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GLIN==> Dredging of Conner Creek in Detroit, MI



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,

Shawn Hupka
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 public.dingell@mail.house.gov.  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 www.john.conyers@mail.house.gov.  If you email either Congressmen send a copy to Russell Kreis at the USEPA Kreis.Russell@epamail.epa.gov

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
Robert.J.Davis.LTC@LRE02.usace.army.mil  The Corps website is http://www.lre.usace.army.mil

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 gray.h@parl.gc.ca.  Send copies of your emails to John Marsden at Environment Canada John.Marsedn@ec.gc.ca.  Implore them to communicate with their counterparts in the US regarding this important bi-national environmental issue.


Thanks,

Shawn Hupka
Citizens Environment Alliance
(519) 973-1116
cea@mnsi.net
2000/04/19

Congressman John Dingell
Room 2328 Rayburn House Office Bldg.
Washington, D.C., 20515
United States of America

Sir,

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.

Yours truly,





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
http://www.lrd.usace.army.mil/gl/cdf98

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: http://www.epa.gov/glnpo/arcs/arcsguide.html 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 environmental impacts.

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.

Jan Miller
Great Lakes & Ohio River Division
U.S. Army Corps of Engineers
111 North Canal Street
Chicago, Illinois 60606-7205
(312) 353-6354
(312) 353-3138 (fax)
jan.a.miller@usace.army.mil
http://www.lrd.usace.army.mil/gl/gl.htm

April 21, 2000

Jan,

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 don’t 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 didn’t 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 treatment demonstration.

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.

Art Ostaszewski
MDEQ-SWQD
OSTASZEA@state.mi.us

Citizens Environment Alliance consultant Dr. Dave Dolan had this to say about the storage of contaminated sediments at the Point Mouillee Confined Disposal Facility (CDF)….

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
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Canada
Ph. 519-973-8352 fax 519-973-8360
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