We do not support the expansion of the PZ but if the PZ is enlarged (Swells as referred to by Pall) to the north many more monitoring wells must be required. The current and proposed number of monitoring wells is insufficient and does not meet the BMP of industry standard groundwater cleanup efforts. This request is consistent with the contention that this plume is moving north toward the Barton Pond, where Ann Arbor gets 85-90% of it's drinking water. Ann Arbor has no other source of drinking water without expenditures of vasts sums of money.

The contamination of the soil on the Gelman Main site, estimates are at around 900k ppb (we don't know for sure because the soil testing had not been done for years), must be addressed to stop the contamination of the underling groundwater. We are basically using precious groundwater as an agent to cleanup soil contamination.

The limited documentation provided by Pall is not consistent with many other similar or lesser contamination cleanup efforts in Michigan. Additional documentation on the rational for reduced cleanup efforts must be required and verified. Reasons and rational for specific well closings must accompany any closing request.

Judge Sheldon must allow the MDEQ to more directly control the cleanup oversight because they have much more expertise in this type of very complicated cleanup operation.