Email from CARD chair Roger Rayle to Ms. Susan Leeming, Division Director, Remediation and Redevelopment Division, Department of Environmental Quality...
Thank you very much for providing your May 10, 2017 e-mail outlining the DEQ position on the 1,4-dioxane (dioxane) drinking water criterion and additional site investigation work to delineate further the dioxane plume in the Old West Side area of Ann Arbor.
The Coalition for Action on Remediation of Dioxane (CARD), a partnership of local governments and citizens, has reviewed the DEQ position on both matters and recently voted to support this formal response, which includes these key points...
CARD requests that the DEQ make permanent this year the Part 201 Emergency Rule 7.2 ug/L dioxane drinking water criterion, regardless of any other Part 201 Proposed Rules elements.
CARD requests that regardless of whether the dioxane vapor intrusion criterion is 29 ug/L, as in the October 2016 Emergency Rule, or 1,900 ug/L, as consistent with the USEPA criterion, DEQ/Gelman need to identify the extent and magnitude of the shallow dioxane plume, so that the residents can decide how they want to protect themselves from any risk.
DEQ should take immediate action to:
determine the extent and magnitude of the Gelman dioxane shallow groundwater plume in the areas surrounding West Park and Waterworks Park;
determine whether buildings in the lower topographic elevations surrounding West Park and Waterworks Park may be in “contact” with the dioxane plume; and
determine whether utility workers may be exposed to shallow groundwater containing dioxane pollution in the areas surrounding West Park and Waterworks Park.
Thank you.
Sincerely,
Roger Rayle
chair, Coalition for Action on Remediation of Dioxane (CARD)