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E-M:/ Connection between seepage from lagoons and discharge to streams



I recently had the occasion to meet a retired U.S. Geological
Survey hydrologist, Marc Hult at a meeting of the Sierra Club
in Kentucky.   

While Mr. Hult was at USGS, he did extensive
work on the issue of regional coal tar contamination in the
metropolitan Twin Cities, with documented movement of
coal tar in groundwater systems up to 6-7 miles away
from the original source contamination upgradient from
the Mississippi River.

Mr. Hult was also involved in pioneering research showing
that certain chemicals, such as benzene, can be consumed
by bacterial action in underground systems.

In the exchange below, I raise the issue of common
agricultural practices in the Midwest in which liquid animal waste storage
lagoons are located directly adjacent to surface water streams and
wetlands that are otherwise indicated as "blue line streams".    I asked
him to look at three CAFO sites in Clinton County and one near Bad Axe, MI

Michigan DEQ water bureau district offices haven't generally considered the
matter of compacted clay liquid animal waste storage pits located next to
streams to be facilities that cause a discharge to surface waters.

On the matter of whether the examples show situations in which
a discharge of lagoon seepage will occur to surface waters, Marc Hult says the following:

===============================Marc Hult reply next.....
==========================================

Reply-To: <hult@hydrologist.com>
From: "Marc F Hult" <hult@hydrologist.com>
To: "'Alex J. Sagady & Associates'" <ajs@sagady.com>,
        
[email list SNIPPED]

Cc: <file@danbeard.com>
References: <6.2.5.6.2.20081207150631.033126b8@sagady.com>
In-Reply-To: <6.2.5.6.2.20081207150631.033126b8@sagady.com>
Subject: Connection between seepage from lagoons and discharge to streams ; was RE:
Date: Mon, 8 Dec 2008 15:41:35 -0500
Organization: Daniel Carter Beard Environmental Center
Message-ID: <012801c95975$6f588e10$4e09aa30$@com>
MIME-Version: 1.0
Content-Type: text/plain;
         charset="iso-8859-1"
X-Mailer: Microsoft Office Outlook 12.0

Alex (and all),

1)   It might be useful to first briefly review what the term "blue-line
stream" does and does not mean.

A hint at the origin of the confusion might be gleaned from the fact that
the US Geological Survey, the agency that draws the maps from which this
information is obtained, does not itself use the term "blue-line" or
"blueline". Note too, that blue, purple (on revisions) and brown (in desert
areas) are all colors that have been used by the USGS to designate perennial
and(or) intermittent streams.

See:
http://nationalmap.gov/gio/standards/
http://rockyweb.cr.usgs.gov/nmpstds/acrodocs/dlgqmap/2dqm0401.pdf.

As John Conroy, USGS/NSDI Standards Team NGTOC III/Mid-Continent Mapping
Center has written: 

"The USGS does not claim any legal authority for the classification of
streams. However, most people consider our maps to be authoritative or
reasonably accurate, so we take care in trying to portray streams
properly. That being said, we like to remind people that stream
classification was a subjective process that was originally done in the
field during a limited time period and relied on observations and
information obtained from local residents. No scientific measurements
were made to determine the classification.'

In Kentucky, 

http://www.water.ky.gov/NR/rdonlyres/96DDAFF4-FB27-4FCA-9183-4C6774B9D736/0/
KY_BMP_Manual_Appendices_FG.pdf

A " Blue-Line Stream [is defined as] Any stream that is shown on a 7.5
minute USGS quadrangle map, unless determined otherwise by the Kentucky
Division of Water or US Army Corps of Engineers. "

So a stream shown in blue on a USGS 7.5 minute topo  may or may not be a
"blue-line stream" in (eg) Kentucky. And in any case, there is no
implication intended by the USGS that the failure to show a surface water
course as a line (blue or otherwise) on a map means that it is not a stream.
Indeed most ephemeral streams are not shown. And (eg) in karst regions,
there may be neither perennial nor intermittent --only ephemeral -- streams.

2) Alex's questions:
 
        "This goes to the concept of whether a waste lagoon might be
considered
        to be designed to discharge to waters of the U.S. because its siting
is
        directly adjacent to a stream.

        Please reply to all.

        that is a blue line stream running east-west immediately south of
the barns.

        
http://terraserver-usa.com/image.aspx?T=1&S=10&Z=17&X=1696&Y=24278&W=3 "

This is a man-made drainage ditch that drains the adjacent property by
capturing a) surface-water flow, b) interflow (water flowing through the
'unsaturated zone' typically in response to a recharge event) and (I
presume) c) ground water beneath the barns.

If one replaces the words "might be considered to be designed to discharge"
with "inevitably discharges" to avoid the issue of intent in Alex's
statement, the science/technical issue is isolated for which the answer is
'yes'.

        Another site next to a blue line stream

        
http://terraserver-usa.com/image.aspx?T=1&S=10&Z=16&X=3462&Y=23825&W=3&qs=|S
t.+Johns|MI

Ditto

        that is a blue line intermittent stream to the north of the lagoon

        
http://terraserver-usa.com/image.aspx?T=1&S=10&Z=16&X=3413&Y=23834&W=3&qs=|S
t.+Johns|MI|

Ditto
        This one is definitely a tougher call.....waste lagoon constructed
on a distinct former    concentrated flow pathline leading to a blue line
stream

        
http://terraserver-usa.com/image.aspx?T=1&S=10&Z=16&X=3443&Y=23842&W=3&qs=|S
t.+Johns|MI|

There appears to be a distinct _physical_ channel ( i.e., geomorphic feature
= landform) in which water flows during recharge events. This is different
from a 'flow path' (i.e., Alex's "flow pathline" ?) which may not create a
depression or landform.

Assuming that this is the feature that Alex describes as a "distinct former
concentrated flow pathline" and that it continues with monotonic decrease in
elevation in the last few meters towards its confluence with the stream
(easily determined in field but not from photo)  this is not "a tough
[technical/scientific] call in my opinion.

However if the riparian buffer interrupts surface flow during almost
recharge events, then not. The channel then is a linear ground-water
recharge feature ("focused recharge") assuming at least moderately
well-drained soil.

Hope This Helps ... Marc

Marc F. Hult
Daniel Carter Beard Environmental Center
322 E. 3rd St.
Covington KY 41011-1710
1.859.261.3882
1.859.261.3884 (mobile)
1.859.261.3886 (fax)
www.hydrologist.com
www.danbeard.com

In Spain (EDT+ 6 hours)
+34.971.612.412 (casa) 
+34.627.034.484 (móvil)
+1.859.261.3885 (VOIP)
hult@yahoo.com

-----Original Message-----
From: Alex J. Sagady & Associates [ mailto:ajs@sagady.com]
Sent: Sunday, December 07, 2008 3:47 PM
To: [snipped]
Subject:

Mark:

Your preliminary thoughts as to the images of the waste lagoons below...  as
to the matter of
the connection between seepage from lagoons and discharge to
waters of the United States?   [setting aside issues such as constructing
a waste storage lagoon over or near a pre-existing field drain system,
something the president of the Farm Bureau in Michigan did.....and
considering seepage only from unlined compacted soil lagooons].

This goes to the concept of whether a waste lagoon might be considered
to be designed to discharge to waters of the U.S. because its siting is
directly adjacent to a stream.

Please reply to all.

that is a blue line stream running east-west immediately south of the barns.

http://terraserver-usa.com/image.aspx?T=1&S=10&Z=17&X=1696&Y=24278&W=3

Another site next to a blue line stream

http://terraserver-usa.com/image.aspx?T=1&S=10&Z=16&X=3462&Y=23825&W=3&qs=|S
t.+Johns|MI|

that is a blue line intermittent stream to the north of the lagoon

http://terraserver-usa.com/image.aspx?T=1&S=10&Z=16&X=3413&Y=23834&W=3&qs=|S
t.+Johns|MI|

This one is definitely a tougher call.....waste lagoon constructed on a
distinct former concentrated flow pathline
leading to a blue line stream

http://terraserver-usa.com/image.aspx?T=1&S=10&Z=16&X=3443&Y=23842&W=3&qs=|S
t.+Johns|MI|

My experience is that these types of situations are very common.

In searching through various state Natural Resource Conservation
Service Conservation Practice Standard Waste Lagoon #313
standards, I have not yet seen one that warns that siting of a
waste lagoon directly adjacent to a water course may result to
discharge to waters of the United States.

I've not seen much recognition of this kind of situation from
U.S. EPA and that shop may actually have tried to mitigate against
such situations being considered discharges, if my memory serves me
correctly.

Finally, the U.S. Resource Conservation and Recovery Act must be evaluated
for use on waste storage facilities.  I'm not sure if that has been done
successfully
anywhere.

By the way, Mark, thanks so much for your wonderful hospitality
for our Friday NMP meeting.

regards, Alex Sagady


=========================================
Alex J. Sagady & Associates        http://www.sagady.com

Environmental Enforcement, Permit/Technical Review, Public Policy,
Expert Witness Review and Litigation Investigation on Air, Water and
Waste/Community Environmental and Resource Protection
Prospectus at:  http://www.sagady.com/sagady.pdf

657 Spartan Avenue,  East Lansing, MI  48823 
(517) 332-6971; ajs@sagady.com
========================================== 



==========================================
Alex J. Sagady & Associates        http://www.sagady.com

Environmental Enforcement, Permit/Technical Review, Public Policy,
Expert Witness Review and Litigation Investigation on Air, Water and
Waste/Community Environmental and Resource Protection
Prospectus at:  http://www.sagady.com/sagady.pdf

657 Spartan Avenue,  East Lansing, MI  48823 
(517) 332-6971; ajs@sagady.com
==========================================