I have reviewed the subject report, which I received complete except for Figure 7, an oversized sheet. In summary, I think J&L was given a pretty impossible job to do, based on what is reported. It is my understanding that the Planning Commission indicated that a conditional use permit for the station could be issued provided there was a natural clay barrier beneath the site. No mention is made of how thick this clay layer must be nor how extensive in horizontal extent. Nor did the Township indicate what performance criteria they expected this clay layer to meet. Without this kind of information, I cannot begin to see how J&L could determine if a Bentonite GCL is a proper substitute.
Having said that, I will skip to J&L's conclusions. I agree with conclusions "a", "c", "d", and "f" through "h". I do not agree with J&L's conclusions in "b" and "e". In "b" he states that a bentonite clay liner may substitute for a natural clay liner. In my opinion, the conditions and criteria for making that statement have not been demonstrated or evaluated in any scientific manner. In "e" he states that if the station is constructed with a state-of-the-art containment and monitoring system as recommended by US EPA, then a thin (less than one inch) bentonite liner alone should suffice. Again, the conditions and criteria for making that statement have not been demonstrated or evaluated in any scientific manner. Nor does J&L present qualifications that would support the author's expertise to make such a statement without a scientific demonstration or evaluation.
I also find that conclusion "h" is somewhat in conflict with conclusion "i". In "h" J&L is asking for much greater information concerning ground water movement including estimating the travel time of pollutants from the station to a down-gradient home if a release occurred. But then in "i" J&L indicates that the station's water supply well will clearly disrupt the direction and rate of travel through the creation of a cone of depression. Of what value then are the calculations that J&L wants reported?
The last conclusion, "j", is a cogent comment. It indicates that this site is naturally in a ground water recharge area. Knowing that, I would think that it is difficult for the Township to justify locating a gasoline station, or any business using hazardous materials at this site, unless all recharge is completely cutoff for the life of the use, a requirement that is difficult if not impossible to meet. In other words, we are talking about permitting uses in recharge areas only if hazardous materials are absent. That is the only action that the Township can take that is truly responsible.
I hope these comments are of help to you.
Sincerely,
George Kunkle
B.S. Geology, Iowa State University, Ames, Iowa
M.S. Geology, The University of Michigan, Ann Arbor, Michigan
Ph.D. Geology, The University of Michigan, Ann Arbor, Michigan
Various publications between 1961 and 1983 in periodicals such as the Journal of Geology, Journal of Geophysical Research, Ground Water, and Journal Water Pollution Control Federation. Also published in U. S. Geological Survey Professional Paper and Water Supply Paper series. Author of many consulting reports.
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