2004/07/09-SRSW Response to DEQ E Unit Cleanup Plan

Post date: Sep 01, 2014 5:46:11 AM

Pall's E unit cleanup plans have been submitted and the DEQ has chosen which approach they prefer. The DEQ has scheduled a Public Meeting for 7-9pm, July 28, 2004, at Slauson Middle School to review the plans. A TOSC meeting to further address the issues is planned for August 4 at a time and location to be determined. Details are or will soon be available on the TOSC, DEQ, and City of Ann Arbor websites.

Go to the SRSW website at www.srsw.org and click on the appropriate links.

The public comment period set by the DEQ is short; it ends on August 6, 2004. So get informed, attend the meetings, and send in your comments.

Here are some concerns SRSW has regarding the DEQ and Pall E unit cleanup plans:

• • not enough definition of or remediation of the E plume/pathway from the core to Maple Rd.

  • for more remediation along pathway, consider Michigan Inn property, whose owner was ready to cooperate soon after MW was installed at that location.

  • too much concentration on pumping at leading edge without adequate understanding and substantial pumping from the pathway will create another Evergreen-like failure. (Still not sure if some of E is really escape from Evergreen!)

  • before approving any plans, DEQ needs independent consultancy to review plans in conjunction with early involvement of local govt and citizens resource people.

  • The cleanup plan has no delineation of contingencies for cleanup changes if current assumptions prove erroneous.

  • Assumptions about how much water must be pumped/treated.discharge are shaky so don't know how big the pipe should be for the pipeline to the river... could end up with another undersized solution like happened at Evergreen.

  • Need ongoing, low MDL byproduct sampling of treated discharges. Also, need bio-sampling at and downstream from discharge point.

  • Need more professionally acceptable data gathering and analyses to sufficiently define the reality of the plumes before settling on a solution based on assumptions that are faulty and ending up with another failed cleanup attempt. (Remember that DNR/DEQ allowed Pall/Gelman to not sample the only E unit well east of Wagner Road for about 7 years. Even now, recent Pall well borings have lacked basic well log data and had omissions in vertical sampling. Some areas of very high concentrations remain unsampled after initial borings. C3/D2 modeling data remains hidden from the public. E unit modeling is not yet done. Effects of pumping changes are not being considered in Pall flow projections. Stochastic modeling is not being done. Pall has removed more dioxane from the C3/D2 units that was believed to be down there, yet some areas still see increasing or high levels of dioxane, including a recent discovery of 43,000 ppb in an area depicted on recent Pall maps as being under 5000 ppb.)