1,4-Dioxane Wiki - Recently Updated Pages

CARD 1,4-Dioxane Wiki Home

HydroGeek — Thu, 03 Dec 2009 15:05:35 CST

Welcome to the 1,4-dioxane Wiki

Working to expand the knowledge base and create interaction in the affected Washtenaw County and Ann Arbor, Michigan, communities.

Recent documents posted on the MDEQ Gelman Information page that address dispute resolution issues and PLS proposal issues, as well as MDEQ responses to recent PLS submittals.

Recent Events:

(December 3, 2009) According to Sybil Kolon, MDEQ Project Managern -the MDEQ is in discussions with PLS regarding issues related to the States denial of the PLS proposal that would change the cleanup objectives for the site. These matters will be decided in court if the MDEQ and PLS are unable to resolve them cooperatively. The MDEQ indicated they are making progress in these discussions, and the court hearing that was scheduled for December 9, on the state's motion to enforce the Consent Judgment, has been postponed. A new date has not been set. The earliest potential date would be in January. Stay Tuned.

EPA includes 1,4-dioxane to Final Contaminant Candidate List 3 (CCL 3)

Excerpt from EPA: "CCL 3 is a list of contaminants that are currently not subject to any proposed or promulgated national primary drinking water regulations, that are known or anticipated to occur in public water systems, and which may require regulation under the Safe Drinking Water Act (SDWA). The list includes, among others, pesticides, disinfection byproducts, chemicals used in commerce, waterborne pathogens, pharmaceuticals, and biological toxins. The Agency considered the best available data and information on health effects and occurrence to evaluate thousands of unregulated contaminants. EPA used a multi-step process to select 116 candidates for the final CCL 3. The final CCL 3 includes 104 chemicals or chemical groups and 12 microbiological contaminants."

Recent Court Filings:

Washtenaw County Trial Court Documents:

Plaintiffs Motion to Enforce Order Prohibiting Groundwater Use

MDEQ Documents:

DEQ June 2009 Nancy Drive MW Dispute Resolution
DEQ June 2009 Response to PLS Proposal
DEQ June 2009 PLS Proposal Memo
DEQ June 2009 Evergreen Memo

PLS Documents June 2009

Evergreen Area Verification -
Comprehensive GW Monitoring Plan -
Table 1 -
Figure 1 - Revised groundwater quality/sampling frequency figure (PDF)
Figure 2 - Revised groundwater level monitoring figure (PDF)

MDEQ Denies Pall/Gelman's (PLS's) Proposal

On 6-15-2009, MDEQ denied Pall/Gelman's (PLS's) 5-4-2009 proposal to reduce its dioxane groundwater cleanup activities and risk polluting more area water supplies... including Barton Pond where Ann Arbor gets 80% of its water.
[DEQ 6-15-2009 Response ] [DEQ Public Comment Response ]

Stay turned to make sure this decision is not overturned as it makes its way through upcoming court hearings.

Proposal Summary (see above for more recent infomation):

On May 4, 2009, PALL submitted the "Comprehensive Proposal to Modify Cleanup Program" at the former Gelman site, now owned by PALL. The text of the document is attached, see below. Here is a link to the complete document including maps and tables.

Pall Corporation (PALL) and the Michigan Department of Environmental Quality are required to adhere to the schedule contained in the April 22, 2009, Stipulated Order which modified the previous April 6, 2009, Order.

While the Washtenaw County Circuit Court (Court) is not supporting the public comment period that MDEQ requested, the MDEQ is making one available, albeit much shorter (4 weeks).

A main concern is that PLS is interested in expanding the prohibition zone to include the Evergreen area, eliminating the Consent Order requirement to clean up to 85 there and instead allowing up to 2800 ppb of 1,4-dioxane to migrate further downgradient. (See CARD State of the Cleanup for more info.)

Currently, there is very little geologic or hydrogeologic information to the north of the "Evergreen plume" (Dexter-Ann Arbor Rd area west of Maple rd and east of M-14) and no demonstration that expanding the prohibition zone toward Barton Pond will have no detrimental effects at Barton. Ann Arbor’s drinking water comes from a combination of sources. Eighty-five percent is drawn from the Huron River in Barton Pond. The remainder comes from groundwater wells located near the airport on the south side of town.

The concern of those close to the issue is that the Court took the Groundwater Surface Water Interface criteria (GSI) of 2800ppb and "dragged" it back from the Huron River to Maple Road with very little information demonstrating that the plume would head only to the east. It is unclear whether the Court is willing (or MDEQ will be effective in arguing) to "drag" the 35 ppb cleanup criteria for a GSI in proximity to a surface water drinking water source back to the northern boundary of the prohibition zone.

Key issues related to the the revised "global" remediation strategy are the current lack of demonstration that there is no northerly flow (toward Barton Pond) prior to allowing this and what is the contingency plan if/when something goes wrong.

If PALL has to pump a significant amount of water from the northern prohibition zone when something goes wrong, they are still currently limited to 1300 gallons per minute by the NPDES discharge permit so PALL will stop pumping elsewhere - not to mention the need for more wells and piping to get contaminated water from these neighborhoods.

Michigan Department of Environmental Quality public information meeting
May 27, 2009, 7-9pm, Haisley Elementary School for the MDEQ public meeting.

A PDF of the powerpoint presented by MDEQ is available under attachments, located at the bottom of the page.

5-27-2009 WEMU interview with Michael Gebhard about the issues discussed at the meeting.
Link: Video of the meeting.

CARD Annual Meeting
May 20, 2009, 7-9pm, Washtenaw Intermediate School District.
Link: Video of the meeting.

Regular Meeting Reminder:

The next CARD - Coalition for Action on Remediation of Dioxane meeting is currently TBD, at the Washtenaw County Western Service Center from 6:00 P.M. to 8:00 P.M.

What: CARD Meeting
When: TBD
Where: Washtenaw County Western Service Center
705 N. Zeeb Rd.
Ann Arbor, MI 48103

Click here for directions to Washtenaw County Western Service Center

WC Trial Court Schedule:

Washtenaw County Trial Court Schedule for JUDGE DONALD E. SHELTON

slope factor

HydroGeek — Fri, 28 Aug 2009 14:40:05 CDT

EPA Office and staff charged with evaluating the cancer slope factor (CSF) to estimate risk and set exposure standards for 1,4 dioxane for drinking water.

What are the assumptions being used for the model? Including the toxicity information, exposure assumptions (e.g., volumes consumed and at what concentrations), population (e.g., adult male vs. sensitive populations)

Please describe what is new about this effort to revise the cancer slope factor compared with the current assumptions in IRIS, the integrated risk information database. Please describe for the layperson what changes in assumptions or data are being used.

Links to Related Websites

HydroGeek — Fri, 28 Aug 2009 14:39:23 CDT

CARD (Coalition for Action on Remediation of Dioxane) website contains info on CARD meetings and documents

DEQ's Gelman Website contains official documents relating to Pall/Gelman contamination site

SRSW (Scio Residents for Safe Water) main website contains Pall/Gelman site data graphs, maps, news articles, etc.

SRSW (Scio Residents for Safe Water) Google Group website contains more SRSW presentations about the Pall/Gelman site

SRSW (Scio Residents for Safe Water) ning website contains more SRSW photos and videos about the Pall/Gelman site

TOSC (Technical Outreach Services For Communities) contains selected Pall/Gelman site documents from 2000-2004

City of Ann Arbor Environ Coord Dept website - Pall/Gelman site contains various documents and contact/resource info

Washtenaw County website contains County Commission agenda/minutes items as well as the CARD website
also:Washtenaw County Environmental Portal

Scio Township website contains Township agenda/minutes items as well as Township contact info

Ann Arbor Township website contains basic Township info

Pall Corp website contains search function to find 10Q/10K SEC and annual report sections on Gelman site

Criteria for DEQ Decisions

HydroGeek — Fri, 28 Aug 2009 08:33:47 CDT

Criteria Relevant to Selecting a Remedial Alternative Generally
and
Criteria Relevant to Gelman
Consent Judgment Modification

The Gelman Consent Judgment:

§XXIV This Consent Judgment may not be modified unless such modification is in writing, signed by all Parties, and approved and entered by the court. Remedial Plans, work plans, or other submissions made pursuant to this Consent Judgment may be modified by mutual agreement of the parties

Part 201 of the NREPA:
324.20102a
Sec. 20102a. (1) Notwithstanding any other provision of this part, the following actions shall be governed by the provisions of this part that were in effect on May 1, 1995:
(a) Any judicial action or claim in bankruptcy that was initiated by any person on or before May 1, 1995 under this part.
(b) An administrative order that was issued on or before May 1, 1995 pursuant to section 20119.
(c) An enforceable agreement with the state entered into on or before May 1, 1995 by any person under this part.
(2) For purposes of this section, the provisions of this part that were in effect on May 1, 1995 are hereby incorporated by reference.
(3) Notwithstanding subsection (1), upon request of a person implementing response activity, the department shall approve changes in a plan for response activity to be consistent with sections 20118 and 20120a.

Part 201 Criteria Relevant to Selecting a Remedial Alternative -§20118

18(2)(a)Assure the protection of the public health, safety, and welfare, and the environment (PHSWE)

(2)(b)Except as otherwise provided in 18(5) & (6), attain a degree of cleanup and control of hazardous substances that complies with all applicable or relevant and appropriate requirements, rules, criteria, limitations and standards of state and federal environmental law (ARARs)

ØLaw allows the following rules to be “waived” under certain conditions
lRule 705 (5): plume can’t expand after start of cleanup
lRule 705(6): active cleanup required unless naturally occurring chemical or biological process is documented to be taking place

18(3) The cost effectiveness of alternative means of complying with this section shall be considered by the department only in selecting among alternatives that meet all of the criteria of subsection (2).

18(4) Remedies that permanently and significantly reduce the volume, toxicity, or mobility, (MTV) of hazardous substances

Part 201 Rules
Rule 603(1) When the department is selecting or approving a remedial action, or when another person is selecting a remedial action, all of the following shall be considered:

(a) Effectiveness of alternative in protecting PHSWE
(b) Long-term uncertainties
(c) Persistence, toxicity, mobility and propensity to bioaccumulate of the hazardous substances
(d) Short-term and Long-term potential for adverse health effects from human exposure
(e) Costs of remedial action, including long-term maintenance costs, except that costs shall only be considered as specified in R 299.5601(3).
(f) Reliability of the alternatives.
(g) The potential for future remedial action costs if an alternative fails.
(h) The potential threat to human health, safety, and welfare and the environment associated with excavation, transportation, and redisposal or containment.
(i) The ability to monitor remedial performance.
(j) For remedial actions that require the opportunity for public comment under section 20120d of the act, the public's perspective about the extent to which the proposed remedial action effectively addresses requirements specified in part 201 of the act and these rules.
(2) Evaluation of the factors in subrule (1) of this rule shall consider all factors in balance with one another as necessary to achieve the objectives of part 201 of the act and R 299.5601. No single factor in subrule (1) of this rule shall be considered most important.

Recent 1,4-Dioxane Toxicology Research

HydroGeek — Fri, 28 Aug 2009 08:32:50 CDT

Summary

Inhalation Toxicology

September 2009, Vol. 21, No. 11, Pages 889-897

Two-year inhalation study of carcinogenicity and chronic toxicity of 1,4-dioxane in male ratsTatsuya Kasai ‌1, Hirokazu Kano ‌1, Yumi Umeda ‌1, Toshiaki Sasaki ‌1, Naoki Ikawa ‌1, Tomoshi Nishizawa ‌1, Kasuke Nagano ‌1, Heihachiro Arito ‌1, Hiroshi Nagashima ‌2, Shoji Fukushima ‌1

1Japan Bioassay Research Center, Japan Industrial Safety and Health Association, Hadano, Kanagawa, Japan

2Laboratory of Developmental Engineering, Department of Life Science, School of Agriculture, Meiji University, Kawasaki, Kanagawa, Japan

Address for Correspondence: Tatsuya Kasai, Japan Bioassay Research Center, Japan Industrial Safety and Health Association, 2445 Hirasawa, Hadano, Kanagawa 257-0015, Japan. E-mail: t-kasai@jisha.or.jp

Carcinogenicity and chronic toxicity of 1,4-dioxane were examined by inhalation exposure of 50 male F344 rats to 1,4-dioxane vapor at 0 (clean air), 50, 250, or 1250 ppm (v/v) for 6 h/day, 5 days/wk, and 104 wk. Survival rates of 250 and 1250 ppm-exposed groups were decreased near the end of the 2-yr exposure period, due probably to the occurrence of malignant tumors. A statistically significant but marginal decrement of terminal body weight (<10%) was found in the 1250 ppm-exposed group, suggesting slight systemic toxicity. Significant changes in plasma levels of AST, ALT, ALP, and γ-GTP and relative weight of the liver occurred in the 1250 ppm-exposed group. Dose-dependent and statistically significant increases in incidences of nasal squamous cell carcinomas, hepatocellular adenomas, and peritoneal mesotheliomas were found primarily in the 1250 ppm-exposed group. The incidences of renal cell carcinomas, fibroadenomas in the mammary gland, and adenomas in the Zymbal gland were also increased dose-dependently. Preneoplastic lesions occurred in the nasal cavity and liver of the 1,4-dioxane-exposed groups. As nonneoplastic lesions, the significantly increased incidences of nuclear enlargement, atrophy, and respiratory metaplasia in the nasal cavity were noted at 50 ppm and above. A LOAEL (lowest observed adverse effect level) was determined at 50 ppm for the nasal endpoint of general chronic toxicity. This study provides clear evidence of carcinogenicity for 1,4-dioxane in male rats. A cytotoxic-proliferative and in vivo genotoxic mode of action is suggested to operate in 1,4-dioxane-induced carcinogenesis.

CARD MDEQ Response Amendment

HydroGeek — Fri, 28 Aug 2009 08:27:02 CDT

Outline of draft in progress - 07/07/2009

Enough sampling to explain Dupont Circle screened elevation - how it got there and where it's going
cite GW flows to NE

IRIS-stds chg

Water level sampling qtrly to be able to do more accurate predictions

No industry-accepted justification for reducing sampling (Pall should follow standard practices such as MAROS).

Don't eliminate wells without having delination.

Usually complaince wells are clean (not just below 85 ppb)

Include comparison of Clare site (email from Mike) vs Pall site

Soil sampling overdue... soils continue to contaminate groundwater... most cleanups address source of contamination.

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.

Fact Sheets and other links related to Dioxane

HydroGeek — Wed, 24 Jun 2009 09:28:28 CDT

Fact Sheets and Toxicology Related Resources

Technical reports

Solvent Stabilizers white paper - Includes human health data and cleanup techniques for 1,4-Dioxane) by a geologist for the Santa Clara Valley Water District, CA
ER-1422: Biodegradation of 1,4-dioxane - Comprehensive research study on the biodegradation of 1,4-dioxane sponsored by the DOD/DOE/EPA Strategic Environmental Research and Development Program (SERDP))

CARD May 20 2009 Annual Public Meeting

srswrep — Fri, 29 May 2009 10:47:55 CDT

On May 4, 2009, Pall Life Sciences (PLS) submitted a new "Comprehensive Proposal to Modify Cleanup Program" that will drastically increase how much 1,4-dioxane it will leave in the groundwater at the Pall/Gelman contamination site.

The MDEQ (Michigan Department of Environmental Quality) has only until June 15, 2009, to respond to the PLS proposal. To comply with the compressed court ordered schedule, the MDEQ established a Public Comment Period (5/11/2009-6/8/2009) to take comments from the public on the PLS proposal. Also, the MDEQ will hold a Public Meeting on May 27, 2009, where the public can ask questions and make comments in person.

Because the far reaching changes in the PLS proposal could result in further damage to area water supplies, CARD decided to host its own meeting where the public can learn about the new PLS plan and how its loosened cleanup criteria could affect area water resources:

CARD (Coalition for Action on Remediation of Dioxane)
Annual Update - Public Meeting
Wednesday, May 20, 2009 - 7-9 pm

Washtenaw Intermediate School District

Vogel Room, 1819 S Wagner Rd, Ann Arbor

AGENDA
• Introduction to CARD - History, membership, joining
• Brief history of the site and status of cleanup extractions treatment and discharges
• Summary of the PALL’s Comprehensive Proposal to Modify Cleanup Program
• Questions & Answers

Current Concerns:
PLS PROPOSES TO TERMINATE CLEANUP AT HIGHER DIOXANE LEVELS.

Proposed expanded Well Prohibition Zone for the Evergreen plume would mean cleanup criteria there would change from 85 ppb to 2800 ppb and require deed restrictions for all properties in the Well Prohibition Zone.
Proposed cleanup termination criteria for the Core Area from 85 ppb to 500 ppb would require ongoing deed restrictions for all current and future affected properties.

PLS PROPOSES TO CUT GROUNDWATER SAMPLING ALMOST IN HALF.

The proposal reduces sampling frequency in most wells and terminates sampling at some wells above the current 85 ppb cleanup standard.
Infrequent sampling could miss slugs of dioxane as they move through the groundwater.
Annual sampling of static water levels would mask seasonal effects needed for effective flow modeling.

PLS PROPOSES TO REDUCE PURGE RATES BY MORE THAN ONE THIRD.

The proposed reduction from 1300 gpm to 800 gpm, the purge rate that was inadequate to contain the plumes in 2002.
Less purging means more dioxane will escape to spread to new areas.

PLS PROPOSAL WOULD ALLOW EVEN MORE DIOXANE TO SPREAD UNREMEDIATED.

High levels of dioxane may contaminate more water supplies to the north and west as groundwater flow conditions revert back to natural patterns after the purging stops.
Some of the leftover dioxane may again flow northwest and north to Scio Township residential wells with no access to replacement water.
Some of the leftover dioxane may flow northeast to Barton Pond where Ann Arbor gets 80% of its water.

The Coalition for Action on Remediation of Dioxane (CARD) is a partnership of local governments, citizen groups, and individual citizens that develops policies and strategies to address the problems associated with Pall/Gelman 1,4-dioxane contamination. Members include:

Information Contacts:

Michael Gebhard, Washtenaw County Environmental Health Division, 734-222-3855, or Email at gebhardm@ewashtenaw.org
Matt Naud, City of Ann Arbor, Systems Planning, 734-794-6430 x43712 , or Email at MNaud@a2gov.org
Roger Rayle, Scio Residents for Safe Water, PO Box 97, Dexter, MI 48130, 734-761-8932 or Email at rmrayle@gmail.com
Sybil Kolon, MDEQ Remediation and Redevelopment Division, 517-780-7937, or Email at kolons@michigan.gov.

Information Links:

5-27-2009 WEMU interview with Michael Gebhard about the 5-4-2009 Pall/Gelman Proposal
CARD (Coalition for Action on Remediation of Dioxane) - Official local government/citizen stakeholder group Pall-Gelman site
1,4-Dioxane Wiki Website - collaborative postings about Pall/Gelman Dioxane Site
SRSW home website - mostly links to more info
SRSW ning website - recent news, photos, videos, forums, etc.
SRSW Google Group website - most recent Powerpoint presentations, Google Earth mashups, and sampling data
DEQ's Gelman Website

Public Participation:

CARD 5-20-09 Meeting on Facebook
Use hash tag #A2CARD to follow/comment/ask questions on Twitter
Search Wguru Live on Ustream.tv for possible live streaming of meetings

Pall-Gelman Attempts to Hide Evidence of Escaping Dioxane Plumes

HydroGeek — Thu, 28 May 2009 11:22:41 CDT

Pall-Gelman seems to be trying to hide what's going on at monitoring well 2575 Valley Drive in 2009 like Gelman Sciences did with monitoring well MW-30d in 2003.

In 1993, Gelman Sciences quit sampling MW-30d even though the dioxane levels were on an upwards trend reaching 9 ppb (three times the 3 ppb cleanup standard at the time).

MW-30d was a deep well, bottom of screen elevation = 725 ft, the only well in the deeper E aquifer being sampled that had significant dioxane levels.

When MW-30d sampling was finally resumed in 2001, the dioxane levels had reached 67 ppb.

Since 2007, MW-30d dioxane levels have been over 1100 ppb. Had MW-30d been sampled all along between 1993 and 2001, maybe the deep E aquifer contamination would have been detected up to seven years sooner, and Ann Arbor's Northwest Supply Well would not have been contaminated and had to be shut down.

(Incidentally, when Pall transferred Gelman Sciences' sampling data to Pall's computerized database, Pall left off the MW-30d sampling prior to 2001... but one can still view it on the SRSW's 1995 Gelman Sciences' database archive... except for the last 9 ppb reading which Gelman Sciences failed to record from its paper records.)

Now in 2009, Pall-Gelman (officially Pall Life Sciences, PLS) proposes to quit sampling a well at 2575 Valley Drive even though the dioxane levels there are on an upwards trend reaching 75 ppb in 2008 (almost to the current relaxed cleanup standard of 85 ppb). Why would Pall want to do this? Pall's well data table says that the well is not in the E aquifer, nor is it in the D2/Evergreen aquifer... Pall labels it as being in a "Not Determined" aquifer... this, in spite of the well screened elevation being consistent with the D2/Evergreen aquifer (~837 feet above sea level). While the 2575 Valley well depth is not deep enough to be in the E aquifer even though Pall's latest E aquifer plume map would encompass it. In fact, Pall does not show the well on any of its recent maps justifying its May 5, 2009, proposal to relax its cleanup responsibilities nor was it on Pall's recent Evergreen analysis maps ... it only appears on the 2009 Base Map.

A nearby well at 2601 Dexter is also labeled as being in a "Not Determined" aquifer even though it is has a depth similar to 2575 Valley's well. 2601 Dexter's dioxane levels also had been on an upwards trend (up to 8 ppb) before the well was abandoned in 2007.

Is Pall labeling these wells as being in a "Not Determined" aquifer to hide the fact that Pall is once again in violation of the current Consent Judgment by letting the D2/Evergreen plume escape beyond its purge wells? Or is Pall hiding the fact that there is yet another (a "Not Determined") aquifer that is about to be contaminated above the current 85 ppb cleanup standard? Either way, loosening the cleanup criteria in the Evergreen area to 2800 ppb and halting sampling of these "Not Determined" aquifer wells is a way to keep the problem hidden.

Will the MDEQ allow sampling of a key well to be halted like the DNR did with MW-30d in 1993?

One of the next closest wells upgradient to these two is 456 Clarendon which is labeled as being in the D2/Evergreen aquifer and has dioxane levels on an upwards trend since Evergreen purging was reduced.

The well at 440 Clarendon lacks well log data to determine at what elevation the well is screened, but its dioxane levels were on an upwards trend reaching 192 ppb when sampling stopped in 2005. Pall claims in its well table note that this well is "Access Denied" when in fact the homeowner is waiting for Pall to repair the well so it can be sampled.

CARD Meeting Schedule

srswrep — Sun, 17 May 2009 21:39:34 CDT

CARD calendar (link to CARD.ewashtenaw.org)

Public Meeting
UPDATE ON THE PALL/GELMAN 1,4-DIOXANE CONTAMINATION SITE

Wednesday, May 20, 2009, 7:00-9:00 pm
Washtenaw Intermediate School District, Vogel Room
1819 S. Wagner Road, Ann Arbor, Michigan

SPONSORED BY THE COALITION FOR ACTION ON REMEDIATION OF DIOXANE (CARD)

Citizen and Local government representatives of CARD will provide an update on PALL’s “Comprehensive Proposal to Modify Cleanup Program” submitted on May 4, 2009, to the Michigan Department of Environmental Quality (MDEQ).

Included in this proposal is a further expansion of the Prohibition Zone established by the Court to prevent groundwater use and potential exposure to contaminated groundwater, and significant reductions in the active remediation activities (groundwater extraction and treatment).

AGENDA
• Introduction to CARD - History, membership, joining
• Brief history of the site and status of cleanup extractions treatment and discharges
• Summary of the PALL’s Comprehensive Proposal to Modify Cleanup Program
• Questions & Answers

MDEQ staff are planning to attend but not provide a formal presentation, MDEQ Staff will be able to address
questions during the Question & Answer section of the meeting.

Information Contacts:
• Michael Gebhard, Washtenaw County Environmental Health Division, 734-222-3855, or Email at gebhardm@ewashtenaw.org
• Matt Naud, City of Ann Arbor, Systems Planning, 734 794 6430 x43712 , or Email at MNaud@a2gov.org
• Roger Rayle, Scio Residents for Safe Water, PO Box 97, Dexter, MI 48130, 734-761-8932 or Email at rmrayle@gmail.com
• Sybil Kolon, MDEQ Remediation and Redevelopment Division, 517-780-7937, or Email at kolons@michigan.gov.

Current Concerns:
PLS PROPOSES TO TERMINATE CLEANUP AT HIGHER DIOXANE LEVELS.

Proposed expanded Well Prohibition Zone for the Evergreen plume would mean cleanup criteria there would change from 85 ppb to 2800 ppb and require deed restrictions for all properties in the Well Prohibition Zone.
Proposed cleanup termination criteria for the Core Area from 85 ppb to 500 ppb would require ongoing deed restrictions for all current and future affected properties.

PLS PROPOSES TO CUT GROUNDWATER SAMPLING IN HALF.

The proposal reduces sampling frequency in most wells and terminates sampling at some wells above the current 85 ppb cleanup standard.
Infrequent sampling could miss slugs of dioxane as they move through the groundwater.
Annual sampling of static water levels would mask seasonal effects needed for effective flow modeling.

PLS PROPOSES TO REDUCE PURGE RATES BY MORE THAN ONE THIRD.

The proposed reduction from 1300 gpm to 800 gpm, the purge rate that was inadequate to contain the plumes in 2002.
Less purging means more dioxane will escape to spread to new areas.

PLS PROPOSAL WOULD ALLOW EVEN MORE DIOXANE TO SPREAD UNREMEDIATED.

High levels of dioxane may contaminate more water supplies to the north and west as groundwater flow conditions revert back to natural patterns after the purging stops.
Some of the leftover dioxane may again flow northwest and north to Scio Township residential wells with no access to replacement water.
Some of the leftover dioxane may flow northeast to Barton Pond where Ann Arbor gets 80% of its water.

Information Links:

CARD (Coalition for Action on Remediation of Dioxane) - Official local government/citizen stakeholder group Pall-Gelman site
1,4-Dioxane Wiki Website - collaborative postings about Pall/Gelman Dioxane Site
SRSW home website - mostly links to more info
SRSW ning website - recent news, photos, videos, forums, etc.
SRSW Google Group website - most recent Powerpoint presentations, Google Earth mashups, and sampling data
DEQ's Gelman Website

Public Participation:

CARD 5-20-09 Meeting on Facebook
Use hash tag #A2CARD to follow/comment/ask questions on Twitter
Search wguru on Ustream.tv for possible live streaming of meetings

Data - Pall/Gelman Site

srswrep — Wed, 13 May 2009 14:50:07 CDT

Feb 2009 Well Data and Sampling Data (brief version) tables from the Pall/Gelman database are available as comma-delimited (.csv) files in attachments below.

The Well Data table (see attachment below) includes the following fields:

ID

Well ID

Well Name

Map Location

Date Installed

TOC Elevation AMSL (Feet)

Depth from TOC to bottom of screen (Feet)

Boring Depth (Feet bgl)

Ground Elevation

Top of Screen 1

Bottom of Screen 1

Top of Screen 2

Bottom of Screen 2

Screen Length (Feet)

Aquifer

X CORD

Y CORD

Well Driller (if known)

Comments

Statics Required?

Well Types

Sampling Interval

MonthlySorting

Print Resident Letters

ResidentID

House, Bail or Pump:

GF

Area

Group

Static ID

Sampling Comments

Location Information:

The Sampling Data (brief) table (see attachment below) includes the following fields:

Well Name

1,4-Dioxane Results (ppb)

Date Sampled

The full Sampling Data table (not available here) includes the following fields:

Sample ID

Entered

Well Name

1,4-Dioxane Results (ppb)

Date Sampled

Time Sampled

Date Received

Date Analyzed

Reporting Limit

Reporting Lab

Static Reading

Static Time

Static Only?

Comments

Bromate Results

Date Bromate

Bromate Reporting

Bromide Results

Date Bromide

Bromide Reporting

Completed Sample?

1995 GSI data

srswrep — Wed, 13 May 2009 14:49:12 CDT

A large portion of sampling data collected by Gelman Sciences Inc. up until 1995 is still not available on the "complete" database that Pall (Pall Life Science - PLS) submits to the DEQ on a regular basis.

Some of the missing data is significant, e.g. the 1988-1993 samples from MW-30d that indicated a problem with the deeper aquifer 7-8 years before the deep E aquifer contamination was "discovered". Incredibly, the company was allowed to suspend sampling of MW-30d from 1993-2001. The last sample from 1993 was 9 ppb, 3 times the cleanup standard at the time, 3ppb. (Incidentally, the 9 ppb sample never made it into the GSI database -- it only existed on a paper copy submitted to the state.) Only after discovery of dioxane in the deep E unit to the area west of the Third Sister Lake in 2000 did the company re-start sampling of MW-30d in Feb 2001and got a 67 ppb reading. MW-30d has been over 1000 ppb since 2006.

Frequently Asked Questions

srswrep — Wed, 13 May 2009 13:58:01 CDT

(also visit Card State of the Cleanup for more FAQs)

What is 1,4 Dioxane?

1,4 dioxane is a solvent and is listed by US EPA as a probable carcinogen. It should not be confused with dioxin, a more potent, known carcinogen. Technical information is available on-line at the US Environmental Protection Agency. http://www.epa.gov/ttn/atw/hlthef/dioxane.html

Is there 1,4 Dioxane in the City of Ann Arbor’s drinking water?

No. No observable level of 1,4 Dioxane is, or ever has been detected to-date in Ann Arbor’s municipal drinking water supply. Tests are frequently applied to the source water brought into the Water Treatment Plant as well as the water supplied to our customers.

Has the City ever detected 1,4 Dioxane in any Ann Arbor drinking water source?

Yes. During a routine test in 2001, a trace level of 1,4 Dioxane (1-2 ppb/parts per billion) was detected in water from Ann Arbor’s Northwest Supply well, which was used by the city as a water source during the winter months. The Northwest Supply well water was not being used at the time of the positive test and was immediately closed and remains closed. The Northwest Supply well provided less than 5% of Ann Arbor’s total source water.

How can I learn more about Ann Arbor’s drinking water quality?

The Ann Arbor Water Utility provides an Annual Water Quality Report to municipal customers, including test results that demonstrate our drinking water consistently meets or exceeds all Federal water quality standards. The most recent report, and more water quality information, is available on the web at http://www.ci.ann-arbor.mi.us/Utilities/WTP/int-lab.html .

CARD Public Meeting Agenda Development Area

srswrep — Wed, 13 May 2009 13:26:44 CDT

Outline of points to make

What about using this site as the agenda to walk folks through some history and get them familiar with it? (MJN)

4/30/2007 CARD Public Meeting Questions

srswrep — Wed, 13 May 2009 13:25:07 CDT

The following questions were submitted by attendees in writ ting following the completion of the April 30, 2007 public informational meeting. CARD associates will work to obtain or develop answers to these questions or provide direction to the most appropriate agency related to the question.

Note: Questions have been entered as close to verbatim as possible, and have not been paraphrased. If corrections are needed, please enter the question number and correction in the comments section at the bottom of the page.

Question 1: "The 1,4-dioxane dumping went on from 1966 to 1986, and now it is 2007! Are we gaining on the plume or loosing ground?
Response:

Question 2: "Why has thee extraction/treatment well in the Maple Village Center been terminated?"
Response:

Question 3: "The new test-well at Charlton/Virginia . . . . what does it show?"
Response: PLS has completed installation of a set of three monitoring wells near
the intersection of Virginia and Charlton. Samples of groundwater were collected at ten foot intervals where water was encountered. Seven samples taken from 40 to 110 feet were all non-detect for 1,4-dioxane. Three samples taken from 150 to 170 feet had 1,4-dioxane of 3, 2 and 5 parts per billion, respectively. Samples taken at 200 and 210 feet were non-detect. Bedrock was encountered at 212 feet. Three monitoring wells have been installed, screened at 50-55 feet, 165-170 feet and 202-207 feet. (Based on an email from Sybil Kolon, MDEQ)

Question 4: "Please explain the win or lose aspects of the city lawsuit. What did it cost to litigate?"
Response:

Question 5: "Why was the community excluded (from the city lawsuit)?"
Response:

Question 6: "Please explain the affect on the storm water sewers & pipelines with regard to settlement?"
Response:

Question 7: "with the $285,000 win from the lawsuit, can you put some of that back in the community affected? The Northwest supply well need tuck pointing and fence repair & landscaping."
Response:

Question 8: " How will you compensate the neighborhoods affected? What are you doing with the $$?"
Response:

Question 9: "Page 23 of settlement; why did the city agree to points 2 & 3? They effectively eliminate citizens?"
Response:

Question 10: "What are the criteria for test/monitoring well sites?"
Response: Monitoring wells are proposed by Pall or MDEQ. The City typically looks for city right of way sites for these wells once the wells are approved by MDEQ. Typically CARD is aware of proposed well sites and to the extent possible, sites are identified that limit neighborhood disruption. The criteria depend on the rationale for the wells. Some are to identify downstream geology to understand how contaminated groundwater is likely to flow. Some are to delineate the 85 ppb boundary of the contamination.

Pall/Gelman Dioxane Treatment Costs

srswrep — Wed, 13 May 2009 13:23:37 CDT

Link to Google Group Spreadsheet summarizing treatment costs of original UV/Ox and current O3Ox systems.

Cost figures from: Jan 2005 EPA News and Trends - Issue 18 - pp3-4

Green Fair 2008 Update

srswrep — Wed, 13 May 2009 13:18:53 CDT

Ann Arbor Green Fair June 13, 2008 6-9pm Downtown Ann Arbor

CARD will have a table at the Ann Arbor Green Fair along with Scio Residents for Safe Water (SRSW.ORG).

1,4-Dioxane Groundwater Contamination

What's New

Groundwater access and use is restricted for a significant portion of western Ann Arbor by a court-ordered Prohibition Zone. The Prohibition Zone allows 1,4-dioxane concentrations up to 2800 ppb, exceeding the 85 ppb groundwater clean-up standard.

There is a contamination plume that is nearly a mile long and 1/4 mile wide with 1,4-dioxane concentrations that exceed the 2,800 ppm Prohibition Zone standard .

In the Evergreen neighborhood, 1,4-dioxane levels have been unexpectedly increasing at the northern and eastern boundaries despite ongoing clean-up efforts.

MDEQ denied a PLS request to reduce purging by 50% of the 1,4-dioxane "bubble" that is located west of the Gelman/PLS plant site. PLS continues to purge once a month at this location.

There are ongoing discussions between PLS and MDEQ in an attempt to resolve conflicting consent agreements and current contamination conditions. The results of which should be available soon

By court order, there should be no additional 1,4-dioxane contamination exceeding 2800 ppm allowed to move east across Maple Road, to the extent feasible.

By court order, there should be no additional 1,4-dioxane contamination exceeding 85 ppm allowed to move east across Wagner Road, to the extent feasible.

April 28, 2008 Meeting Follow-up

srswrep — Wed, 13 May 2009 13:17:59 CDT

What do we need to do different:

Ask for meeting comments & concern (did it meet your needs and what do you want to know that we didn't tell you?)

Less Talk, more time for Question & Answer

More update and less history (or pre-can YouTube video)

Distill the information vs heavy detail

CARD State of the Cleanup

HydroGeek — Tue, 12 May 2009 11:25:28 CDT

What is CARD?

The Coalition for Action on Remediation of Dioxane (CARD) is a partnership of local governments and citizens that develops policies and strategies to address the problems caused by 1,4-dioxane released by Pall/Gelman (Pall Life Sciences or PLS).

What is 1,4-dioxane?

1,4-dioxane is an industrial solvent.
Acute (short-term) inhalation exposure to high levels of 1,4-dioxane has caused vertigo, drowsiness, headache, anorexia and irritation of the eyes, nose, throat, and lungs in humans. It may also irritate the skin. Damage to the liver and kidneys has been observed in rats chronically (long-term) exposed in their drinking water. In three epidemiological studies on workers exposed to 1,4-dioxane, the observed number of cancer cases did not differ from the expected cancer deaths. Tumors have been observed in orally exposed animals. EPA has classified 1,4-dioxane as a Group B2, probable human carcinogen. (EPA Technology Transfer Network)
RLC - [Please insert toxicology concerns and any updates]
EPA has 1,4 Dioxane on its contaminant candidate list 3 (CCL3) - their list of compounds of concern for drinking water. [cite]
Important Note - this is 1,4-dioxane and NOT DIOXIN, which is a worse carcinogen but one that does not migrate with water nearly as readily as 1,4-dioxane.
1,4-dioxane is fully miscible in water, thus will go whereever water goes.
Most dioxane contamination sites result from spills of other industrial solvents that contain a small percentage of 1,4-dioxane as a stabilizer. The Pall/Gelman contamination resulted from Gelman's use of 100% dioxane in the manufacture of its filters.

Where did it come from?

From 1966 to 1986, Gelman Sciences used a reported 800,000 lbs of 1,4-dioxane in the manufacture of its filters.
Dioxane and other industrial chemicals were disposed of in a number of ways on the property including disposal in unlined lagoons, spray irrigation, and deep well injection. There was also some venting of contiminated wastewater to nearby surface waters.
The contamination has migrated in groundwater aquifers several directions off of the site. [plume map]
In 1989-90, a company analysis estimated that there were 64,000 lbs in the groundwater and that it would cost $44 million to clean it up to the 3 ppb standard in effect at that time. Since then, the company has removed over 80,000 lbs of 1,4-dioxane.
In 2009, there are still areas with over 20,000 ppb of 1,4-dioxane in the groundwater.
The contaminated groundwater plumes are over 3 miles long and 1 mile wide.

Where is the Contamination in 2009?

Pall/Gelman Property closeup 2009 Plume Map
- High concentrations of 1,4-dioxane contamination still exist in the soils, marshy area, and groundwater on the company's property on South Wagner Road.
- Contamination still eminates from the site in several directions - southwest, west, northwest, north, northeast, and east.
- The largest known plume is in the deepest aquifer and is heading generally east through Ann Arbor.
Scio Township 2009 Plume Map + Scio Twp Props with Wells
- Dozens of township properties' wells around the Gelman site were contaminated with dioxane and had to be shut down and the properties hooked up to the City of Ann Arbor's municipal water and sewer system.
- For properties east of Wagner Road, the properties also were required to annexed to the City, thus reducing Scio Township's tax base and increasing the municipal property tax for the annexed properties.
- Hundreds of Scio Township with wells and no access to city water lie north of the Pall/Gelman site.
Ann Arbor Township Plume Map + Ann Arbor Twp "islands"
- There are township islands within the city boundary that have been affected.
- Additional properties may be affected if the dioxane plumes are allowed to spread.

City of Ann Arbor Plume Map - Ann Arbor with NW Supply Well
- Contamination has moved with the groundwater from the Pall/Gelman site to the northeast and east within the city limits.

The northeastly Evergreen Plume [map] has been remediated since 1993 and refers to the original subdivision affected along Dexter Road.
- Most of these homes were on wells but are now connected to city water because the wells were contaminated with dioxane.
- There is an extraction system in place and the company (Pall Life Sciences) is required to capture the plume at 85 ppb - the current MDEQ residental groundwater cleanup standard.
- Status: It is doubtful that PLS is capturing the plume at Evergreen as required by the Consent Judgement. This is important for two reasons. (1) the company is required to capture the leading edge of the Evergreen plume and (2) significant fines were placed on hold but may be back in play if PLS is out of compliance.
- PLS had argued that they are extracting contamination from another source (the E Plume) and are not out of compliance. They have installed additional wells to attempt to demonstrate this to the MDEQ.
- Recently, PLS reversed its position and concluded that the D2 aquifer at Evergreen and the deeper E aquifer are parts of the same aquifer.
- PLS uses this to argue for expanding the 2800 ppb Prohibition Zone [pink outline] to include the Evergreen contaminaton and eliminate the need to clean up Evergreen.
The deeper E plume is the largest plume and has moved east from the Gelman site under the west side of Ann Arbor.
- Unlike the Evergreen plume, the court has allowed PLS to let 2800 ppb of 1,4 Dioxane to migrate east of Maple Road.
- The 2800 ppb number is based on the Groundwater-Surface water Interface or GSI standard - or the amount of 1,4-dioxane in groundwater that MDEQ believes is allowable to "vent" to surface water where the water is not used for human consumption downstream.
- The E unit contamination has to be cleaned up to 85 ppb west of Wagner Road, but just east of Wagner Road, the contamination only has to be cleaned up to 2800 ppb.
- PLS predicts that the E plume of dioxane will vent to the Huron River somewhere near Argo Dam.
- The Court ordered a prohibition zone [red outline] for the E aquifer contamination east of Wagner Road that severely limits the use of groundwater by property owners.
- PLS had planned to pump 200 gpm from Maple Village to remediate the E plume, but they are currently pumping only about 50 gpm and are having problems maintaining that rate because of plugging of the well were the treated effluent is being re-injected back into the aquifer.
- Because of these apparent re-injection problems, the company now proposes to drastically reduce the cleanup effort at Evergreen, build another pipeline from Maple to connect with the Evergreen pipeline, and pump the Maple Road purgewater back to PLS's Wagner Road plant for discharge to the Honey Creek tributary.

Outstanding questions include:

What changes are in PLS's current proposal?
- PLS'a current proposal would change the cleanup criteria for the Evergreen plume from 85 ppb to groundwater-surface water interface standard of 2800 ppb.
- It also would change the core cleanup criteria west of Wagner Road from 85 ppb to an arbitrary 500 ppb.
- PLS proposes to reduce their total purge rates from 1300 gpm to 800 gpm.
What will happen to the dioxane that PLS no longer has to clean up?
- Current modeling is inadequate to predict where the dioxane will end up.
- When purging stops, the groundwater flow patterns will return to the natural state, which judging from where dioxane flowed originally, may contaminate additional water supplies.
- The core dioxane may again head southwest, northwest, north, northeast at unknown rates.
- The Western Plume may again increase to unacceptable levels and threaten residential wells north of I-94.
- The Evergreen plume may head towards Barton Pond where Ann Arbor gets 80% of its water.

Where will the plume through the city go and where will it vent to the River?
- PLS is required to perform a downgradient investigation and has submitted this report to MDEQ. MDEQ responded with comments.
- Some of the dioxane is deep enough that it may flow under the river.
- Some of the dioxane may shift and flow along the river threatening some wells outside the prohibition zone further downstream.
- Some of the dioxane may vent the Allen Creek drain before it gets to the river as it gets to neighborhoods with historically active artesian conditions.
- No investigation has occurred to measure 1,4-dioxane in the stormwater system to see if any of the groundwater is infiltrating into the stormwater or sanitary systems.
How do we know that the contamination crossing Maple Road will remain under the court ordered 2800 ppb GSI standard?
- MDEQ has required PLS to install monitoring wells in Veterans Park across from the Maple Village Shopping Center. Three wells were to be installed - two were and one could not be installed because the well rig hit boulders. PLS and MDEQ disagree about the installation of the third well - the northernmost well.
- PLS has installed extraction and re-injection wells at Maple Village. Water is extracted from two wells - piped north to a portable treatment system on the former Milk Depot property on Dexter Road where it is treated with hydrogen peroxide and ozone to partially destroy the 1,4 dioxane. The effluent is then piped back to Maple Village where it is re-injected back into the contaminated aquifer. Re-injection of partially treated water can cause the well screens to become plugged, thus the PLS Maple Road system is often shut down because PLS cannot re-inject at the necessary rate.

Who is responsible for cleaning up the contamination?

Pall Corporation acquired Gelman Sciences in 1997 and thereby assumed responsibly for the cleanup.

1,4-Dioxane - Water Standards by State

srswrep — Tue, 17 Jun 2008 13:01:16 CDT

from Screenshot of Google Earth Map with data from EPA state dioxane standards table

It's shocking that Michigan, steward to 20% of the earth's fresh water, has such a lax standard for the allowable levels of 1,4-dioxane in water... thanks to the state's leaders in 1995 when the residential cleanup standard for dioxane was lossened from 3 ppb to 77 ppb... and an EPA factor change soon after that increased that by about 10% to the current 85 ppb.

Maybe it's time for Michigan to once again re-establish itself at the forefront of more protective environmental standards instead of being a laggard compared to other states.