Ye old unlined landfill off Old Farm Road. Amherst Woods top center
Assistant Town Manager Dave Ziomek (far right) attended Water Supply Protection Committee meeting yesterday
The Amherst Water Supply Protection Committee voted 3-1 yesterday to recommend the town do one extra sampling analysis at Well 4-08, located in a sensitive area for our drinking supply (Zone 2) where a high level of Dioxane was detected in one lone sampling back in July, 2012.
As per DEP regulations the town tests annually at 15 sites for contamination from two closed landfills off Belchertown Road (lined landfill) and Old Farm Road (unlined).
After the alarming test results taken in July, 2012 the town quickly did a resampling in August using a better testing method which turned up nothing. Zero. Zip.
And for the past three years annual testing has turned up nothing. Zero. Zip.
Dissenting member John Tobiason, who is also a Board of Health member, was sure the unusually high readings on that one test date were simply due to error, or a false positive. Especially since that lone sample date is so far outside the norm for all the other sampling ever done.
About a half dozen neighbors showed up for the meeting and were adamant the town test four times per year to account for "seasonal variations."
But the Committee pointed out the retest using a better testing method was done in August of 2012 only a month after the alarming sample was taken, and August is in the same "season" as July.
Of course these are the same Amherst Woods neighbors who filed a lawsuit against the town to prevent a solar array from going on ye old landfill.
After the appeased neighbors filed out of the meeting, just before adjournment, the Water Supply Protection Committee confirmed, "We're not concerned."
The southern end of Gull Pond has tested positive for contamination, but it's not like anybody would drink that water (or swim in it)
71 comments:
If Gull Pond is contaminated, why isn't it being cleaned up?
Because those affluent taxpayers are hated NIMBYs who deserve to get hammered!
If you check the location of the wells listed in the above table, the dioxane contamination is detected not only at the Gull pond, but also at the KC Trail and at Hoop Brook wetlands on both sides of the railroad. There was no disagreement about that at the committee meeting.
The above picture shows only a half of the table. It does not show the second half that includes a 2-12 well that was installed at the DEP request to investigate potential buried drums. This well showed high levels of dioxane, but the was never tested again after 2012. Wondering why?
The 2012 measurements that showed higher concentrations were taken at the beginning of July, while in the rest of the years it was done in the late autumn, when the water level is low. At the meeting, the committee members suggested it was done earlier in 2012 because one member of the team was pregnant, and there is no need in trying to test it in the spring or early summer, as suggested by experts. Really?
Also, it's not zero or zip. The 0.2 mcg/L detection limit shown in the table is 66% of the maximum allowed concentration of 0.3 mcg/L. The actual dioxane level, while less then 0.2 mcg/L, is not "zip", but rather unknown. It may very well be 50% of the maximum allowed level in the autumn, at the time when the level is lowest. This is yet another reason why it is important to perform periodic quarterly sampling suggested by reputable environmental experts - especially when it concerns the bedrock well 4-08 at the Station Road, deep inside the DEP Aquifer Protection Area.
And finally, wells 5-08 and 4-08 are the only deep bedrock wells, one near to the landfill and one at the Station Road, in the Zone II aquifer protection area. This is why the potential bedrock connectivity between them is so important to investigate. Even the committee members agreed that it is impossible to make any any judgment about connectivity and flow distribution based on just two bedrock wells, which is the reason additional bedrock monitoring wells are called for by the experts.
It is better be safe when we are talking about the aquifer we use for drinking water!
Actually, affluent taxpayers will have no problem paying for the bottled water, so it is the rest of the Town folks who will get hammered. Be careful what you wish for!
A complete report on the conditions of the Old Landfill is available at www.area-group.org
That you paid for.
As an Amherst Woods resident, and not part of this group, I'm worried that contamination from the old landfill could have very dangerous consequences. The town needs to take aggressive steps to reline and cap the landfill (regardless of whether solar farm is built or not), rather than stalling until this problem has caused a cancer hotspot.
The town is not going to relive and recap the landfill.
But if you look closely at the aerial photo I took yesterday you can see the leftover large pile of dirt from the recent regrading done by DPW.
"Reline"
Aw, go ahead Amherst. Drink up!
Amherst woods, the best place for cancer in town.
What are the laws on landfills? It seems that the town should keep it fit and safe.
They are abiding by state law.
The law was for 12" of clay in 1986 and for 18" now. The Town managed to get a DEP approval for 6" of clay cap to save $56,000 30 years ago, under the condition that the clay cap maintains low hydraulic conductivity required by the landfill closure plan.
However, according to the 2006 Interim Comprehensive Site Assessment, the cap is 150 times more permeable than specified in the landfill closure plan, and is 1500 times more permeable then required by today's standards.
It's not about the law, but about its enforcement, which is not easy to force, as municipalities are exempt and may be allowed by DEP to pollute.
Why spending some money now to investigate and prevent when we can wait for it to repeat on a large scale, and then ask the state for millions to fix it?
Insensitive statement 1029.
Why spending some money now to investigate and prevent, if we can wait for it to repeat on a large scale, and then request a few millions from the state to fix it?
Not really, I meant it!
Two groups of scientists look at the very same data, one says there's no such thing as global warming, so we don't need to look for evidence or do anything. The other group says global warming is happening and we need to do something now. In Amherst, one group says there is a known carcinogen moving west in our groundwater, but it isn't moving south toward the water supply for half of Amherst because it's not expected to disperse in that direction. This group presents data in such a way to support that assertion, though they concede it would really require more bedrock wells to track the actual flow. Still, they conclude, we don't need to do anything. The other group says, since the drinking water for 50% of Amherst residents is at stake, and since the carcinogen was detected in the protected area south of the landfill when measured at a different time of the year, we need to add more bedrock monitoring wells in the protected area and test them seasonally to understand how to keep the water supply safe. It all comes down to which perspective you prefer...the one that suggests it's better not to look, so we can all stay comfortably asleep or the one that says it's time to stop hitting the snooze button and wake up to find out what’s actually there.
Feel free to hire a company to dig a test well or two.
I pay over $12,000 a year in property taxes. Odd that CPA funds can go to all kinds of frivolous things, but preventing cancer should be optional.
Wow. Must be a nice house.
I'm not the only one in Amherst Woods that pays that much.
In response to the cold, insensitive comment about cancer risk, the writer misses the point that leachate in the form of a carcinogenic contaminant from the Old Landfill is dispersing west to all those down-gradiant areas of Amherst, not staying put in the neighborhood where the landfill is located. The latest environmental report from Roux Associates states that carcinogen is also detected in the Zone II Protection Area to the south of the landfill, heading toward the Lawrence Swamp Aquifer, which supplies drinking water to 50% of Amherst residents. To spell things out clearly, this means the issue of water contamination is not a neighborhood issue. The risk for cancer from contaminated water is the same for anyone who gets their water from the south end of town, that is...half of Amherst.
Wow, Larry, you're one of the few people who can make "nice home" seem like it's something to be ashamed of. Our neighbors are doctors, teachers and business owners who live in "nice houses" and pay high property taxes that benefit the Town coffers. Truth is, the Town wouldn't be quite so nice without them.
Larry, it's always been easy for you and posters to your blog to dismiss Amherst Woods homeowners concerned about the Old Landfill cap as NIMBYs. But the truth is, we're canaries in the coal mine sounding an alarm that a serious problem exists with the Old Landfill cap due to some short-sighted folks in charge of things 30 years ago. While the source of that problematic legacy is located in our backyard, the contamination leaking from the Old Landfill is a problem for half of Amherst's residents, (likely including you as well) as the carcinogenic contaminant finds its way to the Lawrence Swamp aquifer. So how about letting go of the class warfare you've been waging by using the term "affluent" like it's an insult, and step up and help get the real story out there? The state agency that was supposed to protect all of us by protecting the environment, instead, 30 years ago gave the Town a pass to save a few bucks by watering down their own safety standards. All of Amherst is living with the consequences of that poor decision. Ignoring or denying the problem exists, will only will make the problem more costly to fix. One way to fix the problem is to remediate the clay cap now by installing a waterproof membrane on top of the Old Landfill to drastically reduce the leaching toxins. In the long run, the cost of not doing this will be much higher for everyone.
Don't worry, my water comes from the north end. We never needed Amherst Woods anyway.
It would be better with solar panels.
I know a good moving company. How bright can you be buying a house next door to an old dump???
Amherst has a responsibility to protect its citizens. They are taxpayers, but even more important, they are human beings.
No, but it would make sense to install a waterproof membrane over the top of the Old Landfill as an alternative to building up the clay layer in order to meet today's safety standards. The problem with the inadequate cap on the Old Landfill is that rain/snow passes through the current cap like a sieve allowing the toxins buried deep underground to be carried far and wide. Nothing will stop or at least slow the spread of those buried toxins until the cap is fixed. A waterproof membrane is expensive, but nothing compared to the costs of contaminating half the Town's water supply.
Some of the posters on this blog appear to be appalling human beings. I'm sure the Town doesn't really "need" them either, so perhaps they should move. Larry, are you secretly writing these hostile posts to drum up drama on your blog? No one in Amherst is really this vile...are they?
I agree with the taxpayer part.
I wish I had the time to write all the idiot comments but, alas, no.
My main computer died two weeks ago and I'm trying to run the blog with pretty much an iPhone.
As if my digital life was not challenging enough as it is.
Many people writing comments don't live in Amherst.
Amherst better start a more aggressive testing regimen, and look at realistic remediation steps, before we all end up with a Superfund clean-up site. You can laugh at this all you want, but I wouldn't wish cancer on anyone's children.
Four scientists with no ax to grind looked at this and found no danger to the general public.
The sky is falling, the sky is falling. C'mon let's keep this in perspective.
No ax to grind? Larry, are you sure about that? It's a well-meaning group I'm sure, but maybe it's time to dig a little deeper. What do 3 of the 4 scientists have in common that might create a bias? Hint: If you live near a risky environmental site (whether it's a nuclear power plant or a landfill) and you are informed there's a problem, there are two basic ways to respond: 1) you become an advocate to have the problem fixed, or 2) you stay in denial that there's any problem at all. There's also the possibility of professional pride about not wanting to be wrong and/or your boss wants to benefit financially from a project proposed on the site. Voila, the basis for an ax to grind. As for the other group, a reputable environmental firm whose job it is to evaluate brownfield sites for development, who have no investment in this particular site and who get paid regardless of their report findings, they have no reason to have an ax to grind.
Years ago Town's scientists with no ax to grind looked at the proposed 6" clay cap and found no danger to the general public. Another group of scientists with no ax to grind looked into the current DEP data and reported danger to the environment and human health due to the insufficient cap thickness. History repeats itself...
I had my closest friend who lived in AmWoods die of cancer. Gave him 6 months. Prognosis was exact. You'll pardon me if I still think you're insensitive.
How so? What do u like so much about those hideous things?
I'd live in Amherst Woods any day if I could afford it.
Here is an example where dioxane tests were fine in 2013 too:
http://www.northjersey.com/news/new-danger-found-at-ringwood-superfund-site-1.1516132
It is in the news now. Hopefully, the scale is not comparable to the Old Landfill, but the symptoms are similar.
"the symptoms are similar"
Maybe you could help educate me about some of the basic facts? From the article you cited:
"The concentrations that were found ranged from 20 micrograms per liter to an estimated 38 micrograms per liter."
Has a concentration exceeding 20 micrograms per liter ever appeared in any test result in Amherst? What is the highest test result that has ever appeared in Amherst? Can you indicate the date and location of that test?
I notice above someone said this:
"The above picture shows only a half of the table."
Can you advise where I can find the data that is missing from the above picture? Is there a complete table in any of the Roux Associates reports? Is there a complete table anywhere on the area-group.org site? Is there a complete table on the town site?
Maybe you could post the other half of the table here in this thread?
Thanks in advance.
You'll pardon me but that doctor is real good!
Who was the Town Scientist 30 years ago?
One more thing. You said this (8:12 am):
"Here is an example where dioxane tests were fine in 2013 too"
That claim is incorrect. From your article:
"Prior to last year, EPA officials had not been looking for 1,4-dioxane in groundwater samples of contaminants collected at the site"
There was no dioxane testing at this site (Ringwood NJ) prior to August 2015. There were never any prior "dioxane tests [that] were fine." There was no history of prior dioxane testing that failed to find dioxane. There was simply no history of prior dioxane testing, period. The first attempt to find dioxane, in August 2015, succeeding in finding dioxane.
This is an important point that should not be distorted.
By all means, let's go with the rubber cap. I suggest bright orange and yellow striped rubber with huge red "biohazard" symbols placed every 20 meters. And surround it with kleiglights, razor wire, and dobermans to protect our children. . .
Well 2-12 showed concentrations of 50 mcg/L. Few other wells also showed from 10 to 16 mcg/L. That was in the second part of the table, only the first half is shown above. The table was distributed on paper at the meeting. The Roux report posted online at www.area-group.com is also based on these numbers that came from the DEP materials available at the DEP office, you are welcome to verify.
They did test four samples at the water treatment plant for dioxane in 2013 with negative results, and the site itself was routinely monitored for decades. Now they drill more wells to study the flow of dioxane towards the sources of drinking water.
Great idea - and let's place an aerial photo on the Amherst's web site!
"Well 2-12 showed concentrations of 50 mcg/L. Few other wells also showed from 10 to 16 mcg/L."
Thank you for answering part of my question, but I am looking for a complete table, with all observations from all wells, which you seem to either not have or are not willing to share.
"The Roux report posted online at www.area-group.com is also based on these numbers"
I am familiar with the Roux report, and I realize it is "based on these numbers," but the Roux report does not present a complete table of these numbers. It simply makes various claims, but those claims are impossible to verify without seeing a complete table of numbers.
"that came from the DEP materials available at the DEP office"
You seem to be saying that if I want to see a complete table, I need to find it at "the DEP office." I am surprised that the Roux report and the area-group site both make various claims about the underlying numbers, but do not make available a complete table of numbers so that their claims can be verified.
The table on three pages was distributed by the Town, and is a selected fraction of many thousands of pages of DEP reports. I expect the table to be on the Town's website when they post the minutes of the meeting, or you can ask them and they will provide it to you. I don't think any party would want to pay for scanning 1000's of pages of DEP reports to place them on the web site. Any volunteers?
You can also ask Larry who owns this blog to post the second half - LOL!
If the anonymous posters at 5:24pm or 8:24pm bothered to do any research on methods used to remediate landfill caps, they would know that using a waterproof membrane is a cost-effective method used to supplement inadequate landfill caps. A layer of soil is added on top of the membrane so sadly, their suggestion to use orange and yellow striped rubber with colorful symbols wouldn't be visible...though carcinogens and contaminated drinking water is really funny stuff. Crazy environmentalists actually believe it's important to have an impermeable clay layer on a closed landfill to keep rain/snow from penetrating the buried toxins to prevent them from leaching into the surrounding environment. The standard for landfill caps today is 36" of an impermeable layer, but Amherst's Old Landfill started out with only 6" of partial clay, which has deteriorated over the last 30 years. It's really great that there are extra special people here who think the situation with landfills is funny. They probably drive hummers and laugh at global warming too.
Larry, it's posts like this one that warrants consideration of removing the option of posting anonymously. It would be interesting to see if bullies who post these kinds of remarks on your blog would have the courage to let people know who they are. I'd post with my name if it was a level playing field.
"By all means, let's go with the rubber cap. I suggest bright orange and yellow striped rubber with huge red "biohazard" symbols placed every 20 meters. And surround it with kleiglights, razor wire, and dobermans to protect our children. . ."
Or at the very least, post it No Trespassing" and have the APD arrest anyone who does.
If the cap is that unstable and the stuff inside that dangerous, people shouldn't be walking on it.
That would be a great punishment to the neighbors for raising up their concerns, but unfortunately, it would not stop the leak.
Larry, the order in which replies are listed on your blog are not in line with where the "reply" button is chosen. Is this a temporary technology glitch while your computer is down? The post I was referring to that lead me to suggest that you discontinue anonymous posting was in response to someone posting about a friend dying from cancer and a response remarking on the doctor's skill at estimating how long the friend had to live. If it is the intent of your blog to provide a serious place for discussion on Town matters, I urge you to remove the option to post anonymously. As I stated previously, I'll post using my name if you make this a level playing field, so posters are held accountable for the despicable things they say here. So, how about it Larry? What do want your blog to be...a place for serious discussion of Town issues or an entertainment platform for anonymous cyber-bullies?
test
You passed.
[This is a response to anonymous, February 29, 2016 at 8:22 PM]
"They did test four samples at the water treatment plant for dioxane in 2013 with negative results, and the site itself was routinely monitored for decades."
You're talking about Ringwood NJ, and you're still not addressing the problem I pointed out. Instead, you're compounding the problem.
Earlier you said this: "Here is an example where dioxane tests were fine in 2013 too." In that statement you are suggesting that there is a place where dioxane tests in 2013 showed no dioxane, and now tests in that same place are suddenly showing dioxane. That claim is false. That's not what happened.
The "dioxane tests [that] were fine in 2013" were done at the Wanaque Reservoir. The 2015 tests revealing dioxane were done at the Ringwood Superfund site. The Ringwood Superfund site and the Wanaque Reservoir are near each other, but they are not the same place. No prior test had ever revealed dioxane at the Ringwood Superfund site because prior to 2015 no one had ever bothered to do that test there.
This distinction is important, because you are trying to claim that Amherst and Ringwood are "similar," even though they are not. In Amherst, there are indeed specific locations where a series of tests indicated an absence (or a very small amount) of dioxane, and then another test in that exact same location indicated a much larger amount of dioxane. This is a remarkable, mysterious occurence that requires explanation. Why is there suddenly dioxane in a place where we know that dioxane was not present previously?
If such a thing had happened in Ringwood, that would indeed be an ominous and relevant development, from our perspective here, because it would suggest that dioxane can travel rapidly from one place to another, appearing spontaneously in a new place for no apparent reason. And that's exactly what you were implying when you said "here is an example where dioxane tests were fine in 2013 too." Trouble is, Ringwood is not an example, based on the currently available data, of how dioxane can travel rapidly from one place to another. And neither is Amherst, because when dioxane mysteriously appeared in certain places here, it then disappeared, just as mysteriously. And that's why it's reasonable to conclude that those higher results here are erroneous.
And now I should point out again that you said this: "the site itself was routinely monitored for decades." This is another example of you making a statement that suggests, incorrectly, that Ringwood presents an example of a specific location where a series of tests indicated an absence of dioxane, and then another test in that same location suddenly indicated a large amount of dioxane. That did not happen in Ringwood. Yes, "the [Superfund] site itself was routinely monitored for decades," but only for substances other than dioxane. Your assertion about how a site was "routinely monitored for decades" has no relevance whatsoever in this discussion about dioxane, because that site was never "routinely monitored" for dioxane. I wish I knew your reason for presenting that assertion.
Dioxane did not suddenly appear at the Superfund site because previous dioxane tests at that location had failed to detect it, or because dioxane has suddenly and recently traveled there. Dioxane suddenly appeared at the Superfund site because someone decided, in 2015, to look for it there for the first time.
Which brings me to another question. Roux has plenty of experience with dioxane, right? Are they aware of any other situation where dioxane mysteriously and suddenly appeared and then disappeared, as it has apparently done in Amherst?
(PS: I posted previously as 'anonymous.')
I respect different perspectives and strong opinions. That's not what makes a bully. Some of the posts that say things like residents in a particular neighborhood deserve to "get hammered"; or a neighborhood is the best place for cancer; or, after I suggested the Old Landfill cap could be remediated using a waterproof membrane on top, suggest covering the top of the landfill will yellow and orange rubber, adding biohazard symbols and surrounding the site with razor-wire, etc. Those are bone-headed comments that aren't worthy of a serious blog. These cyber-bullies intentionally hit below the belt with mean-spirited comments designed only to be provocative and hide like cowards behind anonymity, which has nothing to do with being a "grown up". Quite the opposite. Maybe one day you'll be grown up enough to recognize the difference.
[This is a response to anonymous, March 1, 2016 at 10:40 PM]
"Some of the posts that … suggest covering the top of the landfill will yellow and orange rubber, adding biohazard symbols and surrounding the site with razor-wire, etc."
I didn't write that post, but I'm going to explain why I think that post was legitimate. My interpretation of that post is that it expressed, through mockery and satire, an important point that I have been expressing in a different way: you are exaggerating the risk. Here's an example of you exaggerating the risk: when you suggest that Amherst and Ringwood NJ are in some material way "similar." I have explained why they are not. And I think it's telling that you have not responded to my explanation, even though you are able to find time to repeatedly complain about the mockery.
Dioxane has not mysteriously disappeared: it continues to be consistently detected in the wells west of the landfill, so the dioxane is known to be leaching form the landfill. The dioxane spiked to levels similar to (or even twice higher then) at Ringwood when the test were done at a different time of the year, instead of the usual time in late autumn when the water level is low. When the spike occurred, it was detected in at least 7 wells, two of them being deep bedrock wells. One of the bedrock wells is 1 mile away from the landfill, which suggests bedrock connectivity which would punch a whole in the current assumption that contamination does not travel south towards the Lawrence Swamp aquifer.
Similar to Ringwood NJ, the tests before 2012 did not show dioxame because the used detection limit was too high. Unlike Ringwood NJ, the Town stopped monitoring the 2-12 well that showed the highest dioxane level of dioxane (50 mcg/L, twice more then at Ringwood NJ) after initial tests in 2012 (any reason why?). No periodic seasonal tests are done to investigate seasonality of levels of dioxane and other contaminants, and no additional bedrock wells are planned to investigate the contaminants flow in the bedrock.
Roux has plenty of experience with monitoring and remediating multiple brownfield sites, which is why they insist on additional investigation to make sure it is not a periodic event that affects the aquifer. Given that it concerns drinking water resources, it seems like wise approach, as opposed to discarding a multiple-well event as a sampling error.
Saving $56K on the landfill cap 30 years ago resulted in the landfill that contaminates wetlands west of it. It would be prudent to spend some money now to investigate the extent of the problem and make sure our water is safe.
"Similar to Ringwood NJ, the tests before 2012 did not show dioxame because the used detection limit was too high."
Was the used detection limit too high when well 4-08 was tested on 8/17/12, and the test result was at least 99% lower than the test result that was reported just 37 days prior?
"Roux has plenty of experience"
That's good. Then surely they can handle the following questions. Can Roux present any other example, from anywhere, of a dioxane level falling at least 99% during an interval that short? Has Roux attempted to explain what would cause a dioxane level in a given location to decline by over 99% during an interval that short?
"Dioxane has not mysteriously disappeared"
Really? If you have a certain quantity of a certain substance, and then more than 99% of it is mysteriously gone 37 days later, is there some other word that is more appropriate than "disappeared?"
A better question is why the presence of dioxane is so "mysterious" when wells down-gradient of the Old Landfill consistently show its presence. Another great question is why the landfill is leaching a witch brew of contaminants after the Town repeatedly stated throughout the years the landfill is in a great shape.
The data Roux used are not secret and are available at the following link: http:/www.area-group.org/DEP-1-7-15.pdf
What is so mysterious about seasonal fluctuations of the ground water level and the amount of rainfall?
"A better question is why the presence of dioxane is so 'mysterious' when wells down-gradient of the Old Landfill consistently show its presence."
The "presence" of dioxane can be either material or immaterial, depending on the amount. When you ignore the amount, "consistently show its presence" applies to such things as baby shampoo, tomatos, shrimp, coffee and chicken, because tests for dioxane "show its presence" in those items.
You are consistently glossing over the difference between amounts that are material and amounts that are immaterial. 14 Amherst wells were tested last year. For 11 of those 14, no dioxane was detected. For the other 3, these were the test results:
0.28
0.40
0.95
All those numbers are low. The MA standard of 0.30 is exceptionally strict, and a little perspective is helpful. Most states either have no standard or a standard much higher than that. For example, in CA the drinking water standard is 1, which means that our worst result from last year would be considered acceptable drinking water in CA, and in most other states. So it is not the case that "wells down-gradient of the Old Landfill consistently show its presence" in amounts that are material.
"The data Roux used are not secret and are available at the following link: http:/www.area-group.org/DEP-1-7-15.pdf"
I appreciate the link, but I still wish I knew why I cannot find any reference to that report in the Roux documents or on any public page on the area-group site.
"What is so mysterious about seasonal fluctuations of the ground water level and the amount of rainfall?"
I asked you to explain why a test done 8/17/12 (well 4-08) detected no dioxane, even though a test done 7/11/12 did detect dioxane, at a relatively high level. It should be noted that this well was also tested in 2008, 2010, 2011, 2013, 2014 and 2015, and all those tests detected no dioxane. The result of 7/11/12 is a pretty obvious error, but you're treating it as a correct result. When a test of that same well 37 days later detected no dioxane, you claim this is explained by "seasonal fluctuations of the ground water level and the amount of rainfall." Really? Those two dates (7/11 and 8/17) are definitely part of the same "season." I am able to find no evidence that significant "seasonal fluctuations" of any kind take place in the short period between those two dates. Are you able to show any such evidence? I doubt it.
And even if there were "seasonal fluctuations," your explanation still makes no sense. We are not measuring "ground water level and the amount of rainfall." We are measuring the ratio of dioxane to water. Let's say I have a bucket full of water, and I test it for dioxane, and I learn that the dioxane level is x. Then I pour half the bucket on the ground, and do the test again, using the water remaining in the bucket. Will the result be 2x? Will it be 0.5x? No, it will still be x, because reducing the amount of water does not change the ratio of dioxane to water, which is what we're measuring. So there is no reason to believe that alleged changes in "ground water level and the amount of rainfall" will cause dioxane to become completely undetectable 37 days after we were able to easily detect it.
I asked you if Roux could show any example, from anywhere in the world, where dioxane was found at a significant level (e.g., 15), and then a subsequent test just 37 days later at the same location was able to detect no dioxane at all. That's what happened here (and at more than one well). You did not address this question, which tends to create the impression that Roux cannot show any such example. And I think I know why: because extreme changes like this indicate a testing error, not a correct result.
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