Dear Administrator McCarthy:
This letter is regarding the contamination of groundwater in Ann Arbor, Michigan with 1,4-dioxane. The contamination is the result of irresponsible business practices by Gelman Sciences, now owned by Pall Life Sciences, which incorporated the chemical in its manufacturing of medical filters in Scio Township, Michigan. Between 1966 and 1986, wastewater containing 1,4-dioxane was sprayed on lawns and stored in unlined lagoons that has seeped through soil and rock layers into the groundwater and begun to spread in an ever-growing plume. It is my understanding that EPA has classified 1,4-dioxane as "likely to be carcinogenic in humans by all routes of exposure."
Recent developments have increased the level of concern in the community. First, the 1,4-dioxane plume has greatly expanded over the last 20 years, now encompassing an area over three square miles. It is troubling that the plume continues to grow even as remediation efforts are ongoing. Second, the number of monitoring wells that have had their highest reading ever has increased as well. Finally, 1,4-dioxane was recently detected in shallow groundwater on the west side of the city for the first time. This round of testing also detected chloroform and trichloroethane in groundwater. These developments are deeply troubling and raise questions about the adequacy of existing remediation efforts, which Pall Life Sciences is required to do by a court approved consent agreement.
Therefore, I respectfully request answers to the following questions:
1. Current remediation efforts are being conducted by Pall Life Sciences and overseen by the Michigan Department of Environmental Quality (MDEQ) pursuant to a consent decree. What role does EPA have in ensuring that MDEQ and Pall are living up to their obligations and meeting the terms of the consent decree?
2. Has EPA reviewed whether the remediation plan outlined in the consent decree is consistent with requirements of the Safe Drinking Water Act and the Clean Water Act?
3. Based on available information, does EPA assess that the current level of contamination is an immediate threat to human health?
4. Residents have long been concerned that the expansion of the plume could lead to greater health risks through a vapor intrusion pathway. Recent testing has now detected 1,4-dioxane in shallow groundwater near a neighborhood. Is EPA concerned that dioxane could be inhaled as vapor when it comes into contact with building foundations and basements?
5. Does EPA believe the presence of chloroform and tricholoroethane in the groundwater is related to the 1,4-dioxane plume or are they unrelated?
Thank you for your prompt attention to these questions.
Sincerely,