Dept. of Health & 3M’s PFC/PFOA contamination
August 23rd, 2016
3M has gotten away with poisoning the water of Minnesota, and the Dept. of Health has taken some protective and/or remedial measures, but it’s not nearly enough. Isn’t it a wake-up call that we need a “Drinking Water Health Advisory” in this Land of 10,000 Lakes? Minnesota’s “Pollution Control Agency” has not been proactive on this, and we’ve known about 3M’s contamination for how long? This is why we need the EPA! The EPA is leading the charge, and Minnesota’s Department of Health (MDH), as above, has “responded” to the EPA Advisories.
80 Washington County homes will get bottled water as state reviews new pollution rules
In part:
The Dept. of Health page:
MDH Response to EPA Health Advisory for PFOS and PFOA
From the EPA’s page:
Basic Information
- Fact Sheet on PFOA and PFOS Drinking Water Health Advisories (May 2016)
- BLOG: Science Guides Public Health Protection for Drinking Water by Joel Beauvais
Technical Information
- FR Notice on the Health Advisories for PFOA and PFOS (May 25, 2016)
- 2016 PFOA Health Advisory
- 2016 PFOA Health Effects Support Document
- 2016 PFOS Health Advisory
- 2016 PFOS Health Effects Support Document
- 2016 EPA Response to Peer Review Comments
Provisional Health Advisories and Draft Health Effects Documents
Technical documents
- 2009 Provisional Health Advisory
- 2014 Draft Health Effects Document for Perfluorooctanoic Acid (PFOA)
- 2014 Draft Health Effects Document for Perfluorooctane Sulfonate (PFOS)
- Peer Reviewer Summary Report: External Peer Review of EPA’s Draft Health Effects Documents for Perfluorooctanoic Acid (PFOA) and Perfluorooctane Sulfonate (PFOS)
Peer Review
Metachem meeting in Delaware City Tuesday
July 30th, 2009
Alan Muller, Green Delaware, questioning and commenting at the meeting
Tuesday night, there was a meeting in Delaware City regarding the “Standard Chlorine of Delaware, a/k/a Metachem Superfund Site.” This meeting was to gather comments on the “OU3 Proposed Plan.”
Here’s a link to the News Journal article about it — and the full story is below:
EPA: Metachem toxins will linger
Comments must be sent in by August 14, 2009, postmarked if mailed by that date, to:
thornton.hilary@epa.gov Hilary Thornton, Mailcode 3HS23 US EPA, Region 3 1650 Arch Street Philadelphia, PA 19103
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Here are my comments, sent just now:
Now, take a few minutes and work on yours!
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The way they handle these proceedings, it’s misleading and diversionary, a false, technical compartmentalization of the problem and solutions, which leads to a preordained, incomplete, and probably ineffective “clean-up.” Part of the problem is that it’s not clear that cleaning up is a priority. My impression is that they’re just interested in “dealing with it” in some way, the CHEAPEST way, checking off the “OU3 box” and moving on.
Their plan, their PREFERRED plan, is to cover it up and move on to “OU4.” Their “Preferred Plan” is, direct from their powerpoint slide 8:
2A. Surface Cap/Institutional Controls Impermeable Surface CapInstitutional Controls
- Cap materials TBD during Remedial Design Phase
- Cap materials and thickness would vary depending on future land use
Five-Year Reviews
- Future land use must not interfere with ongoing remedies
Est. $11.5 – 18.5 Million
- Required for any Superfund Site where contaminants remain
Why look! Imagine that! This is the CHEAPEST of the options. All options are “cap” crap, with “materials TBD” and, based on prior past bad experience with DNREC’s “hare-brained” ideas (yes, that’s a direct quote)for “beneficial use” and using coal ash and sewage sludge to cap the dump next to the river:
- I asked whether they’d use coal ash in the “TBD” cover material, and they would NOT commit to rejecting coal ash.
- I asked whether they’d use sewage sludge in the “TBD” cover material, and they would NOT commit to rejecting sewage sludge.
This is where that compartmentalization becomes a problem. They said that was not an issue for “OU3” and that it would be addressed in the “design phase.” Uh-huh, and the public is involved in that exactly HOW? And hello — WHAT the impermeable surface is has much to do with the appropriateness of using an impermeable cover. Rainfall on the impermeable cover will trickle off the cover over the edge, onto and into the ground, groundwater, etc. Even if it’s asphalt, that should be considered. Isn’t the EPA is in the process of addressing coal ash, and a rule pending?
Cost… Their “preferred” option 2A costs $11.5-18 million. The others?
The other options, from their powerpoint:
2B Surface Cap/ICs, with Soil Vapor Extraction Same surface cap and ICs as mentioned in 2A, plus an in Situ SVE system:2B Surface Cap/ICs, with ISTD Same surface cap and ICs as mentioned in 2A, plus in Sit thermal Desorption:
- Est. 200-500 air extraction wells at 50′ depth
- Treat contaminated air from beneath the cap
- treat off-gas from SVE system before discharge
- Additional sampling to identify “hot spots”
- Pilot study first, to test effectiveness
- Est. $19.1-20.2 Million
- Est. 2,800 heater and 1,400 heated vapor extraction wells, 8-12′ apart through 330,000 sq. ft. area
- Additional sampling to identify “hot spots” within 10′ of barrier wall
- Pilot study first, to test effectiveness
- Est. $92.8-99.8 Million
Let’s see… $11.5-18.5 v. $19.1-20-2 & $92.8-99.8. Doesnt’ take a rocket scientist to see that the cheapest “option” is “preferred,” and since when is cost the primary driver? Is this an indication of how they value those living here, drinking the water, breathing the air?
Oh, and did I mention they admitted, finally, that the contamination goes down at least 140 feet! That’s something they haven’t wanted to talk about before.
These options are the only ones looked at, the only ones that are under consideration.
CONSIDER THIS: One other option I want them to consider is to dig up part of the site, the cleaner part, and put a liner down there and take the contaminated dirt from the rest of the site and bury it there with the solid multi-layer liner, and then cover it.
Here’s an example of that in Minnesota, showing that it can and should be done. This is a scenario where it’s been sitting there since before the mid 70s, it has contaminated ground water in Lake Elmo and Oakdale, Minnesota. They’re using three layers of liner over packed clay and another three layers of plastic, plus sand with a collection and draingae system. In the Metachem case, they know groundwater is contaminated, that it’s seeping down, so what, short of this, will stop it? Take a look — Tom Meersman did a very good job on this:
History-making landfill do-over in Washington County