia Creek Greenway: $400-500K in new tax receipts, 600% increase in revenues with $12M/yr festival revenue; From Backwater to one of the Hottest locations in town - retail, rental, condos, gathering space; Can handle beyond a 500-year storm now where it flooded almost every year, and Increase Tax Base.
Better Tax Base = Better Long-term Green Environmental Stewardship!
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 a very steep slope. Wendy Ramson a city staffer told me that site would never be developed because of the slope and creek location. Buldose a private woodland and Bury another creek 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, unlike Ann Arbor DDA, the Kalamazoo DDA proudly spearheaded the Greenway, for good reason and results!
Kalamazoo Arcadia Creek Greenway: $400-500K in new tax receipts, 600% increase in revenues with $12M/yr festival revenue; From Backwater to one of the Hottest locations in town - retail, rental, condos, gathering space; Can handle beyond a 500-year storm now where it flooded almost every year, and Increase Tax Base.
Better Tax Base = Better Long-term Green Environmental Stewardship!
Get a Clue Ann Arbor!
Arcadia Creek Festival Place - Discover Kalamazoo; https://www.discoverkalamazoo.com/member-detail/arcadia-creek-festival-place/
MDEQ/County/City Adopted Allen's Creek Watershed Management Plan on ACWG WebSite
"Cement emits as much CO2 as India". Washington Post June 27, 2023
The Standard, Student Housing, Under Construction Recently In Ann Arbor
(MLive; Rt Clk for Larger)
Ann Arbor is pushing taller concrete buildings as a "Mantra" to Developers, RealEstate Interests and U of M. with disregard for Climate Change.
From the 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)
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 five- and six-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 highrise cities and better for the residents in many ways.
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.
Ann Arbor generates about 1/2 M tons of carbon a year so one 20 story concrete 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 and death.
Links:
Cement emits as much CO2 as India. Washington Post June 27, 2023
May 2023 - No Watershed Issues of Interest and Updates Due to Vacation and Travel Schedules
April 2023 - No Meeting this Month Due to COVID-19 Pandemic Cautions
Watershed Issues of Interest and Updates:
Gelman/Danaher Toxic Waste Dump Still Waiting for the EPA Superfund Final Scoring, EPA Had Planned to Report it in March
Report from EPA on Superfund Score for the Gelman/Danaher Toxic 1,4 Dioxane Waste Dump Site in and around Ann Arbor was expected in March according to EPA documents. No word yet on the EPA Score on the site as of the date of this Update sent.
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.
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
West Park area and nearby parts of the Allen's Creek creek picks up a lot of groundwater, you can stand on top of the grates and you can hear it gushing even in a major drought condition, generally agreed is high groundwater flows. Environment, Great Lakes and Energy (EGLE) did the latest tests during a low rainfall time, as they have in the past, to obtain better data on the groundwater contamination. EGLE has detected 1,4 dioxane in West Park groundwater, West Park pond and Allen's Creek Drain, Chapin St., 8th St in front of Slauson Middle School. Others have tested contaminated Near-Surface Groundwater (NSG) in West Park. Past tests, during extreme drought conditions, of the West Park Allen's Creek showed no 1,4 Dioxane Positive tests just upstream yet positive in West Park. 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.
The concern here is that with lots of homes on the West Side with wet or very wet basements, from groundwater, "vapor intrusion" of contaminated groundwater could be a concern. This groundwater is near-surface and as such could be a violation of the Prohibition Zone which is said to protect against exposure to 1,4 dioxane from the Toxic Dump Site. Very minimal tests of basement intrusion of contaminated groundwater have been done in the city, which has been questioned by CARD and ACWG.
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.
Groundwater coming to the surface on the near west side are the reasons 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 WC: YouTube link to CARD Meeting videos
Scio Twp Gelman Plume Townhall 2-17-2022
EWG https://www.ewg.org/tapwater/reviewed-1-4-dioxane.php
https://www.mlive.com/news/ann-arbor/2021/11/in-letter-to-epa-dingell-calls-latest-ann-arbor-area-dioxane-news-alarming.html
EPA, EGLE and Local Government Joint Session on 3-18-21; YouTube link to the Video
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.
Construction for Residential and Hotel Starts on Coal Tar, Floodplain Site, Just Below Argo Dam!
"How Ann Arbor project got $20M earmark still a mystery to local lawmakers" in a Lansing Back Door Deal; Development of Polluted DTE Site at Depot St and 841 Broadway St In the FW FP - No Real Cleanup Proposed; DTE Energy is Rated top 10 worst Water Polluter in the USA;
DTE Site, Mostly Floodway in Blue, City of Ann Arbor GIS Web Site;
(Likely Much Larger According to FEMA Comments)
(Annotation ACWG; Rt Clk for Larger)
Coal Tar (highly toxic) found at the DTE Site and shown by DEQ (EGLE) at river's edge at the site, the pollution at the river's edge was subsequently cleaned up in recent years (WUOM) but is still on site and leaching into the Huron River and likely groundwater (never tested)
(WUOM, EGLE; Rt Clk for Larger)
This Was an Approximate Design City Approved Plan
(Roxbury Group, Rt Clk for Larger)
"How Ann Arbor project got $20M earmark still a mystery to local lawmakers" like "mana from heaven" to the $23B DTE and Roxbury with very little or no clue how it happened in the "dead of the night". Local lawmakers and public officials have no knowledge or comment on the appearance of these funds for this development.
The developer has started construction on this site largely in the floodway and in the floodplain, on top of a Coal Tar Dump Site, just below the Argo Dam which was over-topped and almost failed in the 1968 flood.
Federal Emergency Management Agency (FEMA) has stated they agree the floodplain maps are outdated and other reputable studies show they are 30% Low Balling the actual floodplains when Global Warming effects are included in flood modeling.
With discussions in Lansing regarding reinstating Polluter Pay legislation it would seem DTE will walk away from this site with very little cleanup leaving the polluted site to others to deal with, likely Michigan taxpayer
At a public meeting for this project, I attended, but ACWG was not invited to for some reason, the developer described the materials buried on site as 'Inert', which I challenged. Coal Tar is not Inert as we wrote previously and commented on earlier before Council's Meeting with Public Hearing for this project.
“Inert waste is waste that is neither chemically nor biologically reactive and will not decompose. Examples of this are sand and concrete. This has particular relevance to landfills as inert waste typically requires lower disposal fees than biodegradable waste or hazardous waste.”
The coal gasification process produces a bi-product called coal tar. Coal tar is a mixture of volatile organic compounds such as benzene, and a class of compounds known as polynuclear aromatic hydrocarbons (PAHs) which include compounds such as naphthalene and benzo(a)pyrene. These compounds are rated as possible and known carcinogens and are very dangerous to humans and other life forms. Some PAHs, Benzene and benzo(a)pyrene are Group 1 carcinogens.
This Coal Tar is leaching into the Huron River and the groundwater is said to be contaminated. This site is the site of the old Huron River Riverbed pre-early 1900s
Structures on this site will be placed on top of a toxic waste site with coal tar and other chemicals from the old MichCon Gasification Plant that was on this site. The groundwater below is contaminated but downstream contamination tests in the Huron River were not done according to the developer.
Vapor Intrusion is a real issue being faced by many sites which were built over old dump sites. In Petoskey MI recently 11 of 14 condos were evacuated due to VI issues from building in an old dump site. See our website for information on Vapor Intrusion as it relates to the Gelman Toxic Dump Site and Plume.
At a CARD meeting years ago discussion of the Ann Arbor City Apartments at Washington and First St came up regarding the below-ground parking 2 stories below grade. The ACWG and the CARD Group asked about potential groundwater contamination with 1,4 Dioxane issues with this city-owned parking garage below in the path of the plume, deep into the water table. Soon thereafter we learned the city did a stop-work order to make changes to the soon-to-be-started building, to raise the building a full 2 stories up to avoid this issue, at great cost to the city. The city's explicit requirement not to have parking on the street level was quickly thrown out the window. At the DTE site we know we have major pollution below the surface and yet feel OK with building residential above it very close to the dangerous pollution
Flood hazard is getting worse, not better with Global Warming. This site is in the site of the old Huron River riverbed, just downstream of two dams both of which were breached and others completely failed in the 1968 100-year (1% chance) flood, which had 15 feet of water flowing over this site. The 1968 flood is more like a 50-year (2% chance) flood of today by many accounts.
They were planning a Brownfield partial cleanup with about $25M from taxpayers, and about $12M from the developer
This will not be a full cleanup as they say this is not required in the current very weak MI Part 201 statute.
DTE, a $23B company, should be doing a cleanup of this site as the Responsible Party Legal Owner, not taxpayers. Polluter Pay legislation has been introduced in Lansing this year
If done right could be a great park close to the city center. When it floods hose it off and go back to being a park, like many progressive (and non-progressive) cities are doing.
All of the other outcroppings in the Huron River near Ann Arbor and beyond are parks, for good reason, due to the flood hazard associated with them.
When the city worked on the River Path near this site they cleaned up the Coal Tar before putting in the trail. Yes, clean up for a trail but not residential development on the same building site.
A developer across Depot St. developed a lot that was full of Coal Tar, site of the original MichCon plant, and they told me they were not to happy this development was not required to do a similar cleanup for a development.
DTE Energy rated top 10 worst Water Polluters in the USA. Great partner for the city.
'Researchers at the University of Massachusetts Amherst have published three lists detailing the 100 worst air, water and greenhouse gas polluters in the country.
The lists — the Toxic 100 Air Polluters Index, Toxic 100 Water Polluters Index and Greenhouse 100 Index.
Zombies Rising Up From the Grave:
"What’s kind of a like a zombie rising from the grave is these buried contaminants that are now showing up in people’s homes, in their air, specifically. That was not envisioned by the science at the time; if you left chemicals in the ground they could actually migrate up through even impervious surfaces and affect people’s health." Dave Dempsey, For The Love Of Water FLOW - WUOM (bold by u
DTE, a $23B company, should be doing a full cleanup of this site as the Responsible Party Legal Owner, not taxpayers
The City of Ann Arbor is negligent in not forcing EPA and DTE Responsible Party to do a full cleanup of the site in the middle of our Huron River.
Links:
https://www.mlive.com/news/ann-arbor/2022/09/how-ann-arbor-project-got-20m-earmark-still-a-mystery-to-local-lawmakers.html
https://www.peri.umass.edu/toxic-100-water-polluters-index-current
https://www.citylab.com/newsletter-editions/2019/07/maplab-hidden-risks-flood-maps/595126/
As Ann Arbor Pushes for Tall Buildings "Is building tall really best? Researchers dispel the myth of climate-friendly skyscrapers; Neighborhood of skyscrapers results in about 140% more total emissions": FastCompany.Com; Where Will Find All the Drinking Water
Downtown Paris, Low-rise Buildings Are the Norm Not the Exception and Is Much More Dence Then High-rise Cities
(Google, ACWG; Rt Clk for Larger)
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. 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.
Paris, for example, with its mostly five- and six-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.
Low-rise buildings can mostly be built with carbon capturing wood as high-rises do not currently have this option. This has never been addressed by the city.*
Isolate residents especially children and elderly, disabled..." (bold by us)
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.
Just the 20-story 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!
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.
Limited Ann Arbor Drinking Water Supply:
As we discussed previously - 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.
Links:
Smart Cities Dive site https://www.smartcitiesdive.com/
Dr. Rita Loch-Caruso: "New exposure concerns for 1,4-dioxane from the legacy Gelman Sciences groundwater contamination." CLEAR WSU, YouTube Video Available Online
"New exposure concerns for 1,4-dioxane from the legacy Gelman Sciences groundwater contamination."
Dr. Rita Loch-Caruso, Professor Emerita, University of Michigan, Toxicology and Program in the Environment, invited speaker, presented April 20th "New exposure concerns for 1,4-dioxane from the legacy Gelman Sciences groundwater contamination." (Video on YouTube)
Synopsis by CLEAR:
Groundwater became contaminated with 1,4-dioxane by onsite industrial wastewater disposal at the Gelman Sciences site just west of the city of Ann Arbor, Michigan. The contaminated groundwater has continued to spread, prompting closure of private wells and one municipal well. A court-ordered Prohibition Zone, which bars most groundwater uses in a large section of the city of Ann Arbor, was based on the assumption that the contaminated groundwater would remain below ground until it flowed into the Huron River. However, recent findings show that 1,4-dioxane is approaching the land surface in the middle of the city of Ann Arbor, 0.3 km before it reaches the river. Because damp basements are common in Ann Arbor and 1,4-dioxane is highly miscible with water, we examined potential exposure and health risks from basement intrusion of contaminated groundwater with subsequent indoor volatilization. This represents a novel exposure route distinct from vapor intrusion. Our analysis suggests that liquid intrusion with indoor volatilization could increase risk to 1 in a 1,000,000 for excess cancer if 1,4-dioxane in shallow groundwater is greater than 150 μg/L and certain conditions are met. (bold by us)
We have had 49 μg/L (49 ppb) in West Park Allen's Creek in recent years which is an indication of local groundwater contamination, as commented on by CARD members and EGLE in CARD meetings. These tests will continue and have EGLE and EPA attention and were a main reason EPA supported an evaluation for Superfund site potential for the Gelman/Danaher contamination and will likely propose a Superfund Site for the Gelman/Danaher site and contaminated groundwater.
Novel Finding of Potential Exposures of 1,4 dioxane:
See our website for recent entries for the two peer-review publications' Abstracts describing this analysis.
The Liquid to Vapor Intrusion into buildings publication by Dr. Robert E. Bailey, Environmental Chemest, CARD Member, published the first-ever peer-reviewed analysis showing a new potential exposure to pollution in groundwater, as we have here in Ann Arbor in our groundwater.
Link:
March 2023 - No Meeting this Month Due to COVID-19 Pandemic Cautions
Watershed Issues of Interest and Updates:
Gelman/Dananer Toxic Waste Dump Site Should Receive EPA Superfund Scoring This Month, No Score Yet; CARD Passes and Sends to Lansing Support of Polluter Pay State Legislation
Report from EPA on Superfund Score for the Gelman/Danaher Toxic 1,4 Dioxane Waste Dump Site in and around Ann Arbor is expected in March according to reliable sources. No word yet on the EPA Score on the site as of the date of this Update sent.
Once a Score is given then 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.
Updated Consent Judgement for Gelman/Danaher Toxic 1,4 Dioxane Plume
Attorney General Dana Nessel announced on March 24, the Michigan Department of Environment, Great Lakes and Energy (EGLE) and Gelman have filed a motion asking the Washtenaw County Circuit Court to enter an updated consent judgment governing response activities to address the toxic chemical plume. 7.2 ppb will be the groundwater cleanup standard, the same as the drinking water standard. Additionally, more response activities to ensure compliance with the lower cleanup criteria for drinking water, surface water and soils. (More details here - Ryan Stanton, Mlive)
These changes are woefully inadequate, do not protect life and health and the environment, and EPA will impose much more strict and protective cleanup standards when and if EPA declares the site a Superfund site. Michigan's environmental rules were greatly reduced under GOP control of the state government with Governor John Engler initiated 40 years ago. With state GerryMandering undone by referendum, Democrats are the majority party in Lansing and now propose major changes in environmental state standards to much better standards.
CARD Resolution In Support of Polluter Pay State Legislation:
For many years CARD has discussed reinstating the old enacted Polluter Pay Legislation revoked by GOP elected officials. Our former Ann Arbor Mayor, state Senator and state Representative Liz Brater championed the Polluter Pay Legislation in 1989-1990 in Lansing.
"From 1990 until 1995, Michigan had the strongest “polluter pay” law in the country. If a corporation was responsible for contaminating our land, air, or water, that corporation was also responsible for cleaning up the mess they made. In 1995 the administration of former Governor John Engler, backed by their allies at the Michigan Chamber of Commerce, gutted the polluter pay law, and funding for environmental cleanups in Michigan has suffered ever since." Clean Water Action
CARD has Recently passed and Has Communicated it to Lansing in Support of Polluter Pay State Legislation:
CARD Resolution In Support of Polluter Pay State Legislation
Whereas: The Coalition for Action on Remediation of Dioxane (CARD) is a partnership
of local governments and citizens reviewing strategies to address the groundwater
contamination from the industrial solvent 1,4-dioxane, released by Gelman Sciences,
Inc.
Whereas: The cleanup of this contamination and of contaminated sites in Michigan is of
paramount public importance;
Whereas: The cleanup of contaminated sites with impacted groundwater is particularly
important because contaminated groundwater does not remain static in the
environment;
Whereas: The Gelman 1,4-dioxane plume, The current PFAS crisis and increasing algal
blooms in the Great Lakes from nutrient pollution are all warning signals that we must
do more to address water pollution, particularly on the Huron River.
Whereas: In July 2022, Tribar Manufacturing, located in Wixom, Michigan, negligently
discharged toxic chemicals that endangered public health, the City of Ann Arbor’s
drinking water supply and the environment in general; and had previously discharged
PFAS chemicals that created a “no eating of fish taken from Huron River order” several
years earlier;
Whereas: Under current law, polluters are not required to clean up contamination to
residential standards and generally can simply restrict access to a site or aquifer instead
of meeting residential standards;
Whereas: The fourth court order between Pall/Gelman/Danaher and the State of
Michigan has been rejected by the Michigan Court of Appeals, and remaining action is
subject to the current third consent judgment based on standing state regulation when
third judgment was adopted by all parties;
Whereas: Intervenors of said fourth court order were essentially dismissed by the
Michigan State Court of Appeals;
Whereas: Senate Bill 58 and House Bill 4314 would require polluters to clean up
contamination they cause to residential standards and restore affected aquifers to
drinking water standards, unless meeting those standards would be technically
infeasible; and,
Whereas: Senate Bill 58 and House Bill 4314 would make it more difficult for polluters to
use institutional controls as a substitute for active remediation;
RESOLVED: That the CARD Group calls for hearings to be held, and the legislature to
adopt MI 2021 SB 58 and HB 4314; and urges all legislative and congressional
representatives of Washtenaw County to support this action, and support the USEPA
Superfund intervention.
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.
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
West Park area and nearby parts of the Allen's Creek creek picks up a lot of groundwater, you can stand on top of the grates and you can hear it gushing even in a major drought condition, generally agreed is high groundwater flows. Environment, Great Lakes and Energy (EGLE) did the latest tests during a low rainfall time, as they have in the past, to obtain better data on the groundwater contamination. EGLE has detected 1,4 dioxane in West Park groundwater, West Park pond and Allen's Creek Drain, Chapen St., 8th St in front of Slauson Middle School. Others have tested contaminated Near-Surface Groundwater (NSG) in West Park. Past tests, during extreme drought conditions, of the West Park Allen's Creek showed no 1,4 Dioxane Positive tests just upstream yet positive in West Park. 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.
The concern here is that with lots of homes on the West Side with wet or very wet basements, from groundwater, "vapor intrusion" of contaminated groundwater could be a concern. This groundwater is near-surface and as such could be a violation of the Prohibition Zone which is said to protect against exposure to 1,4 dioxane from the Toxic Dump Site. Very minimal tests of basement intrusion of contaminated groundwater have been done in the city, which has been questioned by CARD and ACWG.
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. Other 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.
Groundwater coming to the surface on the near west side are the reasons 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 WC: YouTube link to CARD Meeting videos
Scio Twp Gelman Plume Townhall 2-17-2022
EWG https://www.ewg.org/tapwater/reviewed-1-4-dioxane.php
https://www.mlive.com/news/ann-arbor/2021/11/in-letter-to-epa-dingell-calls-latest-ann-arbor-area-dioxane-news-alarming.html
EPA, EGLE and Local Government Joint Session on 3-18-21; YouTube link to the Video
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.
The City of Ann Arbor Has Dragged Its Feet for Decades Working On Clean Up of the Argus Site and 415 W. Washington Soil and Ground Water Contamination
Sign(s) created and posted in a Near West Side Neighborhood
Residents on the near west side of Ann Arbor have been asking city officials for decades to get a cleanup of the Argus Building and 415 W. Washington Sites ground and groundwater contamination.
EGLE is now doing tests in homeowners' basements, drilling holes and checking for pollution. Some tests have found pollution, very likely from Argus or the 415 site, under the homes.
One major contaminant is Trichloroethylene (TCE). It is used as a solvent for degreasing metal parts during the manufacture of a variety of products. Trichloroethylene may cause irritation to the eyes and skin. Exposure to high concentrations can cause dizziness, headaches, sleepiness, confusion, nausea, unconsciousness, liver damage, and even death. Trichloroethylene is a known carcinogen. Individuals may be harmed from exposure to trichloroethylene.
Benzine is another major contaminant that has also been found in the groundwater on site, and is another major contaminant. Benzine is also a known carcinogen. Individuals may be harmed from exposure.
The 415 W. Washington site has several pollutants on-site and leaching into the groundwater which is now moving off-site into neighboring properties. Also likely in the Allen's Creek as it flows through the site in a large pipe and into other properties, potentially leaking polluted water into them, and the Huron River. This would seem to be another MS4 Violation of city and county disregard for pollution flows through their known polluted property into the Allen's Creek and downstream.
CARD and ACWG have expressed concerns for years regarding the Foot Dragging on the Argus and 415 cleanups.
EPA has a responsible party, GTE OSI, for the Argus site and, City of Ann Arbor and Washtenaw County for the 415 site, and needs to get them to move on this cleanup immediately.
Our Mayor and Council want to wait longer until a developer takes over the 415 W. Washington site and works with the RP to do a cleanup, which may take another decade, if ever.
Link:
Centers for Disease Control and Prevention(CDC):
cdc.gov : https://www.cdc.gov › niosh › topics › trichloroethylene
Council Took a Step to Put Residential Housing At 415 W. Washington, Which Would Be a Major Mistake and Dangerous
City Council voted First Reading to Develop 415 W. Washington for Residential Is Ill-Advised and Dangerous.
The ACWG does not support this proposal. We communicated this to the Planning Commission and at City Council Meeting as shown below.
Association of State Floodplain Managers 2007 (ASFPM)
"BUILDING IN THE FLOODPLAIN IS LIKE
PITCHING YOUR TENT ON A HIGHWAY WHEN THERE ARE NO CARS COMING"!
ASFPM: www.floods.org
(ASFPM; Rt Clk for larger image)
415 W Washington Flood Hazard; (First Street Evaluation)
(First Street; Rt Clk for Larger)
415 W. Washington Floodplain Map; Floodway in Blue, Floodplain in Green (ACWG)
First Street Foundation 30-Year Flood Hazard 0.1% Chance, Probable
First Street Foundation 30-Year Flood Hazard 0.2% Chance
These were ACWG.ORG comments to Council and Planning Commission in recent weeks both verbally at the meetings and written:
New Discussions at City Hall Regarding Developing 415 W. Washington for Residential Is Ill-Advised and Dangerous.
The ACWG does not support this proposal. We communicated this to the City Council and the Planning Commission.
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, 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.
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 LowBalling 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 Penceled 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 Talyor 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!
Thank You
One recent example of 1,000 year (0.1% chance) Rains in Michigan UP:
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
February 2023 - No Meeting this Month Due to COVID-19 Pandemic Cautions
Watershed Issues of Interest and Updates:
Gelman/Dananer Toxic Waste Dump Site Should Receive EPA Superfund Final Scoring This Month, Very Likey to be Above the Standard for Superfund Status and Next Listed on the National Priorities List (NPL) then Cleanup Starts After Required Time on the NPL
Report from EPA on Superfund Score for the Gelman/Danaher Toxic 1,4 Dioxane Waste Dump Site in and around Ann Arbor is expected in March according to reliable sources.
Once a Score is given the 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.
EGLE continues to test wells in Scio and Ann Arbor Twp. Roger Rayle showed a map of the recent drinking water well data that he said, others agreed including us, that it seemed to show the plume is moving to the north toward Barton Pond, where Ann Arbor gets about 85% of our city drinking water.
This new data of wells to the north pushes the plume location much farther north than had been expected, affecting homeowner drinking water wells and moving it closer to Barton Pond to within 1/4 mile.
If and when EPA takes over with a Superfund Cleanup of this site they will stop the movement of the plume and protect drinking water wells and Barton Pond.
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
With the ruling from the Michigan Court of Appeals, the previous MI Court Judgement with more protective exposure values is now disallowed and the old less protective exposure levels are reinstated, from 7.2 ppb to 85 ppb standard, although Gelman has kept with the 7.2 standard in recent years. The Judge ruled that the Interveners (Local Elected officials and NGOs) should not have been allowed to join the suit. The legal team for the community failed to provide a strong enough argument for the inclusion of Interveners.
West Park area and nearby parts of the Allen's Creek creek picks up a lot of groundwater, you can stand on top of the grates and you can hear it gushing even in a major drought condition, generally agreed is high groundwater flows. EGLE did the latest tests during a low rainfall time, as they have in the past, to obtain better data on the groundwater contamination. EGLE has detected 1,4 dioxane in West Park groundwater, West Park pond and Allen's Creek Drain, Chapen St., 8th St in front of Slauson Middle School. Others have tested contaminated Near-Surface Groundwater (NSG) in West Park. Past tests, during extreme drought conditions, of the West Park Allen's Creek showed no 1,4 Dioxane Positive tests just upstream yet positive in West Park. 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.
The concern here is that with lots of homes on the West Side with wet or very wet basements, from groundwater, "vapor intrusion" of contaminated groundwater could be a concern. This groundwater is near-surface and as such could be a violation of the Prohibition Zone which is said to protect against exposure to 1,4 dioxane from the Toxic Dump Site. Very minimal tests of basement intrusion of contaminated groundwater have been done in the city, which has been questioned by CARD and ACWG.
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. Other 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 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.
The Water Resources Commissioner had notified Gelman/Danaher they are not in compliance on MS4 with 1,4 dioxane in the Allen's Creek and would like to see a plan to mitigate the violation and act on it.
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.
'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.
Groundwater coming to the surface on the near west side are the reasons 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 2023; YouTube: https://www.youtube.com/watch?v=Upi-aHp2g0M
Scio Twp Gelman Plume Townhall 2-17-2022
EWG https://www.ewg.org/tapwater/reviewed-1-4-dioxane.php
https://www.mlive.com/news/ann-arbor/2021/11/in-letter-to-epa-dingell-calls-latest-ann-arbor-area-dioxane-news-alarming.html
EPA, EGLE and Local Government Joint Session on 3-18-21; YouTube link to the Video
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.
Putting Residential Housing At 415 W. Washington Would Be a Major Mistake and Dangerous
New Discussions at City Hall Regarding Developing 415 W. Washington February 2023 for Residential Is Ill-Advised and Dangerous,
The ACWG does not support this proposal. We communicated this to the Planning Commission.
415 W Washington Flood Hazard; (First Street Evaluation)
415 W. Washington Floodplain Map; Floodway in Blue, Floodplain in Green (ACWG)
First Street Foundation 30-Year Flood Hazard 0.1% Chance, Probable
First Street Foundation 30-Year Flood Hazard 0.2% Chance
The First Steet Foundation 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 dangerous floodplain location.
Voters passed an Ann Arbor Affordable Housing Tax Proposal, With a Ban On Fund's Use In Floodplains for a reason.
This site in all likelihood has a much larger Floodway due to climate change and FEMA LowBalling Floodplain maps, and be much more dangerous than the maps suggest.
This site has been forbidden to be used for Affordable housing with city funds by city council against the mayor and others wishes. Floodplains are not for residential and will be even more so as we see more Global Warming effects in Ann Arbor and Worldwide.
The floodplain and floodway delineations for this site are arguably outdated and inaccurate and unsafe to unsuspecting individuals.
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 city and county officials were meeting their 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, tells you how dangerous this site is.
At the Planning Commission discussion on the 415 development by Jerry Handcock, Ann Arbor Stormwater and Floodplain Programs Coordinator:
"Jerry Hancock, the city’s stormwater and floodplain programs coordinator, raised other concerns about the development proposal in a Feb. 6 memo, 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, he said.
While codes do allow residential uses in the flood fringe, that increases the responsibility and cost of city emergency services responding to flood events and creates a risk of residents being injured in a flood, Hancock said.
Plans show the housing would be elevated above a surface parking level and officials said it would be designed to withstand a 500-year flood event.
Lisa Disch, City Council’s representative on the Planning Commission, said every project can’t satisfy every priority. She sees the proposal on the table as a way to address the “moving toxic sludge,” which she called an urgent priority." Stanton: MLive
City passed a $1B plan for Climate Change!! "But let's build in the floodplains and likely floodways".
Dr. Missy Stults city's Sustainability and Innovations Manager states at A2Zero Kickoff Meeting on Nov 11th, 2020 when asked by the ACWG she responded: "No Building In Floodplain" Period. No discussion, no questions, just NO.
Y site across the street has dangerous fencing and other obstructions across virtually the entire site acting as a huge dam for floodwaters, in the middle of the floodway, flowing north to the river. ACWG strongly petitioned the MDEQ to stop the Y building and then later after the building was finished, the Y fencing but was not successful.
This fencing and many other obstructions were installed after the building was finished.
Smith Group has commented in 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.
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 a FEMA Letter of Map Revision (LoMR), and is out of federal and state floodplain floodway compliance!!
Y has regular flooding evacuation drills and worries about flood hazard according to a reliable inside source.
Just to note the FIRM raw data used for maps is basically 1968 flood data, from the 100-year (1% chance) flood of that year and as such is not up to date. Consultants/Planners hired for the YMCA site plans thought the FIRM maps were based on 1992 data because the maps had a 1992 printing date. ACWG corrected that statement, even though the planner would not agree during a meeting on this issue. He said he would get back to us but never did.
It would be malpractice to propose residential on this site given the facts about the flood hazard, outdated FEMA Maps, and soon will be much worse flood hazard here.
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.
Long past time to follow the Green Belt mandate 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 did not meet the GreenBelt Millage mandate.
Local, State and Federal funds will not be available for this site due to its location in the floodway and floodplain. This for good and obvious reason.
President Obama virtually forbid using federal funds for building in the 100-year (1% chance) floodplain and virtually forbid the use of federal funds for building any critical structures in the 500-year (.2% chance) floodplain due to Global Warming effects causing more intense rain events.
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.
When the Homeless Shelter on Huron St. was about to start construction the ACWG and others contested building in the floodplain and likely floodway. An EMU professor working with ACWG and others showed the plans put the building in the Allen's Creek floodway. The MDEQ put a Stop Work Order on the plans and determined the building would be illegally and dangerously in the floodway. The design had to be scrapped with ~$1M loss and redesigned up the hill outside the floodway. Unfortunately, it was built in the floodplain just inches away from the New DEQ Floodway designation, likely in the current larger floodway.
Best Most Logical Use Of This Site
Best use of this site is for the Allen's Creek Greenway/Tree Line pocket park and green trail. Green space in the downtown will be a huge amenity for Ann Arbor, to enhance the Greenway and set aside flood-prone land for flood mitigation.
The ACWG has proposed, since 1998, a Allen's Creek Greenway and included in the MDEQ adopted Watershed Management Plan 2001, an Allen's Creek Greenway, the city included a Greenway in 1980 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 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.
415 W Washington Development Plan Would be a Mistake!
Links:
MLive https://www.mlive.com/news/ann-arbor/2015/09/should_ann_arbor_adopt_new_reg.html#incart_river
Dr. Rita Loch-Caruso was Interviewed On WEMU (EMU Public Radio) Issues of the Environment, About the Gelman Toxic Waste Site Update and Liquid To Vapor Intrusion*, to be Broadcast on WEMU
Issues of the Environment - WEMU
Dr. Rita Loch-Caruso PhD is a Professor Emerita, School of Public Health and LS&A, U of M Ann Arbor, a founding member of ACWG and founding member of Coalition for Action on Remediation of Dioxane (CARD). Rita is also an External Advisor to the Superfund Center at Yale directed by Vasilis Vasiliou PhD, Chair of Public Health of Yale University, USEPA SuperFund Center Director at Yale University, was asked by David Fair to give an on-air update on the Gelman/Danaher Toxic Waste site and potential Liquid to Vapor Intrusion of 1,4 Dioxane into homes and businesses and recent findings of contaminated wells in the Scio and Ann Arbor Twp. on the WEMU-Issues of the Environment WEMU program.
WEMU-Issues of the Environment airs Wednesdays during Morning Edition and should (was aired*) this week and is available on their website.
Links:
WEMU-Issues of the Environment
Dr. Rita Loch-Caruso's Interview
Tom Bletcher, Founding and Long Time Member of ACWG, Died Earlier this Month
Tom Bletcher and Vince Caruso, ACWG
Nancy Kaplan Host and Producer, "Other Perspectives - A2", Ann Arbor 2011
(Other Perspectives, ACWG;
Rt Clk for larger)
Tom Bletcher died of natural causes earlier this month.
Tom was a founding member of the ACWG, a former Deputy Drain Commission, a Consultant on many types of work including watershed management, a teacher, a scientist and an owner of Consulting firm in Ann Arbor.
Tom was a good friend, a great activist and knowledgeable in so many areas. He helped create the Allen's Creek Watershed Group in the early 90's to help Ann Abor deal with water quality, flooding and city watershed management issues. He always had great advice and suggestions on fixing what was "broke" and, had a very deep knowledge on watershed issues that made a real difference in the area and state.
Thomas "Tom" Bletcher obituary, 1940-2023, Ann Arbor, MI; MLive
Dr. Rita Loch-Caruso has been appointed to the State of Michigan Department of Health Advisor - Toxicologist
State of Michigan
Rita Loch-Caruso PhD is Professor Emarita of School of Public Health and LS&A U of M Ann Arbor, recipient of many EPA and NIHES grants, founding member and member of CARD and ACWG, has been appointed to the State of Michigan Department of Heath Advisor - Toxicologist. Rita was a founding member, 13-year member and for several years Chair of the City of Ann Arbor's Environmental Commission.
Rita will serve as a great resource for Michigan and Ann Arbor area especially the Gelman/Danaher Toxic Dump Site affecting Ann Arbor, Scio Twp and Ann Arbor Charter Twp. She will have opportunities to advise and seek advice from state environmental leaders in Lansing.
https://www.michigan.gov/mdhhs
January 2023 - No Meeting this Month Due to COVID-19 Pandemic Cautions
Watershed Issues of Interest and Updates
Gelman/Dananer Toxic Waste Dump Site Should Have Health Effects Invesigated After Decades of Exposures in Water and Air
Vasilis Vasiliou PhD, Chair of Public Health of Yale University, USEPA SuperFund Center Director at Yale University To Work With CARD and Other Locals on Gelman/Danaher Toxic Dump Site and commented on strong interest in health effects studies.
Dr. Vasiliou is very interested in doing health effects studies partly due to the fact this site is largely contaminated with 1,4 dioxane in its pure form in up to 850.000 pounds dumped in the area.
A regestry of health effects would be very useful for the community to understand and work on several health effects associated with past exposures of the compound. Unfortunately, these exposures are worldwide and have great need for prevention and treatment options.
NSG Tests continue:
The ACWG and CARD had asked EGLE in past years to do tests of the Allen's Creek during low flow periods as most agree this would be more likly to be near-surface groundwater (NSG). These recent tests were done in low-flow periods. The geologist for EGLE on site helping with sampling did not see a problem sampling in dry conditions and told me that he had to walk a long way up the open section of the Allen's Creek behind our house in our FairGlen Wooded Commons off Glendale Circle to get any water to test.
Residents were advised to use bottled water after new dioxane exposure discovery north of Ann Arbor plume.
This pollution in the Allen's Creek during drought periods is almost surely from the Gelman Toxic 1,4 Dioxane Plume in near-surface shallow groundwater (NSG) that is picked up by the Allen's Creek Drain system that illegally flows through West Park.
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
With the ruling from the Michigan Court of Appeals, the previous MI Court Judgement with more protective exposure values is now disallowed and the old less protective exposure levels are reinstated, from 7.2 ppb to 85 ppb standard, although Gelman has kept with the 7.2 standard in recent years. The Judge ruled that the Interveners (Local Elected officials and NGOs) should not have been allowed to join the suit. The legal team for the community failed to provide a strong enough argument for the inclusion of Interveners.
The more than a million taxpayers' dollars spent was for naught and the result is a much less protective exposure rules are now in effect. Chris Taylor's law firm (which he is and owner and Principle) was very involved in this case which was a failed process according to the Judge. Taylor says he gets no income from his firm working with Scio Twp. on the Gelman pollution but he is an owner and Principle of the firm that is making hundreds of thousands of dollars and prestige in working on this case. Many have said he should recuse including us.
West Park area and nearby parts of the Allen's Creek creek picks up a lot of groundwater, you can stand on top of the grates and you can hear it gushing even in a major drought condition, generally agreed is high groundwater flows. EGLE did the latest tests during a low rainfall time, as they have in the past, to obtain better data on the groundwater contamination. EGLE has detected 1,4 dioxane in West Park groundwater, West Park pond and Allen's Creek Drain, Chapen St., 8th St in front of Slauson Middle School. Others have tested contaminated Near-Surface Groundwater (NSG) in West Park. Past tests, during extreme drought conditions, of the West Park Allen's Creek showed no 1,4 Dioxane Positive tests just upstream yet positive in West Park. 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.
The concern here is that with lots of homes on the West Side with wet or very wet basements, from groundwater, "vapor intrusion" of contaminated groundwater could be a concern. This groundwater is near-surface and as such could be a violation of the Prohibition Zone which is said to protect against exposure to 1,4 dioxane from the Toxic Dump Site. Very minimal tests of basement intrusion of contaminated groundwater have been done in the city, which has been questioned by CARD and ACWG.
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. Other 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.
'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.
Groundwater coming to the surface on the near west side are the reasons 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:
Scio Twp Gelman Plume Townhall 2-17-2022
EWG https://www.ewg.org/tapwater/reviewed-1-4-dioxane.php
https://www.mlive.com/news/ann-arbor/2021/11/in-letter-to-epa-dingell-calls-latest-ann-arbor-area-dioxane-news-alarming.html
EPA, EGLE and Local Government Joint Session on 3-18-21; YouTube link to the Video
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.
Water Resources Commissioner Has Questioned the Threat of Liquid To Vapor Intrusion in Ann Arbor, Especially In West Park Area Where 49 ppb Was Found In Recent Years in Near-Surface Groundwater
Roger Rayle (top photo); Jack Eaton, Vince Caruso (Photos SRSW, ACWG),
Ann Arbor Green Fair October 2022
(CARD, ACWG; Rt Clk for larger)
Graphic Abstract to R. Bailey's Article from
Elsevier Journal- Current Opinion in Environmental Science & Health 12-2022
(R. Bailey; Rt Clk for larger)
At the latest Green Fair and in emails from Water Resources Commissioner (WRC) I have been accused of falsely claiming that Liquid To Vapor Intrusion (LVI) is a real danger in Ann Arbor, especially in West Park with tests showing 49 ppb in recent years there in Near-Surface Groundwater (NSG).
EGLE's Dan Hamel commented at the last CARD meeting that:
"[we] interpreted [it] to be contaminated groundwater shallow groundwater venting to the to the drain", as noted in the transcript from the meeting below.
At the most recent CARD meeting Dan Hamel's comments regarding LVI:
From Transcript of CARD meeting January 3, 2023
Dan Hamel Comments on NSG in West Park:
Link to location of discussion of NSG described below, in the YouTube video*
https://youtu.be/eZ1Ih6XuAOE?t=2840
YouTube video link: https://www.youtube.com/watch?v=eZ1Ih6XuAOE:
YouTube Transcript excerpts:
48:16 Vince identified as we sample that once or twice a year and down in West Park at
48:21 the great [grate] there and that's where there is positive actions in there which are interpreted to be
48:28 contaminated groundwater shallow groundwater venting to the to the drain
48:34 so and then moving down you know down gradient down the pipe and so we do have
48:39 positive detections in there we have done some in years past some uh shallow
48:46 groundwater investigations down there
(Bold By Us)
Note: Shallow Groundwater is the same as Near-Surface Groundwater (NSG).
I as an ACWG and CARD member and others have asked EGLE to do meaningful testing NSG with shallow wells which was rejected. In desperation we then asked to test Allen's Creek drains in West Park and in other locations where high flows occur even in major drought conditions which was very likely NSG flows into the drains. This simple request quickly showed positive results EGLE detected 1,4 dioxane in West Park groundwater, West Park pond and Allen's Creek Drain, Chapen St., 8th St in front of Slauson Middle School. As noted above EGLE considers this NSG.
Findings from tests requested and pushed by CARD, Scio Residents for Safe Water (SRSW) and ACWG of significant NSG contamination in West Park and the threat to homeowner and business exposures lead to an EGLE implementation of a First State-Wide Vapor Intrusion Rule for the State of Michigan and set lower standards for drinking water to 7.2 ppb. EPA also cited this as a major reason to consider a Superfund Site for the Gelman/Danaher 1,4 Dioxane Toxic Waste Plume. High-ranking EGLE officials commented to CARD /ACWG that public involvement in this Gelman/Danaher 1,4 Dioxane Toxic Waste Plume was a major reason for this change.
As we, and others, have said the LVI danger is real for many locations of the Gelman Toxic Plume and West Park is showing signs that the plume is very close to the surface at this location and likely others. Scio Twp. has many homes in low-lying areas that may also at risk.
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.
Liquid to Vapor Intrusion (LVI) is a real issue being faced by many sites which were built over old dump sites and sites in the path of toxic plumes like Gelman/Danaher's 1,4 Dioxane Toxic Dump Site Plume moving through Scio, Ann Arbor Townships and Ann Arbor.
At a CARD meeting years ago discussion of the Ann Arbor City Apartments at Washington and First St came up regarding the below-ground parking 2 stories below grade. The ACWG and the CARD Group asked about potential groundwater contamination with 1,4 Dioxane issues with this city-owned parking garage below in the path of the plume, deep into the water table. Soon thereafter we learned the city did a stop-work order to make changes to the soon-to-be-started building, to raise the building a full 2 stories up to avoid this issue. The city's explicit requirement not to have parking on the street level was quickly thrown out the window. At the DTE site we know we have major pollution below the surface and yet feel OK with building residential above it very close to the dangerous pollution.
Dr. Robert E. Bailey, Dr. Rita Loch-Caruso article on Liquid to Vapor Intrusion it the first ever Peer-Reviewed article showing this exposure to chemicals near basements and will likely be incorporated in many environmental studies and cleanup efforts.
This exposure route may be a major issue with the Gelman Plume as 1,4 dioxane is very missable in water (likes to stay with water. why it is so hard to clean up) and will evaporate with the water if it enters a confined space like a basement or slab on grade home or building and exposes the occupants.
With 98 ppb at Sisters Lake and was 49 ppb at West Park and Dr. Bailey's calculations showing 150 ppb a potential health issue, this is a real concern for the Gelman/Danaher mitigating plume.
A Note:
Environmental Toxicology 2022: 1,4 DioxaneEdited by Vasilis Vasiliou, Yale University, USEPA SuperFund Center Director at Yale University
Articles have been published and were available for personal use during the 50-day Free Access till January 13th, after which is embargoed till the one-year Embargoed date from November 24, 2022.
Links and Articles are for Personal Use Only Till the One Year Journal Embargo Period is Over
Article Titles:
- "Michigan's Gelman Site 1,4-Dioxane Groundwater Contamination: Still Spreading Decades after Detection"
- "Atmosphere of Wet Basements as a Novel Route for Potential Residential Exposure to 1,4-Dioxane Vapor"
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
Proposal To Build Residential Affordable Housing in Huron River OxBows, Major Flood Risk with Global Warming, Is Not a Safe Proposition According to First Street Foundation and Others
First Street Foundation Evaluations, 30 Year Maps, Huron River OxBows at Ann Arbor,
DTE Major Toxic Dump Site is at Left North of Tracks Now to Start Building Residental and Hotel
(Annotations by ACWG; Rt Clk for larger)
"... the Equitable Ann Arbor Land Trust, also known as EA2, a nonprofit group that hopes to catalyze creation of affordable and market-rate housing in sustainable, mixed-use developments near the river to address a housing shortage with a focus on creative placemaking."
"EA2 has laid out a draft development plan focusing on eight spots within five oxbows or U-shaped bends along the river where the group sees potential for 5,000 to 10,000 housing units. The group aims to inspire the city and University of Michigan to get behind the vision, since most of the sites are city-owned or university-owned parking lots."
The above maps show some of the 30 Year Flood Hazard for the OxBows along the Huron River in Ann Arbor, First Street Foundations FloodFactor(r).
Ann Arbor needs to lead in protecting the residents and environment with the real threats from Global Warming effects like extreme weather we have already experienced.
Michigan has had 1,000-year (.1% chance) rains in recent years, enough to destroy 13 bridges in SouthWest Michigan and destroy towns in the UP and, flooding several towns in one event. Lightning storms have also gotten much stronger with bigger storm events, causing concerns for those outside during storm events.
Recent credible reports have stated that FEMA "Low Balls" floodplain maps by up to 33% across the country due to reduced funding and political pressure. Ann Arbor is approving buildings without knowing the real flood risk or location of the Floodway when they rely on FEMA flood maps. FEMA even says they are working on FEMA 2.0 to try to make maps more reliable. They are working with First Street Foundation to upgrade the flood maps.
Flood hazard is getting worse, not better with Global Warming. The OxBows are the old Huron River riverbed, some just downstream of two dams both of which were breached and others completely failed in the 1968 100-year (1% chance) flood, which had 15 feet of water flowing over the DTE OxBow site. The 1968 flood is more like a 50-year (2% chance) flood of today by many accounts.
Time to stop putting the less fortunate and new housing in harm's way with real flood risk in the coming years.
Links:
FEMA "Low Balls" floodplain maps by up to 33%
BridgeMI: "Road salt, a stealthy pollutant, is damaging Michigan waters"
Mall Rd, Portland ME, 6 Lane Porous Pavement Roadway
(Google Maps; Rt Clk for larger)
Road salt, a stealthy pollutant, is damaging Michigan waters
January 26, 2023 | Brett Walton, Circle of Blue in Michigan Environment Watch
Rivers and lakes are becoming saltier while law and practice limit effective responses.
ACWG was instrumental in getting the city to use porous (permeable) pavement over many years. The ACWG went to a MI Concrete Assoc. demonstration project in Lansing MI around 2013 where they paved their large parking lot with porous concrete as a demonstration project to support porous pavements. They saved $30,000 in connection fees to the county drain with this project.
The city of Ann Arbor has done some porous roadways with the urging of the ACWG but has pulled back on this effort. U of M did a very large porous pavement parking lot on off Fuller Rd near Mitchel Field that can handle 1,300 inches of rain an hour (this is like many hurricanes going over it at once rain event)! Walden Pond has a very nice looking porous parking lot that was installed in 1972.
Porous pavement allows much less salt use because the reduction of Black Ice, and 2" snow melts quickly. Porous pavement with naturally occurring micorbes in the pores of the pavement detoxifies common pollutent on roadways when the rain water soaks into the pavement. Also will make the community much less noisy.
The new Mall Rd. porous roadway was credited with the major restoration of a nearby Long Creek, an impaired waterway, that flows into the ocean less than a mile away.
Links:
ACWG on Benifits of Porous Pavement
https://www2.a2gov.org/greeninfra/SylvanAvenuePermeableAsphalt.pdf
Bridge: Road salt, a stealthy pollutant, is damaging Michigan water
December 2022 - No Meeting this Month Due to COVID-19 Pandemic Cautions
Watershed Issues of Interest and Updates
EPA Has Finished the Gelman/Dananer Toxic Waste Dump Site Contamination Testing of 1, 4 Dioxane and Will Likely Declare the Site a Superfund Site This Next Year, New Data On NSG Contamination
Gelman Site likly to be a Long Overdue, and Ridiculed by some, Superfund Site By Next Year
EPA has finished doing various tests of the Gelman/Danaher 1,4 dioxane (solvent) toxic plume under Ann Arbor, Ann Arbor Twp and Scio Twp this month in preparation for a decision on EPA Superfund designation for the Gelman Toxic Plume.
Reliable sources indicate that the preliminary EPA finding was 50 point result, out of a total 50-point maximum, in support of a Superfund site and will very likely find the same result after analyzing the data collected in the past year or so. A Superfund designation is very likely this year and a full cleanup or close to that may start this year.
New Tests by Townships Show Well Contamination Expanding
Ann Arbor and Scio Twp have done recent tests in October and November, with their own funds, using the EPA Method 522, which detects contamination down to 0.12 ppb in drinking water. Tests are shown on the city website.
Why townships need to pay for best tests for 1,4 dioxane in drinking water wells is a travesty.
Township Results show:
Up to 9.1 ppb in Ann Arbor Twp drinking water well, single-family residential well
Honey Creek 1.6-2.4 ppb this year
3.7-6.8 ppb in Scio Twp tributaries
Tests in Barton Pond were non-detect just downstream
Environment, Great Lakes and Energy (EGLE) Tests done in early October during low rain period, show:
Up to 9.1 ppb in Ann Arbor Twp drinking water well. residential well
West Park 37 ppb, Chapin St 15 ppb, Hannah Nature Area 1 ppb
Near West Park Eighth Street showed 19 ppb, up from 13 ppb in 2021 and 11 ppb in 2020
Eighth Street across from Slauson Middle School showed 2.4 ppb down from 2.5 ppb in 2020
No detections the last three years at First Sister Lake, Second Sister Lake and Arbor Landing Pond
Third Sister Lake in UM’s Saginaw Forest just west of the Gelman site in Scio Township showed 98 ppb up from 3 to 57 ppb in 2021 and 2020
Little Lake just northwest of Third Sister Lake, showed 6.6 ppb, up from 4.2-4.9 in 2021 and 2020
The ACWG and CARD had asked EGLE in past years to do tests of the Allen's Creek during low flow periods as most agree this would be more likley to be near-surface groundwater (NSG). These recent tests were done in low-flow periods. The geologist for EGLE on site helping with sampling did not see a problem sampling in dry conditions and told me that he had to walk a long way up the open section of the Allen's Creek behind our house in our FairGlen Wooded Commons off Glendale Circle to get any water to test.
Residents were advised to use bottled water after new dioxane exposure discovery north of Ann Arbor plume.
This pollution in the Allen's Creek during drought periods is almost surely from the Gelman Toxic 1,4 Dioxane Plume in near-surface shallow groundwater (NSG) that is picked up by the Allen's Creek Drain system that illegally flows through West Park.
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
With the ruling from the Michigan Court of Appeals, the previous MI Court Judgement with more protective exposure values is now disallowed and the old less protective exposure levels are reinstated, from 7.2 ppb to 85 ppb standard, although Gelman has kept with the 7.2 standard in recent years. The Judge ruled that the Interveners (Local Elected officials and NGOs) should not have been allowed to join the suit. The legal team for the community failed to provide a strong enough argument for the inclusion of Interveners.
The more than a million taxpayers' dollars spent was for naught and the result is a much less protective exposure rules are now in effect. Chris Taylor's law firm (which he is and owner and Principle) was very involved in this case which was a failed process according to the Judge. Taylor says he gets no income from his firm working with Scio Twp. on the Gelman pollution but he is an owner and Principle of the firm that is making hundreds of thousands of dollars and prestige in working on this case. Many have said he should recuse including us.
Scio Twp With 98 ppb Was Found in Sister Lake in the Saginaw Forest With Lots of New Homes Going In Currently
Graphic Abstract to R. Bailey's Article from
Elsevier Journal- Current Opinion in Environmental Science & Health 12-2022
(Rt Clk for larger)
EGLE tested Allen's Creek in West Park and other locations early this October
EGLE tested on the city west side as the ACWG and Coalition for Action on Remediation of Dioxane (CARD) requested for many years now and they have obliged.
West Park area and nearby parts of the Allen's Creek creek picks up a lot of groundwater, you can stand on top of the grates and you can hear it gushing even in a major drought condition, generally agreed is high groundwater flows. EGLE did the latest tests during a low rainfall time, as they have in the past, to obtain better data on the groundwater contamination. EGLE has detected 1,4 dioxane in West Park groundwater, West Park pond and Allen's Creek Drain, Chapen St., 8th St in front of Slauson Middle School. Others have tested contaminated Near-Surface Groundwater (NSG) in West Park. Past tests, during extreme drought conditions, of the West Park Allen's Creek showed no 1,4 Dioxane Positive tests just upstream yet positive in West Park. 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.
The concern here is that with lots of homes on the West Side with wet or very wet basements, from groundwater, "vapor intrusion" of contaminated groundwater could be a concern. This groundwater is near-surface and as such could be a violation of the Prohibition Zone which is said to protect against exposure to 1,4 dioxane from the Toxic Dump Site. Very minimal tests of basement intrusion of contaminated groundwater have been done in the city, which has been questioned by CARD and ACWG.
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. Other 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 resediments 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.
Findings from tests requested and pushed by CARD, Scio Residents for Safe Water (SRSW) and ACWG of significant NSG contamination in West Park and the threat to homeowner and business exposures lead to an EGLE implementation of a State-Wide Vapor Intrusion Rule for the State of Michigan and set lower standards for drinking water to 7.2 ppb. EPA also cited this as a major reason to consider a Superfund Site for the Gelman/Danaher 1,4 Dioxane Toxic Waste Plume. High-ranking EGLE officials commented to CARD /ACWG that public involvement in this Gelman/Danaher 1,4 Dioxane Toxic Waste Plume was a major reason for this change.
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.
'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.
Groundwater coming to the surface on the near west side are the reasons 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:
Scio Twp Gelman Plume Townhall 2-17-2022
EWG https://www.ewg.org/tapwater/reviewed-1-4-dioxane.php
https://www.mlive.com/news/ann-arbor/2021/11/in-letter-to-epa-dingell-calls-latest-ann-arbor-area-dioxane-news-alarming.html
EPA, EGLE and Local Government Joint Session on 3-18-21; YouTube link to the Video
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.
Liquid to Vapor Intrusion is a Major Issue With Gelman Plume and Other Plumes
Graphic Abstract to R. Bailey's Article from
Elsevier Journal- Current Opinion in Environmental Science & Health 12-2022
(Rt Clk for larger)
Liquid to Vapor Intrusion (LVI) is a real issue being faced by many sites which were built over old dump sites and sites in the path of toxic plumes like Gelman/Danaher's 1,4 Dioxane Toxic Dump Site Plume moving through Scio, Ann Arbor Townships and Ann Arbor.
New development in Scio Twp with 98 ppb was found in Sister Lake in the Saginaw Forest With Lots of New Homes going In currently. Dr. Bailey's article shows 150 ppb 1,4 Dioxane near basements could be dangerous in some cases, especially if the liquid-contaminated water enters the home and evaporates without any or enough ventilation. Skin contact to the liquid-contaminated water is less of an issue but still not advised as the 1,4 D will be absorbed on the skin but not as dangerous as breathing the vapors of 150 ppb or greater.
As we have noted earler here, in Petoskey MI recently 11 of 14 condos were evacuated due to VI issues from building in an old dump site. See our website for information on Vapor Intrusion as it relates to the Gelman Toxic Dump Site and Plume.
At a CARD meeting years ago discussion of the Ann Arbor City Apartments at Washington and First St came up regarding the below-ground parking 2 stories below grade. The ACWG and the CARD Group asked about potential groundwater contamination with 1,4 Dioxane issues with this city-owned parking garage below in the path of the plume, deep into the water table. Soon thereafter we learned the city did a stop-work order to make changes to the soon-to-be-started building, to raise the building a full 2 stories up to avoid this issue. The city's explicit requirement not to have parking on the street level was quickly thrown out the window. At the DTE site we know we have major pollution below the surface and yet feel OK with building residential and a hotel* above it very close to the dangerous pollution.
Dr. Robert E. Bailey, Dr. Rita Loch-Caruso article on Liquid to Vapor Intrusion is the first ever Peer-Reviewed article showing this exposure to chemicals near basements and will likely be incorporated in many environmental studies and cleanup efforts.
This exposure route may be a major issue with the Gelman Plume as 1,4 dioxane is very missable in water (likes to stay with water. why it is so hard to clean up) and will evaporate with the water if it enters a confined space like a basement or slab on grade home or building and expose the occupants.
With 98 ppb at Sisters Lake and was 49 ppb at West Park and Dr. Bailey's calculations showing 150 ppb a potential health issue, this is a real concern for the Gelman/Danaher mitigating plume.
A Note:
"Environmental Toxicology 2022: 1,4 Dioxane" Edited by Vasilis Vasiliou, Yale University, USEPA SuperFund Center Director at Yale University
Articles have been published and available for personal use during the 50-day Free Access till January 13th, after which is embargoed till the one-year Embargoed date from November 24, 2022.
Links and Articles are for Personal Use Only Till the One Year Journal Embargo Period is Over
Article Titles:
- "Michigan's Gelman Site 1,4-Dioxane Groundwater Contamination: Still Spreading Decades after Detection"
- "Atmosphere of Wet Basements as a Novel Route for Potential Residential Exposure to 1,4-Dioxane Vapor"
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
City Leaders Push For More High-Rises While Our Water Source is Being Push to Its Limits
GLWA Intake For AA Water, Just Below Zug Island Mega Dump Site and
Other Near By Dump Sites, Sewer Treatment Plant that Overflows (SSO) Regularly and Rouge River Outfall
(ACWG Annotated in Red (Google Maps), Rt Clk for larger)
The city of Ann Arbor keeps pushing for more High-Rise that residents reject while our water supply is being pushed to its limits.
As we have commented here in the recent past Low Rise development, like Paris for example, actually provide more density and is more human center development.*
This city is being pressured by Developers, Real-estate interests and, the U of M with a record 50k student enrolments. The effects on the community are not being evaluated carefully as shown by the GLWA proposal which was shot down due to cost, quality and environmental effects (super high energy needs and costs to the environment to pump so much water from the Detroit River to Ann Arbor).
Water source not what some have communicated to the city. 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 early this year 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 (and long-time follower of Gelman Pollution) and others in ACWG comment.
City utility staff did not support GLWA switch for Ann Arbor drinking water in reports to City Council yet many on council including the mayor ignored the concerns.
It is clear that our drinking water source will not be able to service huge new developments unless we go with the environmentally unfriendly, polluted and super expensive GLWA water piped from the Detroit River. This could also be seen as a major subsidy for developers at the cost of existing residents who will likely receive poor-quality water at an extremely higher cost.
TC1 - SuperHigh Buildings at SuperHigh Costs For Existing Residents*
Recent reports indicate the city TC1 Super High-density Zoning effort (proposed initially unlimed building heights, now up to 700' tall buildings) was not vetted very well as the easements needed for the TC1 Zoning will cost the city much more than it could afford for many years if ever. It may also take a very long time to work out all the Bugs in the "plan".
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!
Costs for the water will be mainly bared by existing residents as they pay 80% of city taxes and utility bills, and receive much poorer drinking water.
Vasilis Vasiliou PhD, Chair of Public Health of Yale University, USEPA SuperFund Center Director at Yale University
(Yale (Yale), Rt Clk for larger)
Dr. Vasiliou has recently received in October 2022 a US EPA SuperFund Center Grant to study 1,4D health effects. He is the Chair of this Superfund Grant.
Vasilis Vasiliou PhD, Chair of Public Health of Yale University
Dr. Vasiliou attended the last CARD meeting and commented
He would like to attend more CARD meetings
Hi would like to attend any Town Hall meetings
He is very interested in Health Effects from 1,4 Dioxane exposures in the Ann Arbor Area
It would be great to try to pull together information and data of exposures that he and his group at Yale can investigate this unique situation of toxic exposures. We are likly one of the only sites with almost pure 1,4 D exposure and in some cases very high exposures in past decades. CARD does have some significant data to share ranging over many decades. It will be necessary to evaluate privacy issues with any data that may be used.
I have commented to him at the last CARD meeting that we have a unique exposure that may be very useful in determining effects of various 1,4D exposures. He seemed very interested in our situation and how his center and Yale SPH could help our community and better understand the health effects of 1,4 D.
He may also investigate cleanup options for various forms of contamination of 1,4 D.
Unfortunately, 1,4 D is a very common contaminant not just in the US but worldwide Dr. Vasiliou commented at the CARD meeting. He felt it is urgently needed to understand and discover cleanup processes. Little is known about 1,4 D exposures.
New Discussions at City Hall Regarding Developing 415 W. Washington for Residential
(First Street Evaluation, Rt Clk for larger)
415 W. Washington Floodplain Map; Floodway in Blue, Floodplain in Green
(ACWG; Rt Clk for larger)
The First Steet Foundation has been closely working with Federal Emergency Management Agency (FEMA) in recent years to update the greatly LowBalling floodplain maps, and FEMA agrees. FEMA is now working on FEMA 2.0 to update the maps they say are not accurate.
This site has been forbidden to be used for Affordable housing with city funds by city council against the mayor and others wishes. Floodplains are not for residential and will be even more so as we see more Global Warming effects in Ann Arbor and Worldwide.
The floodplain and floodway delineations for this site are arguably outdated and inaccurate and unsafe to unsuspecting individuals.
Y site across the street is not accurately included in flood hazard mapping with fencing and other obstructions across virtually the entire site acting as a huge dam for floodwaters, in the middle of the floodway, flowing to the river. ACWG strongly petitioned the MDEQ to stop the Y building and then later after the building was finished, the Y fencing but was not successful.
This fencing and other obstructions were installed after the building was finished.
Smith Group has commented in public meeting recently 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.
The Y lost the required FEMA Freeboard (open space 1' above the floodplain safety zone) in just 1.5 years after it was built, in a FEMA Letter of Map Revision (LoMR), and is out of state floodplain floodway compliance!!
Y has regular flooding evacuation drills and worries about flood hazard according to a reliable inside source.
Jerry Hancock, Stormwater and Floodplain Programs Coordinator on flooding at the Y and 415 site:
The obstructions at the YMCA site were included on the MDEQ permit and were in place when the study was done for the 2012 FEMA Flood Insurance Rate Maps (FIRM). The YMCA floodway obstruction's impact on 415 W. Washington St. is already taken into account on the current FIRM.
Just to note the FIRM raw data used for maps is basically 1968 flood data, from the 100-year (1% chance) flood of that year and as such is not up to date. Consultant/Planners hired for the YMCA site plans thought the FIRM maps were based on 1992 data because the maps had a 1992 printing date. ACWG corrected that statement, even though the planner would not agree during a meeting on this issue. He said he would get back to us but never did.
As was noted earlier in a past Agenda entry, the Smith Group Planner currently working on the 415 W. Washington site stated the the YMCA building would never get approved today by the EGLE, former MDEQ.
It would be malpractice to propose residential on this site given the facts about the flood hazard, outdated FEMA Maps, and soon will be much worse flood hazard here.
Link: MLive https://www.mlive.com/news/ann-arbor/2015/09/should_ann_arbor_adopt_new_reg.html#incart_river
November 2022 - No Meeting this Month Due to COVID-19 Pandemic Cautions
Watershed Issues of Interest and Updates
Early General Press Release Elsevier Journal: CARD, SRSW, ACWG Articles
Sent by Rita Loch-Caruso PhD, Nov. 28, 2022
Below the ground’s surface and out of sight, a plume of groundwater contaminated with 1,4-dioxane continues to spread despite decades of remediation effort. The plume originates from the Gelman Sciences, Inc. industrial site in Scio Township just west of the city of Ann Arbor.
This 1,4-dioxane groundwater contamination is the subject of two invited articles recently published in a special issue on 1,4-dioxane in the journal Current Opinion in Environmental Science & Health. One article provides the historical context for current concerns for human exposure and health from the Gelman Sciences contamination. The other article describes a novel exposure pathway for 1,4-dioxane and potential cancer risk that could arise in homes with damp basements in contact with contaminated groundwater. The authors are members of the Coalition for Action on Remediation of Dioxane (CARD), a multi-jurisdiction partnership of citizens and government representatives working to coordinate responses related to the Gelman Sciences 1,4-dioxane contamination.
The articles are accessible without charge from the journal until January 14, 2023 using the following links:
Michigan's Gelman Site 1,4-Dioxane Groundwater Contamination: Still Spreading Decades after Detection: https://authors.elsevier.com/a/1g8o68nIePaaYW
Novel Route for Potential Residential Exposure to 1,4-Dioxane Vapor:
https://authors.elsevier.com/c/1g94G8nIePaaYi
After January 14, 2023, access to the journal publications will be restricted by subscription. However, the articles will be publically available after the journal’s embargo period on the National Institutes of Health's National Library of Medicine PubMed Central website.
Rita Loch-Caruso, PhD
Professor Emerita of Toxicology, Dept of Environmental Health Sciences, SPH
Professor Emerita of Program in the Environment, LSA
University of Michigan
Ann Arbor, MI
Founding Member and Member CARD and ACWG
Founding and 13 Year Member and Chair of Ann Arbor Environmental Commission
Environmental Toxicology 2022: 1,4 Dioxane
Edited by Vasilis Vasiliou, Yale University, USEPA SuperFund Center Director at Yale University
Articles have been published and available for personal use during the 50-day Free Access till January 13th, after which is embargoed till the one-year Embargoed date from November 24, 2022.
Links and Articles are for Personal Use Only Till the One Year Journal Embargo Period is Over
Article Titles:
- "Michigan's Gelman Site 1,4-Dioxane Groundwater Contamination: Still Spreading Decades after Detection"
- "Atmosphere of Wet Basements as a Novel Route for Potential Residential Exposure to 1,4-Dioxane Vapor"
Graphic Abstract To R. Loch-Caruso's Article
Graphic Abstract to R. Bailey's Article
(Rt Clk for larger)
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
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.
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.
One option with the Yale US EPA Superfund grant is to investigate health effects in the Ann Arbor area with so many exposed over many decades at some very high concentrations, this is a very unique situation for 1,4 dioxane drinking water contamination. Very few sites have had this almost pure 1,4 dioxane contamination, with estimates of 850,000 pounds pumped or dumped into the ground or waterways. Something we will need to promote in the next few years. We have Gelman old data of thousands of exposures over many years that would very useful in this effort.
EPA doing more tests this month in Ann Arbor and the area in preparation for a decision on EPA Superfund designation for the Gelman Toxic Plume.
Testing In West Park Allen's Creek on West Side of Park, Nov. 3, 2022
EGLE, City of Ann Arbor Staff and City Council Member Kathy Griswold
(ACWG; Rt Clk for Larger)
EGLE tested Allen's Creek in West Park and other West Side locations early this October
EGLE tested on the city west side as the ACWG and Coalition for Action on Remediation of Dioxane (CARD) requested for many years now and they have obliged. This test was done in very dry conditions with very large flows in the Allen's Creek in West Park drain. Data will be available in about a month (longer than normal due to EGLE's current high demand for lab tests). This part of the creek picks up a lot of groundwater, you can stand on top of the grates on top of the Allen's Creek drain and you can hear it gushing even in a major drought condition, generally agreed is high groundwater flows. EGLE did the latest tests during a very low rainfall time, as they have in the past, to obtain better data on the groundwater contamination. EGLE has detected 1,4 dioxane in West Park groundwater, West Park pond and Allen's Creek Drain, Chapen St., 8th St in front of Slauson Middle School. Others have tested contaminated Near-Surface Groundwater (NSG) in West Park. Past tests, during extreme drought conditions, of the West Park Allen's Creek showed no 1,4 Dioxane Positive tests just upstream yet positive in West Park. Minimal shallow groundwater well tests by the county and city in recent years did show 1,4 dioxane. 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.
We have requested copies of the AsBuilt plans for West Park and West but have not received them after many requests including while in the County Water Resources Office.
The concern here is that with lots of homes on the West Side with wet or very wet basements, from groundwater, "vapor intrusion" of contaminated groundwater could be a concern. This groundwater is near-surface and as such could be a violation of the Prohibition Zone which is said to protect against exposure to 1,4 dioxane from the Toxic Dump Site. Very minimal tests of basement intrusion of contaminated groundwater have been done in the city, which has been questioned by CARD and ACWG. We have not been asked to advise government officials as to the best locations for testing which has led to funds being wasted on meaningless studies of groundwater and basement contamination.
One simple test we have requested is to test the basement of the West Park Band Shell which is in close proximity of groundwater both for effluent and air contamination of 1,4 Dioxane. This building is not in use for over a year and would be a simple effort.
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. Other 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 resediments of the community facing the real and present danger from the Plume, leaving Ann Arbor in the Lurch.
City of Ann Arbor is spending $300K to install wells to detect migration of the Gelman Toxic Waste Plume near Ann Arbor. We know we have had 49 ppb Gelman 1,4 dioxane in groundwater in Allen's Creek in West Park area in recent years. Meaningful tests of Near-Surface Groundwater (NSG) are not going to happen apparently until EPA gets involved in finding the true extent of NSG contamination.
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.
Findings from tests requested and pushed by CARD, Scio Residents for Safe Water (SRSW) and ACWG of significant NSG contamination in West Park and the threat to homeowner and business exposures lead to an EGLE implementation of a State-Wide Vapor Intrusion Rule for the State of Michigan and set lower standards for drinking water to 7.2 ppb. EPA also cited this as a major reason to consider a Superfund Site for the Gelman/Danaher 1,4 Dioxane Toxic Waste Plume. High-ranking EGLE officials commented to CARD /ACWG that public involvement in this Gelman/Danaher 1,4 Dioxane Toxic Waste Plume was a major reason for this change.
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 4 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.
'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)
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 Now Collecting Data, and Likely Declare the Gelman Plume a Superfund Site:
An EPA official attends some of the CARD meetings and has said that US EPA is now working with a consultant and they are now collecting critical supporting data for the Superfund designation of the Gelman/Danaher Toxic Waste Plume. These tests and analyses and evaluations should be done in 6 to 12 months as is the normal process for EPA Superfund Site Listing. The delay in this process was caused by the requirement to use a different consultant to do tests because the normal consultant was not allowed due to conflicts of interest of related past efforts with the Gelman Plume.
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.
Groundwater coming to the surface on the near west side are the reasons 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 2022; https://www.youtube.com/watch?v=HDs2Me8GsEE
Scio Twp Gelman Plume Townhall 2-17-2022
EWG https://www.ewg.org/tapwater/reviewed-1-4-dioxane.php
https://www.mlive.com/news/ann-arbor/2021/11/in-letter-to-epa-dingell-calls-latest-ann-arbor-area-dioxane-news-alarming.html
EPA, EGLE and Local Government Joint Session on 3-18-21; YouTube link to the Video
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.
MI EGLE Awards $400,000 to Ann Arbor, and the City Will Contribute $100,000 For Stormwater Comprehensive Stormwater Management Plan; City Pulls Away from Past Practices on Very Polluted Stormwater Cleanup and Major Flood Dangers
City of Ann Arbor Porous Pavement Poster in Recent Past Years
(Rt Clk for larger)
University of Michigan Fuller Rd Parking Lot, Ann Arbor, 2020
Porous Pavement where cars are parked, Handles 1,300" an Hour (city staff tests)
The access area in the center is not porous and shows cracks fixed
(Google Maps; ACWG; Rt Click for Larger)
Canceled Fuller Park Proposed Mega Parking Garage (for U of M Hosp in Our Fuller Park)/Tiny Train Station
with Porous Pavement Proposed for All Access Roads,
Rain Gardens, and Underground Infiltration Trenches
(City of Ann Arbor, Large Arrowed Labels by us, Rt Clk for Larger)
Infiltration Beds Being Installed Below to be Paved Street at 4th Street between Huron and Washington
(ACWG; Rt Clk for Larger)
A grant application to receive $400,000 from the Michigan Department of Environment, Great Lakes and Energy (EGLE) High Water Infrastructure Grant Program. The City will provide $100,000 in local matching funds from the Stormwater Sewer System Fund. A total of $500,000 will be spent to update and align the City’s Comprehensive Stormwater Management Plan with resiliency and climate adaptation strategies. This project will evaluate and quantify the effectiveness of the City’s street trees, the community’s urban forest, and other green infrastructure and best management practices on stormwater management. (City of Ann Arbor Legistar)
Many of these methods were presented and promoted by the ACWG for many years. The city has pulled back on stormwater improvements, like the use of porous pavement which the city has used on many streets in the city and infiltration beds below streets like was done on 4th Street between Huron and Washington.
Benefits of Porous Pavement on Streets, Parking Lots and Paths:
Many examples are listed on our website Benefits of Porous Pavements.
Bruce Ferguson's 7 Top Porous Pavement Myths:
1. It doesn’t work on clay soil
2. It always fails because subgrade is always compacted
3. It always fails because subgrade gets wet & soft
4. It fails where there is freezing in winter
5. It always gets clogged and fails quickly
6. It costs too much
7. There is no experience with it in my region
Bruce K. Ferguson, FASLA
Professor and Director, School of Environmental Design, University of Georgia
Text: Porous Pavements, Bruce K. Ferguson, FASLA; Porous Pavements, Boca Raton,
Florida: Taylor & Francis Group, 2005
Some of the Many Benefits and Examples of Porous (Pervious) Pavements on Roadways:
1. Bicycle safety: Porous pavement does not have Black Ice; better traction, does not hold snow on pavement when it is
below 2” as it melts within a few hours or less; much less heat island effect.
2. University of Michigan Ann Arbor paved a parking lot on Fuller Rd. with porous pavement: handles 1,300 inches of
water per hour according to city staff.
3. Porous asphalt is a good product for local roads, parking lots and trails. A Caltrans study performed in 1989 on the
structural value of open-graded asphalt-treated base and open-graded asphalt concrete pavement concluded that these
materials would be assigned the same structural strength value as their dense-graded counterparts. LID Workshop, UofWash
- Mark A. Palmer, P.E., LEED® APKPFF ConsultingEngineers Tacoma, WA; Oct.2008
4. From the Chicago 2,000 miles of Porous Pavement Allies project - “I think they’re pretty price competitive.” Janet Attarian, the project’s director. Chicago allies are used for cars and trucks accessing home garages, garbage truck pickup and delivery trucks.
5. Much less road noise on pavement or concrete, this when neighbors in Ann Arbor want a less noisy community, like we have on M14 and I94 on the West Side. Pavement would cost less, less noise, less pollution, less flooding, better traction, ... A Portland OR Road Planner said, in a trip to AA to discuss road design with a task force on road improvements, they installed porous pavement on city roads and called them the Butterfly Road because he did not hear cars on the road until they were very close to him and very quiet. I discussed this option with MI MDOT when they had a meeting about I94 paving and they said they would study it.
Probably the longest running quiet pavement study in the nation is on I-80 at Davis, California. That study and others are comparing dense-graded asphalt pavement with open-graded and rubber-asphalt. After eight years, the I-80 pavement has provided a 4.3 dB(A) noise reduction when compared with the original asphalt pavement.
Links: Legistar
https://sites.google.com/site/allenscreekwatershedgroup/benefits-of-porous-pavements-acwg
"3 Downpours in 8 Days: How Extreme Rain Soaked the Midwest" At Least 39 Died: NYT
(NWS, Rt Clk for larger)
From New York Times Article:
"Back-to-back deluges swamped Kentucky, Missouri and Illinois. These types of storms are expected to be more frequent and more intense as the planet warms, climate experts say.
Three separate downpours across three states over a span of eight days this summer swept away homes, destroyed crops and left at least 39 people dead.
The intense rainfall, in Missouri, Kentucky and Illinois, broke century-old records and destroyed swaths of communities, prompting warnings from climate experts, who said the intensity and frequency of heavy rain was likely to increase as Earth continued to warm."
‘Historically unheard-of’ amounts of rain. In four days, between 14 and 16 inches of rain fell in a narrow swath in the eastern part of the state [of KY] according to radar-based estimates from the Weather Service. It said that this is “historically unheard-of” and that there was a less than 1 in 1,000 chance of that much rain falling in a given year." (bold by us)
Michigan has had 1,000-year (.1% chance) rains in recent years, enough to destroy 13 bridges in SouthWest Michigan and destroy towns in the UP and, flood several towns in one event. Lightning storms have also gotten much stronger with bigger storm events, causing concerns for those outside during storm events.
Link: 3 Downpours in 8 Days: How Extreme Rain Soaked the Midwest: NYT
October 2022 - No Meeting this Month Due to COVID-19 Pandemic Cautions
Watershed Issues of Interest and Updates
CARD, SRSW and ACWG Articles in International Journal Elsevier Peer-Review Accepted for Publication in the Invitation Only Journal "Current Opinion in Environmental Science & Health"
Article Titles:
- "Michigan's Gelman Site 1,4-Dioxane Groundwater Contamination: Still Spreading Decades after Detection"
- "Atmosphere of Wet Basements as a Novel Route for Potential Residential Exposure to 1,4-Dioxane Vapor"
Graphic Abstract To R. Loch-Caruso's Article
Graphic Abstract to R. Bailey's Article
(Rt Clk for larger)
Elsevier - Current Opinion in Environmental Science & Health
"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
Abstract:
Disposal practices of industrial wastewater by Gelman Sciences led to high concentrations of 1,4-dioxane in groundwater in Michigan, USA. Since discovery of off-site pollution in 1984, the contaminated groundwater prompted closure of over 124 private wells, closure of one municipal well, and prohibition of most groundwater uses in a large section of the city of Ann Arbor. Recent 1,4-dioxane detections in shallow groundwater in Ann Arbor and in township residential wells pose new exposure threats. Patterns of increased 1,4-dioxane well concentrations raise concerns for threats to Ann Arbor’s municipal water intake in the Huron River. Health effects surveillance from 1,4-dioxane exposure is lacking. The community continues to seek solutions in the decades-long fight to clean up this contamination.
"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
Abstract:
Detection of 1,4-dioxane has been reported in shallow groundwater in neighborhoods of the city of Ann Arbor, Michigan. Michigan has a voluntary 1,4-dioxane shallow groundwater screening level based on its potential for vapor intrusion. Calculations show that if 1,4-dioxane-contaminated water were to enter a basement and evaporate, potentially unhealthy concentrations of 1,4-dioxane could arise in homes with damp basements under certain conditions. Potential residential risk is suggested if: 1) shallow groundwater is within 3 m of the surface, 2) groundwater 1,4-dioxane concentration exceeds 150 μg/L, and 3) a basement has higher humidity than the upper floors. Different from vapor intrusion, this suggests that liquid water intrusion with subsequent volatilization within a structure may be a novel exposure pathway for 1,4-dioxane.
Links to the full articles should be available soon for personal use and Links will be posted here.
These articles were requested by the editor of the journal Vasilis Vasiliou Ph.D., and only publishes articles from invited authors. This current edition of the journal will investigate 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., Emeratus Professor U of M, has been asked, and has accepted an External Advisory Board Member position on the Yale US EPA Superfund Grant.
One option with the Yale US EPA Superfund grant is to investigate health effects in the Ann Arbor area with so many exposed over many decades at some very high concentrations, this is a very unique situation for 1,4 dioxane drinking water contamination. Very few sites have had this almost pure 1,4 dioxane contamination, with estimates of 850,000 pounds pumped or dumped into the ground or waterways. Something we will need to promote in the next few years. We have Gelman old data of thousands exposed over many years that would very useful in this effort.
EPA doing more tests this month in Ann Arbor and the area in preparation for a decision on EPA Superfund designation for the Gelman Toxic Plume.
EGLE will be testing Allen's Creek in West Park as the ACWG and Coalition for Action on Remediation of Dioxane (CARD) requested for many years now and they have obliged. This part of the creek picks up a lot of groundwater, you can stand on top of the grates and you can hear it gushing even in a major drought condition, generally agreed is high groundwater flows. EGLE said they will test during a low rainfall time, as they have in the past, to obtain better data on the groundwater contamination. EGLE has detected 1,4 dioxane in West Park groundwater, West Park pond and Allen's Creek Drain, Chapen St., 8th St in front of Slauson Middle School. Others have tested contaminated Near-Surface Groundwater (NSG) in West Park.
The concern here is that with lots of homes on the West Side with wet or very wet basements, from groundwater, "vapor intrusion" of contaminated groundwater could be a concern. This groundwater is near-surface and as such could be a violation of the Prohibition Zone which is said to protect against exposure to 1,4 dioxane from the Toxic Dump Site. Very minimal tests of basement intrusion of contaminated groundwater have been done in the city, which has been questioned by CARD and ACWG.
Roll Back of 1,4 dioxane Weaker Exposure Standards:
Now that the Michigan Court of Appeals has voided Judge Connors 6/1/2021 court order that included the proposed 4th Consent Judgment, we’ve reverted back to the 3rd CJ and its less protective Groundwater Surface Water Interface (GSI) and drinking water criteria:
3rd CJ: Groundwater Surface-water Interface (GSI) 2800 ppb, drinking water 85 ppb
4th CJ GSI 280 ppb, drinking water 7.2 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. Other 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 supporters 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.
City of Ann Arbor is spending $300K to install wells to detect migration of the Gelman Toxic Waste Plume near Ann Arbor. We know we have had 49ppb Gelman 1,4 dioxane in groundwater in Allen's Creek in West Park area in recent years. Meaningful tests of Near-Surface Groundwater (NSG) are not going to happen apparently until EPA gets involved in finding the true extent of NSG contamination.
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, west side basements like no other entity we can turn to.
Findings from tests requested and pushed by CARD, Scio Residents for Safe Water (SRSW) and ACWG of significant NSG contamination in West Park and the threat to homeowner and business exposures lead to an EGLE implementation of a State-Wide Vapor Intrusion Rule for the State of Michigan and set lower standards for drinking water to 7.2 ppb. EPA also cited this as a major reason to consider a Superfund Site for the Gelman/Danaher 1,4 Dioxane Toxic Waste Plume. High-ranking EGLE officials commented to CARD /ACWG that public involvement in this Gelman/Danaher 1,4 Dioxane Toxic Waste Plume was a major reason for this change.
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 4 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.
'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)
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 Now Collecting Data, and Likely Declare the Gelman Plume a Superfund Site:
An EPA official attends some of the CARD meetings and has said that US EPA is now working with a consultant and they are now collecting critical supporting data for the Superfund designation of the Gelman/Danaher Toxic Waste Plume. These tests and analyses and evaluations should be done in 6 to 12 months as is the normal process for EPA Superfund Site Listing. The delay in this process was caused by the requirement to use a different consultant to do tests because the normal consultant was not allowed due to conflicts of interest of related past efforts with the Gelman Plume.
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.
Groundwater coming to the surface on the near west side are the reasons 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:
Link to Abstract for Articles: https://www.sciencedirect.com/science/article/abs/pii/S2468584422000812
https://www.sciencedirect.com/science/article/pii/S2468584422000800
Scio Twp Gelman Plume Townhall 2-17-2022
EWG https://www.ewg.org/tapwater/reviewed-1-4-dioxane.php
https://www.mlive.com/news/ann-arbor/2021/11/in-letter-to-epa-dingell-calls-latest-ann-arbor-area-dioxane-news-alarming.html
EPA, EGLE and Local Government Joint Session on 3-18-21; YouTube link to the Video
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.
Please Vote In the 2022 November 8th Elections!
Support Effective City Leaders With Proven Track Records in protecting the environment and quality of life in Ann Arbor:
Vote Eric Lipson for Mayor, Independent: Some of Eric Lipson's Positions
You can vote Stright Ticket and for Eric Lipson, Independent, also.
Promote affordable housing options so our teachers, nurses, and service workers can live here.
Take real climate action such as mandating electrically heated buildings when approving NEW development to promote A2Zero sustainability goals, not just ask residents to retrofit their houses and pay more taxes.
Address the long term threat of the dioxane plume to local drinking water. It’s critical that the Gelman Dioxane Cleanup start with strong advocacy for EPA Superfund status which the mayor has resisted. Lobby Lansing for Polluter Pay legislation.
Prevent problems caused by lack of planning that have caused flooded basements and roads, traffic congestion, deteriorating roads and over-taxed infrastructure. We must complete the A2 Comprehensive Land Use Plan before making massive zoning changes.
Recruit minorities to achieve Diversity, Equity and Inclusion goals in hiring and promotion of city staff to correct the city’s shameful past track record of minority hiring and promotion.
Adopt conflict of interest and financial disclosure rules for mayor and council that set forth clear ethics standards and thereby improve government transparency.
Enact Non-Partisan city elections to enfranchise students and others who do not vote in the August Primary. This was vetoed twice by the current mayor.
Protect the health and safety of our 50,000 renters by adding rental housing inspectors. There are only 5 inspectors for 25,000 rental housing units!
Eric Lipson and Mayor Taylor debate presented by the Orchard Hills Maplewood Homeowners’, very informative debate
We have worked with Eric on many pollution issues, recycling, housing and parks issues and find he has a keen mind, great temperament and great experience.
ERIC LIPSON Independent for Mayor of Ann Arbor
https://www.ericlipson4mayor.com/
SRSW, CARD and ACWG at the October 2022 Green Fair
(Roger Rayle (top photo); Jack Eaton, Vince Caruso (Photos SRSW, ACWG),
( Rt Clk for larger)
SRSW, CARD and ACWG shared a table at the Green Fair this fall on October 7th in Downtown Ann Arbor. We had lots of folks ask about Gelman, 1,4 dioxane, and EPA Superfund Status. We had many signup for email updates on the Gelman Plume.
We have attended all the Green Fair events except for the past year with Covid issues precautions.
The members at the CARD table did tour the Green Fair at different times but no one saw the mayor in attendance for some reason.
Church Hill Downs, Churchill Park Detention Basin, Flood Hazard Mitigation for Lawton Area Moves Close to Finishing
(City of Ann Arbor, Rt Clk for larger)
The ACWG was involved in the effort to reduce stormwater flows and flood hazard due to home foundations footers connected to the sanitary sewer system. We were successful in having the city disconnect footers to sanitary sewers and not allow an outrageous plan to have huge sewage holding tanks in several clear-cut west-side woodlands, which was the "preferred solution" to the flooding, we were instrumental in stopping and preventing it.
I, as Coordinating Member of the ACWG and vocal opponent to sewage holding tanks in place of woodlands, I was deposed for several court challenges the city had ultimately got dismissed. The ACWG testimony was critical to the dismissal according to city legal staff in personal communications and thanked us for the effort. The court challenge said the footer disconnect was a 'Taking', "an appropriation or diminution of private property rights by a governmental regulation which exceeds the government's legitimate police power" (Webster).
The developers, somehow, got the city to allow footer connections to the sanitary sewer to save about $100 or less per house, and we, the city, had to then pay thousands per house to fix the mess with installed sump pumps and sanitary sewer disconnects.
The effort to capture flood waters in detention basins and promote rainwater infiltration has since been an ongoing effort to reduce flood hazard and improve water quality.
The ACWG promoted the option to capture flood waters in parks during major rain events, and allow them to drain in a controlled fashion and return to bring a park 99.9% of the time.
Flood hazard is getting worse in the state of Michigan every year with Global Warming and more innovative techniques need to be implemented.
1,000-year (.1% chance) rains/floods are now common in the midwest and Michigan.
Link: Washtenaw County Water Resources
EGLE: 50 Years of the Clean Water Act: Success Stories of the Clean Water Act in Michigan Discussions
(MI EGLE; Rt Clk for larger)
October 2022 EGLE Best Successes https://youtu.be/GWwHd8Hixu0
Some comments about Michigan's efforts regarding Clean Water in the State during this Webinar:
“There's a wide range of what can be done with our funding to address non-point source pollution we do
Pervious Paving systems use increased
Install Rain Gardens and other green infrastructure and low-impact development practices we can restore and,
Protect Wetlands we do conservation easements
Places a deed restriction on a parcel of land and it prevents that land from being developed, so that's one practice that we do that as a permanent protection"
(bold by us)
Many of these Clean Water efforts, and others, have long been promoted and adopted, by the ACWG in Ann Arbor and the region and elsewhere since the early 90's. Michigan has great freshwater resources we must protect for future generations and protect health and safety and, promote sustainable economies for this state and region.
Special Update October 9, 2022
Scio Township Reports New Drinking Water Wells with 1,4- Dioxane
News Release by Scio Township on Oct. 3, 2022:
Scio Township, Michigan. – For years many residential wells in Scio Township have been sampled for 1,4–dioxane as a result of the large plume of groundwater contamination caused by the former Gelman Sciences facility. The Michigan Department of Great Lakes, Environment and Energy (EGLE) contracts with the Washtenaw County Health Department (WCHD) to conduct long-term monitoring of drinking water wells around the plume. Drinking water wells within 1,000 feet of the estimated plume boundary are included in this state-funded monitoring. Approximately 218 drinking water wells are sampled either twice per year, once per year or every other year, depending on proximity to the plume and nearby detections. Historically this sampling program has had a detection limit of 1 ug/L (or part per billion). However, beginning in June of 2022, samples will be analyzed by the EGLE lab using a detection limit of 0.50 ug/L.
Due to concerns about potential movement of the 1,4-dioxane plume to residential areas located north of M-14, Scio Township has completed four rounds of sampling which expands on the state-funded program and uses a testing method which detects 1,4-dioxane down to 0.12 ug/L. The first round of sampling in July and September of 2021 identified low levels of 1,4- dioxane at one location which had previous detections under the state-funded program and at two locations which had not been previously sampled, and were below 1 ug/L. One of these locations was a significant distance north of the estimated northern boundary of the plume as delineated with existing data.
The second round of sampling was conducted in November of 2021 and included 15 additional residences. This round of sampling identified four additional residences with low levels of 1,4- dioxane, all of which are located north of the estimated plume boundary. The levels of dioxane detected in the four residences ranged from 0.26 ug/L to 1.0 ug/L.
The third round of sampling was conducted the week of May 16, 2022 and included 27 additional residences and a re-sampling of a residence from the second round. Eight additional residences were identified with low-levels of 1,4-dioxane and re-sampling confirmed the presence of 1,4-dioxane in the residence from the second round. The eight residences are all located north of northernmost detection from the second round of sampling. The levels of 1,4- dioxane detected in the nine residences ranged from 0.15 ug/L to 0.89 ug/L.
The fourth round of sampling was conducted the week of August 22 and included 63 additional residences. This round of sampling identified ten additional residences with low levels of 1.4- dioxane, all of which are located in the area where previous sampling occurred between M-14 and the Huron River. The levels of 1,4-dioxane detected in the ten residences ranged from 0.17 ug/L to 1.3 ug/L. The concentrations are below the State of Michigan drinking water standard for 1,4-dioxane of 7.2 ug/L. All other residences tested non-detect for 1,4-dioxane. The residents have been informed of the sample results.
A total of 122 private wells were sampled in all four rounds. Of that total, 26 wells showed the presence of 1,4-dioxane. All of the wells were sampled using a United States Environmental Protection Agency (USEPA) 1,4-dioxane analytical method for residential wells, Method 522, which has a detection limit of 0.12 ug/L. This testing method is more sensitive than the 1,4- dioxane analytical methods used by Gelman or the state-funded program.
Will Hathaway, Scio Township Supervisor, has worked together with Scio Trustee Kathleen Knol to push for more data on the extent of the contamination and faster progress on the Gelman cleanup. Their efforts have included advocating for the Environmental Protection Agency (EPA) to become involved with the cleanup. The Township will continue to coordinate with WCHD and EGLE regarding future sampling efforts.
The Gelman Site is owned by PALL Life Sciences, Inc., a wholly owned subsidiary of Danaher Corporation, and there are no active plant operations. Historically, the plant manufactured filter devices and used dioxane as a solvent. Thousands of pounds of 1,4-dioxane were discharged to soil, surface water, and groundwater through seepage lagoons, land spray irrigation, and direct discharges at the site. Wastewater disposal practices at the former Gelman plant located near Ann Arbor contaminated on-site and off-site groundwater with the likely human carcinogen 1,4-dioxane. The 1,4-dioxane groundwater plume, which currently is about four miles long and one mile wide, has polluted local lakes, creeks, residential drinking water wells, and a City of Ann Arbor municipal water supply well.
More information regarding 1,4-dioxane and the state-funded residential sampling program can be obtained at the webpage: 1,4-Dioxane | Washtenaw County, MI.
CONTACT: Will Hathaway – Scio Township – Supervisor – 734-369-9400 – whathaway@sciotownship.org
Kathleen Knol – Scio Township – Board Trustee – 734-369-9400 – kknol@sciotownship.org
September 2022 - No Meeting this Month Due to COVID-19 Pandemic Cautions
Watershed Issues of Interest and Updates
Ann Arbor Township is Doing Its Own Drinking Water Wells Tests* with EPA 522 Test Which Measures 1,4 Dioxane Down to 0.12 ppb; EGLE to Test Allen's Creek in November* in West Park
EGLE Testing Allen's Creek in West Park in Recent Past Years
(ACWG; Rt Clk for larger)
EPA doing more tests this month in Ann Arbor and the area in preparation for a decision on EPA Superfund designation for the Gelman Toxic Plume.
EGLE will be testing Allen's Creek in West Park as the ACWG and CARD requested for many years now and they have obliged (they were not willing to do regular tests on Near-Surface Groundwater*). This part of the creek picks up a lot of groundwater, you can stand on top of the grates and you can hear it gushing even in a major drought condition. EGLE said they will test during a low rainfall time, as they have in the past, to obtain better data on the groundwater contamination.
The concern here is that with lots of homes on the West Side with wet or very wet basements, from groundwater, "vapor intrusion" of contaminated groundwater could be a concern. This groundwater is near-surface and as such could be a violation of the Prohibition Zone which is said to protect against exposure to 1,4 dioxane from the Toxic Dump Site. Very minimal tests of basement intrusion of contaminated groundwater have been done in the city, which has been questioned by CARD and ACWG.
Scio Township is doing more drinking water well tests for 1,4 dioxane. Scio Township is paying for these tests themselves. Some of these wells found recently with the compound are very close to the Huron River, the source of 85% of Ann Arbor drinking water. The results should be available very soon and will be posted here.
As identified by GEA in 2017, the dioxane plume is migrating into Scio Township following the subsurface features along low topographic areas.
"If the Gelman Site became a USEPA Superfund Site, based upon similar USEPA Superfund Sites, USEPA would halt the dioxane plume migration towards the Scio Township residential drinking water wells and remediate the dioxane contaminated groundwater to drinking water quality." (bold by us)
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. Other council members attend regularly.
The Mayor at the 2016 Green Fair expressed surprise when I told him EGLE found 1,4 D in near-surface shallow groundwater (NSG) in West Park, after we pressured them (with no help from the city) to do Just Do The Simple Tests, a few months earlier. He was not going to stop at the Ann Arbor Green Fair CARD Table so I stepped out to approach him and asked him about this danger with City Adm. Lazarus walking with him, and he said he had not known of this, as Lazarus quickly pull him away from our conversation. He moved on without asking for any details of the very real potential West Side resident's exposure in wet basements with contaminated groundwater seepage or flooding.
The Mayor and his council supporters obstructed the effort to bring EPA Superfund to the Gelman Toxic Plume at every turn for years and his city supporters 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.
City of Ann Arbor is spending $300K to install wells to detect migration of the Gelman Toxic Waste Plume near Ann Arbor. We know we have had 49 ppb Gelman 1,4 dioxane in groundwater in Allen's Creek in West Park area in recent years.
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, west side basements like no other entity we can turn to.
Gelman, the egregious polluter is winning and we are losing. Many people have died and sickened, and will die and be sickened from the Plume without action.
Green Fair: SRSW (reserved the table), CARD and ACWG will be jointly hosting a table at the Green Fair on October 7th 6pm.
Findings from tests requested and pushed by CARD, SRSW and ACWG of significant NSG contamination in West Park and the threat to homeowner and business exposures lead to an EGLE implementation of a State-Wide Vapor Intrusion Rule for the State of Michigan and set lower standards for drinking water to 7.2 ppb. EPA also cited this as a major reason to consider a Superfund Site for the Gelman/Danaher 1,4 Dioxane Toxic Waste Plume. High-ranking EGLE officials commented to CARD /ACWG that public involvement in this Gelman/Danaher 1,4 Dioxane Toxic Waste Plume was a major reason for this change.
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 4 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.
'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)
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 Now Collecting Data, and Likely Declare the Gelman Plume a Superfund Site, Likely This Year:
An EPA official attended the June CARD meeting and said that US EPA is now working with a consultant and they are now collecting critical supporting data for the Superfund designation of the Gelman/Danaher Toxic Waste Plume. These tests and analyses and evaluations should be done in 6 to 12 months as is the normal process for EPA Superfund Site Listing. The delay in this process was caused by the requirement to use a different consultant to do tests because the normal consultant was not allowed due to conflicts of interest of related past efforts with the Gelman Plume.
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.
Groundwater coming to the surface on the near west side are the reasons 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 September, 2022; YouTube: https://www.youtube.com/watch?v=ijCDvGOQibohttps://youtu.be/RaVwJKbOpSc
Scio Twp Gelman Plume Townhall 2-17-2022
EWG https://www.ewg.org/tapwater/reviewed-1-4-dioxane.php
https://www.mlive.com/news/ann-arbor/2021/11/in-letter-to-epa-dingell-calls-latest-ann-arbor-area-dioxane-news-alarming.html
EPA, EGLE and Local Government Joint Session on 3-18-21; YouTube link to the Video
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.
Please Vote In the 2022 November Elections!
(ACWG, Rt Clk for larger)
Support Effective City Leaders With Proven Track Records in protecting the environment and quality of life in Ann Arbor:
Vote Eric Lipson for Mayor, Independent: Some of Eric Lipson's Positions
Promote affordable housing options so our teachers, nurses, and service workers can live here.
Take real climate action such as mandating electrically heated buildings when approving NEW development to promote A2Zero sustainability goals, not just ask residents to retrofit their houses and pay more taxes.
Address the long term threat of the dioxane plume to local drinking water. It’s critical that the Gelman Dioxane Cleanup start with strong advocacy for EPA Superfund status which the mayor has resisted. Lobby Lansing for Polluter Pay legislation.
Prevent problems caused by lack of planning that have caused flooded basements and roads, traffic congestion, deteriorating roads and over-taxed infrastructure. We must complete the A2 Comprehensive Land Use Plan before making massive zoning changes.
Recruit minorities to achieve Diversity, Equity and Inclusion goals in hiring and promotion of city staff to correct the city’s shameful past track record of minority hiring and promotion.
Adopt conflict of interest and financial disclosure rules for mayor and council that set forth clear ethics standards and thereby improve government transparency.
Enact Non-Partisan city elections to enfranchise students and others who do not vote in the August Primary. This was vetoed twice by the current mayor.
Protect the health and safety of our 50,000 renters by adding rental housing inspectors. There are only 5 inspectors for 25,000 rental housing units!
You can vote Stright Ticket and for Eric Lipson, Independent, also.
We have worked with Eric on many pollution issues, housing and parks issues and find he has a keen mind, great temperament and great experience.
ERIC LIPSON Independent for Mayor of Ann Arbor
Here's what MLive thought of our Mayor when he was caught messaging "special council members", during City Council Meeting, making fun of residents making Public Comments to city council! Not great material for a Mayor.
It was called Special Council Members Pandering Award, and they gave out Special Council Panda Awards to themselves, to the one who Pandered the most at the council meeting. Sweet?
Pat Ryan Died of Natural Causes in August this Summer, a True Environmentalist Till the End
Pat was a founding member of ACWG, and did extensive work on the Allen's Creek Watershed Management Plan, she was in the forefront of promoting the restoration of watersheds and fighting Gelman dumping its effluent into various water bodies including Allen's Creek.
Gelman pressured Pat to ignore the pollution coming from the company but she did not pull back. Pat was a major force in keeping the Gelman effluent (especially 1,4dioxane) out of the Allen's Creek and our city sanitary sewers.
She was not happy at all when I told her 1,4 dioxane was found in the Allen's Creek in West Park at up to 49ppb.
The Allen's Creek Watershed Management Plan, shown on the ACWG.ORG front page, was written by the group without external funds support and was adopted by the MDEQ, Washtenaw County and City of Ann Arbor, and Huron River Watershed Council.
Pat and her parents lived in Ann Arbor, her father was a big part of creating the Old West Side Association where he lived for many years.
Pat worked hard to make Ann Arbor a better place for decades and her passing will be a loss to the community and a loss of the extensive community knowledge she kept in her head.
"How Ann Arbor project got $20M earmark still a mystery to local lawmakers" in a Lansing Back Door Deal; DTE's Coal Tar Dump Site With Proposed Homes and Hotels Floating on Top; Development of Polluted DTE Site at Depot St and 841 Broadway St In the FW FP - No Real Cleanup Proposed;
DTE Energy is rated top 10 worst Water Polluter in the USA
(DTE Site, Mostly Floodway in Blue, City of Ann Arbor GIS Web Site; Rt Clk for larger)
Coal Tar (highly toxic) found at the DTE Site and shown by DEQ at river's edge at the site, the pollution at the river's edge subsequently cleaned up in recent years (WUOM) but is still on site and leaching into the Huron River and likly groundwater (never tested)
At a public meeting for this project I attended, but ACWG was not invited to for some reason, the developer described the materials buried on site as 'Inert', which I challenged. Coal Tar is not Inert as we wrote previously and commented on earlier before Council's Meeting with Public Hearing for this project.
“Inert waste is waste that is neither chemically nor biologically reactive and will not decompose. Examples of this are sand and concrete. This has particular relevance to landfills as inert waste typically requires lower disposal fees than biodegradable waste or hazardous waste.”
The coal gasification process produces a bi-product called coal tar. Coal tar is a mixture of volatile organic compounds such as benzene, and a class of compounds known as polynuclear aromatic hydrocarbons (PAHs) which include compounds such as naphthalene and benzo(a)pyrene. These compounds are rated as possible and known carcinogens and are very dangerous to humans and other life forms. Some PAHs, Benzene and benzo(a)pyrene are a Group 1 carcinogens.
This Coal Tar is leaching into the Huron River and the groundwater is said to be contaminated. This site is the site of the old Huron River Riverbed pre early 1900s.
Structures on this site will be placed on top of a toxic waste site with coal tar and other chemicals from the old MichCon Gasification Plant that was on this site. The groundwater below is contaminated but downstream contamination tests in the Huron River were not done according to the developer.
Vapor Intrusion is a real issue being faced by many sites which were built over old dump sites. In Petoskey MI recently 11 of 14 condos were evacuated due to VI issues from building in an old dump site. See our website for information on Vapor Intrusion as it relates to the Gelman Toxic Dump Site and Plume.
At a CARD meeting years ago discussion of the Ann Arbor City Apartments at Washington and First St came up regarding the below-ground parking 2 stories below grade. The ACWG and the CARD Group asked about potential groundwater contamination with 1,4 Dioxane issues with this city-owned parking garage below in the path of the plume, deep into the water table. Soon thereafter we learned the city did a stop-work order to make changes to the soon to be started building, to raise the building a full 2 stories up to avoid this issue. The city's explicit requirement not to have parking on the street level was quickly thrown out the window. At the DTE site we know we have major pollution below the surface and yet feel OK with building residential above it very close to the dangerous pollution.
Flood hazard is getting worse, not better with Global Warming. This site is in the site of the old Huron River riverbed, just downstream of two dams both of which were breached and others completely failed in the 1968 100-year (1% chance) flood, which had 15 feet of water flowing over this site. The 1968 flood is more like a 50-year (2% chance) flood of today by many accounts.
They were planning a Brownfield partial cleanup with about $25M from taxpayers, and about $12M from the developer.
This will not be a full cleanup as they say this is not required in the current very weak MI Part 201 statute.
DTE, a $26B company, should be doing a cleanup of this site as the Responsible Party Legal Owner, not taxpayers. Polluter Pay legislation has been introduced in Lansing this year.
If done right could be a great park close to the city center. When it floods hose it off and go back to being a park, like many progressive (and non-progressive) cities are doing.
All of the other outcroppings in the Huron River near Ann Arbor and beyond are parks, for good reason, due to the flood hazard associated with them.
When the city worked on the River Path near this site they cleaned up the Coal Tar before putting in the trail.
A developer across Depot St. developed a lot that was full of Coal Tar, site of the original MichCon plant, and they told me they were not to happy this development was not required to do a similar cleanup for a development.
DTE Energy rated top 10 worst Water Polluters in the USA. Great partner for the city.
'Researchers at the University of Massachusetts Amherst have published three lists detailing the 100 worst air, water and greenhouse gas polluters in the country.
The lists — the Toxic 100 Air Polluters Index, Toxic 100 Water Polluters Index and Greenhouse 100 Index.
"What’s kind of a like a zombie rising from the grave is these buried contaminants that are now showing up in people’s homes, in their air, specifically. That was not envisioned by the science at the time; if you left chemicals in the ground they could actually migrate up through even impervious surfaces and affect people’s health." Dave Dempsey, For The Love Of Water FLOW - WUOM (bold by us)
DTE, a $26B company, should be doing a full cleanup of this site as the Responsible Party Legal Owner, not taxpayers.
Three 1,000 year (.1 % chance) in a Week, Climate Change Is Here
(WaPo, Rt Clk for larger)
August 2, 2022: Washington Post
It’s the third 1-in-1,000-year rain event in the Lower 48 states in about a week.
More than 10 inches of rainfall in Illinois, another exceptional deluge It’s the third 1-in-1,000-year rain event in the Lower 48 states in about a week.
3 1000-year rains in a week, the Ann Arbor 68 flood is said to be more like a 50-year event, blew out dams, streets, homes and was a major disruption in Ann Arbor for years.
https://www.washingtonpost.com/climate-environment/2022/08/02/illinois-flooding-thousandyear-rainstorm/
August 2022 - No Watershed Issues of Interest and Updates Due to Vacation and Travel Schedules
July 2022 - No Watershed Issues of Interest and Updates Due to Vacation and Travel Schedules
June 2022 - No Meeting this Month Due to COVID-19 Pandemic Cautions
Watershed Issues of Interest and Updates
Data From Scio Twp. Testing of Drinking-Water Wells Show Elevated 1,4 Dioxane, Many be Over a Level Of Dangerous Exposures at .35 ppb Over Long Periods; EPA Superfund Is The Only Hope
Map of Recent Data Showing Groundwater Flow of Gelman Toxic Plume 1,4 Dioxane
Toward More Scio Drinking Water Wells and the Huron River to the North
Wells Showing 1,4 Dioxane Concentrations in Home Owner Drinking Water Wells
EPA Reports 0.35 ppb (micrograms per L, mgl) In Drinking Water for long periods Is
Dangerous To Human Health
(Scio Twp.; Rt Clk for larger)
The above map shows the migration of the Gelman Toxic Plume 1,4 dioxane is moving into new Scio Twp. drinking water wells and toward the Huron River. The River supplies about 85% of Ann Arbor's drinking water supply.
Dan Bicknell of GEA communicated to Scio Twp officials on June 28:
"The most recent Scio Township residential drinking water wells sampling indicates that the dioxane plume has migrated far north and is moving in the subsurface along low topographic areas directly to the Huron River, see below summary figure with Scio Township drinking water well dioxane results."
As identified by GEA in 2017, the dioxane plume is migrating into Scio Township following the subsurface features along low topographic areas.
"If the Gelman Site became a USEPA Superfund Site, based upon similar USEPA Superfund Sites, USEPA would halt the dioxane plume migration towards the Scio Township residential drinking water wells and remediate the dioxane contaminated groundwater to drinking water quality." (bold by us)
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. Other council members attend regularly including Anne Bannister now running for mayor, and former City Council Member, in the August Primary and Council Member Ali Ramlawi running for reelection.
The Mayor at the 2016 Green Fair expressed surprise when I told him EGLE found 1,4 D in near-surface shallow groundwater (NSG) in West Park, after we pressured them (with no help from the city) to do Just Do The Simple Tests, a few months earlier. He was not going to stop at the Ann Arbor Green Fair CARD Table so I stepped out to approach him and asked him about this danger with City Adm. Lazarus walking with him, and he said he had not known of this, as Lazarus quickly pull him away from our conversation. He moved on without asking for any details of the very real potential West Side resident's exposure in wet basements with contaminated groundwater seepage or flooding.
The Mayor and his supporters obstructed the effort to bring EPA Superfund to the Gelman Toxic Plume at every turn for years and his predecessors 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.
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, west side basements like no other entity we can turn to.
Gelman, the egregious polluter is winning and we are losing. Many people have died and sickened, and will die and be sickened from the Plume without action.
Findings from tests requested and pushed by CARD, SRSW and ACWG of significant NSG contamination in West Park and the threat to homeowner and business exposures lead to an EGLE implementation of a State-Wide Vapor Intrusion Rule for the State of Michigan and set lower standards for drinking water to 7.2 ppb. EPA also cited this as a major reason to consider a Superfund Site for the Gelman/Danaher 1,4 Dioxane Toxic Waste Plume. High-ranking EGLE officials commented to CARD /ACWG that public involvement in this Gelman/Danaher 1,4 Dioxane Toxic Waste Plume was a major reason for this change.
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 4 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.
'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)
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 Now Collecting Data, and Likely Declare the Gelman Plume a Superfund Site, Likely This Year:
An EPA official attended the June CARD meeting and said that US EPA is now working with a consultant and they are now collecting critical supporting data for the Superfund designation of the Gelman/Danaher Toxic Waste Plume. These tests and analyses and evaluations should be done in 6 to 12 months as is the normal process for EPA Superfund Site Listing. The delay in this process was caused by the requirement to use a different consultant to do tests because the normal consultant was not allowed due to conflicts of interest of related past efforts with the Gelman Plume.
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.
Groundwater coming to the surface on the near west side are the reasons 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 June 7, 2022 YouTube: https://www.youtube.com/watch?v=ijCDvGOQibohttps://youtu.be/RaVwJKbOpSc
Scio Twp Gelman Plume Townhall 2-17-2022
EWG https://www.ewg.org/tapwater/reviewed-1-4-dioxane.php
https://www.mlive.com/news/ann-arbor/2021/11/in-letter-to-epa-dingell-calls-latest-ann-arbor-area-dioxane-news-alarming.html
EPA, EGLE and Local Government Joint Session on 3-18-21; YouTube link to the Video
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.
Please Vote In the 2022 August Primary!
(ACWG, Rt Clk for larger)
Support Effective City Leaders With Proven Track Records in protecting the environment and quality of life in Ann Arbor:
Anne Bannister For Ann Arbor Mayor www.bannister4mayor.com
Anne was one of the council members who File Suit to Stop Mayor Taylor from selling the Library Lot Without Council Approval and it was not sold as the Mayor wanted
Strong environmental interests to protect the community
Continuous Intrest in Gelman Plume Cleanup
Long Career in Financial Services
Ali Ramlawi Council Member Running for Reelection https://voteali.org/
Small business experience and concerns
Strong environmental interests to protect the community
Pushing for a Cleaner More Welcoming Downtown Ann Arbor
Continuous Intrest in Gelman Plume Cleanup
Preventing Affordable Housing in the Floodplains
UC Berkeley Enrollment Capped by Local Residents' Lawsuit Due To Environmental Effects Of Over Enrollment; UM-Ann Arbor Has the Same Problem
Lawsuit To Stop Mega Admissions to UC Berkeley
Court: UC Berkeley admissions must reduce a third of admissions
(therealdeal.com, Rt Clk for larger)
The City of Ann Arbor has similar issues with overcrowing the city with UM Students with the UM proposing increasing enrollments of at least 10,000 more students in the near term to have a 50,000 student enrolment at the Ann Arbor Campus. The UM is in competition with Ohio State Univ. (OSU) who currently has 50.000 students on its Columbus campus.
UM expects our city leadership to LockStep to build HighRises in the downtown to house the huge increase in student enrollment.
High enrollments in small land-locked towns like Berkeley and Ann Arbor can cause tremendous environmental and affordable housing issues.
From an Article in therealdeal.com (based in Berkeley CA):
"The problem is particularly acute now because UC Berkeley’s student enrollment has increased 34% in recent years, while a broader housing crisis has also made it harder to find an affordable place to live anywhere in the Bay Area.
The tension between the rising number of students and the lack of housing boiled over in February in a neighborhood lawsuit that drew national attention. Save Berkeley’s Neighborhoods sued UC Berkeley in 2019 over an environmental impact report the university did for a housing project on Hearst Avenue." : therealdeal.com
The Mayor and his supporters (The HighRisers) are Hell-Bent to build out Ann Arbor with HighRises all over Ann Arbor with significant health and environmental effects on the community.
As we have communicated here HighRises Neighborhoods are not environmentally supported. HighRises are not as dense as low-rise buildings and better environment for residents and the community.
UM wants to emulate OSU and have 50,000 student enrolments at all costs.
As many know, workers seeking jobs at UM came to live in a small community without HighRises, noise, pollution, unaffordable housing and traffic like they experienced in the God Awful NYC, DC, LA, SF, Boston, ...
The UM, developers and real-estate interests want more HighRises for obvious reasons, the community not so much.
The California Governor unilaterally blocked the residents from limiting enrollments at Berkley for the time being.
Our current city leadership refuses to require a PILOT (Payment in Lieu Of Taxes) as many universities in the US currently have, like Northwestern, MIT, Yale, Harvard, ...
One option Ann Arbor could use, like the Lever Evanston successfully used for Northwestern, is to declare the UM campus a Historic District zoned area that would force the UM to get permission to develop properties.
Ann Arbor does not have the water resources to support more major HighRise developments. The Mayor planned to move Ann Arbor to the Great Lake Water Authority (Detroit Water, GLWA) at great cost to the community until Dr. Rita Loch-Caruso Toxicologist Emeritus UM and Dan Bicknell MPH GEA, explained in detail at a City Council Public Hearing that the quality of the GLWA water intake in the Detroit River very questionable.
Link: therealdeal.com
WoodTV - Big Rapids Flooding; 4.5” Inches Rain 1 Hour, May 2022; Another "Wake Up Call"
Big Rapids Flooding May 2022
Police Request Avoiding the City Entirely
(bigrapidsdailynews.com; Rt Clk for larger)
May 11, 2022
WoodTV: "Mecosta County Emergency Management said the Big Rapids area got between 2 and 4 inches of rain. Farther north, parts of Isabella County WoodTV reported 4.5 inches of rain in a single hour." (bold by us)
These large rain events are becoming more common and more dangerous, especially in communities that do not prepare.
Ann Arbor is building more in the Federal Emergency Management Agency (FEMA) floodplains and UM is Low Balling Floodplains on campus, when even FEMA agrees the floodplain maps are out of date and studies show they are 30% Low Balling the actual floodplains when Global Warming effects are included in flood modeling. FEMA has said they are now in FEMA 2.0 efforts to create much more reliable floodplain maps to replace the outdated maps now in use.
Ann Arbor and the UM should not be building in and around the Floodway or Floodplains till new FEMA Flood Maps are issued.
Link https://www.woodtv.com/weather/thunderstorm-causes-flooding-in-big-rapids/
"Tree Removal a Bad Plan to Fight Global Warming in the Amazon" and IN Ann Arbor
"Urban heat island: Satellite images show some parts of the cities face the highest heat"
Maple Rd and Pauline Development, Former Pauline Woodland ClearCut
(MLive; Rt Clk for Larger)
From the Article: "The surface urban heat island is the result of surfaces made up of heat-absorbing materials, such as asphalt, concrete, and metal. Such materials are highly effective absorbers of heat energy from the Sun, and their surfaces warm rapidly and in turn emit the absorbed energy. You can feel the heat when you touch them."
Atlanta GA has a Tree Canopy Law that protects the cooling effect of shade in a city. They also recognize that a full tree canopy has a calming effect in dense city centers.
Clear-cutting woodlands all across Ann Arbor is removing large areas of tree canopy with impunity for developers who largely don't even live in Ann Arbor.
Our Private FairGlen Wooded Commons on the west side is not immune. When the city approved a development on a wooded steep hillside next to one of the few open sections of the Allen's Creek in the Commons, the city had to pay about $1/2M (tax dollars) to pipe 500 feet of the creek and cut 7 Landmark Trees and remove many 10s of other trees due to effects of the very poorly permitted development. The DWWhite developer paid nothing, he had a city permit. Windy Ramson a City staff in Building Dept. told me the site was unbuildable when we asked before it was approved for development.
Not only did the city not pay the Commons owners for damages, the MissLabled Tree plan Penitely was never paid as per city code.
North Side development, Maple Rd. development sites are just some of the recent clear-cutting happening regularly in Ann Arbor woodlands.
Why? UM, Developers, real estate and Chris Taylor and his supporters are siding with developers against Greenspace preservation in Ann Arbor at all costs, even heat island health and death threat to residents, low income and elderly with diminished defenses against excessive heat island.
More Green Spaces are needed in Ann Arbor not less. Ann Arbor is low on the amount of Green Space/Park Space in relation to progressive towns.
Green Belt Millage called for 33% of green space purchased in the city, not the current 9%.
Porous Pavement Greatly Reduces Heat Island, pollution, noise, cost, flooding, ... :
At ACWG prodding the city and UM have done some Porous Pavement roads and parking lots but much more conversion of impervious paving is need. The ACWG has a page on the website that highlights the Benefits of Porous Pavement.
Just one local amazing example is UM converted porous parking lot installed a few years ago on Fuller Rd that can handle 1,300 inches of rain an hour according to tests run by the city! And the PP will decontaminate toxins coming off autos as the rainwater percolates into the ground, naturally from microbes' actions.
Links:
May 2022 - No Meeting this Month Due to COVID-19 Pandemic Cautions
Watershed Issues of Interest and Updates
City of Ann Arbor and Washtenaw County Did Not Permit Gelman Toxic Dump Plume In the Allen's Creek Decades Ago Yet Is Now Freely Flowing in the Allen's Creek and NSG On the West Side at Up To 49 ppb in Ann Arbor; EGLE Pulls Back On Offers To Help Stop It
ACWG/CARD Observe EGLE and City Utility Staff Sampling NSG and Allen's Creek in West Park on 9-9-18
Tests This Year Showed a High of 49 ppb NSG
(ACWG, Rt Clk for larger)
Environment, Great Lakes & Energy (EGLE) at the last meeting of the Coalition for Action on Remediation of Dioxane (CARD) Group has stated that they will assist the County and City to stop the Gelman/Pall/Danaher toxic Plume from illegally flowing into the Allen's Creek on the West Side of Ann Arbor at up to 49 ppb in recent tests. The Near-Surface Groundwater (NSG) in the West Park area flows into the Allen's Creek.
It is very clear to ACWG and CARD that the Allen's Creek is being contaminated by the Gelman Toxic Dump Site Plume and that the NSG is contaminated and flowing into the Allen's Creek in West Park and likely spreading in the NSG on the West Side of Ann Arbor.
EGLE has pulled back on action on Gelman Plume in the NSG and Allen's Creek after saying at the April CARD meeting they would assist the city and county on this dumping violation.
The city and county have both ruled and communicated to Gelman, many years ago, that Gelman cannot use the storm sewer or sanitary sewer for disposal of 1,4 dioxane from the Gelman Plant to flow to our Huron River. Gelman asked for this allowance many years ago but was denied by both the city and county.
The city and county need to work with EGLE to stop this illegal flow in our Allen's Creek and NSG on the West Side. The ACWG, CARD and Scio Residents for Safe Water (SRSW) groups will work with government officials to stop this illegal flow.
Findings from tests requested and pushed by CARD, SRSW and ACWG of significant NSG contamination in West Park and the threat to homeowner and business exposures lead to an EGLE implementation of a State-Wide Vapor Intrusion Rule for the State of Michigan and set lower standards for drinking water to 7.2 ppb. EPA also cited this as a major reason to consider a Superfund Site for the Gelman/Danaher 1,4 Dioxane Toxic Waste Plume. High-ranking EGLE officials commented to CARD /ACWG that public involvement in this Gelman/Danaher 1,4 Dioxane Toxic Waste Plume was a major reason for this change.
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 4 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.
'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)
The city has not consulted with the ACWG or CARD on potential NSG or Allen's Creek tests. This has led to tests that were of very little value and wasted taxpayer dollars. We have made complaints to the city on many occasions regarding this issue to no avail. We have wasted taxpayer funds on ill-conceived tests that have not been helpful in following the Allen's Creek and NSG exposures and protecting the environment and health and safety.
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 Now Collecting Data, and Likely Declare the Gelman Plume a Superfund Site, Likely This Year:
An EPA official attended the March CARD meeting and said that US EPA is now working with a consultant and they are now collecting critical supporting data for the Superfund designation of the Gelman/Danaher Toxic Waste Plume. These tests and analyses and evaluations should be done in 6 to 12 months as is the normal process for EPA Superfund Site Listing.
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.
We think Mack School area is also in a section of buried the Allen's Creek, just north of West Park, is a logical location to include in monitoring at this time. Seeps have been reported in the playground by parents with children attending that school, including City Council Membres children, and they have concerns of exposures.
Groundwater coming to the surface on the near west side are the reasons 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.
U of M Offical Tell U of M Administrators, Facility and Students to Not Work On Gelman Plume For Many Years:
U of M and the city of Ann Arbor's leadership, for years, have caused delays in getting the Gelman/Danaher Toxic Waste Site cleaned up with objections to EPA involvement in past years. Some comments from both city leaders and U of M were that an EPA Superfund would be a sigma, not be supported by developers and the officials at U of M which provide large amounts of campaign funds to select Council candidates. They should be held accountable for this. We now have potential exposures in homes on the west side of Ann Arbor, more drinking water wells contaminated in Scio Township and potential NSG exposures in Scio Twp. which may/would have been avoided if the city and UM did not obstruct efforts to get help from EPA.
Links:
CARD Meeting May 5, 2022 YouTube: https://www.youtube.com/watch?v=ijCDvGOQibohttps://youtu.be/RaVwJKbOpSc
Scio Twp Gelman Plume Townhall 2-17-2022
EWG https://www.ewg.org/tapwater/reviewed-1-4-dioxane.php
https://www.mlive.com/news/ann-arbor/2021/11/in-letter-to-epa-dingell-calls-latest-ann-arbor-area-dioxane-news-alarming.html
EPA, EGLE and Local Government Joint Session on 3-18-21; YouTube link to the Video
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.
MS4 Allen's Creek 1,4 Dioxane Violation Inconsistent With MI Part 201 Environmental Law - Needs Fixing
US EPA
CARD and ACWG have stated at recent CARD meetings that the free-flowing of the Gelman plum in the Allen's Creek violates the Federal Municipal Separate Storm Sewer System (MS4) Rules. This Federal MS4 Violation has not been addressed by EGLE.
At the April CARD meeting, we asked to have an explanation how the Part 201 and MS4 can coexist if they contradict each other.
The MS4 regulations for the state have been delegated to the State by EPA and overseen by EPA.
The MS4 Permit requires that no dioxane above background concentration be allowed to infiltrate into the Allen's Creek. Since the background level is previously 0 ppb that should be the level of cleanup required at this time. This cleanup is currently not even started after years of above 0 ppb flowing in the Allen's Creek.
When Gelman first requested the county and city to use the storm drain (Allen's Creek) or the sanitary sewer as a conduit to the Huron River of Gelman waste effluent of 1,4 dioxane, Gelman was told by the city and county they will not allow it.
The major issues facing the County and City are (and reasons the city and county did not allow it years ago):
Who is responsible for homeowner and business exposure through NSG both health effects or death and property losses
Who is responsible for the environmental impacts of this discharge into Ann Arbor, Allen's Creek and NSG
How can Gelman be allow to violate a Federal MS4 Regulation with no moral-hazard
We have asked EGLE to explain how these two rules on Waters of the State of Michigan can violate Federal Clean Water Act MS4 Regulations.
Link:
https://www.google.com/url?q=https%3A%2F%2Fwww.michigan.gov%2Fegle%2F0%2C9429%2C7-135-3313_71618_3682_3716-24366--%2C00.html&sa=D&sntz=1&usg=AOvVaw0Lf_DPWr1fsJoO4zEHWM2I
Greenbelt Funds Spent 2003 to 2020 only about 9% Have Been Used in the City, Not the Promised and Voted on 33%, Leave No Developers Behind
Atlanta, GA New BeltLine, Huge Health and Economic Benefits (Tax Base)
(NexGen, Rt Clk for larger)
The ACWG and others have gotten a lot of push back on purchases in the city with Millage funds but if you read what was passed you would see it is required.
The city officials are currently so beholding to developers, real estate and UM interests that forbid the city from adding new Green Space lest they prevent new HighRise Development. UM pushing for 50K or more enrolment and demands we supply living space for the 10K new students.
Berkely CA sued UC Berkely on much larger UC Berkely enrolments proposed and the town's significant degraded environmental outcomes. Similar issue here with UM and the city of Ann Arbor.
Greenbelt funds spent to 2020 only about 9% have been used in the city, not the promised and voted on 33%, is spent in the city for green space according to CM Jane Lumm who did an analysis recently.
The current mayor and his HighRisers were adamantly opposed to the City Center Green Space and pushed for a 17 story HigeRise instead. The mayor even tried to sell the space without Council Approval which he was sued for by some on Council. The voters overwhelming passed a change to the City Charter* to create a Town Center Park to the Charter not supporting the 17 story HigeRise.
We posted adopted millage language on our website due to all the misinformation floating around when we asked the city to buy property to reduce flooding, greenway or save critical woodland.
Link to ACWG page:
https://sites.google.com/site/allenscreekwatershedgroup/greenbelt-millage-council-resolution-2003-showing-required-spending-33-in-the-city?authuser=0
Wanted to ask you to include some comments about the actual Greenbelt Millage language passed by the city that states:
2. Millage revenues will continue to be used for the acquisition of parkland as previously approved under the existing millage. It is expected that approximately one-third of the millage revenues will be used for purchases within the City and approximately two-thirds for purchases in the Greenbelt area. (bold by us)
The Greenway and additional greenspace have been dismissed due to funding issues yet the Mileage requires spending in the city. Our recent mayors and some on city council have commented that the Greenbelt was never designed for this use and did not support significant spending on city parcels.
Parks and greenspace are tremendous assets for communities in many ways as has been shown in recent years including mental health. Ann Arbor ranks low for greenspace per capita.
Clear Cutting Wood Lots All Over Ann Arbor for McMansions and Rich UM Out of Town Students:
With a promise to protect green space and environmentally sound land management, the city is on at Tare to Remove most of the remaining Green Spaces in Ann Arbor.
The Green Belt Millage is being misused to create green space outside the city at the expense of green space in the city, with city residents paying the Lion's Share of the cost, and can not afford to own the homes being built where the wooded sites are being clear cut.
These clear-cut wood lots are largely descended to be Luxury McMansions for out of towners with enormous bank accounts and rich out of town students at UM.
North Side Development is just one recent example, Concord Pines - with the vast majority of trees cut down: 447 landmark trees and 311 will be cut down, along with 450 of the 741 low-level woodland trees.
This with the city symbol is a large tree!
Link:
Greenbelt Millage Language; https://sites.google.com/site/allenscreekwatershedgroup/greenbelt-millage-council-resolution-2003-showing-required-spending-33-in-the-city?authuser=0
Concord Pines: https://www.mlive.com/news/ann-arbor/2021/10/ann-arbor-oks-plan-to-cut-down-hundreds-of-trees-for-57-home-luxury-subdivision.html
Daylighting Arcadia Creek Kalamazoo, Michigan Green Space AND Economic Development,
US EPA's #1 Way to Improve a Watershed, Unlike in Ann Arbor
DayLighted Arcadia Creek Park and Festival Space, Kalamazoo
Several DayLighted Sections of Arcadia Creek in Downtown Kalamazoo
(ACWG Google Earth, Rt Clk for larger)
US EPA has often said, and told the ACWG, that Daylighting Streams are the most effective techniques to rehabilitate streams and watersheds that they know of. This is because you get the community interested and take ownership in the stream, watershed and water quality which does wonders for the environment.
Daylighting also greatly reduces flooding as an open stream can handle much more water than a pipe and because it is visible the community is more likely to demand better watershed management.
Also, pollution is much more obvious to the community in an open creek than in a piped creek and gets the community's attention and action.
The old buried Arcadia Creek area flooded often, now daylighted it does not and is a major green amenity for the city.
Kalamazoo took a blighted part of the city along the Arcadia Creek and created a Gem (over 20 years ago): the Arcadia Creek Greenway. It greatly reduces flooding, is a green park gathering space and is a large performance and fair venue in the downtown. The DDA in Kalamazoo spearheaded this effort.
Kalamazoo Arcadia Creek Greenway: $400-500K in new tax receipts, 600% increase in revenues with $12M/yr festival revenue; From Backwater to one of the Hottest locations in town - retail, rental, condos, gathering space; Can handle beyond a 500-year storm now where it flooded almost every year, and Increase Tax Base.
Better Tax Base = Better Long-term Green Environmental Stewardship!
Allen's Creek's Few Open Parts sections 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 a very steep slope. Wendy Ramson a city staffer told me that site would never be developed because of the slope and creek location. Soon after a development happened on the site the city was forced to pipe (enclose) 500' the upper Allen's Creek at a cost of about $1/2M, with the developer walking away without paying anything. Tens of trees were lost including many Landmark Trees and the community lost a major amenity in a private wooded park commons owned by the neighborhood. Commons owners were not given the large number of trees due to the city's failure to mark existing trees carefully and residents proved errors were made in IDing the existing trees, as we were promised. The Utility Director in charge and who canceled the penalty trees promised was removed after this debacle.
Allen's Creek Greenway Could Involve Daylighting, Flood Mitigation and Pollution Reduction: As We Proposed in the MDEQ/County/City Adopted Allen's Creek Watershed Management Plan.
The ACWG has worked for many years to promote the Allen's Creek Greenway (also now called Tree Line). City master plan of 1980 also promoted it. The Allen's Creek Greenway would run along the tracks from south Ann Arbor to the Huron River. It could reduce flooding, pollution and become a major amenity for the city and environment. The floodplain where the creek was should not be developed with Global Warming greatly increased threats of flooding.
Arcadia Creek Festival Place - Discover Kalamazoo; https://www.discoverkalamazoo.com/member-detail/arcadia-creek-festival-place/
MDEQ/County/City Adopted Allen's Creek Watershed Management Plan on ACWG WebSite
New York Times: Creeks, Once Overlooked, Are Now Seen as Assets for Urban Renewal (and Greater Tax Base)
One of The Few Remaining Open Sections of the Allen's Creek in
Fair Glen Commons, Ann Arbor West Side
(ACWG VPC, Rt Clk for larger)
From the NYT, 3-1-2022:
"Developers have recently realized the value of even the most minor waterways for commerce, but experts advise caution because of flooding risks.
.. cities ... could benefit commercially from their creeks even as they kept them at arm’s length. Opening up a creekfront and making it accessible to an existing downtown infrastructure so people can walk along with it would enhance existing commercial developments like strip malls.
... 'if the creek just becomes an amenity for existing residents there, then it brings tangential economic benefit' " (bold by us)
People are drawn to natural systems like open creeks and developers and smart planners see the benefit of better economic, environmental benefits and an improved and, increased and stable Tax Base.
From the City, County and State Adopted, ACWG's Allen's Creek Watershed Management Plan:
"Although Allen's Creek has the potential to be a community amenity, issues of water quality, flooding, ecological health and structural integrity overshadow the creek's potential. With proper planning, government oversight, educational efforts and community investment, Allen's Creek will again become a resource to the city. By improving the health of the Allen's Creek Watershed now, the city is likely to reap long-term savings."
Links:
https://www.nytimes.com/2022/03/01/business/creek-development-urban-renewal.html
https://sites.google.com/site/allenscreekwatershedgroup/allens-creek-watershed-group-acwg-ann-arbor-mi
April 2022 - No Meeting this Month Due to COVID-19 Pandemic Cautions
Watershed Issues of Interest and Updates
Gelman Toxic Dump Plume Is Now Freely Flowing in the NSG and Allen's Creek On the West Side at Up To 49 ppb, Ann Arbor and Washtenaw County Have Notified Gelman in the Past "This is Not Allowed", EGLE Offers To Help Stop It
Latest Plume Map April 25, 2022 Shown at Earth Day CARD Table
(Roger Rayle CARD/SRSW; Rt Clk for Larger)
Environment, Great Lakes & Energy (EGLE) at the last meeting of the Coalition for Action on Remediation of Dioxane (CARD) Group has stated that they will assist the County and City to stop the Gelman/Pall/Danaher toxic Plume from illegally flowing into the Allen's Creek on the West Side of Ann Arbor at up to 49 ppb in recent tests. The Near-Surface Groundwater (NSG) in the West Park area flows into the Allen's Creek.
The city and county have both ruled and communicated to Gelman, many years ago, that Gelman cannot use the storm sewer or sanitary sewer for disposal of 1,4 dioxane from the Gelman Plant to flow to our Huron River. Gelman asked for this allowance many years ago but was denied by both the city and county.
The city and county need to work with EGLE to stop this illegal flow in our Allen's Creek. The ACWG, CARD and Scio Residents for Safe Water (SRSW) groups will work with government officials to stop this illegal flow.
Findings from tests requested and pushed by CARD, SRSW and ACWG of significant NSG contamination in West Park and the threat to homeowner and business exposures lead to an EGLE implementation of a State-Wide Vapor Intrusion Rule for the State of Michigan and set lower standards for drinking water to 7.2 ppb. EPA also cited this as a major reason to consider a Superfund Site for the Gelman/Danaher 1,4 Dioxane Toxic Waste Plume. High-ranking EGLE officials commented to CARD /ACWG that public involvement in this Gelman/Danaher 1,4 Dioxane Toxic Waste Plume was a major reason for this change.
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 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 4 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.
'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)
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 Now Collecting Data, and Likely Declare the Gelman Plume a Superfund Site, Likely This Year:
An EPA official attended the March CARD meeting and said that US EPA is now working with a consultant and they are now collecting critical supporting data for Superfund designation of the Gelman/Danaher Toxic Waste Plume. These tests and analysis and evaluation should be done in 6 to 12 months as is the normal process for EPA Superfund Site Listing.
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.
We think Mack School area is also in a section of buried the Allen's Creek, just north of West Park, is a logical location to include in monitoring at this time. Seeps have been reported in the playground by parents with children attending that school and they have concerns of exposures.
Groundwater coming to the surface on the near west side are the reasons 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 and U of M Pressure to Delay a Cleanup Cause More Potential Exposures:
The city of Ann Arbor's leadership, for years, have caused delays in getting the Gelman/Danaher Toxic Waste Site cleaned up with objections to EPA involvement in past years. Some comments from both the city leaders and U of M were that an EPA Superfund would be a sigma, not be supported by developers and the officials at U of M which provide large amounts of campaign funds to select Council candidates. They should be held accountable for this. We now have potential exposures in homes on the west side of Ann Arbor, more drinking water wells contaminated in Scio Township and potential NSG exposures in Scio Twp. which may/would have been avoided if the city and U did not obstruct efforts to get help from EPA.
Links:
CARD Meeting 4-5-22 YouTube: https://youtu.be/RaVwJKbOpSc
Scio Twp Gelman Plume Townhall 2-17-2022
EWG https://www.ewg.org/tapwater/reviewed-1-4-dioxane.php
https://www.mlive.com/news/ann-arbor/2021/11/in-letter-to-epa-dingell-calls-latest-ann-arbor-area-dioxane-news-alarming.html
EPA, EGLE and Local Government Joint Session on 3-18-21; YouTube link to the Video
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.
More Very Tall and Ugly 'Climate Changing Buildings' Going Up In Ann Arbor, Contrary to Promises
1100 Broadway,
Now Likely Luxury UM Student Apartments; Mainly Concrete and Steel
Previous Location of the Very Good DTE Brick Building, 426 S Main,
Now Likely Luxury UM Student Apartments; All Concrete and Steel
Images Of Buildings Going Up Largely Built With
Major Climate Changing Concrete and Steel,
Enormous Carbon Emissions Given Below
(ACWG; Rt Cl for larger)
Tall buildings in Ann Arbor are not meeting Climate Change Mandate that the city has proposed to hold to. Comments at city council that new buildings will be environmentally friendly and low carbon emitters, but not seen in these new buildings.
Ann Arbor's $1B A2Zero Resolution needs to be taken seriously. These and other very tall buildings do not seem to.
Ann Arbor needs to publish the proposed Carbon Emissions from the plans for new buildings and their use!
High Carbon emissions do affect weather conditions. Our weather is changing quickly in SEM and elsewhere due to Global Warming.
We noted previously that:
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!
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.
Proof Low Rise is More Dense and Low Carbon:
Paris, for example, with its mostly five- and six-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.
The threat of City Council Member Ali Ramlawi proposed Resolution, and a passed resolution to that effect, to keep the 100 Affordable Housing (AH) units in the Old Y Lot project at this location if and when it is adopted by a developer and built and public outcry, the 100 AH units will stay at this site if built.
Link:
Fast Company, Aug 2021: Is building tall really best? Researchers dispel the myth of climate-friendly skyscrapers; https://www.fastcompany.com/90666746/is-building-tall-really-best-researchers-dispel-the-myth-of-climate-friendly-skyscrapers
Mary St. Major Flooding Again, Ann Arbor, in recent years
(ACWG; Rt Clk for larger)
New York Times Article, April 25, 2022:
... among the investment groups that provide capital to developers, perspectives are beginning to shift. Many may not have given climate change a second thought a few years ago, but they’re paying close attention now.
Awareness of climate-related risk among investment groups is new, said Laura Craft, the head of global environmental, social and governance strategy at Heitman, a real estate investment management firm that teamed up with the Urban Land Institute to write a series of reports on real estate investment and climate risk.
In a red flag for investors, commercial property insurance rates have risen significantly over the last 18 months. In the past, investors might have depended on insurance to absorb most of a property’s risk, but these days, “investment managers are realizing they have to own the risk over the property’s lifetime — they can’t rely on insurers,” Ms. [Laura] Craft said." (bold by us)
Ann Arbor needs to lead in protecting the residents and environment with the real threats from Global Warming effects like extreme weather we have all ready experienced.
Recent credible reports have stated that FEMA "Low Balls" floodplain maps by up to 33% across the country due to reduced funding and political pressure. Ann Arbor is approving buildings without knowing the real flood risk or location of the Floodway when they rely on FEMA flood maps. FEMA even says they are working on FEMA 2.0 to try to make maps more reliable.
This site had 15' of water careening over it in the 1968 100 year flood according to eye witnesses.
First Street Foundations FloodFactor(r) for this site is 9 out of 10! 100 year flood: 4.8 feet to 5.6 feet of water
100 year (1% chance) First Street Flood Maps for 415 W Washington shown below
4 1/2 Feet to Near 8 Feet of Floodwater
100 year (1% chance)* First Street Flood Maps for 415 shown below, Near 10 Feet of Floodwater
Link: First Street Foundations FloodFactor(r)
CARD, SRSW and ACWG Discuss Gelman/Pall/Danaher Toxic Waste Plume With Many Earth Day 2022 Attendees
Roger Rayle, Beth Collins, Vince Caruso at Table (all Board Members of CARD)
CARD, SRSW, ACWG Table
(CARD/ACWG VPC, Rt Clk for larger)
CARD, Scio Residents for Safe Water (SRSW) and ACWG had a table at the Earth Day Event on Sunday, April 26 with many attendees stopping by to learn more about and latest development on the 1,4 Dioxane Plume in Ann Arbor and Scio Twp. CARD, SRSW and ACWG have been presenting at public meetings for decades. Tables were spread out and, tables and tents were brought by presenters.
We had many, 100 or so, folks come by and talk to us and ask questions, add their names to our signup sheet, vast majority were Ann Arbor and Scio Twp. residents. They were all very concerned about the new Scio Twp. wells and NSG contamination, potential basement exposures near West Park Allen's Creek and NSG contamination and, worried our government officials are not paying enough attention to this Toxic Plume.
All hoped US EPA would be taking over this long and drawn out "non-clean up" soon and return to a safe community with the protection of clean drinking water and neighborhoods.
Parks & Recreation Master Plan Survey: The City of Ann Arbor
City of Ann Arbor:
"Please share your experience with the Ann Arbor park system and your ideas for the future.
Your input is an important part of Ann Arbor Parks and Recreation’s effort to provide quality parks and recreation for the Ann Arbor community. This survey will take approximately 10 minutes to complete and the information collected will be used to update the Park and Recreation Open Space Master Plan."
Parks, greenspace and affordable recreation are Keystones to a community and this city.
Please add your input to this survey. We would suggest comments on:
Center of the City Park, overwelmingly supported by voters in stopping a proposed 17 story luxury high-rise, needs to start moving, (push back from the mayor and his supporters on council), Higher Tax Base
Greenway/Tree Line improved design and spending, reduce flooding and pollution having it in the Allen's Creek floodplain/floodway, city's with Greenways have had great success, Higher Tax Base
Greenbelt funds be spent in the city at 33% of Millage as passed but only at about 9% currently, Higher Tax Base
Support Green Space in the city for a more better amenity, reduce heat island, Climate Friendly, Good for public mental health, Higher Tax Base
Preserve Our Very Valuable City Parks, DO NOT support a train station in our Fuller Park just down the street from the Depot St. AmTrak Train Station; Our city parks are gems and need to be preserved not sold off, U of M (mayor and some on council) want a Mega Parking Garage in this Fuller City Park with a small Train Station tacked on, Higher Tax Base
Ann Arbor should go back to it's roots and stop over charging for City recreation, its an amenity not a Profit Center for the City
To take the survey, please visit: https://www.opentownhall.com/11734
https://opentownhall.us5.list-manage.com/track/click?u=afcceb1b9e6a294a87a9831ec&id=25f43db997&e=34de5d68ae
March 2022 - No Meeting this Month Due to COVID-19 Pandemic Cautions
Watershed Issues of Interest and Updates
Gelman Toxic Dump Plume Is Being Very Poorly Monitored By Public Officials, State, County, and City; Townships Are Trying Hard With Little Help
Gelman Toxic Waste Plume 2021 (EGLE; Rt Clk for Larger)
Environment, Great Lakes & Energy (EGLE) has refused Scio Twp, Coalition for Action on Remediation of Dioxane (CARD) group and ACWG requests to do more groundwater testing in Scio Twp. EGLE has decided to do tests with a 0.5 ppb detection limit. Scio is ordering and paying for more tests with EPA522 test with 0.12 ppb detection limit. The lower detection limit of 0.12 ppb has allowed Scio Twp. to follow the plume more closely and notify residents of contaminated drinking water wells.
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
Scio Twp Goes It Alone:
Scio Twp should not be required to plan for, pay and monitor tests of the Gelman Plume in the Twp with Twp funds.
Recent tests have shown levels of about 1 ppb and lower in wells northwest of the recognized existing plume. Scio Twp paid for the EPA 522 Method of testing which goes down to 0.12 ppb. These findings show the plume has moved unexpectedly north out of the accepted plume limits. More tests need to be made and are planned for spring using the new EGLE 0.5 ppb EPA method. Scio said they will do more of its own tests with EPA 522 method. More and better testing is needed.
“Scio Twp Gelman Plume Townhall 2-17-2022” Regarding Drinking Well Contamination Findings:
Scio Twp had a Gelman/Danaher Plume discussion via zoom. Discussions centered on the use of EPA 522 1,4 dioxane lab test to tests drinking water wells in Scio Twp. paid for by Scio Twp.
EPA Now Collecting Data, and Likely Declare the Gelman Plume a Superfund Site:
An EPA official attended the March CARD meeting and said that US EPA is now working with a consultant and they are now collecting critical supporting data for Superfund designation of the Gelman/Danaher Toxic Waste Plume. These tests and analysis and evaluation should be done in 6 to 12 months as is the normal process for EPA Superfund Site Listing.
The EGLE map shown above is not correct. CARD and ACWG have shown near-surface shallow groundwater (NSG) contamination in West Park and Chapin St. as well as the Slauson School area on the west side of 8th St. all well over the 7.2 ppb used to draw the area of the plume on the map. Without meaningful NSG tests the creek tests need to be used for the map till NSG direct data is collected.
The Scio Twp data should also be considered for the map as EPA has defined a concentration of 0.35 parts per billion, or ppb as a dangerous exposure. Scio Twp has found .35 ppb to 1 ppb in several drinking water wells in Scio Twp. with very minimal testing. More tests are planned by Scio Twp.
Findings pushed by CARD and ACWG of significant near-surface shallow groundwater (NSG) contamination in West Park and the threat to homeowner and business exposures lead to an EGLE implementation of a State-Wide Vapor Intrusion Rule for the State of Michigan and set lower standards for drinking water to 7.2 ppb. EPA also cited this as a major reason to consider a Superfund Site for the Gelman/Danaher 1,4 Dioxane Toxic Waste Plume. High-ranking EGLE officials commented to CARD /ACWG that public involvement in this Gelman/Danaher 1,4 Dioxane Toxic Waste Plume was a major reason for this change.
Gelman Using Allen's Creek to Dump its Toxic Plume and Flow To Huron River:
EGLE seems to have decided, for now, to allow Gelman/Danaher to use the Allen's Creek in the West Park area as a conduit for contaminated water to the Huron River as it has not pressured the Water Resources Commissioners Office (WRCO) or Gelman/Danaher to clean up the water in the creek to state standards, which would be 0 ppb or the amount before the contaminate was dumped and injected below bedrock in the local groundwater. This is a violation of the US Clean Water Act as we have commented on previously. The Prohibition Zone was not stated to allow 1,4 D to flow into the creek. In talks with Gelman the city specifically forbids this process going back to when Gelman wanted to use it for dumping its effluent decades ago.
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 via Vapor Intrusion and or direct contact, and negatively affects property values due to these potential exposures.
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.
We think Mack School area is also in a section of buried the Allen's Creek, just north of West Park, is a logical location to include in monitoring at this time. Seeps have been reported in the playground by parents with children attending that school and they have concerns of exposures.
Groundwater coming to the surface on the near west side are the reasons why it is called Water Hill, and have Bath, Fountain, Spring Streets.
The prohibition zone does not allow movement of the plume to the surface, which we now have.
City and U of M Pressure to Delay a Cleanup Cause More Potential Exposures:
The city of Ann Arbor's leadership, for years, have caused delays in getting the Gelman/Danaher Toxic Waste Site cleaned up with objections to EPA involvement in past years. Some comments from both the city leaders and U of M were that an EPA Superfund would be a sigma, not be supported by developers and the officials at U of M which provide large amounts of campaign funds to select Council candidates. They should be held accountable for this. We now have potential exposures in homes on the west side of Ann Arbor, more drinking water wells contaminated in Scio Township and potential NSG exposures in Scio Twp. which may/would have been avoided if the city and U did not obstruct efforts to get help from EPA.
Links:
CARD Meeting 3-1-22 YouTube: https://www.youtube.com/watch?v=ieU2LbIFUBg
Scio Twp Gelman Plume Townhall 2-17-2022
EWG https://www.ewg.org/tapwater/reviewed-1-4-dioxane.php
https://www.mlive.com/news/ann-arbor/2021/11/in-letter-to-epa-dingell-calls-latest-ann-arbor-area-dioxane-news-alarming.html
EPA, EGLE and Local Government Joint Session on 3-18-21; YouTube link to the Video
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.
Floods Heat Waves Crop Failures Report Shows Michigan Must Prepare: MLive March 2022
500 Year (.2% Chance) Rain In Houghton MI Storm Damage 2018
(Houghton County; Rt Click for Larger)
MLive: "Floods, heat waves, crop failures: Report shows Michigan must prepare for climate future"
"The climate crisis is already here, and experts say Michiganders must prepare for an increasingly “risky” future.
Residents of the Great Lakes State can expect to experience more frequent torrential downpours, heavy lake effect snowstorms, flooded homes and streets, oppressive heat waves, crop failures, and more. Just how bad it will become will depend on what happens around the world in the immediate coming years." (underline by us)
Ann Arbor and the area around us already have major flood risk with recent storms giving a hint of what is to come. Ann Arbor had a 100-year (1% chance) event in 2012 with the Dexter Tornado Storm that caused major flooding in SE Ann Arbor and some since then. The state has seen 1,000-year (.1% chance) Storms in recent years destroying whole towns.
Ann Arbor has new housing, and old housing, in the very unreliable floodplain, like all other US communities. It has been reported and FEMA Hears the Call, that unlike First Street Foundation Flood Factor (R) Models FEMA does not account for Global Warming in its models, and for other reasons, they are very much Low Ball values by at least 30%. Much more dangerous than it may appear to the uneducated, uninterested or unethical. The floodway (FW) analysis for this site is likely in error as well with new Global Warming effects.
Create Allen['s] Creek Greenway in floodplain area recommended in the Flood Hazard Mitigation Plan 2007 looks more critical by the day (see more details below). Turning over the well-established Greenway effort to developers some years ago, from ACWG and other involved residents groups including the Friends of the Greenway, has stalled this effort completely and dangerously.
loods, heat waves, crop failures: Report shows Michigan must prepare for climate future"
https://www.mlive.com/public-interest/2022/03/floods-heat-waves-crop-failures-report-shows-michigan-must-prepare-for-climate-future.html
Bait and Switch Affordable Housing, More Very Tall and Ugly 'Climate Changing Buildings'
5th Street City-Owned Old YMCA Lot, 350 S 5th, Recent Version of the Proposal
(Smith Group, City of Ann Arbor; Rt Cl for larger)
The city is proposing and voted to support a pre-approved design for a developer to accept and build generally - a Market Rate (full market price) 20 story and with 100 unit affordable housing (AH) 14 story buildings on city-owned Old YMCA Lot, which housed 100 AH units before being torn down.
The city initially stated they would provide 100 affordable housing units in this Y site pre-entitlement development proposal.
Now the city is saying they could do a "Payment in Lieu" scheme and try to move the 100 AH units to the outskirts of town, "to save money".
This is disingenuous to go through this much planning and voting to then propose moving the AH from the plan.
We noted previously that:
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!
Paris, for example, with its mostly five- and six-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.
City Council Member Ali Ramlawi has said he will propose a Resolution to keep the 100 AH units in this project at this location if and when it is adopted by a developer and built.
Link:
Fast Company, Aug 2021: Is building tall really best? Researchers dispel the myth of climate-friendly skyscrapers; https://www.fastcompany.com/90666746/is-building-tall-really-best-researchers-dispel-the-myth-of-climate-friendly-skyscrapers
Adopted City Of Ann Arbor Flood Hazard Mitigation Plan 2007 - Should Not Be Ignored
City of Ann Arbor
The ACWG working closely with the Water Committee of the Environmental Commission helped write and get past this plan in 2007. An ACWG founding member was chair of the EC and member WC. Many of the major objectives have not been followed in recent years. Working closely with developers to develop new homes and businesses in flood-prone properties is not a recommendation of this plan.
The city has added over 110 new homes in the floodplain and many of the people in these homes may not know they are in the floodplain or know they should have flood insurance. We have another hundred or more approved and proposed homes in the floodplain and likely floodway. Building homes in the floodway is a Federal Offence and pleading ignorance is not a defense.
With Climate Change and Global Warming, the floodplain and floodways are only getting larger and more dangerous.
Some of the Major Objectives of the Plan:
Public acquisition and management of flood-prone properties.
Permanent relocation of flood-prone structures to areas outside the floodplain.
Establish clear and consistent government policy for public-owned land in the floodplain aimed at preventing public buildings in the floodplain.
Create Allen['s] Creek Greenway in floodplain area
Regular data collection and modeling to update flood hazard maps
Decrease Flood Insurance Rates by meeting FEMA required flood hazard mitigation recommendations
Most of these objectives are still not being met by the city.
A 2017 Hazard Mitigation Plan, which now includes the Flood Hazard Plan, has been produced and accepted. This plan, according to city staff, has many of the same aims as the 2007 Flood Hazard Mitigation Plan versio
Links:
Flood Hazard Mitigation Plan 2007
https://www.a2gov.org/departments/systems-planning/planning-areas/water-resources/floodplains/Documents/FloodplanMitigationPlan_Mar07.pdf
https://www.google.com/url?q=https%3A%2F%2Fwww.a2gov.org%2Fdepartments%2Femergency-management%2FSiteAssets%2FPages%2FHazard-Mitigation-Plan-%2FAnn_Arbor_Hazard_Mitigation_Plan_FINAL_20171205_REDACTED_reduced%2520_size.pdf&sa=D&sntz=1&usg=AOvVaw2qUXNORfuLy2G_UEWRkCPJ
February 2022 - No Meeting this Month Due to COVID-19 Pandemic Cautions
Watershed Issues of Interest and Updates
Gelman Plume Keeps Spreading In Many Directions Poorly Monitored, Contaminating More Drinking Water Wells in Scio Township, In NSG in Ann Arbor
ACWG/CARD Observe EGLE and City Utility Staff Sampling
Allen's Creek Drain (NSG) and pond in West Park on 9-9-18
(ACWG; Rt Click for Larger)
Environment, Great Lakes & Energy (EGLE) has done its yearly test of Near-Surface Ground Water (NSG), as requested by ACWG and CARD, in stormwater pipes in West Park and Slauson Middle School areas and reported the results. We had asked for more frequent testing and testing using permeant NSG wells in the West Park and Slauson Middle School areas over many years, but were denied these requests. CARD even summitted permeant NSG wells plans many years ago.
CARD pass a unanimous resolution asking for Permanent NSG Wells to Monitor the Gelman 1,4-Dioxane Plume on the Ann Arbor West Side and Potentially Scio Township in October 2021, see link to resolution in Left Side Bar.
In the Nov. 2021 tests for the first time EGLE detected 1 ppb at West Park Pond. They and we were surprised at this finding. This is the pond to the east side of West Park. Seeps in West Park drain into this pond which may be the source of this finding.
Additionally, they found slightly lower readings in Allen's Creek drain in the West Park and Slauson School areas.
Request To Test to Bed Rock Ignored:
ACWG and CARD have asked EGLE to force Gelman/Danaher to drill any new wells in the Core area to Bedrock. This has not been done and would provide important and necessary data on 1,4 dioxane potential very high concentrations that may be recontamination nearby groundwater. EGLE does not think they have the ability to ask for this even though it seems this contamination will affect exposures to residents and businesses. In the past 2B ppb has been found on the Gelman Site before drilling to bedrock stopped for some reason.
MS4 Violation in Allen's Creek And Not Much Being Done, 'it is not hurting anyone':
Ann Arbor's Environmental Commission had a discussion with Evan Pratt the Water Resources Commissioner and Dan Bicknell GEA late last month (1-27-22) regarding the MS4 Gelman Violation of 1,4 Dioxane in the Allen's Creek in the West Park area. It may be in other areas of the city and Scio Twp, it has not been effectively tested for as ACWG and CARD have asked for many years now.
At the EC meeting, WRC Pratt commented that he is not sure he has the right to force Danaher to clean up the ground water contamination, according to comments he said he received from county and state lawyers. Dan Bicknell commented that WRC Pratt needs to start the process of inforcing the MS4 violation and getting a cleanup to non-detect (0 ppb) in the Allen's Creek which has recently been 49 ppb in the West Park.
At the EC meeting WRC Pratt commented that he does not think the contaminated NSG in the West Park area is an issue for homes and businesses, stating 'it is not hurting anyone'. It seems that this NSG could be now or soon, entering homes and businesses and cause a vapor intrusion (VI) indoor exposure as we have discussed on this website before. EGLE has had set a VI exposure level and noted below, to attempt to protect against indoor exposures.
The Federal MS4 Violation in Allen's Creek Going on 4 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.
'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 storm water or uncontaminated groundwater except discharges pursuant to an NPDES permit.' (bold by us)
See the CARD poster Presented at an MLeed event with VI diagrams and descriptions.
Gelman/Danaher seem to be in violation of the MS4 Federal Regulations with their 1,4 dioxane flowing in Allen's Creek that flows into the Huron River.
EPA Now Collecting Data, and Likely Declare the Gelman Plume a Superfund Site:
US EPA has hired a consultant to collect critical supporting data for Superfund designation of the Gelman/Danaher Toxic Waste Plume. These tests and analysis and evaluation should be done in 6 to 12 months as is the normal process for EPA Superfund Site Listing.
Findings pushed by CARD and ACWG of significant near-surface shallow groundwater (NSG) contamination in West Park and the threat to homeowner and business exposures lead to an EGLE implementation of a State-Wide Vapor Intrusion Rule for the State of Michigan and set lower standards for drinking water to 7.2 ppb. EPA also cited this as a major reason to consider a Superfund Site for the Gelman/Danaher 1,4 Dioxane Toxic Waste Plume. High-ranking EGLE officials commented to CARD /ACWG that public involvement in this Gelman/Danaher 1,4 Dioxane Toxic Waste Plume was a major reason for this change.
"Scio Twp Gelman Plume Townhall 2-17-2022" Regarding Drinking Well Contamination Findings:
Scio Twp had a Gelman/Danaher Plume discussion via zoom. Discussions centered on the use of EPA 522 1,4 dioxane lab tests to tests drinking water wells in Scio Twp.
Recent tests have shown levels of about 1 ppb and lower in wells northwest of the recognized existing plume. Scio Twp paid for the EPA 522 Method of testing which goes down to 0.12 ppb. These findings show the plume has moved north out of the accepted plume limits. More tests need to be made and are planned for spring using the new EGLE 0.5ppb method. Scio may do its own tests with EPA 522 method. More and better testing is needed.
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
EGLE Changing Lab Tests to Test 1,4D to 0.5ppb, not the current 1ppb:
EGLE has commented recently that they will be switching to lab tests that will detect 1,4D to 0.5ppb not the current 1ppb. ACWG and CARD have asked EGLE to use the EPA 522 method that will test to 0.12ppb. EGLE labs do not do EPA 522 but we have asked them to send them out to local labs and have Danaher pay the cost.
Mayor Needs to Recuse On Ann Arbor votes to Support Gelman Legal Services Spending:
City of Ann Arbor just voted for another $95.000 for legal services on Gelman Plume with Bodman PLC.
MLive Reports 2-8-22: “Some officials and residents have raised concerns Taylor may have a conflict of interest since he’s a partner at the Hooper Hathaway law firm and one of his partners has been representing Scio Township as a co-plaintiff in the case. Taylor has maintained he receives no financial benefit from that.” (bold by us)
His support of more legal efforts as Mayor affects his firm who is also involved in the Gelman legal efforts.
By supporting the continued legal effort his firm, where he is a Partner/Owner benefits and he should recuse himself from voting. City Council should step up and force a recusal now. Many would say, for the Spirit if not the Letter Of the Law.
Links:
EWG https://www.ewg.org/tapwater/reviewed-1-4-dioxane.php
https://www.mlive.com/news/ann-arbor/2021/11/in-letter-to-epa-dingell-calls-latest-ann-arbor-area-dioxane-news-alarming.html
CARD Meeting 2-2-22 YouTube: https://www.youtube.com/watch?v=ieU2LbIFUBg
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 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.
U of M Blocking Allen's Creek Drainage Basins On Athletic Campus, Causing More Dangerous and Unnecessary Flood Hazard for Nearby Homes and Businesses
Stadium Parking Area with Snow Filled Allen's Creek Drainage Basin, 2-2022
Stadium Parking Area with Snow Filled Allen's Creek Drainage Basin, 2-2022
Buffalo Street with Snow Filled Allen's Creek Drainage Basin, 2-2022
U of M Dumping Snow Into the Allen's Creek Drainage Basins 2=2022
(Tom Bletcher ACWG; Rt Click for Larger)
UM is dumping snow into the Allen's Creek Drainage Basins on the UM Athletic Campus increasing Flood Hazard for Nearby Homes and Businesses.
The City of Ann Arbor is pushing for residents to keep the fresh rainwater runoff (stormwater) drains clear to reduce Flood Hazard for Nearby Homes and Businesses.
Update: dumping all this snow in the drainage basins also causes more pollution to flow unablated into the creek/drain and to the river. In the past UM dumped snow directly into the Huron River till the County Drain Office notified them that this is in violation of the Clean Water Act due to pollution loading into the river.
UM is ignoring this request to protect life, health and property by piling snow into the Allen's Creek Drainage Basins on the Athletic Campus as shown in the above ACWG images. These drainage basins near these parking areas drain directly into the Allen's Creek Drain but only if they are not piled full of snow. These huge snow piles could take weeks to melt away. UM may be in violation of the Drain Code in these actions.
The Athletic Campus has very high levels of impervious surfaces, one third more added after the stadium was improved a few years ago, which create much more fresh rainwater runoff (stormwater) flood hazard and pollution to the Huron River. The UM should continue using porous pavement as the UM used in the Fuller Rd. UM parking lot a few years ago, which has been shown by city staff to handle 1,300 inches and hour!
UM has a history of ignoring the environmental effects of high flows, polluted waters and dangers to property.
UM contracted to get new floodplain maps for the campus, trying to show less fresh rainwater runoff (stormwater) drains flow to the river through the city stormwater pipes. City pushed back and UM was forced to pay the additional Stormwater Fees that they tried to cheat the city from collecting.
UM also hired a contractor to redraw floodplain maps for the Athletic Campus which showed a much smaller floodplain. The city has indicated to the ACWG, and showed us, that they have new floodplain maps that are accurate and show the larger floodplain. A smaller floodplain would allow more flexible development of land in the Athletic Campus and potentially more flood hazards for the community. This with reports that FEMA is Low Balling the FEMA Floodplain Maps by 30%.
Link:
City of Ann Arbor Stormwater Page: https://www.a2gov.org/departments/systems-planning/planning-areas/water-resources/stormwater/Pages/default.aspx
Doctors in Canada Can Now Prescribe National Park Passes to Patients to Go Take a Walk, in the Woods: Washington Post
High Line Elevated Greenway, NYC; Way More visitors per year than the 7th Wonder of the World
This Greenway can be so crowded that they were encouraged in 2021 to add a $60M Expansion
(High Line Trees NYCGovParks.Org)
Washington Post: 2-7-2022:
"Studies show that time in nature can lead to a range of benefits, including less stress and higher self esteem.
There’s almost no medical condition that nature doesn’t make better,” said Melissa Lem, a family physician and director of the PaRx initiative, which partnered with Parks Canada to help distribute the initial batch of 100 passes. While similar programs elsewhere have offered regional or local park visits, Lem says this is the first such initiative with a national annual pass." (bold by us)
The ACWG has pushed for more Green Space in Ann Arbor for this and many other reasons. The Allen's Creek Greenway/Tree Line has long been promoted by the ACWG for this and, flood hazard mitigation and, biking and walking transport among others. We were leaders in the Center Of the City Park Park passed voter referendum.
As we have promoted for many years, that U of M, with others, conducted a study with students walking in the Arboretum vs walking on streets on campus and in town showed significant reductions in stress indicators, as reported here in the past on ACWG. They found taking a walk in the woods seemed to be as effective as anti-depressant drugs, without the nasty side effects, for mood elevation. This would be a very cost-effective way to improve the community in many ways.
Short Changing the City Tax Payers on the Green Belt Millage from its Inception:
Long past time to follow the Green Belt mandate 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 did not meet the GreenBelt Millage mandate.
The City of Atlanta requires the preservation of the existing tree canopy and planting more trees to enhance the livability of the residents in the city, reduce runoff, polluted runoff and heat island, among other benefits, Ann Arbor pretends to support.
Washington Post: https://www.washingtonpost.com/climate-solutions/2022/02/07/national-park-prescriptions-mental-health/
Porous Pavement Road and Parking Lot Provider: ACI ASPHALT & CONCRETE; Indiana
Porous Road: Mall Rd, Portland ME;
Four Lane Porous Road Test, 2019 Image Many Years After Install
(Google Streets; ACWG)
ACI ASPHALT & CONCRETE: "The main advantage and primary reason why porous asphalt is a suggested option for certain commercial paving projects is its permeable characteristics. Pervious asphalt allows water to flow right through, and into the ground beneath.
The benefit of this is that water cannot accumulate and build up on the surface of asphalt pavement. This means less water accumulation and puddles in parking lots and streets. It also prevents damaging water run-off and flooding.
You will often find permeable pavement in the form of sidewalks, driveways, streets, parking lots, municipal spaces, and more." (bold by us)
See our other comments on Mall Road and Porous Pavement our web site Agenda and Updates Pages and, see our Benefits of Porous Pavement Page.
Link:
Porous Pavement Installer web page, ACI ASPHALT & CONCRETE; Indiana: https://www.aciindiana.com/blog/facts-about-permeable-pavement/
A Flood Mitigation Detention Pond To Be Installed in Lawton Neighborhood To Reduce Flood Hazard
Churchill Downs Park Proposed Detention Flood Mitigation Basin
(City of Ann Arbor; Rt Clk for larger)
MLive 2/2022: “In the coming weeks, crews will begin digging a large stormwater pond at Churchill Downs Park, just south of Scio Church Road along I-94, to better handle severe rainstorms and keep adjacent neighborhood homes from flooding.”
Great to see this $3.2 million project move forward. It will provide much-needed flood hazard mitigation for the down stream neighborhoods. We have been promoting this work for a long time.
Initially, the city proposed large sewage holding tanks in several woodlands on the west side to mitigate flooding for these neighborhoods, ACWG stopped that nearly adopted 'preferred plan' and pushed for footer disconnects, reduced runoff and detention areas to reduce the obvious flood hazard.
A lawsuit to prevent city-required footer disconnects was not successful, partly due to ACWG's comments in support of footer disconnects during an oral legal deposition for the court cases.
Footer drains installed around the houses when they were built, saved developers about $150 per house avoiding sump pump installs, now taxpayers pay Thousands per house to fix the mess. Homes built in old creek beds and swampland were shown in city hall presentation after the flood, in a 1940’s aerial image of the neighborhood before it was built-out. The home's footer drains discharged large amounts of fresh water flowing in them and overwhelmed the sanitary sewer system as a major cause of massive basement flooding.
With Global Warming more needs to be done including I94 runoff and Scio Twp runoff into these neighborhoods, Rain barrels, Rain Gardens and less impervious surfaces are effective low-cost flood and pollution reduction methods which the ACWG initiated and supported for many years.
The 6” rain event March 2012 with Dexter Tornado (100 year (1% chance)) is just an example of what we will need to plan for. More parks like this that are added green space and can be allowed to flood in a large rain holding rainwater temporally, drain off slowly and then go back to being a park for 99.99% of the time.
The Allen's Creek Greenway was planned to have this option of capturing floodwaters and reducing flooding, until city leaders gave it over to developers the project and seem to have made an effort to maximize development minimize flood hazard mitigation. This is an opportunity lost that has great potential.
Ann Arbor should have learned a lesson. Mayor Taylor and his supporters wanted the city-owned lot at 415 W. Washington to have the option for Affordable housing and was pushing for the development in the floodplain and likely floodway, with new models showing FEMA is 30% low balling floodplains in the USA and proposed FEMA2.0 to correct it. ACWG pushed for an amendment to the recently voter-approved Affordable Housing Millage that now bans the use of funds for Affordable housing in Ann Arbor floodplains
Fast Company: "Is building tall really best? Researchers dispel the myth of climate-friendly skyscrapers", Ann Arbor Leadership Is Not Listening, Pushing for More Very Tall and Ugly 'Climate Changing Buildings'
5th Street City-Owned Old YMCA Lot, 350 S 5th, Recent Version of the Proposal
(Smith Group, City of Ann Arbor; Rt Cl for larger)
The city is proposing and Planning Commission has voted to support a pre-approved design for a developer to accept and build generally - a Market Rate (full market price) 20 story and affordable housing 14 story buildings on city-owned Old YMCA Lot.
Planning Commission had a meeting to discuss this proposal and took Public Comment which ACWG made (and sent to City Council), shown below:
"I am the Founding and Coordinating Member of ACWG
We support affordable housing, just sensible affordable housing.
Ann Arbor's $1B A2Zero Resolution needs to be taken seriously. This and other very tall buildings do not seem to.
You need to publish the proposed Carbon Emissions from the plans for these very tall buildings and their use!
High Carbon emissions do affect weather conditions. Our weather is changing quickly in SEM and elsewhere due to Global Warming.
A report from Fast Company, Aug 2021:
'Is building tall really best? Researchers dispel the myth of climate-friendly skyscrapers' states:
'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, for example like most Parisian neighborhoods.
Taller and denser isn’t necessarily better for the environment, according to a new study published in the journal NPJ Urban Sustainability. 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' (underline by us)
Ann Arbor voters recently overwhelmingly voted down a proposal for a 17 story highrise building across the street in favor of a central park on city-owned land. That should not be ignored.
The Mayor and his supporters on city council proposed unlimited building heights in Ann Arbor which is not discussed very much now due to resident push back.
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!
Paris, for example, with its mostly five- and six-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.
Tall buildings also isolate residents, especially children, the elderly and the disabled.
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.
Just 10 tall buildings in NYC produce more Carbon emissions than all other buildings in NYC combined due to poor design, shoddy construction and upkeep.
Tall buildings create major health risks and high energy usage with dangerous heat island effects in the downtown.
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.
More excessive carbon emissions mean more dangerous weather for our community, like the now common 100-year (1% Chance) rains SEM is getting and causing death and major damage.
Having very little on-site parking required for this building is great for developers, much more income, very bad for citizens of Ann Arbor, especially nearby neighborhoods whose streets will be completely parked up 24/7. Not what these residents were expecting or want.
Thank You
This proposal is a Pre-Entitlement Design for a development the city would like to see built on this city lot.
Link:
Fast Company, Aug 2021: Is building tall really best? Researchers dispel the myth of climate-friendly skyscrapers; https://www.fastcompany.com/90666746/is-building-tall-really-best-researchers-dispel-the-myth-of-climate-friendly-skyscrapers
January 2022 - No Meeting this Month Due to COVID-19 Pandemic Cautions and Travel Plans
Watershed Issues of Interest and Updates
CARD Group Canceled January Meeting Due to Vacation and Travel Schedules;
Gelman Plume Keeps Spreading In Many Directions, EPA has Superfund For Gelman/Danaher Site Under Study
Vince Caruso Makes Comment at Joint City County EGLE Session 12-12-19
(Roger Rayle CARD YouTube, Rt Click for Larger)
The Coalition for Action on Remediation of Dioxane (CARD) group and ACWG have pushed for more and better testing of drinking water wells in nearby townships. Using a more sensitive test Scio Twp paid for better testing of homeowner drinking water wells, not Environment, Great Lakes & Energy (EGLE). These tests showed drinking water wells for four homes in Scio Twp have tested positive for 1,4 Dioxane at about 0.8 parts per billion (ppb) and another home at 1.81 ppb, outside the area considered part of the Gelman 1,4 Dioxane plume. These wells are to the north outside the recognized Gelman/Danaher Plume. Large number of private residential wells are in this area.
EWG.ORG, as described below, writes that EPA says 0.35 ppb is dangerous in drinking water.
0.8 and 1.81 ppb were found using a much better method, one CARD and ACWG has demanded, than EGLE used previously, the United States Environmental Protection Agency-developed “Method 522,”. This method can detect 1,4 dioxane contamination down to 0.12 ppb. This test gives much better understanding of where and when the plume has moved in groundwater. CARD and ACWG have been asking for these types of tests in the Gelman/Danaher 1,4 Dioxane Toxic Waste Plume for years, and Gelman/Danaher and EGLE have refused to use.
US EPA has hired a consultant to collect critical supporting data for Superfund designation of the Gelman/Danaher Toxic Waste Plume. These tests and analysis and evaluation should be done in 6 to 12 months as is the normal process for EPA Superfund Site Listing.
Findings pushed by CARD and ACWG of significant near-surface shallow groundwater (NSG) contamination in West Park and the threat to homeowner and business exposures lead to an EGLE implementation of a State-Wide Vapor Intrusion Rule for the State of Michigan and set lower standards for drinking water to 7.2 ppb. EPA also cited this as a major reason to consider a Superfund Site for the Gelman/Danaher 1,4 Dioxane Toxic Waste Plume. High-ranking EGLE officials commented to CARD ACWG that public involvement in this Gelman/Danaher 1,4 Dioxane Toxic Waste Plume was a major reason for this change.
"U.S. Rep. Debbie Dingell is urging the Environmental Protection Agency to designate the Gelman plume as a federal Superfund site.
Citing the recent discovery of new dioxane-contaminated residential drinking water wells north of the designated plume area just outside Ann Arbor, Dingell sent a letter to EPA Administrator Michael Regan on Friday, Nov. 12, “to reenforce (sic) the urgent need” for a Superfund cleanup.
“This news is alarming and strongly suggests the plume is expanding within the environment and throughout the surrounding communities,” Dingell wrote." : MLive (bold by us)
“It was surprising to find the dioxane contamination so far away from the established area of the dioxane pollution,” said Scio Township Supervisor Will Hathaway in a statement. “While the level of dioxane in the homeowner wells is deemed safe according to the EGLE drinking water standard, we believe that the residents of Scio Township deserve to know if any dioxane is in their wells using the best science.” MLive
Finding 1,4 Dioxane in NSG in West Park shows the plume has moved to an area where homes may be affected, seemingly in violation of the very weak MI Part 201 "environmental regulations".
U of M Radio also covered this story.
'Still, Scio Township Supervisor Will Hathaway said, the news was concerning. "The dioxane is spread much further north than had been known previously. Even though this is a very low concentration, there's no doubt that this is dioxane and that it's in the groundwater in this part of the township," Hathaway said.'
Residential Basements and Allen's Creek Infrequent Tests as Pollution Sentinels is Wrong, EGLE needs to Change:
Even with CARD's unanimous request for more meaningful near-surface shallow groundwater (NSG) tests EGLE is still keeping with its old plan of simple tests of the Allen's Creek yearly. Simple tests in Allen's Creek in West Park last year tested at 49 ppb. These simple tests this year tested somewhat lower.
The Federal MS4 Violation in Allen's Creek Going on 4 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 Clean Water Act violation.
'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 storm water or uncontaminated groundwater except discharges pursuant to an NPDES permit.' (bold by us)
Gelman/Danaher is in violation of the MS4 Federal Regulations with their 1,4 dioxane flowing in Allen's Creek and into the Huron River.
The Water Resources Commissioners Office (WRCO) has notified Gelman that they are in violation of the Federal MS4 Permit in a statutory Freshwater Runoff (Stormwater) Drain. WRCO is the delegated authority by EGLE and the Federal Government to manage MS4 permits in the County. No word on what Gelman/Danaher will do about this over 3-year-old Federal MS4 Violation. WRCO has done very little to force Gelman/Danaher to mitigate this pollution in the Allen's Creek since discovered over 3 years ago.
The tests near Slauson Middle School on 8th St. with a recent high test of 11 ppb, are a concern and should be followed up with more NSG critical tests.
The Majority of our City Council "Sits on Their Hands" while this ill-advised testing protocol and MS4 violation continues.
Basements used for sentinels of NSG contamination, like drinking water wells used as sentinels, is wrong.
Instead of seeking out the true location of the plume we have officials making poor decisions on where to or not to test for the NSG plume. They do not consult with CARD and for some reason keep testing the same old locations without a real meaningful plan.
Waste of taxpayer funds and endangering residents and businesses testing basements and creek tests to far west repeatedly, No real attempt to get CARD position on the tests that need to be done.
Links:
EWG https://www.ewg.org/tapwater/reviewed-1-4-dioxane.php
https://www.mlive.com/news/ann-arbor/2021/11/in-letter-to-epa-dingell-calls-latest-ann-arbor-area-dioxane-news-alarming.html
CARD Meeting 11-03-21 YouTube: https://www.youtube.com/watch?v=ieU2LbIFUBg
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 and WEMU News Program GreenRoom
Washtenaw County CARD Site
See ACWG site pages EPA Superfund Option Details from CARD/ACWG.
"$2.4M demolition and cleanup of polluted Ann Arbor dry cleaner site underway":MLive, at Armen Cleaner Site 630 S. Ashley St. Downtown Ann Arbor!
Armen Cleaners at 630 S. Ashley St., Site of Decades-Long Major Dry Cleaning Fluid Pollution
(Google Maps)
Armen Cleaners has been at 630 S. Ashley St. for decades and has seriously polluted groundwater in and around this area for decades. This one block from downtown Main St. City of Ann Arbor.
The main or only dry-cleaning solvent used on this site tetrachloroethylene or PCE is a known carcinogen and readily evaporates and can enter homes and businesses from the contaminated ground.
The ACWG, residents and Washtenaw County officials have pushed the city to do a cleanup of this site for decades. One comment from the city was it was waiting for an appraisal to buy the site to clean it up. It never seems to happen and the site sat for decades polluting the area and exposing residents to cleaning fluid vapors in their homes.
This pollution was so egregious US EPA decided to come to Ann Arbor and do testing of home exposures and groundwater contamination. They found significant pollution in and around the Armen Cleaners Site and notified the city.
Years later EPA is here to remove the building and attempt to clean up the soils in the area.
Links:
https://www.mlive.com/news/ann-arbor/2022/01/24m-demolition-and-cleanup-of-polluted-ann-arbor-dry-cleaner-site-underway.html
Excessive Use of Road Salt Threatens Michigan Streams, Lakes and Rivers, and Our Great Lakes!
Porous Roadway Drinking Up Huge Amounts of Water In a Demonstration
(PBS 2018)
Porous Pavement City of Ann Arbor Sign at the Y Lot the ACWG Encouraged and Promoted
( ACWG, Rt Clk for larger)
Canceled Fuller Park Proposed Mega Parking Lot/Train Station with Porous Pavement Proposed for All Access Roads*
(City of Ann Arbor, Large Black Arrowed Labels by us)
'De-icing salts end up in bodies of freshwater, contaminating lakes and streams and building up in wetlands. The Environmental Protection Agency’s thresholds are not high enough to protect life in freshwater, the scientists write'
The ACWG started and promoted Porous Pavements for years in Ann Arbor area. We help write and pass the City of Ann Arbor's new Green Streets Policy with the Ann Abor Environmental Commission (EC), Rita Loch-Caruso as an EC and ACWG, and CARD Founding Member. The city and U of M have done several projects with Porous Pavement including many Streets, parking lots and paths.
Bike paths being installed in Ann Arbor would have greatly benefited from the use of porous pavement as noted below. New paths should use it. For some reason, they are not included now.
U of M Fuller Rd.'s Porous Parking Lot across from the soccer fields, installed a few years ago, was tested by the city and showed it could handle a huge 1,300" of water an hour. This parking site has held up very well.
Some Benefits of Porous Pavements Including Less or No Salt Use:
Much reduce salt use as many snowfalls and ice will naturally melt into the porous pavement
Much less snow and ice removal is needed, and salt and sand applications
Much less runoff and flooding
Easy to maintain, if and when clogged one vacuum regenerates perviousness to near 100% original levels (Michigan Concrete Assoc. personal comment to ACWG at PP project to pave their large parking lot in Lansing MI)
No Black Ice, fewer accidents, great for bike and walking paths, Black Ice melts into pavement
Pollution mitigation as the water percolated into the ground and gets naturally detoxified
80% reduction of road noise
Similar or less cost the conventional
Fewer Pot Holes
6 Lane Experimental Porous Mall Road in Portland Maine greatly helped restore a nearby stream in about a year or two, and has held up well in the past 6 years, among many other benefits
Safer for bikers and pedestrians
Much less heat island effect as heat is absorbed into the earth below the pavement, cooler city
Little or no hydroplaning on roadways
Porous pavement preserves street trees near pavement allowing critical water and air to the root systems
The surface offers long-term performance for cold climate settings as shown in comprehensive tests
See the ACWG Site for Benefits of Porous Pavement Page with more details
https://sites.google.com/site/allenscreekwatershedgroup/benefits-of-porous-pavements-acwg?authuser=0
Links:
https://www.bridgemi.com/michigan-environment-watch/road-salt-threatens-michigan-lakes-and-rivers-can-alternative-take-hold
ACWG Site for Benefits of Porous Pavement Page with more details
Daylighting Streams Makes Communities Safer, Greener, Cleaner and More Pleasant To Be In;
EPA Says Daylighting Is the Most Effective Watershed Restoration Technique;
Ann Arbor Just Buries Them For Short Term Gaines, Long Term Losses!
DayLighted Formally Buried Arcadia Creek in Downtown Kalamazoo,
Now A Greenway and Major Flood Mitigation Site
(Kalamazoo DDA)
'Why New York Is Unearthing a Brook It Buried a Century Ago
A plan to “daylight” Tibbetts Brook in the Bronx would be one of the city’s most ambitious green infrastructure improvements.'
The city plans to unearth the brook — an engineering feat known as “daylighting” — at a cost of more than $130 million because burying it in the sewer system has worsened the city’s flooding problems as a warming planet experiences more frequent and intense storms.'
EPA has often said, and told the ACWG, that Daylighting Streams are the most effective techniques to rehabilitate streams and watersheds that they know of. This is because you get the community interested and take ownership in the stream, watershed and water quality which does wonders for the environment.
Daylighting also greatly reduces flooding as an open stream can handle much more water than a pipe and because it is visible the community is more likely to demand better watershed management.
Also, pollution is much more obvious to the community in an open creek than in a piped creek and gets the community's attention and action.
The old buried Arcadia Creek area flooded often, now daylighted it does not and is a major green amenity for the city.
Allen's Creek's Few Open Parts sections in our Private Commons, was Buried Costing About $1/2M City Tax Payer Dollars:
A terrible example of Ann Arbor's ongoing treatment of streams is the upper Allen's Creek that was piped due to very poor planning allowing development just up to the open creek bank on a very steep slope. Wendy Ramson a city staffer told me that site would never be developed because of the slope and creek location. Soon after a development happened on the site the city was forced to pipe (enclose) 500' the upper Allen's Creek at a cost of about $1/2M, with the developer walking away without paying anything. Tens of trees were lost including many Landmark Trees and the community lost a major amenity in a private wooded park commons owned by the neighborhood. Commons owners were not given the large number of trees due to the city's failure to mark existing trees carefully and residents proved errors were made in IDing the existing trees, as we were promised. The Utility Director in charge and who canceled the penalty trees promised was removed after this debacle.
Allen's Creek Greenway Could Involve Daylighting, Flood Mitigation and Pollution Reduction: As We Proposed in the MDEQ/County/City Adopted Allen's Creek Watershed Management Plan.
The ACWG has worked for many years to promote the Allen's Creek Greenway (also now called Tree Line). City master plan of 1980 also promoted it. The Allen's Creek Greenway would run along the tracks from south Ann Arbor to the Huron River. It could reduce flooding, pollution and become a major amenity for the city and environment. The floodplain where the creek was should not be developed with Global Warming greatly increased threats of flooding.
The 415 W. Washington city site was proposed by the mayor for affordable housing. The ACWG was largely responsible for making the floodplains off-limits to Affordable Housing in the City Millage, something the city has, unfortunately, routinely done in the past.
Link:
https://www.nytimes.com/2021/12/06/nyregion/tibbets-brook-bronx-daylighting.html
MDEQ/County/City Adopted Allen's Creek Watershed Management Plan
December 2021 - No Meeting this month due to COVID-19 Pandemic Cautions and Travel Plans
No Watershed Issues of Interest and Updates Posted This Month.
November 2021 - No Meeting this month due to COVID-19 Pandemic Cautions
Watershed Issues of Interest and Updates:
CARD and ACWG Pushed for More and Better Well Testing and It Was Found; MLive: “In letter to EPA, Dingell calls latest Ann Arbor-area dioxane news ‘alarming’ “; Scio Drinking Water Wells Found To Contain 1,4 Dioxane
The Coalition for Action on Remediation of Dioxane (CARD) group and ACWG have pushed for more and better testing of drinking water wells in nearby townships. Using a more sensitive tests Scio Township* tests showed drinking water wells for two homes in Scio Twp have tested positive for 1,4 Dioxane at about 0.8 parts per billion (ppb) and one home at 1.81 ppb, outside the area considered part of the Gelman 1,4 Dioxane plume.
EWG.ORG, as described below write that EPA says 0.35 ppb is dangerous in drinking water.
0.8 and 1.81 ppb were found using a much better method, one CARD and ACWG has demanded, than EGLE used previously, the United States Environmental Protection Agency-developed “Method 522,”. This method can detect 1,4 dioxane contamination down to 0.12 ppb. This test gives much better understanding of where and when the plume has moved in groundwater.
"U.S. Rep. Debbie Dingell is urging the Environmental Protection Agency to designate the Gelman plume as a federal Superfund site.
Citing the recent discovery of new dioxane-contaminated residential drinking water wells north of the designated plume area just outside Ann Arbor, Dingell sent a letter to EPA Administrator Michael Regan on Friday, Nov. 12, “to reenforce (sic) the urgent need” for a Superfund cleanup.
“This news is alarming and strongly suggests the plume is expanding within the environment and throughout the surrounding communities,” Dingell wrote." : MLive (bold by us)
“It was surprising to find the dioxane contamination so far away from the established area of the dioxane pollution,” said Scio Township Supervisor Will Hathaway in a statement. “While the level of dioxane in the homeowner wells is deemed safe according to the EGLE drinking water standard, we believe that the residents of Scio Township deserve to know if any dioxane is in their wells using the best science.” MLive
Environmental Working Group (EWG.ORG) Health Effects Information on unsafe drinking water levels of 1,4 Dioxane:
https://www.ewg.org/tapwater/reviewed-1-4-dioxane.php
"In 2013, the EPA classified 1,4-dioxane as a likely human carcinogen and defined a concentration of 0.35 parts per billion in tap water as the amount expected to cause no more than one additional case of cancer in 1 million people who drink it for a lifetime. But because there are no federal regulations limiting 1,4-dioxane in tap water, seven states have set their own criteria: CA 1ppb, Colorado’s 0.35, Massachusetts 0.3, North Carolina’s surface water supply standard 0.35" (bold by us)
(Click Image for HighResolution; Rt Clk for larger)
Link to Original Map: https://www.michigan.gov/documents/egle/Dioxane-Plume_Map-7-2-ppb-Gelman-Sciences-Inc-Remediation-2020-2021-07-13_731040_7.pdf.
Link to Interactive EGLE Gelman Plume Map with extensive details regarding wells and well data:*
https://egle.maps.arcgis.com/apps/webappviewer/index.html?id=b2d077fdef2b4005883a5305a92ad1df
USEPA is still in the preliminary steps of very likely making this Gelman/Danaher Toxic Dump Site a USEPA Superfund Site for likely full cleanup.
Michigan Part 201 "environmental law" (GOP sponsored) are very weak and ineffective leaving Zombies in the ground for later generations to deal with.
"What’s kind of a like a zombie rising from the grave is these buried contaminants that are now showing up in people’s homes, in their air, specifically. That was not envisioned by the science at the time; if you left chemicals in the ground they could actually migrate up through even impervious surfaces and affect people’s health." Dave Dempsey, For The Love Of Water FLOW - WUOM (bold by us)
Finding 1,4 Dioxane in NSG in West Park shows the plume has moved to an area where homes may be affected, seemingly in violation of the very weak Part 201 regulations.
Residential Basements and Allen's Creek Infrequent Tests as some kind of Pollution Sentinels is Wrong:
Even with CARD's unanimous request for more meaningful near-surface shallow groundwater (NSG) tests EGLE is still keeping with its old plan of simple tests of the Allen's Creek yearly. Even the simple tests in Allen's Creek in West Park have always come back with double the previous tests. Last published test was over a year ago and was at 49 ppb.
The Majority of our City Council "Sits on Their Hands" while this ill-advised testing protocol continues.
Basements used for sentinels of NSG contamination, like drinking water wells used as sentinels, is wrong.
Instead of seeking out the true location of the plume we have officials making poor decisions on where to or not to test for the NSG plume. They do not consult with CARD and for some reason keep testing the same old locations without a real meaningful plan.
Waste of taxpayer funds and endangering residents and businesses testing basements and creek tests to far west repeatedly, No real attempt to get CARD position on the tests that need to be done.
Links:
EWG https://www.ewg.org/tapwater/reviewed-1-4-dioxane.php
https://www.mlive.com/news/ann-arbor/2021/11/in-letter-to-epa-dingell-calls-latest-ann-arbor-area-dioxane-news-alarming.html
CARD Meeting 11-03-21 YouTube: https://www.youtube.com/watch?v=ieU2LbIFUBg
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 and WEMU News Program GreenRoom
Washtenaw County CARD Site
See ACWG site pages EPA Superfund Option Details from CARD/ACWG.
Ann Arbor Approves Clear Cut of Well over 30 Acres of Woodlands and 311 of 447 Landmark Trees and 450 of the 741 Low-Level Woodland Trees For Luxury Homes
Toll Brothers proposed at 660 Earhart Rd. plans for the 57-home luxury subdivision that was approved by City Council this month.
While Ann Arbor "Leaders" works hard to take out major wood lots for Luxury Homes in Ann Arbor while others are adding wood lots and greenery in out-Ann Arbor and other cities.
This when we have a Greenbelt Millage that was past with ~33% spending in the City of Ann Arbor stipulated, when we are spending less then 9% in the city.
Greenbelt Millage Council Resolution 2003, Showing Required Spending ~33% in the City;
Green Lots for outside the city:
"Greenbelt purchase of 375 acres in Salem Township, ultimately costing the City $1,122,367 (30% of the purchase price). This would be the largest Greenbelt purchase in the history of the program.": MLive
ZHA transforms inner-city neighborhood into a greenery-filled oasis
(Zaha Hadid Architects; Rt Clk for larger)
“Zaha Hadid Architects has now revealed plans to reshape a sizable chunk of inner-city Budapest, Hungary. The Zugló City Centre development will involve transforming a roughly 7-hectare (17-acre) site into a modern and energy-efficient neighborhood filled with greenery.
It will connect to a nearby creek and will add almost 35,000 sq m (roughly 376,000 sq ft) of communal green space, including a park, multiple plazas, and ponds. Pedestrian pathways and cycle paths will be added too, and 900 new trees will be planted for shading.
“[The project] …will form a harmonious whole with the large green areas and community spaces that will be created.” NewAtlas.Com (bold by us)
Green spaces, especially with trees, is a real benefit to a community for calming and relaxing effects.
U of M, with others, conducted a study with students walking in the Arboretum vs walking on streets on campus and in town showed significant reductions in stress indicators, as reported here in the past on ACWG. They found taking a walk in the woods seemed to be as effective as anti-depressant drugs, without the nasty side effects, for mood elevation. This would be a very cost-effective way to improve the community in many ways.
CityLab: "In recent years, study after study has found that living in neighborhoods with abundant green space is linked to positive health outcomes. These include better heart health, stronger cognitive development, and greater overall longevity. No wonder these areas are also linked to lower levels of Medicare spending.
But when it comes to promoting human health, not all green spaces are created equal. That’s the conclusion of new Australian research, which finds higher levels of wellness in areas marked by one particular manifestation of the natural world: leafy trees." This study with almost 50,000 subjects. (bold by us)
Long past time to follow the GreenBelt mandate 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 very valuable few green spaces left in the city.
Link NewAtlas.Com
Links:
https://newatlas.com/architecture/zaha-hadid-budapest-zuglo-city-centre/
CityLab: https://www.citylab.com/environment/2019/07/urban-tree-canopy-green-space-wellbeing-research/595060/
"World Ill-Prepared for 'Looming Water Crisis', U.N. Agency Says": Washington Post
Michigan UP 1,000 (0.1% chance) Year Rain Event 2018
(Rt Clk for larger)
"Recent deluge in Italy sets European record: 29 inches in 12 hours.
It followed a summer of climate change-fueled extreme precipitation events in the Northern Hemisphere.
An intense complex of thunderstorms stalled over northwestern Italy on Monday, unleashing a 12-hour torrent unrivaled in the history of European weather observations.
It’s the latest extreme rain event supercharged by climate change that follows a summer of historic deluges in the Northern Hemisphere.
In just 12 hours, 29.2 inches of rain fell in Rossiglione in Italy’s Genoa province, roughly 65 miles south-southwest of Milan and 10 miles north of the Mediterranean coastline. It marked the greatest 12-hour rainfall on record in Europe, according to Maximiliano Herrera, a climatologist who specializes in world weather extremes." (bold by us)
ProPublica: "FEMA’s maps are notoriously incomplete"
' "… FEMA’s maps are notoriously incomplete. They capture some flooding from rivers and other coastlines, yet they rarely account for the risks from intense rainfall — a growing problem made worse by urban development and climate change.
A comprehensive new assessment of flood risk, released this week by the nonprofit First Street Foundation, exposes blind spots in FEMA’s maps to show just how vulnerable the nation’s properties are."
"We’re encouraged to see First Street Foundation building on federal agency datasets. ... FEMA…"
“We have some communities that cannot afford (the financial burden from flooding). There’s a big discrepancy and they’re not getting the level of attention that they need — and they need a lot of help.” '
Links:
"Detroit homes are being overwhelmed by flooding — and it's not just water coming in" : NPR.ORG
Detroit Neighborhoods Flooding June 2021
(WXYZ)
NPR (National):
Floodwaters mix with sewage and, flood and severely contaminate homes and businesses with high costs to clean up if at all possible. Detroit had multiple major floods this past Summer 2021.
'On June 26, 2021 six inches of rain fell in Detroit within three hours. The heaviest downpour hit the low-lying southeastern parts of the city.
Detroit isn't alone — communities across the country are seeing an increase in the severity and frequency of flooding due to climate change, testing the limits of water infrastructure built for a more moderate climate. The federal infrastructure bill, recently signed by President Biden, addresses that with billions of dollars for flood prevention.
"The hundred-year storm now kind of looks like a 10-year storm, because the recurrence interval has changed," Mobley [Palencia Mobley chief engineer for the Detroit Department of Water and Sewerage] says. Research shows that, as the climate warms, precipitation is also increasing, bringing heavier storms with higher rainfall. "Your system is not designed to respond to something like that." ' (bold by us)
It is now common for Michigan to get 1,000 year (0.1% chance) rains and will get more common by the year.
Link:
NPR: https://www.npr.org/2021/11/23/1037540261/detroit-homes-are-being-overwhelmed-by-flooding-and-its-not-just-water-coming-in
October 2021 - No Meeting this month due to COVID-19 Pandemic Cautions
Watershed Issues of Interest and Updates.
CARD Unanimously Passes Resolution Supporting Near-Surface Shallow Groundwater Permanent Wells to Monitor the Gelman 1,4-Dioxane Plume on the Ann Arbor West Side (see below)
CARD Zoom Meeting 10-05-21 (CARD; Rt Clk for larger)
At the October meeting of Coalition for Action on Remediation of Dioxane (CARD) the resolution, shown just below, was Unanimously Adopted. This Resolution was written by both CARD and ACWG members.
We hope that our government agencies will heed this request and act on it with due haste to protect the residents of Ann Arbor of this clear and present danger, and potentially a risk also in Scio Township.
10/5/21 Resolution that the Coalition for Action on Remediation of Dioxane (CARD) Request Near-Surface Shallow Groundwater Permanent Wells to Monitor the Gelman 1,4-Dioxane Plume on the Ann Arbor West Side and Potentially Scio Township.
WHEREAS, 1.4-dioxane from the Gelman Sciences site contaminated and persists in groundwater that continues to migrate into urbanized areas,
WHEREAS, 1.4-dioxane-contaminated groundwater continues to flow unremediated in near-surface shallow aquifers towards the Huron River,
WHEREAS, Decreasing topographic elevation along the eastward migration path allows the plume to approach the land surface,
WHEREAS, Sampling from two temporary shallow groundwater wells in 2016 already showed 1,4-dioxane at 1.9-3.3 ppb in near-surface shallow groundwater less than 10 feet deep just downgradient from Slauson Middle School,
WHEREAS, A Monitoring shallow well just over one half mile upgradient from West Park is now 340 ppb at an elevation similar to West Park and Slauson Middle School,
WHEREAS, The Rockworks interactive map sponsored by the Michigan Department of Environment, Great Lakes, and Energy (EGLE) confirms the near-surface shallow groundwater 1,4-dioxane contamination and shows areas lacking sufficient sampling,
WHEREAS, cited a threat to public health, safety, or welfare of citizens and the environment from 1,4-dioxane detected in near-surface shallow groundwater in the Ann Arbor area in close proximity to residential homes as the rationale for a stricter residential drinking water cleanup criterion and establishment of a new residential vapor intrusion screening criterion for 1,4-dioxane in the Emergency Rule dated October 27, 2016,
WHEREAS, Samples from the Allen Drain and storm water pipes have shown 49 ppb in the West Park area, 11 ppb in the Slauson Middle School area, and 28 ppb on Chapin St. near 8th Street, with levels trending upward,
WHEREAS, EGLE has acknowledged that Dr. Robert Bailey's (Environmental Chemist and CARD member) analysis showing 100 ppb may be a valid screening level for dioxane volatilizing with water vapor from near-surface shallow groundwater into homes, with certain assumptions,
WHEREAS, Ann Arbor’s west side has very shallow groundwater and groundwater seeps in some areas and many homes with wet or damp basements for long periods of time, and may experience liquid intrusion,
WHEREAS, Scio Township has shallow groundwater in some locations that could be contaminated with 1,4-dioxane now or in the near future,
WHEREAS, We still do not have permanent wells to monitor this clear and present danger from near-surface shallow groundwater contamination, as previously requested by CARD in 2016 and in later years,
RESOLVED, CARD strongly requests permanent near-surface shallow groundwater wells on the west side of Ann Arbor and potentially in Scio Township,
RESOLVED, CARD strongly urges our local government officials to support this Resolution,
RESOLVED, CARD requests permanent near-surface shallow groundwater monitoring wells on Ann Arbor west side across from Arborview Blvd and north side of Miller Ave, along 7th St to W Huron St., and along 8th St. to W Liberty St. installed in the next three months before hard winter weather returns. The CARD Group needs to be consulted on the placement of these well locations.
Sponsored by Vince Caruso, Rita Loch Caruso, and Roger Rayle
It was noted recently in a MLive report, on the West Park Band Shell Structural Problems, that the groundwater at West Park is as close as 2 feet from the surface. This has still not been tested by Ann Arbor or EGLE For Some Reason.
Many homes on the west side have wet and damp almost year round and 1,4 Dioxane contaminated NSG could be a significant exposure.
Links:
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 and WEMU News Program GreenRoom
Washtenaw County CARD Site
See ACWG site pages EPA Superfund Option Details from CARD/ACWG.
"Is building tall really best? Researchers dispel the myth of climate-friendly skyscrapers;
Neighborhood of skyscrapers results in about 140% more total emissions": FastCompany.Com
Downtown Paris, Low-rise Buildings Are the Norm Not the Exception
(Google, ACWG; Rt Clk for Larger)
A report in Fast Company:
"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.
But taller and denser isn’t necessarily better for the environment, according to a new study published in the journal npj Urban Sustainability. 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.
Paris, for example, with its mostly five- and six-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.
Isolate residents especially children and elderly, disabled..." (bold by us)
Children not outside as parents can’t see:
A 5 year old in our neighborhood unlocked his front door and walked away from home and I saw him and took him home before he was able to cross a nearby very busy street. Eyes on the neighborhood really make a difference.
Tall buildings are not the answer to housing shortages, but are a blight on our community, produce 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.
First Street Foundation More Accurate Flood Modeling is Affecting "Low Balled" Flood Maps Made by FEMA, Astronomical Flood Insurance Increases Likely
"New federal flood insurance rates that better reflect the real risks of climate change are coming. For some, premiums will rise sharply." See the Washington Post article below.
Compare Ann Arbor FEMA flood map of DTE toxic dump site, 841 Broadway St, and First Street's FloodFactor(R) map.
This site had 15' of water careening over it in the 1968 100 year flood according to eye witnesses.
First Street Foundations FloodFactor(r) for this site is 9 out of 10!
DTE Site Extreme Flood Factor, the Highest Level Possible
"As FEMA prepares to remove subsidies from its flood insurance, a new assessment says 8 million homeowners in landlocked states are at risk of serious flooding because of climate change"
Washington Post, Oct 1, 2021
From the Article:
" 'Flooding is the most common and costly type of natural disaster in the United States.
On Friday [October 1, 2021], the Federal Emergency Management Agency [FEMA] will incorporate climate risk into the cost of flood insurance for the first time, dramatically increasing the price for some new home buyers. Next April, most current policyholders will see their premiums go up and continue to rise by 18 percent per year for the next 20 years.
The price hike under a new assessment, Risk Rating 2.0, will more accurately reflect the threat of flooding in a changing climate, federal officials say. '
'Moderately priced homes were overinsured and million-dollar mansions were underinsured. In a nutshell, middle-income policyholders were helping to subsidize the rich.
First Street never worked directly with FEMA, but it presented its model to the agency’s technical committee shortly before the agency made plans to implement Risk Rating 2.0.
'...heavily subsidized government flood insurance that made the cost of protecting their homes much less expensive, despite the risk of living in a flood zone ,,.'
'It is now going to say if you’re in a risky place, you’re going to get charged more for it, and other people aren’t footing the bill,' ...
'The price hike under a new assessment, Risk Rating 2.0, will more accurately reflect the threat of flooding in a changing climate, federal officials say.
Most homeowners will see modest increases starting at $120 per year in addition to what they already pay, and a few will see their insurance costs decrease. But wealthy customers with high-value homes will see their costs skyrocket by as much as $14,400 for one year.' " (bold by us)
These more protective flood model changes are being promulgated after FEMA had discussions with First Street Foundation. Some locations in Ann Arbor built in the floodplains may see astronomical increases in FEMA flood insurance rates, some built in recent years.
Link:
September 2021 - No Meeting this month due to COVID-19 Pandemic Cautions and Travel Schedules
Watershed Issues of Interest and Updates:
Danaher/Pall/Gelman 1,4-Dioxane Toxic Dump Site Plume - Permeant Near-Surface Shallow Groundwater Monitoring on West Side Resolution to be Requested by CARD Due to Rising Readings with "Quick and Dirty" Allen's Creek Sampling in Recent Years
The Michigan Department of Environment, Great Lakes, and Energy - EGLE cited a threat to public health, safety, or welfare of citizens and the environment from 1,4-dioxane detected in near-surface shallow groundwater (NSG) in the Ann Arbor area in close proximity to residential homes as the rationale for,
stricter residential drinking water cleanup criterion and
establishment of a new residential vapor intrusion screening criterion for 1,4-dioxane in the Emergency Rule dated October 27, 2016.
Potential exposures also may occur in Scio Twp in locations with near-surface shallow groundwater in some locations and should be tested also if warranted .
Before the October 27, 2016 Michigan did not have a residential vapor intrusion screening criterion for any contamination. ACWG and Coalition for Action on Remediation of Dioxane (CARD) forced the state to make these changes.
EPA is currently doing well testing and studying geological aspects of the Gelman/Danaher Toxic Waste Plume as part of the effort to likely begin a EPA Superfund process for the site in the next year or two. Governor Whitmer Has Sent a Letter To EPA in Support (Concurrence Letter) of an EPA Superfund for the Gelman/Danaher Toxic Dump Site and Plume in April 2021.
US EPA has set up a website for the Gelman/Danaher Toxic Dump Site and Plume with basic descriptions of the site and status.
At the August CARD meeting, after issuing another request, EGLE and local officials agreed to set a date to investigate potential 1,4 dioxane exposure because of detection and increasing levels being found at and near West Park. Potential exposure could occur from vapor intrusion into buildings and other exposures from outside contact with contaminated groundwater seeping to the surface. See details below.
With 49 ppb at West Park TEN MONTHS since the last tests, we said, is way too long to wait. Additional tests are now planned for this summer.
Very Detailed Gelman/Danaher Plume Geological Study Published:
EGLE has contracted with RockWorks to report on very detailed geological aspects of the Gelman/Danaher contamination. This recently published report is on the city web site. Lots of details, charts and maps which will take some time to study this very long PDF file.
For some reason the RockWorks report was not communicated to CARD or the public in a timely manner.
"June 2021 Court Order" (4th Consent Judgement (CJ) Agreement) Mess;
Interveners Left in the Dust!:
CARD suggests we not call this a 4th Consent Judgement , but call it "Courts Order" or "June 2021 Court Order" because the only ones working on the consent are the lawyers and Judge and not including the Interveners from reliable reports.
Judge makes confusing comments and statements that are confusing even Ann Arbor experienced lawyers on CARD. Not clear where this court is going. Gelman/Danaher very happy with the confusion, delays are a win for them. The public has spent over $1 Million on this June 2021 Court Order with little to show for the effort. Not clear what is the direction or intent of this process other than to delay and get Lawyers rich off Tax Payers doing a very poor job.
Million Dollar Legal Service Unacceptable:
Poor service to the public, for example, the public was left to determine the many Outrageous GOCHAS in the very complex proposed June 2021 Court Order.
The Ann Arbor Mayor's Law firm, which he is a part-owner, is part of this legal team for the public via Scio Twp hire. The Mayor has vigorously and consistently pushed for CJ negotiations over the past few years and not supported EPA Superfund. He has said he is decoupled from the case but as an owner of the law firm that does not seem plausible. He should recuse himself on voting on these CJs.
Rockworks analysis and other past analysis shows the Gelman/Danaher Plume may surface in the West Park area due to geological layers from the glacial action being exposed as the groundwater flow move toward the Huron River east of Argo Pond.
It is the ACWG and CARD's position that the EPA Superfund route is the most effective option the community has, given the fights Gelman/Pall/Donaher, a $140B company, has put up to avoid an effective cleanup for over 40 years.
All local governments and most NGOs, including CARD, ACWG, SC HVG, have voted for the Governor to Petition EPA for Superfund Status for Gelman/Danaher Toxic Dump Site Plume.
With over 100 Public Comments in public comment sessions, there have been no supporters of the June 2021 Court Order.
40 years of mismanagement, deaths, illness, property and wells damaged, valuable pristine groundwater polluted is enough.
Mayor Taylor should recuse from voting on the current Proposed CJ, he is a Partner/Owner of the law firm making $100's thousands on the ill-conceived CJ legal effort, in lieu of a Gelman/Danaher fully funded Superfund plan and full Cleanup.
ACWG and CARD have stated and Dan Bicknell has proposed a plan for permanent NSG wells back in 2016 that EGLE has not chosen to implement and they have not forced Gelman/Danaher to do it either.
The CARD Group has moved to virtual meetings like others starting in May for an undermined length of time, see details at the Washtenaw County CARD site.
Links:
RockWorks Geological Gelman Analysis, Very Long PDF File on City Website
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 Lucus at Dioxane.Org and WEMU News Program GreenRoom
Washtenaw County CARD Site
See ACWG site pages EPA Superfund Option Details from CARD/ACWG.
Click here to view and/or sign in support of Superfund Designation
City of Ann Arbor Proposing to Have Developer Build Residential At 415 W. Washington in the Floodplain And Just Up to the Floodway and Likely in the Floodway (FEMA Shown to be “Low Balling” Flood Maps by 30%)
415 W Washington almost entirely in the floodplain/floodway, FEMA City of Ann Arbor Floodplain Map, Floodway in Blue, Floodplain in Green
(FEMA, City of Ann Arbor, Annotations in Red by ACWG, Rt Clk for Larger)
100 year (1% chance) First Street Flood Maps for 415 shown below
4 1/2 Feet to Near 8 Feet of Floodwater
100 year (1% chance) First Street Flood Maps for 415 shown below
Near 10 Feet of Floodwater
First Street Flood Maps for 415 W. Washington
(Rt Clk for larger images)
South East Michigan is now getting 500 and 1,000 year rains on a regular basis.
Local, State and Federal funds will not be available for this site due to its location in the floodway and floodplain.
This for good and obvious reason.
One of the most dangerous sites in the City of Ann Arbor for housing or building due to major flood hazard.
Best use of this site is for the Allen's Creek Greenway/Tree Line pocket park and green trail.
The ACWG proposed since 1998, and included in the MDEQ adopted Watershed Management Plan 2001, an Allen's Creek Greenway, the city included a Greenway in 1980 City Master Plan.
In the 1968 flood this site and main building were in many feet of floodwater trapping those attending a watershed meeting (of all things) from the drain office, city staff and interested residents.
Residents in Northern Ohio in recent years were killed trying to get cars out of parking areas in the floodplain, under their apartments/condos, in a flood, parking is proposed in the floodplain at 415.
With FEMA's poor floodplain maps this building will likely be in the real floodway not just many 10's of feet into the floodplain.
ACWG helped stop the city building the Homeless Shelter in the floodway, losing $1M tax dollars in a failed plan in the floodway.
The Homeless Shelter was still built in the Floodplain with emergency exits into the Floodway!
President Obama virtually forbid using federal funds for building in the 100-year (1% chance) floodplain and virtually forbid the use of federal funds for building any critical structures in the 500-year (.2% chance) floodplain due to Global Warming effects causing more intense rain events.
Recent credible reports have stated that FEMA "Low Balls" floodplain maps by up to 33% across the country due to reduced funding and political pressure.
City staff has commented in public meetings that FEMA floodplain maps are very poorly calibrated flood maps and lack real data to guide them.
Y site across the street is not accurately included in flood hazard mapping with fencing and obstructions across virtually the entire site acting as a huge dam for floodwaters, in the middle of the floodway, flowing to the river. ACWG strongly petitioned the MDEQ to stop the Y building and then the Y fencing but was not successful.
Smith Group has commented in public meeting recently that the 2006 Y would never get approved today, and this group helped design the building in the floodway.
Y lost the required FEMA Freeboard (safety zone) in 1.5 years after built-in a FEMA Letter of Map Revision (LoMR), and is out of state floodplain floodway compliance.
Y has regular flooding evacuation drills and worries about flood hazard according to a reliable inside source.
As we asked before and FOIA'ed the DDA - we would like to see the FTCH Study: The DDA's FTCH $1/4 to $1/2M budgeted consultants study of the watershed, just upstream of this site. should be made available to the public. The ACWG FOIA'ed the study but was just given a copy of the raw data and model run data used to do models but the report was never offered. FTCH said the DDA had to agree to make it available which they never did. These results were said to ACWG to be 'Very Surprising' by FTCH.
$1B plan for Climate Change!!! "But let's build in the floodplain and likely floodway".
Dr. Missy Stults city's Sustainability and Innovations Manager states at A2Zero Kickoff Meeting on Nov 11th 2020 when asked by the ACWG: "No Building In Floodplain" Period. No discussion, no questions, just NO.
TaxBase is a huge buzz word with many in the Planning Commission and some on the council to justify any new development.
But a critical Tax Base is the existing Tax Base you don't "Throw Under The Bus. Into the Floodplain".
The Old West Side is one of the most valuable areas in the city and has hundreds of homes that have been paying taxes close to a hundred years, and will pay property tax for decades longer, and many will be at risk if the floodplain and floodway are blocked with new developments greatly threatening existing Tax Base.
Floods recently in the lower Michigan area include 500 year rain with 3 deaths and $2B in losses, 500 year rains that washed out 13 bridges, and back to back 100 year rains.
Mayor Taylor said recently that Ann Arbor has personally experienced the effects of climate change, referencing a one-degree temperature increase during the last few years as well as a more than 45 percent increase in precipitation within the last 50 years.
Follow Adopted goals of the 2007 Flood Hazard Mitigation Plan, no building in the floodplain:
We should follow the Long-Past Adopted goals of the 2007 Flood Hazard Mitigation Plan the ACWG contributed to:
"Public acquisition and management of flood-prone properties. Permanent relocation of flood-prone structures to areas outside the floodplain. Establish clear and consistent government policy for public-owned land in the floodplain aimed at preventing public buildings in the floodplain. Create Allen['s] Creek Greenway in the floodplain area. Regular data collection and modeling to update flood hazard maps Decrease Flood Insurance Rates by meeting FEMA required flood hazard mitigation recommendations." (bold by us)
National Weather Service (NWS) New Normal - 12" Flooding Rains: 'Heavy rain accompanied the thunderstorms with the hardest-hit areas across portions of Manistee, Mason, and Lake counties in northwest lower Michigan on July 20, 2019.' : NWS
12" rain in 24 hours caused flooding and severe erosion in the area. These types of historic rains are the new normal for Michigan and other parts of the nation, the 1,000-year June 2018 rain in the MI UP and 10,000-year April 2016 “Tax Day” rain in Houston for example.
“Increasing precipitation, especially heavy rain events, has increased the overall flood risk,” according to the most recent National Climate Assessment.
This site best and most valuable use is clearly to be part of the Tree Line Greenway, Allen's Creek Greenway.
Here is as Association of State Floodplain Managers (ASFPM) logo (on left below) used on City Official Planning Documents yet ASFPM cartoon (on right) makes fun of communities building in the Floodplain, like not so smart Ann Arbor!:
Links:
https://www.citylab.com/newsletter-editions/2019/07/maplab-hidden-risks-flood-maps/595126/
City of Ann Arbor Floodplain Maps: https://www2.a2gov.org/GIS/MapAnnArbor/Floodplain/
Association of State Floodplain Managers (ASFPM): Floods.Org
The Ann Arbor Mayor and His Supporters Proposed to Switch Ann Arbor Drinking Water Over To YCUA Water (GLWA) At Great Cost and Decreased Quality, and Huge Increase in Energy Use to Pump To Ann Arbor
Just Upstream of One of Two Intakes for GLWA Water Source for YCUA and Potentially Ann Arbor
In the Most Polluted Zip Code In Michigan, Zug Island and GLWA Sewage Treatment Plant
(Google Maps, Annotation in Red ACWG, Rt Clk for Larger)
At public City Council Working Session last week Mayor Taylor and his supports proposed switching from Local Ann Arbor Treated Drinking Water from Barton Pond to Ypsilanti Community Utility Authority (YCUA) / Great Lakes Water Authority (GLWA) which is much more expensive and lower quality.
Vince Caruso's ACWG written Comments to City Council:
"I agree with Dr. Rita Loch-Caruso and Dan Bicknell's arguments and statements not to pursue GLWA water for Ann Arbor.
City of Ann Arbor has done a great job providing clean drinking water to the city and area, to city staff and our credit.
I also agree with Black and Veatch Consultant's 2015 Report and the city staff recent report not to pursue GLWA.
Also, the outrageous unnecessary amount of energy and cost to pump the much lower quality water to Ann Arbor, the AA $1B A2ZERO plan I support, and I thought you support, is being egregiously ignored in this instance."
Dr. Rita Loch-Caruso (Emerita Professor of Toxicology from the University of Michigan; Founding Member of CARD and ACWG, and City of Ann Arbor's Environmental Commission) commented at the Council Work Session on why we should not switch, water quality issues at the intake of the GLWA for YCUA:
"Ann Arbor Drinking Water – City Council Working Session Sept 13, 2021
Submitted by Rita Loch-Caruso, 556 Glendale Circle, Ann Arbor.
I have approximately 40 years of experience as a toxicologist, recently retired as Emerita Professor of Toxicology from the University of Michigan
I strongly advocate for continuing Ann Arbor’s current Water Treatment Facility and argue that we do not need to consider further a proposal to switch our water service to the Great Lakes Water Authority.
The Detroit River is not a preferred source of drinking water.
The Detroit River would be the source of water for Ann Arbor via the Great Lakes Water Authority, originating from the Fighting Island and Belle Isle intakes.
The Fighting Island intake in the Detroit River is a short 2-3 miles downstream of the Rouge River outflow to the Detroit River just south of Zug Island, a heavily polluted industrial site. The Rouge River courses through zip code 48217 just before joining the Detroit River. This zip code is cited as the most polluted ZIP code in Michigan, home to the huge 250-acre Marathon Refinery, a coal-fired power plant, a Great Lakes Water Authority wastewater treatment plant, and dozens of industries.
The Belle Isle intake is where Lake St. Claire drains into the Detroit River. This intake is downstream from Sarnia’s heavily industrialized and polluted “Chemical Valley” along the St. Claire River in Canada, which flows from Lake Huron to Lake St. Claire. Because the river has such a strong flow rate, a chemical spill in Sarnia will reach U.S. downstream water intakes in only minutes, according to a 2014 report by the NOAA Great Lakes Environmental Research Laboratory in Ann Arbor. Retrospectively, U.S. officials documented at least 700 chemical spills that happened in Sarnia between 1986 and 2002. Moreover, there are about 40 pipelines in the river that carry oil, natural gas, and other hazardous materials.
The Lake St. Claire, Detroit River and Rouge River sediments are heavily contaminated with metals, cancer-causing petroleum by-products, forever chemicals like PCBs, and more
The Detroit River, with water intakes downstream from highly industrialized and polluted sites, is a more highly contaminated and less secure source of drinking water for Ann Arbor compared to the Huron River intake in Barton Pond.
Chlorination and Disinfection By-Products will be higher in Water from the Great Lakes Water Authority
Chlorine and chloramine are common treatments to disinfect water.
The farther the finished water has to travel after leaving the water treatment plant, the higher the concentration of chlorine or chloramine needed to control bacteria and other pathogens.
Disinfection by-products are formed when chlorine or bromine react with naturally occurring organic matter (e.g., plant debris) to create many (>700) water disinfection by-products. Only ~80 water disinfection by-products have been evaluated for toxicity, and several have known carcinogenic, mutagenic, reproductive and developmental toxicity.
In water from the Great Lakes Water Authority, Ann Arbor will be at the end of the line with the longest travel time in pipes – requiring more chlorination and the most opportunity for forming harmful disinfection by-products.
In summary: 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 chlorination."
Links:
Ypsilanti Community Utility Authority (YCUA)
Great Lakes Water Authority (GLWA)
August 2021 - No Meeting this month due to COVID-19 Pandemic Cautions
No Watershed Issues of Interest and Updates.
No meeting due to vacation and travel schedules.
July 2021 - No Meeting this month due to COVID-19 Pandemic Cautions
Watershed Issues of Interest and Updates:
Danaher/Pall/Gelman 1,4-Dioxane Toxic Dump Site Plume - EPA Superfund Update; Consent Agreement Is Still A Mess, NSG Tests and Cleanup Long Overdue, County Staff Challenge Tests Needed and Schools At Risk; Over $1M Tax Payer Dollars Spent On Lawyers!
Zoom Hosted by Roger Rayle; screenshot of YouTube view (click image to view)
(Roger Rayle; Clk for larger)
EPA is currently doing well testing and studying geological aspects of the Gelman/Danaher Toxic Waste Plume as part of the effort to likely begin a EPA Superfund process for the site in the next year or two. Governor Whitmer Has Sent a Letter To EPA in Support (Concurrence Letter) of an EPA Superfund for the Gelman/Danaher Toxic Dump Site and Plume in April 2021.
US EPA has set up a website for the Gelman/Danaher Toxic Dump Site and Plume with basic descriptions of the site and status.
At the July Coalition for the Remediation of Dioxane (CARD) meeting, after issuing another request, EGLE and local officials agreed to set a date to investigate potential 1,4 dioxane exposure because of detection and increasing levels being found at and near West Park. Potential exposure could occur from vapor intrusion into buildings and other exposures from outside contact with contaminated groundwater seeping to the surface. See details below.
With 49 ppb at West Park EIGHT MONTHS since the last tests, we said, is way too long to wait. Additional tests are now planned for this summer.
Very Detailed Gelman/Danaher Plume Geological Study Published:
EGLE has contracted with RockWorks to report on very detailed geological aspects of the Gelman/Danaher contamination. This recently published report is on the city web site. Lots of details, charts and maps which will take some time to study this very long PDF file.
For some reason, the RockWorks report was not communicated to CARD or the public in a timely manner.
4th Consent Judgement (CJ) Agreement Mess:
Still No Consent amongst the litigants yet is suggested as such in the court with the 4th Consent Judgement actions.
Judge makes confusing comments and statements that are confusing even Ann Arbor experienced lawyers on CARD. Not clear where this court is going. Gelman/Danaher very happy with the confusion, delays are a win for them. The public has spent over $1 Million on this 4 CJ with little to show for the effort. Not clear what is the direction or intent of this process other than to delay and get Lawyers rich off Tax Payers doing a very poor job.
Million Dollar Legal Service Unacceptable:
Poor service to the public, for example, the public was left to determine the many Outrageous GOCHAS in the very complex proposed 4CJ.
The Ann Arbor Mayor's Law firm, which he is a part-owner, is part of this legal team for the public via Scio Twp hire. The Mayor has vigorously and consistently pushed for CJ negotiations over the past few years and not supported EPA Superfund. He has said he is decoupled from the case but as an owner of the law firm that does not seem plausible. He should recuse himself on voting on these CJs.
Screening levels for 1,4 dioxane were 29 ppb originally set by EGLE and changed to 1,900 ppb, analysis by a CARD member and now comments from EGLE indicates 100 ppb would be appropriate with some assumptions.
The past analysis shows the Gelman/Danaher Plume may surface in the West Park area due to geological layers from the glacial action being exposed as the groundwater flow move toward the Huron River east of Argo Pond.
It is the ACWG and CARD's position that the EPA Superfund route is the most effective option the community has, given the fights Gelman/Pall/Donaher, a $140B company, has put up to avoid an effective cleanup for over 40 years.
All local governments and most NGOs, including CARD, ACWG, SC HVG, have voted for the Governor to Petition EPA for Superfund Status for Gelman/Danaher Toxic Dump Site Plume.
With over 100 Public Comments in public comment sessions, there have been no supporters of the 4th CJ.
40 years of diddling with Gelman is way too long, and the community, the state and the environment deserve better. The State and local governments can not deal with this, this is very apparent now as it was 20 years ago.
40 years of mismanagement, deaths, illness, property and wells damaged, valuable pristine groundwater polluted is enough.
Mayor Taylor should recuse from voting on the current Proposed CJ, he is a Partner/Owner of the law firm making $100's thousands on the ill-conceived CJ legal effort, in lieu of a Gelman/Danaher fully funded Superfund plan and full Cleanup.
ACWG and CARD have stated and Dan Bicknell has proposed a plan for permanent NSG wells back in 2016 that EGLE has not chosen to implement and they have not forced Gelman/Danaher to do it either.
The CARD Group has moved to virtual meetings like others starting in May for an undermined length of time, see details at the Washtenaw County CARD site.
Links:
July 2021 Regular Coalition for the Remediation of Dioxane (CARD) Group Meeting Video - Taped by Roger Rayle, Chair CARD
RockWorks Geological Gelman Analysis, Very Long PDF File on City Website
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 Lucus at Dioxane.Org and WEMU News Program GreenRoom
Washtenaw County CARD Site
See ACWG site pages EPA Superfund Option Details from CARD/ACWG.
Click here to view and/or sign in support of Superfund Designation
Why Has EGLE and the City Council Majority Not Supported Permanent Near-Surface Shallow Groundwater (NSG) Tests With All the Data Pointing to This As A Major Issue For Ann Arbor's West Side, and May Also an Issue In Scio Twp NSG Locations
Locations of EGLE 10-9-2020 NSG Tests and Schools
(West Part is in the middle of the image)
(ACWG, Rt Clk for larger)
We need these wells installed by Gelman/Danaher and monitored to understand the movement of this plume.
Homes, school(s) and businesses exposures to 1,4 Dioxane is not an issue we should be waiting for exposures to happen before we act.
Homes, school(s) and businesses should not be the ' Canary in the Coal Mine'.
The city contracted basement tests but chose not to consult with CARD or ACWG on this. They placed the tests to far west based on previous data from Near-Surface Shallow Groundwater (NSG) tests. More public funds are wasted.
At the May CARD meeting, EGLE and local officials agreed to investigate potential 1,4 dioxane exposure because of detection and increasing levels being found at and near West Park. Potential exposure could occur from vapor intrusion into buildings and other exposures from outside contact with contaminated groundwater seeping to the surface.
EGLE found 49 ppb in West Park 8 months ago in its last test. EGLE tested upstream of West Park in the Allen's Creek drain and found no 1,4 Dioxane. It would be logical to say the tests in West Park are near-surface shallow groundwater (NSG) entering the Allen's Creek drain very near or in West Park. The Allen's Creek drain in West Park has very high flows even in drought conditions, very likely to be groundwater. The 8th St Allen's Creek drain also has high flows even in drought conditions and is also very likely to be NSG and is also contaminated with 1,4 dioxane.
This NSG is contaminated and very likely to be Gelman/Danaher 1.4 dioxane contaminated as shown below in the geological map produced by Gelman/Pall/Danaher showing the pollution in the NSG coming to the surface in the West Park area.
ACWG and CARD have been requesting very simple tests since 2016, when EGLE and Gelman refused to do a meaningful test program, as reported here in 2016 and posted on the website.
ACWG and CARD have stated and Dan Bicknell has proposed a plan for permanent NSG wells back in 2016 (as ACWG has sent out and posted on our site) that EGLE has not chosen to implement and they have not forced Gelman/Danaher to do it either.
Concern that the seeps, groundwater entering lower levels of schools, kids getting wet in the playground from seep flows and taking this into the school after recess could lead to exposures.
Like in a home's basement, Vapor Intrusion (VI) into a school lower levels can be at risk with high enough concentrations of contaminated Near Surface Shallow Groundwater next to the structure.
It would seem that children's exposures would a concern as they may be at risk at much lower values compared to adult exposures.
The MS4 Violation in Allen's Creek Going on 3 Years and still not even started to be fixed:
The CARD Group has 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 with the illicit 1,4 Dioxane pollution levels in the drain continuously going up. The ACWG pushed for and also supports the CARD resolution. No resolution of this Federal MS4 violation reported at the last CARD meeting about this violation.
The Water Resources Commissioners Office (WRCO) has notified Gelman that they are in violation of the Federal MS4 Permit in a statutory Freshwater Runoff (Stormwater) Drain. WRCO is the delegated authority by EGLE and the Federal Government to manage MS4 permits in the County. No word on what Gelman/Danaher will do about this over 3-year-old Federal MS4 Violation.
Screening levels for 1,4 dioxane was 29 ppb originally set by EGLE, analysis by a CARD member and comments from EGLE indicates 100 ppb would be appropriate with some assumptions.
Lack of NSG Monitoring Wells is a real concern for West Ann Arbor.
The only "shallow monitoring well" (NSG) in the area was in Maple Village MW-87s is now gone due to development, never replaced. Previous credible reports of the wells elevation were in error and previously reported here.
Elevations are generally: West Park area is at 816', Mack Open School at 845', Slauson School at 821'
Ann Arbor Sanitary Sewer Overflow 25,000-gallon July 1
Another SS overflow of 25,000 gallons on July 1 after a rain event. Flows entered wooded area near Hogback Road in Ann Arbor.
“ 'Upon review of the rain data from the storm event that occurred over June 25 and 26, 2021, staff engineers determined that there were several isolated areas just upstream of this sewer overflow that received rainfall of a duration and intensity equivalent to a 1% chance rainfall event,” the city stated in a news release, noting that’s known as a 100-year storm.' ": MLive
These new 100-year storms are getting more common every year due to Global Warming effects. 'Business as Usual' is not an option.
Link:
SS Overflow 25,000-gallon sewage overflow reported in Ann Arbor after ‘immense rainfall’ - mlive.com
Armen Cleaners at 630 S. Ashley St. in the Old West Side Polluted Ground for Decades Finally Gets Partial Cleanup, Nearby Residents Exposed For Years
Armen Cleaners Site
(Google Street View; Clk for Larger)
The ACWG, county officials and others tried to get this cleaning solvent ground contamination cleaned up for decades. The city dragged its feet ignoring the danger to the residents and the environment.
The city at one point, after many years of fending off charges of nonconcern, said they would buy the property and have it cleaned up. The assessment of the property value dragged on for years and the purchase seemed to never happen.
Residents were exposed even when it was known that the cleaning fluids were leaking into the neighborhood.
This has taken way too long to deal with and is not Environmental Stewardship by any Stretch.
Ryan Stanton, MLive: " Armen Cleaners has stood at 630 S. Ashley St. in the Old West Side for decades, but it now faces the wrecking ball so the state can take action to remove contaminated soil, a problem first discovered 36 years ago, officials said."
"Improper handling of waste by the dry cleaning business was first documented in 1985 when releases of PCE to soil and groundwater were discovered, and throughout the 1990s, 2000s and 2010s there were several additional investigations to define the extent of the problem, according to EGLE."
The cleaning fluids from the cleaners are highly toxic and a common and well-understood dangerous Vapor Intrusion exposure in homes and businesses, as well as a very common groundwater contaminant associated with these kinds of sites.
The city dragging its feet on the Gelman Plume migration to the surface on the west side is another example of a lack of Environmental Stewardship in our city government. The city has paid for a basement test study west of West Park but is being done in the wrong locations because they chose not to discuss it with CARD or ACWG members who would have pushed for a much more valid study.
Link:
https://www.mlive.com/news/ann-arbor/2021/07/ann-arbor-dry-cleaner-faces-wrecking-ball-under-pollution-cleanup-plan.html
Whitmer announces historic $150 million investment in local parks and trails
Kalamazoo Arcadia Creek Greenway, City 'Gem'
(Kalamazoo DDA; Rt Clk for Larger)
Kalamazoo took a blighted part of the city along the Arcadia Creek and created a Gem (over 20 years ago): the Arcadia Creek Greenway. It greatly reduces flooding, is a green park gathering space and is a large performance and fair venue in the downtown. The DDA in Kalamazoo spearheaded this effort.
"LANSING, Mich. - Gov. Gretchen Whitmer today announced a historic investment in community parks and recreation facilities, proposing $150 million in federal relief dollars from President Biden’s American Rescue Plan be dedicated to addressing critical needs in local park systems. This investment will create good-paying, blue-collar jobs across the state as we jumpstart our economy and get Michigan back to work.
Whitmer announced the proposal at the Idema Explorers Trail in Ottawa County, an example of a recreation property that could benefit from the new funding. The proposed investment would be administered as a grant program by the Michigan Department of Natural Resources and would support the economies, health and recovery of communities across the state."
Last month, Whitmer announced a similar proposal to invest $250 million of American Rescue Plan funding in parks and trails managed by the State of Michigan.
Ann Arbor should take advantage of these funds to move more aggressively on the Allen's Creek Greenway/Tree Line which has been promoted by the ACWG and other Citizens Groups for over 20 years. Other communities have had tremendous results with Greenways in urban settings.
The Center of the City Park should receive support for the voter-approved park, a vote over 3 years ago now. The voice of the people should not be ignored, and a central park for Ann Arbor is sorely lacking in what some call a Green City with very little or no green in the city center or gathering space for residents and visitors.
“These two new investment programs, totaling $400 million, mark a once-in-a-generation chance to improve quality of life for our residents, support local economies and bring people back to Michigan as the state continues its recovery from the effects of the pandemic,” Whitmer said. “These investments will ensure our children and grandchildren continue to enjoy the rejuvenating benefits of natural beauty and outdoor spaces so prized by Michiganders. I look forward to working with the Legislature to secure this investment for our communities.”
Link: More Details Here of Whitmers Comments
The University Of Michigan Medical Creates an Artificial Woodland Seen, Recharge Room, to Help Calm and Relax Medical Staff Dealing With Covid Surges, While Ann Arbor Cuts Down More Trees; U of M: Walk in the Woods May Be As Good As Antidepressants, Without Side Effects
Recharge Room: A place of calm in the middle of it all,
in the Frankel Cardiovascular Center, Med Inn and C.S. Mott Children’s Hospital.
(U of M; Rt Clk for Larger)
"Studio Elsewhere is a company that creates immersive environments to improve cognitive performance and address anxiety by creating rooms that stimulate the senses through light, sounds and scents.
The rooms ... are intended to induce short-term decreases in blood pressure, stress hormones and heart rate through elements like dimmed lighting, relaxing music, abundant greenery, socially-distanced, cozy seating and tranquil imagery projected on a video wall. Future plans include featuring aromatherapy in the rooms." U of M.
Green spaces, especially with trees, is a real benefit to a community for calming and relaxing effects.
U of M, with others, conducted a study with students walking in the Arboretum vs walking on streets on campus and in town showed significant reductions in stress indicators, as reported here in the past on ACWG. They found taking a walk in the woods seemed to be as effective as anti-depressant drugs, without the nasty side effects, for mood elevation. This would be a very cost-effective way to improve the community in many ways.
CityLab: "In recent years, study after study has found that living in neighborhoods with abundant green space is linked to positive health outcomes. These include better heart health, stronger cognitive development, and greater overall longevity. No wonder these areas are also linked to lower levels of Medicare spending.
But when it comes to promoting human health, not all green spaces are created equal. That’s the conclusion of new Australian research, which finds higher levels of wellness in areas marked by one particular manifestation of the natural world: leafy trees." This study with almost 50,000 subjects. (bold by us)
Long past time to follow the GreenBelt mandate 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'.
Stop promoting the misconception that the Greenbelt funds can not be used in the city of Ann Arbor.
Links
CityLab: https://www.citylab.com/environment/2019/07/urban-tree-canopy-green-space-wellbeing-research/595060/
June 2021 - No Meeting this month due to COVID-19 Pandemic Cautions
Watershed Issues of Interest and Updates:
EPA Now Has a New Gelman EPA Superfund Website, Since Governor Whitmer Has Sent a Letter To EPA in Support (Concurrence Letter) of an EPA SUPERFUND for the Gelman/Danaher Toxic Dump Site and Plume
US EPA has set up a website for the Gelman/Danaher Toxic Dump Site and Plume with basic descriptions of the site and status.
From the EPA Gelman Site:
EPA Update:
On April 12, 2021 EGLE requested that EPA reinstate the evaluation process needed to consider the Gelman Sciences site for inclusion on the Superfund National Priorities List.
Previously, in 2016, EPA received a petition from Ann Arbor Charter Township, Scio Township and Sierra Club to evaluate the site for inclusion on the NPL. In response to that petition, and in coordination with the state, EPA conducted a preliminary assessment to assess site data and to determine data gaps.
Another preliminary assessment is not needed, and EPA will work with EGLE to continue evaluating the site for potential NPL listing.
This evaluation process is expected to take an additional two to three years, at which point the site, if determined eligible, will be proposed to the NPL.
The public will then be invited to comment on the NPL proposal, and, if determined appropriate following the public comment period, the site will be finalized on the NPL.
Gelman Science Frequently Asked Questions
A full evaluation for Superfund will start. It was said by EPA officials that this site would very likely become a Superfund site with Gelman/Danaher as the Responsible Parties (RPs) responsible for the cost of the evaluation and cleanup with support from the Governor.
Here is a link to the ACWG page, on this site, with EPA Superfund Option Details with Flow Chart by Dan Bicknell GEA LLC, including a detailed flow chart of the process to Superfund status and the difference between MDEQ/EGLE and EPA Superfund Elements from 2016.
The initial EPA evaluation of the Gelman site scored very high, well over the required value, which indicates a likely listing on the EPA Federal Superfund Cleanup listing. The initial evaluation did not include many environmentally serious conditions that will heighten the scoring of this site for Superfund listing.
US EPA Superfund will have much stricter environmental cleanup standards than Michigan's very weak Part 201 Environmental standards. EPA will force Gelman/Danaher to pay for the cleanup and any losses to residents due to the Gelman Plume.
If during the full evaluation EPA finds critical dangerous environmental conditions they may order immediate mitigation and cleanup to protect the life and health of the community.
Danaher/Pall/Gelman 1,4-Dioxane Toxic Dump Site Plume - Consent Agreement A Mess, NSG Tests and Cleanup Long Overdue, County Staff Challange Tests Needed and Schools At Risk; Over $1M Tax Payer Dollars Spent!
Zoom Hosted by Roger Rayle; screenshot of YouTube view (click image to view)
(Roger Rayle; Clk for larger)
At the June Coalition for the Remediation of Dioxane (CARD) meeting, after issuing another request, EGLE and local officials agreed to set a date to investigate potential 1,4 dioxane exposure because of detection and increasing levels being found near Ann Arbor Open/Mack and Slauson Schools in West Park 1/2 block away. Potential exposure could occur from vapor intrusion into buildings and other exposures from outside contact with contaminated groundwater seeping to the surface. See details below.
With 49 ppb at West Park EIGHT MONTHS since the last tests, we said, is way too long to wait.
4th Consent Judgement (CJ) Agreement Mess:
No Consent amongst the litigants yet is suggested as such in the court.
Judge makes confusing comments and statements. Not clear where this court is going. Gelman/Danaher very happy with the confusion, delays are a win for them. The public has spent over $1 Million on this 4 CJ with little to show for the effort. Not clear what is the direction or intent of this process other than to delay and get Lawyers rich off Tax Payers doing a very poor job.
Million Dollar Legal Service Unacceptable:
Poor service to the public, for example, the public was left to determine the many Outrageous GOCHAS in the very complex proposed 4CJ.
Some egregious examples of lack of direction by the publicly hired $1M legal staff:
500 ppb! was a proposed cleanup level, totally unacceptable, EPA would likely be 0.3 ppb
The public would be Forbidden and Prevented to ask for EPA Assistance In Perpetuity!, totally unacceptable
First Sisters Lake would receive contaminated effluent from the treatment process polluting a pristine Ann Arbor lake and potential flooding in the nearby homes, totally unacceptable
The Ann Arbor Mayor's Law firm, which he is a part-owner, is part of this legal team for the public via Scio Twp hire. The Mayor has vigorously and consistently pushed for CJ negotiations over the past few years and not supported EPA Superfund. He has said he is decoupled from the case but as an owner of the law firm that does not seem plausible. He should recuse himself on voting on these CJs.
Screening levels for 1,4 dioxane were 29 ppb originally set by EGLE, analysis by a CARD member and now comments from EGLE indicates 100 ppb would be appropriate with some assumptions.
The past analysis shows the Gelman/Danaher Plume may surface in the West Park area due to geological layers from the glacial action being exposed as the groundwater flow move toward the Huron River east of Argo Pond.
It is the ACWG and CARD's position that the EPA Superfund route is the most effective option the community has, given the fights Gelman/Pall/Donaher, a $140B company, has put up to avoid an effective cleanup for over 40 years.
All local governments and most NGOs, including CARD, ACWG, SC HVG, have voted for the Governor to Petition EPA for Superfund Status for Gelman/Danaher Toxic Dump Site Plume.
With over 100 Public Comments in public comment sessions, there have been no supporters of the 4th CJ.
40 years of diddling with Gelman is way too long, and the community, the state and the environment deserve better. The State and local governments can not deal with this, this is very apparent now as it was 20 years ago.
40 years of mismanagement, deaths, illness, property and wells damaged, valuable pristine groundwater polluted is enough.
Mayor Taylor should recuse from voting on the current Proposed CJ, he is a Partner/Owner of the law firm making $100's thousands on the ill-conceived CJ legal effort, in lieu of a Gelman/Danaher fully funded Superfund plan and full Cleanup.
ACWG and CARD have stated and Dan Bicknell has proposed a plan for permanent NSG wells back in 2016 that EGLE has not chosen to implement and they have not forced Gelman/Danaher to do it either.
The CARD Group has moved to virtual meetings like others starting in May for an undermined length of time, see details at the Washtenaw County CARD site.
Links:
June 2021 Regular Coalition for the Remediation of Dioxane (CARD) Group Meeting Video - Taped by Roger Rayle, Chair CARD
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 Lucus at Dioxane.Org and WEMU News Program GreenRoom
Washtenaw County CARD Site
See ACWG site pages EPA Superfund Option Details from CARD/ACWG.
Click here to view and/or sign in support of Superfund Designation
After ACWG and CARD Request Additional NSG Tests, EGLE and Local Officials Now Agree to Do More NSG Testing Soon to Investigate Ann Arbor Open/Mack and Slauson Middle School Properties for 1,4 Dioxane, with Detection and Increasing Levels Found Near West Side Schools
At the May CARD meeting, EGLE and local officials agreed to investigate potential 1,4 dioxane exposure because of detection and increasing levels being found near Ann Arbor Open/Mack and Slauson Schools 1/2 block away at West Park. Potential exposure could occur from vapor intrusion into buildings and other exposures from outside contact with contaminated groundwater seeping to the surface.
EGLE found 49 ppb in West Park 8 months ago in its last test. EGLE tested upstream of West Park in the Allen's Creek drain and found no 1,4 Dioxane. It would be logical to say the tests in West Park are near-surface shallow groundwater (NSG) entering the Allen's Creek drain very near or in West Park. The Allen's Creek drain in West Park has very high flows even in drought conditions, very likely to be groundwater. The 8th St Allen's Creek drain also has high flows even in drought conditions and is also very likely to be NSG and is also contaminated with 1,4 dioxane.
This NSG is contaminated and very likely to be Gelman/Danaher 1.4 dioxane contaminated as shown below in the geological map produced by Gelman/Pall/Danaher showing the pollution in the NSG coming to the surface in the West Park area.
The CARD Group has lobbied for VI for 1,4 Dioxane and MDEQ/EGLE included it as a special case for VI regulations.
Mack School is 1/2 blocks from West Park and has been reported to have seeps (like in many areas on the West Side) on the school grounds. Slauson Middle School has 1,4 dioxane levels in the near-surface shallow groundwater (NSG) at the 8th St street drain just south of the school grounds at 11 ppb.
More testing of the school grounds needs to be done to determine the potential exposures.
ACWG and CARD have been requesting simple tests since 2016, when EGLE and Gelman refused to do a meaningful test program, as reported here in 2016.
ACWG and CARD have stated and Dan Bicknell has proposed a plan for permanent NSG wells back in 2016 (as ACWG has sent out and posted on our site) that EGLE has not chosen to implement and they have not forced Gelman/Danaher to do it either.
Concern that the seeps, groundwater entering lower levels of schools, kids getting wet in the playground from seep flows and taking this into the school after recess could lead to exposures.
Like a home's basement, Vapor Intrusion (VI) into school lower levels can be at risk with high enough concentrations of contaminated Near Surface Shallow Groundwater next to the structure.
The MS4 Violation in Allen's Creek Going on 3 Years and still not even started to be fixed:
The CARD Group has 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 with the illicit 1,4 Dioxane pollution levels in the drain continuously going up. The ACWG pushed for and also supports the CARD resolution. No resolution of this Federal MS4 violation reported at the last CARD meeting about this violation.
The Water Resources Commissioners Office (WRCO) has notified Gelman that they are in violation of the Federal MS4 Permit in a statutory Freshwater Runoff (Stormwater) Drain. WRCO is the delegated authority by EGLE and the Federal Government to manage MS4 permits in the County. No word on what Gelman/Danaher will do about this over 3-year-old Federal MS4 Violation.
Recent data from EGLE Near-Surface Shallow Groundwater test done 10-9-20 sent out on 11-23-20 indicates that Allen's Creek stormwater on the West Side has increased dioxane values from the 2019 sampling.
West Park SW is at 49 ppb up from 22 ppb in 2019,
Chapin St. is at 28 ppb up from 9.1 ppb in 2019,
Eight St. next to Slawson Middle School is at 11 ppb up from 1 ppb in 2019.
Screening levels for 1,4 dioxane was 29 ppb originally set by EGLE, analysis by a CARD member and comments from EGLE indicates 100 ppb would be appropriate with some assumptions.
Lack of NSG Monitoring Wells is a real concern for West Ann Arbor.
The only "shallow monitoring well" (NSG) in the area was in Maple Village MW-87s is now gone due to development, never replaced, with readings 400-1,500 ppb at 843' elevation as mentioned by Roger. Vet's park has been 1,000 ppb in recent years.
Elevations are generally: West Park area is at 816', Mack Open School at 845', Slauson School at 821', all at or below MW-87s
Links:
Michigan MS4 Regulation
June 2021 Regular Coalition for Action On the Remediation of Dioxane (CARD) Group Meeting Video
Michigan Radio: "Michigan’s climate-ready future: wetland parks, less cement, roomy shores".
Ann Arbor Voter-Approved Greenbelt Millage Ignored to Support Developers
West Park Rebuild Plan, ACWG Played a Big Part in Getting Stormwater and Green Treatment and, Being Shovel Ready For Obama Federal Funds For Green Infrastructure Projects
Michigan Radio, part of The Great Lakes News Collaborative, story June 9, 2021:
' “We can turn back the clock, in terms of urban development,” [Sanjiv] Sinha said, transforming cities with vast acreages of paved land that no longer serve a purpose, from Detroit to Milwaukee, into “garden cities” where large urban parks double as stormwater retention ponds.
That would also help remedy the dearth of parkland in cities like Detroit, which has fewer acres of parkland per-person and spends less on parks per-person than other cities with similar population densities. And while the up-front costs of buying new land or renovating existing parks can be high, communities save big on water treatment by “treating the rain where it falls,” allowing natural filtration in the earth to strip away sediment and toxins, Sinha said.
Covering porous soil with concrete and asphalt sends rain streaming into streets, sewers and neighborhoods, where it sometimes floods homes, overtaxes infrastructure and raises water treatment costs.
Water is at once Michigan’s greatest environmental asset and its most obvious, persistent climate hazard. Scientists expect a warming globe to alter rainfall patterns in the state, bringing more intense storms like the one that flooded mid-Michigan and destroyed two dams in May of last year, leaving a $200 million repair bill. ' (bold by us)
Ann Arbor Mayor and his supporters refuse to use appropriate GreenBelt Millage inside our city for 33% of the millage for inside Ann Arbor.
Only 9% of Mileage funds have been used up to recent years in the city in violation of the voter-approved Green Belt Mileage which requires 33% to be spent in the city ( Text of Green Belt Millage City Resolution Passed by voters in the City of Ann Arbor).
The Great Lakes News Collaborative includes Bridge Michigan; Circle of Blue; Great Lakes Now at Detroit Public Television; and Michigan Radio, Michigan a NPR News Host
Link:
https://www.michiganradio.org/post/michigan-s-climate-ready-future-wetland-parks-less-cement-roomy-shores
Biden: Trump's Waters of the U.S. Rule to Be Rewritten. New Supreme Court Could Object!
The Waters of the U.S. Rule was originally written under the Obama administration to better clarify which bodies of water should be protected under the U.S. Clean Water Act.
National Public Radio (NPR.ORG) 1-20-20
Trump Administration Cuts Back Federal Protections For Streams And Wetlands
"The Environmental Protection Agency is dramatically reducing the amount of U.S. waterways that get federal protection under the Clean Water Act — a move that is welcomed by many farmers, builders and mining companies but is opposed even by the agency's own science advisers.
EPA Administrator Andrew Wheeler, who announced the repeal of an earlier Obama-era water rule in September, chose to make the long-anticipated announcement Thursday in Las Vegas, at the National Association of Home Builders International Builders' Show.
'All states have their own protections for waters within their borders, and many regulate more broadly than the federal government,' Wheeler told reporters on a conference call before the announcement."
Engineer News-Record (ENR.COM), 6-9-21
Waters of the U.S. Rule to Be Rewritten, Yet Again
https://www.enr.com/articles/51886-waters-of-the-us-rule-to-be-rewritten-yet-again
The US Army Corps of Engineers and US Environmental Protection Agency (EPA) will rewrite, yet again, the “Waters of the United States” rule. This comes after a review ordered by President Biden found that the law, revised under the Trump administration, has resulted in fewer bodies of water being protected.
The rule was originally written under the Obama administration to better clarify which bodies of water should be protected under the U.S. Clean Water Act. Under Waters of the U.S., or WOTUS, seasonal water bodies and ephemeral streams could be classified as needing federal protection. Contractor groups were opposed to WOTUS because having more water bodies under federal jurisdiction could impact construction.
Acting Assistant Secretary of the Army for Civil Works Jaime A. Pinkham made a June 9 announcement about the revisions.
Larry Liebesman, senior advisor at Dawson & Associates [said]: “Ultimately, any rule will have to stand a reasonable chance of being upheld by the Supreme Court,” he says. “With a conservative majority, any final rule that looks too much like the 2015 Obama rule will have a hard time being upheld.” (bold by us)
The President has issued[1/20/21] an executive order [13990] setting aside the 2015 rule, and ordering the USEPA and the Army [Corps of Engineers] to review the current rule, and proceed to adopt a "durable Rule" that can survive changes in administration, whilst being "fair" to "farmers" and "developers" and other stakeholders [gravel miners] inconvenienced by government regulation. Whether the natural resources are a "stakeholder" along with the human race generally is the base issue.
Henry David Thoreau wrote about the wholesale destruction of our rivers:
"Who hears the fishes when they cry?'
"Maybe we need to go down to the river bank and try to listen."
Links:
NPR: https://www.npr.org/2020/01/23/798809951/trump-administration-is-rolling-back-obama-era-protections-for-smaller-waterways
ENR: https://www.enr.com/articles/51886-waters-of-the-us-rule-to-be-rewritten-yet-again
May 2021 - No Meeting this month due to COVID-19 Pandemic Cautions
Watershed Issues of Interest and Updates:
Governor Whitmer Has Sent a Letter To EPA in Support (Concurrence Letter) of an EPA SUPERFUND for the Gelman/Danaher Toxic Dump Site and Plume!!
Michigan Request for Gelman SuperFund Status:
MLive has reported Monday, April 12:
“The Michigan Department of Environment, Great Lakes and Energy (EGLE) announced its request Monday for the Gelman dioxane plume to be added to the U.S. Environmental Protection Agency’s (EPA) Superfund National Priorities List for federal cleanup, according to a release from U.S. Rep. Debbie Dingell, D-Dearborn.”
A full evaluation will start. It was said by EPA officials that this site would very likely become a Superfund site with Gelman/Danaher as the Responsible Parties (RPs) responsible for the cost of the evaluation and cleanup.
Here is a link to the ACWG page, on this site, with EPA Superfund Option Details with Flow Chart by Dan Bicknell GEA LLC, including a detailed flow chart of the process to Superfund status and the difference between MDEQ/EGLE and EPA Superfund Elements from 2016.
The initial EPA evaluation of the Gelman site scored very high, well over the required value, which indicates a likely listing on the EPA Federal Superfund Cleanup listing. The initial evaluation did not include many environmentally serious conditions that will heighten the scoring of this site for Superfund listing.
US EPA Superfund will have much stricter environmental cleanup standards than Michigan's very weak Part 201 Environmental standards. EPA will force Gelman/Danaher to pay for the cleanup and any losses to residents due to the Gelman Plume.
If during the full evaluation EPA finds critical dangerous environmental conditions they may order immediate mitigation and cleanup to protect the life and health of the community.
The ACWG and CARD have several concerns with regard to critical dangerous environmental conditions from this toxic plume migration.
ACWG/CARD Observe EGLE and City Utility Staff Sampling NSG in West Park on 9-9-18
Currently Tests Show 49 ppb NSG, More test results soon
(ACWG, Rt Clk for larger)
ACWG's most critical issues for immediate attention by EPA, more discussion needs to occur on this:
Gelman/Danaher is in violation of Federal Regulations for MS4 in Allen's Creek and flows to Huron River for over 3 years.
Fully test and install permanent wells for near-surface shallow groundwater (NSG) in Ann Arbor and Scio Twp.
Scio Twp. drinking water well analysis and 1,4D flows stopped migration toward drinking water wells.
Flows of 1,4D toward Barton Pond analysis and 1,4D flows stopped migration toward Barton Pond
Basement exposures evaluation. The current City evaluation is not meaningful. CARD and ACWG were not consulted and does not agree with the protocol.
Basement analysis and 1,4D flows stopped migration toward basements of homes and businesses.
Worker exposures need to be investigated. Exposure to those digging or working in trenches or below ground areas could be exposed.
Investigate past drinking water exposures, some in the thousands of PPB in Scio Twp.
Investigate illegal intentional dumping of 1,4 D into Scio Twp. wetlands and other locations, which have been personally communicated to CARD and ACWG members and likely others.
Engage with the local community on the effects and concerns of the Gelman/Danaher Toxic Dump Site and Plume.
Danaher/Pall/Gelman 1,4-Dioxane Toxic Dump Site Plume - EPA/EGLE Joint Session Comments, EPA: We Are Ready to Step In as a Superfund Manager if We Are Asked by the State
Zoom Hosted by Roger Rayle; screenshot of YouTube view (click image to view)
(Rt Clk for larger)
At the May Coalition for Action on Remediation of Dioxane (CARD) meeting, after issuing another request, EGLE and local officials agreed to investigate potential 1,4 dioxane exposure because of detection and increasing levels being found near Ann Arbor Open/Mack and Slauson Schools in West Park 1/2 block away. Potential exposure could occur from vapor intrusion into buildings and other exposures from outside contact with contaminated groundwater seeping to the surface. See details below.
Screening levels for 1,4 dioxane were 29 ppb originally set by EGLE, analysis by a CARD member and comments from EGLE indicates 100 ppb would be appropriate with some assumptions.
The past analysis shows the Gelman/Danaher Plume may surface in the West Park area due to geological layers from the glacial action being exposed as the groundwater flow move toward the Huron River east of Argo Pond.
It is the ACWG and CARD's position that the EPA Superfund route is the most effective option the community has, given the fights Gelman/Pall/Donaher, a $140B company, has put up to avoid an effective cleanup for over 40 years.
All local governments and most NGOs, including CARD, ACWG, SC HVG, have voted for the Governor to Petition EPA for Superfund Status for Gelman/Danaher Toxic Dump Site Plume.
Even Mayor Taylor commented recently he is now finally supportive of an EPA Superfund Petition. He had previously threatened to Veto a Superfund vote of a City Council Resolution to support the Petition.
With over 100 Public Comments in public comment sessions, there have been no supporters of the 4th CJ.
40 years of diddling with Gelman is way too long, and the community, the state and the environment deserve better. The State and local governments can not deal with this, this is very apparent now as it was 20 years ago.
40 years of mismanagement, deaths, illness, property and wells damaged, valuable pristine groundwater polluted is enough.
Mayor Taylor should recuse from voting on the current Proposed CJ, he is a Partner/Owner of the law firm making $100's thousands on the ill-conceived CJ legal effort, in lieu of a Gelman/Danaher fully funded Superfund plan and full Cleanup.
After extensive prodding by ACWG and CARD, EGLE has agreed to do more near-surface shallow groundwater testing but has still refused to do more aggressive testing of near-surface shallow groundwater (NSG) that may be seeping into home's basements causing potential exposures due to high values in October 2020. ACWG and CARD have stated and Dan Bicknell has proposed a plan for permanent NSG wells back in 2016 that EGLE has not chosen to implement and they have not forced Gelman/Danaher to do it either.
The CARD Group has moved to virtual meetings like others starting in May for an undermined length of time, see details at the Washtenaw County CARD site.
Links:
May 2021 Regular Coalition for Action On the Remediation of Dioxane (CARD) Group Meeting Video - Taped by Roger Rayle, Chair CARD
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 Lucus at Dioxane.Org and WEMU News Program GreenRoom
Washtenaw County CARD Site
See ACWG site pages EPA Superfund Option Details from CARD/ACWG.
Click here to view and/or sign in support of Superfund Designation
After ACWG and CARD Request Additional NSG Tests, EGLE and Local Officials Now Agree to Do More NSG Testing Soon to Investigate Ann Arbor Open/Mack and Slauson Middle School Properties for 1,4 Dioxane, with Detection and Increasing Levels Found Near West Side Schools
Locations of EGLE 10-9-2020 NSG Tests and Schools
(West Part is in the middle of the image)
(ACWG, Rt Clk for larger)
At the May CARD meeting, EGLE and local officials agreed to investigate potential 1,4 dioxane exposure because of detection and increasing levels being found near Ann Arbor Open/Mack and Slauson Schools 1/2 block away at West Park. Potential exposure could occur from vapor intrusion into buildings and other exposures from outside contact with contaminated groundwater seeping to the surface.
MLive (Red Text Annotated on left by us)
(ACWG, Rt Clk for larger)
Professor and Department Chair of the Yale School of Public Health and Toxicology Journal Editor Asks CARD and ACWG to Submit Poster Write-Ups for Special Edition 1,4 Dioxane Journal Publication to be Published Later This Year
Invited Poster Presentation at U of M School of Public Health M-LEEaD Toxicology Symposium 2-20-2020
Vince Caruso (CARD, ACWG), Beth Collins (CARD Board Member) and
Dr. Robert Bailey PhD (Inorganic Chemist, CARD Member)
(Collins, Rt Clk for larger)
1, 4 Dioxane has become a major contaminant of concern by EPA, NIH and NIEHS in recent years, so much so the Frank R. Lautenberg Chemical Safety for the 21st Century Act of 2016 amends the Toxic Substances Control Act (TSCA), the nation’s primary chemicals management law.
1,4 Dioxane was one of ten chemicals, of the thousands possible, to be included for evaluation for TSCA inclusion as proposed in the Lautenberg Act.
Professor and Department Chair at Yale School of Public Health and Journal Editor asks CARD and ACWG to Submit a Poster from the MLeead Presentation Write-Ups for Special Edition 1,4 Dioxane Journal Publication to be Published later this year. Dr. Rita Loch-Caruso PhD (U of M School of Public Health Emeritus, former Director of M-LEEaD) was asked to work with CARD and ACWG and to present an article to be included in the special 1,4 Dioxane journal publication planned to be published later this year.
Links:
ACWG WebPage link to Posters Presented: U of M M-LEEaD Posters 02-20-20 - Response to 1,4-Dioxane Groundwater Contamination: (CARD); 1,4 D Vapor Intrusion : (Bailey, CARD)
MLive: ‘Root ball’ at Nichols Arboretum causes 600-gallon sewage overflow - again
Nichols Arboretum, U of M, in Ann Arbor
(Google St View; Rt Clk for Larger)
Smart Sewer with Cell Transmitter and Battery
Example of a Smart Wireless Flow Gauge
(Civil + Structural Engineer Magazine; Rt Clk for Larger)
On April 2 another "‘Root ball’ causes 500-gallon sewage spill in Nichols Arboretum in Ann Arbor: MLive.
"A similar sewage overflow occurred at the arboretum on April 1 when 500 gallons of sewage was spilled due to a root ball blockage." MLive.
The ACWG has been advocating touchless remote sewer system video monitoring. The city did buy remote flow monitors in recent years.
The ACWG attended a city meeting in recent years where a U of M professor detailed his funded research on remote video and stormwater flow monitoring. He designed a computer monitor that received data and images and an alarm system to notify personal of selected critical events.
This area of the city seems to have regular Sanitary Sewer Overflows (SSO's) which would benefit from flow and/or video monitoring
City staff has recently communicated to ACWG that they now have purchased 12 of our own sewer flow gauges on July 30. 2018.
As commented here before the ACWG has been advocating for Smart Sewers for years. We cited in our May 17, 2018 Agenda, and posted on our site, an NPR national story on how effective they can be and at low cost in a city similar to size as Ann Arbor.
As noted in an NPR May 8, 2018 report "These Smart Sewers Are Part Of A Growing Trend Connecting Infrastructure To The Internet" and, in South Bend Indiana "According to city officials, the sensors save the city a ton of money, more than $500 million."
The city and county over the years have paid to install temporary gauging for many studies, at great expense, many cases in the recent past at close to $10K each, then they are removed. This is for both sanitary and stormwater flows.
With permanent gauges will save money, and changes in development could have more accurate predictions of flood potential with proposed added flows. Additionally, the data would be invaluable in modeling efforts to show the most 'bang for the buck' in our city and county's sanitary and stormwater upgrade planning and upgrades to the floodplain map.
Link: https://www.npr.org/2018/05/08/609493403/these-smart-sewers-are-part-of-a-growing-trend-connecting-infrastructure-to-the-
MLive: " ‘Root ball’ causes 500-gallon sewage spill in Nichols Arboretum in Ann Arbor"
NYT: "Climate Change Is Making Big Problems Bigger", May 12, 2021
Michigan UP Flooding After 1,000 Year Flood/Rain Event 2018
(ABC13 News; Rt Clk for Larger)
From the NYT Article:
'Wildfires are bigger, and starting earlier in the year. Heatwaves are more frequent. Seas are warmer, and flooding is more common.
Climate change is already happening around the United States, the Environmental Protection Agency said on Wednesday. And in many cases, that change is speeding up.
The freshly compiled data, the federal government’s most comprehensive and up-to-date information yet, shows that a warming world is making life harder for Americans, in ways that threaten their health and safety, homes and communities.
Michael S. Regan, the E.P.A. administrator, said - “Americans are seeing and feeling the impacts up close, with increasing regularity.”
At many locations, “floods are now at least five times more common than they were in the 1950s,” according to the E.P.A.' NYT (bold by us)
Michigan is seeing major storm flooding, dams destroyed, Great Lakes rising to record levels of flooding and causing massive home, building and infrastructure destruction along the shorelines.
Scientific American 2021: Rising Costs of U.S. Flood Damage Linked to Climate Change and Intensifying Precipitation Events
SEM I94 Highway Flooding in Recent Years
(Detroit Free Press, Rt Clk for Larger)
From Scientific American Article 2021:
"Increased precipitation resulting partially from climate change has caused an additional $2.5 billion a year in U.S. flood damage, according to a new study that pinpoints the effect of changing weather on the cost of natural disasters.
A study published yesterday in the Proceedings of the National Academy of Sciences journal says that from 1988 through 2017, intensifying precipitation was responsible for a total of $75 billion in U.S. flood damage over the 29-year study period. Total flood damage in those years was nearly $200 billion, meaning that the excess precipitation accounted for more than a third of the damage in that period.
“The fact that a third of the total [flood damage] is contributed by increasing precipitation is substantial,” said study co-author Noah Diffenbaugh, a climate scientist at Stanford University." (bold by us)
Michigan is now getting 1,000-year rains and 500-year rains on a regular basis. Large rains are causing dams to be breached causing large flood events.
April 2021 - No Meeting this month due to COVID-19 Pandemic Cautions
Watershed Issues of Interest and Updates:
Governor Whitmer Has Stated She Will Be Sending a Letter To EPA in Support of an EPA SUPERFUND for the Gelman/Danaher Toxic Dump Site and Plume!!
Rally for Ann Arbor Area EPA Superfund in Lansing Capital Building Canceled
Danaher/Pall/Gelman 1,4-Dioxane Toxic Dump Site Plume - US EPA/EGLE Joint Session Comments, EPA: We Are Ready to Step In as a Superfund Manager if We Are Asked by the State
EPA, EGLE and Local Government Joint Session Potential EPA Superfund Discussions on 3-18-21;
(Rt Clk for larger)
Zoom Hosted by Roger Rayle; screenshot of YouTube view (click image to view)
(Rt Clk for larger)
At the April Coalition for Action on the Remediation of Dioxane (CARD) meeting, EGLE and local officials agreed to investigate potential 1,4 dioxane exposure because of detection and increasing levels being found near Ann Arbor Open/Mack and Slauson Schools in West Park 1/2 block away. Potential exposure could occur from vapor intrusion into buildings and other exposures from outside contact with contaminated groundwater seeping to the surface. See details below.
At the Gelman Community Information Session on March 18th representatives from the U.S. Environmental Protection Agency (EPA) and the Michigan Department of Environment, Great Lakes, and Energy (EGLE) met to answer questions from the community and local officials about the status of the Plume and discuss potential next steps. The opportunity for public comment was for elected officials, public comment did not occur due to an unexpected shortened meeting. This meeting was organized by Representative Debbie Dingell and Washtenaw County on behalf of the community.
Even Mayor Taylor commented at the meeting he is now finally supportive of an EPA Superfund Petition. He had previously threatened to Veto a Superfund vote of a City Council Resolution to support the Petition.
All local governments and most NGOs, including CARD, ACWG, SC HVG, have voted for the Governor to Petition EPA for Superfund Status for Gelman/Danaher Toxic Dump Site Plume.
EPA Superfund Petitions have been delivered to Governor Whitmer. She is said to be sending a Concurrence Letter from The State of Michigan to Petition Superfund standing for the Gelman Toxic 1,4 Dioxane Dump Site on Wager Rd. and Plume flowing in all directions from the Toxic Dump Site.
When EPA gets such a Superfund request, as Governor Whitmer is likely about to send, EPA accepts it and starts the Superfund process for a full evaluation and full cleanup.
It is the ACWG and CARD's position that the EPA Superfund route is the most effective option the community has, given the fights Gelman/Pall/Donaher, a $140B company, has put up to avoid an effective cleanup for over 40 years.
With over 100 Public Comments in public comment sessions, there have been no supporters of the 4th CJ.
Some comments from City Council members seem to indicate they are proposing not supporting the passed Superfund Petition. We urge your continued support of the Governor sending a concurrence letter to EPA of support of Gelman EPA Superfund status.
Diddling with Gelman:
40 years of diddling with Gelman is way too long, and the community, the state and the environment deserve better. The State and local governments can not deal with this, this is very apparent now as it was 20 years ago.
40 years of mismanagement, deaths, illness, property and wells damaged, valuable pristine groundwater polluted is enough.
Mayor Taylor should recuse from voting on the current Proposed CJ, he is a Partner/Owner of the law firm making $100's thousands on the ill-conceived CJ legal effort, in lieu of a Gelman/Danaher fully funded Superfund plan and full Cleanup.
Contact Governor Whitmer to request she send a Concurrence Letter to EPA in support of Superfund designation. The link below is to a direct contact page to enter a written comment:
Link to comment to Governor: https://somgovweb.state.mi.us/GovRelations/ContactGovernor.aspx
After extensive prodding by ACWG and CARD, EGLE has agreed to do more near-surface shallow groundwater testing but has still refused to do more aggressive testing of near-surface shallow groundwater (NSG) that may be seeping into home's basements causing potential exposures due to high values in October 2020. ACWG and CARD have stated and Dan Bicknell has proposed a plan for permanent NSG wells back in 2016 that EGLE has not chosen to implement and they have not forced Gelman/Danaher to do it either.
The CARD Group has moved to virtual meetings like others starting in May for an undermined length of time, see details at the Washtenaw County CARD site.
Links:
April 2021 Regular Coalition for Action on Remediation of Dioxane (CARD) Group Meeting Video - Taped by Roger Rayle, Chair CARD
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 Lucus at Dioxane.Org and WEMU News Program GreenRoom
Washtenaw County CARD Site
See ACWG site pages EPA Superfund Option Details
Click here to view and/or sign in support of Superfund Designation
After ACWG and CARD Request Tests, EGLE and Local Officials Agree to continue to Investigate Ann Arbor Open/Mack and Slauson Middle School Properties for 1,4 Dioxane, with Detection and Increasing Levels Found Near West Side Schools
Locations of EGLE 10-9-2020 NSG Tests and Schools (West Part is in the middle of the image)
(ACWG, Rt Clk for larger)
At the March CARD meeting, EGLE and local officials agreed to investigate potential 1,4 dioxane exposure because of detection and increasing levels being found near Ann Arbor Open/Mack and Slauson Schools 1/2 block away at West Park. Potential exposure could occur from vapor intrusion into buildings and other exposures from outside contact with contaminated groundwater seeping to the surface.
The CARD Group has lobbied for VI for 1,4 Dioxane and MDEQ/EGLE included it as a special case for VI regulations.
Mack School is 1/2 blocks from West Park and has been reported to have seeps (like in many areas on the West Side) on the school grounds. Slauson Middle School has 1,4 dioxane levels in the NSG at the 8th St street drain just south of the school grounds at 11 ppb.
More testing of the school grounds needs to be done to determine the potential exposures.
ACWG and CARD have been requesting simple tests since 2016, when EGLE and Gelman refused to do a meaningful test program, as reported here in 2016.
ACWG and CARD have stated and Dan Bicknell has proposed a plan for permanent NSG wells back in 2016 (as ACWG has sent out and posted on our site) that EGLE has not chosen to implement and they have not forced Gelman/Danaher to do it either.
Concern that the seeps, groundwater entering lower levels of schools, kids getting wet in the playground from seep flows and taking this into the school after recess could lead to exposures.
Like a home's basement, Vapor Intrusion (VI) into school lower levels can be at risk with high enough concentrations of contaminated Near Surface Shallow Groundwater next to the structure.
MS4 Violation in Allen's Creek Going on 3 Years:
The CARD Group has 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 with the illicit 1,4 Dioxane pollution levels in the drain continuously going up. The ACWG pushed for and also supports the CARD resolution. No resolution of this Federal MS4 violation reported at the last CARD meeting about this violation.
The Water Resources Commissioners Office (WRCO) has notified Gelman that they are in violation of the Federal MS4 Permit in a statutory Freshwater Runoff (Stormwater) Drain. WRCO is the delegated authority by EGLE and the Federal Government to manage MS4 permits in the County. No word on what Gelman/Danaher will do about this over 3-year-old Federal MS4 Violation.
Recent data from EGLE Near-Surface Shallow Groundwater test done 10-9-20 sent out on 11-23-20 indicates that Allen's Creek stormwater on the West Side has increased dioxane values from the 2019 sampling.
West Park SW is at 49 ppb up from 22 ppb in 2019,
Chapin St. is at 28 ppb up from 9.1 ppb in 2019,
Eight St. next to Slawson Middle School is at 11 ppb up from 1 ppb in 2019.
EGLE and EPA have indicated a value of 29 ppb in NSG near homes or buildings as a vapor-intrusion (VI) screening level when first published. Currently, 100 ppb seems to be a better value given most circumstances and recent current analysis by EGAL and others.*
Lack of NSG Monitoring Wells is a real concern for West Ann Arbor.
The only "shallow monitoring well" (NSG) in the area was in Maple Village MW-87s is now gone due to development, never replaced, with readings 400-1,500 ppb at 843' elevation as mentioned by Roger. Vet's park has been 1,000 ppb in recent years.
Elevations are generally: West Park area is at 816', Mack Open School at 845', Slauson School at 821', all at or below MW-87s
Links:
April 2021 Regular Coalition for Action on Remediation of Dioxane (CARD) Group Meeting Video - Taped by Roger Rayle, Chair CARD
Gelman Plume Related Stories by Ann Arbor News/MLive: MLive
Michigan MS4 Regulation
Latest 1% Chance (100 Year) Flood Map from First Street Foundation 2021 for DTE Toxic Waste, Housing and Hotel Development Site, 841 Broadway St.
DTE Development Site FloodFactor(r) Predicted 100-Year (1% Chance) Flooding Including Global Warming Effects
(No Buildings on this Site so above Table shows No Buildings Flooded; Annotations ACWG, Click for Larger)
First Street Foundation Flood Factor (R) Models show a site virtually fully flooded in a 100-year (1% chance) flood. The parking area to the SE is AmTrak owned long-term parking property outside the floodplain.
The developer and DTE (a $46B company) have no plans for a full cleanup of the site, they plan to build condos and a hotel on top of the highly toxic Coal Tar and other pollution, as shown above, in FloodFactor modeled floodplain. This map shows the proposed building site virtually in 100-year (1% chance) floodplain. The ACWG has attended many meetings about this project over the recent years and does not support the proposal, mainly due to the floodplain and toxic waste issues. Many of those on this site will have no idea they are in this situation in a major rain event flood potential.
Unlike First Street Foundation, FEMA does not account for Global Warming in its models, and for other reasons, they are very much Low Ball values by at least 30%. Much more dangerous than it may appear to the uneducated or uninterested. The floodway (FW) analysis for this site is likely in error as well.
During the 1968 100-year (1% chance) flood this site had 15' of water careening across this site, this without the Argo or Barton Dams having been destroyed by the flooding. Argo was breached in the flood and almost was lost due to over-topping the dam and undermining the base of the dam.
Some have reported that the 1968 flood was more along the lines of a 50-year flood.
Structures on this site will be placed on top of a toxic waste site with coal tar and other chemicals from the old MichCon Gasification Plant that was on this site. The groundwater below is contaminated but downstream contamination tests in the Huron River were not done according to the developer.
Vapor Intrusion is a real issue being faced by many sites which were built over old dump sites. In Petoskey MI recently 11 of 14 condos were evacuated due to VI issues from building in an old dumpsite. See our website for information on Vapor Intrusion as it relates to the Gelman Toxic Dump Site and Plume.
Link: First Street Foundation Flood Factor (R) Models Lookup.
See Details in previous entries on our website.
UPDATE: 214 W Kingsley is no longer in the FEMA floodway since several years ago FEMA map revision showed it just outside the floodway. The ACWG has raised concerns about this remapping, and does not support it, with no elevation changes at this part of the floodway and much larger rain events happening in SEM with Global Warming. First Street Foundation shows 3'+ flood water well into the front of the building in 100-Year 1% Chance Flood Event.
As stated in past entries - unlike First Street Foundation, FEMA does not account for Global Warming in its models, and for other reasons, they are very much Low Ball values by at least 30%. Much more dangerous than it may appear to the uneducated or uninterested. The floodplain and floodway analysis for this site seems it could be in error from this published information.
In the city web map page image of the floodmap, you can see the floodway does a left hook around the building. FEMA representatives indicated to us at the digital FP map presentation, without equivocation, this should not occur unless there is a grade change at the site, which does not seem to occur. The street in front of this site floods routinely to become impassable.
Beal Building at 214 W Kingsley St. Fencing in Floodway Now Locked Down for the Third Time, EGLE Required Swing Up Flood Hazard Prevention Fencing for this Building, It is Blocking the Allen's Creek Floodway and is Dangerous
Beal Building 214 W Kingsley St, Locked Down Swing Up Fence in Floodway, 3-23-21
(ACWG, Clk for larger image)
Slinker Building with Submarine Door Wide Open (circled), Random Google Street View Image 2020
Update: 4-13-21 Morning ACWG Drive by showed Door Open (photo available)
(ACWG, Clk for larger image)
Third time for this MDEQ/EGLE and City of Ann Arbor potential Floodway and Occupancy Permit Violation at this site.
City staff will be notified again of this potential violation. In the past staff has indicated to ACWG that the locks or other means of holding down the swing-up flood hazard fencing were in violation and have been removed in the past as requested by staff. In this case, there is a wire cable holding the fences down as of 3-23-21.
Several years ago, the first time the city was notified by the ACWG, it took many months and an ACWG request to the MDEQ, and a special visit from the MDEQ, to force the city leadership to get the fences unlocked. Link to one of the previous locked down Swing-Up Fence violation occurrences.
These fences under the elevated building were not to be locked down in the floodway to prevent flood hazards for homes and businesses upstream due to a much higher floodplain as the locked-down fencing would cause blockage of floodwater flow to the river. The Building received an ill-conceived permit that required Floodway waters to flow under it. Locked down fencing violates this.
Fencing clogs up quickly in a flood and acts like a cement wall in blocking floodwater flow causing more unnecessary and dangerous flooding upstream. Hydrologically chain link fencing is treated like a concrete wall with no water able to flow through it.
This is the THIRD time this has happened in recent years.
Clearly, there needs to be protections for upstream residents and businesses from unnecessary and dangerous flood hazard. Not clear if a fine or other action was taken for this potential third egregious infraction.
Another Example of Floodplain Misplaced Allowances:
There are real issues with these kinds of allowances in the floodplain and floodway. Slinker Building 213 W. Liberty St. when renovated for office space had a locking "Submarine Door" installed at its lower level exit into the Allen's Creek floodplain. As this is in the floodplain generally it is expected to be kept locked, when not in use, to prevent damage to the building and hazard to occupants. The ACWG has reported to the city the many occurrences where it is open on weekdays, weekends and holidays creating a flood hazard. In past years the ACWG has never seen it closed and locked.
March 2021 - No Meeting this month due to COVID-19 Pandemic Cautions
Watershed Issues of Interest and Updates:
Danaher/Pall/Gelman 1,4-Dioxane Toxic Dump Site Plume - EPA/EGLE Joint Session This Thursday, Comments Welcome
Zoom Hosted by Roger Rayle; screenshot of YouTube view (click image to view)
(CARD; Rt Clk for larger)
At the March Coalition for Action on Remediation of Dioxane (CARD) meeting, Michigan Department of Environment, Great Lakes, and Energy (EGLE) and local officials agreed to investigate potential 1,4 dioxane exposure because of detection and increasing levels being found near Ann Arbor Open/Mack 1/2 block away from West Park with 49 ppb finding and Slauson School next to 11 ppb finding. Potential exposure could occur from vapor intrusion into buildings and other exposures from outside contact with contaminated groundwater seeping to the surface. See details below.
Thursday, March 18 will be a joint session of Local Elected in a Zoom Meeting to discuss Gelman/Danaher Toxic Dump Site Plume EPA Superfund Status, see below.
All local governments and most NGOs, including CARD, ACWG, SC HVG, have voted for the Governor to Petition EPA for Superfund Status for Gelman/Danaher Toxic Dump Site Plume. We hope our elected officials will abide by these votes and insist Governor Whitmer send the Concurrence Letter to EPA.
This from Sue Shink Chair, Washtenaw County Board of Commissioners:
Gelman Community Information Session on March 18th at 5pm. At this meeting, representatives from the U.S. Environmental Protection Agency (EPA) and the Michigan Department of Environment, Great Lakes, and Energy (EGLE) will answer questions from the community and local officials around the status of the Toxic Dump Site and Plume and, discuss potential next steps. There will be an opportunity for public comment. This meeting is being organized by Representative Debbie Dingell and Washtenaw County on behalf of the community.
The Meeting is saved on YouTube by CARD currently (may be moved at some point):
https://www.youtube.com/watch?v=1a3VHv6_qAM
EPA Superfund Petitions have been delivered to Governor Whitmer. She is working on a Concurrence Letter from The State of Michigan to Petition Superfund standing for the Gelman Toxic 1,4 Dioxane Dump Site on Wager Rd. and Plume flowing in all directions from the Toxic Dump Site.
When EPA gets such a request, as Governor Whitmer is likely about to send, EPA accepts it and starts the Superfund process for a full evaluation and full cleanup.
It is the ACWG and CARD's position that the EPA Superfund route is the most effective option the community has, given the fights Gelman/Pall/Donaher, a $140B company, has put up to avoid an effective cleanup for over 40 years.
With over 100 Public Comments in public comment sessions, there have been no supporters of the 4th CJ.
Some comments from City Council members seem to indicate they are proposing not supporting the passed Superfund Petition. We urge your continued support of the Governor sending a concurrence letter to EPA of support of Gelman EPA Superfund status.
Diddling with Gelman:
40 years of diddling with Gelman is way too long, and the community, the state and the environment deserve better. The State and local governments can not deal with this, this is very apparent now as it was 20 years ago.
40 years of mismanagement, deaths, illness, property and wells damaged, valuable pristine groundwater polluted is enough.
Mayor Taylor should recuse from voting on the current Proposed CJ, he is a Partner/Owner of the law firm making $100's thousands on the ill-conceived CJ legal effort, in lieu of a Gelman/Danaher fully funded Superfund plan and full Cleanup.
Contact Governor Whitmer to request she send a Concurrence Letter to EPA in support of Superfund designation. The link below is to a direct contact page to enter a written comment:
Link to comment to Governor: https://somgovweb.state.mi.us/GovRelations/ContactGovernor.aspx
After extensive prodding by ACWG and CARD, EGLE has agreed to do more near-surface shallow groundwater testing but has still refused to do more aggressive testing of near-surface shallow groundwater (NSG) that may be seeping into home's basements causing potential exposures due to high values in October 2020. ACWG and CARD have stated and Dan Bicknell has proposed a plan for permanent NSG wells back in 2016 that EGLE has not chosen to implement and they have not forced Gelman/Danaher to do it either.
The CARD Group has moved to virtual meetings like others starting in May for an undermined length of time, see details at the Washtenaw County CARD site.
Links:
March 2021 Regular Coalition for Action on Remediation of Dioxane (CARD) Group Meeting Video - Taped by Roger Rayle, Chair CARD
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 Lucus at Dioxane.Org and WEMU News Program GreenRoom
Washtenaw County CARD Site
See ACWG site pages EPA Superfund Option Details
Click here to view and/or sign in support of Superfund Designation
After ACWG and CARD Request Tests, EGLE and Local Officials Agree to Investigate Ann Arbor Open/Mack and Slauson Middle School Properties for 1,4 Dioxane, with Detection and Increasing Levels Found Near West Side Schools
Locations of EGLE 10-9-2020 NSG Tests and Schools (West Part is in the middle of the image)
(ACWG, Rt Clk for larger)
At the March Coalition for Action on Remediation of Dioxane (CARD) meeting, EGLE and local officials agreed to investigate potential 1,4 dioxane exposure because of detection and increasing levels being found near Ann Arbor Open/Mack 1/2 block away from West Park with 49 ppb finding and Slauson School next to 11 ppb finding. Potential exposure could occur from vapor intrusion into buildings and other exposures from outside contact with contaminated groundwater seeping to the surface.
Mack School is 1/2 blocks from West Park and has seeps on the school grounds and lower levels into the ground. Slauson Middle School has lower levels into the ground with 8th St just south of the school grounds at 11 ppb on the street storm drain.
More testing of the school grounds needs to be done to determine the potential exposures.
ACWG and CARD have been requesting simple tests since 2016, when EGLE and Gelman refused to do a meaningful test program.
ACWG and CARD have stated and Dan Bicknell has proposed a plan for permanent NSG wells back in 2016 (as ACWG has sent out and posted on our site) that EGLE has not chosen to implement and they have not forced Gelman/Danaher to do it either.
Concern that the seeps, groundwater entering lower levels of schools, kids getting wet in the playground from seep flows and taking this into the school after recess could lead to exposures.
Like a home's basement, Vapor Intrusion (VI) into school lower levels can be at risk with high enough concentrations of contaminated New Surface Shallow Groundwater next to the structure.
The CARD Group has 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 with the illicit 1,4 Dioxane pollution levels in the drain continuously going up. The ACWG pushed for and also supports the CARD resolution.
The Water Resources Commissioners Office (WRCO) has notified Gelman that they are in violation of the Federal MS4 Permit in a statutory Freshwater Runoff (Stormwater) Drain. WRCO is the delegated authority by EGLE and the Federal Government to manage MS4 permits in the County. No word on what Gelman/Danaher will do about this over 3-year-old Federal MS4 Violation.
Recent data from EGLE Near-Surface Shallow Groundwater test done 10-9-20 sent out on 11-23-20 indicates that Allen's Creek stormwater on the West Side has increased dioxane values from the 2019 sampling.
West Park SW is at 49 ppb up from 22 ppb in 2019,
Chapin St. is at 28 ppb up from 9.1 ppb in 2019,
Eight St. next to Slawson Middle School is at 11 ppb up from 1 ppb in 2019.
EGLE and EPA have indicated a value of 29 ppb in NSG near homes or buildings as a vapor-intrusion (VI) screening level when first published. Currently, 100 ppb seems to be a better value given most circumstances and recent current analysis by EGAL and others.*
Links:
March 2021 Regular Coalition for Action on Remediation of Dioxane (CARD) Group Meeting Video - Taped by Roger Rayle, Chair CARD
Gelman Plume Related Stories by Ann Arbor News/MLive: MLive
Michigan MS4 Regulation
Communities Have Pushed Low Income Housing Into Floodplains for Generations for a Reason: Racism - Bloomberg CityLab-March 15, 2021
Bloomberg CityLab 'Redlined, Now Flooding'
(Bloomberg, Rt Clk for larger image)
Association of State Floodplain Managers 2007 (ASFPM)
"BUILDING IN THE FLOODPLAIN IS LIKE PITCHING
YOUR TENT ON A HIGHWAY WHEN THERE ARE NO CARS COMING"! ASFPM: www.floods.org
(ASFPM; Rt Clk for larger image)
Bloomberg CItyLab: March 15, 2021
This from the Article:
" Maps of historic housing discrimination show how neighborhoods that suffered redlining in the 1930s face a far higher risk of flooding today.
Flooding is a rising threat across the U.S., with homeowners facing as much as $19 billion in damages every year. What puts a neighborhood at high risk for flooding? Geography is key, but new data reveal another factor that can be determinative, too: race.
Using flood risk data from the nonprofit First Street Foundation and redlining maps from the University of Richmond’s Mapping Inequality project, Redfin assessed racial disparities in flood risk across dozens of major metro areas.
Across 38 major U.S. metros, more than $107 billion worth of homes at high risk for flooding were located in historically redlined (and yellowlined) neighborhoods.
Severe storms and hurricanes have a disproportionate effect on minorities in terms of damage done, life lost, and the amount of money that gets reimbursed, ...” (bold by us)
415 W. Washington, City-Owned Lot
Flood risk for 415 W. Washington proposed for potential development;
First Street Foundation (Rt Clk for larger)
Flood risk for 721 N Main St. proposed for potential development;
First Street Foundation (Rt Clk for larger)
As ACWG commented on last year, 721 N. Main and 415 W. Washington and, other flood-prone sites have been widely discussed by some on City Council as proposed sites for Affordable Housing (AH), with a flood analysis that includes Global Warming, which, some on council purportedly agree is real, a major threat and, is causing bigger rain events. The City just authorize a $1,000.000.000 plan to deal with Global Warming effects.
The ACWG has commented last year in AH issues meetings that the Profit Motive has failed and we need to move to a more proactive city lead effort. Also have discussed not building in the floodplain (FP) for decades now, especially "AH". Glad to see these changes finally happening, better late than never.
CM Ali Ramlawi proposed an amendment to the AH Millage to ban the use of the Millage funds in the Floodplain as suggested by the ACWG.
Amendment passed with Mayor Taylor and CM's Smith, Ackerman, Grand voting against.
“In a 7-4 vote, council decided to prohibit spending money from the tax on building, maintaining or acquiring new affordable housing units in floodways or floodplains." : MLive.
The affordable housing tax passed with 73% support last November.
Unlike First Street Foundation, FEMA does not account for Global Warming in its models, and for other reasons, they are very much Low Ball values by at least 30%. Much more dangerous than it may appear to the uneducated or uninterested. The floodway (FW) analysis is likely in error as well.
It’s ok to put disadvantaged in very dangerous FP and likely FW according to Taylor, Smith, Ackerman, Grand and their supporters.
The city has a very sordid history of placing minorities and disadvantaged in FP and FW which should be stopped especially with Global Warming effects clearly making this more dangerous by the day.
First Street Foundation's https://floodfactor.com/
UPDATE: Gelman Community Information Session on March 18th at 5pm.
This from Sue Shink Chair, Washtenaw County Board of Commissioners:
Gelman Community Information Session on March 18th at 5pm. At this meeting, representatives from the U.S. Environmental Protection Agency (EPA) and the Michigan Department of Environment, Great Lakes, and Energy (EGLE) will answer questions from the community and local officials around the status of the Plume and discuss potential next steps. There will be an opportunity for public comment. This meeting is being organized by Representative Debbie Dingell and Washtenaw County on behalf of the community.
Was a Zoom Meeting.
The Meeting is saved on YouTube currently by CARD (may be moved at some point):
https://www.youtube.com/watch?v=1a3VHv6_qAM
February 2021 - No Meeting this month due to COVID-19 Pandemic Cautions
Watershed Issues of Interest and Updates:
Danaher/Pall/Gelman 1,4-Dioxane Toxic Dump Site Plume - Waiting for Ruling on EPA Superfund
Locations of EGLE 10-9-2020 NSG Tests (West Part is at Upper Right)
(ACWG, Rt Clk for larger)
The CARD Group has passed a resolution asking for the illicit 1,4 Dioxane pollution flowing into the Allen Creek Drain to be removed by Gelman. Gelman and EGLE have been notified of this for over 3 years with the illicit 1,4 Dioxane pollution levels in the drain continuously going up. The ACWG pushed for and also supports the CARD resolution.
The Water Resources Commissioner's Office (WRCO) has notified Gelman that they are in violation of the Federal MS4 Permit in a statutory Freshwater Runoff (Stormwater) Drain. WRCO is the delegated authority by EGLE and the Federal Government to manage MS4 permits in the County.
The Statement to WRCO did not include a Notice of Violation (NOV), did not cite the civil and criminal penalties for violating the MS4 permit for which Gelman is responsible.
Additionally, the NOV did not stress that no dioxane is allowed to infiltrate into the stormwater drain under the MS4 permit.
This pollution is almost surely from the Gelman Toxic 1,4 Dioxane Plume in near-surface shallow groundwater that is picked up by the Allen's Creek Drain system that flows through West Park.
1,4 Dioxane has been found in the Allen's Creek after the ACWG asked EGLE (DEQ) to do simple tests (kinda hard for them to refuse) in West Park and 8th St as this is a known area of high groundwater flows into the Allen's Creek, which enters the drain and flows to the Huron River.
Recent tests in the drain in West Park and Chapin St in early October 2020 show a 49 ppb reading in West Park's SE corner and Chapin St at 28 ppb.
Near-Surface Shallow Groundwater (NSG) much-delayed tests come back alarmingly high:
Recent data from EGLE delayed Near-Surface Shallow Groundwater test done 10-9-20 sent out on 11-23-20 indicates that Allen's Creek stormwater on the West Side has increased dioxane values from the 2019 sampling.
West Park SW is at 49 ppb up from 22 ppb in 2019,
Chapin St. is at 28 ppb up from 9.1 ppb in 2019,
Eight St. next to Slawson Middle School is at 11 ppb up from 1 ppb in 2019.
EGLE and EPA have indicated a value of 29 ppb in NSG near homes as a vapor-intrusion (VI) screening level.
ACWG and CARD commented that large flows of water were in the Allen's Creek pipe in South West West Park entrance and 8th St. near Slauson Middle School with very dry conditions, seeming to indicate high groundwater flows in the pipe as has been described previously. Seeps are said to be in many areas of the city on the west side including higher elevations.
The illicit 1,4 Dioxane pollution flows into the Huron River are just upstream of the very popular Cascades outfall into the Huron River less than 1,500 feet away. Many people tube down the Cascades and out into the Huron River just upstream of the Allen's Creek Outlet into the river.
Michigan MS4 Regulation:
'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)
Link: Michigan MS4 Regulation
Full Resolution CARD Google Drive File Here.
City Proposing Unlimited Building Heights in T1 Zoning to "Fight Climate Change" and Suburban Sprawl, Support Developers, Ignore Global Warming?
Zoom Hosted by Roger Rayle; screenshot of YouTube view (click image to view)
(Rt Clk for larger)
EPA Superfund Petitions have been delivered to Governor Whitmer. She is working on a Concurrence Letter from The State of Michigan to Petition Superfund standing for the Gelman Toxic 1,4 Dioxane Dump Site on Wager Rd. and Plume flowing in all directions from the Toxic Dump Site.
When EPA gets such a request, as Governor Whitmer is likely about to send, EPA accepts it and starts the Superfund process for a full evaluation and full cleanup.
It is the ACWG and Coalition for Action on Remediation of Dioxane (CARD)'s position that the EPA Superfund route is the most effective option the community has, given the fights Gelman/Pall/Donaher, a $140B company, has put up to avoid an effective cleanup for over 40 years.
With over 100 Public Comments in public comment sessions, there have been no supporters of the 4th CJ.
Some comments from City Council members seem to indicate they are proposing not supporting the passed Superfund Petition. We urge your continued support of the Governor sending a concurrence letter to EPA of support of Gelman EPA Superfund status.
Diddling with Gelman:
40 years of diddling with Gelman is way too long, and the community, the state and the environment deserve better. The State and local governments can not deal with this, this is very apparent now as it was 20 years ago.
40 years of mismanagement, deaths, illness, property and wells damaged, valuable pristine groundwater polluted is enough.
Contact Governor Whitmer to request she send a Concurrence Letter to EPA in support of Superfund designation. The link below is to a direct contact page to enter a written comment.
Link to Comment: https://somgovweb.state.mi.us/GovRelations/ContactGovernor.aspx
City of Ann Arbor Near-Surface Shallow Groundwater Tests Missing the Mark:
Near-surface shallow groundwater (NSG) tests paid for by the city will not be doing much testing east of West Park where NSG 1,4 Dioxane test show 49 ppb in October 2020. Most of the testing is west of West Park against the recommendations of the ACWG and CARD Group.
Michigan Department of Environment, Great Lakes, and Energy (EGLE) has indicated a value of 29 ppb in NSG near homes as a vapor-intrusion (VI) screening level.
We need tests mainly to the East of West Park where we know there is a good chance of VI exposures with 49 ppb found upstream. Additionally, we need to test in basements that are wet for long periods of time, common on our West Side homes.
City not warning residents for VI Wet Basement Testing for 1,4-Dioxane:
The city web site (https://www.a2gov.org/departments/water-treatment/Pages/1,4-Dioxane-Wet-Basement-Testing-.aspx) indicates flooded or standing water contamination are the conditions to be tested. ACWG and CARD have commented extensively that we also need to evaluate wet basements (wet walls, floors not necessarily flooded) as 1,4 dioxane contaminated water on the walls and floor will evaporate with the water and expose the residents or businesses. These types of tests would be of interest to the US EPA with potential exposures.
This information on the city web site is not correct, it does not discuss VI exposures of wet basements:
'In April, City Council authorized funding to sample flooded basements for 1,4-dioxane in low-lying areas intersecting the Gelman plume.
Q: What if my basement doesn't flood and I live over the plume? Should I be concerned?
A: No, the 1,4-dioxane in Ann Arbor is present in groundwater. If your home does not flood, you will not be in contact with the groundwater plume.' (bold by us)
After extensive prodding by ACWG and CARD, EGLE has agreed to do more near-surface shallow groundwater testing but has still refused to do more aggressive testing of near-surface shallow groundwater that may be seeping into home's basements causing potential exposures due to high values in October 2020. ACWG and CARD have stated and Dan Bicknell has proposed a plan for permanent NSG wells back in 2016 (as ACWG has sent out and posted on this site) that EGLE has not chosen to implement and they have not forced Gelman/Danaher to do it either.
The CARD Group has moved to virtual meetings like others starting in May for an undermined length of time, see details at the Washtenaw County CARD site.
Links:
February 2021 Regular Coalition for Action on Remediation of Dioxane (CARD) Group Meeting Video - Taped by Roger Rayle, Chair CARD
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 Lucus at Dioxane.Org and WEMU News Program GreenRoom
Washtenaw County CARD Site
See ACWG site pages EPA Superfund Option Details
Click here to view and/or sign in support of Superfund Designation
WRCO statement to Gelman did not Include a Statement on Fines and Other Issues;
"RESOLUTION SUPPORTING THE WASHTENAW COUNTY – WATER RESOURCES COMMISSIONER ISSUING A NOTICE OF VIOLATION TO GELMAN SCIENCES, INC. FOR VIOLATION OF MS4 PERMIT COVERING THE ALLEN CREEK DRAIN" - CARD
Glendale Neighborhood With High Flood Hazard vs Development
(ACWG, Rt Clk for larger)
Glendale Area Flood Hazard vs Development vs Tax Base
The current development of the Green Space shown above was barely approved for Hillside Memory Care Center Building in a Residential Neighborhood. Two previous large building proposals votes failed. The neighborhood showed via a survey that 50% of the homes in the 5 block area had flooding problems (see ACWG Survey Map).
The neighborhood lobbied for the Green Space to be bought with Green Belt Millage funds but City Council did not support that. This when only 9% of Mileage funds have been used in recent years in the city in violation of the voter-approved Green Belt Mileage which requires 33% be spent in the city (Text of Green Belt Millage City Resolution Passed by voters in the City of Ann Arbor).
The City's own $2M stormwater study, which ACWG suggested and participated in, showed this area as a clear Target Area for Reduced Flood Hazard city spending: $2M “Ann City of Ann Arbor Stormwater Model Calibration and Analysis Project”, June 1, 2015 section ‘C, viii. Glendale/Charlton, page 62’.
This green space site with a slight depression could have captured the extensive fresh rainwater (stormwater) runoff from several upstream apartments of the 1960's, Hillside Terrace and Stadium Retail areas, and be a great park space 99.99% of the time (as described in the $2M city stormwater study).
This development won over a reduced flood hazard for a neighborhood with a known tax base to a new development with a much lower tax base.
Tax Base Math (2020):
~30 homes at real risk of major flooding = ~$4000 property tax ea = $120,000 taxes per year
New Hillside Development = about $30K property taxes per year
City of Ann Arbor Loses $90,000 per year for decades to come
(Not including the flood hazard risks tax losses, that could be avoided, of an existing residential neighborhood)
Flood hazard is increasing quickly in SEM by the year so many more homes may be at risk soon, than the ones shown on the map
Green Belt Mileage Spending on City Greenspace Option:
Millage funds were available to buy green space land for park space to reduce flood hazard
This new building creates more runoff, delay release with detention but has significantly increased amounts with more flooding
Ignore Global Warming effects on Ann Arbor when convenient
Direct attract on residential neighborhood with existing very stable long-lived tax base to help developers make money
City loses a large amount of tax money
Green space in urban communities has many other benefits besides flood hazard reduction, including an improved Tax Base for the Bean Counters.
Links:
ACWG Survey Map
Green Belt Millage Resolution Passed by voters in the City of Ann Arbor
First Street Foundation Flood Factor(R) Models Lookup.
January 2021 - No Meeting this month due to COVID-19 Pandemic Cautions
Watershed Issues of Interest and Updates:
UPDATE*: "In Deep: Ann Arbor’s Water Troubles" Posted January 1, 2021 by Vivienne Armentrout
In depth online article on the Hahn Suit and "water" fees uses by City of Ann Arbor
Danaher/Pall/Gelman 1,4-Dioxane Toxic Dump Site Plume - EPA Superfund Petitions Have Been Sent
Blowing Up Ann Arbor For Special Interests
City Residents Overwhelming Voted to Reject 17+ Story "Behemoth Library Lane Proposal"
(ACWG, Rt Clk for larger)
T1 Zoning is a new proposed zoning for Transit-Oriented Development in the City of Ann Arbor. The proposal is to have mixed-use unlimited height tall buildings and more people living and shopping on transit corridors.
This after Ann Arbor overwhelmingly rejected the Library Lane 17+ story Behemoth in a voter referendum in recent years.
Ann Arbor should not be required to handle all comers. We are a Landlocked city. We have lots of communities within minutes of the city. Affordable housing yes, but this proposal is not a workable solution for it. We are using the new passed Affordable Housing millage funds and some city-owned land which is a supportable and valid option.
Vivienne Armentrout, former County Commissioner, has several articles on these issues, a link to a recent one on her Local in Ann Arbor *:
https://localinannarbor.com/2020/07/12/disruption-in-ann-arbor-its-a-promise-2/
The city has adopted a $1B Net Zero (!) proposal for Ann Arbor, yet the unlimited building heights or very tall buildings, will generate huge amounts of unsustainable carbon emissions.
Climate Change and Global Warming are not in line with this T1 Zoning.
For example, just a 20 story concrete and/or steel building has a Huge Carbon Footprint: 20,000,000 pounds of carbon:
20 story concrete and/or steel building's enormous Carbon Footprint is about 20,000,000 pounds of carbon into the atmosphere for just the concrete and steel alone not including all the construction carbon emissions which is considerable!
Tall buildings are also incredibly inefficient compared to smaller buildings to about 8 stories. Poor insulation, windows, HVAC and siding if any, most are built with extensive inefficient glass siding. NYC is now taxing tall buildings based on excessive energy use in an attempt to force owners to make the building more energy-efficient, most building owners say this is not possible to do.
Reasons to support T1 zoning are to have more people living in areas near mass transit. Our busses are noisy, smelly, hard surfaces, generally not ridden by large number of average residents, will not drop off riders close to homes and winter riding is not popular with snow mounds to clime and unplowed sidewalks to traverse. Our family has ridden the busses almost daily in the last 35 years and the busses, bus maintenance, design and ride has gotten terrible. Electric busses are a real option. Park and ride needs to be more effectively used as well.
Tall buildings isolate residents, setup exclusive communities and, with no parking proposed for cars, cars will over park in neighborhoods affecting the exiting long-lived reliable tax base. Many residents in current tall buildings in Ann Arbor have two cars per person not no cars. NYC is having Parking Wars Like Hunger Games due to tall buildings with no parking and mass transit aversions.
Water Utilities for T1, $300M-$400M:
Our water utilities can not take on a new huge number of residents. The only option is to tap into YUCA's water utilities at a cost of $300M-$400M, this with a current $100M upgrade going on for our existing water utilities.
Unlimited building heights is not great for cities, residents or the environment.
The proposal is for virtually all neighborhoods will have T1 zoning except Burns Park and other High-End neighborhoods, which will not be by chance.
Carbon emissions are a major contributor to Global Warming and the dangerous flooding weather patterns we are now facing. State of Michigan is having 500 year rains almost every year and 1,000 year rains now.
Link:
City proposal from late 2019 : MLive
Local in Ann Arbor: https://localinannarbor.com/2020/07/12/disruption-in-ann-arbor-its-a-promise-2/
Images of 1,000 Year Rain in Northern MI
Existing Reliable Larger Tax Base Ignored, for New Less Valuable Tax Base; 'Shiny New Thing' Syndrome or Crony Capitalism
Locations of EGLE 10-9-2020 NSG Tests (West Part is at Upper Right)
(ACWG, Rt Clk for larger)
The CARD Group has passed a resolution asking for the illicit 1,4 Dioxane pollution flowing into the Allen Creek Drain to be removed by Gelman. Gelman and EGLE have been notified of this for over 3 years with the illicit 1,4 Dioxane pollution levels in the drain continuously going up. The ACWG push for and also supports the CARD resolution.
This pollution is almost surely from the Gelman Toxic 1,4 Dioxane Plume in near-surface shallow groundwater that is picked up by the Allen's Creek Drain system that flows through West Park.
1,4 Dioxane has been found in the Allen's Creek after the ACWG asked EGLE (DEQ) to do simple tests (kinda hard for them to refuse) in West Park and 8th St as this is a known area of high groundwater flows into the Allen's Creek, which enters the drain and flows to the Huron River.
Recent tests in the drain in West Park and Chapin St in early October 2020 show a 49 ppb reading in West Park's SE corner and Chapin St at 28 ppb.
Near-Surface Shallow Groundwater (NSG) much-delayed tests come back alarmingly high:
Recent data from EGLE delayed Near-Surface Shallow Groundwater test done 10-9-20 sent out on 11-23-20 indicates that Allen's Creek stormwater on the West Side has increased dioxane values from the 2019 sampling.
West Park SW is at 49 ppb up from 22 ppb in 2019,
Chapin St. is at 28 ppb up from 9.1 ppb in 2019,
Eight St. next to Slawson Middle School is at 11 ppb up from 1 ppb in 2019.
ACWG and CARD commented that large flows of water were in the Allen's Creek pipe in South West West Park entrance and 8th St. near Slauson Middle School with very dry conditions, seeming to indicate high groundwater flows in the pipe as has been described previously. Seeps are said to be in many areas of the city on the west side including higher elevations. The elevations of found seeps will help determine risk to homeowners through potentially contaminated water infiltrating into the basement and evaporating with 1,4 Dioxane into the air of a confined basement space. Many westside homes have wet basements, some from groundwater infiltration. See the previous neighbor survey showing many homes with water issues, of the Glendale Virginia St. areas in past agenda items. Also, Pall/Gelman produced 2006 soil drilling profiles, as shown in past Agenda Items, that indicate seeps with NSG would be likely in the West Side of the city near West Park.
The illicit 1,4 Dioxane pollution flows into the Huron River are just upstream of the very popular Cascades outfall into the Huron River less than 1,500 feet away. Many people tube down the Cascades and out into the Huron River just upstream of the Allen's Creek Outlet into the river.
1,4 Dioxane in Huron River, Exposure at the Argo Cascades:
Exposures to people using the Cascades is a concern with full-body contact potential and ingesting of contaminated river water.
(Zoom Hosted by Roger Rayle; screenshot of YouTube view; Rt Clk for larger)
EPA Superfund Petitions have been delivered to Governor Whitmer. She is working on a Concurrence Letter from The State of Michigan to Petition Superfund standing for the Gelman Toxic 1,4 Dioxane Dump Site on Wager Rd. and Plume flowing in all directions from the Toxic Dump Site.
When EPA gets such a request, as Governor Whitmer is likely about to send, EPA accepts it and starts the Superfund process for full evaluation and full cleanup.
It is the ACWG and Coalition for Action on Remediation of Dioxane's (CARD) position that the EPA Superfund route is the most effective option the community has, given the fights Gelman/Pall/Donaher, a $140B company, has put up to avoid an effective cleanup for over 40 years.
Attempts to Delay City of Ann Arbor Superfund Letter of Support, Withdrawn under withering protests by constituents:
A reliable source at City Hall had indicated that the city attorney's office proposed a delay of the transmission of a City Council Resolution in support of sending a Superfund Letter of Support.
The city attorney's office should not be making policy for the city, they should be responding to city Council requests and Council should be the body that decides policy for the city. If the council wanted to not send a Superfund Support Letter to EPA then they should ask the Attorney's Office to assist in this effort, not the other way around.
New Council members Briggs (Ward 5) and Disch (Ward 1) had proposed a resolution, introduced on Friday Evening 12/4/20, to Delay the US EPA Superfund Petition, previously pasted by the city council, for Monday 12/7/20 meeting. The Resolution was removed before the Council Meeting started.
During the City Council Caucus on the prior Sunday night, extensive comments were made on why not to take this action convinced them to remove the resolution for consideration.
Mayor Taylor objects to an EPA Superfund Petition, most all other local leaders support it unanimously.
The city has now sent the Petition for US EPA Superfund Status after extensive delays and ill-conceived and very costly legal maneuvering.
With over 100 Public Comments in public comment sessions, there have been no supporters of the 4th CJ.
After extensive prodding by ACWG and CARD, Michigan Department of Environment, Great Lakes, and Energy (EGLE) has agreed to do more near-surface shallow groundwater testing but refused to do more aggressive testing of near-surface shallow groundwater that may be seeping into home's basements causing potential exposures due to high values in October 2020. ACWG and CARD have stated and Dan Bicknell has proposed a plan for permanent NSG wells back in 2016 that EGLE has not chosen to implement and they have not forced Gelman/Danaher to do it either.
The CARD Group has moved to virtual meetings like others starting in May for an undermined length of time, see details at the Washtenaw County CARD site.
Links:
January 2021 Regular Coalition for the Remediation of Dioxane (CARD) Group Meeting Video - Taped by Roger Rayle, Chair CARD
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 Lucus at Dioxane.Org and WEMU News Program GreenRoom
Washtenaw County CARD Site
See ACWG site pages EPA Superfund Option Details
Click here to view and/or sign in support of Superfund Designation
"RESOLUTION SUPPORTING THE WASHTENAW COUNTY – WATER RESOURCES COMMISSIONER ISSUING A NOTICE OF VIOLATION TO GELMAN SCIENCES, INC. FOR VIOLATION OF MS4 PERMIT COVERING THE ALLEN CREEK DRAIN" - CARD
Allen's Creek Outlet just upstream of Argo Cascades Potential Exposures
(ACWG, Rt Clk for larger)
Michigan MS4 Regulation:
'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) More details of MS4 Regulations can be found on this site in past entries.
The full Resolution can be found on CARD Google Drive File Here.
Ann Arbor City Council passed a similar or identical resolution yesterday, Tuesday.*
'Resolves' Portion of the Resolution is below written by Dan Bicknell CARD member:
"RESOLVED, That the WRC immediate prepare and issue within 30 days a Notice of Violation (NOV) to Gelman, pursuant to the WRC MS4 Permit authorities, to halt the illicit groundwater discharges into Allen Creek Drain, including immediately beginning the corrective action process to treat the contaminated groundwater to uncontaminated groundwater levels prior to infiltrating into the storm water(sic);
RESOLVED, That the NOV require that Gelman: 1) perform an Extent of Contamination (EOC) Study to delineate the extent and magnitude of the shallow dioxane groundwater contamination in the area that it is infiltrating into the Allen Creek Drain; 2) prepare a Remedial Design Investigation (RDI) to design a Corrective Action groundwater extraction and treatment system which will collect and treat the contaminated groundwater to uncontaminated levels prior to infiltrating into the storm water(sic) drain and discharge the dioxane treated groundwater; and 3) implement the Corrective Action groundwater extraction and treatment system until the MS4 Permit compliance is attained by Gelman. As the dioxane groundwater concentrations are increasing and will increase with time, the option of developing a plan to consider a time for the pollutant concentrations to reduce to uncontaminated levels (such as a five year period) is not a viable regulatory compliance option;
RESOLVED, That the NOV require that: 1) Gelman immediately begin the design, obtain WRC approval of and complete the EOC Study within four months from the issuance of the NOV; 2) Gelman design, obtain WRC approval of and complete the RDI within five months of the EOC Study completion; and 3) Gelman begin implementation of the Corrective Action within two months of the RDI completion;
RESOLVED, That the NOV require that Gelman be responsible for the civil and criminal fines and penalties for violating the MS4 Permit since November 2019, when the documented illicit dioxane plume infiltration was made public in the November 2019 - Allen Creek Drain Sampling Investigation Summary Report (EGLE site);
RESOLVED, That the City of Ann Arbor, Washtenaw County, and the State of Michigan support the WRC in requiring Gelman to attain compliance with the MS4 Permit; and RESOLVED, That the CARD Secretary send this resolution to the City of Ann Arbor, Washtenaw County, Washtenaw County delegation to the Michigan Legislature, the Director of the Michigan Department of Environment, Great Lakes, and Energy, and the Region Administrator - United States Environmental Protection Agency - Region V."
Link: Michigan MS4 Regulation
Full Resolution CARD Google Drive File Here.
City of Ann Arbor to Consider Development at 700 N Main. Near North, Adjacent to the Very Poorly Delineated and Dangerous Allen's Creek Floodway and Floodplain; The Only Auto Exit is Directly into Floodway
700 N Main; Near North, Plans to Build Homes Right Up to the Floodway and Floodplain
Only Auto Exits from Parking Are Directly Into the Floodway and Floodplain
(Blue Arrows with Flood Indicators ACWG; Rt Clk for larger)
700 N Main
(ACWG, Rt Clk for larger)
Ann Arbor Planning Commission voted to support the Near North development of Condos up against the 100-year (1% chance) floodway and floodplain.
As you can see in the First Street Foundation FloodFactor(R) map above, 3 to 4 feet of floodwater just outside the only car access point to the building parking entrance.
Having the only exits from the building into floodwater is unacceptable especially when know FEMA is lowballing Floodplain by 30% and we are expecting larger than normal rain events due to Global Warming as reported by many scientist.
If credible studies are correct the floodplain and floodway are likely much larger now or in the near future and may be blocked by the new building with unnecessary flooding and danger to life, health and property upstream of this site.
OHM 2017 FIRM New Berm Opening at the RR Tracks Analysis generally does not show much change (reduction) in this floodplain at this location, contrary to some county and other official's comments.
This is the same site where the 1.2-acre development site was given a special Planned Unit Development zoning designation over a decade ago for an Avalon Housing affordable housing project that had to be scrapped at great cost. The project was scrapped after FEMA federal flood map updates just before groundbreaking showed major changes and made it ineligible for federal assistance.
We have a new development on W Kingsley with one of two exits into the floodway where cars driving down W Kingsley have been disabled and drivers rescued in floodwater in recent years.
Car Stalling On W Kingsley St in Floodwaters in Allen's Creek Floodway
(AA Chronicle; Rt clk for larger)
Cars Disabled and Cars Attempting to Exit Martin Building In Floodwaters of the Floodway
on Depot St. in Recently Built Building's Parking Lot, 2010
First Street Foundation Flood Factor(R) Models Lookup.
City of Ann Arbor Considers a Development at the 1st and William Site in the Very Dangerous Allen's Creek Floodway, Again; Much Un-Communicated Higher Flood Hazard on the Old West Side
(ACWG, Rt Clk for larger)
Developing sites in the floodway will cause more flood hazard for those upstream, in the Old West Side, who may not know they are in more danger, may not know they should have very expensive flood insurance and may not be willing to take on this extreme danger for the sake of Developers profits. Flood hazard in Ann Arbor and Michigan has gone up significantly in recent years.
The Existing Decades-Long Tax Base (Old West Side) you may destroy is worth much more than the new tax base if done in the Floodway.
The ACWG with others helped stop an ill-advised parking garage development on this site some years ago. The ACWG FOIAed a DDA funded watershed study of the site at the time.
FTCH Consultants Floodway Floodplain Study of this Site, Still Not Released:
As we asked before and FOIA'ed the DDA - we would like to see the FTCH Study: The DDA's FTCH $1/4 to $1/2M budgeted consultants study of the watershed of this site should be made available to the public. The ACWG FOIA'ed the study but was just given a copy of the raw data and model run data used to do models but the report was never offered. FTCH said the DDA had to agree to make it available which they never did. These results were said to ACWG to be 'Very Surprising' by FTCH. SNRE scientist's quick review of the raw data released to ACWG at the time indicated extremely flood water high flows (and likely a very deep floodway) in a 100 year (1% chance) flood event, it also showed higher flows than the Huron River we were told.
Follow Adopted goals of the 2007 Flood Hazard Mitigation Plan:
We should follow the Long-Past Adopted goals of the 2007 Flood Hazard Mitigation Plan the ACWG contributed to: "Public acquisition and management of flood-prone properties. Permanent relocation of flood-prone structures to areas outside the floodplain. Establish a clear and consistent government policy for public-owned land in the floodplain aimed at preventing public buildings in the floodplain. Create Allen['s] Creek Greenway in the floodplain area. Regular data collection and modeling to update flood hazard maps Decrease Flood Insurance Rates by meeting FEMA required flood hazard mitigation recommendations." (bold by us)
With new data on much worse flood hazards with Global Warming in Michigan, and FEMA Low Balling Flood maps across the US (see CityLab article), we need to protect public life, health and property with this new awareness, not ignore it.
Cars and a parking garage in the floodway are not benign. This is a potential site of a park for the Greenway which would not exacerbate flooding like a structure.
Link:
FEMA flood maps have been reported to be 'low balled' by FEMA in recent studies, and could be 33% times higher risk of flooding then is in the FEMA maps, CityLab article
First Street Foundation Flood Factor(R) Models Lookup.
National Flooding Risk Index released by the Federal Emergency Management Agency:
- Washtenaw Ranks Highest In MI
U of M Ath. Campus, Mary St. Flooding in Recent Years
(ACWG, Rt Clk for larger)
National Risk Index released by the Federal Emergency Management Agency:
In this new project, FEMA calculated a risk score for every county in America, looking at 18 types of natural disasters,...
"Flooding: Estimated total annual loss is about $105 million statewide, with about one death a year.
Top counties in the likelihood of occurrence:
Lenawee, Macomb, Saginaw, Washtenaw and Wayne." MLive. (bold by us)
University of Wisconsin-Madison: Small Streams Have Big Impacts on Great Lakes, 235 Small Streams Sampled
One of the Few Open Sections of the Eberwhite Branch of Allen's Creek - Ann Arbor. Michigan
Cover Image for the ACWG Watershed Management Plan (on Main ACWG webpage)
(ACWG, Rt Clk for larger)
In the summer of 2018, Rob Mooney, a graduate student at the University of Wisconsin-Madison's Center for Limnology took a snapshot of a total of 235 tributaries that empty into Lake Michigan to study the effects of small streams on the Great Lakes.
"The primary goal was to understand how small tributaries contributed to what scientists call nutrient loading, where elements like the nitrogen and phosphorus found in agricultural fertilizers run off of the land and into downstream waters. These nutrients are also good at fertilizing algal growth and lead, among other things, to potentially toxic algal blooms and oxygen-starved dead zones."
“Within the Great Lakes there are hundreds and hundreds of small tributaries that are flowing in but, for the most part, they haven't been considered by previous nutrient-loading studies because they're so small compared to the big ones,”
" Smaller tributaries often had nutrient loads that were high for their size and, more important to water-quality concerns, contained higher percentages of soluble reactive phosphorus, a compound that is readily available for nutrient-starved algae or aquatic plants to snap up and use to feed their growth."
The ACWG has commented that our watershed has large effects big and small locally and regionally. That is why we have spearheaded locally for well over two decades - EPA Superfund 1,4 Dioxane Cleanup, Ann Arbor Green Streets, Road Dieting, use of Porous Pavements, Rain Gardens, BioSwales, Rain Barrels, Daylighting (Not Enclosing) Streams, the Allen's Creek Greenway (Allen Creek - Treeline), Footer Disconnects, Flood Safe Developments, Strengthen Flood Hazard Rules Related to Global Warming Threats, Allen's Creek Berm Opening Into Huron River, among others.
The Allen's Creek flows into the Huron River and to Lake Erie, which has had large and very dangerous, and costly algal blooms in recent years.
Also see our adopted Allen's Creek Watershed Management Plan, show on our ACWG front page, with lots of details on watershed friendly community management.*
Link:
Small Streams Have Big Impacts on Great Lakes
https://phys.org/news/2020-10-summer-road-small-streams-big.amp
December 2020 - No Meeting this month due to COVID-19 Pandemic Cautions
Watershed Issues of Interest and Updates:
Danaher/Pall/Gelman 1,4-Dioxane Plume - EPA Superfund Petitions Being Sent; Washtenaw County Board Passes EPA SUPERFUND, Scio Township Board Passes EPA SUPERFUND Petition Resolution
Informal EPA Superfund CARD Table Poll at Green Fair 2019,
Support EPA Superfund Status Results were 61-YES, 0-NO as shown,
as posted here previously ( Rt Clk for larger, ACWG)
(Rt Clk for larger; ACWG)
Officials from all local governments have or will be sending EPA Superfund Petitions for Gelman/Danaher Toxic Waste Dump and Toxic Plume out to Governor Whitmer.
Washtenaw County Board of Commissioner Unanimously Adopts Superfund Resolution for Gelman/Danaher Toxic 1,4 Dioxane Plume.
Scio Township Board of Trustees voted to reject the 4th CJ. They also voted to support US EPA Superfund Petition, in a 6-1 vote, joining the other government and environmental advocacy groups in the Ann Arbor Area. CARD and ACWG made vocal and written comment in support of the winning position. MLive Article.
Attempts to Delay City of Ann Arbor Superfund Letter of Support, Withdrawn under withering protests by constituents:
New Council members Briggs (Ward 5) and Disch (Ward 1) had proposed a resolution, introduced on Friday Evening 12/4/20, to Delay the US EPA Superfund Petition, previously pasted by the city council, for Monday 12/7/20 meeting.
During the City Council Caucus Sunday night, extensive comments were made on why not to take this action convinced them to remove the resolution for consideration. The main reason I and others made were that both a legal effort and a Superfund effort can occur at the same time. ACWG made written comment in support of the canceling of the resolution.
An experienced trial lawyer commented in the Causas they had no idea legally what they were suggesting in the proposed resolution.
It is the ACWG's position that the EPA Superfund route is the most effective option the community has, given the fights Gelman/Donaher, a $140B company, has put up to avoid an effective cleanup for over 40 years. MLive Article.
Did Mayor Taylor decide to not Veto the Council Resolution he had voted against and he said he would veto, and allow Newbee Council members to "Carry His Water" even though it is questionable if they can delay a Passed Resolution when they were not involved in the vote and did not vote on the winning side?
Mayor Taylor's law firm has much to gain if the city does not petition the EPA for Superfund with Hundreds of Thousands already paid to his law firm on a totally unsupported 4th CJ they helped to negotiate.
Mayor Taylor objects to an EPA Superfund Petition, all other local leaders support it unanimously.
The city will now be sending a Petition for US EPA Superfund Status after extensive delays and ill-conceived and very costly legal maneuvering.
With over 100 Public Comments in public comment sessions, there have been no supporters of the 4th CJ.
Near-Surface Shallow Groundwater (NSG) much-delayed tests come back alarmingly high:
Recent data from Michigan Department of Environment, Great Lakes, and Energy (EGLE) delayed Near-Surface Shallow Groundwater test done 10-9-20 sent out on 11-23-20 indicates that Allen's Creek stormwater on the West Side has increased dioxane values from the 2019 sampling.
Locations of EGLE 10-9-2020 NSG Tests (West Part is at Upper Right)
(ACWG, Rt Clk for larger)
West Park SW is at 49 ppb up from 22 ppb in 2019,
Chapin St. is at 28 ppb up from 9.1 ppb in 2019,
Eight St. next to Slawson Middle School is at 11 ppb up from 1 ppb in 2019.
EGLE should not be ignoring these major changes in NSG and potential exposures in homes and businesses.
EGLE has written that given some assumptions related to Dr. Bailey's (saved on our ACWG site) Vapor Intrusion (VI) work, like homes with wet basements, 29 ppb would be a potentially dangerous VI value in homes or businesses with wet basements almost all year.
EGLE and EPA have indicated a value of 29 ppb in NSG near homes or buildings as a vapor-intrusion (VI) screening level when first published. Currently, 100 ppb seems to be a better value given most circumstances and recent current analysis by EGAL and others.*
EGLE has refused to do more aggressive testing of near-surface shallow groundwater that may seep into home's basements causing potential exposures due to high values in October 2020. ACWG and CARD have stated and Dan Bicknell has proposed a plan for permanent NSG wells back in 2016 that EGLE has not chosen to implement and they have not forced Gelman/Danaher to do it either.
City-sponsored tests for basement water are looking to test for 28 ppb in standing water as commented on by Patti McCall (Tetra Tech) at December CARD Meeting. Unfortunately, this test is not designed for use with homes having wet basements (not flooded) that can expose residents to vapor from 1,4 Dioxane contaminated NSG seeping into homes and evaporating.
Roger Rayle CARD/SRSW Chair, Artesian areas in Green ( Rt Clk for larger)
Roger Rayle has produced a map, above, showing the know areas of Artesian NSG on the west side in Green. This map agrees with recent findings of 1,4 Dioxane in NSG up to 49 ppb. Other areas of the city have NSG that is a potential exposure issue for homeowners and businesses.
Comments at the last CARD meeting from a resident, who lives north of West Park in the Prohibition Zone, stated he and most of his neighbors have wet basements. He vacuums up a gallon or more of water at least 4 times a year in his wet basement and expressed concerns of potential exposure issues in his home.
Reports about Wuster Park, W Madison and 5th St. have had NSG issues which are at a higher elevation and south of West Park area.
The Allen's Creek Group (ACWG.ORG) supports an EPA Superfund Petition and Cleanup.
We support Dan Bicknell's comments shown below in support of an EPA Superfund Petition and Cleanup.
The CARD and ACWG were instrumental in the state adoption of Vapor Intrusion (VI) Rules recently, according to comments to ACWG from MDEQ/EGLE officials at the VI Introduction Public Meeting. This danger to residents should not be ignored.
The majority in MI State Government are pushing Polluter Pay right now. We will have new fairer Districts in MI in 2022, with much more progressive outcomes. We support that effort and think in the near future MI will have this again, and Gelman will be forced to do a meaningful cleanup if EPA Superfund has not.
Danaher should be using the best available technologies for the cleanup. Gelman has and can treat to Non-Detect, below 1 ppb it just cost slightly more.
Lower high contamination aquifers will cross-talk with near-surface aquifers and be contaminated which could expose people in residential and business structures.
We Support Dan Bicknell's comments below in support of EPA Superfund cleanup (see below).
EPA initial evaluation of the Gelman Plume site initially Scored Very High for a Superfund cleanup full evaluation.
Senator Stabenow told me in 2016, after Donald Trump took office, EPA will still be doing polluter pay cleanup, it's the orphaned sites that are a real problem. This is not an Orphaned Site.
Now with President Biden EPA will be under new more aggressive management.
Danaher is on the hook for this cleanup according to several comments by Mitch Adelman of MDEQ/EGEL (EGLE Jackson Office District Head at the time) in MDEQ public meetings when asked.
With all the significant hard work the CARD group, city and county have done the EPA will have a headstart on this effort. The EPA Score of the partial Superfund Evaluation was very high for Superfund Listing with a minimal evaluation. In this case, we have a Responsible Party that EPA will require to do and pay for cleanup as is happening now with other sites all over the country.
This revised proposed roundly rejected 4th CJ is basically an exit route for Danaher and Gelman with a partial cleanup and not further action required by law.
SuperFund is the most prudent path for Gelman Full Cleanup; this from Dan Bicknell (CARD Member, former SuperFund Manager, President of GEA):
"The main USEPA Superfund Site benefits, based upon similar sites, were detailed by USEPA – Region V - Office Of Superfund in a July 25, 2016 meeting/call with the City, County and Townships representatives. They include:
Active restoration of the aquifer to a protective drinking water criterion, regardless of whether the dioxane plume is in a Prohibition Zone or not with Gelman paying the clean-up costs;
As a first USEPA priority, extend the municipal drinking water supply to any resident who may be potentially adversely impacted by the dioxane contaminated groundwater at a Gelman cost;
Halt the expansion of the dioxane groundwater contamination and treat the source and outer margins of the dioxane plume with an active remedial technology like groundwater extraction and treatment;
The active remedial action would prevent the dioxane contamination of Barton Pond, so no additional Contingency Plan would be required to protect Barton Pond.
The USEPA will require that Gelman pay for residential well sampling and dioxane analysis at homes immediately down-gradient of the dioxane plume;
The USEPA will require a monitoring well network which will establish the full extent and magnitude of the dioxane groundwater contamination, including the Old West Side and West Park areas of the City;
The USEPA offers Community Grants (e.g., $50K) to support public input into the Superfund Site cleanup process; and
The USEPA has the technical, administrative and legal resources to establish a protective federal Administrative Order and provide high-quality oversight of Gelman in the clean-up with the backing of the US Department of Justice and USEPA Regional Counsel."
EPA Superfund will be the most effective cleanup and protect the economic status of the area. Economic research has shown when you have uncertainty with a contaminated site this is the least protective option of economic status for a community.
The University of Michigan has not supported EPA Superfund but it clearly is in their best interest to see a Superfund cleanup that will be faster and more effective, and maintain the positive status of the community. Most unfortunately they have been minimally involved with the public on this matter.
The CARD Group has moved to virtual meetings like others starting in May for an undermined length of time, see details at the Washtenaw County CARD site.
Links:
December 2020 Regular Coalition for Action on Remediation of Dioxane (CARD) Group Meeting Video - Taped by Roger Rayle, Chair CARD
Gelman Plume Related Stories by Ann Arbor News/MLive: MLive
Ann Arbor-area officials delay Gelman plume decision another month: MLive Ryan Stanton
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 Lucus at Dioxane.Org and WEMU News Program GreenRoom
Washtenaw County CARD Site
See ACWG site pages EPA Superfund Option Details
Click here to view and/or sign in support of Superfund Designation
Water Resources Commissioner Office Changes Mind Suggest an MS4 Violations in Allen's Creek from Gelman 1,4 Dioxane at 49 ppb Flowing to the Huron River
EGLE and City Staff assisting tests in West Park Allen's Creek Drain SW Path 2018
(ACWG, Rt Clk for larger)
ACWG and CARD felt that Near-Surface Shallow Groundwater (NSG) should be tested but it was very hard to get these tests done. Asking for tests in the Allen's Creek drain grates was simple and hard to refuse for DEQ/EGLE and have shown a clear increasing level of Gelman's Toxic Plume moving to the NSG and posing a risk to residents, businesses and the environment.
Water Resources Commissioner Office (WRCO) has commented at the last CARD meeting that they have changed their minds and are now interested in a potential MS4 violation (details below) by Gelman/Danaher for the continued rise in 1,4 Dioxane in the Allen's Creek flowing through West Park, now at 49 ppb in the October 2020 test.
The tests on 8th St. Allen's Creek flow also should be of concern, now at 11 ppb in the October 2029 tests and rising.
As I commented at the December 12th Joint Session of EGLE and local government bodies, during public comment at this meeting, we have a Gelman's Illicit Discharge into a Michigan MS4 system for over 3 years now, the Allen's Creek flowing to the Huron River, Dan Bicknell GEA has investigated and communicated in more detail on the issues of MS4.
ACWG and CARD commented that large flows of water were in the Allen's Creek pipe in South West West Park entrance with very dry conditions, seeming to indicate high groundwater flows in the pipe as has been described previously. Seeps are said to be in many areas of the city on the west side including higher elevations. The elevations of found seeps will help determine risk to homeowners through potentially contaminated water infiltrating into the basement and evaporating with 1,4 Dioxane into the air of a confined basement space. Many westside homes have wet basements, some from groundwater infiltration. See the previous neighbor survey showing many homes with water issues, of the Glendale Virginia St. areas in past agenda items. Also, Pall/Gelman produced 2006 soil drilling profiles, as shown in past Agenda Items, that indicate seeps with NSG would be likely in the West Side of the city near West Park.
Michigan MS4 Regulation:
'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)
Under the MS4 permit, it would seem no dioxane contamination at any level should be legally allowed to infiltrate/seep into the MS4 storm drain (without an NPDS Permit which they do not seem to have), Allen's Creek at West Park for example, yet it clearly has for 3 years.
Link: Michigan MS4 Regulation
Update 12/8/20*
Scio Township Board of Trustees voted to reject the 4th CJ. They also voted to support US EPA Superfund Petition, in a 6-1 vote, joining the other government and environmental advocacy groups in the Ann Arbor Area. CARD and ACWG made vocal and written comment in support of the winning position. MLive Article.
Update 12/7/20*
Council members Briggs (Ward 5) and Disch (Ward 1) had proposed a resolution, introduced on Friday Evening 12/4/20, to Delay the US EPA Superfund Petition previously pasted by the city for Monday 12/7/20 meeting. During the City Council Caucus Sunday night, extensive comments were made on why not to take this action convinced them to remove the resolution for consideration. The main reason I and others made were that both a legal effort and an Superfund effort can occur at the same time. ACWG made written comment in support of the canceling of the resolution. It is the ACWG's position that the EPA Superfund route is the most effective option the community has, given the fights Gelman/Donaher, a $140B company, has put up to avoid an effective cleanup for over 40 years. MLive Article.
Update 11/23/20*
Recent data from EGLE delayed Near-Surface Shallow Groundwater tests sent out on 11-23-20 indicates that Allen's Creek storm water on the West Side has increased dioxane values from the 2019 sampling.
West Park is at 49 ppb from 22 ppb in 2019,
Eight St. next to Slawson Middle School is at 11 ppb from 1 ppb in 2019, and
Chapin St. is at 28 ppb from 9.1 ppb in 2019.
November 2020 - No Meeting this month due to COVID-19 Pandemic Cautions
Watershed Issues of Interest and Updates:
Danaher/Pall/Gelman 1,4-Dioxane Plume - 4th Consent Judgement Largely Rejected, City Council Passes EPA SUPERFUND Petition Resolution, CARD Passes EPA SUPERFUND Petition Resolution
Informal EPA Superfund CARD Table Poll at Green Fair 2019,
Support EPA Superfund Status Results were 61-YES, 0-NO as shown,
as posted here previously (Rt Clk for larger; ACWG)
City of Ann Arbor adopts Superfund Petition Resolution for Gelman/Danaher Toxic 1,4 Dioxane Plume November 5th in a 6 to 5 vote. Those voting against are Major Taylor, CM Grand, CM Ackerman, CM Smith and CM Lumm.*
Washtenaw County Commissioners voted unanimously to reject, Ann Arbor Charter Township unanimous vote to reject, Sierra Club Huron Valley Group, Ann Arbor Environmental Commission, Scio Residents for Safe Water all voted to reject this 4th Consent Judgement for Gelman Polluter Cleanup Proposal (4th CJ). (see this ACWG Side Bar Page 10/10/2020 Resolution - CARD Group Reject the Proposed Gelman 4th Consent Judgement or agenda items below for more details on the 4th CJ)
CARD Adopts Superfund Resolution for Gelman/Danaher Toxic 1,4 Dioxane Plume, see details and resolution below, and now posted on our web site.
In all the Public Comment sessions to date there have been no supporters of the CJ.
The Allen's Creek Group (ACWG.ORG) supports an EPA Superfund Petition and Cleanup.
We support Dan Bicknell's comments shown below in support of an EPA Superfund Petition and Cleanup.
The CARD and ACWG were instrumental in the state adoption of Vapor Intrusion (VI) Rules recently, according to comments to ACWG from MDEQ/Michigan Department of Environment, Great Lakes, and Energy (EGLE) officials at the VI Introduction Public Meeting. This danger to residents should not be ignored.
The majority in MI State Government are pushing Polluter Pay right now. We will have new fairer Districts in MI in 2022, with much more progressive outcomes. We support that effort and think in the near future MI will have this again, and Gelman will be forced to do a meaningful cleanup if EPA Superfund has not.
Danaher should be using the best available technologies for the cleanup. Gelman has and can treat to Non-Detect, below 1 ppb it just cost slightly more.
EGLE is slow in getting the latest near-surface/shallow groundwater tests back, over a month late. West Park was last tested months ago and was at 22ppb. Action level for NSG, on a house with a wet basement year round, could be 29ppb.
Lower high contamination aquifers will cross-talk with near-surface aquifers and be contaminated which could expose people in residential and business structures.
We Support Dan Bicknell's comments below in support of EPA Superfund cleanup (see below).
EPA initial evaluation of the Gelman Plume site initially Scored Very High for a Superfund cleanup full evaluation.
Senator Stabenow told me in 2016, after Donald Trump took office, EPA will still be doing polluter pay cleanup, it's the orphaned sites that are a real problem. This is not an Orphaned Site.
Danaher is on the hook for this cleanup according to several comments by Mitch Adelman of MDEQ/EGEL in MDEQ public meetings when asked.
With all the significant hard work the CARD group, city and county have done the EPA will have a headstart on this effort. The EPA Score of the partial Superfund Evaluation was very high for Superfund Listing with a minimal evaluation. In this case, we have a Responsible Party that EPA will require to do and pay for cleanup as is happening now with other sites all over the country.
This revised proposed CJ is basically an exit route for Danaher and Gelman with a partial cleanup and not further action required by law.
SuperFund is the most prudent path for Gelman Full Cleanup; this from Dan Bicknell (CARD Member, former SuperFund Manager, President of GEA):
"The main USEPA Superfund Site benefits, based upon similar sites, were detailed by USEPA – Region V - Office Of Superfund in a July 25, 2016 meeting/call with the City, County and Townships representatives. They include:
Active restoration of the aquifer to a protective drinking water criterion, regardless of whether the dioxane plume is in a Prohibition Zone or not with Gelman paying the clean-up costs;
As a first USEPA priority, extend the municipal drinking water supply to any resident who may be potentially adversely impacted by the dioxane contaminated groundwater at a Gelman cost;
Halt the expansion of the dioxane groundwater contamination and treat the source and outer margins of the dioxane plume with an active remedial technology like groundwater extraction and treatment;
The active remedial action would prevent the dioxane contamination of Barton Pond, so no additional Contingency Plan would be required to protect Barton Pond.
The USEPA will require that Gelman pay for residential well sampling and dioxane analysis at homes immediately down-gradient of the dioxane plume;
The USEPA will require a monitoring well network which will establish the full extent and magnitude of the dioxane groundwater contamination, including the Old West Side and West Park areas of the City;
The USEPA offers Community Grants (e.g., $50K) to support public input into the Superfund Site cleanup process; and
The USEPA has the technical, administrative and legal resources to establish a protective federal Administrative Order and provide high-quality oversight of Gelman in the clean-up with the backing of the US Department of Justice and USEPA Regional Counsel."
EPA Superfund will be the most effective cleanup and protect the economic status of the area. Economic research has shown when you have uncertainty with a contaminated site this is the least protective option of economic status for a community.
The University of Michigan has not supported EPA Superfund but it clearly is in their best interest to see a Superfund cleanup that will be faster and more effective and maintain the positive status of the community. Most unfortunately they have been minimally involved with the public on this matter.
In the EGLE Public Comment Zoom meeting on September 14 all the public comments were negative, not in support of the Proposed CJ, no positive public comments were made.
The Ann Arbor Township, Scio Township, Washtenaw County Board of Commissions, Sierra Club Huron Valley Group, CARD and ACWG all voted in supported a petition to the US EPA for Full Preliminary Assessment of the Gelman 1,4-Dioxane groundwater contamination.
Governor Whitmer would be much more approachable than our previous Republican Governor when we present her with a US EPA Full Preliminary Assessment in a Superfund Petition. The former governor refused to allow US EPA to do a Full Evaluation when requested by US EPA.
The CARD Group has moved to virtual meetings like others starting in May for an undermined length of time, see details at the Washtenaw County CARD site.
Links:
November 2020 Regular Coalition for the Remediation of Dioxane (CARD) Group Meeting Video - Taped by Roger Rayle, Chair CARD
10/10/2020 Resolution - CARD Group Reject the Proposed Gelman 4th Consent Judgement
Gelman Plume Related Stories by Ann Arbor News/MLive: MLive
Ann Arbor-area officials delay Gelman plume decision another month: MLive Ryan Stanton
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 Lucus at Dioxane.Org and WEMU News Program GreenRoom
Washtenaw County CARD Site
See ACWG site pages EPA Superfund Option Details
Click here to view and/or sign in support of Superfund Designation
CARD Adopts Superfund Resolution for Gelman/Danaher Toxic 1,4 Dioxane Plume
USEPA
Full Voting Members of CARD unanimously adopts Resolution to Support US EPA Superfund Petition yesterday on November 16, '20.
This is a resolution CARD adopted at the last meeting on Tuesday, 11-10-20.
Full CARD Resolution Petition for US EPA Superfund is shown on ACWG Page Here.
CARD Petition Resolved Clauses:
"NOW, THEREFORE, IT IS RESOLVED, That CARD supports that the Gelman Site be designated as a USEPA Superfund Site under the Comprehensive Environmental Response, Compensation, and Liability Act and that the USEPA be the lead agency;
RESOLVED , That CARD supports the Governor sending a Concurrence Letter to USEPA for the continuation of the National Priorities List designation process to have the Gelman Site designated as a USEPA Superfund Site;
RESOLVED , That CARD authorizes its Secretary to support the designation of the Gelman Site as a USEPA Superfund Site; and
RESOLVED , That a copy of this resolution be sent to the Washtenaw County Board of Commissioners and its delegation to the Michigan Legislature, the Governor of the State of Michigan, the Director of EGLE, Congresswoman Debbie Dingell, Michigan’s U.S. Senators Debbie Stabenow and Gary Peters, the City of Ann Arbor City Council, Scio Township Board of Trustees and Ann Arbor Charter Township Board of Trustees."
NPR: "Undisclosed: Most Homebuyers And Renters Aren't Warned About Flood Or Wildfire Risk"
NRDC 2018, MI Ranks Low ( Rt clk for larger)
From the NPR Report:
" None of the landlords, real estate agents, sellers, appraisers, bankers or home inspectors the families interacted with explained the risk of flooding or wildfires, because no one had to do so.
Every American pays the price for the lack of information, whether or not they have been directly affected by a flood or wildfire. The annual number of floods and wildfires that exceed $1 billion in damage has exploded in recent years. Between 2015 and this September, there were 28 such disasters. Taxpayers foot the bill directly when the federal government pays out billions of dollars in disaster relief." (bold by us)
Unfortunately, Ann Arbor has a long and sordid history of placing less fortunate city residents in affordable housing in the floodway and floodplain, and many still exist, including the current Homeless Shelter in the floodplain with some of the emergency exits into the floodway.
Depot St. Flooding in Recently Built Martin Building Parking Lot 2010, YouTube
The recently build First Martin Building on Depot St., in the floodplain and floodplain was so flood-prone we have had YouTube videos posted of the flooding as workers tried to escape in their cars from the flooding. Link and Link to videos on Youtube. "What the F#$% Ann Arbor': YouTube comments from traped First Martin Building occupants trying to avoid very common flooding at the site.
Affordable Housing Mileage funds are now not allowed to be used in Ann Arbor floodplains, as Council Member Ali Ramlawi recently proposed and got passed in an amendment to the resolution that would have allowed funds from the Affordable Housing Millage to be used in the floodplains. ACWG strongly lobbied for this change.
Current Mayor Taylor and CM Grand voted against the amendment.
Link: NPR, https://www.npr.org/2020/10/18/918725965/undisclosed-most-homebuyers-and-renters-arent-warned-about-flood-or-wildfire-ris
NPR: Most Tenants Get No Information About Flooding. It Can Cost Them Dearly.
W. Kingsley St Flooding 4" Rain, Flooding Affecting New Homes
in Ann Arbor, July 2020. Cars would be flooded/disabled/destroyed leaving this
new building onto W. Kingsley especially in the dark.
( Rt clk for larger; ACWG)
First Street Foundation Flood Factor(R) 410 N 1st St. Ann Arbor
First Street Foundation Flood Factor(R) Models for Recent Developments
at/near 410 N1st St. in the Floodplain, Which Includes Global Warming
Effects for More Accurate Flood Mapping ( Rt clk for larger)
First Street Foundation Flood Factor(R) Models for 721 N Main in the Floodplain
100 year (1% chance), Which Includes Global Warming Effects for More Accurate Flood Mapping
( Rt clk for larger)
NPR.ORG: Most Tenants Get No Information About Flooding. It Can Cost Them Dearly.
October 22, 2020
“... many homeowners in the most flood-prone areas are required to purchase flood insurance, which means mortgage lenders inform them of their flood risk. That's in stark contrast with tenants: The vast majority of renters such as Daniels are not entitled to any information about flood dangers.”
“An NPR review of the laws in 29 states that require disclosure of flood risk during real estate transactions found that only one mentions tenants.”
“Renters who lost their belongings in a flood are ineligible for some types of federal assistance available to homeowners. “ (bold by us)
Ann Arbor is proposing more and more homes and rental properties be built in flood-prone areas of the city. Yet renters are generally lower-income and not aware they are moving into a dangerous home. This when FEMA is lowballing floodplain maps across America at up to 30% less than the actual flood risk and not using Global Warming effects in its flood models.
City of Ann Arbor does not use Global Warming effects, which are significant, in its floodplain maps unlike First Street Foundation and others, and relies on FEMA mapping which has been shown to be lowballing floodplain maps we use by up to 30% below the current flood elevations in the US.
Link: https://www.npr.org/2020/10/22/922270655/most-tenants-get-no-information-about-flooding-it-can-cost-them-dearly
Update 11-17-20*
CARD Full Voting Membership Unanimously Adopts Superfund Resolution for Gelman/Danaher Toxic 1,4 Dioxane Plume;
Link to CARD Adopted EPA Superfund Resolution on ACWG
Update 10-19-20*
CARD has voted Oct. 18th, by a unanimous vote of voting members,
to NOT SUPPORT the Gelman 4th Consent Judgement and strongly urges our local government officials to immediately jointly pursue a Petition to US EPA for Superfund Status.
Link to CARD Resolution Page on ACWG.ORG (also on Site Page Navigation List)
Ann Arbor City Council also voted to
NOT SUPPORT the Gelman 4th Consent Judgement at the Oct. 19, 2020 Regular City Council Meeting
Link: Ryan Stanton MLive Article
October 2020 - No Meeting this month due to COVID-19 Pandemic Cautions
Watershed Issues of Interest and Updates:
Danaher/Pall/Gelman 1,4-Dioxane Plume - Proposed 4th Consent Judgement Negotiations Have Concluded, Public Input Requested Prior to Government Bodies Vote to Accept or Reject, Many Have Already Rejected
Vince Caruso Discusses Gelman Contaminated Groundwater Issues in
CARD Presentation at City Council Gelman Work Session 2019
( Rt Clk for larger; ACWG)
Informal EPA Superfund CARD Table Poll at Green Fair 2019,
Support EPA Superfund Status Results were 61-YES, 0-NO as shown,
as posted here previously ( Rt Clk for larger, ACWG)*
Michigan Department of Environment, Great Lakes, and Energy (EGLE) and City Council members have indicated a proposed 4th Consent Judgement (CJ) Agreement with Danaher/Pall/Gelman on the "cleanup" of the 1,4-Dioxane plume is done with negotiations and released for viewing and comment. City, County and Townships will have Public Comment options. EGLE had Public Comment recently, details below.
City Council in a public meeting will be discussing the proposed CJ later in October, and likely to vote on acceptance or rejection.
In all the Public Comment session there have been no supporters of the CJ.
Mayor Taylor's comments WEMU news story 'Virtual Q&A Meeting Will Be Held Tonight To Discuss 1,4 Dioxane Plume':
Mayor Christopher Taylor: "I don’t believe that EPA engagement is likely to result in anything better. And it will certainly take years, if not decades, before a plan is even devised."
This comment seems to have no basis in fact.
Some benefits in the Proposed CJ but,
Ann Arbor Charter Township unanimous vote to reject, Sierra Club Huron Valley Group, Ann Arbor Environmental Commission, Scio Residents for Safe Water all voted to reject this 4th CJ.
The Allen's Creek Group (ACWG.ORG) does not support this Proposed CJ, we support an EPA Superfund Petition and Cleanup.
We support Dan Bicknell's comments shown below in support of an EPA Superfund Petition and Cleanup.
The ACWG and CARD were instrumental in the state adoption of Vapor Intrusion Rules recently, according to comments to ACWG from MDEQ/EGLE officials at the VI Introduction Public Meeting. This danger to residents should not be ignored.
EGLE/DEQ: Not Capable: Some Past Comments and Actions -
Natural Blocking agent at Barton Pond, Ann Arbor Drinking Water Source (95%), this is not true
No preferred flow to Barton past M14 described by MDEQ, this is not true
No effort to test to bedrock at the core where suspected high concentrations exist
2M ppb contaminated soils ignored till GW cleaned up is done, ill-advised
Vapor Intrusion (VI) exposures not seriously considered
ACWG and CARD forced VI analysis and tests
Still no clear evaluation by EGLE of CARD Member Dr. Robert Bailey's VI Analysis showing a 100 ppb Action Level not EGLE's 2,800 ppb
EGLE has written that given some assumptions related to Dr. Bailey's work like homes with wet basements, 29 ppb would be a potentially dangerous VI value.
We now have 22ppb at West Park in NSG, a real threat to residents and businesses.
Years of MS4 Violations Allen's Creek West Park not being addressed.
Went to court with Gelman that lasted for decades with very poor results, no real cleanup of the soils or groundwater, with many residential wells and our city well contaminated.
Larry Lemke Consultant working on CJ seems Conflicted:
Stated to CARD in a recorded meeting in recent years - there is no blocking at Barton as presented by MDEQ
and he said, in fact, there is preferred flow to Barton
He has since reversed positions on these and other points
No comment on VI ppb, or soils very high ppb - 2M ppb;
No obvious explanation as to his change in his opinions
Leadership at city hall is lacking, inattentive.
Surprisingly and alarmingly Mayor Taylor was uninformed about the high near-surface groundwater (also called shallow groundwater) 1,4 D contamination about 6 months after it was discovered on the west side. I approached him and asked him about this danger at the Ann Arbor Green Fair with City Adm. Lazarus walking with him, and he said he had not known of this, as Lazarus seemed to pull him away from our conversation.
Mayor Taylor should recuse from voting on this Proposed CJ, he is a Partner in the law firm making $100's thousands on this ill-conceived CJ; also as a Partner in the firm it is generally not acceptable to challenge another partner
Taylor Minority City Council Group were forced by CC Majority to have a Working Session with CARD in 2019 with presentations that discussed clear and compelling reasons to support EPA Superfund
$40K current city effort basement west side evaluation is ill-advised. It is not appropriate from the data; to far west; CARD was not really involved! CJ proposal also has shallow groundwater sentinel wells in poor locations, generally too high in elevation
MS4 Violation in Allen's Creek not being addressed after years of known violations
Mayor Taylor and City Council supporters very rarely or never attend CARD meetings to ask questions, suggest solutions or make comment.
Mayor Taylor and his most of his City Council supporters never read the ACWG.ORG monthly Agenda or Updates which would have informed them, like where the west side VI exposures evaluation would have been actually useful.
The majority in MI State Government are pushing Polluter Pay right now. We will have new fairer Districts in MI in 2022, with much more progressive outcomes. We support that effort and think in the near future MI will have this again, and Gelman will be forced to do a meaningful cleanup if EPA Superfund has not.
Enlarging the Prohibition Zone, for the 3rd Time, is not appropriate should not be allowed.
Sisters Lake should not get proposed Gelman 1,4 Dioxane and Bromate discharge into a clean lake at 200gm and affect the adjacent wetland and flood hazard.
Danaher should be using the best available technologies for the cleanup. Gelman has and can treat to Non-Detect, below 1 ppb it just cost slightly more.
Lower high contamination aquifers will cross-talk with near-surface aquifers and be contaminated which could expose people in residential and business structures.
EGLE has commented that 29ppb could be an Action Level in near-surface groundwater.
We have 1,4D under our house at monitoring well showing high 1,4 Dioxane in lower aquifers now, and do not want it to percolate up into our or neighbor's basements.
We have had 2 homes built in our neighborhood recently both basements filled with groundwater soon after they were dug.
Most homes on the west side have damp or wet basements and will not be protected from VI of 1,4D.
Basically, a 500 ppb cleanup standard is a non-starter;
Who suggested this as a meaningful target? Gelman?
7.2ppb in MI, 1 ppb other states limits in drinking water, Environmental Working Group states 0.35 ppb
500 ppb could very well migrate to homeowner drinking water wells
Homeowner wells to the North West of the plume in Ann Arbor Twp. clearly have no protection
100 ppb Action Level for basement exposure Dr. Robert Bailey's VI analysis not addressed
aquifers are connected and will crosstalk and equilibrate potentially causing shallow groundwater exposures into structures
no discussion on VI levels, 500 ppb dangerous to the community
2,800 ppb, and 280 proposed, GSI where it seems clearly an issue with 29 or 100 ppb potentially a reasonable VI Action Level
We Support Dan Bicknell's comments below in support of EPA Superfund cleanup (see below).
EPA initial evaluation of the Gelman Plume site initially Scored Very High for a Superfund cleanup full evaluation.
Senator Stabenow told me in 2016, after Donald Trump took office, EPA will still be doing polluter pay cleanup, it's the orphaned sites that are a real problem. This is not an Orphaned Site.
Danaher is on the hook for this cleanup according to several comments by Mitch Adelman of MDEQ/EGEL in MDEQ public meetings when asked.
With all the significant hard work the CARD group, city and county have done the EPA will have a headstart on this effort. The EPA Score of the partial Superfund Evaluation was very high for Superfund Listing with a minimal evaluation. In this case, we have a Responsible Party that EPA will require to do and pay for cleanup as is happening now with other sites all over the country.
This revised proposed CJ is basically an exit route for Danaher and Gelman with a partial cleanup and not further action required by law.
SuperFund is the most prudent path for Gelman Full Cleanup; this from Dan Bicknell (CARD Member, former SuperFund Manager, President of GEA):
"The main USEPA Superfund Site benefits, based upon similar sites, were detailed by USEPA – Region V - Office Of Superfund in a July 25, 2016 meeting/call with the City, County and Townships representatives. They include:
Active restoration of the aquifer to a protective drinking water criterion, regardless of whether the dioxane plume is in a Prohibition Zone or not with Gelman paying the clean-up costs;
As a first USEPA priority, extend the municipal drinking water supply to any resident who may be potentially adversely impacted by the dioxane contaminated groundwater at a Gelman cost;
Halt the expansion of the dioxane groundwater contamination and treat the source and outer margins of the dioxane plume with an active remedial technology like groundwater extraction and treatment;
The active remedial action would prevent the dioxane contamination of Barton Pond, so no additional Contingency Plan would be required to protect Barton Pond.
The USEPA will require that Gelman pay for residential well sampling and dioxane analysis at homes immediately down-gradient of the dioxane plume;
The USEPA will require a monitoring well network which will establish the full extent and magnitude of the dioxane groundwater contamination, including the Old West Side and West Park areas of the City;
The USEPA offers Community Grants (e.g., $50K) to support public input into the Superfund Site cleanup process; and
The USEPA has the technical, administrative and legal resources to establish a protective federal Administrative Order and provide high-quality oversight of Gelman in the clean-up with the backing of the US Department of Justice and USEPA Regional Counsel."
EPA Superfund will be the most effective cleanup and protect the economic status of the area. Economic research has shown when you have uncertainty with a contaminated site this is the least protective option of economic status for a community.
The University of Michigan has not supported EPA Superfund but it clearly is in their best interest to see a Superfund cleanup that will be faster and more effective and maintain the positive status of the community. Most unfortunately they have been minimally involved with the public on this matter.
In the EGLE Public Comment Zoom meeting on September 14 all the public comments were negative, not in support of the Proposed CJ, no positive public comments were made.
The Ann Arbor Township, Scio Township, Washtenaw County Board of Commissions, Sierra Club Huron Valley Group, CARD and ACWG all voted in supported a petition to the US EPA for Full Preliminary Assessment of the Gelman 1,4-Dioxane groundwater contamination.
Governor Whitmer would be much more approachable than our previous Republican Governor when we present her with a US EPA Full Preliminary Assessment in a Superfund Petition. The former governor refused to allow US EPA to do a Full Evaluation when requested by US EPA.
The CARD Group has moved to virtual meetings like others starting in May for an undermined length of time, see details at the Washtenaw County CARD site.
Links:
October 2020 Regular Coalition for the Remediation of Dioxane (CARD) Group Meeting Video - Taped by Roger Rayle, Chair CARD
Gelman Plume Related Stories by Ann Arbor News/MLive: MLive
Ann Arbor-area officials delay Gelman plume decision another month: MLive Ryan Stanton
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)
WEMU Article- 'Virtual Q&A Meeting Will Be Held Tonight To Discuss 1,4 Dioxane Plume'
Lots of details from Barbara Lucus at Dioxane.Org and WEMU News Program GreenRoom
Washtenaw County CARD Site
See ACWG site pages EPA Superfund Option Details
Click here to view and/or sign in support of Superfund Designation
Berm Opening For Flood Mitigation and B2B Ped and Bike Access at Depot St Near Completion, Extensive Use of Concrete for Circuitous Access to Go Around Martin Buildings is Questionable
View of very long approach to Berm Opening
Goes East Well Passed the White Martin Building
(Rt Clk for larger; ACWG)
Preferred 2013 Option (not used) with Much Easer/Very Much Less Expensive Pedestrian and Bike Access Paths (circled in red)*
(City of Ann Arbor; Rt Clk for larger; red circled annotations ACWG)
This project was greatly helped by residents and the ACWG pushing for the pedestrian and bicycle access. When approached MDOT (the owner of the RR track) initially was not supportive of the Berm Opening until they were told it would connect the B2B trail. MDOT did a '180 degree' and strongly supported it.
The ACWG was extensively involved in this proposal. The pedestrian and bicycle access was in question initially. We strongly supported pedestrian and bicycle and, the MDOT interest in this help get the funding for the project which had to include pedestrian and bicycle access.
The very expensive and extensive use of concrete for the Depot St. access path around the Martin building in the RR Right of Way and its huge carbon footprint are unfortunate and unnecessary. The city is boasting A2Zero when these kinds of projects are the antithesis of low carbon emissions. An easement between two Martin buildings on Depot St. would have proved a much easier, less costly and much fewer carbon emissions access to the B2B trail as shown in original plans. The Martin buildings in the old floodway and floodplain will greatly benefit from this project with a stormwater tunnel to the river.
841 Broadway St., DTE Energy Huge Toxic Coal Tar Dump Site, in the Old Huron River Channel, Just Below Argo Dam in a Major Flood Zone, Roxbury Group's Proposal Approved for Housing and Hotel
841 Broadway St., DTE Site, Major Flood Risk with Global Warming
"Extreme Flood Factor for This Site, 9 Out of Ten!"
Rt Outrageous Flood risk for 841 Broadway St., DTE Site,
proposed for development; First Street Foundation ( Rt Clk for larger)
Recent photo of piles of polluted soil temporally stored by the city on
DTE site from work to cut opening in the Berm under the RR Tracks
and connect the B2B trail to the Treeline/Greenway
(ACWG, Rt Click for Larger Image)
Taxpayers are subsidizing DTE Energy, rated top 10 worst Water Polluter in the USA.
First Street rates this site as Extreme Flood Factor, 9 out of 10, which unlike the city, county, state and federal ratings, include Global Warming effects.
FEMA has also been shown to Low Ball Floodplains by at least 30% due to poor data and do not take into account the Global Warming effects that we are seeing now in SEM.
In the 1968 flood (likely a 50-year flood or less, by today's standards) had 15' of water careening across this DTE site.
The City of Ann Arbor does due diligence and removes toxic Coal Tar deposits in new path to B2B trail and flood relief channel to Huron River,
not so much DTE.
DTE is a $1.7B Company yet Ann Arborites and the State will be paying $25M to do a very minimal partial cleanup of the site. Most of the highly toxic coal tar and other pollution, which goes upto 30 feet down into the groundwater table, will be left for future generations to deal with. Downriver was never tested for groundwater contamination into the river as commented by the developer at a public meeting.
Council Member Jeff Hyner commented, basically stated ' why are we capping toxic dump site with homes and a hotel in the flood prone river' and voted NO to the PUD approval.
Roxbury Group proposed this development that will sit on top of a toxic dump site of Coal Tar and other pollutents.
Not only is there vapor intrusion (VI) issues due to very toxic and very volatile coal tar, you are capping this site with structures so a cleanup in a few years from now will not be possible. You are condemning our river to be contaminated for decades or centuries.
Petoskey had to evacuate 11 new condos recently due to VI into the condo development built on top of a pollution site with toxic volatile organics.
Several permits are sill to be obtained, yet it received approval by council.
These permits should not be given to this development. ACWG has contacted government officials regarding these permits.
Links: Toxic 100 Air Polluters Index, Toxic 100 Water Polluters Index and Greenhouse 100 Index
$40 Million Dollar Unlawful Enrichment Law Suit Against Ann Arbor, Due To Stormwater Utility Fees and Other Sanitary Sewer and Water Utility Fees Misuse
Seal of the City of Ann Arbor
After a casual comment at a very recent CARD meeting, the ACWG asked a council member to receive details on the commented on 'Law Suit against the city for water issues'. Sorry, interested residents were not made aware of this suit until over a month since it was filed and had to make a specific request.
PDF Image of the text of the Washtenaw Circuit Court pleading:
The class-action suit alleges generally the city is overcharging in fees for Stormwater Utility Fees and other fees like Sanitary Sewer and Drinking Water Fees. They have filed suit to obtain refunds for users for some city utility.
It finds the city has tens of millions of dollars in utility fees saved up when generally fees for utilities are to pay the cost of the utilities in a 'Pay as You Go'.
Additionally, they have found the city is using utility fees for things they say are not related to the utility. For example stormwater fees used for street work, fully funding the Forestry Department. In the past, we have been told that the city has used these fees to pay for police protection of sewer lids that were said to be regularly stolen. Fees were used to build water-related artwork at city hall.
Stantec who consulted on Utility Fees recommended that the city " draw down" excessive reserves. "Stantec recognized that the City's cash and investments in is Stormwater Fund were far in excess of appropriate reserve amounts, "
It seems to us the city has commented in the past that it is collecting fees in some cases for expected costs like treatment plant upgrades and replacement. It has also commented that some of the fees go to tree planting because it reduces stormwater runoff and pollution. similar to actions by other communities. City Recycling efforts were also partially paid for off Utility fees collected, called 'source water protection'. The city has paid $475,000 from Water Supply Fees for Gelman legal work.
According to their website, this law firm has gotten millions of dollars in similar suits.
The ACWG has commented many times in the recent past on the potential abuse of these fees could cause the loss of this much needed and progressive Stormwater Utility as has happened in Lansing and Jackson, and others, due to court actions.
Links:
UPDATE*: "In Deep: Ann Arbor’s Water Troubles" Posted January 1, 2021 by Vivienne Armentrout
In depth online article on the Hahn Suit and "water" fees uses by City of Ann Arbor
MLive Ryan Stanton recent article on this suit.
Update 10-8-20*:
Scio Residents for Safe Water (SRSW) has voted to reject the Proposed 4th Consent Judgement (CJ) Agreement with Danaher/Pall/Gelman and immediately petition the US EPA for intervention and appeal to Circuit Judge Timothy Connors to impose a plan that addresses the many shortcomings of the proposed Consent Judgement. SRSW is Chaired by Roger Rayle, who is also Chair of CARD.
Update 9-21-20*:
The Ann Arbor Township Board of Trustees unanimously approved a resolution this past week voicing strong opposition to the proposed settlement, while expressing concerns about EGLE’s oversight of the plume.
Ann Arbor, Scio Township and Washtenaw County elected officials are planning to hold a joint Zoom meeting at 6:30 p.m. Sept. 24 to hear public input and provide answers to questions about the proposed deal.
Members of the public will be able to watch the Sept. 24 meeting using this link. To participate via Zoom, use this link and passcode 966628.
https://www.mlive.com/news/ann-arbor/2020/09/washtenaw-county-officials-seeking-more-input-on-pollution-cleanup-plan.html
September 2020 - No Meeting this month due to COVID-19 Pandemic Cautions
Watershed Issues of Interest and Updates:
Danaher/Pall/Gelman 1,4-Dioxane Plume - Consent Judgement Negotiations Have Concluded, Public Input Requested Prior to Government Bodies Vote to Accept or Reject
Vince Caruso Discusses Gelman Contaminated Groundwater Issues in
CARD Presentation at City Council Gelman Work Session 2019
(ACWG)
Michigan Department of Environment, Great Lakes, and Energy (EGLE) and City Council members have indicated a Consent Judgement (CJ) Agreement with Danaher/Pall/Gelman on the "cleanup" of the 1,4-Dioxane plume is done with negotiations and released for viewing and comment. City, County and Townships will have Public Comment options. EGLE had Public Comment recently, details below.
Some benefits in the Proposed CJ but,
The Allen's Creek Group (ACWG.ORG) does not support this Proposed CJ, we support an EPA Superfund Petition and Cleanup.
We support Dan Bicknell's comments shown below in support of an EPA Superfund Petition and Cleanup.
EGLE/DEQ: Not Capable: Some Past Comments and Actions -
Natural Blocking agent at Barton Pond, Ann Arbor Drinking Water Source (95%), this is not true
No preferred flow to Barton past M14 described by MDEQ, this is not true
No effort to test to bedrock at the core where suspected high concentrations exist
2M ppb contaminated soils ignored till GW cleaned up is done, ill-advised
Vapor Intrusion (VI) exposures not seriously considered
ACWG and CARD forced VI analysis and tests
Still no clear evaluation by EGLE of Dr. Robert Bailey's VI Analysis showing a 100 ppb Action Level not EGLE's 2,800 ppb
Years of MS4 Violations Allen's Creek West Park
Went to court with Gelman that lasted for decades with very poor results, no real cleanup of the soils or groundwater, with many residential wells and our city well contaminated
Larry Lemke Consultant working on CJ seems Conflicted:
Stated to CARD in a recorded meeting in recent years - no blocking at Barton as presented by MDEQ
and he said, in fact, there is preferred flow to Barton
He has since reversed positions on these and other points
No comment on VI ppb, or soils very high ppb - 2M ppb;
No obvious explanation as to his change in his opinions
Leadership at city hall is lacking, inattentive.
Surprisingly and alarmingly Mayor Taylor was uninformed about the high near-surface groundwater (also called shallow groundwater) 1,4 D contamination about 6 months after it was discovered on the west side. I approached him and asked him about this danger at the Ann Arbor Green Fair with City Adm. Lazarus walking with him, and he said he had not known of this, as Lazarus seemed to pull him away from our conversation.
Mayor Taylor should recuse from voting on this Proposed CJ, he is a Partner in the law firm making $100's thousands on this ill-conceived CJ
Taylor Minority City Council Group were forced by CC Majority to have a Working Session with CARD in 2019 with presentations that discussed clear and compelling reasons to support EPA Superfund
$40K current city effort basement west side evaluation is ill-advised. It is not appropriate from the data; to far west; CARD was not really involved! CJ proposal also has shallow groundwater sentinal wells in poor locations, generally too high in elevation
MS4 Violation in Allen's Creek not being addressed after years of known violations
Mayor Taylor and City Council supporters rarely or never attend CARD meetings to ask questions, suggest solutions or make comment.
Mayor Taylor and his most of his City Council supporters never read the ACWG.ORG monthly Agenda or Updates which would have informed them, like where the west side VI exposures evaluation would have been actually useful.
The majority in MI State Government are pushing Polluter Pay right now. We support that effort and think in the near future MI will have this again, and Gelman will be forced to do a meaningful cleanup if EPA Superfund has not.
Enlarging the Prohibition Zone, for the 3rd Time, is not appropriate should not be allowed.
Sisters Lake should not get proposed Gelman 1,4 Dioxane and Bromate discharge into a clean lake at 200gm and affect the adjacent wetland and flood hazard.
Danaher should be using the best available technologies for the cleanup. Gelman has and can treat to Non-Detect, below 1 ppb it just cost slightly more.
Lower high contamination aquifers will cross-talk with near-surface aquifers and be contaminated which could expose people in residential and business structures.
We have 1,4D under our house at monitoring well showing high 1,4 Dioxane in lower aquifers now, and do not want it to percolate up into our or neighbor's basements.
We have had 2 homes built in our neighborhood recently both basements filled with groundwater soon after they were dug.
Most homes on the west side have damp or wet basements and will not be protected from VI of 1,4D.
Basically a 500 ppb cleanup standard is a non-starter;
Who suggested this as a meaningful target? Gelman?
7.2ppb in MI, 1 ppb other states limits in drinking water, Environmental Working Group states 0.35 ppb
500 ppb could very well migrate to homeowner drinking water wells
Homeowner wells to the North West of the plume in Ann Arbor Twp. clearly have no protection
100 ppb Action Level for basement exposure Dr. Robert Bailey's VI analysis not addressed
aquifers are connected and will crosstalk and equilibrate potentially causing shallow groundwater exposures into structures
no discussion on VI levels, 500 ppb dangerous to the community
2,800 ppb, and 280 proposed, GSI where it seems clearly an issue with 100 ppb potentially a reasonable VI Action Level
We Support Dan Bicknell's comments below in support of EPA Superfund cleanup (see below).
EPA initial evaluation of the Gelman Plume site initially Scored Very High for a Superfund cleanup full evaluation.
Senator Stabenow told me in 2016, after Donald Trump took office, EPA will still be doing polluter pay cleanup, it's the orphaned sites that are a real problem. This is not an Orphaned Site.
Danaher is on the hook for this cleanup according to several comments by Mitch Adelman of MDEQ/EGEL in MDEQ public meetings when asked.
With all the significant hard work the CARD group, city and county have done the EPA will have a headstart on this effort. The EPA Score of the partial Superfund Evaluation was very high for Superfund Listing with a minimal evaluation. In this case, we have a Responsible Party that EPA will require to do and pay for cleanup as is happening now with other sites all over the country.
This revised proposed CJ is basically an exit route for Danaher and Gelman with a partial cleanup and not further action required by law.
SuperFund is the most prudent path for Gelman Full Cleanup; this from Dan Bicknell (CARD Member, former SuperFund Manager, President of GEA):
"The main USEPA Superfund Site benefits, based upon similar sites, were detailed by USEPA – Region V - Office Of Superfund in a July 25, 2016 meeting/call with the City, County and Townships representatives. They include:
Active restoration of the aquifer to a protective drinking water criterion, regardless of whether the dioxane plume is in a Prohibition Zone or not with Gelman paying the clean-up costs;
As a first USEPA priority, extend the municipal drinking water supply to any resident who may be potentially adversely impacted by the dioxane contaminated groundwater at a Gelman cost;
Halt the expansion of the dioxane groundwater contamination and treat the source and outer margins of the dioxane plume with an active remedial technology like groundwater extraction and treatment;
The active remedial action would prevent the dioxane contamination of Barton Pond, so no additional Contingency Plan would be required to protect Barton Pond.
The USEPA will require that Gelman pay for residential well sampling and dioxane analysis at homes immediately down-gradient of the dioxane plume;
The USEPA will require a monitoring well network which will establish the full extent and magnitude of the dioxane groundwater contamination, including the Old West Side and West Park areas of the City;
The USEPA offers Community Grants (e.g., $50K) to support public input into the Superfund Site cleanup process; and
The USEPA has the technical, administrative and legal resources to establish a protective federal Administrative Order and provide high-quality oversight of Gelman in the clean-up with the backing of the US Department of Justice and USEPA Regional Counsel."
EPA Superfund will be the most effective cleanup and protect the economic status of the area. Economic research has shown when you have uncertainty with a contaminated site this is the least protective option of economic status for a community.
The University of Michigan has not supported EPA Superfund but it clearly is in their best interest to see a Superfund cleanup that will be faster and more effective and maintain the positive status of the community. Most unfortunately they have been minimally involved with the public on this matter.
In the EGLE Public Comment Zoom meeting on September 14 all the public comments were negative, not in support of the Proposed CJ, no positive public comments were made.
The Ann Arbor Township, Scio Township, Washtenaw County Board of Commissions, Sierra Club Huron Valley Group, CARD and ACWG all voted in supported a petition to the US EPA for Full Preliminary Assessment of the Gelman 1,4-Dioxane groundwater contamination.
Governor Whitmer would be much more approachable than our previous Republican Governor when we present her with a US EPA Full Preliminary Assessment in a Superfund Petition. The former governor refused to allow US EPA to do a Full Evaluation when requested by US EPA.
The CARD Group has moved to virtual meetings like others starting in May for an undermined length of time, see details at the Washtenaw County CARD site.
Links:
September 2020 Regular Coalition for the Remediation of Dioxane (CARD) Group Meeting Video - Taped by Roger Rayle, Chair CARD
Gelman Plume Related Stories by Ann Arbor News/MLive: MLive
Ann Arbor-area officials delay Gelman plume decision another month: MLive Ryan Stanton
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 Lucus at Dioxane.Org and WEMU News Program GreenRoom
Washtenaw County CARD Site
See ACWG site pages EPA Superfund Option Details
Click here to view and/or sign in support of Superfund Designation
W. Kingsley and N. First Street Flooding in 4" Rain Blocks One of Two Entrances to a New Condos on July 15th
W. Kingsley Flooding Entrance to New Beal Condos
( Rt Clk for larger; ACWG)
Flooding during a 4-inch rain on W. Kingsley St. completely blocks one of the two entrances to a new occupied Beal condo building development between W. Kingsley and N First Streets.
Homeowners unaware, especially after dark, may leave the condo’s and drive into this standing water where many cars have been disabled and trapped in floodwaters in the past. This is a common occurrence as it is the Allen's Creek floodway. Some flooded car occupants have had to be rescued by First Responders in recent years.
Across the street are new condos on Ashley with water lapping up to the building also built in the floodplain next to the floodway.
The ACWG has opposed these developments in the floodplain and likely floodway for many years but our city government has chosen to ignore the real dangers to life, health and property.
This building is in the floodplain and likely floodway with more meaningful floodplain maps. FEMA has been shown to Low Ball the FEMA floodplain maps by at least 30% due to poor data and do not take into account the Global Warming effects that we are seeing now in SEM.
This new building in the floodplain is required to pay flood insurance which is expected to rise dramatically in the years to come, an unnecessary burden on the homeowners and the community.
Extreme rains fueled the Michigan flood, and Midwest precipitation is increasing and intensifying with climate change: Weather Underground
Annual precipitation since 1895 in the Central Lower Michigan climate division. (NOAA/NCEI; Rt Clk for larger)
From Weather Underground:
'One of the recurring messages in decades of projections of human-produced climate change is that precipitation will tend to decrease in the subtropics and increase at northern midlatitudes. That’s exactly what is happening in central Michigan. What’s more, the intensity of multi-day downpours is rising in many parts of the world, including the United States, and the most-affected U.S. regions are the Midwest and Northeast, as noted by Climate Central.
“Stormwater management systems and other critical infrastructure in the Midwest are already experiencing impacts from changing precipitation patterns and elevated flood risks,” said the 2018 U.S. National Climate Assessment. In a message that rings out, the assessment added: “Infrastructure currently designed for historical climate conditions is more vulnerable to future weather extremes and climate change.” ' (bold by us)
2019 was the wettest year for Central Lower Michigan in recorded history.
Link: https://www.wunderground.com/cat6/aging-dams-changing-climate-a-dangerous-mix
West Michigan residents face ‘catastrophic’ flooding after record-breaking rainfall; May 19, 2020: MLive
Flooding West Michigan (MLive; Rt Click for larger)
MLive:
"Across West Michigan, the heavy rainfall has resulted in major flooding that has shut down roadways, filled basements and led to declarations of countywide State of Emergency alerts.
Muskegon received 3.35 inches of rainfall Sunday alone, making it the second heaviest 24-hour rainfall total in May since 1904, according to the weather service.
Meanwhile in Ottawa County, one Grand Haven resident saw so much flooding in his neighborhood that he was able to go kayaking in his neighbor’s yard." (bold by us)
Link: https://www.mlive.com/news/muskegon/2020/05/west-michigan-residents-face-catastrophic-flooding-after-record-breaking-rainfall.html
UPDATE 8-31-20*:
Consent Judgement Proposed Changes:
"Gelman Proposed Settlement Documents
This is a repository of proposed settlement documents prepared by Washtenaw County and its Health Department, the City of Ann Arbor, Scio Township, and the Huron River Watershed Council."
August 2020 - No Meeting this month due to COVID-19 Pandemic Cautions
Watershed Issues of Interest and Updates:
Danaher/Pall/Gelman 1,4-Dioxane Plume - Consent Judgement Negotiations Seem To Have Concluded, (More Details Later!? Still no Word!)
Michigan Department of Environment, Great Lakes, and Energy (EGLE) and City Council members have indicated a Consent Judgement (CJ) Agreement with Danaher/Pall/Gelman on the "cleanup" of the 1,4-Dioxane plume is done with negotiations but no word on a report to the community date.
There seems to be some confusion as if the public will be given the text of the agreement before a Council Vote or after the vote. It has been commented by a council member that it cannot be divulged if it is not voted to accept, so until the vote, it will stay secrete contrary to city council promises made to the public. One council member has said she will not support a vote till it is made public. Clear as Mud.
Allowing the 1,4 Dioxane to move through the city with migration to the near-surface or surface would seem to be a violation of the very weak MI Part 201 standards of Isolation of the Contaminate. We just so happen to have a Ph.D. scientist, Dr. Robert Bailey, with past experience doing professional Environmental Fate and Transport Analysis of Volatile Chemicals including 1,4D in our CARD group he has shown that 100 ppb near a home or business's basements could be a dangerous exposure to occupants. EGLE's toxicologist is still evaluating this finding many months after receiving it.
We have shown, due to CARD and ACWG's persistence to have basic simple near-surface groundwater (NSG also called shallow groundwater) tests, that West Park has 22 ppb in NSG. Just upstream, 6 to 8 blocks, we have had 1,000 ppb at Vets Park and 800 ppb at Mary Field Park neighborhood.
We have Gelman/Pall's own geological maps (!) from 2006 that show this would likely happen in West Park, as it now has.
As commented on before the Allen's Creek pipe in West Park has high flows in drought conditions because it picks up lots of seep's groundwater just upstream. This is to reduce the damage NSG can cause if left uncontrolled, like home and street undermining. This NSG is contaminated.
As I commented at the December 12th Joint Session of EGLE and local government bodies, during public comment at this meeting, we have a Gelman's Illicit Discharge into a Michigan MS4 system for over 2 years now, the Allen('s) Creek flowing to the Huron River, Dan Bicknell GEA has investigated and communicated in more detail on the issues of MS4. I also commented that residents are not being protected if this compound is allowed to percolate into basements and evaporate (VI -Vapor Intrusion) into this confined space and expose the residents. Many Ann Arbor residents use their basements for play space, workspace, office space, ...
Contaminated Near-Surface Groundwater is now a near-term threat to the community and is an example of how Gelman/Danaher has not protected the community. West Park is now at 22 ppb in NSG yet we have no permanent wells to monitor this. This is just one of a myriad of examples of mismanagement of this threat to the community.
Why SuperFund is the most prudent path for Gelman Full Cleanup; this from Dan Bicknell (CARD Member, former SuperFund Manager, President of GEA):
"The main USEPA Superfund Site benefits, based upon similar sites, were detailed by USEPA – Region V - Office Of Superfund in a July 25, 2016 meeting/call with the City, County and Townships representatives.
They include:
Active restoration of the aquifer to a protective drinking water criterion, regardless of whether the dioxane plume is in a Prohibition Zone or not with Gelman paying the clean-up costs;
As a first USEPA priority, extend the municipal drinking water supply to any resident who may be potentially adversely impacted by the dioxane contaminated groundwater at a Gelman cost;
Halt the expansion of the dioxane groundwater contamination and treat the source and outer margins of the dioxane plume with an active remedial technology like groundwater extraction and treatment;
The active remedial action would prevent the dioxane contamination of Barton Pond, so no additional Contingency Plan would be required to protect Barton Pond.
The USEPA will require that Gelman pay for residential well sampling and dioxane analysis at homes immediately down-gradient of the dioxane plume;
The USEPA will require a monitoring well network which will establish the full extent and magnitude of the dioxane groundwater contamination, including the Old West Side and West Park areas of the City;
The USEPA offers Community Grants (e.g., $50K) to support public input into the Superfund Site cleanup process; and
The USEPA has the technical, administrative and legal resources to establish a protective federal Administrative Order and provide high-quality oversight of Gelman in the clean-up with the backing of the US Department of Justice and USEPA Regional Counsel." (bold by us)
With all the significant hard work the CARD group, city and county have done the EPA will have a headstart on this effort. The EPA Score of the partial Superfund Evaluation was very high for Superfund Listing with a minimal evaluation. In this case, we have a Responsible Party that EPA will require to do and pay for cleanup as is happening now with other sites all over the country.
The Ann Arbor Township, Scio Township, Washtenaw County Board of Commissions, Sierra Club Huron Valley Group, CARD and ACWG all voted in supported a petition to the US EPA for Full Preliminary Assessment of the Gelman 1,4-Dioxane groundwater contamination.
Governor Whitmer would be much more approachable than our previous Republican Governor when we present her with a US EPA Full Preliminary Assessment in a Superfund Petition. The former governor refused to allow US EPA to do a Full Evaluation when requested by US EPA.
The CARD Group has moved to virtual meetings like others starting in May for an undermined length of time, see details at Washtenaw County CARD site.
Links:
CARD August Meeting was canceled due to vacation schedules
July 2020 Regular Coalition for the Remediation of Dioxane (CARD) Group Meeting Video - Taped by Roger Rayle, Chair CARD
Gelman Plume Related Stories by Ann Arbor News/MLive: MLive
Ann Arbor-area officials delay Gelman plume decision another month: MLive Ryan Stanton
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 Lucus at Dioxane.Org and WEMU News Program GreenRoom
Washtenaw County CARD Site
See ACWG site pages EPA Superfund Option Details
Click here to view and/or sign in support of Superfund Designation
Ann Arbor Affordable Housing Tax Proposal, With a Ban On Fund's Use In Floodplains, Heads to November Ballot
415 W. Washington, Ann Arbor MI:
Flood risk for 721 N Main St. proposed for potential development; First Street Foundation ( Rt Clk for larger)
721 N. Main has been widely discussed by some on City Council as a proposed site for Affordable Housing, with a flood analysis that includes Global Warming, which some on council purportedly agree is real, a major threat and is causing bigger rain events. The City just authorize a $1B plan to deal with it.
841 Broadway St., DTE Site, Major Flood Risk with Global Warming
Flood risk for 415 W. Washington proposed for potential development; First Street Foundation ( Rt Clk for larger)*
721 N. Main City Owned Lot
Outrageous Flood risk for 841 Broadway St., DTE Site, proposed for development; First Street Foundation ( Rt Clk for larger)
Affordable Housing (AH) Millage proposal with restrictions passed City Council on July 27.
The ACWG has commented recently in AH issues meetings that the Profit Motive has failed and we need to move to a more proactive city lead effort. Also have discussed not building in the floodplain (FP) for decades now, especially "AH". Glad to see these changes finally happening, better late than never.
CM Ali Ramlawi proposed an amendment to the Millage to ban use of the Millage funds in the Floodplain.
Amendment passed with Taylor, Smith, Ackerman, Grand voting against.
“In a 7-4 vote, council decided to prohibit spending money from the tax on building, maintaining or acquiring new affordable housing units in floodways or floodplains.
...20-year millage that, if approved, could raise over $6.5 million in the first year it’s levied in 2021, and potentially around $160 million over the next two decades, according to city officials. $125 per year for a home with a $250,000 market value and $125,000 taxable value”: MLive.
Unlike First Street Foundation, FEMA does not account for Global Warming in its models, and for other reasons, they are very much Low Ball values. Much more dangerous than it may appear to the uneducated or uninterested. The floodway (FW) analysis is likely in error as well.
It’s ok to put disadvantaged in very dangerous FP and likely FW according to Taylor, Smith, Ackerman, Grand and their supporters.
The city has a very sordid history of placing minorities and disadvantaged in FP and FW which should be stopped especially with Global Warming effects clearly making this more dangerous by the day.
Above you can see flood predictions, including Global Warming effects, for a site considered developable by the city: DTE Site.
Link:
First Street Foundation's https://floodfactor.com/
City of Ann Arbor Floodplain Management Overlay Zoning District Passed
An Apt. building in Versailles, Northern OH where
two people died in recent years trying to get cars out of a
floodplain parking area below the building,
an ill-advised but allowed common building practice in Ann Arbor
(photo: T. Bletcher ACWG; Rt Click for larger).
City Web Page Link to Project Page: https://www.a2gov.org/departments/systems-planning/planning-areas/water-resources/floodplains/Pages/default.aspx
This is a good step but banning building in the floodplain would be much safer, environmentally recommended, and improve the economic viability of the community.
Relying on Federal Emergency Management Agency (FEMA) floodplain maps is ill-advised at it does not take into account Global Warming effects that we are already seeing in Michigan. First Street Foundation's maps do include predicted Global Warming effects and show much larger flood hazards.
ACWG did make comments in the webinar. We asked for more restrictions on development in the floodplains.
City has said that the presentation and comments are available online.
Top city staff comments do not support development in the Floodplain:
Dr. Missy Stults, Manager City of Ann Arbor Sustainability Office at A2Zero KickOff Meeting to ACWG question: 'I do not support city building in the floodplain (period).'
Jerry Handcock has commented at public meetings, as a Floodplain Manager, he would not like to see building in the floodplain.
All the predictions of Global Warming and much heavier rain events, this is the most prudent way forward.
'Floodplain Management Overlay Zoning District:
The City is proposing to adopt a Floodplain Management Overlay Zoning District to add to Chapter 55 (PDF), the Unified Development Code. The regulations are proposed for a variety of reasons:
Improved protection of public safety and welfare
Reduced loss of life and property, especially for vulnerable populations and neighborhoods
More consistency with State floodplain regulations
Clarifying the permit approval process
Better Community Rating System score
Saving money and resources by lowering flood insurance rates and less flood damages to repair
Furthering the City's sustainability and climate action goals'
Jerry Hancock Stormwater and Floodplain Programs Coordinator had led this effort for many years.
The ACWG has been promoting this option for many years.
Unfortunately, Ann Arbor still does not receive all the benefits of FEMA Flood Community Rating System (CRS) or lower flood insurance and other benefits.
Brett Lenart, Planning Manager commented at the Webinar that:
"No, the City is not at full CRS discounts. We believe that this ordinance has the potential to improve our rating, however."
A charter member of the ACWG and a charter member of the Environmental Commission, and the ACWG pushed for this plan and got it supported by the EC many years ago.
This proposal is long overdue and will protect the residents and businesses, and the environment from major storms coming with Global Warming.
Past Mistakes Cause More Threats:
Unfortunately, the past city council and current mayor defeated in 2015 a previous effort and, they went on to support over 110 new homes in a very dubious Floodplains in the city of Ann Arbor. One of these council members, who was not reelected, did not even know they were supporting so many new homes in the floodplain when the ACWG asked him a year later how he could justify his vote.
Many communities forbid building in floodplains, President Obama virtually forbid using federal Tax Dollars for building in the floodplain.
Links:
MLive https://www.mlive.com/news/ann-arbor/2015/09/should_ann_arbor_adopt_new_reg.html#incart_river
Flooding of Homes Caused by Construction at 312 Glendale Memory Care (MC) - Has Just Recently Started Construction Almost 2 1/2 Years After Approval and a Failed ACWG Attempted Reconsideration Request
Results of residents neighborhood survey of Water Issues in 2013; (ACWG)
MC Site is to left in dark olive tone with Legend, stormwater flow to the right ( Rt Click for Larger Image)
Two homes were flooded from excessive runoff from this construction site on July 10, 2020 as reported by one of the flooded home's owner. This was a concern residents brought up during the Planning and City Council discussions.
Neighbors commented that flooding from the Hillside Terrace next to the MC site occurred when first built in the 1970's. Downstream homeowners settled out of court for money damages.
Lazarus: Never Happen Again:
Former City Administrator Lazarus said in very sternly construction induced flooding, like on the North Side recently, would never happen again yet it has and may again! The city ignores flood hazard in favor of developers routinely.
Council approved plans for the MC at 312 Glendale on April 3rd 2017 in a 6-3 vote.
The ACWG, neighbors and a 5th ward council member strongly opposed this development.
We had unsuccessfully asked for reconsideration of this vote because when this went before Council issues were falsely or misleadingly presented to City Council and/or Planning Commission including the Water Resources Commissioner’s Office (WRCO). This may have lead to votes without full knowledge of the issues facing the neighborhood. The WRCO Staff, presenting at the meetings, did mention he was at the last minute standing in for someone in the office.
False or misleading statements by staff that may have helped this to get passed by City Council in a very close vote:
WRCO: The curb will block the huge flows off unmitigated Hillside Terrace (HT) from all major rain events onto this site.
This is not true it will overwhelm the stormwater (SW) system for the MC in a 10 or 20-year event overwhelming the MC SW system causing more flooding downstream. These types of street curb flood conditions in Ann Arbor have been discussed extensively in city meetings repeatedly, that I have attended in the past 20 years.
WRCO: The neighborhood really is not one of the few target neighborhoods for SW mitigation.
This is not true as shown in the $2M “Ann City of Ann Arbor Stormwater Model Calibration and Analysis Project”, June 1, 2015 section ‘C, viii. Glendale/Charlton, page 62’.
In this study they propose detention upstream of Glendale, which clearly could be the orchard.
Greenbelt funds should be used for projects like these, only about 9%, not the promised and voted on 33%, is spent in the city for green space.
WRCO: The orchard has sheet flow and no rainfall runoff infiltration now, this will be mitigated by the development.
This is not true as the orchard, where this proposed building will go, captures much if not all the unmitigated runoff from HT. We have videos and eye witness to attest to this. This will be lost with this development making flood hazard worse for the neighborhood and overwhelm the MC SW system.
WRCO: ‘Vince Caruso did a survey of neighbors’. As a lead in to question its results.
This is not true. I was not involved in the survey, and this seems to be an attempt to ‘tar’ and ‘belittle’ the extensive and important effort. The city took it seriously enough to do 100’s of hours of work in the neighborhood to mitigate the flood hazard since the survey was first presented unblocking 3 sewer lines in the neighborhood.
This new development will improve SW handling we were told. We have been told for over 30 years that new development like this will be the major way we improve SW handling in Ann Arbor.
Not true as this proposal will make it worse causing more flooding downstream into an overtaxed neighborhood.
See previous entries on this site for more details; search site option is at top of these pages.
Midwest and Northeast Getting Record Rain Events, Chicago Set a May Record 3rd Year in a Row
Chicago Highway damage due to recent flooding effects (MPR News; Rt Click for Larger)
Holland Sentinel July 19, 2020:
"The Midwest and the Northeast are getting more precipitation than in the past, and more of that coming in larger events, particularly in the winter and spring. Since 1951, total annual precipitation has increased by 13.6% in the Great Lakes region, with the amount falling in heavy storms increasing 35% in that time period, according to Great Lakes Integrated Sciences Assessments, or GLISA, an Ann Arbor-based partnership between the University of Michigan and Michigan State University serving as a climate change-related regional center for the National
Oceanic and Atmospheric Administration Chicago set its record for May rainfall for the third year in a row this year." (bold by us)
Much larger rain events are to be expected with Global Warming effects in the midwest and SE Michigan. Plan now.
July 2020 - No Meeting this month due to COVID-19 Pandemic Cautions
Watershed Issues of Interest and Updates:
Danaher/Pall/Gelman 1,4-Dioxane Plume - Consent Judgement Negotiations Seem To Have Concluded, (More Details Later!?)
Michigan Department of Environment, Great Lakes, and Energy (EGLE) and City Council members have indicated a Consent Judgement (CJ) Agreement with Danaher/Pall/Gelman on the "cleanup" of the 1,4-Dioxane plume is done with negotiations but no word on a report to the community date.
There seems to be some confusion as if the public will be given the text of the agreement before a Council Vote or after the vote. It has been commented by a council member that it cannot be divulged if it is not voted to accept, so until the vote, it will stay secrete contrary to city council promises made to the public. One council member has said she will not support a vote till it is made public. Clear as Mud.
At the last Coalition for Action on Remediation of Dioxane (CARD) meeting I asked, and we discussed, the option to do shallow groundwater tests in an 8th Street street drain.
EGLE is considering tests of shallow groundwater in an 8th Street street drain with very high flows in dry conditions, much like West Park drain. This is a very simple test, in lieu of permanent shallow groundwater wells that should be installed, that could be very instructive like the West Park tests.
The city and EGLE have indicated that they would be willing to work with U of M faculty on Vapor Intrusion (VI) issues related to near-surface groundwater (NSG, also called shallow groundwater) contamination on the westside of the city.
EGLE is still delaying the NSG tests after commenting months ago they would have done additional testing and have results by now. CARD and ACWG members commented that these tests should have been done by now with no real comment for a reason for delays by EGLE.
Why SuperFund is the most prudent path for Gelman Full Cleanup; this from Dan Bicknell (CARD Member, former SuperFund Manager, President of GEA):
"The main USEPA Superfund Site benefits, based upon similar sites, were detailed by USEPA – Region V - Office Of Superfund in a July 25, 2016 meeting/call with the City, County and Townships representatives.
They include:
Active restoration of the aquifer to a protective drinking water criterion, regardless of whether the dioxane plume is in a Prohibition Zone or not with Gelman paying the clean-up costs;
As a first USEPA priority, extend the municipal drinking water supply to any resident who may be potentially adversely impacted by the dioxane contaminated groundwater at a Gelman cost;
Halt the expansion of the dioxane groundwater contamination and treat the source and outer margins of the dioxane plume with an active remedial technology like groundwater extraction and treatment;
The active remedial action would prevent the dioxane contamination of Barton Pond, so no additional Contingency Plan would be required to protect Barton Pond.
The USEPA will require that Gelman pay for residential well sampling and dioxane analysis at homes immediately down-gradient of the dioxane plume;
The USEPA will require a monitoring well network which will establish the full extent and magnitude of the dioxane groundwater contamination, including the Old West Side and West Park areas of the City;
The USEPA offers Community Grants (e.g., $50K) to support public input into the Superfund Site cleanup process; and
The USEPA has the technical, administrative and legal resources to establish a protective federal Administrative Order and provide high quality oversight of Gelman in the clean-up with the backing of the US Department of Justice and USEPA Regional Counsel." (bold by us)
We currently have 22 ppb at West Park in the Near-Surface Groundwater (NSG, some also call shallow groundwater). 11 blocks upstream we have had 1,000 ppb at Vet's Park in recent years flowing toward West Park and beyond. CARD pressured EGLE to do these NSG tests and most were very surprised the 1,4 dioxane was in the NSG at such high levels and seemingly moving higher.
We have Gelman/Pall's own geological maps (!) from 2006 that show this would likely happen in West Park, as it now has.
As commented on before the Allen's Creek pipe in West Park has high flows in drought conditions because it picks up lots of seep's groundwater just upstream. This is to reduce the damage NSG can cause if left uncontrolled, like home and street undermining. This NSG is contaminated.
Contaminated Near-Surface Groundwater is now a near-term threat to the community and is an example of how Gelman/Danaher has not protected the community. West Park is now at 22 ppb in NSG yet we have no permanent wells to monitor this. This is just one of a myriad of examples of mismanagement of this threat to the community.
With all the work the CARD group, city and county have done the EPA will have a headstart on this effort. The EPA Score of the partial Superfund Evaluation was very high for Superfund Listing with a minimal evaluation. In this case, we have a Responsible Party that EPA will require to do and pay for cleanup as is happening now with other sites all over the country.
The Ann Arbor Township, Scio Township, Washtenaw County Board of Commissions, Sierra Club Huron Valley Group, and ACWG all voted in supported a petition to the US EPA for Full Preliminary Assessment of the Gelman 1,4-Dioxane groundwater contamination.
Governor Whitmer would be much more approachable than our previous Republican Governor when we present her with a US EPA Full Preliminary Assessment in a Superfund Petition. The former governor refused to allow US EPA to do a Full Evaluation when requested by US EPA.
The CARD Group has moved to virtual meetings like others starting in May for an undermined length of time, see details at Washtenaw County CARD site.
Links:
July 2020 Regular Coalition for the Remediation of Dioxane (CARD) Group Meeting Video - Taped by Roger Rayle, Chair CARD
Gelman Plume Related Stories by Ann Arbor News/MLive: MLive
Ann Arbor-area officials delay Gelman plume decision another month: MLive Ryan Stanton
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 Lucus at Dioxane.Org and WEMU News Program GreenRoom
Washtenaw County CARD Site
See ACWG site pages EPA Superfund Option Details
Click here to view and/or sign in support of Superfund Designation
City of Ann Arbor Floodplain Webinar: Proposed Floodplain Management Overlay Zoning District
UPDATE: this Webinar is now available on the City YouTube channel.
City Web Page Link to Project Page: https://www.a2gov.org/departments/systems-planning/planning-areas/water-resources/floodplains/Pages/default.aspx
'The webinar will provide an overview of proposed regulation changes establishing higher building standards within the floodplain with the intent of minimizing public and private losses due to flooding.'
Thursday, July 16 5:30 p.m.
Link to join (ZOOM) from a PC, Mac, iPad, iPhone or Android device. (https://a2gov.zoom.us/j/99897934373?pwd=Zjlodk1jNlVlU05QVE5GVFBEeDJIdz09#success)
Password: 128174
To join by phone:
(for higher quality, dial a number based on your current location):
US: 213.338.8477
888.788.0099 (Toll Free)
877.853.5247 (Toll Free)
Webinar ID: 998-9793-4373
Comments and questions may be submitted before the webinar, for potential discussion, to Jerry Handcock at JHancock@A2Gov.org
'Floodplain Management Overlay Zoning District:
The City is proposing to adopt a Floodplain Management Overlay Zoning District to add to Chapter 55 (PDF), the Unified Development Code. The regulations are proposed for a variety of reasons:
Improved protection of public safety and welfare
Reduced loss of life and property, especially for vulnerable populations and neighborhoods
More consistency with State floodplain regulations
Clarifying the permit approval process
Better Community Rating System score
Saving money and resources by lowering flood insurance rates and less flood damages to repair
Furthering the City's sustainability and climate action goals'
Jerry Hancock Stormwater and Floodplain Programs Coordinator had led this effort for many years and will lead the Webinar.
The ACWG has been promoting this option for many years.
A member of the ACWG was a charter member of, and on the Environmental Commission, who pushed for this plan and got it supported by the EC many years ago. This proposal is long overdue and will protect the residents and businesses, and the environment from major storms coming with Global Warming.
Unfortunately, the past city council and current mayor defeated in 2015 a previous effort and, they went on to support over 110 new homes in a very dubious Floodplains in the city of Ann Arbor. One of these council members, who was not reelected, did not even know they were supporting so many new homes in the floodplain when the ACWG asked him a year later how he could justify his vote.
Many communities forbid building in floodplains, President Obama virtually forbid using federal Tax Dollars for building in the floodplain.
Ann Arbor should forbid building in the floodplains and work to remove homes currently in the floodplain, not support more homes and affordable housing in the floodplains. All the predictions of Global Warming and much heavier rain events, this is the most prudent way forward.
UPDATE From Jerry Hancock, Stormwater and Floodplain Programs Coordinator on flooding at the Y and 415 site:*
The obstructions at the YMCA site were included on the MDEQ permit and were in place when the study was done for the 2012 FEMA Flood Insurance Rate Maps (FIRM). The YMCA floodway obstruction's impact on 415 W. Washington St. is already taken into account on the current FIRM.
Just to note the FIRM raw data used for maps is basically 1968 flood data, from the 100 year (1% chance) flood of that year and as such is not up to date. Consultant/Planners hired for the YMCA site plans thought the FIRM maps were based on 1992 data because the maps had a 1992 printing date. ACWG corrected that statement, even though the planner would not agree during a meeting on this issue. He said he would get back to us but never did.
As was noted earlier in the most recent Agenda entry, the Smith Group Planner currently working on the 415 W. Washington site stated the the YMCA building would never get approved today by the EGLE, former MDEQ.
Link: MLive https://www.mlive.com/news/ann-arbor/2015/09/should_ann_arbor_adopt_new_reg.html#incart_river
Bloomberg News Warns Unsuspecting Americans, That Flooding Is Much Worse Than FEMA Reports, Check For Yourself
Bloomberg News(rt click for larger)
" Millions of Americans just woke up in a flood zone that had never before been listed on U.S. government maps."
Look up the real flood risk for your address here!
"The first-ever public evaluation of flood risk for every property in the 48 contiguous states has found that federal maps underestimate the number of homes and businesses in significant danger by 67%. The new flood-risk data, released Monday by the research and technology nonprofit First Street Foundation, is a virtually unprecedented disclosure of how much damage climate change can be expected to inflict at the level of individual homes.
Look up the Flood Factor score for your home and any other property in the database.
First Street’s model gives homeowners access to risk-analysis techniques that had previously been available to insurers and financiers. (Look up your address here.) Until now public information on flood vulnerability in the U.S. relied heavily on maps produced by the Federal Emergency Management Agency, which are often out of date, incomplete, and difficult to understand." (bold by us)
Use the links to search your street and see the current First Street Foundation flood risk, normally not available to the public but that has now changed.
Links:
Bloomberg News (free first 3 articles)
Look up your address here.
First Street Foundation's https://floodfactor.com/
First Street Foundation's Flood Factor Extreme Rain Events Flood Rating for Ann Arbor Area, Much Heavier Rains and Flood Risks Projected
First Street Foundation's Flood Factor Flood Rating (First Street, rt click for larger)
"The First Street Foundation Flood Model is a nationwide, probabilistic flood model that shows any location’s risk of flooding from rain, rivers, tides, and storm surge. It builds off of decades of peer-reviewed research and forecasts how flood risks will change over time due to changes in the environment." (bold by us)
Ann Arbor and SEM, with all their flood enhancing impervious surfaces, especially need to adjust to Global Warming's effects on rainfall amounts and flood hazard, not hope "it will all go away" like our President continually pontificates.
Our city leaders have an obligation to ask the tough questions and make decisions that protect life, health and property to the best ability available.
Below is an example of First Street's model for dramatic increasing FLOOD RISK for, proposed "Affordable Housing" at:
415 W. Washington, Ann Arbor MI:
Michigan has had the greatest perception levels ever recorded last year in 2019.
Link: First Street Foundation's https://floodfactor.com/
NYT 6-29-20: New Data Reveals Hidden Flood Risk Across America
New York Times, Example Section of the Flood Risk Chart 6-20-20
New York Times (NYT) Article: New Data Reveals Hidden Flood Risk Across America:
" Nearly twice as many properties may be susceptible to flood damage than previously thought, according to a new effort to map the danger.
Across much of the United States, the flood risk is far greater than government estimates show, new calculations suggest, exposing millions of people to a hidden threat — and one that will only grow as climate change worsens.
That new calculation, which takes into account sea-level rise, rainfall and flooding along smaller creeks not mapped federally, estimates that 14.6 million properties are at risk from what experts call a 100-year flood, far more than the 8.7 million properties shown on federal government flood maps.
[ Detroit, Mich. +20,455 more structures than FEMA show]
Federal flood maps, managed by the Federal Emergency Management Agency, have long drawn concerns that they underestimate flood risk.
… FEMA’s maps aren’t designed to account for flooding caused by intense rainfall, a growing problem as the atmosphere warms.
Ms. Forbes [Ms. Forbes, a member of the Broward County Climate Change Task Force and a policy expert at the Natural Resources Defense Council] pointed out that black families tend to be more exposed to flooding because their homes are often built on cheaper land in historically segregated areas." (bold by us)
Ann Arbor needs to seriously heed these risks, especially for minority and lower-income residential housing.
Ann Arbor, especially, should not be putting minority and lower-income residents in and around floodplains.
Vote By Mail or In-Person on August 4th
Vote August 4th or by Mail for Watershed supporting candidates:
June 2020 - No Meeting this month due to COVID-19 Pandemic Cautions
Watershed Issues of Interest and Updates:
Correction of WRCO Request for Correction - Floodplain at 721 N. Main In Not Greatly Affected by Rail Road Tunnel Through the Berm as Stated by WRCO
Fig 5 - OHM Models for Berm Opening Floodplain Effects
(annotated in red by ACWG, Rt click for larger)
Contrary to past posts with respect to a request for Corrections by the Water Resouces Commissioners Office (WRCO) the Floodplain at 721 N. Main is Not Greatly Affected by Rail Road Tunnel through the Berm according to a city report of recent flood modeling, by Consultants OHM, with proposed changes due to the Berm opening and comments to ACWG by city staff.
The report indicates a very slight decrease in the new proposed floodplain and no real change in the new proposed floodway both of which largely cover the entire 721 N Main city-owned site.
Development on this site is greatly ill-advised due to the inherent dangers and recent past and current policies adopted by the City of Ann Arbor to not develop the floodplain including the Flood Hazard Mitigation Plan and Allen's Creek Watershed Management Plan.
Greenway/Tree Line green open space with flood reductions and park space are clearly indicated and most environmentally and economically advised. Many communities in Michigan are adopting a Green Space Planning Agenda to reduce flood hazard and increase economically viable communities with open space incorporating paths and bikeways.
This site is directly on the proposed Greenway/Tree Line and as such is a natural location to create a part of the Greenway and trail system.
Report available from the city or ACWG upon request.
Report: "Berm Floodplan effects ACRRB CLOMR Narrative FEMA (revised_reduced size no Appendix.PDF(sic)"*
Danaher/Pall/Gelman 1,4-Dioxane Plume - Michigan Department of Environment, Great Lakes, and Energy (EGLE) Continues to Delay and Make Errors in Very Important Tests on the West Side Near West Park, For Some Reason
EGLE and City Council members have again indicated a Consent Judgement (CJ) Agreement with Danaher/Pall/Gelman on the cleanup of the 1,4-Dioxane plume is still in negotiations and no word on progress or end date.
Again Coalition for Action on Remediation of Dioxane (CARD) commented at the last meeting that clearly delays in dealing with the Gelman Plume is a clear win for Gelman and a loss for the community, the environment and our economy.
West Park NSG Tests EGLE & City of Ann Arbor, MDEQ 9-19-18
(ACWG, Rt click for larger)
The city and EGLE have indicated that they would be willing to work with U of M faculty on Vapor Intrusion (VI) issues related to near-surface groundwater (NSG, also called shallow groundwater) contamination on the westside of the city.
EGLE is delaying the NSG tests after commenting months ago they would have done additional testing and have results by now. CARD and ACWG members commented that these tests should have been done by now with no real comment for a reason for delays by EGLE.
A lab at U of M School of Public Health did tests near homes west of West Park and found no 1,4D near the surface. They are interested in validating their models of 1,4D VI into homes with 1,4D near the surface and are hoping to do additional tests here in Ann Arbor or elsewhere.
It was indicted to us by one of the original Gelman Plume activists that in the recent past there was 800 ppb in the lower aquafer at Wildwood Neighborhood, just 7 blocks away from West Park where 22 ppb was found in the last tested many months ago.
This from Dan Bicknell (Globel Environmental Alliance (GEA) and CARD member) to local officials recently in regards to NSG tests on the west side:
"As you may know from past GEA work, the most sensitive and likely areas for dioxane contaminated shallow groundwater to be in contact with basements is in the lower elevations of the West Park area (e.g., near Chapin Street). This is based upon: the general depth to dioxane contaminated shallow groundwater; the results of the 2019 DEQ-WRC Allen Creek Drain storm water sampling; the general topography; and the local shallow dioxane contaminated geologic unit indentified(sic) in the 2016 DEQ/Gelman Shallow Groundwater Report (Report). Attached are GEA Reports which discuss the 2019 Allen Creek Drain storm water sampling and the 2016 DEQ Shallow Groundwater Work Plan & Report."
"The City proposes to sample basements along Maple Ridge Street. Dioxane was not detected in the 2019 Allen Creek Drain storm water at the Maple Ridge sampling location (see first below figure), therefore, it is unlikely that the shallow dioxane plume is near the surface or basements in this area. Whereas, dioxane was detected in the 2019 Allen Creek Drain West Park and Chapin Street storm water sampling locations (17.3 ug/L and 9.1 ug/L respectively) indicating that dioxane contaminated shallow groundwater has infiltrated the storm water drain in this area. The 2019 storm water results demonstrate that there is a shallow dioxane plume near the surface and basements in the lower elevations of West Park and Chapin Street." (bold by us)
The city has still not involved stakeholders the Coalition for Action on Remediation of Dioxane (CARD) and ACWG on plans to test in the West Park area. The testing proposed will be of little value. Stakeholder involvement should be Job One at City Hall.
We currently have 22 ppb at West Park in the Near-Surface Groundwater (NSG, some also call shallow groundwater). 11 blocks upstream we have had 1,000 ppb at Vet's Park in recent years flowing toward West Park and beyond. CARD pressured EGLE to do these NSG tests and most were very surprised the 1,4 dioxane was in the NSG at such high levels and seemingly moving higher.
We have Gelman/Pall's own geological maps (!) from 2006 that show this would likely happen in West Park, as it now has.
As commented on before the Allen's Creek pipe in West Park has high flows in drought conditions because it picks up lots of seep's groundwater just upstream. This is to reduce the damage NSG can cause if left uncontrolled, like home and street undermining. This NSG is contaminated.
Contaminated Near-Surface Groundwater is now a near-term threat to the community and is an example of how Gelman/Danaher has not protected the community. West Park is now at 22 ppb in NSG yet we have no permanent wells to monitor this. This is just one of a myriad of examples of mismanagement of this threat to the community.
With all the work the CARD group, city and county have done the EPA will have a headstart on this effort. The EPA Score of the partial Superfund Evaluation was very high for Superfund Listing with a minimal evaluation. In this case, we have a Responsible Party that EPA will require to do and pay for cleanup as is happening now with other sites all over the country.
The Ann Arbor Township, Scio Township, Washtenaw County Board of Commissions, Sierra Club Huron Valley Group, and ACWG all voted in supported a petition to the US EPA for Full Preliminary Assessment of the Gelman 1,4-Dioxane groundwater contamination.
Governor Whitmer would be much more approachable than our previous Republican Governor when we present her with a US EPA Full Preliminary Assessment in a Superfund Petition. The former governor refused to allow US EPA to do a Full Evaluation when requested by US EPA.
The CARD Group has moved to virtual meetings like others starting in May for an undermined length of time, see details at Washtenaw County CARD site.
Links:
June 2020 Quarterly Coalition for the Remediation of Dioxane (CARD) Group Meeting Video - Taped by Roger Rayle, Chair CARD
Gelman Plume Related Stories by Ann Arbor News/MLive: MLive
Ann Arbor-area officials delay Gelman plume decision another month: MLive Ryan Stanton
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)
Ryan Stanton in Ann Arbor News/MLive: 'EPA holding off on Superfund designation for Gelman dioxane plume'
Lots of details from Barbara Lucus at Dioxane.Org and WEMU News Program GreenRoom
Washtenaw County CARD Site
See ACWG site pages EPA Superfund Option Details
Click here to view and/or sign in support of Superfund Designation
With Discussions of Affordable Housing or ANY HOUSING at 415 W. Washington New Flood Modeling Must be Done
415 W. Washington Proposed Affordable Housing
in Floodway ( Rt click for larger)
YMCA site with floodway obstructions shown in Red
(annotations in red and black ACWG, Rt click for larger)
The floodplain and floodway delineations for this site are arguably outdated and inaccurate and unsafe to unsuspecting individuals.
Y site across the street is not accurately included in flood hazard mapping with fencing and other obstructions across virtually the entire site acting as a huge dam for floodwaters, in the middle of the floodway, flowing to the river. ACWG strongly petitioned the MDEQ to stop the Y building and then later after the building was finished, the Y fencing but was not successful.
This fencing and other obstructions were installed after the building was finished.
Smith Group has commented in public meeting recently that the 2006 Y would 'never get approved today', and this group helped design the building in the floodway.
The Y lost the required FEMA Freeboard (open space 1' above the floodplain safety zone) in just 1.5 years after it was built, in a FEMA Letter of Map Revision (LoMR), and is out of state floodplain floodway compliance.
Y has regular flooding evacuation drills and worries about flood hazard according to a reliable inside source.
As we asked before and FOIA'ed the DDA - we would like to see the FTCH Study: The DDA's FTCH $1/4 to $1/2M budgeted consultants study of the watershed, just upstream of this site. should be made available to the public. The ACWG FOIA'ed the study but was just given a copy of the raw data and model run data used to do models but the report was never offered. FTCH said the DDA had to agree to make it available which they never did. These results were said to ACWG to be 'Very Surprising' by FTCH.
Recent credible reports have stated that FEMA "Low Balls" floodplain maps by up to 33% across the country due to reduced funding and political pressure.
High Flows On Eight Street Drain Inlet Next to Slauson Middle School Needs to Be Tested for 1, 4 Dioxane
Location of High Flow in Storm Drain, Circled in Red
(ACWG, Rt click for larger)
A street storm drain on 8th St. just east of Slauson Middle School has very high flows during very dry spells and, as is in West Park, should be tested for 1,4 Dioxane. These flows, like in West Park just a block to the southeast, are likely groundwater flows that are migrating into the drain and may be contaminated and therefore be tested. These flows could be coming from the same contaminated groundwater source as is in West Park.*
EGLE should include these tests with tests in West Park by easily sampling the flows in the drain through the street stormwater inlet grate.
This test, like the ones done in West Park, are simple, quick and important, and as such would be hard to deny the request. It would be much better to have permanent Near Surface Groundwater wells for testing but EGLE has denied the CARD and ACWG requests to install them at Gelman's expanse.*
Over the years this area has issues with high water table and, damp and wet basements.
ACWG will request that CARD join in a request that these tests be done by EGEL ASAP, during a dry period as is being done in West Park Allen's Creek.*
Link:
Washtenaw County CARD Site
EGLE, MEC - Now Common 500 Year Rains are Putting Stress on our Natural Systems and Our Ability to Deal With Them
An aerial view of the Sanford dam failure
(MI Advance; Rt click for larger)
Sanford and Edenville Dams were destroyed in a 500-year flood event after an 8-inch rain event in 2 days hit the Midland MI area. This event estimated to have caused $200 Million in damage.
'Tom Zimnicki, program director of groundwater, surface water and agriculture at Michigan Environmental Council (MEC), added that “stress to critical infrastructure will only intensify as the effects of climate change are realized.”
"In just the last six years, EGLE has recorded several 500-year storm events on different river systems throughout Michigan. These extreme events largely exceed the state’s regulatory criteria for dams and could foreshadow future disasters." '
Links:
Washtenaw County CARD Site
May 2020 - No Meeting this month due to COVID-19 Pandemic Cautions
Watershed Issues of Interest and Updates:
Danaher/Pall/Gelman 1,4-Dioxane Plume - U of M SPH and CE Lab Tests on West Side for 1,4 Dioxane Found NO 1,4D; Issues of Potentially Seeping or Flooding into Basements, or Other Confined Spaces
Michigan Department of Environment, Great Lakes, and Energy (EGLE) and City Council members have again indicated a Consent Judgement (CJ) Agreement with Danaher/Pall/Gelman on the cleanup of the 1,4-Dioxane plume is still in negotiations and no word on progress or end date.
Mayor Taylor keeps voting on Gelman CJ resolutions while his law firm has received close to $1/2M for work on the CJ. He says he is "decoupled".
This information about CJ funding from a recent Ryan Stanton's MLive article 12-20-19:
“ After three years of court battles and negotiations with polluter Gelman Sciences, local officials have spent over $1 million fighting for a better cleanup of the company’s dioxane plume.”
"... [for] Gelman litigation, increasing the city’s contract with Detroit-based Bodman PLC by $55,000, adding to $445,000 previously approved."
" Mayor Christopher Taylor is a partner at Hooper Hathaway, the law firm representing Scio Township in the Gelman litigation, and City Attorney Stephen Postema used to be a partner at Bodman, the law firm representing the city in the case."
"The township’s costs in the Gelman case for the last few years amount to just under $400,000, said Township Supervisor Jack Knowles, while the county reports spending more than $157,000."
"Taylor, who has supported litigating against the polluter in court, said he receives no financial benefit from his firm’s role in the case"...
" 'My finances are entirely decoupled from other partners’ performance,' Taylor said."
"Taylor has maintained it’s important for the city to have a seat at the table in the litigation"...
(bold by us)
Some council members and I do not agree he is 'decoupled' from his law firm as he affirms. His firm is greatly enhanced in value and stature with this high-value commission and that, it seems, cannot be decoupled. It seems he should recuse himself from all votes on this issue to avoid Conflict of Interest. or the Appearance of Conflict of Interest. Voting against a Superfund Petition and continuing on this endless CJ effort with contracts for his law firm could be seen as a means to increase contracts with, and stature for, his law firm while potentially causing harm to the community.
A lab at U of M School of Public Health did tests near homes west of West Park and found no 1,4D near the surface. They are interested in validating their models of 1,4D VI into homes with 1,4D near the surface and are hoping to do additional tests here in Ann Arbor or elsewhere.
The city has plans to test in the same areas but it seems like it would be much more productive to test more easterly where the water table seems to be higher and contaminated with up to 22 ppb 1,4D.
The city should have involved stakeholders the Coalition for Action on Remediation of Dioxane (CARD) and ACWG on plans to test in the West Park area. The testing proposed will be of little value. Stakeholder involvement should be Job One at City Hall.
At the last CARD meeting (YouTube video here) when specifically asked by ACWG EGLE has indicated that they are now evaluating Dr. Robert Bailey's modeling, saved on the ACWG site, of 1,4D VI, after over a year of asking to reevaluate 1,4D VI by CARD and ACWG. EGLE's proposed action level is 1,900 ppb where Dr. Bailey finds 100 ppb should be the action level.
The Coalition for Action on Remediation of Dioxane (CARD) and the ACWG have been pushing for this testing for years for testing of potential or existing Vapor Intrusion (VI) from this near-surface groundwater (shallow groundwater).
VI tests were proposed by U of M SPH and CE researchers (with equipment and funds to do the work) but no word if any of these efforts will be supported by the city or EGLE.
MI EGLE is doing additional tests in Allen's Creek watershed of near-surface groundwater (shallow groundwater). Results should be available soon.
We currently have 22 ppb at West Park in the Near-Surface Groundwater (NSG, some also call shallow groundwater). 11 blocks upstream we have had 1,000 ppb at Vet's Park in recent years flowing toward West Park and beyond. CARD pressured EGLE to do these NSG tests and most were very surprised the 1,4 dioxane was in the NSG at such high levels and seemingly moving higher.
We have Gelman/Pall's own geological maps (!) from 2006 that show this would likely happen in West Park, as it now has.
As commented on before the Allen's Creek pipe in West Park has high flows in drought conditions because it picks up lots of seep's groundwater just upstream. This is to reduce the damage NSG can cause if left uncontrolled, like home and street undermining. This NSG is contaminated.
Contaminated Near-Surface Groundwater is now a near-term threat to the community and is an example of how Gelman/Danaher has not protected the community. West Park is now at 22 ppb in NSG yet we have no permanent wells to monitor this. This is just one of a myriad of examples of mismanagement of this threat to the community.
With all the work the CARD group, city and county have done the EPA will have a headstart on this effort. The EPA Score of the partial Superfund Evaluation was very high for Superfund Listing with a minimal evaluation. In this case, we have a Responsible Party that EPA will require to do and pay for cleanup as is happening now with other sites all over the country.
The Ann Arbor Township, Scio Township, Washtenaw County Board of Commissions, Sierra Club Huron Valley Group, and ACWG all voted in supported a petition to the US EPA for Full Preliminary Assessment of the Gelman 1,4-Dioxane groundwater contamination.
Governor Whitmer would be much more approachable than our previous Republican Governor when we present her with a US EPA Full Preliminary Assessment in a Superfund Petition. The former governor refused to allow US EPA to do a Full Evaluation when requested by US EPA.
The CARD Group has moved to virtual meetings like others starting in May for an undermined length of time, see details at Washtenaw County CARD site.
Links:
May 2020 Coalition for the Remediation of Dioxane (CARD) Group Meeting Video - Taped by Roger Rayle, Chair CARD
Gelman Plume Related Stories by Ann Arbor News/MLive: MLive
Ann Arbor-area officials delay Gelman plume decision another month: MLive Ryan Stanton
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)
Ryan Stanton in Ann Arbor News/MLive: 'EPA holding off on Superfund designation for Gelman dioxane plume'
Lots of details from Barbara Lucus at Dioxane.Org and WEMU News Program GreenRoom
Washtenaw County CARD Site
See ACWG site pages EPA Superfund Option Details
Click here to view and/or sign in support of Superfund Designation
Proposed Affordable Housing Again in the Floodplain (likely floodway), at City-Owned Lot at 415 W. Washington
415 W. Washington Proposed Affordable Housing
in Floodway ( Rt click for larger)
Public Meeting on Housing in the Floodplain at this site.
City notice of meeting ( Rt click for larger)
This notice misleadingly does not state Proposed Affordable Housing, but at a public meeting on city-owned properties, this was clearly proposed as an Affordable Housing project in the Allen's Creek Floodplain (likely floodway).
Federal, and likely State, funds will not be available for this site due to its location in the floodway and floodplain.
One of the most dangerous sites in the City of Ann Arbor for housing or building due to major flood hazard.
In the 68 flood this site and main building were in many feet of floodwater trapping those attending a watershed meeting (of all things) from the drain office, city staff and interested residents.
Residents in Northern Ohio in recent years were killed trying to get cars out of parking areas, under their apartments/condos, in a flood.
With FEMA's poor floodplain maps this building will likely be in the real floodway not just many 10's of feet into the floodplain.
City has a long sordid history of placing disadvantaged in harm's way like floodplains and floodways
ACWG helped stop the city putting the Homeless Shelter in the floodway, losing $1M tax dollars in a failed plan in the floodway.
The Homeless Shelter was still built in the Floodplain with emergency exits into the Floodway!
President Obama virtually forbid using federal funds for building in the 100-year (1% chance) floodplain and virtually forbid the use of federal funds for building any critical structures in the 500-year (.2% chance) floodplain due to Global Warming effects causing more intense rain events.
Recent credible reports have stated that FEMA "Low Balls" floodplain maps by up to 33% across the country due to reduced funding and political pressure.
City staff has commented in public meetings that FEMA floodplain maps are very poorly calibrated flood maps and lack real data to guide them.
Y site across the street is not accurately included in flood hazard mapping with fencing across virtually the entire site acting as a huge dam for floodwaters, in the middle of the floodway, flowing to the river. ACWG strongly petitioned the MDEQ to stop the Y building and then the Y fencing but was not successful.
Smith Group has commented in public meeting recently that the 2006 Y would never get approved today, and this group helped design the building in the floodway.
Y lost the required FEMA Freeboard (safety zone) in 1.5 years after built-in a FEMA Letter of Map Revision (LoMR), and is out of state floodplain floodway compliance.
Y has regular flooding evacuation drills and worries about flood hazard according to a reliable inside source.
As we asked before and FOIA'ed the DDA - we would like to see the FTCH Study: The DDA's FTCH $1/4 to $1/2M budgeted consultants study of the watershed, just upstream of this site. should be made available to the public. The ACWG FOIA'ed the study but was just given a copy of the raw data and model run data used to do models but the report was never offered. FTCH said the DDA had to agree to make it available which they never did. These results were said to ACWG to be 'Very Surprising' by FTCH.
$1B plan for Climate Change!!! "But let's build in the floodplain and likely floodway".
Dr. Missy Stults city's Sustainability and Innovations Manager states at A2Zero Kickoff Meeting on Nov 11th 2020 when asked by the ACWG:
"No Building In Floodplain" Period. No discussion, no questions, just NO.
TaxBase is a huge buzz word with many in the Planning Commission and some on the council to justify any new development.
But a critical Tax Base is the existing Tax Base you don't "Throw Under The Bus".
The Old West Side is one of the most valuable areas in the city and has hundreds of homes that have been paying taxes close to a hundred years, and will pay property tax for decades longer, and many will be at risk if the floodplain and floodway are blocked with new developments greatly threatening existing Tax Base.
Floods recently in the lower Michigan area include 500 year rain with 3 deaths and $2B in losses, 500 year rains that washed out 13 bridges, and back to back 100 year rains.
Mayor Taylor said recently that Ann Arbor has personally experienced the effects of climate change, referencing a one-degree temperature increase during the last few years as well as a more than 45 percent increase in precipitation within the last 50 years.
Follow Adopted goals of the 2007 Flood Hazard Mitigation Plan, no building in the floodplain:
We should follow the Long-Past Adopted goals of the 2007 Flood Hazard Mitigation Plan the ACWG contributed to: "Public acquisition and management of flood-prone properties. Permanent relocation of flood-prone structures to areas outside the floodplain. Establish clear and consistent government policy for public-owned land in the floodplain aimed at preventing public buildings in the floodplain. Create Allen['s] Creek Greenway in the floodplain area. Regular data collection and modeling to update flood hazard maps Decrease Flood Insurance Rates by meeting FEMA required flood hazard mitigation recommendations." (bold by us)
NWS New Normal - 12" Flooding Rains: 'Heavy rain accompanied the thunderstorms with the hardest-hit areas across portions of Manistee, Mason, and Lake counties in northwest lower Michigan on July 20, 2019.' : NWS
12" rain in 24 hours caused flooding and severe erosion in the area. These types of historic rains are the new normal for Michigan and other parts of the nation, the 1,000-year June 2018 rain in the MI UP and 10,000-year April 2016 “Tax Day” rain in Houston for example.
“Increasing precipitation, especially heavy rain events, has increased the overall flood risk,” according to the most recent National Climate Assessment.
The Tree Line Greenway Conservancy asked the city to wait on actions on this site, which is being ignored.
This site best and most valuable use is clearly to be part of the Tree Line Greenway, Allen's Creek Greenway.
Here is as Association of State Floodplain Managers (ASFPM) logo (on left below) on City Official Planning Documents yet ASFPM cartoon (on right) makes fun of communities building in the Floodplain, like not so smart Ann Arbor!:
Links: https://www.citylab.com/newsletter-editions/2019/07/maplab-hidden-risks-flood-maps/595126/
Lake Michigan-Huron Recorded at Highest in Recorded History Due to Excessive Rain Fall Amounts In the Region in Recent Years Due to Global Warming Effects
MLive - MI Upper Peninsula 1,000 Year Rain
June 2018, Massive Historic Flooding (rt click for larger image)
Last month, the Army Corps of Engineers reported water levels on Lakes Michigan and Huron are measuring about 3 foot higher than average. That’s the highest in recorded history. This record high water is largely due to excessive rainfall amounts in recent years.
Current educated predictions are that this will not end anytime soon and may well get worse with the commensurate flood hazard.
April 2021 - No Meeting this month due to COVID-19 Pandemic Cautions
Watershed Issues of Interest and Updates:
Danaher/Pall/Gelman 1,4-Dioxane Plume - City to Test Basements on West Side for 1,4 Dioxane Potentially Seeping or Flooding into Basements or Other Confined Spaces
The city is planning to test basements on West Side for water in basements for potential contamination from the Gelman 1,4-Dioxane plume as it flows under the city.
The Coalition for Action on Remediation of Dioxane (CARD) and the ACWG have been pushing for this testing for years, to do tests for potential or existing Vapor Intrusion (VI) from this near-surface groundwater (shallow groundwater).
VI tests were proposed by U of M researchers (with equipment and funds to do the work) but no word if any of these efforts will be supported by the city or Michigan Department of Environment, Great Lakes, and Energy (EGLE).
Residents are not being protected if this compound is allowed to percolate into basements and evaporate (VI -Vapor Intrusion) into this confined space and expose the residents. Many Ann Arbor residents use their basements for play space, workspace, office space, ...
These tests will cost $40,000 of city tax dollars, when Gelman should be doing the tests.
If we had a Superfund designation EPA would force Gelman to do and pay for the work.
MI EGLE is doing additional tests in Allen's Creek watershed of near-surface groundwater (shallow groundwater). Results should be available soon.
Many Council members are supportive of a proposal to submit a petition for EPA Superfund site. Some have asked Council to wait to see if a consensus can be reached before voting on a Petition. A council resolution to Petition EPA has been tabled for several months.
We currently have 22 ppb at West Park in the Near-Surface Groundwater (NSG, some also call shallow groundwater). 11 blocks upstream we have had 1,000 ppb at Vet's Park in recent years flowing toward West Park and beyond. Coalition for Action on Remediation of Dioxane (CARD) pressured EGLE to do these NSG tests and most were very surprised the 1,4 dioxane was in the NSG at such high levels and seemingly moving higher.
We have Gelman/Pall's own geological maps from 2006 that show this would likely happen in West Park, as it now has.
As commented on before the Allen's Creek pipe in West Park has high flows in drought conditions because it picks up lots of seep's groundwater just upstream. This is to reduce the damage NSG can cause if left uncontrolled, like home and street undermining. This NSG is contaminated.
Contaminated Near-Surface Groundwater is now a near-term threat to the community and is an example of how Gelman/Danaher has not protected the community. West Park is now at 22 ppb in NSG yet we have no permanent wells to monitor this. This is just one of a myriad of examples of mismanagement of this threat to the community.
With all the work the CARD group, city and county have done the EPA will have a headstart on this effort. The EPA Score of the partial Superfund Evaluation was very high for Superfund Listing with a minimal evaluation. In this case, we have a Responsible Party that EPA will require to do and pay for cleanup as is happening now with other sites all over the country.
The Ann Arbor Township, Scio Township, Washtenaw County Board of Commissions, Sierra Club Huron Valley Group, and ACWG all voted in supported a petition to the US EPA for Full Preliminary Assessment of the Gelman 1,4-Dioxane groundwater contamination.
Governor Whitmer would be much more approachable than our previous Republican Governor when we present her with a US EPA Full Preliminary Assessment in a Superfund Petition. The former governor refused to allow US EPA to do a Full Evaluation when requested by US EPA.
The CARD Group has moved to virtual meetings like others starting in May for an undermined length of time, see details at Washtenaw County CARD site.
Links:
March 2020 Coalition for the Remediation of Dioxane (CARD) Group Meeting Video - Taped by Roger Rayle, Chair CARD
Gelman Plume Related Stories by Ann Arbor News/MLive: MLive
Ann Arbor-area officials delay Gelman plume decision another month: MLive Ryan Stanton
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)
Ryan Stanton in Ann Arbor News/MLive: 'EPA holding off on Superfund designation for Gelman dioxane plume'
Lots of details from Barbara Lucus at Dioxane.Org and WEMU News Program GreenRoom
Washtenaw County CARD Site
See ACWG site pages EPA Superfund Option Details
Click here to view and/or sign in support of Superfund Designation
The City of Ann Arbor Does Full Cleanup of DTE Site At RR Berm Opening, DTE and Developer Not So Much Proposed For the Rest of Polluted DTE Site at Depot St and 841 Broadway St In the FW FP
Recent photo of piles of polluted soil temporally stored by city on
DTE site from work to cut opening in the Berm under the RR Tracks
and connect the B2B trail to the Treeline/Greenway
(ACWG, Rt Click for Larger Image)
DTE Site, Mostly Floodway in Blue
City of Ann Arbor GIS Web Site (Annotations ACWG; Rt Click for Larger View)
Coal Tar (highly toxic) found at the DTE Site and shown by DEQ/EGLE
at river's edge at the site, the pollution at the river's edge
subsequently cleaned up in recent years
but is still leaching into the Huron River (WUOM)
The city has recently received a draft Letter Of Map Revision FEMA (LoMR) for DTE site with some changes in the floodplain floodway map. Staff has said they will review and comment on the LoMR. A 120 day comment period is allowed for this LoMR, normally only 90 days before potential adoption.
The city has started work on the Berm Opening Project and has stockpiled the contaminated soil for later removal on an existing concrete slab with tarp covers.
The ACWG attended all the public meetings on this Berm Opening project and was instrumental, with years of effort, in its adoption and the addition of a pedestrian and bike tunnel next to the stormwater tunnel. This will greatly reduce flooding in the upstream neighborhood and protect homeowners, the environment and city tax base in the area. The berm acts as a dam of flowing stormwater to the river causing flooding and property damage.
Developer and DTE has no plans for a full cleanup of the site they plan to build condos and a hotel on top of the highly toxic Coal Tar and other pollution. The ACWG has attended many meetings about this project and not support the proposal.
With buildings sitting on top of this polluted site the state proposed polluter pay clean up will be very difficult or impossible no matter how strong the new law is.
Recent photo of the southwest side of DTE site near the city
berm opening construction area with very high water levels
(ACWG, Rt Click for larger image)
With such high water levels without major storm event at the DTE site it is hard to imagine when we have another 100-year or larger rain in the area how this site will fair. The wall will block the flooding of the site according to the developer's comments at public meetings.
Staff had indicated the developer's models presented for the LoMR:
Do not accurately portray the railroad berm damming effect - they do not show it continuously dropping off to level grade at the AmTrak Station making the site more flood-prone, according to city staff
Do not include current data used by the city for 100-year (1% chance) rainfall amounts, according to city staff
Do not take into account the very poorly calibrated flood maps used for this site, according to city staff passed comments
In the 1968 100-Year (1% chance) Flood, we had 15 Feet of Flood Water careening across this site, most of the dams were damaged some breached and destroyed.
Groundwater on site is contaminated up to 30 feet down but downriver groundwater has not been tested. This is the site of the old river bed where generally groundwater wants to flow.
The city recently passed a resolution in support of the State's Proposed Polluter Pay Legislation yet seems supportive of building on top of a toxic DTE Coal Tar site with very little cleanup. These Engler GOP Polluted Sites are caused by the very weak MI Engler GOP Part 201 "Environmental" laws.
"What’s kind of a like a zombie rising from the grave is these buried contaminants that are now showing up in people’s homes, in their air, specifically. That was not envisioned by the science at the time; if you left chemicals in the ground they could actually migrate up through even impervious surfaces and affect people’s health." Dave Dempsey, For The Love Of Water FLOW - WUOM (bold by us)
DTE, a $26B company, should be doing a full cleanup of this site as the Responsible Party Legal Owner, not taxpayers.
The ACWG is reviewing the LoMR and is considering an unsupportive comment to FEMA under the 120-day comment period, the city should also submit an unsupportive comment.
Links: http://michiganradio.org/post/1994-michigan-ok-d-partial-pollution-cleanups-now-we-have-2000-contaminated-sites
City of Ann Arbor Project Page https://www.a2gov.org/departments/engineering/Pages/Allen-Creek-Railroad-Berm-Project.aspx
"State hits Ann Arbor with $45K penalty fine for repeated sewage overflows"; ACWG Has Worked Hard to Improve the Utilities and the Environment in Ann Arbor
Vince Caruso showing Glendale area flooding
resident survey results at a Council Meeting
(Ann Arbor, CTN)
" Ann Arbor must pay a $45,000 fine for repeated sewage overflows in recent years.
The penalty is included in terms of an administrative consent order with the Michigan Department of Environment, Great Lakes and Energy approved by City Council this week.
The 21-page document outlines several sewage overflows since 2016, including some discharging large amounts into the Huron River and Malletts Creek." Ryan Stanton - MLive
As in the case in the Glendale Virginia Sts area, with constant home, yard, street flooding and basement sewer backup, with the help of the ACWG, the neighbors did a survey and showed about 50% of the homes had flooding issues. See ACWG June 20, 2019 entry and others for more details.
Only after the survey was presented did the city take action and found 3 sewer lines blocked, two sanitary and one freshwater runoff (stormwater). This should not be the way we operate.
The city has indicated they are working on a more proactive management plan. If the complaints of the Glendale area over many years had resulted in TVing the sewer lines to look for the reasons for flooding problems much of the flooding could have been avoided.
The health and safety, environment and tax base of a community are very closely tied and not exclusive, we need to preserve them all.
The ACWG has been working for over 20 years to improve the utilities including:
Supporting and was deposed for evidence in a court case the city won relating to footer disconnect from sanitary sewer systems, which has greatly reduced sanitary and freshwater runoff (stormwater) issues. We stopped the original plan to build many huge sewage holding tanks in our wooded park spaces. The director of utilities was removed after this debacle occurred.
Got passed by council the Green Streets Policy with the Environmental Commission Water Committee (my wife Rita was chair) and city staff - any street rebuild must be evaluated for Green Street Policy to reduce building cost, pollution, runoff and introduce infiltration. Green Streets are less costly than conventional without all the obvious benefits, which was agreed with from comments on by city staff.
Instrumental in helping the neighborhood create the Dicken Woods area to reduce flooding and preserving a wetland area from condo development in the flood-prone Dicken Neighborhood attending many neighborhood meetings, planning commission meetings and council meetings.
Stopped the city from building the homeless shelter in the floodway which would have been illegal and cause more flooding in the Old West Side, the scraped plan in the floodway cost taxpayers $1M. The shelter was still placed in the floodplan, a common building location for disadvantaged in Ann Arbor, and still proposed today.
Instrumental in stopping development of the First and William parking garage in the Allen('s) Creek floodway.
Promoted the use of and utility fee rebates for rain barrels, rain gardens, bioswales in Ann Arbor.
Tried to stop construction of the Y blocking a key section of the Allen('s) Creek the floodway that is now said could never happen today by the consultant who helped plan the development. We had unsuccessfully petitioned the DEQ to stop plans for fencing in the nearly the entire site. The fencing still should be taken out in the floodway as it is making the Old West Side unnecessarily more flood-prone and dangerous. Chain link fence is treated like a solid concrete wall in hydrological modeling.
...
Ann Arbor Planning Commission has a Working Session on Floodplain Overlays, Little Notice of Proposed Major Changes to City Code
Association of State Floodplain Managers 2007 (ASFPM) (Rt Click for larger image)
"BUILDING IN THE FLOODPLAIN IS LIKE PITCHING YOUR TENT ON A HIGHWAY WHEN THERE ARE NO CARS COMING"! ASFPM: www.floods.org
Planning Commission Working Session will be held on Tuesday, April 14, 2020 at 7 pm and is available for live listening and call-in comments and questions. Please call 888-788-0099, enter meeting ID 162 641 977.
The Working Session agenda includes presentations and discussion about:
Floodplain Management Overlay District and Regulations - a proposed amendment to Chapter 55 Unified Development Code
The ACWG did not get timely notice until a few days ago on this meeting and this proposal.
Sorry to say no public outreach or stakeholder outreach has occurred that we are aware since the City Council shot down a Floodplain Overlay proposal from the city staff and Ford School Graduate students, who spent over two years working on this, in 2016. The ACWG was pushing and working for this proposal with others for years before it was shot down.
After shooting down the proposal city went on to approve over 120 new homes in the floodplain some with parking on top of the Allen's Creek pipe in a very flood-prone area off W. Kingsley.
Public outreach or stakeholder outreach should be JOB ONE for our city government.
This proposal allows development in the floodplain which the ACWG and American Association of State Floodplain Managers (ASFPM) do not support. With Global Warming effects now hitting Michigan with record rainfall amounts every year, 1,000-year rain in the UP in 2018 for example, we need to be very careful how we develop in our city especially in the very dangerous flashy Allen's Creek watershed.
ACWG has proposed for decades Ann Arbor reduce the size of our floodplains and make a safer city with obvious changes in weather patterns. Green Streets, porous pavement for parking and streets, rain catchment and rain infiltration, Greenway in the Allen's Creek Floodplain, stronger regulations, are just some of the efforts.
Recent talk by some city leaders has been to put Affordable Housing in our very dangerous floodplains. Unfortunately, this has been a very sad sordid history of the treatment of the less fortunate in Ann Arbor.
President Obama virtually forbid using federal funds for building in the 100-year (1% chance) floodplain and virtually forbid the use of federal funds for building any critical structures in the 500-year (.2% chance) floodplain due to Global Warming effects causing more intense rain events.
Recent credible reports have stated that FEMA "Low Balls" floodplain maps by up to 33% across the country due to reduced funding and political pressure.
Eppie Potts, One of the Original Founding Members of the ACWG Died Earlier This Month
Ethel (Eppie) Potts (The Ann Arbor Chronicle)
Eppie was involved in many good things that happened in Ann Arbor and was very effective and pleasant doing it.
Eppie got involved and helped create the ACWG when we unsuccessfully tried to stop the city from bulldozing a private woodland and installed a 500' 8'x5' pipe in one of the few remaining open sections of the Allen's Creek due to very poor city planning, at cost of almost $1/2M in taxpayer funds and loss to the environment and tax base.
Eppie was active till the week she died sending emails of support and comment on the keeping of the existing AmTrak Station on Depot St. and not building an out of the way big parking garage-little RR station at Fuller next to the hospital in our Fuller City Park.
She was loved and will be greatly missed by her family and many in the Ann Arbor area, but we learned a lot of great things from Eppie.
https://www.mlive.com/news/ann-arbor/2020/03/ethel-potts-former-ann-arbor-planning-official-and-pottery-artist-dies-at-95.html Ryan Stanton - Mlive
March 2020 - No Meeting this month due to COVID-19 Pandemic Cautions
Watershed Issues of Interest and Updates:
Posters from U of M M-LEEaD Center's: "From PBB to PFAS: Research and Action to Address Michigan’s Large-Scale Chemical Contaminations" - U of M Earth Day at 50; February 20, 2020
Members of the CARD Group and ACWG attended and presented posters in the Poster Session at this meeting. Posters show below discuss Vapor Intrusion for 1,4 Dioxane poorly studied and published issue, and the work of the CARD Group in Scio and Ann Arbor Townships and City of Ann Arbor.
CARD Poster 1,4 Dioxane Groundwater Contamination
( Rt Click for larger or Click to View PDF on ACWG Web Page)
CARD Bailey Poster: 1,4 Dioxane Vapor Intrusion (VI)
For more information contact Dr. Robert Bailey at: bob.bailey734(at)gmail.com
( Rt Click for larger or Click to View PDF on ACWG Web Page)
From Left to Right: Vince Caruso Board Member CARD ACWG;
Beth Collins Board Member CARD;
Dr. Robert Bailey Member CARD -
Presenting Posters at U of M M-LEEaD Event
(Photo Beth Collins, CARD)
U of M - Michigan Center on Lifestage Environmental Exposures and Disease (M-LEEaD). Support for M-LEEaD Center is provided by grant P30ES017885 from the National Institute of Environmental Health Sciences, National Institutes of Health; THE PBB TO PFAS SYMPOSIUM IS ORGANIZED BY: The University of Michigan M-LEEaD Center, Emory University’s HERCULES Center, and Central Michigan University
YouTube Video of Meeting by M-LEEaD U of M SPH Center: https://www.youtube.com/playlist?list=PLt4u9Gmt5XuI18jrOQBfcg3MZClie2zUJ
Web Page: http://mleead.umich.edu/Event_FromPBBtoPFAS.php
Danaher/Pall/Gelman 1,4-Dioxane Plume - Elected Officials Have Received Final Changes in Consent Judgement with Gelman, Still No Word on Decision on Text Disclosure or Agreement of Consent Judgment In Lieu of Petitioning US EPA for Superfund Standing and Potential Cleanup
City Council has indicated a Consent Judgement (CJ) Agreement with Danaher/Pall/Gelman on cleanup of the 1,4-Dioxane plume could be/is at an end. ACWG and CARD members attended Judge Connor's court session last week. They went into closed meeting discussions on the proposed CJ.
No word on the outcome of these or later discussions on the proposed CJ.
Many Council members are supportive of a proposal to submit a petition for EPA Superfund site. Some have asked Council to wait to see if a consensus can be reached before voting on a Petition. A council resolution to Petition EPA has been tabled for several months.
Ann Arbor officials may have misled the public:
If the elected officials come to an agreement on a new Consent Judgement (CJ) Ann Arbor officials may have misled the public when they said they will present it to the community before council has a vote on it's acceptance. It has been commented recently by Council and others that this may not be an option given the agreement on the confidentiality of the CJ discussions. If it is not agreed upon it cannot be released, and it cannot be released until it is approved.
Some of the main issues and questions currently facing us related to the Gelman Plume that are not being addressed are making our community less safe.
As I commented at the December 12th Joint Session of Michigan Department of Environment, Great Lakes, and Energy (EGLE) and local government bodies, during public comment at this meeting, we have a Gelman's Illicit Discharge into a Michigan MS4 system for 2 years now, the Allen('s) Creek flowing to the Huron River, Dan Bicknell GEA has investigated and communicated in more detail on the issues of MS4. I also commented that residents are not being protected if this compound is allowed to percolate into basements and evaporate (VI -Vapor Intrusion) into this confined space and expose the residents. Many Ann Arbor residents use their basements for play space, work space, office space, ...
The current Consent Judgement (CJ) does not address this VI issue or have oversite of it.
We currently have 22 ppb at West Park in the Near-Surface Groundwater (NSG, some also call shallow groundwater). 11 blocks upstream we have had 1,000 ppb at Vet's Park in recent years flowing toward West Park and beyond. Coalition for Action on Remediation of Dioxane (CARD) pressured EGLE to do these NSG tests and most were very surprised the 1,4 dioxane was in the NSG at such high levels and seemingly moving higher.
We have Gelman/Pall's own geological maps from 2006 that show this would likely happen in West Park, as it now has.
As stated before EGLE has a (proposed) 1,900 ppb standard for VI which may be too high. They and EPA have not commented on the 100 ppb Action Level technically detailed technical proposal submitted by some CARD members to EPA and EGLE for evaluation over a year ago.
Ann Arbor should be using the 100 ppb until EGLE or EPA comes back with evaluations by Dr. Bailey showing 100 ppb should be the Action Level for near-surface groundwater near buildings.
Michigan MS4 Regulation:
'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)
Under the MS4 permit, it would seem no dioxane contamination at any level should be legally allowed to infiltrate/seep into the MS4 storm drain (without a NPDS Permit which they do not seem to have), Allen's Creek at West Park for example, yet it clearly has for 2 years.
As commented on before the Allen's Creek pipe in West Park has high flows in drought conditions because it picks up lots of seep's groundwater just upstream. This is to reduce the damage NSG can cause if left uncontrolled, like home and street undermining. This NSG is contaminated.
Coalition for Action on Remediation of Dioxane (CARD) and Allen’s Creek Watershed Group (ACWG) have again this past CARD Meeting requested additional NSG tests upstream of West Park to try to understand the 22 ppb finding in recent West Park NSG tests. These additional tests will help locate where permanent NSG well monitoring should be located. EGLE has stated they will be doing additional tests but not all we have requested.
It seems apparent that these developments on NSGs increasing quickly speaks to the need for a Superfund petition to deal with this clear and present danger to the West Side of Ann Arbor homes and businesses. The standard for NSG 1,4 dioxane is not clear, but EGLE started at 29 ppb then jumped to 1,900 ppb now they are using 280 ppb. Robert Bailey PhD, CARD member, calculated a proposed level of 100 ppb.
Again, we have again requested permanent NSG well monitoring. Dan Bicknell's GEA Comments on the DEQ Shallow Groundwater Work Plan and his proposed plan is posted in November 2016. Dan had a very well and logical plan laid out for dealing with the initial investigation of the NSG issue which seems to be clearly a problem that needs addressing.
Contaminated Near-Surface Groundwater is now a near-term threat to the community and is an example of how Gelman/Danaher has not protected the community. West Park is now at 22 ppb in NSG yet we have no permanent wells to monitor this. This is just one of a myriad of examples of mismanagement of this threat to the community.
Even if it is included in a new consent judgment agreement, we will be relying on EGLE and Gelman/Danaher to do a very weak job of protecting the community with containment, not cleanup. State law Part 201 is very weak and not protective in the long term. EPA has a much stronger cleanup standard.
With all the work the CARD group, city and county have done the EPA will have a headstart on this effort. The EPA Score of the partial Superfund Evaluation was very high for Superfund Listing with a minimal evaluation. In this case, we have a Responsible Party that EPA will require to do and pay for cleanup as is happening now with other sites all over the country.
The Ann Arbor Township, Scio Township, Washtenaw County Board of Commissions, Sierra Club Huron Valley Group, and ACWG all voted in supported a petition to the US EPA for Full Preliminary Assessment of the Gelman 1,4-Dioxane groundwater contamination.
Governor Whitmer would be much more approachable than our previous Republican Governor when we present her with a US EPA Full Preliminary Assessment in a Superfund Petition. The former governor refused to allow US EPA to do a Full Evaluation when requested by US EPA.
Links:
March 2020 Coalition for the Remediation of Dioxane (CARD) Group Meeting Video - Taped by Roger Rayle, Chair CARD
Gelman Plume Related Stories by Ann Arbor News/MLive: MLive
Ann Arbor-area officials delay Gelman plume decision another month: MLive Ryan Stanton
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)
Ryan Stanton in Ann Arbor News/MLive: 'EPA holding off on Superfund designation for Gelman dioxane plume'
Lots of details from Barbara Lucus at Dioxane.Org and WEMU News Program GreenRoom
See ACWG site pages EPA Superfund Option Details
Click here to view and/or sign in support of Superfund Designation
President Trump States All Buildings Must Not Be in Flood Zones In the United States, Eminent Domain Should Be Used: NYT 3-11-20
W. Kingsley St Ann Arbor Recent Flooding in Floodplain
with Over One Hundred of NEW Homes added in Ann Arbor's Floodplain
(AAChronicle; Rt Click for Larger)
MLive - MI UP 1,000 Year Rain; 2018 ( Rt Click for larger image)
President Trump had declared all homes in the flood zones should be removed, even if Eminent Domain is required to remove them.
From the New York Times - March 11, 2020:
"The federal government is giving local officials nationwide a painful choice: Agree to use eminent domain to force people out of flood-prone homes, or forfeit a shot at federal money they need to combat climate change.
That choice, part of an effort by the Army Corps of Engineers to protect people from disasters, is facing officials from the Florida Keys to the New Jersey coast, including Miami, Charleston, S.C., and Selma, Ala. Local governments seeking federal money to help people leave flood zones must first commit to push out people who refuse to move." (bold by us)
This after the city of Ann Arbor has killed a million-dollar floodplain map overlay planning effort, created over 2 years by Ford School Graduate Students with lots of help from city staff, to reduce flood hazard, then a year or so later permitted over 110 new homes in the very 'poorly calibrated floodplain' as described by local experts and city staff.
With mega-storms hitting Michigan every year now, 1,000-year (0.1% chance) storm summer 2018, 500-year (.2% chance) storms almost every year, Ann Arbor is not being protective of the community.
President Obama virtually forbid using federal funds for building in the 100-year (1% chance) floodplain and virtually forbid the use of federal funds for building any critical structures in the 500-year (.2% chance) floodplain due to Global Warming effects causing more intense rain events.
Any structure secured by a loan from federally regulated lenders which is located in a Special Flood Hazard area (A or V zones) must have flood insurance as required under the U.S. Flood Disaster Protection Act. This includes condominiums/high-rise structures. FDIC
Link: https://www.nytimes.com/2020/03/11/climate/government-land-eviction-floods.html
Discussions of Development of Polluted DTE Site at Depot St and 841 Broadway St In the FW FP, Unlike the City Effort, No Real Cleanup Proposed, Like "Zombies Rising Up"
DTE Site, Mostly Floodway in Blue (City of Ann Arbor GIS Web Site; Rt Click for Larger View)
Coal Tar (highly toxic) found at the DTE Site and shown by DEQ/EGLE staff at
river's edge at the site, the pollution at the river's edge
subsequently cleaned up in recent years (WUOM) but is still leaching into the Huron River
The city has recently received a draft Letter Of Map Revision FEMA (LoMR) with some changes in the floodplain floodway map [calculated by and submitted to FEMA by the developer of the DTE site*]. Staff has said they will review and comment on the LoMR.
At the Ground Breaking for the Berm Opening Project on Depot St. and DTE site in February the city indicated they will do a full cleanup where the work is done including on the DTE site because it is the right thing to do and funding sources require it.
Staff had indicated the developer's models presented for the LoMR:
Do not accurately portray the railroad berm damming effect - they do not show it continuously dropping off to level grade at the AmTrak Station making the site more flood-prone, according to city staff
Do not include current data used by the city for 100-year (1% chance) rainfall amounts, according to city staff
Do not take into account the very poorly calibrated flood maps used for this site, according to city staff passed comments
In the 1968 100-Year (1% chance) Flood, we had 15 Feet of Flood Water careening across this site, most of the dams were damaged some breached and destroyed. Groundwater on site is contaminated but downriver has not been tested and pollution is 30' down on the site.
The city recently passed a resolution in support of the State's Proposed Polluter Pay Legislation yet seems supportive of building on top of a toxic DTE Coal Tar site with very little cleanup.
These Engler GOP Polluted Sites are caused by the very weak MI Part 201 "Environmental" laws.
"What’s kind of a like a zombie rising from the grave is these buried contaminants that are now showing up in people’s homes, in their air, specifically. That was not envisioned by the science at the time; if you left chemicals in the ground they could actually migrate up through even impervious surfaces and affect people’s health." Dave Dempsey, For The Love Of Water FLOW - WUOM (bold by us)
DTE, a $26B company, should be doing a full cleanup of this site as the Responsible Party Legal Owner, not taxpayers.
The ACWG is reviewing the LoMR and is considering an unsupportive comment to FEMA under the 90-day comment period, the city should also submit an unsupportive comment.
Links: http://michiganradio.org/post/1994-michigan-ok-d-partial-pollution-cleanups-now-we-have-2000-contaminated-sites
City of Ann Arbor Project Page https://www.a2gov.or
February 2021 - No Meeting this month due to COVID-19 Pandemic Cautions
Watershed Issues of Interest and Updates:
UPDATE: CARD Poster from M-LEEaD 2-20-20 Meeting:
Click here or image below to go to ACWG Web Page for full PDF version.
CARD Poster (CARD)
See details below in this date's Agenda entry.
Danaher/Pall/Gelman 1,4-Dioxane Plume - Elected Officials Still Negotiating Changes in Consent Judgement with Gelman In Lieu of Petitioning US EPA for Superfund Standing and Potential Cleanup
The Public, local elected officials, Michigan Department of Environment, Great Lakes, and Energy (EGLE) and EPA Officials had a discussion and a Question-Answer Session on January 16 on the options for designating the Danaher/Pall/Gelman 1,4-Dioxane plume a potential EPA Superfund site.
The officials attending the January Joint Session have postponed judgment on EPA Superfund option till after the January 16 meeting. No word on changes in policy although negotiations with Gelman are still ongoing and are said to be coming to a close soon.
If the elected officials come to an agreement on a new Consent Judgement (CJ) Ann Arbor officials will present it to the community before council has a vote on acceptance.
Representative Debbie Dingell has arranged for this meeting and to allow for questions and comments about the potential options for a cleanup of this plume.
Congresswoman Debbie Dingell, Officials from the Environmental Protection Agency (EPA), Michigan Department of Environment, Great Lakes, and Energy (EGLE), the Office of the Michigan Attorney General, and local elected officials were present, and stakeholders and the public had an opportunity to ask questions and make comment. See link for YouTube video by Roger Rayle CARD/SRSW.
Vince Caruso and Rita Loch-Caruso PhD Making Comment at Joint Session on 12-12-19 (Roger Rayle Video SS, Rt Click for Larger)
Some of the main issues and questions currently facing us related to the Gelman Plume that are not being addressed are making our community less safe.
As I commented at the December 12th Joint Session of EGLE and local government bodies, during public comment at this meeting, we have a Gelman's Illicit Discharge into a Michigan MS4 system for 2 years now, the Allen('s) Creek flowing to the Huron River, Dan Bicknell GEA has investigated and communicated in more detail on the issues of MS4. I also commented that residents are not being protected if this compound is allowed to percolate into basements and evaporate (VI -Vapor Intrusion) into this confined space and expose the residents. Many Ann Arbor residents use their basements for play space, workspace, office space, ...
The current Consent Judgement (CJ) does not address this VI issue or have oversite of it.
We currently have 22 ppb at West Park in the Near-Surface Groundwater (NSG, some also call shallow groundwater). 11 blocks upstream we have had 1,000 ppb at Vet's Park in recent years flowing toward West Park and beyond. Coalition for Action On Remediation of Dioxane (CARD) pressured EGLE to do these NSG tests and most were very surprised the 1,4 dioxane was in the NSG at such high levels and seemingly moving higher.
We have Gelman/Pall's own geological maps from 2006 that show this would likely happen in West Park, as it now has.
As stated before EGLE has a (proposed) 1,900 ppb standard for VI which may be too high. They and EPA have not commented on the 100 ppb Action Level technically detailed technical proposal submitted by some CARD members to EPA and EGLE for evaluation.
Michigan MS4 Regulation:
'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)
Under the MS4 permit, it would seem no dioxane contamination at any level should be legally allowed to infiltrate/seep into the MS4 storm drain (without a NPDS Permit which they do not seem to have), Allen's Creek at West Park for example, yet it clearly has for 2 years.
As commented on before the Allen's Creek pipe in West Park has high flows in drought conditions because it picks up lots of seep's groundwater just upstream. This is to reduce the damage NSG can cause if left uncontrolled, like home and street undermining. This NSG is contaminated.
CARD and Allen’s Creek Watershed Group (ACWG) have again this past CARD Meeting requested additional NSG tests upstream of West Park to try to understand the 22 ppb finding in recent West Park NSG tests. These additional tests will help locate where permanent NSG well monitoring should be located. EGLE has stated they will be doing additional tests but not all we have requested.
It seems apparent that these developments on NSGs increasing quickly speaks to the need for a Superfund petition to deal with this clear and present danger to the West Side of Ann Arbor homes and businesses. The standard for NSG 1,4 dioxane is not clear, but EGLE started at 29 ppb then jumped to 1,900 ppb now they are using 280 ppb. Robert Bailey PhD, CARD member, calculated a proposed level of 100 ppb.
Again, we have again requested permanent NSG well monitoring. Dan Bicknell's GEA Comments on the DEQ Shallow Groundwater Work Plan and his proposed plan is posted in November 2016. Dan had a very well and logical plan laid out for dealing with the initial investigation of the NSG issue which seems to be clearly a problem that needs addressing.
Contaminated Near-Surface Groundwater is now a near-term threat to the community and is an example of how Gelman/Danaher has not protected the community. West Park is now at 22 ppb in NSG yet we have no permanent wells to monitor this. This is just one of a myriad of examples of mismanagement of this threat to the community.
Even if it is included in a new consent judgment agreement, we will be relying on EGLE and Gelman/Danaher to do a very weak job of protecting the community with containment, not cleanup. State law Part 201 is very weak and not protective in the long term. EPA has a much stronger cleanup standard.
With all the work the CARD group, city and county have done the EPA will have a headstart on this effort. The EPA Score of the partial Superfund Evaluation was very high for Superfund Listing with a minimal evaluation. In this case, we have a Responsible Party that EPA will require to do and pay for cleanup as is happening now with other sites all over the country.
The Ann Arbor Township, Scio Township, Washtenaw County Board of Commissions, Sierra Club Huron Valley Group, and ACWG all voted in supported a petition to the US EPA for Full Preliminary Assessment of the Gelman 1,4-Dioxane groundwater contamination.
Governor Whitmer would be much more approachable than our previous Republican Governor when we present her with a US EPA Full Preliminary Assessment in a Superfund Petition. The former governor refused to allow US EPA to do a Full Evaluation when requested by US EPA.
Links:
Fourth Joint County/City/Townships Special Session Public/Stakeholders Q&A with EPA & EGLE officials on the Gelman Dioxane Plume & EPA Option January 16, 2020; YouTube - Taped by Roger Rayle, Chair CARD
February 2020 Coalition for the Remediation of Dioxane (CARD) Group Meeting Video - Taped by Roger Rayle, Chair CARD
Gelman Plume Related Stories by Ann Arbor News/MLive: MLive
Ann Arbor-area officials delay Gelman plume decision another month: MLive Ryan Stanton
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)
Ryan Stanton in Ann Arbor News/MLive: 'EPA holding off on Superfund designation for Gelman dioxane plume'
Lots of details from Barbara Lucus at Dioxane.Org and WEMU News Program GreenRoom
See ACWG site pages EPA Superfund Option Details
Click here to view and/or sign in support of Superfund Designation
Discussions on Vapor Intrusion (VI) Modeling and Tests for 1,4 Dioxane in Ann Arbor
MLive (Red Text Annotated on left by us; Rt Click for Larger)
Card Group and ACWG has been in contact with U of M facility on potential VI tests inside basements where 1,4 Dioxane may be found in NSG near homes.
In discussions with the city Administrator Lazarus at City Hall on January 23rd we were told the city is planning to do VI tests in selected homes to get a better idea of what VI issues the city may or may not face if the 1,4 Dioxane Plume continues to migrate through the city to the Huron River. The VI tests council resolution is being worked on and should go to council for a vote. He also said the city would consider West Park Band Shell unused basement for a location for U of M professor and Post Doc to test for VI in an enclosed space with existing potential groundwater contamination. City staff still working on access to the Band Shell for evaluation.
We will try to find options for scientists to test basement exposures and validate exposure models they have worked on specifically for VI of 1,4 Dioxane in buildings. Our understanding is, from discussions with EGLE and other scientists including those at U of M, that VI for 1,4 Dioxane is poorly studied and understood and these studies are sorely needed to help effectively protect the communities.
VI of 1,4 Dioxane is different than for the vast majority of other chemicals that may seep into a home in a vapor state. 1,4 dioxane will generally enter the structure with contaminated water, and when the water evaporates the compound will become airborne and expose the inhabitants. A major issue we face in Ann Arbor is the large number of homes on the west side with wet basements that may get occupants exposed if the compound is allowed to migrate in the NSG and infiltrate into the basements.
The standard for NSG 1,4 dioxane is not clear, but EGLE started at 29 ppb then jumped to 1,900 ppb now they are using 280 ppb. Dr. Robert Bailey, CARD member, calculated a proposed level of 100 ppb.
Link: Poison vapor funds trapped in debate over how DEQ pays for cleanups - MLive
https://www.mlive.com/news/2017/06/deq_budget_vapor_intrusion.html
M-LEEaD Center: "From PBB to PFAS: Research and Action to Address Michigan’s Large-Scale Chemical Contaminations" - U of M Earth Day at 50; 8:30 am Thursday, February 20, 2020
Keynote address by Linda S. Birnbaum, PhD, DABT, ATS (Director (retired), Scientist Emeritus, National Institute of Environmental Health Sciences and National Toxicology Program): “The Challenges of PFAS”
Members of the CARD Group and ACWG will be attending and presenting posters in the Poster Session at this meeting. Posters will discuss Vapor Intrusion for 1,4 Dioxane poorly studied and published issue, and the work of the CARD Group in Scio and Ann Arbor Townships and City of Ann Arbor. See CARD Poster entry in UPDATE above.
The meeting quickly reached it's maximum allowed attendance for the reserved rooms at the U of M Michigan League but live streaming is available.
Michigan Center on Lifestage Environmental Exposures and Disease (M-LEEaD). Support for M-LEEaD Center is provided by grant P30ES017885 from the National Institute of Environmental Health Sciences, National Institutes of Health; THE PBB TO PFAS SYMPOSIUM IS ORGANIZED BY: The University of Michigan M-LEEaD Center, Emory University’s HERCULES Center, and Central Michigan University
YouTube Video of Meeting: https://www.youtube.com/playlist?list=PLt4u9Gmt5XuI18jrOQBfcg3MZClie2zUJ
Web Page: http://mleead.umich.edu/Event_FromPBBtoPFAS.php
Local Public Hearing on MI Proposed PFAS in Drinking Water Rules
EGLE PFAS Public Hearing 1-14-20 (WCC; ACWG, Rt Click for Larger)
NRDC, Aug. 2019 ( Rt Click for Larger)
At the January 14th meeting, the ACWG asked officials to use standards similar to the NRDC's published low single-digit values. The EGLE is proposing low double-digit standards for the longer chain PFOSs.
NRDC local officials in attendance made comment and proposed using the low single-digit PFOS values.
Proposed standards are in Part Per Trillion, giving a good indication of the toxic nature of these compounds which do not break down for a very long time in nature and bioaccumulate in biologic systems including humans. One part per trillion would equal one second in 31,500 years, very small amounts.
Ann Arbor has PFOS in the Huron River and in the small amounts in our drinking water. As shown above, it is a major issue for Michigan, and will be for other states as well. Michigan has been out front on testing for PFOS in water and may be/is a sentinel for other states.
The Michigan Department of Environment, Great Lakes, and Energy (EGLE), Drinking Water and Environmental Health Division (DWEHD), had three public hearings to receive public comments on proposed rules to establish maximum contaminant levels (MCLs) for seven per- and polyfluoroalkyl substances (PFAS) compounds in drinking water.
The proposed rules will amend the current rules to provide provisions that reduce exposure to seven PFAS compounds in drinking water. The provisions include establishment of drinking water standards, sampling requirements, public notification requirements and laboratory certification criteria.
Links:
NRDC's published low single-digit value recommendations for PFOS
Rail Road Berm Tunnel Between Depot St. and B2B Trail and, Tree Line/Greenway Ground Breaking Tuesday 10 am at Amtrak Parking Area
Study Adopted Berm Opening Under Rail Road Track (City of Ann Arbor; Rt Click for Larger)
City of Ann Arbor will have a ribbon-cutting at the AmTrak Parking area Tuesday to mark the start of this project.
The ACWG attended all the planning meetings for this project supporting the Allen's Creek flood reduction for the Depot St area residents and businesses and access to the B2B Trail. The berm currently acts as a dam in flood situations causing flood hazard upstream. Many homes (tens) in this area will be now out of the 1% chance (100 year) floodplain with this important project because flood flows to the Huron River will be much less blocked as they are now.
Early in the planning process the inclusion of a pedestrian and bike access was in doubt. Many local residents and the ACWG strongly supported the addition of the pedestrian and bike access tunnel next to the Fresh Water Runoff (stormwater). MDOT was not initially supportive of the tunnel until they learned it would include a trail connection to the B2B trail which had them reverse positions and strongly support the plan.
City staff worked very long and hard to make this project happen which will be a major improvement in the city, much more valuable in the many decades of property protection and amenity value than the cost of the project.
City of Ann Arbor Project Page
https://www.a2gov.org/departments/engineering/Pages/Allen-Creek-Railroad-Berm-Project.aspx
January 2020 - No Meeting this Month Due to Conflict with EPA, MI EGLE, Rep. Dingell Joint Session
Watershed Issues of Interest and Updates:
Danaher/Pall/Gelman 1,4-Dioxane Plume - Public, Elected Officials Joint Session With EGLE and EPA for Question-Answer Session Thrs. 1-16-20: Organized by Rep. Debbie Dingell
The Public, local elected officials, Michigan Department of Environment, Great Lakes, and Energy (EGLE) and EPA Officials will meet at a Question-Answer Session on January 16 6:30pm to discuss the options for designating the Danaher/Pall/Gelman 1,4-Dioxane plume a potential EPA Superfund site.
The officials attending the December Joint Session have postponed judgment on EPA Superfund option till after the January 16 meeting. Representative Debbie Dingell has arranged for this meeting and to allow for questions and comments about the potential options for a cleanup of this plume.
Congresswoman Debbie Dingell, Officials from the Environmental Protection Agency (EPA), Michigan Department of Environment, Great Lakes, and Energy (EGLE), the Office of the Michigan Attorney General, and local elected officials will be present, and stakeholders and the public will have the opportunity to ask questions and make comment.
Public, Joint Session, EPA, EGLE, Rep. Debbi Dingell - Question Answer Session:
When: Thursday, January 16th
Time: 6:30-8:30pm
Where: Washtenaw Learning Resource Center, 4135 Washtenaw Ave, Ann Arbor, MI 48108. (Google Map Link)
Update: Video of Session 1/16/20: Taped and posted on YouTube by Roger Rayle
Joint Session on 12-12-19; wide-angle (ACWG, Click for Larger)
Vince Caruso Comments at 1/16/20 EPA/EGLE/AG Stake Holder Meeting ( Rt Click for Larger, Video Roger Rayle CARD)
Some of the main issues and questions currently facing us related to the Gelman Plume that are not being addressed are making our community less safe.
As I commented at the December 12th Joint Session of EGLE and local government bodies, during public comment, we have a Gelman's Illicit Discharge into a Michigan MS4 system for 2 years now, the Allen('s) Creek flowing to the Huron River, Dan Bicknell GEA has investigated and communicated in more detail on the issues of MS4. I also commented that residents are not being protected if this compound is allowed to percolate into basements and evaporate (VI -Vapor Intrusion) into this confined space and expose the residents. Many Ann Arbor residents use their basements for play space, workspace, office space, ...
The current Consent Judgement (CJ) does not address this VI issue or have oversite of it.
We currently have 22 ppb at West Park in the Near-Surface Groundwater (NSG, some also call shallow groundwater). 11 blocks upstream we have had 1,000 ppb at Vet's Park in recent years flowing toward West Park and beyond. Coalition for Action On Remediation of Dioxane (CARD) pressured EGLE to do these NSG tests and most were very surprised the 1,4 dioxane was in the NSG at such high levels and seemingly moving higher.
We have Gelman/Pall's own geological maps from 2006 that show this would likely happen in West Park, as it now has.
As stated before EGLE has a (proposed) 1,900 ppb standard for VI which may be too high. They and EPA have not commented on the 100 ppb Action Level technically detailed technical proposal submitted by some CARD members to EPA and EGLE for evaluation.
Michigan MS4 Regulation:
'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)
Under the MS4 permit, it would seem no dioxane contamination at any level should be legally allowed to infiltrate/seep into the MS4 storm drain (without a NPDS Permit which they do not seem to have), Allen's Creek at West Park for example, yet it clearly has for 2 years.
As commented on before the Allen's Creek pipe in West Park has high flows in drought conditions because it picks up lots of seep's groundwater just upstream. This is to reduce the damage NSG can cause if left uncontrolled, like home and street undermining. This NSG is contaminated.
Coalition for Action On Remediation of Dioxane (CARD) and Allen’s Creek Watershed Group (ACWG) have again this past CARD Meeting requested additional NSG tests upstream of West Park to try to understand the 22 ppb finding in recent West Park NSG tests. These additional tests will help locate where permanent NSG well monitoring should be located.
It seems apparent that these developments on NSGs increasing quickly speaks to the need for a Superfund petition to deal with this clear and present danger to the West Side of Ann Arbor homes and businesses. The standard for NSG 1,4 dioxane is not clear, but EGLE started at 29 ppb then jumped to 1,900 ppb, CARD has argued for 280 ppb*. Robert Bailey PhD, CARD member, calculated a proposed level of 100 ppb.
Again, we have again requested permanent NSG well monitoring. Dan Bicknell's GEA Comments on the DEQ Shallow Groundwater Work Plan and his proposed plan is posted in November 2016. Dan had a very well and logical plan laid out for dealing with the initial investigation of the NSG issue which seems to be clearly a problem that needs addressing.
Contaminated Near-Surface Groundwater is now a near-term threat to the community and is an example of how Gelman/Danaher has not protected the community. West Park is now at 22 ppb in NSG yet we have no permanent wells to monitor this. This is just one of a myriad of examples of mismanagement of this threat to the community.
Even if it is included in a new consent judgment agreement, we will be relying on EGLE and Gelman/Danaher to do a very weak job of protecting the community with containment, not cleanup. State law Part 201 is very weak and not protective in the long term. EPA has a much stronger cleanup standard.
With all the work the CARD group, city and county have done the EPA will have a headstart on this effort. The EPA Score of the partial Superfund Evaluation was very high for Superfund Listing with a minimal evaluation. In this case, we have a Responsible Party that EPA will require to do and pay for cleanup as is happening now with other sites all over the country.
The Ann Arbor Township, Scio Township, Washtenaw County Board of Commissions, Sierra Club Huron Valley Group, and ACWG all voted in supported a petition to the US EPA for Full Preliminary Assessment of the Gelman 1,4-Dioxane groundwater contamination.
Governor Whitmer would be much more approachable than our previous Republican Governor when we present her with a US EPA Full Preliminary Assessment in a Superfund Petition. The former governor refused to allow US EPA to do a Full Evaluation when requested by US EPA.
Links:
Video of Session 1/16/20: Taped and posted by Roger Rayle Chair CARD
Special Joint Working Session with City of Ann Arbor, Washtenaw County, Scio Township and Ann Arbor Township - Taped by Roger Rayle, Chair CARD
January 2020 Coalition for the Remediation of Dioxane (CARD) Group Meeting Video - Taped by Roger Rayle, Chair CARD
Gelman Plume Related Stories by Ann Arbor News/MLive: MLive
Ann Arbor-area officials delay Gelman plume decision another month: MLive Ryan Stanton
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)
Ryan Stanton in Ann Arbor News/MLive: 'EPA holding off on Superfund designation for Gelman dioxane plume'
Lots of details from Barbara Lucus at Dioxane.Org and WEMU News Program GreenRoom
See ACWG site pages EPA Superfund Option Details
Click here to view and/or sign in support of Superfund Designation
Discussions with U of M Facility on Vapor Intrusion (VI) Modeling and Tests for 1,4 Dioxane
MLive (Red Text Annotated on left by us; Click for Larger)
Card Group and ACWG has been in contact with U of M facility on potential VI tests inside basements where 1,4 Dioxane may be found in NSG near homes.
The city has bought some homes in the floodway of Allen's Creek in recent years to reduce flood hazard, and potentially to connect the Greenway/Treeline to adjacent park spaces or other trails.
We will try to find options for scientists to test basement exposures and validate exposure models they have worked on specifically for VI of 1,4 Dioxane in buildings. Our understanding is, from discussions with EGLE and other scientists including those at U of M, that VI for 1,4 Dioxane is poorly studied and understood and these studies are sorely needed to help effectively protect the communities.
VI of 1,4 Dioxane is different than for the vast majority of other chemicals that may seep into a home in a vapor state. 1,4 dioxane will generally enter the structure with contaminated water, and when the water evaporates the compound will become airborne and expose the inhabitants. A major issue we face in Ann Arbor is the large number of homes on the west side with wet basements that may get occupants exposed if the compound is allowed to migrate in the NSG and infiltrate into the basements.
The standard for NSG 1,4 dioxane is not clear, but EGLE started at 29 ppb then jumped to 1,900 ppb, CARD has argued for 280 ppb*. Dr. Robert Bailey, CARD member, calculated a proposed level of 100 ppb.
Local Public Hearings on MI Proposed PFAS in Drinking Water Rules Tonight
NRDC, Aug. 2019 (Click for Larger)
Ann Arbor has PFOS in the Huron River and in the drinking water. As shown above, it is a major issue for Michigan, and will be for other states as well. Michigan has been out front on testing for PFOS in water and may be/is a sentinel for other states.
The Michigan Department of Environment, Great Lakes, and Energy (EGLE), Drinking Water and Environmental Health Division (DWEHD), will this week hold the first of three public hearings to receive public comments on proposed rules to establish maximum contaminant levels (MCLs) for seven per- and polyfluoroalkyl substances (PFAS) compounds in drinking water.
The proposed rules will amend the current rules to provide provisions that reduce exposure to seven PFAS compounds in drinking water. The provisions include establishment of drinking water standards, sampling requirements, public notification requirements and laboratory certification criteria.
A local public hearing is scheduled for:
Today Tuesday, January 14, from 5:00 to 8:00 p.m.,
at Washtenaw Community College, Morris Lawrence Building, 4800 E. Huron River Dr., Ann Arbor, Mich.,
in ML Towsley Auditorium
Proposed Agenda and Updates:
December 19, 2019
Danaher/Pall/Gelman 1,4-Dioxane Plume - Public, Elected Officials Joint Session With EGLE and EPA for Question-Answer Session 1-16-20
The Public, local elected officials, Michigan Department of Environment, Great Lakes, and Energy (EGLE) and EPA Officials will meet at a Question-Answer Session on January 16, location TBD, to discuss the options for designating the Danaher/Pall/Gelman 1,4-Dioxane plume a potential EPA Superfund site.
The officials attending the Joint Session have again postponed judgment on EPA Superfund option till after the January 16 meeting Representative Debbie Dingell has arranged to allow for questions and comments about the potential options for a cleanup of this plume.
Public, Joint Session, EPA, EGLE, Rep. Debbi Dingell - Question Answer Session:
January 16
Time/Location TBD
Joint Session 12-12-19, wide-angle (ACWG, Click for Larger)
Vince Caruso Makes Comment at Joint Session 12-12-19 (Roger Rayle CARD YouTube, Click for Larger)
I commented on the Gelman's Illicit Discharge into a Michigan MS4 system, the Allen('s) Creek flowing to the Huron River, Dan Bicknell GEA has communicated in more detail on the issues of MS4. I also commented that residents are not being protected if this compound is allowed to percolate into basements and evaporate (VI -Vapor Intrusion) into this confined space and expose the residents. Many Ann Arbor residents use their basements for play space, workspace, office space, ...
We currently have 22 ppb at West Park in the NSG. 11 blocks upstream we have had 1,000 ppb at Vet's Park. CARD pressured EGLE to do these NSG tests and most were very surprised the 1,4 dioxane was in the NSG at such high levels and seemingly moving higher.
As stated here before EGLE has a (proposed) 1,900 ppb standard for VI which may be too high. They and EPA have not commented on the 100 ppb Action Level proposal submitted by some CARD members for evaluation.
MI EGLE MS4 Regulation:
'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 storm water or uncontaminated groundwater except discharges pursuant to an NPDES permit.' (bold by us)
Under the MS4 permit, it would seem no dioxane contamination at any level should be legally allowed to infiltrate/seep into the MS4 storm drain, Allen's Creek for example, yet it clearly has for many months and going higher at every test.
Evan Pratt Followup Communication on the MS4 Discharge email from Dan Bicknell:
Even Pratt has commented to CARD that he has not gotten a clear indication from EGLE or EPA on this MS4 Illicit Discharge Issue and is willing to pursue options with regulatory bodies for clarification and actions as needed.
As commented on here before the Allen's Creek pipe in West Park has high flows in drought conditions because it picks up lots of seep's groundwater just upstream. This is to reduce the damage NSG can cause if left uncontrolled, like home and street undermining.
Coalition for Action On Remediation of Dioxane (CARD) and Allen’s Creek Watershed Group (ACWG) have again this past CARD Meeting requested additional NSG (some call shallow groundwater) tests upstream of West Park to try to understand the 22 ppb finding in recent West Park NSG tests. These additional tests will help locate where permanent NSG well monitoring should be located.
It seems apparent that these developments on NSGs increasing quickly speaks to the need for a Superfund petition to deal with this clear and present danger to the West Side of Ann Arbor homes and businesses. The standard for NSG 1,4 dioxane is not clear, but started at 29 ppb then jumped to 1,900 ppb, CARD has argued for 280 ppb*. Dr. Bailey, CARD member, calculated a proposed level of 100 ppb.
Again, we have again requested permanent NSG well monitoring. Dan Bicknell's GEA Comments on the DEQ Shallow Groundwater Work Plan and his proposed plan is posted in the November 2016 Agenda. Dan had a very well and logical plan laid out for dealing with the initial investigation of the NSG issue which seems to be clearly a problem that needs addressing.
Near-Surface Groundwater (surface groundwater) is now a near-term threat to the community and is an example of how Gelman/Danaher has not protected the community. West Park is now at 22 ppb in NSG yet we have no permanent wells to monitor this. This is just one of a myriad of examples of mismanagement of this threat to the community.
Even with a consent judgment agreement, we will be relying on EGLE and Gelman/Danaher to do a very weak job of protecting the community with containment, not cleanup. State law Part 201 is very weak and not protective in the long term.
Contact your elected officials and make your support of a Full Superfund Evaluation for this Massive Plume known to them.
With all the work the CARD group, city and county have done the EPA will have a headstart on this effort. The score of the partial Superfund Evaluation was very high for Superfund Listing with a minimal evaluation.
The Ann Arbor Township, Scio Township, Washtenaw County Board of Commissions, Sierra Club Huron Valley Group (SCHGV), CARD and ACWG all voted in supported a petition to the US EPA for Full Preliminary Assessment of the Gelman 1,4-Dioxane groundwater contamination.
Governor Whitmer would be much more approachable than our previous Republican Governor.
Links:
Special Joint Working Session with City of Ann Arbor, Washtenaw County, Scio Township and Ann Arbor Township - Taped by Roger Rayle, Chair CARD
December 2019 Coalition for the Remediation of Dioxane (CARD) Group Meeting Video - Taped by Roger Rayle, Chair CARD
Ann Arbor-area officials delay Gelman plume decision another month: MLive Ryan Stanton
Dioxane test results for Allen Creek raise more questions: MLive Ryan Stanton
Ongoing discharges may be to blame for dioxane in Ann Arbor drinking water: MLive Ryan Stanton
Environment, Great Lakes & Energy (formally MDEQ)-Gelman Project Site; Washtenaw County CARD Site; Scio Residents for Safe Water (SRSW)
Lots of stores by Ryan Stanton in Ann Arbor News/MLive including this recent article 'EPA holding off on Superfund designation for Gelman dioxane plume'
Lots of details from Barbara Lucus at Dioxane.Org and WEMU News Program GreenRoom
See ACWG site pages EPA Superfund Option Details
Click here to view and/or sign in support of Superfund Designation
Michigan Had the Wettest Year Ever Recorded in 119 Years of Records!
NOAA - Michigan Record Perception 2019 ( Rt Click for larger)
MLive reports:
"The Great Lakes water levels are a good sign of the above-average precipitation. Now NOAA has given us the on just how much precipitation has fallen across Michigan.
The water year from Nov.1, 2018 to Oct. 31, 2019, has been declared the wettest water year on record across Michigan.
Michigan isn’t alone on the wettest weather. Five states across the Midwest and Great Lakes have had the wettest year up to Oct. 31." (bold by us)
Great Lakes are also at all-time record levels partially due to record precipitation, see below.
This should give our city officials pause in suggesting more buildings in the Floodplain will be OK because we have FEMA Maps.
FEMA Floodplain maps are not keeping up with Global Warming effects in Michigan and should not be considered fail-safe. As previously reported here, FEMA has been shown to currently 'Low Ball' Flood Maps by 33%.
Wettest Year Ever - Mark Torregrossa - Mlive
Great Lakes Water Levels to rise in 2020, More Intense Rains in Michigan Are Clearly a Part of the Problem
Lake Michigan West Shore Town major unrelenting flooding 2019 (LSJ, Rt Click for larger)
Former Ann Arbor Parks Director and now MI DNR Director Ron Olson interviewed and comments on high lake levels and larger rain events.
"Water is rising along Michigan's prized Great Lakes shoreline, shrinking beaches, eroding dunes, flooding campgrounds, costing millions.
2019 was bad and 2020 is expected to be worse.
And the Great Lakes are projected to keep rising in spring 2020. It's unclear what to expect after that.
The violent storms and the rainfalls and all of that has really combined together to create this situation where it looks like we’re sailing into uncharted territory" ..." (bold by us)
More rain and more flooding are clearly a real possibility for Michigan with changes in our climate due to Global Warming effects because of atmospheric CO2 increases. Uncharted waters with planning requires much more due diligence and caution. Building in floodways and floodplains will be very dangerous to the residents in the new homes and businesses and more dangerous for those with new unexpected flood hazards up steam due to blocked flood water flows.
Lansing State Journal 12-11-19 - https://www.lansingstatejournal.com/story/news/local/2019/12/12/great-lakes-lake-huron-water-levels-2019-michigan-state-parks-flooding-mi/4239358002/
William St. Protected Bike Lane Opens, Major Potential Connection to Tree Line/Greenway, and Benefits
William St. Protect Bike Lane Opening, wide-angle (ACWG, Click for Larger)
The city opened the new William St. Protected Bike Lane that connects the Old West Side and Campus, and has real potential with a connection to the Tree Line/Greenway proposed project. A very large crowd attended the ribbon-cutting and opening.
Protected bike lanes have been clearly shown to have great benefits for the community. Many more people will bike to town with protected bike lanes and because it will be safer.
The Tree Line/Greenway connection to the Downtown and Campus has real potential to provide many very cost-effective benefits.
The Tree Line/Greenway has great potential as has been shown in many progressive communities for mobility, opening up the floodway to reduce flood hazard, fresh water runoff (stormwater) mitigation with pollution mitigation, economic viability, and in general much better health outcomes for residents and visitors.
One issue facing the city with the Tree Line/Greenway is the potential for major Gentrification of the area around the greenway. Other communities with these types of projects have found major public pushback due to gentrification pushing affordable housing out of the greenway areas.
Atlanta has proposed instituting a property tax freeze or full rebates on landlords that do not jack up rents along the super popular Atlanta Beltline greenway (discussed on ACWG.ORG in the recent June 21, 2018 post). The Beltline has been like other Greenways a colossal success unmatched in Atlanta history, with major flood mitigation built into the design.
NYC High Line and Chicago Greenway have had similar problems with Greenway design and implications. According to a planner working on a project in Ann Arbor and also the Chicago Greenway, she said they have had a hold on planning to deal with pushback due to gentrification of neighborhoods with much higher rents and home prices potentials. She is looking very hard for real solutions to get Chicago Greenway back on track.
Proposed Agenda and Updates:
November 21, 2019
Danaher/Pall/Gelman 1,4-Dioxane Plume Near-Surface Groundwater Tests Requested by CARD ACWG
Coalition for Action Remediation of Dioxane (CARD) and Allen’s Creek Watershed Group (ACWG) have again this past CARD Meeting requested additional Near-Surface Groundwater (NSG) (some call shallow groundwater) tests upstream of West Park to try to understand the 22 ppb finding in recent West Park NSG tests. These additional tests will help locate where permanent NSG well monitoring should be located.
It seems apparent that these developments on NSGs increasing quickly speaks to the need for a Superfund petition to deal with this clear and present danger to the West Side of Ann Arbor homes and businesses. The standard for NSG 1,4 dioxane is not clear, but started at 29 ppb then jumped to 1,900 ppb, CARD has argued for 280 ppb*. Dr. Bailey calculated a proposed level of 100 ppb.
I asked Michigan Department of Environment, Great Lakes, and Energy (EGLE) if they have evaluated the 1,4D potential Vapor Intrusion Action Level calculated by Dr. Robert Bailey, they have not. Dr. Bailey has a Ph.D. in Inorganic Chemistry from U of Wisconsin - Madison, who worked for DOW calculating Fate and Transport of these types of chemicals for 30 years and then had a consulting company doing the same. Dr. Bailey's work was presented to EGLE earlier this year and US EPA over a year ago. The technical term “fate and transport” describes how chemicals entering the subsurface from point or non-point sources relate to groundwater concentrations elsewhere.
Again, we have again requested permanent NSG well monitoring. Dan Bicknell's GEA Comments on the DEQ Shallow Groundwater Work Plan and his proposed plan is posted in the November 2016 Agenda. Dan had a very well and logical plan laid out for dealing with the initial investigation of the NSG issue which seems to be clearly a problem that needs addressing.
Evan Pratt (Washtenaw County Water Resources Commissioner) has asked EGLE for additional NSG tests, which EGLE has agreed to do.
Update: these tests have been put on hold due to needed evaluations of the storm-sewer pipes locations and actual flows in the area. Commissioner Pratt "did request 6 or 12 month sampling at the West park locations (Chapin St. on the east end before discharge to mainline Allens) and the same location on the west end of the park."*
ACWG did a tour of the Glendale Neighborhood with Mr. Pratt in September, where many homes reported water issues, when asked in a neighborhood conducted a survey. The one homeowner we encountered clearly indicate she had groundwater issues in her basement. This is consistent with many homeowners' comments during the survey. I personally witnessed two homes recently built in the neighborhood both filled with groundwater, after the basement holes were excavated. In one neighborhood residents asked me to talk to the builder of their fears that kids would fall into the hole and drowned. I talked to the builder and he blocked access to the hole and home under construction with a flooded basement.
Vince Caruso Making Comment at Monitoring Well Location Discussion (ACWG Screen Shot CTN Video; Rt Click for Larger)
The city had a meeting to discuss Monitoring Wells that are to be added in the northern portion of the Gelman Plume to detect any potential movement toward Barton Pond, Ann Arbor drinking water source. This was requested by CARD then MDEQ many years ago and denied by Judge Shelton due to costs savings issues argued by Gelman. These new Monitoring Wells clearly should be paid for by Responsible Party Gelman/Danaher which would be the case if EPA were in charge of this cleanup.
Near-Surface Groundwater is now a near-term threat to the community and is an example of how Gelman/Danaher has not protected the community. West Park is now at 22 ppb in NSG yet we have no permanent wells to monitor this. This is just one of a myriad of examples of mismanagement of this threat to the community.
Even with a consent judgment agreement, we will be relying on EGLE and Gelman/Danaher to do a very weak job of protecting the community with containment, not cleanup. State law Part 201 is very weak and not protective in the long term.
Contact your elected officials and make your support of a Full Superfund Evaluation for this Massive Plume known to them.
With all the work the Coalition for Action On Remediation of Dioxane (CARD) group, city and county have done the EPA will have a head-start on this effort. The score of the partial Superfund Evaluation was very high for Superfund Listing with a minimal evaluation.
The Ann Arbor Township, Scio Township, Washtenaw County Board of Commissions, Sierra Club Huron Valley Group (SCHGV), CARD and ACWG all voted in supported a petition to the US EPA for Full Preliminary Assessment of the Gelman 1,4-Dioxane groundwater contamination.
Governor Whitmer would be much more approachable than our previous Republican Governor.
Links:
November 2019 CARD Group Meeting Video - Taped by Roger Rayle, Chair CARD
Superfund or legal settlement? Officials discussing next steps for Gelman plume: MLive Ryan Stanton
Dioxane detected in Ann Arbor drinking water from Barton Pond for first time: Mlive Martin Slagter
Dioxane test results for Allen Creek raise more questions: MLive Ryan Stanton
Ongoing discharges may be to blame for dioxane in Ann Arbor drinking water: MLive Ryan Stanton
Environment, Great Lakes & Energy (formally MDEQ)-Gelman Project Site; Washtenaw County CARD Site; Scio Residents for Safe Water (SRSW)
Lots of stores by Ryan Stanton in Ann Arbor News/MLive including this recent article 'EPA holding off on Superfund designation for Gelman dioxane plume'
Lots of details from Barbara Lucus at Dioxane.Org and WEMU News Program GreenRoom
See ACWG site pages EPA Superfund Option Details
Click here to view and/or sign in support of Superfund Designation
Proposed Affordable Housing Being Considered in the Floodplain, and Possibly Floodway
721 N. Main Floodway/plain, Site outlined in Red, floodplain in green, floodway in blue (Current City Map, ACWG annotation, Rt Click for larger)
Update: Evan Pratt (WRC) has recently indicated that the proposed floodplain near
721 N. Main may be much smaller after the installation of the opening in the
Rail Road Berm as shown here in map presented by city consultants floodplain
model analysis. This was presented at a meeting the ACWG attended but did not
include in this agenda item. ( Rt Click for Larger)*
415 West Washington Floodway/plain (Current City Map, ACWG annotation, Rt Click for larger)
216 William St. Almost all Floodway; Floodway/plain (Current City Map, ACWG annotation, Rt Click for larger)
As has been discussed in previous meetings on the 415 site, it is virtually all floodplain and about 1/3 floodway. These FEMA floodmaps have been reported to be 'low balled' by FEMA in recent studies, and could be 3 times higher risk of flooding then is in the FEMA maps, see CityLab article, as discussed in the August ACWG posting. 216 William is also almost all floodway.
The 721 N. Main site is also a prime location for flood hazard mitigation park space on the planned Greenway/Tree Line Master Plan. This site is also virtually all floodplain and floodway.
Update: Evan Pratt has recently indicated to the ACWG that the proposed floodplain as shown above may be much smaller after the installation of the opening in the Rail Road Berm as shown in map presented by city consultants floodplain model analysis. This was presented at a meeting ACWG attended and on file but did not include in this agenda item. There were comments at the meeting as to the realistic representation of the model showing such a small floodplain given the very large existing floodplain as shown above. This berm opening is scheduled to be installed in the next year.*
Michigan in recent years has been getting regular 100 and 500 year rains, and last summer had a 1,000 year rain. The US has now had 10,000 year rain in 2018.
President Obama virtually forbids using any federal funds for building in the 100-year (1% chance) floodplain and no funds for critical structures inside the 500-year (.2% chance) floodplain.
"Increasing precipitation, especially heavy rain events, has increased the overall flood risk," according to the most recent National Climate Assessment.
The LOMR for the YMCA site across the street, just 1 1/2 years after construction showed a change of 33% which obligated the 'Free Board' (1-foot free space below the building to the floodplain) the building was permitted with. Flooding at the YMCA site is a major issue for those working in it according to previous staff comments.
2013 Reuter Report commissioned by the city indicates it can be up to nearly 9-foot floodplain on this site, with Global Warming likely much higher.
216 West William is all floodway and is being discussed as a potential parking garage. Adding obstructions in the floodway is particularly dangerous not only for the owners of the cars who could be drowned trying to move the car (as has happened recently in N. Ohio) but for unsuspecting homeowners and business owners upstream of these projects who will now be much more likely to experience flood hazard. Blocking the floodway is very dangerous especially with the city's own estimate of increased rainfall with Global Warming up.
Cars and a parking garage in the floodway is not benign. This is a potential site of a park for the Greenway which would not exacerbate flooding like a structure.
The Greenway was championed by the ACWG back in the late 90's as a way to reduce flooding in and around the downtown along the Old West Side and along the railroad tracks. The Drain Office at that time supported this option to reduce flood hazard. The adopted Flood Hazard Mitigation Plan also supported a Greenway.
Let's preserve life and health, and property values and our tax base of our long-lived neighborhoods in the Old West Side and other areas who have faithfully paid taxes for over a 100 years in many cases. These neighborhoods should not be threatened with flooding with new structures in the floodplain and actual or, now likely floodways with current and expected Global Warming's effects.
Mayor Taylor said recently that Ann Arbor has personally experienced the effects of climate change, referencing a one-degree temperature increase during the last few years as well as a more than 45 percent increase in precipitation within the last 50 years.
As we asked before and FOIA'ed the DDA - we would like to see the FTCH Study:
The DDA's FTCH $1/4 to $1/2M budgeted consultants study of the watershed, just upstream of this site. should also be made available to the public. The ACWG FOIA'ed the study but was just given a copy of the raw data and model run data used to do models but the report was never offered. FTCH said the DDA had to agree to make it available which they never did.
Follow Adopted goals of the 2007 Flood Hazard Mitigation Plan:
We should follow the Long-Past Adopted goals of the 2007 Flood Hazard Mitigation Plan the ACWG contributed to: "Public acquisition and management of flood-prone properties. Permanent relocation of flood-prone structures to areas outside the floodplain. Establish clear and consistent government policy for public-owned land in the floodplain aimed at preventing public buildings in the floodplain. Create Allen['s] Creek Greenway in floodplain area. Regular data collection and modeling to update flood hazard maps Decrease Flood Insurance Rates by meeting FEMA required flood hazard mitigation recommendations." (bold by us)
City has Announced Public meetings to discuss these issues and other issues with regards to city properties and development.
Meeting Times and Place:
From 5 - 9 p.m. Thursday, Dec. 5 at the Ann Arbor Downtown Development Authority, 150 S. 5th Ave., Suite 301.
From noon to 4 p.m. Friday, Dec. 6 at the Ann Arbor District Library Downtown Branch, 343 S 5th Ave., third floor freespace.
From 9 a.m. to 1 p.m. Saturday, Dec. 7 at the Ann Arbor YMCA, 400 W. Washington St., Michigan Room.
From noon to 4 p.m. Sunday, Dec. 8 at The Cirq Bar, 210 S. First St.
From 9 a.m. to 1 p.m. Monday, Dec. 9 at the Ann Arbor District Library Downtown Branch, 343 S 5th Ave., third floor freespace.
Mlive Article Ann Arbor could develop 2 affordable housing sites ASAP, analysis finds
CityLab: https://www.citylab.com/newsletter-editions/2019/07/maplab-hidden-risks-flood-maps/595126/
City Sustainability Meeting Discussion with Dr. Missy Stults - City of Ann Arbor Sustainability and Innovations Manager - She Does Not Support Building Homes in the Cities Floodplains Due to Climate Change Effects on Flood Hazard
A2Zero KickOff Event, Wide Angle
(ACWG, Rt Clk for Larger)
On this Nov. 11th I attended the A2Zero Sustainability Meeting and had asked Dr. Stults if she supported building homes in Ann Arbor's floodplains. She had a simple and categorical answer which was NO.
City is now evaluating floodplain properties for Affordable Housing and building parking garages in the floodplain and floodway.
This when the city is telling residents we are facing unprecedented climate change in SEM and we need to prepare.
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(*Some agenda items may have been corrected for typos and include follow up updates when posted here.)