2014/01/16 - Some Observations on the Pall/Gelman 1,4-Dioxane Groundwater Contamination Site

DEQ has failed to implement tighter 2010 EPA dioxane revised cancer slope factor... and continues to stall that process...

    • Current 85 ppb should tightened to 3.5 ppb (or 0.35 ppb if Michigan still used a 1 in 1,000,000 risk level that it used up until 1995 and that most other states still use)

    • DEQ failed to meet its Dec 2012 deadline to tighten the standards and again in 2013

    • DEQ refused to let CARD reps attend toxicological discussion of dioxane that Pall reps attended to "review" the EPA findings

    • DEQ seems to be on course to set "site specific" cleanup criteria so EPA standards may not need to be applied to the Pall/Gelman site. (See DEQ semi-secret Collaborative Stakeholders Initiative and its successors... "the foxes re-designing the hen house")

Getting reliable, accurate, up-to-date data in a usable format continues to be a problem over the last several years...

  • Pall's new database had 100’s of anomalies

    • Pall refused to explain them

    • Pall cut off DEQ access to Pall's new database

    • more than 3 years since we’ve had a verifiable database

    • Citizen stakeholders and the DEQ have to spend time reconstituting database from Pall’s monthly summaries (several of which had their own anomalies)

    • + no resolution on data problems for year 2010 and before

    • Neither Pall nor DEQ seem to respect the importance of up-to-date, reliable, verifiable data

    • Data is only means to know what’s happening, to do proper modeling, etc.

    • Sloppy data gathering/analysis/reporting portells a sloppy cleanup

Neither Pall nor the DEQ uses EPA recommended newer dioxane analysis protocol (which can detect to ppt--parts per trillion) ...

    • In a recent major set of split samples, DEQ's dioxane readings were ~25% higher than Pall's

    • Samples analyzed by Pall & an outside lab they used varied even more

    • More range of error with old protocols should require increased sampling frequency to have more confidence in the readings, but instead DEQ is allowing less frequent sampling

What you can do...

    • Pay attention

    • Become informed

  • Attend meetings

    • Contact your elected State representatives and senators

    • Have your friends & relatives in other parts of Michigan do the same

    • (Ann Arbor area officials are on board… it’s the ill-informed or uncaring reps elsewhere that allow bad environmental protection laws and lax DEQ rules)