Lagoon, Pump & Haul permits for Mt. Bohemia delayed LANSING, MARQUETTE ’Äì Michigan Department of Environmental Quality officials are still waiting to receive an Irrigation Management Plan, or IMP, from developer Black Bear, Inc., before scheduling a public hearing on the Part 31 Groundwater Discharge and the Pump & Haul permit applications for the Mt. Bohemia sewage treatment system. Since site suitability for a planned lagoon and sewer system with spray irrigation discharge was not completely addressed in the developer’Äôs Part 31 application of October 24, the DEQ asked UP Engineers and Architects, Inc., to complete an IMP, which should include soil analytical data. According to Randy Conroy, district geologist for the DEQ Waste Management Division in Marquette, Black Bear’Äôs Part 31 Groundwater Discharge permit application dated October 24, 2000, is now administratively complete but still lacks information on the planned spray irrigation system for discharge at Mt. Bohemia (requested by the DEQ in an October 20 letter to UP Engineers & Architects, Inc.). In a November 14 letter to UP Engineers, Conroy states: "The Department cannot further process the Part 31 application and determine the acceptability of the discharge proposal without, at a minimum, the information required by Rules 2233 and 2234 of the Part 22 Groundwater Quality Rules promulgated pursuant to Part 31. "If, after further evaluation of the technical information submitted, the application is considered approvable, a draft permit will be developed. Concurrently, a draft pump and haul permit will be developed and public noticed with the notice of public hearing for the on-site discharge proposal. The applicant will have an opportunity to review both draft permits and to provide comments before they are issued. If the application is not approvable, you will be notified of the deficiencies and given an opportunity to submit the information necessary for approval." On November 17 Conroy said the Lansing DEQ Waste Management office would be reviewing the spray irrigation plan although his Marquette office has been reviewing other technical aspects of the Part 31 application. "The plans and specs are nearly approved but we’Äôre trying to get the site suitability issues resolved," Conroy noted. As of Wednesday, November 22, Bob Deatrick, senior soil scientist in the Groundwater Program Section of the DEQ Waste Management Division in Lansing, said he was still waiting for a completed spray irrigation management plan from Black Bear. "The plan should be structured in such a way as to address management issues such as the ability of soils to treat phosphorus and nitrogen," Deatrick said. "It appears to me that they (UP Engineers) are on top of it as far as getting their IMP together, but I don’Äôt know when they’Äôll have it completed." Deatrick said the plan should provide the operator with all the information needed so that the nitrogen is treated correctly. He noted the DEQ Guidance Document for an IMP should provide helpful information for UP Engineers. Chris Holmes, an environmental engineer for UP Engineers and Architects, Inc., said earlier this week that he was waiting to receive more information from the DEQ concerning the IMP; but he has not returned calls since Wednesday, perhaps because of the holiday. Deatrick said he had seen an October 31 letter from Jim Mihelcic, Michigan Tech professor of civil and environmental engineering, who has raised questions on the ability of the proposed system to remove nitrogen adequately. Deatrick added he would consider Mihelcic’Äôs comments in his review of the IMP. Mihelcic’Äôs chief concern is whether the lagoon system as presently designed is of an area large enough to treat the nitrogen. Since the state sets the depth of the lagoon, the only thing the engineer has control over, Mihelcic said, is the area of the lagoon. "It should have a larger area since we’Äôre in a more northern climate," Mihelcic noted. In his letter to the DEQ, Mihelcic states: "Under Rule 2230, the treatment system is required to have sufficient capacity to treat organic or inorganic loading so that the discharge receives physical, chemical, biological treatment to meet the standards of Rule 2222. It is my understanding that this means the lagoon treatment system must meet a discharge standard of 5 mg/L total inorganic nitrogen and not more than 0.50 mg/L nitrite as measured in the effluent from the lagoon and the groundwater ’Ķ" Mihelcic asks the DEQ to consider whether the proposed Mt. Bohemia lagoon system can meet discharge standards for several reasons: The area of the proposed two-cell lagoon was sized using a BOD (biochemical oxygen demand*) loading rate of 20 lb/acre-day ’Äì a conservative value when the average winter air temperature of the coldest month is 0-15¬ƒ C but not conservative enough for our area, where the average winter temperature of the coldest month is well below 0¬ƒ C. Mihelcic suggests the more conservative value of 10 lb/acre-day. * The BOD is the complex organic matter found in wastewater when it biologically or chemically degrades. It describes the wastewater’Äôs potential to deplete oxygen once it is discharged into a stream. Thus a treatment plant would want to remove BOD prior to discharge. It is well known that lagoons in northern climates may have a low removal of nitrogen. (Mihelcic cites Crites and Tchobanoglous in the text, Small and Decentralized Wastewater Management Systems, WCB McGraw-Hill, 1998, as reporting a three-cell lagoon in Peterborough, N.H., had 43 percent removal of nitrogen while a three-cell lagoon in the warmer climate of Kilmichael, Miss., reported an 80 percent removal of nitrogen.) Nitrification and denitrification are affected by low temperatures and proceed slowly at temperatures of 36-41¬ƒ F. "The lower temperatures we have in the Keweenaw will also result in a lower than expected depletion of oxygen in the soil due to naturally occurring biological reactions with organic carbon that is present in the treated wastewater; thus, anaerobic soil conditions that promote denitrification may not be as great as one might expect in the proposed land application system," Mihelcic adds. Mihelcic also points out that nitrogen uptake rates for trees are much lower than for other vegetative covers. Rates in northern forested land application systems include poplar, 92 lbs/acre-year; red pine, 117 lbs/acre-year and mixed hardwood and pine, 82-240 lbs/acre-year. In contrast, nitrogen removal for agricultural crops ranges from 134-739 lbs/acre-year, he notes. Mihelcic also estimated, from numbers on the Black Bear applications, that they would apply 812 lbs. of nitrogen/acre-year; but he also estimated the assimilation capacity that allows the nitrogen concentration in the infiltrating water to be 10 mg/L resulted in an allowable loading of 570 lbs. of nitrogen/acre-year. He concludes the system needs either a larger lagoon or a larger spray area. "I must say that I was surprised that my calculations showed that the system may be overloaded in regards to its ability to remove nitrogen," Mihelcic writes. In recent public comment letters to the Michigan Department of Environmental Quality, residents say the proposed Mt. Bohemia lagoon sewage treatment system may impact wetlands leading to the Montreal River, pictured here at its mouth where it empties into Lake Superior. Mihelcic also expresses concern about the potential impacts of the spray discharge on surface waters and groundwaters because the natural flow of surface water out of the irrigation area appears to be north towards the Montreal River. Other letters of public comment to the DEQ express the same concern. Keweenaw County residents Michael and Judy Hill write, "There are wetlands on the site (of the spray irrigation discharge) and also a small stream that empties into the Montreal River, which flows into Lake Superior. The proposed spray discharge will contaminate the best brook trout habitat in the country." Vern LeBlanc of Betsy and Paul Campbell of Lac La Belle also raise the question of the project’Äôs potential impact on nearby wetlands that flow into the Montreal River. However, Cary Gustafson, district field representative in Crystal Falls for the DEQ Land and Water Management Division, which enforces state wetland protection laws, said Conroy has not yet contacted him about any concern over the wetlands. On his last visit to Mt. Bohemia, Gustafson said, he investigated a complaint about wetlands near the ski hill parking lot but found no wetland violation in that area. He added he did not investigate the lagoon site since he was not asked to do so. Conroy said the review process of the Part 31 application needs to be completed before he reviews the Pump & Haul application and drafts a permit for it. He indicated he would organize a public hearing to deal with both applications but he didn’Äôt expect to schedule one until after the Christmas holidays. "The Pump & Haul would be a draft permit regarding the Department’Äôs intended decision and would allow the public a chance to comment before the final decision is made," Conroy said. The Pump & Haul application lists the North Houghton County Water & Sewage Authority (NHCWSA) in Calumet Township as the municipal wastewater treatment plant location. NHCWSA Chairman Paul Lehto said the plant will accept Mt. Bohemia sewage "not to exceed sixty thousand (60,000) gallons per week, contingent upon approval by Michigan Department of Environmental Quality." Editor’Äôs note: The most recent (October 24) Part 31 Groundwater Discharge Permit application by Black Bear, Inc., and their Pump & Haul application are now available on the Keweenaw Liberty Library. (Click on Black Bear Entertainment. Move green curtain up to read documents underneath.) - Michele Anderson November 25, 2000