We consider ourselves very fortunate to live and work at a resort surrounded by the Sleeping Bear Dunes National Lakeshore, the place the viewers of ABC’s Good Morning America recently chose as the “Most Beautiful Place In America.” We also consider ourselves to be good stewards and good neighbors as we treasure the lakeshore just as much as anyone.
As part of our stewardship we operate a Wastewater Recycling and Reuse System that is considered state of the art. It treats and disinfects wastewater, irrigates the treated water on agricultural crops, relies on natural processes for nutrient uptake, and recharges the aquifer. Regular tests are taken and results are reported to the Michigan Department of Environmental Quality. They routinely show that the system meets or exceeds all applicable standards for effluent quality.
A former employee of the National Park Service has repeatedly criticized The Homestead for one reason or another. Initially his criticism of the recycling and reuse system was that aerosol drifts would sometimes go onto property owned by the Lakeshore. While we believe that drifts were infrequent and had little impact, we took steps to eliminate them. The steps we took were reviewed and approved by the NPS and the MDEQ. Now the former employee’s criticism is that the system harms wildlife. We believe that does not warrant a response – the system grows agricultural crops just as the farms, orchards, and vineyards in our area do.
We ask that you read a recent release and the water quality standards it includes to assure yourself that these statements – repeated or not – are wrong.
Press Release:
Like others, we treasure the Lakeshore
For Release: December 7, 2011
The author of a December 6, 2011 Forum entitled “Wayward sewage at Sleeping Bear Dunes” (Traverse City, Record Eagle) made several allegations regarding the operation and effectiveness of The Homestead’s wastewater treatment facility. He has made those allegations a number of times in a number of places. They have been corrected with factually accurate information and investigated by the National Park Service (NPS) and the Michigan Department of Environmental Quality (MDEQ) and found to be without merit.
“We are disappointed to again read these statements. Like others, we treasure the Lakeshore and the area in which we live and work and take day-to-day steps to be good stewards. This practice includes treating wastewater in strict accord with the law,” said Adriene Kokowicz Vice President and General Manager of the resort.
She further said: “To let all of our neighbors know the facts, I asked our engineers to read the Forum, again review the compliance reports we file with the MDNR and provide a statement for public release regarding the nature of our system and the quality of the effluent it produces. It follows.”
The wastewater system at The Homestead was reviewed and approved by the Michigan Department of Environmental Quality (MDEQ). The approval was in strict accord with the law and did not rest on a “loophole.”
The treated, sanitized effluent that is discharged by the wastewater system meets or exceeds all environmental standards set by the MDEQ. These standards are the same for all wastewater treatment facilities throughout Michigan.
These standards include a disinfection standard that meets Rules 62(2) and 62(3) of the Part 4 Water Quality Standards for partial body contact (meaning water skiing, canoeing and wading), as required by the permit. Typically, the treated, sanitized effluent from The Homestead’s wastewater system exceeds this standard and actually meets the standard for total body contact (meaning swimming). Any time the treated effluent did not meet those standards The Homestead acted promptly and in full cooperation with the governmental agencies to make any corrections that needed to be made.
The treated, sanitized wastewater is discharged on an easement owned by The Homestead. At the request of the NPS and MDEQ, the easement was fenced. In most cases, the fencing is located inside the resort’s easement to provide an additional buffer for the public. The warning signs around it were installed in response to a NPS request and a MDEQ requirement just as they are at all other discharge areas in the State.
The Homestead’s wastewater treatment system employs an environmentally responsible and sustainable process. It recycles wastewater for irrigating agricultural crops, relies on natural processes for nutrient uptake and recharges the aquifer. Systems of this type are in operation throughout the State of Michigan. They are routinely used in the western US and are considered state of the art where groundwater sources are not as plentiful as in Michigan.
In an earlier response to these allegations, the National Park Service brought an expert from Ft. Collins, Colorado to inspect the system. He found no fault with it. An expert from the MDNRE also inspected the system. She found no fault with it.
Doug Coates, P.E. – Gosling Czubak Engineering Sciences, Inc
December 7, 2011
The facts that the system produces effluent that meets all of the state’s standards and that it has again been inspected by the National Park Service and the MDEQ, should correct any misimpressions created by the Forum. So should the common sense notion that water which is routinely tested and found to meet the State’s standards for safe wading and water skiing is unlikely to be a human health hazard as a result of occasional aerosol drifts.
-END-
______________________________________________________________
For convenience, the rule to which the engineers referred and two definitions appear below.
Rule
R 323.1062 Microorganisms.
Rule 62. (1) All surface waters of the state protected for total body contact recreation shall not contain more than 130 Escherichia coli (E. coli) per 100 milliliters, as a 30-day geometric mean. Compliance shall be based on the geometric mean of all individual samples taken during 5 or more sampling events representatively spread over a 30-day period. Each sampling event shall consist of 3 or more samples taken at representative locations within a defined sampling area. At no time shall the surface waters of the state protected for total body contact recreation contain more than a maximum of 300 E. coli per 100 milliliters. Compliance shall be based on the geometric mean of 3 or more samples taken during the same sampling event at representative locations within a defined sampling area.
(2) All surface waters of the state protected for partial body contact recreation shall not contain more than a maximum of 1,000 E. coli per 100 milliliters. Compliance shall be based on the geometric mean of 3 or more samples, taken during the same sampling event, at representative locations within a defined sampling area.
(3) Discharges containing treated or untreated human sewage shall not contain more than 200 fecal coliform bacteria per 100 milliliters, based on the geometric mean of all of 5 or more samples taken over a 30-day period, nor more than 400 fecal coliform bacteria per 100 milliliters, based on the geometric mean of all of 3 or more samples taken during any period of discharge not to exceed 7 days. Other indicators of adequate disinfection may be utilized where approved by the department.
(4) The department may suspend the provisions of subrule (3) of this rule, for the purpose of discharge permit issuance, from November 1 to April 30, upon an adequate demonstration by the applicant that designated uses will be protected. At a minimum, the provisions of subrule (2) of this rule shall be met.
(5) Acceptable levels of infectious organisms that are not specifically addressed by the provisions of subrules (1), (2), and (3) of this rule shall be established by the department on a case-by-case basis to assure that designated uses are protected.
Definitions of Designated Uses
Partial Body Contact Water quality standards are maintained for water skiing, canoeing, and wading
Total Body Contact Water quality standards are maintained for swimming
