DEQ addresses concerns prior to hearing on Mt. Bohemia sewer permits MARQUETTE ’Äì At a public hearing concerning the proposed lagoon and sewer treatment system for Mt. Bohemia, Department of Environmental Quality officials will provide handouts with a summary of questions and responses on Black Bear Entertainment, Adventure & Recreation Company’Äôs application for a Part 31 Groundwater Discharge Permit and a Pump & Haul Permit. The informational handouts for the public will also include MDEQ drafts of these permits. The hearing will begin at 7 p.m. Wednesday, Jan. 24, at the Mohawk School. DEQ Waste Management Division staff from Marquette will be present: Robert Schmeling, supervisor; Randy Conroy, senior district geologist; Margie Ring, senior engineer; and Karen Isaacson, secretary. Brian Brady, multi-media coordinator, will conduct the hearing, which will be tape-recorded. Conroy said he believed the handouts could satisfy some concerns and benefit the application process. He noted significant questions and comments brought up at the hearing or sent to the Department before Jan. 31 (the end of the comment period) will be added to the comments and response document and made available upon request. "We would respond in the format of this document, and we would provide that to them," Conroy said. UP Engineers and Architects submitted the draft Irrigation Management Plan, or IMP, (for the planned spray irrigation process of wastewater discharge), on Jan. 9, 2001. The IMP was not complete when the Part 31 application was turned in on Oct. 24, 2000. Conroy said some of his questions on the IMP had been answered by Chris Holmes, environmental engineer for UP Engineers and Architects. "(Holmes) clarified the land application rates and the rotation schedule," Conroy said. "(Rotation) allows the soil bacteria to provide greater efficiencies on nitrogen uptake." Rotation prevents saturating the soils of one area, Conroy explained. Instead of the original plan to spread the treated wastewater over a two-acre area, the Jan. 9 IMP calls for five two-acre plots, each of which will be wetted for two consecutive days on a revolving schedule, allowing each one to dry for eight days between wettings. In their summary of comments and responses, DEQ officials address the question of the acreage needed to hydraulically accommodate the discharge, noting the additional eight acres of land application results in a land application rate of 25.62 inches (2.1 feet) per year, or .70 inches per day. (The land application rate in inches refers to the volume of wastewater that will be spread over the 10 acres.) The Jan. 9 draft IMP says, "The spray irrigation system is a slow-rate process that will utilize crop uptake and soil matrices to remove Total Inorganic Nitrogen (TIN). Northern Hardwoods make up the current vegetative cover and will be maintained and harvested to ensure forest health and marketability along with steady nutrient uptake." The document states also that monitoring, testing and maintenance of the system will be performed in accordance with the (Part 31) Groundwater Discharge Permit. It adds that Northern Hardwoods can be expected to remove about 40 lb. of Nitrogen per acre per year and the system has been designed to allow a loading cycle that allows time between each loading for the following: soil organisms to decompose organic constituents in the wastewater; the soil to become aerated; soil conditions to become unsaturated and aerobic; organic solids on the soil surface to decompose; vegetative cover to utilize available nutrients provided through the application of the wastewater; harvesting operations to occur at the appropriate times. The IMP notes that, since the existing forest has been selectively cut, no additional harvesting is believed necessary for the next year or two. However, a professional forester will be contracted yearly to make recommendations on selective cutting, taking into consideration nutrient uptake and forest health. In an October 31 letter to the DEQ, Jim Mihelcic, Michigan Tech professor of civil and environmental engineering, raised questions on the ability of the originally proposed lagoon and spray irrigation system to remove nitrogen and phosphorus adequately. He concluded the system needed either a larger lagoon or a larger spray area. The IMP now calls for a larger spray area; but so far DEQ officials believe the lagoon area is sufficient, especially since the wastewater to be treated will be much less in the summer months. Conroy noted that, unlike a municipal system which generates wastewater every day, these treatment lagoons will have the flexibility to continue to store it until it meets discharge standards. The additional time would mean additional treatment. The effluent can be tested as it is coming out of the lagoons to determine whether it meets standards. The IMP calls for an irrigation season of May 15 to Nov. 15, with a schedule of seven days a week for 26 weeks of the year. The DEQ made Mihelcic’Äôs letter available to UP Engineers during their development of the IMP. In addition, Bob Deatrick, senior soil scientist in the Groundwater Program Section of the DEQ Waste Management Division in Lansing, said he would consider Mihelcic’Äôs comments in his review of the IMP. Conroy said the comment and response summary handout consists primarily of responses to concerns and questions Mihelcic raised in his letter. An example of this is Question/Comment #16 on the handout, which states: "The treatment system may be overloaded with respect to its ability to remove nitrogen due to low removal rates in the lagoon, soil, vegetative uptake, and the low concentrations of natural organic carbon in the sands." The DEQ response to question #16 says the IMP addresses the issue of application rate with regard to nitrogen satisfactorily, but has yet to resolve a problem in the length of the proposed discharge season (May 15-Nov. 15): "The IMP indicates and calculations confirm that Total Inorganic Nitrogen is proposed to be applied at a rate of 64 pounds per acre per year. Published information regarding the nitrogen uptake characteristics of the proposed cropping system indicate that nitrogen can be expected to be removed at a rate of 40 pounds per acre per year. The nitrogen present in excess of the 40 pounds per acre per year may be taken up through luxury consumption by the crop or may percolate to the groundwater at an acceptable concentration of five mg/l." The DEQ comment adds, however, that hardwoods in the region can be expected to cease nutrient uptake from the soil by no later than mid-September. It states further: "This issue has been brought to the attention of the facility’Äôs representatives. They have acknowledged the importance of the matter and are currently working on a resolution to the problem." In response to Mihelcic’Äôs concerns about phosphorus removal, the DEQ replies, "The Department will condition the Part 31 Groundwater Discharge Authorization on adequate treatment of phosphorus to meet a discharge standard of 1 mg/l." In order to meet this standard, the phosphorus will need to be removed in the treatment lagoon prior to land application. The IMP provides for this, stating, "treatment of phosphorus with chemicals will occur prior to spray irrigation discharge." Conroy said the chemical treatment would "possibly" consist of adding alum (potassium aluminum sulfate) to the lagoon. "It binds with the phosphorus and precipitates it out as sludge and accumulates in the lagoon," he explained. Other questions receiving comments or responses in the handout include concerns about possible contamination of wetlands and the Montreal River, noise and diesel pollution, runoff and erosion from slopes and the role of soil pH. DEQ officials note the nearby wetlands and rivers will not be adversely affected by the discharge because of the application rates based on removal capacity of the soils and Northern Hardwoods. As for possible pollution from diesel generators, they refer to Part 5, Pollution Incident Prevention, of Part 31, which provides for methods of inventory of stored material, procedures for preventing pollution of surface waters and groundwaters and emergency clean-up procedures. Noise pollution, however, is outside the jurisdiction of Part 31. The Department offers these responses to erosion concerns: "Slopes in the spray irrigation area are not excessive. Permeable, medium textured sand soils will promote infiltration of rain and snowmelt not overland flow. Spray irrigation can not occur if standing water is present pursuant to Rule 2204(2)(b)." Conroy said Deatrick is still looking into the natural pH of the soils. Since an excessively high or excessively low pH can potentially liberate trace elements (heavy metals), the system needs to assure that these are precipitated out into the sludge, Conroy explained. The Part 31 Groundwater Discharge Permit authorizes the permittee to discharge a maximum of 40,000 gallons per day, 7,000,000 gallons per year. It will expire five years from the date it is issued. After four and a half years, the permittee has to submit an application for re-issuance. The permit is issued under the provisions of Part 31, Water Resources Protection, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended (Act 451), being Sections 324.3101 through 324.3119 of the Compiled Laws of Michigan and the Administrative Rules promulgated thereunder. The Pump and Haul Permit authorizes storing on-site for transport and ultimate off-site disposal a maximum of 15,000 gallons per day seasonally (747,500 gallons per year) in accordance with limitations, monitoring requirements and other conditions. One condition in this permit is its expiration at the end of the construction season of 2001, when the lagoon treatment system should be completed. ’Äì Michele Anderson January 23, 2001