On March 04, 2024, BASF submitted its "60 Percent Design" of a Perimeter Barrier Remedy at the NorthWorks facility
to USEPA and EGLE.

Here is the LINK to the Complete Document as ONE FILE, that is searchable via OCR  (LINK)
Here are the 34 individual sections of  the document, which include appendicies within appendicies (LINK)

Comments on this submittal can be found below.  This submittal by BASF  is deficient and similar to every other "promise to remediate NorthWorks"  BASF has broken starting with the very first Consent Order on the NorthWorks Site  in 1980,  where BASF promised, in State Court,  to stop releasing Toxic and Hazardous Waste from NorthWorks into the Public Waters of the State.    Excerpts from the 1980_10_20 State Consent Decree with BASFare below.

Comments-Opinions on the 60 PCT Design

A. Schedule for Start Up is drawn out to 2029-2030.    The Start Up of actual venting groundwater capture and treatment is 6 years away according to the schedule in the 60 PCT Design.   This is unacceptable for a current release of Toxic Hazardous Waste to a Great Lakes Connection Channel and into a Critical Assessment Zone of a Municipal Intake.   WHAT IS WRONG WITH THE STATE AND EPA to CONTINUE TO ALLOW A TOXIC HAZARDOUS  RELEASE to a Surface Drinking Water zone of the State?  
There are 3 Orders in the Courts already.  What EGLE and EPA must do is SET a definitive "DATE" as to when Stipulated Penalties will commence if continued release of contaminated groundwater is detected by EGLE/USEPA Monitoring.
Compliance with an Inward Gradient should have been achieved under the 1985 Order, which BASF agreed by Dec 31, 1986 to  halt of contaminated groundwater to the Detroit River from NorthWorks. 

B.  BASF supplied NO PERMITS for any of the Construction or Groundwater Treatment in the 60% submittal.  Considering the 30% design was submitted in Sept 2022, and BASF had been working on that for 2 years....it is clear that BASF is not serious about getting any of the necessary permits any time soon.    This puts EPA and EGLE as reviewing the 30% and now the 60% BASF Design that is likely not even permittable.   This is exactly what has occurred since 2000 and BASFs CMI submitall to EPA.   BASF submits plans that are not permit-able on purpose, and "restarts the clock" when they must go back to the drawing board.    EPA and EGLE should outright REJECT any BASF Plan that does NOT include an APPROVED  ACOE/EGLE JOINT PERMIT for CONSTRUCTION, and an NPDES permit for the Discharge of the Treated Groundwater.   DUWA is already on record as stating that it WILL NOT be a part of BASFs 30 or 60 PERCENT GROUNDWATER TREATMENT DESIGN, yet BASF continues to try and strongarm the City of Wyandotte and DUWA into taking the contaminated water from this design.  

C. Appendix N is a Non-starter!   BASF cites DUWA limits for Discharge, yet DUWA has fully rejected BASFs proposed discharge to it from the 30 and 60 Percent Design submittals.  BASF does not intend to get an NPDES permit because it cannot clean the contaminated groundwater to NPDES standards,  so they intend to minimally treat and pass contaminated groundwater down to DUWA and its own NPDES permit.  

D.  Where is EGLEs Monitoring Plan for the Venting Groundwater and Inward Gradient provisions of its 1985 Consent Order with BASF?    Where is USEPAs Monitoring Plan as required by RCRA Statute?    There is absolutely NO State or Federal Monitoring oversight of the current venting Groundwater Contamination.  Neither Agency is monitoring the current contaminant venting to the Waters of the State and within the Critical Assessment Zone of the Wyandotte intake.  Why?  Because they fully know that sky-high existing exceedances are occurring and would have to issue violations.   Is this what DownRiver Citizens and the Public can expect from their State and Federal Agencies to protect their Great Lakes Waterways and Surface Waters used for Drinking?  To ignore exceedances and obvious violations?

E. Section 3.4 "Performance Standards"    BASF fully misconstrues and tries to redefine the language that they signed in the 1985 Consent Decree with the State of Michigan, which set the performance standard for the NorthWorks  site as 

"shall be at all times sufficient to halt the flow of contaminated groundwater to the Detroit River
by maintaining a hydraulic gradient.."

excerpt below:

So why does BASF, a Multi Billion Dollar Chemical Conglomerate, use the Detroit River as its Toxic Waste Dump?
Because it can save tens of millions of dollars a year in extraction and treatment costs. 

If the State and USEPA will not monitor or enforce their Orders with BASF, why should BASF bother complying? 
EGLE should reject the 60 PCT submittal as not meeting the Performance Requirements of the Existing Consent Decree entered with the State in 1985.   EGLE is bound by the Michigan Constitution to hold USEPA,  BASF, and itself, as accountable to Act 451 and the provisions of Acts 111, 31, and 201, which are being violated by all three entities. 

F.  920 pages of Data from the 60 PCT Submittal is a falsehood.
Much of  BASFs 60 Pct Design of 3648 pages is "fluff" and not actually relevant to meeting water quality standards or existing Orders of a remediation project on the NorthWorks Site.  The 920 pages of Appendix 16a Tables of Data: GW Analytical Results is a prime example. 

At over a quarter of the overall submittal, BASF throws hundreds of pages of data tables at EPA,  EGLE, and the public, when EGLE has already reviewed this data and  has acknowledged gross exceedances to both USEPA and BASF, noting thatBASFs venting the groundwater continues to be Toxic (above FAV) and Characteristically Hazardous Waste, both which are Felony violations since they violate a Court Ordered Consent Decrees (1980 and 1985).  

Appendix 16a 920 pages can be summarized by the three Agency existing documents below:
The EGLE MMD  2021 Executive Memo
The EGLE WRD Mixing Zone Review
USEPAs internal 2021 FACT SHEET Summary on BASF releases  (above drinking water criteria, excerpt below)

2024_11_08 USEPA R5 Comments to BASF on 2024_03_04 60 PCT Design Submittal Deficiencies  - LINK

2025_04_28 EPA Tables of BASF 60PCT Response to 2024_11-08  - LINK