09/13/2005 Pall Permit Meeting/Hearing - comments

09/08/2005

Here are some issues to bring up at the Tuesday Public Meeting/Public Hearing on the Pall/Gelman Discharge Permit. (September 13, 2005, 7:00 P.M. at the Scio Township Hall, 827 North Zeeb Road, Ann Arbor)

1. Monthly and daily dioxane ppb limits of 6 & 23 is better than the current 10 & 60 but not quite as good as the 5 & 15 that administrative law judge Lacasse recommended in April 2000.

2. Bromate levels are a major concern. Bromate wasn't there with the old system. Bromate is a carcinogen and should not be allowed to enter the waters where Ann Arbor gets 80% of its water. Will loss of bromate to groundwater through losing sections of Honey Creek become a problem? Many days' bromate levels have been at or above the permitted level of 10 ppb since the new treatment system has been used.

3. The new ozone/oxidation treatment system is not as effective as the prior UV/Ox system. Dioxane levels are about twice as high. They have not achieved non-detect (less than 1 ppb) even once with the new system, while the old system achieved non-detect quite often including a continuous 43-day period in April-June 2003. Bromate is created by the new system.

4. 24-composite for Bromate is good, but Grab Sampling for dioxane opens door for fudging, e.g. when dioxane levels go down, bromate levels go up, and vice versa. If the system is tweaked to produce low levels of dioxane during the dioxane sampling, the bromate level would probably be high, but that high could be averaged down to acceptable levels by re-tweaking the system to produce low levels of bromate for the other 23 hours of the day. The presumed high levels of dioxane for these 23 hours would not be reported... especially if the Green Pond is bypassed.

5. Consider using the new system and old system in series instead of letting the old system sit idle. The new system could be tweaked to produce the lowest levels of bromate. Since the effluent would likely have unacceptable levels of dioxane, run it through the old system to treat the dioxane to non-detect. This should be possible since the influent levels to the old system would be much lower than they were when the influent came from the red pond... probably they would be less than what the levels when the Evergreen system was treating to non-detect. The influent levels may be low enough that the pre- and post-treatment chemicals to adjust pH could be drastically reduced and still allow treatment to non-detect. Probably only some of the old system units would be required to do this "finishing" treatment. The new system might be do 80% of the treatment and the old system could do the other 20%, thus still providing substantial cost savings.

6. A hybrid setup of the new and old systems would allow for higher volume of treatment, something that is needed to capture the plume at Wagner Road and along the pahtways from the core to Maple Road. With treatment to lower levels, the hybrid system would allow for controlled reinjection of some or all of the effluent.

6. Do not bypass the Green Pond.

a. The Green Pond is a safety net to capture effluent when there is an upset.

b. The Green Pond could be used to hold the effluent from the new system before it is routed to the old system for final treatment and direct discharge to the tributary.

c. Discharge from the new system to the Green Pond would allow for random sampling or 24-hour composite sampling of the Green Pond to solve the dioxane sampling issue in #4 above.

7. The requirements to test for breakdown byproducts should still be in the permit, since the old system may still have to be used and since the new system is not as effective as the old system, and when dioxane levels are higher, so are the byproduct levels and variations in the mix of byproducts.

8. The DEQ should perform their own unannounced sampling from time to time.

9. There needs to be formal, ongoing involvement of citizens and local governments in early decision making for the life of this cleanup. We should not have to always fight to have our ideas incorporated after the company has already had their wishes put in black and white in the initial draft.

10. Require all tabular data, analyses, maps, etc. submitted by the company to also be submitted electronically... and make all sampling and modeling data public. When the company makes claims, have them show their work... what is the basis for a claim.

11. Do not limit the discussion during the Public Meeting. If the meeting goes beyond that arbitrary time limit, postpone the Public Hearing portion instead of cutting off discussion.

12. The characteristics of dioxane are pretty well documented, but the characteristics of bromate are not as widely known among the community. Provide fact sheets on both before the meeting.

13. The constant flooding of Little Lake and the two in-stream retention ponds at Sunward Co-Housing caused by the Pall/Gelman discharge has used up the retention capacity. The discharge itself is causing erosion there and at certain other places in the tributary. But with the retention capacity used up, the runoff from any rain event causes even more erosion... including erosion downstream.

14. The constant flooding at the discharge point has backed water up into the marshy area. This causes more dioxane there to wash into the tributary and to seep into the underlying aquifers. It is an uncontrolled reinjection and discharge to groundwater... something explicitly (and rightly) forbidden by the permit. The same thing is happening at Little Lake and the Co-Housing ponds. The effects of this abnormally high water on groundwater flows is not being investigated. It may be causing the yet-to-be-explained phenomena of the Western Plume "bubble".

15. The permission to begin using the new treatment system without a formal premit hearing was a mistake, especially since a new carcinogen is being discharged and more of the old carcinogen is being discharged. Even though the DEQ demanded that the old treatment system be kept around in case it was needed, there is no criteria for what conditions would require the old system to be re-activated.

16. The "Anti-Backsliding" provisions are being glossed over. (See #3 & #15 above).

17. All decisions regarding the cleanup should be made considering the effects on the whole site, not just some arbitrary portion. This means that all decision makers, within the DEQ and within local governments, should have an adequate threshold understanding of the whole site and access to a community and expert advisory group resource to make sure decisions make sense for the whole site.

...

Here are the links to the DEQ documents regarding the permit hearing...

Here is a link to the DEQ's Permits on Public Notice:

http://www.michigan.gov/deq/0,1607,7-135-3313_3682_3713-10463--,00.html

Scroll down and click on the Pall permit MI0048453 for 8/12/2005 to access related links or use the same links shown below.

Here is a link the the DEQ's public notice of the meeting:

http://www.deq.state.mi.us/documents/deq-water-npdes-publicnotice-MI0048453_PN.pdf

Here is a link the a 3-page Fact Sheet concerning the permit:

http://www.deq.state.mi.us/documents/deq-water-npdes-publicnotice-MI0048453_FS.pdf

Here is a link to the 1-page DEQ addendum concerning Rule 1098:

http://www.deq.state.mi.us/documents/deq-water-npdes-publicnotice-MI0048453_AD.pdf

Here is a link to the 20-page draft permit: