08/07/2015 - Pall's Little Lake Report
On March 19, 2015, the DEQ forwarded a copy of Pall's Little Lake- Honey Creek Area Investigation Report to various stakeholders. SRSW reviewed that report and reported a number of problems with it to the DEQ... including the fact that Pall's consultant used the wrong well log for MW-92...
A quick review reveals a number of problems with the report/analysis.
It's good to see Pall finally produce a plume map at 1 ppb, but its boundaries are discontinuous. They should depict where all the plumes are at the level of detect... not just at the current standard of 85 ppb.
Much of the depiction of BHMW-92 is wrong (they mistakenly used well log data for MW-92!) ... probably because of Pall's sloppiness in naming two locations "MW-92" ... and the DEQ's not requiring Pall to make BHMW-92 a monitoring well even though BHMW-92's well log showed 1-6 ppb at depths ~50-112' and 2 ppb at 152' just above where drilling was terminated at 156'.
Some of the same questions about the lack of deeper plume delineation remain. what might Pall have found it BHMW-92 was drilled deeper? ... or what subsequent sampling would have shown if they had kept it as a monitoring well instead of immediately plugging it?
BHMW-92 data is not in the DEQ's well database and while we have a well log for it, some of the well log data is missing (e.g. elevation)... even though Pall's corrected cross-section depicts it.
There's likely some higher concentrations feeding the Little Lake area since the groundwater flow is 1-1.5 ft/day and the "bubble" at MW-53 hasn't moved. The path is probably around or under the locations MW-51 and BHMW-92 where Pall chose to drill... or maybe it's leaking from sediments in Little Lake... that was man-made in it's current form during the time Gelman's dioxane was in Honey Creek at much higher concentrations.
Once again, there are numerous wells shown for which we are missing well logs and X/Y data. (BHMW-92 is one of them). There are several old well locations in the original Western Area missing from this analysis that had detectable dioxane readings before those locations were abandoned (and not replaced). All stakeholders should have online read-only export access to a central, up-to-date, reliable and complete "official" database.
That's all for now, but this should remind everyone of the issue of ongoing shaky data management leading to questionable conclusions... another example of "garbage in, garbage out".
--Roger--
Roger Rayle
chair, Scio Residents for Safe Water (www.srsw.org)
SRSW assumed the DEQ would inform Pall of the mistake as part of the DEQ's oversight role. However, at the CARD meeting on August 4, SRSW.learned that the DEQ did not deem the report and it's problems worthy of a response... until SRSW sent Pall an 8/4/2015 email about the wrong MW-92 well log being used. That led to the following email from Pall's consultant on 8/6/2015 that was then forwarded to SRSW:
Hi Dan,
We followed up on your question regarding a borehole log used in one of the cross sections included in the Little Lake Area System report (cross section C-C’). In building this cross-section, we used the wrong well log for Borehole MW-92. We used a well log titled PLS-04-03/MW-92. We will be issuing a new cross section with the correct well log information. Please be assured that this mistake makes absolutely no difference in our conceptual model for the Little Lake Area or the findings contained in the report.
Sorry for any inconvenience and thank you for bringing this to our attention.
Jim
James Brode, CPG
Senior Project Manager/Associate
FLEIS & VANDENBRINK
SRSW then sent this 8/7/2015 reply to the DEQ:
Regarding Brode's response: "Please be assured that this mistake makes absolutely no difference in our conceptual model for the Little Lake Area or the findings contained in the report. "
Yeah, right. Why let facts get in the way of what Pall/(Danaher) wants its model to show?
UPDATE:
On 2/2/2016, the DEQ hand delivered a corrected BHWM-92 cross-section diagram to SRSW. The corrected cross-section is dated 8/7/2015.