Post date: Sep 01, 2014 4:9:32 AM
September 27, 2000
Comments on Pall-Gelman 5-year Plan
On 7/17/2000, Judge Shelton ordered that "Pall-Gelman shall submit a detailed plan, with monthly benchmarks, which will reduce the dioxane in all affected water supplies below legally acceptable levels within a maximum period of five years". The Remediation Enforcement Order (REO) goes on to say "The Court's remediation order is designed first to require Pall-Gelman to submit an enforceable long range plan which will reduce all dioxane in these water supplies below legally acceptable levels and second to order immediate measures to move that process along faster than it has moved in the past."
Instead, Pall-Gelman submitted an 11-page, DRAFT 5-Year Plan that fails to give details, fails to provide enforcement criteria, fails to provide adequate monitoring, and fails to address the cleanup of "all affected water supplies" as required by the REO.
The Consent Judgment (CJ) called for cleanup of all contaminated areas. Pall-Gelman is now unilaterally claiming that the current REO replaces the CJ and therefore "non-drinking water supplies" no longer need to be cleaned up. The REO said "all water supplies" must be cleaned up but Pall-Gelman claims that the REO only covers "drinking water supplies" leaving out cleanup of the Marshy Area, the Southwest Area, the Soils System, and the Spray Irrigation Area.
Yet all the evidence to date has shown that these other areas are likely ongoing sources of contamination to the underlying "drinking water aquifers." And common sense says it's likely since that's how the original contamination happened in the first place!
Not addressing these areas will leave huge amounts of 1,4-dioxane where it will spread to area drinking water aquifers over the coming decades.
A hasty incomplete cleanup at the expense of protectiveness is not in the public interest.
(To be continued)