Final Report, ECCSCM Water Monitoring Project, 2001-2003
Environmentally Concerned Citizens of South Central Michigan

Coordinators, Janet Kauffman and Kathy Melmoth, R.N.
Click for Total Data in sortable Excel file

The Water Monitoring Project conducted by Environmentally Concerned Citizens of South Central Michigan (ECCSCM) and funded by a Community Action grant from Sierra Club, sampled 79 sites over two years in Hillsdale and Lenawee Counties. Sample sites were located throughout the Bean Creek Watershed and in part of the River Raisin Watershed. The purpose of the Project was to determine the impact to water quality of newly-constructed Confined Animal Feeding Operations (CAFOs), including 10 dairies, with 700-3,400 cows confined at each production facility. Most sites sampled were either adjacent to CAFO facilities or immediately downstream from manure-application fields.

ECCSCM volunteers sampled for E. coli bacteria and Dissolved Oxygen from 2001-2003, collecting a total of 430 water samples. Dissolved Oxygen was tested with a digital YSI 55 DO meter, and bacteria samples were transported as per the Quality Assurance Plan for testing at a DEQ-certified lab. Monitoring was conducted at 10-12 sites twice a month during most months, with weekly samples during the summer of 2002.

The Monitoring Project focused on specific sites of concern, given the recent change in agricultural land use. Whenever possible, sites were selected that drained only fields with manure-application, or as close as possible downstream, so that bacteria sources were limited. This Project was not intended to study water quality generally, or to be a comprehensive monitoring of all CAFOs.

Some critical sites were sampled repeatedly; others only sampled once or twice. During the two years, sites were added depending where manure application was taking place and at the request of citizens concerned about water quality in a particular stream stretch. All sample sites were accessible from road rights-of-way, either at stream crossings or at field tile outlets to road ditches, or by permission of private property owners.

270 of the 430 water samples tested violated Michigan's water standard for E. coli and/or Dissolved Oxygen. The E. coli standard for partial body contact such as wading is 1,000/100ml or lower. The DO standard is 5 mg/L or higher, for healthy aquatic life.

Major findings of the ECCSCM Monitoring Project include (see details below):
1)Identification of Streams of Concern
2)Liquid Manure Contamination through Field Drainage Tiles
These findings led to three recommendations to protect rural watersheds and drinking water sources (see details below).

Data from the ECCSCM project was submitted to the Michigan Department of Environmental Quality. DEQ frequently responded to test results showing extreme contamination. With their own confirming data, the DEQ cited several CAFOs for illegal discharges, including multiple violations in April 2002, March 2003, and the holiday period, December 2003. (For ECCSCM Total Data in sortable Excel file, click here)

Major Finding – 1 – Streams of Concern
The Monitoring Project documented serious water quality problems in several stream stretches near CAFOs. While most waterbodies where liquid manure was applied received some negative impact, these stream stretches showed critical, and repeated, impact.

In the River Raisin Watershed, Bear Creek and its tributaries Henning Drain and Rice Lake Drain (Hudson, Dover Townships, Lenawee County), had the most samples (64 of 86) which violated water standards.

In the Bean/Tiffin Watershed, where the largest CAFOs are located and apply the largest quantities of liquid waste, at least 3 stream stretches tested regularly were shown to be at serious risk:
Lime Creek Inlets to Lime Lake (Wright Twp, Hillsdale County)
Durfee Creek and its tributary Durfee Creek Extension (Medina Twp, Lenawee County)
Medina Drain and South Medina Drain (Medina Twp, Lenawee County)

However, sites downstream from every CAFO included samples that violated E. coli water standards. The DEQ, based on its own samples, has cited every CAFO for illegal discharges, more than 50 violations 2001-2003.

The ECCSCM monitoring frequently observed sharp spikes and plummets at sites downstream from CAFOs, indicating highly variable inputs of bacteria. In some cases, liquid manure applications coincided with bacteria spikes. In other samples, no change in practice was evident, although drain connections at CAFO facilities continue to be a concern as a possible pathway of the pollution. No smoke or dye testing of drains has ever been done at these facilities.

The Rice Lake Drain at Haley Road, one of the most worrisome sites during the 2 year project, demonstrates the bacteria spikes and drops. 20 of the 30 water samples taken violated water standards, either for DO or for E. coli, or both. In 4 samples, E. coli tested TNTC (Too Numerous To Count):

Date Sampled E. coli count  DO mg/L
2/25/2002           297            11.1
4/2/2002              99            11.2
6/24/2002        1,584             8.7
7/2/2002          3,564             6.8
7/9/2002          TNTC             4.5
7/15/2002           200             7.8
7/23/2002         TNTC             2.2
7/31/2002         5,940            3.1
8/14/2002           495             3.9
8/21/2002         TNTC             1.6
8/28/2002       14,790             0.3
10/14/2002         195              6.4
10/21/2002         297              6.9
11/11/2002     19,800             2.8
12/17/2002      4,400             11.8
2/20/2003        4,257              3.6
3/18/2003        6,930             10.2
3/27/2003             0                8.3
4/10/2003          198               10.3
4/21/2003          792               13.3
5/6/2003            297                9.4
5/14/2003          297                7.3
5/29/2003             0                5.1
6/12/2003      20,790               1.5
6/26/2003          792                1.9
7/10/2003             0                2.7
7/24/2003          425                1.7
7/24/2003             0                1.7
9/17/2003      98,010               1.1
11/3/2003      39,600                5.4
12/29/2003      TNTC               10.5

Toad Creek at Mulberry Road in the Bean/Tiffin Watershed also showed extreme spikes and drops in bacteria levels. The site included one of the highest E. coli readings, at 297,000/100 ml on November 11, 2002, as well as testing TNTC 3 times.

Date Sampled E. coli Count
8/28/2001          99
2/6/2002        TNTC
2/25/2002           0
3/13/2002      TNTC
4/2/2002          396
4/16/2002        297
5/29/2002      2,376
7/9/2002       5,940
7/15/2002     4,752
7/23/2002      TNTC
7/31/2002      6,930
8/14/2002      1,287
8/21/2002      1,683
8/28/2002        693
10/14/2002      297
11/11/2002 297,000
3/27/2003           0
7/24/2003         45
7/24/2003           0

Major Finding – 2 – Liquid Manure Contamination through Field Tiles
The ECCSCM project was important in bringing to public attention the serious problem of liquid manure discharges through field drainage tiles to streams. Nearly 100% of manure-application fields in Michigan are tile-drained, according to a study prepared for the Michigan Agriculture Environmental Assurance program, February 2004.

Most illegal manure discharges confirmed by the Department of Environmental Quality occurred after application of liquid manure to tiled fields, with the contaminated liquid percolating through the soils into drainage tiles, and flowing directly to streams.

During the Christmas holidays, 2003, for instance, after liquid manure application at many locations, 10 of 12 ECCSCM water samples (December 29, 2003) tested at bacteria levels Too Numerous To Count (TNTC). Four of those sites were field tile outlets flowing to Lime Lake Inlet from fields where Vreba-Hoff dairy CAFO had applied liquid manure.

Lime Lake Inlet sites tested TNTC eight times during the project, and exceeded the standard of 1,000/100 ml more than 30 times, including an E. coli count of 166,320/100ml on April 2, 2002.

Winter application on frozen ground, with no crops growing, is especially risky, often polluting through overland runoff first and then draining to tile inlets and flowing to sub-surface drains to streams. Rain, too, aggravates discharges through drainage tiles. Samples taken after 1/2" of rain on July 23, 2002, all violated water standards, incluidng 5 samples TNTC.  On June 12, 2003, samples taken in rain also all had excessive bacterial contamination. However, because animal waste is so liquefied, it can reach field tiles without rainfall.  ECCSCM monitoring found contaminated liquid discharging through tiles even in dry weather.

The ECCSCM monitoring project found that serious contamination of waterways occurred during spring thaws of both 2002 and 2003, during liquid manure applications following crop removal, and especially when tile lines were running. However, samples violating water quality standards and bacteria levels TNTC were found during every month of the year, including winter, when underground tiles sometimes still flowed, or liquid manure melted off the surface of fields and entered catch-basins to drains and streams.

While each discharge event is a critical pollution problem, chronic pollution is also a serious problem and needs further study.  Manure (sometimes called nutrient) pollution increases algal growth and lowers Dissolved Oxygen. This eutrophication process can be difficult to reverse. With very low DO levels, below 3 mg/L, many aquatic species are put at risk and fish die. Several streams in the ECCSCM project tested at catastrophically low DO levels. Throughout the summer of 2003, a tributary of Durfee Creek in Medina Township did not once register above 1 mg/L – this is a dead-zone for aquatic life.

Recommendations – To Protect Rural Watersheds
Given the extreme pollution documented in winter and spring thaws, in the discharge through tiles to streams, and given the repeated liquid-waste applications leading to chronic contamination of many waterways in the vicinity of CAFOs, ECCSCM recommends that, to protect our rural watersheds and drinking water sources:

1 – Michigan should immediately prohibit all winter application of liquid manure, December – March.

2 – Michigan should phase-out the application of liquid manure to tiled fields.

3 - Michigan should declare an immediate moratorium on new CAFOs until drier and non-polluting waste systems(1) and watershed-based policies(2) are in place.


(1)Drier waste systems are essential and must be a priority – including promotion of intensive rotational grazing/winter composting and an end to subsidies for CAFOs. On tile-drained fields, liquefied manure is a major pollutant. Stop-gap measures such as tile plugs or gate-valves delay, but do not stop, the flow of contaminants. Frequently these plugs failed or blew out tiles in fields, resulting in overland flow of contaminated liquid. ECCSCM members have met with Michigan State University researchers as well as DEQ and the Michigan Department of Agriculture, to discuss alternatives to the liquid/lagoon system of waste handling at CAFOs. Agriculture is the only industry not required to treat its waste.

(2)The location/siting/expansion rules concerning CAFOs must be watershed-based and must be required (not voluntary as now in Michigan). Herd-size reduction should be required in some small watersheds. While numbers of cows in Hillsdale and Lenawee counties have declined in the last decade as the scattered, small dairies were sold, much larger numbers of cows have been concentrated in a few locations and in certain small drainage areas – especially the Bean/Tiffin Watershed – where the liquefied waste from approximately 8,500 cows is now sprayed on tiled fields in the immediate vicinity of the CAFOs. In the first half of the 20th century, through the 1960’s, industrial and municipal facilities also localized large quantities of chemical and human waste, with non-existent or insufficient treatment. Since the Clean Water Act of 1972 and subsequent upgrades, industrial and municipal sources of pollution have sharply decreased. Livestock production, on the other hand, continues to apply larger and larger volumes of waste – each CAFO equivalent to a city of 15–60,000 people – with non-existent wastewater treatment.

During May and June 2003, Eastern Michigan University researcher Jill Pernicano, Department of Biology, accompanied Janet Kauffman on sampling runs, and conducted an intensive study of Dissolved Oxygen, with pre-dawn and mid-day samples taken every other week at 10 sites. Pernicano also sampled for turbidity and nitrates, finding two sites with especially high nitrate concentrations at Bear Creek and Medina Drain, with NO3-N levels as high as 30 mg/L and 27 mg/L respectively. Her report, Effects on Watersheds of Organic Waste from Confined Animal Feeding Operations near Hudson, Michigan, is available upon request. Her conclusion states in part: “All ten sampling sites were substantially impacted by manure runoff from nearby CAFOs... Nitrate levels were also high, especially when viewed in the context of unpolluted rivers. Organic pollution originating from CAFOs has both environmental and public health implications, which must be addressed.”

In addition, Dr. Joan Rose, Homer Nowlin Chair of Water Research at Michigan State University, and MSU graduate assistants accompanied the monitoring run of July 24, 2003, taking additional samples. Dr. Rose is an internationally-known authority in cryptosporidium and source tracking.


For Total Data, ECCSCM Water Monitoring Project, in an Excel spreadsheet sortable by date, location, and other variables, click here.

Assorted Summaries of Samples Taken
79 sites, 430 water samples taken, 270 showed unacceptably poor water quality

The worst stream stretches, with most samples violating water standards, were:
Stream Stretch -- #of samples violating water standards for E. coli and/or DO:
            River Raisin Watershed:
Bear Cr -- 64 (of 86 samples, at 7 sites)
            Bean/Tiffin Watershed:
Lime Cr/Lime Lake -- 42 (of 82 samples, at 7 sites)
Medina Drain-- 33 (of 43 samples, at 2 sites)
Toad Creek -- 25 (of 40 samples, at 4 sites)
Durfee Creek-- 18 (of 31 samples, at 4 sites)
Squawfield Drain -- 10 (of 10 samples, at 1 site)

The worst individual sites sampled, with the most samples violating water quality standards were:
Site -- # of samples violating water standards (highest E. coli counts, and/or lowest DO;TNTC = E. coli Too Numerous To Count
South Medina Drain (Ingall Hwy) -- 22 (TNTC 2 times; DO 1.8mg/L on 3-18-03)
Bear Creek (Beecher Rd) -- 22 (TNTC on 5-15-02; 27,720/100ml on 11-11-03)
Rice Lake Drain (Haley Rd) -- 20 (TNTC 4 times; 98,010/100ml on 9-17-03)
Lime Lake Inlet (Lime Lake Rd) -- 18 (TNTC 3 times; 166,320/100ml on 4-2-02)
Durfee Cr Ext (Dillon Hwy) -- 18 (DO 0.5mg/L on 6-24-02)
Toad Cr (Coman Rd) -- 12 (TNTC on 3-13-02)
Lime Lake Inlet East (Lime Lk Rd) --12 (166,320/100ml on 4-2-02)
Medina Drain (Ingall Hwy) -- 11 (TNTC 2-6-02; DO 3.8mg/L on 7-9-02)
Toad Cr (Mulberry Rd) -- 11 (TNTC 2 times; 297,000/100ml on 11-11-02)
Drain (Squawfield Rd) -- 10 (DO 0.2mg/L on 6-26-03)

Townships and number of samples violating water quality standards:
Township -- # of samples that violated water standards
Medina --  82
Wright --   67
Hudson --  49
Dover --    26
Pittsford --17
Rollin --      8
Seneca --   8
Rome--       4
Somerset-- 3