PUBLIC FORUM: BAY HARBOR GOLF COURSE AND EAST PARK

LONG-TERM RESPONSE

1. Is there a long-term remedy that will address the problem permanently?
Response from CMS: Long-term remedy options are detailed in the feasibility study. Similar methods have been successful at other sites with similar environmental conditions.

Response from DEQ: Yes, there are long-term remedies that can permanently address the problem. However, since there are many alternatives that can address the problem permanently, it would be premature to identify a single remedy at this time. The feasibility study will detail the potential long-term remedies and provide a basis for selection.

2. Will there be long-term effects to the water quality of Little Traverse Bay, fish and other aquatic species, and public health?
Response from EPA: We do not know yet if there will be long-term effects to the environment of Little Traverse Bay or to public health. We will begin this Spring to evaluate the status of the nearshore environment and potential effects of the releases from the site to aquatic plants and animals. The results of this study will help us determine the next course of action. The information we are currently collecting and will continue to collect will help us evaluate the potential for long-term public health effects.

Response from NWMCHA: At this time, it is uncertain what long-term impacts the CKD leachate will have on the water quality and aquatic species of Little Traverse Bay. From the information collected so far, it appears the CKD leachate disperses or dilutes rapidly from the sites of discharge. As the remedial investigation and ecological survey activities move forward, we will have a much better picture of water quality and the ecological health of the bay.

Some trace metals such as mercury can bioaccumulate in the aquatic food chain, resulting in increased concentrations of those metals in predatory/game fish. It is recommended that individuals continue to observe the fish consumption advisories that currently exist for the Great Lakes (www.michigan.gov/documents/FishAdvisory03_67354_7.pdf).

The most significant public health impact exists with direct exposure to high pH leachate (above 9.0 standard units). Acute exposure to pH values above 9.0 s.u. can cause irritation to skin, eyes and mucus membranes, values above 11.5 s.u. could result in permanent damage to these tissues.

3. Do you have a full understanding of how the water flows beneath and through the piles of cement kiln dust?
Response from CMS: The more than 100 bores, probes and wells installed have provided a great deal of information about water flow. Data collection is on-going and any data gaps will be identified and filled with additional information collection.

4. How does other cement manufacturing companies address cement kiln dust, specifically what process does St. Mary's in Charlevoix use to properly handle the CKD waste produced? Is the Bay Harbor site being held a higher standard for cleanup requirements than other similar sites?
Response from DEQ: Other cement facilities typically manage CKD by disposing of it into a lined landfill which includes a leachate collection system and treatment and an impermeable final cover. At St. Marys, CKD is placed into a lined landfill which includes a leachate collection system. Leachate is treated through the operation of the quarry dewatering system. The CKD will be capped with an impermeable final cover. The standard applied to all CKD sites is generally the same, but often different methods to achieve the standard are utilized.

5. Why is the option of removing all CKD rejected?
Response from CMS: The removal of CKD has not been rejected and is one of the five options studied. CMS does not believe it is the best option based on the following:

To relocate the approximately 400,000 cubic yards of CKD from East Park would result in approximately 20,000 truck loads leaving the site. That is equal to 37 truck loads of CKD a day for two years leaving East Park and making a left hand turn onto U.S. 31. This scenario results in increased risk to public safety based on the dramatically increased traffic. A continued increase in traffic would result from the backfill that would need to be brought into East Park to make the park usable.

The associated dewatering of site resulting from total CKD removal is estimated to generate 1,000 gallons of leachate per minute that would have to be pumped to the lake. This would likely result in more mercury and other solids finding their way to the lake that if nothing at all is done at the park.

Please also see the answer to question 3 under East Park for additional information.

6. How are other cement manufacturing facilities in the area disposing of CKD? Does St. Mary's Cement have a leachate problem? If so is it being monitored?
See number 4 above

7. What is the scheduled timeline for permanent cleanup?
Response from CMS: It is difficult to provide a schedule for permanent clean-up because data is still being collected and proposed remedies have yet to be developed for Bay Harbor. East Park activities are scheduled to begin later this fall based upon regulator approval of the proposed remedy.

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