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Pall's E unit cleanup plans have been submitted and the DEQ has chosen
which approach they prefer. The DEQ has scheduled a Public Meeting for
7-9pm, July 28, 2004, at Slauson Middle School to review the plans. A TOSC
meeting to further address the issues is planned for August 4 at a time
and location to be determined. Details are or will soon be available on
the TOSC, DEQ, and City of Ann Arbor websites.
Go to the SRSW website at www.srsw.org and click on the appropriate links.
The public comment period set by the DEQ is short; it ends on August 6,
2004. So get informed, attend the meetings, and send in your comments.
Here are some concerns SRSW has regarding the DEQ and Pall E unit cleanup
plans:
- not enough definition of or remediation of the E plume/pathway from the
core to Maple Rd.
- for more remediation along pathway, consider Michigan Inn property,
whose owner was ready to cooperate soon after MW was installed at that
location.
- too much concentration on pumping at leading edge without adequate
understanding and substantial pumping from the pathway will create another
Evergreen-like failure. (Still not sure if some of E is really escape
from Evergreen!)
- before approving any plans, DEQ needs independent consultancy to review
plans in conjunction with early involvement of local govt and citizens
resource people.
- The cleanup plan has no delineation of contingencies for cleanup changes
if current assumptions prove erroneous.
- Assumptions about how much water must be pumped/treated.discharge are
shaky so don't know how big the pipe should be for the pipeline to the
river... could end up with another undersized solution like happened at
Evergreen.
- Need ongoing, low MDL byproduct sampling of treated discharges. Also,
need bio-sampling at and downstream from discharge point.
- Need more professionally acceptable data gathering and analyses to
sufficiently define the reality of the plumes before settling on a
solution based on assumptions that are faulty and ending up with another
failed cleanup attempt. (Remember that DNR/DEQ allowed Pall/Gelman to not
sample the only E unit well east of Wagner Road for about 7 years. Even
now, recent Pall well borings have lacked basic well log data and had
omissions in vertical sampling. Some areas of very high concentrations
remain unsampled after initial borings. C3/D2 modeling data remains
hidden from the public. E unit modeling is not yet done. Effects of
pumping changes are not being considered in Pall flow projections.
Stochastic modeling is not being done. Pall has removed more dioxane from
the C3/D2 units that was believed to be down there, yet some areas still
see increasing or high levels of dioxane, including a recent discovery of
43,000 ppb in an area depicted on recent Pall maps as being under 5000
ppb.)
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