The Baltimore Post received the following report from Russell S. Donnelly, an environmental expert, concerning a recent request by Tradepoint Atlantic. TPA is seeking permission from state and federal officials to dredge beyond its existing permit.
Mr. Donnelly’s communication below is published as written.
1. An Extension of the USACE Public Comment period past October 30, 2017
2. A Full and Comprehensive Environmental Impact
3. A Full and Comprehensive USACE Public Hearing pursuant to the Amendment Proposal for the existing Maintenance Dredge Permit – 2013-61758 -M07.
The Tradepoint Atlantic (TPA) application to alter and amend the existing USACE Maintenance Dredge Permit for Sparrows Point exceeds the permitted Maximum Depth Dredge Limit of the original USCAE Permit. That Permit was issued to RG Steel, LLC in 2013, not the current new owners of the property. TPA did not take ownership of the Sparrows Point Peninsula (SPP) until June of 2014. The Ore Pier Basin was dredged in 2014, removing approximately 40,000 cubic yards of superficial shallow sediment.
The characteristics of the sediments surrounding Sparrows Point Peninsula (SPP) are already heavily documented across 30 years as Hazardous Toxic Radioactive Wastes (HTRW) (USACE 2005) and EPA RCRA HIGH PRIORITY contaminated. Maryland Department of the Environment has categorically DENIED Water Quality Certification (WQC) for all previous Sparrows Point Peninsula proposed major dredge projects. The scientific analytical data evidence which qualifies and quantifies this fact is voluminous and unimpeachable. Any proposal which would disturb the naturally deposited sediment cap, approximately 4 feet thick, will expose and re-suspend HTRW/HIGH PRIORITY contaminated sediments beneath.
This would be causal to a new pollution event released into the water column in an already determined MDE 303-d Severely Impaired waterbody. Any proposed TPA projects must have close and integrated Public interface through Public Hearings before any authorization for action. This is especially pursuant to proposed actions affecting, or effecting, the open waters of the State of Maryland and the Sovereign Riparian Rights of the People.
Our regional ecosystem, surrounding Sparrows Point Peninsula (SPP), has taken, in excess of, 50 years to achieve basic minimal restoration of life, after the damages incurred from the 120 year steel industry negative environmental impacts to our region. As of 2016, life has returned to our waterways and ecosystems. The chemical determination has been made by our Agencies that approximately 2 centimeters of surficial sediment is environmentally safe. Any sediments below this benchmark became increasingly contaminated the deeper the sampling.
This TPA Dredge Amendment Proposal will purvey major physical, geomorphological, chemical, and biological characteristic negative environmental impacts to the immediate project site; outward into the Patapsco River Basin; and ultimately into the body of the Chesapeake Bay itself. There is great concern as to the acute, chronic, and cumulative damages this TPA proposed project will levy upon the Public Domain. Also, the duration and length of time involved for any possible recovery from this overall major proposed dredge project.
As previously cited; it has taken approximately 50 years to realize recovery from the former 120 year steel industry effect; quid pro quo; we can conservatively posit another 50 year minimum period for environmental recovery from this TPA proposed project. This proposed TPA project will shovel through every molecule of contamination ever deposited at Sparrows Point Peninsula at this specific site. Overall, our water-body may never recover; since it is already severely impaired now.
We are faced with the prospect of our next two generations of heirs, once again, not being able to use our waterways and our aquatic natural resources for beneficial quality of life endeavors. This situation demands active discourse before any course of action.
We, the Southeast Communities Against Pollution (SECAP) and Associates, respectfully, adamantly, and resolutely enter this FORMAL REQUEST for a Comment Period Extension; a full and comprehensive Environmental Impact Statement; and a full and comprehensive Public Hearing on this TPA Permit Application; and on all, forthcoming permit application processes pursuant to all proposals for projects by TPA concerning our Maryland waterways. Respectfully submitted on this 12th day of October 2017 at 1:00 P.M. EDT.
(Russell S. Donnelly, is the chairman of the Southeast Communities Against Pollution ( SECAP). His interviews have appeared in The Baltimore Sun along with numerous other publications. Mr. Donnelly is also registered as a chemist with the State of Maryland.)