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E-M:/ Dredging of Conner Creek in Detroit, MI
- Subject: E-M:/ Dredging of Conner Creek in Detroit, MI
- From: GreenPlanet <riccawu@MNSi.Net>
- Date: Tue, 25 Apr 2000 12:55:38 -0400
- List-Name: Enviro-Mich
- Reply-To: GreenPlanet <riccawu@MNSi.Net>
Enviro-Mich message from GreenPlanet
The Citizens Environment Alliance posted some concerns about the storage
of contaminated sediments in a Confined Disposal Facility (CDF) in Lake
Erie to the Great Lakes Information Network, Enviro-Mich and other news
groups in an effort to heighten public awareness of this unacceptable
non-solution to the problem.
There has been some feedback. I have included it below. Any
plan to store contaminated sediments in a CDF must be accompanied by a
strict timeline for its eventual removal, treatment and proper
disposal. I urge you to convey this message to the parties listed
below. Thank you,
Citizens Environment Alliance
The Citizens Environment Alliance has learned that the dredged sediment
from Conner Creek in Detroit may be stored at the Confined Disposal
Facility [CDF] at Pointe Mouillee. The final decision on this seems to
rest with the US Amry Corps in Washington, D.C..
The disposal of this contaminated sediment at the CDF at Pointe Mouillee
is unacceptable. Pointe Mouillee was designed to store non-contaminated
navigational dredging and like all CDFs, Pointe Mouillee leaks.
This will speed up the contaminants journey to lake Erie, hardly a
remediation of the problem.
We're asking everyone to call or write Congressman John Dingell Room 2328
Rayburn House Office Bldg., Washington, D.C., 20515, United States of
America. His phone in the Detroit area is (313) 846-1276. His
email address is
If your representative is John Conyers you can reach him at Congressman
John Conyers, Room 2426 Rayburn House Office Bldg., Washington, D.C.,
20515,United States of America. His phone number in the Detroit
area is (313) 961-5670. His email address is
If you email either Congressmen send a copy to Russell Kreis at the USEPA
We must insist that the sediments truly be removed from our
ecosystem. I've attached a sample letter below. It has also
been suggested that these letters be copied to Commander Colonel Robert
Davis at the US Army Corps of Engineers in Detroit, Michigan. The
mailing address is P.O. Box 1027 Detroit, Michigan, 48231-1027, United
States of America. Phone (313) 226-6762 or (313) 226-4680. You can
email him at
The Corps website is
On the Canadian side you
should write to Windsor MP and Deputy Prime Minister Herb Gray. His
postage-free address in Canada is Deputy Prime Minister Herb Gray, House
of Commons, Ottawa, Ontario, Canada. His Windsor phone number is
(519) 257-6817. Or email him at
Send copies of your emails to John Marsden at Environment Canada
Implore them to communicate with their counterparts in the US regarding
this important bi-national environmental issue.
Citizens Environment Alliance
Congressman John Dingell
Room 2328 Rayburn House Office Bldg.
Washington, D.C., 20515
United States of America
The clean up of Conner Creek in Detroit may come at the expense of Lake
Erie. Distressingly, the US Army Corps of Engineers in Detroit has
signaled its willingness to allow the environmental dredging of Conner
Creek be stored at the Confined Disposal Facility [CDF] at Pointe
Mouillee. The final decision, however, seems to rest with the US Army
Corps in Washington, D.C.. Please communicate to the Army Corps in
Washington and the USEPA that the disposal of this contaminated sediment
at the CDF at Pointe Mouillee is unacceptable.
The issues of environmental dredging and disposal of contaminated
sediments need to be viewed on a river-scale basis, not on an individual
site basis. While the immediate concern is being focused on two sites on
the Detroit River that need environmental dredging (Black Lagoon and
Conner Creek) , in reality there are at least 12 sites that have been
identified through the Remedial Action Planning documents as being highly
contaminated and require removal for restoring aquatic health.
Further, utilizing the CDF at Pointe Mouillee for these highly
contaminated sediments is not an ecologically sound solution. This CDF,
like every CDF that has ever been built, leaks. Placing highly
contaminated sediments in the Pointe Mouillee CDF will only fast track
these persistent toxic substances to Lake Erie. The Grassy Island CDF off
the shore of Wyandotte is a case in point of how 'well' CDFs work.
There are reasonable and long term solutions to deal with all of the
highly contaminated sediments in the Lower Rouge and Detroit River.
The construction of a treatment facility (thermal desorption or inert
construction blocks) on one of the many brownfield sites that currently
exists on the Detroit River is one possible solution.
Specifically, the National Steel Corp. - Great Lakes Steel Division owns
seven miles of property along the Detroit River. Much of this property is
brownfield, with no activity on it. Great Lakes Steel has enjoyed 60
years of discharging persistent toxic pollutants into the Detroit River;
it is time they become part of the solution to cleaning this river
up. Their contribution to this effort would be providing the
necessary land to construct the treatment facility for the Detroit River
and Lower Rouge River contaminated sediments.
Placing contaminated sediments from one or two sites into a CDF is a
short-sighted, unsustainable solution. It is merely transferring the
contamination from one place to another. The EPA has spent millions of
dollars in identifying, researching and evaluating various methodologies
for treating contaminated sediments, yet when real situations arise to
address these contaminated sediments, placing this material in landfills
or CDFs (the most antiquated 'technology' of all) becomes the preferred
method; that decision is simply based on short-term cost.
If a treatment facility or facilities were constructed with the intent of
treating ALL the contaminated sediment areas in the river, then the cost,
although admittedly high, would be much more effective in the long
run. The effect would be the permanent removal of the contaminants
from the ecosystem; a REAL clean up for the Lower Rouge, Detroit River
and Lake Erie.
Thank you for your consideration of this important matter.
April 21, 2000
Sir (to the Citizens Environment Alliance)
I wish to clarify some misstatements you made in regard to the confined
disposal facility (CDF) at Pointe Mouillee. This facility was
constructed, as were all Great Lakes CDFs for the disposal of
contaminated sediments dredged from Great Lakes harbors and channels.
Your assertion that the CDF was constructed for clean sediments is not
consistent with the facts, nor the Federal legislation that authorized
these CDFs. The statement that all CDFs leak is not correct and
misleading. CDFs that were constructed in-water were built with permeable
dikes that were intended to keep the sediment particles and attached
contaminants contained while allowing for drainage of water. This
facility has been operated and monitored in compliance with Federal and
State environmental laws and regulations. If you wish to read more about
Great Lakes CDFs, there is a short paper available online at
Your statement recommends
that the sediments be removed from the ecosystem. I presume you are
suggesting that the sediment contaminants could be treated and destroyed
completely. Recommend you visit the USEPA's Assessment & Remediation
of Contaminated Sediments (ARCS) web site which has a significant body of
information on the technologies available for treating contaminated
sediments, their costs and impacts:
In order to treat contaminated sediments, you first need to dredge them,
and place them into a CDF or comparable site where they might be
processed. The ARCS Program reviewed available treatment technologies and
concluded that while many were technically feasible, none were capable of
addressing the variety of sediment contaminants present in most Great
Lakes areas of concern, none were available at full scale, and all had
significant costs both financially and in terms of short-term
Your recommendation that the contaminated sediments not be placed into a
CDF because you prefer an unidentified process that will make the
contaminants "disappear" is the same as advocating no action. I
do not mean to suggest that confined disposal is a perfect solution, but
believe it is not unreasonable to implement 100% of an imperfect
solution, when the alternative is 0% percent of a perfect one.
Great Lakes & Ohio River Division
U.S. Army Corps of Engineers
111 North Canal Street
Chicago, Illinois 60606-7205
(312) 353-3138 (fax)
April 21, 2000
I concur with many of your comments, though I know where these citizens
are coming from. MDEQ identified sediment treatment technologies
applicable to Conners Creek and provided the information to the City of
Detroit. It is the City's determination in the dredging application as to
the method of disposal. They are choosing not to treat it.
The City of Detroit is building a full-scale vitrification treatment
facility on the shore of the Detroit River, via Minergy Process. This is
to be used for sludge from the WWTP, and not available for sediment use,
so the City has told us.
The citizens are aware of the USGS report on the Grassy Island CDF in the
Detroit River and its problems. The USGS recommended decommissioning the
now Wildlife Refuge and removing its contamination, about 3 million cubic
yards worth. Grassy Island is in the citizens front yard. Thus their
contention that CDFs are not safe is born from this experience.
A CDF is very much a leaky landfill, on water. We have
"impermeable" landfills all over the Detroit area that have
been found to leak. We have one right on the Detroit River, BASF
Riverview. While I have tried to inform the citizens that using the Point
Mouillee CDF for Conners Creek sediments is better than leaving it in
place, I dont think dredge spoils in Point Mouillees Cell #5 are
"safe" by any means. It will likely be the next generations
"superfund" site. At least we got it all in one place verses
scattering the dredged contaminants over the western basin of Lake Erie
(open water disposal) like are our predecessors did (they didnt know any
better ; ) .
SWQD and USEPA-GLNPO have reviewed and identified applicable, cost
effective (at the full-scale) and marketable sediment treatment
alternatives for Detroit River sediments. We have given 4 public
presentations on our research to date in the past year. We plan to embark
on a demonstration of the IGT-Cement Lock Technology and/or Minergy
Technology in the Detroit River either later this year or next. The Corp
is holding us up by not issuing the dredging permit. We applied in May of
1999 and have our state permit in hand.
We had planned to remediate Black Lagoon Sediments with a portion of the
material going for the demonstration, and the remainder going to the CDF.
We have the treatment vendor ready, but the Corp will not allow any of
the material to Point Mouillee without the State agreeing to modify the
1974 Point Mouillee Agreement and giving all Federal Agencies full
indemnification for the entire CDF. We want to put in 30,000 cy from
Black Lagoon. The CDFs capacity is 15,000,000 cy. The contamination
levels in Black Lagoon are equal to the levels put in from the Lower
Rouge River Navigational Dredging. Conners Creek levels are higher than
Rouge River for certain contaminants (PCB, Lead, and As I believe).
The citizens did not initially object to Black Lagoon CDF disposal. The
reason is cause while the majority of the sediment would go to the CDF,
we would be moving towards resolving the long term disposal issue with a
Your right that no treatment facility currently exists locally for
Conners Creek. Maybe the City of Detroit should at least help move
towards that goal with the Conners Creek Project.
Citizens Environment Alliance
consultant Dr. Dave Dolan had this to say about the storage of
contaminated sediments at the Point Mouillee Confined Disposal Facility
The storage of highly contaminated sediments in any CDF is a
short-sighted non-solution to the remediation process. Any plan to
store environmentally dredged sediment assumes the contaminants stay
attached to the sediment particles permanently. Also, the more
contaminated the material, the greater the gradient for mass transfer.
This is the second law of thermodynamics: the entropy of a system always
increases. Over time, the CDF will equilibrate with its surroundings. It
may take a hundred years, unless we have a big storm that damages the
CDF, but rest assured it will happen. The proposed storage at Pointe
Mouillee also ignores the impact of plant and animal life in the CDF
which will tend to bring contaminants to the surface and disperse
them. Lastly, if highly contaminated sediments are stored at the
Pointe Mouillee CDF, where will sediments from navigational dredging be
stored? With lake levels as low as they are now, this should be a
concern for everyone.
GreenPlanet Social Justice & Ecology Network
P.O. Box 548
Windsor, ON N9A 6M6
Ph. 519-973-8352 fax 519-973-8360
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