Town to Air Concerns at DNR Hearing on Dredging

Several recommendations will be made by the Town at a Public Hearing to be held regarding the permit the U.S. Army Corps of Engineers (USACE) has applied for from the Indiana Department of Natural Resources (DNR) to dredge the Burns Small Boat Harbor and entrance to the waterway. The dredgings may be placed on the Ogden Dunes beach or in the littoral drift just off the beach. The Hearing will be held at the Firehouse on Tuesday, January 13, 2009 from 5:00-7:00 p.m. Residents are encouraged to attend.

Recommendations to be aired by the Town include the following:

1. USACE should not be able to leave garbage on the beach: When the Small Boat Harbor and entrance were hydraulically dredged in 2000 and the material was placed east of Ogden Dunes, the material contained shredded aluminum cans, broken glass and other materials. The Town of Ogden Dunes has limited resources to keep its beach free of waste. It should be the responsibility of USACE to make sure any garbage or debris resulting from the dredging operation is cleaned up. It may even be possible that USACE may not be able to leave garbage on the beach, according to Indiana Code 14-28, Article 28, which is the Flood Control Act under which this permit is being regulated. (http://www.in.gov/legislative/ic/code/title14/ar28/ch1.html.)

2. Retesting is Requested: During the September 2008 flooding event, more than 331-square miles of floodwater and effluent drained out of Burns Waterway into the Small Boat Harbor and Lake Michigan. The material proposed to be dredged was tested several months before that flooding incident. It is the Town’s position that the material proposed to be dredged should be retested.

Furthermore, the Town recommends that core sample analysis concentrate on the upper strata of the core where contamination is more likely to exist. Conducting sampling in any other manner may not provide an adequate representation of what is contained in what would most likely be stratified sediments.

3. A Debris Survey Should be Conducted: With the amount of debris that is still landing on our beach, including paint cans, whiskey bottles, fishing lures, spray cans and docks, it is strongly recommended that a debris survey be conducted by USACE. This survey will not only benefit the Town, residents, Lake Michigan and the environment, it will also protect USACE’s dredging equipment. These surveys are standard practice in many other dredging operations.

Based on our experiences in 2000 with small debris, it is also recommended that a screen of some sort be placed at the head of the pipe where the sand is pumped onto the beach or into the lake.

4. Direct Beach Placement of Sediment from Management Unit 1 and Annual Documentation Requested: If the material is found to be safe after retesting, the Town requests that the material from Management Unit 1, which includes the approach to as well as the entrance channel to Burns Waterway, be hydraulically piped right onto the beach at the far-east end of Ogden Dunes. A review of USACE reports indicates that this material is low in silty material and contaminants, and may be appropriate for direct beach placement every year of the permit in which dredging is completed.

The Town also recommends that hydraulic dredging be used rather than split-barge dredging. Hydraulic dredging would allow for more refined placement of the material where it is sorely needed. Both forms of dredging are being considered by USACE.

The Town would also like to have some sort of annual documentation indicating how many cubic yards of sediment were dredged and where it was placed.

5. Monitoring Plan Should be Required: Considering the length of this 5-year permit, The Town is also requesting that USACE provide some sort of Monitoring Plan to DNR before the project commences. Monitoring plans are also standard practice in other dredging operations. The Monitoring Plan would tell whether or not the project was completed during the desired time frame, whether or not the material caused any environmental problems or impacts on human health, and whether or not the material actually benefitted the beach. The last point is particularly important since research at Duke University has shown that the wrong kind of sand can erode 10 times faster than native sand. (http://www.emagazine.com/view/?4415)

The plan might also provide evaluation criteria for determining if the project should be temporarily suspended after a significant rain event. Rain events can cause temporary increases in E. coli readings on the beach, as the Town has discovered through its IDEM-funded Beach Monitoring Program conducted each summer. According to the Lake Michigan Shoreline Total Maximum Daily Load (TMDL) for E. coli Bacteria, released by the Indiana Department of Environmental Management in 2004:

“Recent research along the Lake Michigan shoreline has also found that E. coli can survive for extended periods of time in beach sands and algae. A study published in August 2003 found that E. coli survived for over six months in sun-dried algal mats stored at 4°C and readily grew upon rehydration (Whitman et al., 2003). Similar research indicates that E. coli can survive for extended periods in beach sands (Whitman et al., 2001). These findings suggest that algae and beach sands can be a secondary habitat for E. coli and could potentially influence water quality along the shoreline when swimmers or wave action might release E. coli into the water column.” (http://www.epa.gov/waters/tmdldocs/10883_lkmichtmdl%5B1%5D.pdf)

6. Long-Lasting Solutions Needed: The Town is also requesting that more long-lasting solutions be found to ameliorate sedimentation in the Burns Waterway as well as erosion problems on the Ogden Dunes beach.

Work is needed to stabilize the banks of the Little Calumet River West and East Branches -- and the Burns Waterway -- after the September rain event. And more effective buffer areas are needed to prevent excess sediment from entering the waterway.

While dredged sand from Burns Waterway will always be needed for beach nourishment, a more effective solution would be the installation of a bypass piping system that would continually move sand from the NIPSCO intake to the Ogden Dunes beach.

These positions were developed with the assistance of the Ogden Dunes Environmental Advisory Board (ODEAB) and several residents. Susan MiHalo would like to thank Bob Cattani, Randi Light, Gerry Lehmann, Ursula Henkel and John Morris for their assistance. To prepare these statements, USACE reports were reviewed, including pages containing a chemical analysis of the material; plus Indiana Department of Environmental Management (IDEM) standards that provide guidance on evaluating whether or not the material is safe for placement on land. (http://www.in.gov/idem/4198.htm) Unfortunately, there are no standards for specifically assessing the quality of material for beach placement.

Additional comments may surface for the permit USACE needs to obtain from IDEM that will be public-noticed soon. The IDEM permit governs water quality issues, whereas the DNR permit focuses more on sediment impacts on property, safety and the environment. We will let you know as soon as water quality permit is posted on the IDEM website. No public hearing will need to be requested for that permit.

If you wish to submit comments on the DNR permit, comments should be addressed to:

Mr. Michael W. Neyer, P.E.
Director, Division of Water
Indiana Department of Natural Resources
Room W264
402 West Washington Street
Indianapolis, IN 46204

RE: Application #’s: FW-25073 and LM-163

Written and/or verbal comments may be provided on Tuesday evening. It is recommended that if you plan to speak you provide a written statement as well. Emailed comments may be sent to mshepherdson@dnr.IN.gov.