Lone Tree Council and TRW
April 22nd 2006 #65
The Saginaw River Dredge Materials Disposal Facility
A review MDEQ files and Saginaw County files on the Dredge Materials Disposal Facility (DMDF) to be sited in the floodplain just west of the Saginaw River in Zilwaukee Twp (Saginaw Co.) and Frankenlust Twp (Bay Co.) reveals a site rife with environmental problems and cost overruns.
The Saginaw News recently opined on the need to dredge the river.
http://www.mlive.com/news/sanews/index.ssf?/base/news-1/114536652190630.xml&coll=9. There is no disagreement on dredging the river. Where to place these sediments is what’s at issue. One glaring error in the Saginaw News editorial is: “Yet Saginaw County officials have received the go-ahead from the state Department of Environmental Quality -- hardly a pushover agency –…………..” Not totally correct. The DEQ has not signed off on the placement of dredged materials because an Operational Management Plan (OMP) on how the site will be built and how the contaminated sediment will be managed has yet to be submitted for DEQ review, input and approval. Until it is nothing can be placed in the site. More about the OMP below.
Dredging the river is only one issue. Where to put these highly contaminated sediments is another issue. The need for the Saginaw River to be dredged doesn't mean the final resting place for the sediments should not be done correctly. These sediments are highly contaminated with dioxin, the same dioxin found in the Tittabawassee River which triggered all kinds of environmental activities from state and federal agencies. Sampling data in the navigational channel is limited but concentrations exceed 10,000ppt. DEQ says the " dioxin furan concentrations in the Saginaw River are highly variable.” There’s a lot which is not known, making safe disposal of these contaminated sediments imperative. To date, decisions are being made based on the urgency to dredge, scattered sampling, the need to secure a site quickly and the heavy hand of politics.
The proposed site in the floodplain of the river is the wrong site. Three or four previous attempts to site a disposal facility on the west side of the river have been rejected in the past because of flooding, westerly prevailing winds and proximity to the Crow Island Game Reserve. None of these dynamics has changed.
Ships getting stuck in the turn around a basin the past weeks have been unfortunate. However, the dredging delays and ensuing problems with river traffic are the result of poor planning and doing this project “on the cheap” like the Army Corp of Engineers (ACE) stated early on. As of today it would appear plans are now shifting to make dredging the turn around basins the priority. The ACE abandoned site selection in the late 1990’s and in their rush to act on appropriated federal funds and finding a willing partner in Mr. Koski they snatched land that was the most convenient. It had nothing to do with science.
Early on in 2003 Zilwaukee residents, Twp officials and LTC asked for an Environmental Impact Statement (EIS) to determine if this was the safest, most prudent site and was it the best site for the long term placement of highly contaminated sediments. The ACE refused to do the EIS because they knew the detailed investigation in an EIS would eliminate this site in Zilwaukee anf Frankenlust from consideration. Instead Mr. Long opted for the less arduous Environmental Assessment ( EA); a sort of “drive by” assessment which requires little effort and no critical evaluation of the issues. Michigan’s largest watershed, sited for a disposal facility for dioxins and furans on the banks of the Saginaw River apparently does not warrant a rigorous EIS. In a DEQ inter-departmental email dated December 22, 2005 it states:
5. “ All CDF/DMDF’s in Michigan, other than the Upper Saginaw River DMDF, have an EIS according to Les Weigum, USCOE”.
Why are we being treated differently? An EIS would have provided a thorough, independent analysis of the project. Likely too much objectivity. ……….We wouldn't want the facts to get in the way. The recklessness of not doing an EIS may not become apparent for years. Saginaw County is the local sponsor. Mr. Koski committed all the taxpayers of Saginaw County to perpetual liability for the site which will contain sediments highly contaminated with dioxin from Dow Chemical; a most compelling reason if none other to do the EIS. The counties long term obligations include; insurance, inspection and maintenance, deed restrictions, groundwater, storm water and effluent monitoring as well as corrective action planning in the event of environmental problems. In a letter dated December 28th 2005, to Mr. Koski and the ACE, DEQ stated:
“Numerous sand lenses in the upper 13 feet at the site are saturated and have the potential to discharge off-site, either to the wetlands to the west or the Saginaw River to the east…………….The geology of the site does not meet the criteria for the natural clay base of composite liner”.
More poor planning. Only after Mr. Koski purchased the site was it was discovered that the integrity of the clay lining was feathered with sand seams and lenses which permit contamination of ground water or run off back to the river or adjoining properties. Our concerns about the integrity of the clay and ground water contamination were specifically questioned at two public meetings. We were assured by proponents of this site, Mr. Koski included, that the natural clay liner was sufficient. Well it’s not. In a March 16th 2006 email, DEQ is estimating the cost of having to install a groundwater monitoring system. The one time cost estimates for monitoring wells is $55,000 to $165,000 and the range for sampling which will be incurred annually until the permit is terminated are between $54,000 and $423,000. Where is that money coming from? The levels of dioxin in that slurry pit will concentrate over the years and ground water will need to be monitored in perpetuity. Buried dioxins never degrade. Again, this site belongs to the taxpayers of Saginaw County. An EIS would have identified the problem and also permitted a better assessment of the present and long term risks and costs. As for the ACE, Mr. Long, just last month, in a letter to DEQ said groundwater contamination is not a problem because,” “There is no use of the groundwater in the vicinity of the site as a drinking water source.” Cavalier an arrogant disregard for Michigan's water.
Documents indicates the DEQ is asking for a list of “ betterments” needed for the site before any dredge materials can be placed. Mr. Koski in a March 27, 2006 letter to the ACOE is asking for those “betterments” in the form of cut off walls and additional dikes. No cost estimates yet, but Mr. Koski assured the ACE:
“The county understands the County shall be solely responsible for all costs associated with the betterments….”
What is the cost associated with those betterments? Where is the money coming from? The taxpayers are the local sponsors and deserve answers.
In their Finding of No Significant Impact ( FONSI) dated March 25th 2005, the Corp contends the only effects and impacts associated with the site are the irretrievable loss of farmland. Can we really afford to lose any more farmland? Isn't farmland preservation a priority for responsible land use in Michigan. These farms are also wetlands; pumped wetlands that were converted to farmland. Left in their natural state, DEQ says the land would revert to forested wetlands. What makes this relevant is the Corp goes on to claim there is no "significant impact to wetlands". Loss of wetlands is not an impact? WRONG. This site flooded with millions of gallons of water in 1986, it did what wetlands are intended to do which is to provide floodwater storage. Where will the water go in the future? Can the dikes hold back the water? Or will a flood event wash out this slurry pit. Jim Koski and the ACE say the site isn't in the floodplain. Their maps say otherwise.
In a September 2003 DEQ memo, DEQ expressed caution about the placement of contaminated sediments in the floodplain and asked that an “upland facility out of the floodplain” be considered. This concern was also voiced earlier in a May 2006 DEQ document but, “No response was provided to this issue”. DEQ further commented in the March 2003 letter, “We remain concerned about the long term maintenance of a facility placed in the floodplain and the liability for any releases of the sediments resulting from placement of the dredged sediments in the floodplain”.
The ACE Finding of No Significance is convenient and that’s all it is. DEQ memos, comments from US Fish and Wildlife, DNR and EPA appear to come to a few significant and different conclusion about some of the impacts associated with this site. The cumulative impacts of wetland destruction, shoddy placement of contaminated sediments, elimination of floodwater storage, lack of funding, poor planning, secrecy and politics is reckless and will impair this watershed’s resources for generations to come. No one should find comfort in the siting process or the facility.
Operational Management Plan
Below are issues and deficiencies in regard to the Operational Management Plan that have yet to be addressed, revealed or mitigated.
· Fugitive dust
· Compromised air quality and monitoring
· Ground water contamination
· Floodplain impairment
· Loss of wetlands
· Wetland mitigation issues
· Impacted residents
· Rotting organic materials
· Wildlife uptake of contaminant
· Standing water
· Cost overruns : dykes, slurry wall, groundwater monitors, liners
· Reproductive impairment
· NPDES Permit ( water discharge)
· Daily cover
· Run off to adjacent properties to the west
Up against the deadline because of poor planning
“The site search committee in the late 1990’s after identifying 29 potential sites in Saginaw and Bay County abandoned their search……….”no reasons given”, according to one DEQ document. Now it’s a race to the finish line at all costs and the well being and welfare of this river watershed and townships be damned. Poor planning is still in play. Mr. Koski intends on moving ahead with construction of the site next month without:
No dredges spoils can be placed in the site until the DEQ signs off on the Operational Management Plan. What if one is not forthcoming? Putting the cart before the horse has plagued this project from day one.
Lost opportunities abound
Early on there were lost opportunities for safe placement of these contaminants beginning with the failure to plan, the failure to hold the responsible party (Dow Chemical) accountable, refusal to indemnify GM against the placement of dioxin contaminated sediments in their landfill ( as a potential site on the river), the disbanding of the search committee by the ACE in the late 1990’s knowing darn well a site would be needed and finally, the failure to bring all the stakeholders together. It is the absolute failure to engage the entire stakeholder group in meaningful dialogue about an integrated watershed approach to dredging and cleaning up the river. It’s obvious that stakeholder engagement and being kept in the information loop was predicated on going along and getting along. If you asked tough questions you were tossed out of the information loop. It was also contingent on not expecting Dow Chemical to shoulder any burden, even though “dioxin is the contaminant of concern” according to the ACE. One handwritten note I came across
The Saginaw Bay Watershed is Michigan’s largest watershed. We comprise one the longest contiguous coastal wetland system in the US and comprise a portion of the Mississippi flyway. Unfortunately, years of pollution, short sightedness and poor planning have resulted in the Saginaw River and Bay being listed as an Area of Concern ( AOC) by the US and Canadian Governments. The economic losses associated with our contaminated rivers, fish and property is huge. Our Saginaw Bay is the only site on the US side of Lake Huron listed as an AOC. There is an obligation on the part of every business, citizen, unit of government and elected official to be smarter and wiser in the planning and use of natural resources.
This story is ongoing and more detailed than you can imagine. This dioxin update is only a snap shot of what’s wrong. The real story is what’s going on behind the scenes, what’s not being said, what’s not being covered in the media and the disappointing political maneuvering around every facet of the dioxin debacle.
Stay tuned! Happy Earth Day!
Michelle Hurd Riddick
Lone Tree Council
" Criticism may not be agreeable, but it is necessary. It fulfills the same function as pain in the human body. It calls attention to an unhealthy state of things.".........Winston Churchill
Source: Lone Tree Council / TRW
For additional articles like this one, go to the Tittabawassee River Watch web site www.trwnews.net. for complete coverage of the Tittabawassee River Dow Chemical dioxin contamination saga.. The source organization's web site link is listed above. The Newspaper / Media page of our site contains an extensive archive of media articles dating back to January 2002. The Newspaper / Media page may be accessed by scrolling down to the bottom of the CONTENTS section and clicking on the Newspaper/Media link.