Embedded Files
In response to
Pall Life Sciences - Little Lake Area System
Supplementation of Previous Notice of Termination
of Extraction from the Ann Arbor Cleaning Supply Well
April 1, 2014 (follow-up to February 12, 2014, PLS notification of termination) [DEQ links to documents pending]
received via email by SRSW on April 25, 2014,
SRSW asked the DEQ on April 25, 2014, if they knew
"anything about a deal being proposed to Judge Shelton that would reduce Pall/Gelman's future cleanup responsibilities ... to be in place before the judge retires? ... perhaps by exempting Pall from any tightening of the dioxane cleanup criteria?"
The DEQ replied:
"No deal’s in the works that we’re aware of that would exempt PLS from changes in 1,4-D standards.
Recall that we briefed Judge Shelton in the lead-up to, and included in, the 3rd amendment to the CJ language that reserved our rights to petition the court, or seek new actions, for performance of additional response activities if, among other things, the criterion gets changed downward."
SRSW then replied:
"No deal’s in the works that we’re aware of that would exempt PLS from changes in 1,4-D standards".
...Except as it relates to terminating the purging at Little Lake? (per Sybil's email this morning)
The DEQ has been dragging its feet on adhering to the EPA's 2010 dioxane guidelines which allows to Pall to ask to terminate purging based on the old 85pbb standard... which puts Scio Township drinking water wells at risk less than a half mile in the path of this:
Apparently, Pall doesn't even have complete well log data for that well... or maybe it's hidden in their new database that we no longer have access to.
The idea of "compliance wells" to allow termination of purging is a joke. ALL wells should be compliance wells. Otherwise it's saying to homeowners in the path of the plumes "Don't worry about what's in your well... trust the compliance wells." or "Only drink from compliance wells". The DEQ has severely cut back on monitoring drinking water wells around the periphery of the plumes at the same time allowing Pall to cut back on its monitoring and reduce its cleanup activities... thus transferring the cost and risk to individual homeowners... homeowners have to do their own monitoring.
If MW-41s was a homeowner's well, what would that indicate about the effectiveness of using "compliance wells" to make termination decisions... especially with the dioxane cleanup standard re-tightening to the ~3pbb range?
Terminating the purging at Little Lake based on the old 85pbb standard would also set a precedent for other parts of the cleanup... putting even more water supplies at risk in the future.
[images from SRSW's Google Earth Mashup - Well Tables/Graphs/Samples/3D Plumes/PZ/etc thru 2012]
Pall wants to stop purging from the A2 Cleaning Supply well since it and the few "compliance wells" have been under 85 ppb recently. Remember that Pall's data is based on an outdated sampling analysis protocol that seems to underestimate the dioxane levels when compared with the State's. And neither use the latest EPA recommended method.
Page updated
Google Sites
Report abuse