Speculation:
Geothermal heat release continually raises the temperature of bottom water, creating more >39 degree water than can quickly rise away in the absence of any none-density circulating forces under the ice. The density difference, and hence gravity-based mixing/moving force generated, between 39 and 41 degree water cannot be very large.
I assume Dwight's constant ground temperature is above 41 degrees. IIRC it's 52 degrees here in Central Ohio.