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Re: E-M:/ ACOE Dow and Slurry Pit

Enviro-Mich message from "Alexander J. Sagady" <ajs@sagady.com>

At 03:26 PM 02/16/2009, MICHDAVE@aol.com wrote:

>The Army Corp of Engineers contends it would take a great deal of permitting before Dow Chemical would be granted third party use of the navigational slurry pit. Since when? This is the most under permitted facility of its kind in the state--- DEQ tried to do their job, issue the permits and demand infrastructure betterments but the Governor and LG intervened choosing to take  sides with  Dow and the Corp of Engineers. 

as an outside observer looking at this with no details.....

....was there any basis for the state to deny 
a Clean Water Act Section 401 certification for this
spoils disposal project?   did MDEQ deny the certification, or was the 
certification granted?

Dredging operations, environmental cleanup of the river bed/flood banks and ecological
restoration of the Saginaw River watershed all might call for a contaminated 
sediment disposal facility.   Although it is technically feasible to thermally treat
soil/sediments to rid it of organic contaminants only from such operations, 
it is not likely to be feasible economically or practically on the scale of cleanup operations
likely needed in the Saginaw River watershed.  

Contaminated sediment disposal facilities can be controversial.   If memory serves
me correctly, the sediment disposal basins in Western Lake Erie (i think those are off
point moulie (sp?), arn't they?) were a pretty controversial item years ago.   I'd like to know
if anyone monitors stormwater contaminants from them?.....did they ever start the 
site at the mouth of the Saginaw River?   is it being monitored for toxic releases?

Everyone should please understand that field agriculture runoff and erosion is
responsible for a lot of the need for dredging activities on a widescale basis.   Our 19th century 
system of drain commissioners and their practical dominance over water 
management  and our present ineffective soil conservation system are problems.
Allowing turbid runoff from eroded fields with inadequate conservation practices for control
seems to be a frequent mode of operation for agricultural operators in our state.
At the very least, MDEQ should alter NPDES requirements for CAFO operations 
to ensure CWA BAT-stringent soil erosion control measures and accountability 
as part of limiting effluents of phosphorus, pathogens and suspended solids.

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

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