PUBLIC FORUM: BAY HARBOR GOLF COURSE AND EAST PARK

EXTENT OF CONTAMINATION

1. Will Bay Harbor Lake be tested for kiln dust contamination?

Response from EPA: Yes. The evaluation is scheduled to begin during the month of May. All parties, including local environmental groups and citizens agree that a phased evaluation is needed to address concerns of possible lake contamination.

2. Would this be considered the single worst environmental contamination of Little Traverse Bay? Are there other sources that contribute to contamination of our Bay with respect to mercury and other heavy metals?
Response from DEQ: As to whether this is the single worst environmental contamination of Little Traverse Bay, it would call for comparison between other sites of environmental contamination and the various sources of mercury. We don't possess the information to measure one environmental contamination site against another. For instance, we don't have test results for the former leather tannery which operated from the early 1900s to the 1960s or from the manufactured gas plant which operated from the early 1900s to the late 1940s. It is not possible to make any comparison to identify which environmental contamination site is the worst.

Yes. For example, there used to be a former leather tannery located on Tannery Creek during the early 1900s to the 1960s. Also, during the same time frame, a manufactured gas plant operated at the Bear River where it outfalls to Lake Michigan which is now within the harbor area, in the Bayfront Park area. Coal was baked to make gas that lit the gaslight village. Coal is a source of mercury. Mercury also comes from air deposition and enters the Great Lakes. There are likely other sources of mercury in the vicinity that continue to be a source to Little Traverse Bay and Lake Michigan.

3. How much of the shoreline is affected by the leachate and how far out into the Bay did the contamination extend?
Response from CMS: Based on shoreline surveys, about 11 percent of the five-mile-long shoreline is affected by elevated levels of pH (9 or above). When an elevated reading is found, samples are taken every five feet out into the lake until elevated readings are no longer found. An area 110 feet out from shore in the Seep 1 area was the furthest out an elevated reading was found.

4. Has Petoskey State Park been affected by the leachate, specifically is it safe to swim in the Bay at the Park?
Response from NWMCHA: No, outside of the acute hazard of direct contact with high pH leachate there are no other known contact exposure hazards that exist outside of the identified CKD release areas. The leachate discharge areas within Bay Harbor and East Park have been characterized by conducting comprehensive shoreline surveys and other water quality monitoring activities. The results have shown that pH values coincident with CKD and its leachate diminish to values below 9.0 s.u. (standard units) within 100 to 150 feet from shore. Water concentrations of other constituents of CKD leachate, such as the trace metals, were found below those that could cause an adverse health impact by direct contact and incidental ingestion.

5. How does the cement kiln dust affect the soil and does a possibility exist for contamination of neighboring areas?
Response from DEQ: Soil can be affected by CKD when mixed with CKD or when CKD leachate moves through soil. Should this occur, the soil can exhibit an elevated pH and increase in trace metals. The possibility does exist for CKD to affect nearby properties; however, CKD is a solid and it requires a force such as wind or water to move it. Prior to the development the CKD was not covered. Wind and water transport of CKD was certainly possible. One environmental improvement of the redevelopment of the property was that the CKD was physically covered with soil. This action eliminated wind movement. With respect to surface water runoff, the placing of a soil cover and vegetation eliminated water moving CKD down the slope either toward the lake or nearby properties.

Response from EPA: Groundwater moving through the kiln dust is the mechanism which distributes contamination, not kiln dust moving through soil.

6. Little Traverse Bay experienced increased algae growth last summer; was this growth a direct result of cement kiln dust contamination along the shoreline?
Response from NWCHA: No; many areas of Lake Michigan experienced excessive algae growth last year. The NWMCHA receives complaints every year regarding algae growth and its accumulation on shorelines. This is a natural phenomenon as benthic or bottom-dwelling algae slough off of rocks and other bottom materials. The increase of algae is primarily a function of falling lake levels and a greater abundance of zebra muscles, which clean and filter the lake water. Cleaner lake waters allow more sunlight to penetrate to the lake bottom, resulting in accelerated algae growth.

7. Much concern has been expressed about the heavy metals found in the leachate that persist in the lake ecosystem:

What are the current standards that apply for mercury for drinking water, direct contact, aquatic health, etc.?
Response from DEQ: With respect to current standards for mercury, the State of Michigan criteria for groundwater contact is 56 ppb, and the drinking water standard is 2 ppb. The groundwater/surface water interface (GSI) standard is .0013 ppb (1.3 parts per trillion). Mercury in CKD leachate is not a groundwater contact concern nor is it a drinking water concern. The highest concentrations of mercury in CKD leachate (0.60-0.8 ppb) are well below these standards.

What is currently being done to address their presence?
Response from EPA: We understand that there is a lot of concern about contamination from the site and how it is affecting the health of Little Traverse Bay. In order to address those concerns, we need to understand what is going on. How are the CKD piles contributing contamination to the lake? What exactly is the nature of the contamination, how much is there, and where is it going?

The mechanism that currently moves contamination from the CKD piles to the lake is groundwater. Groundwater is moving from the south, into and through the piles, and north into the lake. CMS has been and will continue to collect and analyze groundwater samples upgradient (to determine what the naturally occurring, or background, concentrations of metals are), in, and downgradient of the piles as well as collect and analyze surface water samples in the lake and samples of the leachate collected in the trenches.

It is also important to collect data at different times of the year so we can understand how weather events, such as rainfall, snow melt, rising and falling lake levels, affect contaminant concentrations moving to the lake.

After we understand what metals are present, at what concentrations and at what locations, the next step will be to evaluate the potential impacts of contamination on the nearshore environment. The current status of, and impacts to, small aquatic animals (macroinvertebrates) and small aquatic plants (periphyton) along the shoreline in the lake will be evaluated in areas where releases are occurring and in a adjacent reference area which is outside the areas of CKD contamination. Macroinvertebrates (such as mussels, snails, worms) and periphyton (such as algae) studies will provide information regarding the relative health of the ecosystem and water quality.

Studies will also be conducted to determine if the site contributes any additional mercury loading to nearshore aquatic organisms. Information will be collected on mercury since it bioaccummulates, which means its concentration gradually increases in organisms up the food chain relative to concentrations found in the environment.

This baseline ecological investigation focusing on macroinvertebrate and periphyton communities will be conducted this Spring and will be completed in the Fall. A report on this investigation should be available in early 2007.

Do you know how far out the heavy metals have spread into Little Traverse Bay?
Response from EPA: Once it is determined what, if any, impacts to the nearshore environment are attributable to the site, we will evaluate and determine what the next steps will be. We do not currently know how far out heavy metals have spread. The primary source of mercury to the lake is air deposition. Coal burning power plants and industrial boilers are the considered the most significant sources of mercury. Due to the nature of the lake bottom near the site (bedrock) and the presence of heavy metals, especially mercury, currently existing in Lake Michigan and Little Traverse Bay, it will be very difficult to determine what, if any, impact the heavy metal contamination from CKD leachate has had on the Bay environment.

Are there plans to conduct testing to determine the extent of heavy metals in the Bay and what would the costs of such testing be?
Response from EPA: There are currently no plans to determine the extent of heavy metals in the Bay as related to the CKD release site.

What are the concentrations of heavy metals in the lake bottom and fisheries?
Response from EPA: Information regarding mercury in fish and sediments in Lake Michigan can be found in EPA's Results of the Lake Michigan Mass Balance Study: Mercury Data Report (February 2004). This report can be found on line at http://www.epa.gov/glnpo/lmmb/results/mercury/index.html.

8. What is the condition or amount of contamination in the little lake just west of East Park and East of the Inn?
Response from EPA: Recent pH monitoring in the boat channel west of East Park has resulted in pH measurements ranging from 8.4 to 12.3. These measurements were based on observed discoloration in several areas of the boat channel. Areas with elevated pH (greater than 9) were collected from depths ranging from 5 feet to 20 feet. Further evaluation is currently ongoing in these locations.

9. Has the environmental issue been perceived as an isolated concern (Bay Harbor) or an area of concern (shoreline and Petoskey)?
Response from EPA: The environmental issue has been perceived and is being handled as a specific area associated with the CKD contamination present at Bay Harbor.

10. After treatment of leachate and delivery to Petoskey sewage plant, I would like to know the recommended frequency of delivery of this waste to farm fields.
Specific delivery dates?
What are the test procedures on the delivery trucks?
Are the fields being tested, and if so, what are the follow-up tests?

11. In response to the question "Has Petoskey State Park been affected by the leachate", there was no indication of testing the water at and around the state park. Has any testing been done? If so what are the results? If not, why?

12. What are the heavy metal concentrations for all of the heavy metals?
Response from EPA: A leachate sample collected from a pool on the beach during MDEQ's 2004 investigation contained detected concentrations of aluminum, arsenic, barium, calcium, chromium, copper, mercury, manganese, molybdenum, nickel, potassium, selenium, sodium, strontium, titanium, vanadium, and zinc. Other metals detected during historical sampling are cadmium, iron, lead, and silver. A table summarizing detected metals and their concentrations is attached. All results are in micrograms per liter, or parts per billion.

13. Are heavy metals monitored?
Response from EPA: Yes. As part of the approved work plan, CMS has been and will continue to collect and analyze sample of the groundwater, surface water, and CKD leachate for heavy metals. These results will be made available in future reports.

14. Why is the mercury level for the ground water/surface water so low and why is the limit for mercury in drinking water so much higher than it is for surface water levels?
Response from DEQ: The reason the mercury level for surface water is 0.0013 ppb is that mercury is a bio-accumulative substance. A bio-accumulative substance is a substance that easily transfers from one living organism to another. In the Great Lakes, for example, zebra mussels ingest mercury as they feed along the bottom of the lake; zebra mussels are consumed by smaller fish, which are in turn consumed by large fish. As larger organisms feed upon smaller organisms, they consume the cumulative quantity of mercury contained in that organism. In essence, mercury moves from the bottom of the food chain to the top of the food chain, with mercury concentrations increasing with each transfer. Therefore, the level of mercury in large salmon and lake trout can be millions of times greater than the level of mercury in the water. That is one reason why there is a public health advisory in the State of Michigan for people who consume Great Lakes fish. It is the cumulative effect of mercury, in this instance, that increases the concentration and exposure risk. The mercury level of 2 ppb for drinking water is a health-based limit. However, it is not based upon the bio-accumulative effect of mercury since it is reasonable to assume mercury will not be transferred from person to person

15. It is rumored or reported that the color of the leachate is due to the CKD piles on cedar swamps and the brown color is from the cedar tannin, is this true?
Response from EPA: While a brown tint to water can often be attributed to cedar swamps or tannins, the brown color of the leachate at this site is indicative of CKD. Please note that while most areas of CKD leachate releases to the lake are brown-colored, some of the release areas in some seasons are not discolored.

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