-------
December 15, 1965
417
Re: Erie County
Perkins Township
Industrial Wastes
Bechtel-Mclaughlin, Inc.
P. 0. Box 948
Sandusky, Ohio 448?0
Gentlemen:
As a result of Board Action December 14, 1965.>
enclosed Is renewal permit for the discharge of Industrial
wastes from your establishment Into "waters of the state"
pursuant to the provisions of the Water Pollution Control
Act of Ohio.
You will note that this permit expires July 1,
1966. Renewal of this permit is contingent upon compliance
with the following Orders:
1. The satisfactory maintenance and operation
of the facilities provided thus far for
treatment and disposal of cyanide-bearing
increments of the industrial wastes of this
plant.
2. The elimination of all discharges of strong
acids, chromium-bearing wastes, and other
metal-bearing waste increments to waters of
the state prior to the expiration date of
this permit.
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418
3. The submission to the Division of Engineering,
at regular monthly intervals, of reports to
include information regarding flow volumes
and pertinent analytical data on the
industrial waste discharges.
4. The prompt reporting to the Division of
Engineering of the occurrence and cause of
any accidental or intermittent discharges
of wastes which may have a deleterious effect
on the receiving stream.
5. The submission to the Division of Engineering
of information pertaining to any plant
expansion or process changes which may
affect the character of the industrial
waste discharges, together with a proposal
for providing controls for such discharges
so that there will be no deleterious effect
on the receiving stream.
6. The submission of a proposal for compliance
with the Conclusions and Recommendations of
the Lake Erie Conference (copy enclosed),
with special reference to Sections 12, 13,
16, 17, and 18.
Should you have any questions with respect to the
above Orders, please notify us promptly.
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419
Yours very truly,
E. W. Arnold, M.D., Chairman
Water Pollution Control Board
Enc.-Permit 944.15
-Recom. & Concl.
Certified mail
cc: Health Commissioner
cc: District Office
# # * # #
Re: Lucas County
Washington Township
Industrial Wastes March 28, 1966
Doehler-Jarvis Division
National Lead Company
1945 Broad Avenue
Toledo, Ohio 43601
Gentlemen:
Enclosed is renewal permit for the discharge
of industrial wastes from your Toledo Plant No. 2 into
the "waters of the state" pursuant to the provisions of
the Water Pollution Control Act of Ohio.
You will note that this permit expires February
1, 1967. Renewal of this permit is contingent upon
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420
compliance with the following conditions:
1. The satisfactory maintenance and operation
of facilities provided thus far for the
reclamation and controlled discharge of
industrial wastes incident to the manu-
facturing processes of this plant; submitting
to the Division of Engineering, Ohio Depart-
ment of Health, at regular monthly intervals,
reports to include information and analytical
data pertinent to the definition of the
industrial wastes as discharged to the
receiving stream.
2. The prompt reporting to the Division of
Engineering of the occurrence and cause of
any accidental- or intermittent discharges
of wastes which may have a deleterious effect
on the receiving stream.
3- The submission to the Division of Engineering
of information with respect to proposed
plant expansion or changes in processes
together with a proposal with respect tc
adjustments or improvements of wastes treat-
ment facilities consistent with such
expansions or changes in processes.
4. The submission prior to April 15 > 1966, of
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421
a proposal for complying with the Recom-
mendations and Conclusions of the Lake
Erie Conference, as requested in a letter
dated December 29, 1965 > giving particular
emphasis to Sections 12, 13, 16, 17 , and 18.
5. The submission to and approval by the Ohio
Department of Health of detail plans of
proposed facilities for the satisfactory
treatment of the industrial wastes of this
plant in accordance with Section 15 referred
to above.
Should you have any questions with respect to the
above conditions, please notify us promptly.
Yours very truly,
E. W. Arnold, M.D., Chairman
Water Pollution Control Board
Enc. -Permit 978. 11
Certified mail
cc: Div. of Air & Water Poll. Control
cc : Mr. H. H. Jacobson
cc : Health Commissioner
cc : District Office
* * *
-------
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424
June 8, 1966
Re: Lake County
Painesville Township
Ind. Wastes-Sew.
IRC Fibers Division
Midland Ross Corporation
P. 0. Box 580
Painesville, Ohio 44077
Gentlemen:
Enclosed is renewal permit for the discharge
of industrial wastes and sanitary sewage from your
establishment into the "waters of the state" pursuant
to the provisions of the Water Pollution Control Act and
to the statement of policy of the Board dated February 24,
1953.
You will note that this permit expires February
1, 1967. Renewal of this permit is contingent upon
compliance with the following conditions:
1. The submission to and approval by the
Ohio Department of Health of detail plans
of terminal facilities for the neutraliza-
tion of acids and the precipitation of zinc
and related settleable solids from the
increments of the industrial wastes of this
plant designated as "C2" and "H3", together
with a schedule of construction of these
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425
facilities.
2. - The submission to and approval by the Ohio
Department of Health of detail plans of
facilities for secondary treatment of the
sanitary sewage of this plant together with
a schedule of construction of these
facilities.
3. The satisfactory maintenance and operation
of facilities provided for the clarification
of the ash-bearing wastes of this plant;
submitting to the Division of Engineering,
Ohio Department of Health, at regular monthly
intervals, reports to include information and
analytical data pertinent to the performance
of these facilities and pertinent to the
definition of critical waste loads discharged
to waters of the state.
4. The satisfactory maintenance and operation
of the facilities provided thus far for the
treatment and disposal of sanitary sewage
of this plant; submitting to the Division
of Engineering, at regular monthly intervals,
reports to include information and analytical
data pertinent to the operation and performance
of these facilities.
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426
5. The continued submission to the Division
of Engineering, at regular monthly inter-
vals, of information and analytical data
pertinent to the definition of the critical
industrial waste loads of the significant
increments of industrial wastes of this plant
discharged to waters of the state.
Should you have any questions with respect to
the above conditions, please notify us promptly.
Yours very truly,
E. W. Arnold, M.D., Chairman
Water Pollution Control Board
Enc.-Permit 7^7.14
Certified mail
cc: Health Commissioner
cc: District Office
*****
Re: Wickliffe
Industrial Wastes June 8, 1966
The Lubrizol Corporation
Box 3057, Euclid Station
Cleveland, Ohio
Gentlemen:
-------
427
Enclosed is renewal permit for the discharge
of industrial wastes from your establishment into "waters
of the state" pursuant to the provisions of the Water
Pollution Control Act and to the statement of policy of the
Board dated February 24, 1953.
You will note that this permit expires April 1,
1967. Renewal of this permit is contingent upon compliance
with the following conditions:
1. The satisfactory maintenance and operation
of industrial wastes treatment facilities
which have been provided at this plant.
2. The continued submission to the Division
of Engineering., Ohio Department of Health,
at regular monthly intervals, of reports
to include information and analytical data
pertinent to the operation and to the per-
formance of the industrial wastes treatment
facilities.
3. The continuation of the studies which have
been initiated for the determination and
segregation of the critical increment of
the industrial wastes discharged; submitting
to the Ohio Department of Health a report
setting forth the findings and proposal for
the satisfactory treatment and disposal,
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428
reduction, or elimination of the critical
constituents of this waste.
4. In the event additional wastes treatment
facilities are proposed to comply with the
provisions of Condition 3 (above), the
submission to and approval by the Ohio
Department of Health of detail plans of the
proposed treatment devices or facilities.
Should you have any questions with respect to
the above conditions, please notify us promptly.
Yours very truly,
E. W. Arnold, M.D., Chairman
Water Pollution Control Board
Enc.-Permit 1182.12
Certified mail
cc: Health Commissioner
cc: District Office
*****
Re: Ottawa County
Erie Township
Industrial Wastes March 18, 1966
United States Rubber Company
Erie Army Depot
-------
429
P.O. Box 488
Port Clinton, Ohio 43452
Attention Mr. Frederick E. Weber, Factory Manager
Gentlemen:
As a result of Board action March 8, 1966,
enclosed is permit for the discharge of industrial wastes
from your establishment into the "waters of the state"
pursuant to the provisions of the Water Pollution Control
Act and to the statement of policy of the Board dated
February 24, 1953.
You will note that this permit expires December
1, 1966. Renewal of this permit is contingent upon
compliance with the following conditions:
1. The provision and operation of temporary
expedients for control of industrial wastes
characteristics as outlined in the letter
and report of January 26, 1966.
2. The submission to the Division of Engineering,
Ohio Department of Health, at regular monthly
intervals, of reports setting forth
industrial wastes characteristics as dis-
charged and adequate information to define
the effects of the discharge on the waters
of Lake Erie.
3. The submission to and approval by the Ohio
Department of Health of detail plans of
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430
facilities for the satisfactory treatment
and disposal of the industrial wastes of
this plant.
4. The construction of the proposed industrial
wastes treatment facilities in accordance
with approved plans.
Should you have any questions with respect to
the above conditions, please notify us promptly.
Yours very truly,
E. W. Arnold, M.D., Chairman
Water Pollution Control Board
Enc.-Permit 1958
Certified mail
cc : Health Commissioner
cc: District Office
* * *
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431
APPENDIX III
RECOMMENDATIONS AND CONCLUSIONS
OF THE LAKE ERIE CONFERENCE
# * * #
RECOMMENDATIONS AND CONCLUSIONS
(Agreed upon by Conferees from Michigan, Indiana, Ohio,
Pennsylvania, New York and U. S. Public Health Service
following conference under Section 8 of the Federal Water
Pollution Control Act in the matter of pollution of the
interstate and Ohio intrastate waters of Lake Erie and
its tributaries held in Cleveland, Ohio, August 3-6, 1965,
and in Buffalo, New York, August 10-12, 1965.)
1. The waters of Lake Erie within the United States are
interstate waters within the meaning of Section 8 of
the Federal Water Pollution Control Act. The waters of
Lake Erie within the United States and its tributaries
covered by sessions of this Conference are navigable
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432
waters within the meaning of Section 8 of the Federal
Water Pollution Control Act.
2. Lake Erie and many of its tributaries are polluted.
The main body of the Lake has deteriorated in quality
at a rate many times greater than its normal aging
processes, due to inputs of wastes resulting from the
activities of man.
3. Identified pollutants contributing to damages to water
uses in Lake Erie are sewage and industrial wastes,
oils, silts, sediment, floating solids, and nutrients
(phosphates and nitrates). Enrichment of Lake Erie,
caused by man-made contributions of nutrient materials,
is proceeding at an alarming rate. Pollution in Lake
Erie and many of its tributaries causes significant
damage to recreation, commercial fishing, sport fishing,
navigation, water supply, and esthetic values.
4. Eutrophication or over-fertilization of Lake Erie is of
major concern. Problems are occurring along the lake
shoreline at some water intakes and throughout the lake
from algal growths stimulated by nutrients. Reduction
of one or more of such nutrients will be beneficial in
controlling algal growths and eutrophication.
5. Many sources of waste discharge reaching Lake Erie
have inadequate waste treatment facilities. The delays
in controlling this pollution are caused by the lack
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433
of such adequate facilities and the complex municipal,
industrial, financial and biological nature of the
problem.
6. Interstate pollution of Lake Erie exists. Discharges
into Lake Erie and its tributaries from various sources
are endangering the health or welfare of persons in
states other than those in which such discharges
originate, and in large measure this pollution is
caused by nutrients which over-fertilize the lake.
This pollution is subject to abatement under the
Federal Watep Pollution Control Act.
7. Municipal wastes be given secondary treatment or treat-
ment of such nature as to effectuate the maximum reduc-
tion of BOD and phosphates as well as other deleterious
substances.
8. Secondary treatment plants be so designed and operated
as to maximize the removal of phosphates.
9. Disinfection of municipal waste effluents be practiced
in a manner that will maintain coliform concentrations
not to exceed 5>000 organisms per 100 ml at public water
supply intakes, and not to exceed 1,000 organisms per
100 ml where and when the receiving waters in proximity
to the discharge point are used for recreational purposes
involving bodily contact-- It is recognized that bathing
water quality standards are established by statute
-------
in New York State.
10. All new sewerage facilities be designed to prevent
the necessity of bypassing untreated waters.
11. Combined storm and sanitary sewers be prohibited in
all newly-developed urban areas, and eliminated in
existing areas wherever feasible. Existing combined
sewer systems be patrolled and flow-regulating
structures adjusted to convey the maximum practicable
amount of combined flows to and through treatment plants
12. Program be developed to prevent accidental spills of
waste materials to Lake Erie and its tributaries. In-
plant surveys with the purpose of preventing accidents
are recommended.
13. Unusual increases in waste output and accidental spills
be reported immediately to the appropriate State agency.
14. Disposal of garbage, trash, and other deleterious refuse
in Lake Erie or its tributaries be prohibited and
existing dumps along river banks and shores of the
Lake be removed.
15. The conferees meet with representatives of Federal,
State and local officials responsible for agricultural,
highway and community development programs for the
purpose of supporting satisfactory programs for the
control of runoff which deleteriously affects water
quality in Lake Erie.
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435
16. Industrial plants improve practices for the segregation
and treatment of waste to effect the maximum reductions
of the following:
a. Acids and alkalies.
b. Oil and tarry substances.
c. Phenolic compounds and organic chemicals
that contribute to taste and odor problems.
d. Ammonia and other nitrogenous compounds.
e. Phosphorus compounds.
f. Suspended material.
g. Toxic and highly-colored wastes.
h. Oxygen-demanding substances.
i. Excessive heat.
j. Foam-producing discharges.
k. Other wastes which detract from recreational
uses, esthetic enjoyment, or other beneficial
uses of the waters.
17. The Michigan, Indiana, Ohio, Pennsylvania and New York
Water Pollution Control Agencies undertake action to
insure that industrial plants discharging wastes into
waters of Lake Erie and its tributaries within their
respective jurisdictions institute programs of sampling
their effluents to provide necessary information about
waste outputs. Such sampling shall be conducted at
such locations and with such frequency as to yield
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436
statistically reliable values of all waste outputs
and to show their variations. Analyses to be so
reoorted are to include where applicable: pH, oil,
tarry residues, phenolics, ammonia, total nitrogen,
cyanide, toxic materials, total biochemical oxygen
demand, and all other substances listed in the pre-
ceding paragraph.
18. Waste results be reported in terms of both concentra-
tions and load rates. Such information will be main-
tained in open files by the State agencies for all
those having a legitimate interest in the information.
19. The Department of Health, Education, and Welfare
establish water pollution surveillance stations at
appropriate locations on Lake Erie. Surveillance
of the tributaries will be the primary responsibility
of the States. The Department of Health, Education,
and Welfare will assist the States at such times as
requested.
20. The Department of Health, Education, and Welfare will
be responsible for developing up-to-date information
and experience concerning effective phosphate removal
and control of combined sewer systems. This informa-
tion will be reported to the conferees regularly.
21. Regional planning is often the most logical and
economical approach toward meeting pollution problems.
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437
The water pollution control agencies of Indiana,
Michigan, Pennsylvania, New York and Ohio, and the
Department of Health, Education, and Welfare will
encourage such regional planning activities.
22. Within six months after the issuance of this Summary,
the State water pollution control agencies concerned
will present a schedule of remedial action to the
Conferees for their consideration and evaluation.
23. The Federal Conferee recommends the following for
the consideration of the State agencies :
a. Recommended municipal treatment - Completion of
plans and specifications August 1966$ completion
of financing February 19^7j construction started
August 19^7) construction completed January 1,
1969; chlorination of effluents May 15, 1966;
provision of stand-by and emergency equipment
to prevent interruptions in operation of municipal
treatment plants August 1966; patrolling of com-
bined sewer systems immediately.
b. Discontinuance of garbage and trash dumping
into waters immediately.
c. Industrial waste treatment facilities to be
completed and in operation by January 1, 1969.
24. Federal installations waste treatment facilities to
be completed and in operation by August of 1966.
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438
25. Representatives of the United States Corps of
Engineers meet with the Conferees, develop and put
into action a satisfactory program for disposal of
dredged material in Lake Erie and its tributaries
which will satisfactorily protect water quality.
Such a program is to be developed within six months
after the issuance of this Summary and effectuated
as soon as possible thereafter.
26. The conferees will establish a Technical Committee as
soon as possible which will evaluate water quality
problems in Lake Erie relating to nutrients and make
recommendations to the conferees within six months after
the issuance of the summary of the conference.
27. The Conference may be reconvened on the call of the
Chairman.
At the conclusion of the Cleveland session of the
conference the following was included among the conclusions
and recommendations of the conference:
"Pollution of navigable waters subject to
abatement under the Federal Water Pollution Control
Act is occurring in the Ohio waters of Lake Erie and
its tributaries. The discharges causing and
contributing to the pollution come from various
municipal and Industrial sources, from garbage,
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439
"debris, and land runoff.
"Pollution of the Ohio waters of Lake Erie
and its tributaries within the State of Ohio
endangers health and welfare."
A question has been raised concerning the juris-
diction of this conference over intrastate Ohio waters.
The conferees agreed to present this question to the
Secretary of Health, Education, and Welfare and the Governor
of Ohio for clarification and resolution.
*****
-------
G. Eagle
MR. STEIN: Are there any comments or questions
from the conferees?
A VOICE FROM THE AUDIENCE: Mr. Stein, may I
ask a question?
MR. STEIN: No, just the conferees. If Ohio
wishes their participants later, we will be glad to hear
from them.
MR. POSTON: I noted under the industrial data
comments on Page 6, that you said that it is expected that
full conformity with Item 17 will be attained in the next
six months to a year.
We have had difficulty getting information
relative to industrial waste discharges as to the quantities
from individual sewers and the analysis of these particular
data.
Would you say now that in six months' time we
would be able to get full industrial data in the Lake Erie
Basin portion or Ohio portion of the Lake Erie Basin?
MR. EAGLE: Well, even in less time than that,
Mr. Poston.
I think we are pretty well satisfied as far as
the requirements for the comprehensive survey group are
concerned, at least.
As to the data on the Maumee Basin, there are
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G. Eagle
just a couple of little details to be worked out. I don't
anticipate any trouble here.
We are in the process of getting it on the
Cuyahoga now, and some of this is already coming in, so I
would say that we could have this to you well within the
six-month period.
MR. POSTON: Well, in regard to the Cuyahoga
River Basin, we have not been satisfied with industrial
waste information. It just hasn't been there.
MR. EAGLE: Well, I don't know whether we have
gotten into the complete detail of this.
You have requested us -- and we are now in the
process of clearing this with the industries and getting
it made available to you.
As I say, we are supposed to have this completed
well within the six-month period. Frankly, most of this
approach has been more in the discussion stage rather than
in a stage of actually submitting figures and data.
MR. STEIN: I wonder if I may clarify this
before we go to Mr. Quigley, because I have been getting
correspondence on this.
Mr. Poston, I have seen letters back and forth
where you have asked for data. Are you satisfied with the
data you are getting from Ohio?
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442
G. Eagle
MR. POSTON: Well, we don't have any data on
the Cuyahoga River on industrial
MR. STEIN: Wastes.
MR. POSTON: Industrial wastes.
MR. STEIN: Have you asked for it?
MR. POSTON: Yes, sir. We have asked both the
industries and the State for this information.
MR. STEIN: Well, I think the question here is,
if this is so, can Mr. Poston expect to get this data?
MR. EAGLE: Yes, sir.
MR. STEIN: When?
MR. EAGLE: As I claim, we are in the process of
getting it for you.
MR. STEIN: When? Do you have any dates of when
he can expect this to be?
MR. EAGLE: Well, within the six-month period, as
I said in the report here, and I would hope that within
two or three months we will be able to give him at least
90 percent of it.
We may have to go out and get some more informa-
tion ourselves, but I would expect that we could satisfy
this within a relatively short time.
MR. STEIN: Mr. Quigley?
MR. QUIGLEY: Mr. Stein, I would merely like to
comment, in Secretary Udall's absence, I am almost certain
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G. Eagle
I know the man well enough to know that If he were here In
the afternoon session and heard this colloquy, that he
would have said -- at least, I am assuming he would have
said, and he can contradict me if I am wrong, but I don't
think I am -- if he is looking ror candidates for his
lists of filthy industry, it seems to me that you would
have some likely nominees.
It seems to me that any industry that won't
come clean and reveal the facts, whether they are pleasant
or unpleasant, deserves the full focus of sharp public
attention. This I think Secretary Udall made clear this
morning. He intends to focus public attention on any
industry or any city that just won't face up to its
responsibility in this area.
Now, I am new on this particular assignment. I
don't know the details of any discussion. I don't know what
the holdups might be. But I think it is only fair to serve
notice on any industries in the State of Ohio or anywhere
else in the Basin involved in this Meeting, or, for that
matter, anywhere else in the country, that won't cooperate that
you give us little or no choice but to go one of two ways: l)
the way the Secretary referred to today, and that is to ask
the Congress to give us additional legislative authority for
plant inspection and the right of entry,or 2) the full force
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444
G. Eagle
of public attention.
We will do it either way, but I don't think
anybody should have any doubt when the Meeting breaks up
that we are going to do it.
We have to know what the facts are. We have to
know what the pollution situation is before we can
intelligently move to spell out a proper, sound, corrective
timetable. I think the time has come -- and, in case
anybody doesn't realize that it has, the purpose of my
remarks at this point in the record is to make it clear
-- we are going to quit fooling around.
We want the facts, nothing but the facts -- the
hard or unpleasant ones as well as the glowing ones. This
is the only way that we can accomplish the job.
Having just returned from a luncheon cruise on the
Cuyahoga, I am fascinated by the fact, Mr. Eagle, that on
Page 6 of your report you indicate, "It may be of interest
to the conferees to know that the major industries,
municipalities and counties in the Cuyahoga River Basin
formed a committee about two years ago ... and the major
functions of this committee are: (l) To determine existing
river water quality; (which I could answer for them right
now on the basis of an hour and a half's exposure) (2) To
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G. Eagle
determine the causes of changes in water quality; (I think
I could pretty near write that part of the report in five or
ten minutes) (3) To determine the treatment or control
requirements necessary to upgrade and maintain water
quality for all reasonable and legitimate uses..."
It seems to me that any treatment would auto-
matically result in the upgrading of the quality of a
river such as the Cuyahoga.
Then there is the fourth function. This one, I
confess, I am not able to answer off the top of my head.
This may be why it has taken two years for the committee to
report, but the fourth assignment is: "To determine the
cost of such requirements."
Now, I would be frankly interested in knowing --
and I think it ought to be spread on the record -- the make-
up of this committee; who is serving as its chairman; when
was the last time it met; and when is a report of the kind
that has been referred to here likely to be forthcoming?
1 think it is important that if an industrial
committee, a committee made up of public officials, represent-
ing the counties and the municipalities in that river basin,
were formed two years ago, that it is almost time for at
least a preliminary report.
Now, how would we go about finding out if the
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G. Eagle
committee is still functioning and if a report has ever
been made and if it is likely to be made. If it is, how
might the conferees become privy to it?
MR. EAGLE: Well, Mr. Quigley, the committee is
made up by representatives of principal industries. Mr.
Charles Loundsbury, who is the manager of the duPont Company
here in Cleveland, is the chairman of this committee. Mr.
Walter Godell, who is the Director of the Water Pollution
Control Agency here in the City of Cleveland, is a member,
as well as a representative from Akron and the other major
cities in the Basin. There are some sanitary engineers
who are members of this committee.
They have met as recently as a month ago. They
have several subcommittees that are at work and meet some-
times two or three times a month for a considerable time.
They have made an intensive sampling program of
the river, and perhaps will do another one or two after
they have been able to evaluate this information.
Frankly, this is a very complex situation. We
have many different types of industries that are discharging
in a rather limited stretch of water here in the Cleveland
area, and they are trying to evaluate the problem and then
to come up with a program, each industry come up with a
program, which will be reviewed by the other people, the
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G. Eagle
experts, because they are all affected, to see if this
would be adequate to Improve the water, which In their
opinion would suffice so far as the best Interests of the
public are concerned.
Now, this is admittedly an industry-municipal
committee, and while this information will be helpful to
the State, it certainly is not going to influence our best
judgment and consideration.
This is simply a collection of information and
the making of recommendations that would be of assistance.
We propose within the year, of course, to hold hearings here
at Cleveland, to set up water quality criteria and standards
for Lake Erie as well as the Cuyahoga River, which is an
influencing tributary of Lake Erie. I think this will be
laid out on the table and the Water Pollution Control Board
will make a decision which will be forwarded to you for your
approval with respect to the quality of the water we expect
to have in the Cuyahoga River, and how soon we expect to
attain this.
MR. QUIGLEY: What did you say the chairman's
name was?
MR. EAGLE: Mr. Charles Loundsbury, who is the
manager of the duPont Company in Cleveland, Ohio.
MR. QUIGLEY: Let me ask you one other question
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G. Eagle
on a slightly different phase.
I fioticed the several letters that Dr, Arnold
has sent out to the municipalities. I haven't had a chance
to go through the appendix of the report in detail, but
I am assuming comparable letters were sent to industrial
polluters who are not now in full compliance with the
terms of the permit,. What can the State of Ohio do at the
present time if a city, or, for that matter, an industry
fails to meet the terms which you attach to granting a
permit?
MR. EAGLE: The Water Pollution Control Board
conducts a show-cause hearing why the permit should not be
denied, and if the permit is denied and we do not obtain
compliance within the specified legal limits established,
then it is referred to the courts.
MR. QUIGLEY: And what, may I ask as a lawyer,
with full respect intended for the bench, can the courts do?
MR. EAGLE: The courts can fine the responsible
officials.
MR. QUIGLEY: Have they done this?
MR. EAGLE: No, sir, they have not done this.
We have closed down some industries because of very flagrant
violations for limited times so they could make the necessary
improvements.
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G. Eagle
This has been done by order of the Board, and
while we have not tested this in the courts, they did comply
with the cease-and-desist order.
In the case of municipalities, we find our most
effective weapon to date to be a freeze on any additionaj.
building or any additional connections to the sewer system
which are tributary to an already inadequate, overloaded
plant, or no plant in some cases. Of course, placing a
building freeze on this has brought results faster than
most any other action.
MR. QUIGLEY: How long has Ohio had the permit
system?
MR. EAGLE: Since 1951.
MR. QUIGLEY: I have no further questions.
MR. STEIN: Are there any other comments or
questions?
(No response. )
MR. STEIN: I have one just for clarification.
You talked about completion in 1970 and 1971 of
plants at Cleveland and Akron. Can we sort those out?
Which one is 1970, and which one is 1971?
MR. EAGLE: I think we would have to go back to
the tables, Mr. Stein. I am not sure what we do say on the
tables. They are on the Cuyahoga River Basin, and we have
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G. Eagle
a lot of things in this index, Appendix II.
I would stress, Mr. Stein, that as to both of
these cities we are talking about, they have secondary
treatment plants now,
MR. STEIN: Well, not all of the plants in
Cleveland are secondary, are they, Mr. Eagle?
MR. EAGLE: Yes, but this is the one I am talking
about in this connection.
Now, I didn't give you a detailed breakdown on
Cleveland here. I think maybe you will find it back under
the Cuyahoga River Basin.
MR. STEIN: The reason I am asking, and I think
this is a relatively vital question, is if we are going
to establish a time-table for the clean-up of major dis-
charges into Lake Erie, I think the question of whether
you are proposing that Cleveland be completed in 1970 or
1971 assumes some significant proportions.
MR. EAGLE: Yes. Under the Cleveland breakdown
you will note that as to westerly plant, which is now a
primary plant, we are scheduled to have a report and
general plan this year in September, which will outline
what needs to be done and set up a schedule for these
improvements. jn our discussions with the c'ity officials
in Cleveland, we anticipate that this will take two to three
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G. Eagle
years, and therefore will be well ahead of this 1970 and
1971 date.
MR. STEIN: In other words, you think Cleveland
can be all completed and In operation by 1970?
MR. EAGLE: Well, so far as secondary treatment
is concerned, yes, sir; but all of these plants constantly
need enlargement and improvement. This is what we have
pointed out with the 1970 and 1971 dates.
MR. STEIN: I understand that, but will they be
in compliance with the recommendations of the conferees?
MR. EAGLE: Yes, sir. So far as secondary
treatment is concerned, yes, sir.
MR. STEIN: I don't have any further questions.
Are there any other questions?
(No response.)
MR. STEIN: If not, thank you very much for Ohio.
I have just one comment. I didn't want to spend
time this morning on commendations. One is for Michigan.
As I say, I don't think your record is so bad.
How many individual sources did you have up
there 37?
MR. OEMING: 36 individual waste disposers.
MR. STEIN: They got compliance on 35. That is
only one off. From our experience with a lot of enforcement
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G. Eagle
cases, I think that is a pretty good record of stipulations
with 35.
We have heard from the Federal installations.
Of course, we have that one outside the BasJn, but in the
Basin they are all going. One is a little behind, but that
is going too. I think that is pretty good.
I have been dealing with Ohio for many years,
and they have with us. I hope we are getting more friendly
all the time, but this is certainly the most optimistic
report I have heard from Ohio, and I think we are talking
the same language.
MR. EAGLE: Thank you.
MR. STEIN: I think this is very good.
I wonder if we can go on to Indiana?
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B. A. Poole
STATEMENT OP BLUCHER A. POOLE, CONFEREE
AND TECHNICAL SECRETARY, INDIANA STREAM
POLLUTION CONTROL BOARD
MR. POOLE: Commissioner Quigley, Chairman Stein,
Fellow Conferees and Ladies and Gentlemen:
Shortly after the August 19^5 conference, the
State of Indiana mailed a copy of the conclusions and
recommendations to each municipality which had a sewer
system, and to each industry that maintained a separate
outlet into the Indiana waters of the Lake Erie Basin.
With that letter of transmittal, we checked the
various items of the conclusions of the conferees that
applied to the particular installation under discussion,
and requested action to comply with the conferees' recom-
mendations .
There follows a very brief summary of the situa-
tion insofar as Indiana is concerned.
1. All municipalities with sewer systems have
secondary sewage treatment works in operation.
2. The City of Fort Wayne has submitted a
request for a Federal grant to construct a pilot plant to
reduce phosphates in the waste water treatment plant. The
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B. A. Poole
Federal Water Pollution Control Administration has not as
yet acted on the request of the city.
I might add here that there have been various
and sundry efforts made in the Fort Wayne sewage treatment
plant during the past several months by way of altering
operation procedures to see what could be accomplished in
the way of phosphate removal with the addition of silting,
and I believe everybody requires a modern activated sludge
plant.
Unfortunately, there at Fort Wayne, we have not
had too much luck. That is, the average phosphate removals
have been in the neighborhood of perhaps 12, 15 and maybe
some 20 percent, but certainly not to the point that was
indicated insofar as the problem in Lake Erie is concerned,
I am hopeful that we can go forward at Fort
Wayne with this pilot project, which is in the middle.
3. The City of Garrett advised the Board it will
install effluent chlorination facilities and the City of
£uburn has included such facilities in its expansion program
to protect the Fort Wayne public water supply souce. The
Cities of Fort Wayne and New Haven have not been requested
to install effluent chlorination facilities pending the
establishment of water quality criteria and a determination
of water uses for the Maumee River.
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B. A. Poole
i might point out that we are in touch with
Ohio., and under the Water Quality Act of 1965, Ohio will be
holding its hearings, I think perhaps a little before
Indiana, with respect to water quality criteria for the
Maumee, but I can assure you that these will be worked
together and we will get into harmony. If, as I anticipate,
it develops that there are body-contact water uses in Ohio
within the reach of Port Wayne and New Haven, I assure you
that the Indiana Board will require chlorination at these
facilities.
4. All industries requested to institute
effluent monitoring programs with the exception of Kitchen-
Quip, Inc., Waterloo, are now sampling or have agreed to
sample waste effluents. These data are maintained in open
files.
5. Five industrial plants have improved or
constructed new treatment works since the conference in 1965
6. Of the 21 industrial plants in the basin,
thirteen have adequate waste control facilities and eight
need additional treatment works.
I think, as I reported in August last year, that
the monitoring program in Indiana is very adequate for the
waters under consideration. There are stations on the St.
Joe and St. Mary shortly after they enter the State of
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B. A Poole
Indiana, and there are two stations on the Maumee between
the City of Fort Wayne and the State line,
70 Water quality data at highway 101 approxi-
mately two miles from the State line on the Maumee River
show the minimum dissolved oxygen was 5.3 mg/1 in 1965.
This indicates the Maumee River waters are of about as good
quality as presently known economic sewage treatment tech-
nology can provide, and I would hasten to add, with the
exception of phosphates, which I have touched upon earlier,
and also with the exception of coliform, which I have
touched upon earlier.
8. The City of Port Wayne has a routine program
of patrolling three times each week all regulating chambers
at storm overflow points on the sewer system. Less frequent
patrolling of storm overflows is carried out by the smaller
cities.
9. All cities are requiring separate storm and
sanitary sewers in newly-developed areas.
I wish to point out the City of Fort Wayne has
under study the possibility of separation or some other
means of handling its storm overflow problems.
10. All municipalities have complied with the
suggested time-table as all sewered communities in the basin
have secondary treatment facilities in operation. All
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B. A. Poole
industrial plants will have adequate waste treatment works
in operation on or before the suggested date of January 1,
1969, and I hope well in advance of that date of January 1,
1969.
Now, Mr. Chairman, the rest of the report I can
read if you desire, but in essence all it does is document
very briefly the situation with respect to each sewered
municipality and with respect to each industry that maintains
an outlet into any of the Indiana waters of the Lake Erie
Basin.
I would suggest we dispense with the reading,
but request that the entire report be entered in the record.
MR. STEIN: It will be entered into the record
as if read, without objection.
MR. FOOLE: Thank you.
MAUMEE RIVER BASIN
Fort Wayne
The City of Port Wayne is continuing effective
operation and maintenance of its sewage treatment facilities.
The City is requiring sewer separation in newly-developed
urban areas and investigating feasibility in existing
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B. A. Poole 458
sewered areas. The Board of Works has indicated that an
engineering study would be instituted to determine what
should be done to control pollution from existing combined
sewer systems.
Recent monthly reports indicate daily BOD in
the effluent ranging from 10 to 35 mg/1 with monthly averages
less than 20 mg/1 and suspended solids ranging from 5 to 25
mg/1 with monthly averages less than 15 mg/1.
The oity has tried various operational procedures
in an effort to obtain better phosphate removal; however, it
is removing about as much as it can with present iacilities.
Special laboratory analyses on 24-hour composite samples show
the following results for soluble phosphates in mg/1:
Raw Sewage - Average - 14.5; Maximum - 30.4; Minimum - 3.2
Final Effluent - Average - 13.3; Maximum - 31.6; Minimum - 2.8
The city was considered by the Federal Water
Pollution Control Administration for a grant for a plant study
on phosphate removal in August 1965. Some preliminary
meetings and tests have been conducted and an engineering
report prepared; however, approval of the project has not
been received.
A private corporation is proposing the installation
of sanitary sewers in the fringe area east of Fort Wayne with
discharge of sewage and waste to the municipal sewage treatment
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459
B. A. Poole
plant for treatment. These sewers would serve subdivisions
and commercial development and two or three major industries
in the area.
The municipal water works has received final
plans and specifications for water works improvements which
include provisions for abating the discharge of waste lime
sludge from the water softening process to the Maumee River.
New Haven
The city is providing effective operation of its
sewage treatment facilities.
BuHerman-Maumee River Plant
Diversified Utilities, the private corporation
operating a 0.5 mgd plant serving a residential area east 01
Fort Wayne, has experienced difficulty in maintaining effective
operation during initial phases of start-up. However, treat-
ment efficiency has improved and further improvement is
anticipated in the near future.
Salisbury Division, Dana Corporation, Fort Wayne
Inspections and results from the effluent
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B. A. Poole 460
monitoring program indicate that waste control is adequate.
The Corporation's effluent monitoring program has been in
effect for 13 years.
Essex Wire Corporation, Fort Wayne
Inspections and effluent data indicate that
additional waste treatment is needed. Expansion of the waste
treatment facilities and additions to the effluent monitoring
program have been requested.
Franke Plating Works, Inc., Fort Wayne
Inspections and results of effluent monitoring
program indicate that additional treatment of metallic ions
and cyanide is needed. Expansion of the waste treatment
facilities and effluent monitoring program has been requested.
General Plating and Engineering, Inc., Fort Wayne_
Inspections and effluent data indicate that
treatment of cyanide wastes and heavy metals is needed. This
is a small job shop and expansion of treatment facilities and
the effluent monitoring program have been requested.
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B. A. Poole 461
Gladieux Oil Refinery, Inc., Fort Wayne
Inspections and effluent data indicate that
waste control is generally satisfactory. In-plant studies
are being made to locate and eliminate periodic oil spills.
An effluent monitoring program is being established.
ITT Federal Laboratories, Fort Wayne
Effluent data and inspections indicate that
waste control is generally satisfactory. In-plant studies
are being, made to locate and eliminate periodically high
concentrations of heavy metals. An effluent monitoring
program was initiated in March, 1966.
International Harvester Company, Fort Wayne
During 1965* additional industrial wastes were
connected to the Fort Wayne sewerage system; however, the
results of the effluent monitoring program indicate that
additional waste control is needed. In-plant studies are
being made to locate sources of waste for discharge to the
municipal sewerage system. The company is planning to
purchase automatic samplers and expand the monitoring program,
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B. A. Poole 462
Magnavox Company, Fort Wayne
During 1965* improved housekeeping practices
were initiated and waste control was substantially improved.
Inspections indicate that waste control is adequate. An
effluent monitoring program is being established.
Parrot Packing Company, Fort Wayne
Parrot Packing Company, as a result of a hearing
scheduled by the Stream Pollution Control Board, agreed to
connect to the municipal sewer system. The city has not
constructed the proposed interceptor. The company is negotiat-
ing with the City of Port Wayne and a nearby utility regarding
connection to the Fort Wayne sewerage system or the utility
system for disposal of all wastes. An effluent monitoring
program has been requested.
Phelps Dodge Copper Products Corporation, Fort Wayne
During 1965* an acid neutralization and water
reuse system was installed on the copper wire pickle line.
Rinse water and remaining industrial wastes were connected
to the Fort Wayne sewerage system. The results of the
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B. A. Poole 463
effluent monitoring program and inspections indicate that
waste control is adequate. In-plant studies and improved
housekeeping practices have been instituted to eliminate
periodically high concentrations of copper in the effluent.
Zollner Corporation, Fort Wayne
Inspections and effluent data indicate that only
cooling waters are discharged to the receiving stream. Sewage
is discharged to the Fort Wayne sewerage system. The plant
has no industrial waste.
Shaw's Dressed Poultrya Grabill
Inspections indicate that waste control is
adequate. An effluent monitoring program was not required.
B. F. Goodrich Company! Woodburn
The effluent data and Inspections indicate that
waste control is adequate.
ST. JOSEPH RIVER BASIN
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B. A. Poole 464
Avilla
The waste stabilization ponds serving this
municipality were placed in operation in December, 1965. This
was the last sewered community in the Maumee Basin in Indiana
without secondary treatment.
Auburn
The city on January 11, 1966, sold a sewer revenue
bond issue of $2,285,000 to finance a sewage works project
which includes plant additions and effluent chlorination
(Federal grant of $411,900). The city is Installing new
sanitary sewers in several sections of the city and eliminating
some combined sewers with the project now under construction.
Combined sewers are prohibited in all newly-developed areas.
But ler
The city is providing effective operation of its
sewage treatment facilities. The mayor advised, in reply to
this Board's letter of January 11, 1966, that sewer separation
was required in newly-developed areas.
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B. A. Poole 465
Garrett
The city is providing effective operation of its
sewage treatment facilities. The mayor advised, in reply to
this Board's letter of January 11, 1966, that separate sewers
would be required in newly-developed areas and that effluent
chlorination would be instituted to protect the Fort Wayne
public water supply source.
Waterloo
The town is providing effective operation of its
sewage treatment plant; however, one lift station is not in
effective operation due to surface and ground water problems.
The town has been requested to take action to improve this
situation.
Crane Edmund Corporation, Butler
Inspections indicate that waste control is
satisfactory. During 1965, a static rinse tank was installed
and housekeeping improved. An Affluent monitoring program has
been established.
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B. A. Poole 466
Universal Tool and Stamping Company, Inc., Butler
During 1965, a static rinse tank: was installed
following the zinc plating bath and cyanide dragout nas been
reduced considerably. Inspections indicate that additional
waste control may be required. A partial effluent monitoring
program has been established. Expansion of the monitoring
program has been requested.
Kitchen-Quip, Inc., Waterloo
Inspections indicate that treatment for plating
wastes is needed. An effluent monitoring program has not
been established.
T. H. Products Corporation, Waterloo
Inspections indicate that waste treatment is
satisfactory. An effluent monitoring program was not required
Auburn Tankage Company, Auburn
Inspections indicate that waste control is
adequate. An effluent monitoring program was not required.
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B. A. Poole 46?
County Line Cheese Company, Auburn
Inspections Indicate that waste control is
adequate. An effluent monitoring program is being established.
Warner Motive Division, Borg Warner Corporation, Auburn
An effluent monitoring program has been established
and will be expanded. The results show high oil and suspended
solids in the effluent. Extensive in-plant studies are being
made to locate and eliminate the source of oil and suspended
solids.
Sechler and Sons, Inc., St. Joe
A partial effluent monitoring program has been
established. Inspections and previous data show that additional
treatment is needed. A consulting engineer has been employed
to prepare plans and specifications for waste treatment
facilities and plans have been submitted to the Stream Pollution
Control Board.
ST. MARY'S RIVER
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B. A. Poole 468
Berne
The city is providing fairly effective operation
of its waste stabilization ponds; however, the Stream Pollution
Control Board has suggested operational adjustments to improve
efficiency. (The city was operating the two cells in
parallel. Series operation was recommended.)
Decatur
The city is providing effective operation of its
sewage works facilities.
Central Soya Company, Inc., Decatur
Inspections and results of the effluent monitoring
program indicate that waste control is adequate. The company's
effluent monitoring program has been in effect since December,
1964.
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B. A. Poole
MR. STEIN: One of the recommendations was,
wasn't it, that all the municipalities have chlorination
as well as secondary treatment?
MR. POOLE: No. The recommendation was that
the municipalities that have coliform counts in water
intakes which exceed 5,000 per 100 milliliters, or for
water that is used for body contact sports which exceeds
1,000 per 100 milliliters.
MR. STEIN: You have no water contact at all?
MR. POOLE: I had asked my crew to take me down
the Indiana portion of the Maurn?e last September. We have
a 14-foot boat with a 5-horsepower motor, and they said,
'You can't get down the river unless you want to drag the
boat half-way," and I didn't want to be a party to that,
so we didn't make the trip.
I don't think in the Indiana section there are
body contact sports, knowing the characteristics of the
river. I don't know where they start in Ohio, and this is
the reason that I indicated that if and when that is deter-
mined, why, we will hold up our end.
MR. STEIN: £re there any comments or queistions?
If not, thank you very much, Mr. Poole.
MR. QUIGLEY: Mr. Stein?
MR. STEIN: Yes.
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470
B. A. Poole
MR.- QUIGLEY: One question: Before I am tempted
to make quick quips about Kitchen-Quip meeting its compli-
ance, why are they the one hoId-out?
MR. POOLE: I think possibly, Mr. Quigley,
because they are a small installation. They are way up
on the headwaters, and we probably just haven't breathed
down their neck as yet as much as we have some of the
others.
It is one of these smaller industries where it
would be difficult to establish a sampling program and
make arrangements for laboratory facilities. I don't know
whether it is big enough to go on the Secretary's list.
MR. QUIGLEY: He might not want to discriminate.
He might want some small ones as well as some big ones.
MR. STEIN: As long as we are getting into that
detail, let me raise another point with you.
In Point 8 you state:
"The City of Fort Wayne has a routine program
of patrolling three times each week all regulating
chambers at storm overflow points on the sewer
system."
This means whether it rains or not. Is that
right?
MR. POOLE: This is correct. Of course, you
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471
B. A. Poole
understand that in my opinion, at least, in our larger
cities and I am talking of cities of even lesser size
than Fort Wayne from there on up -- that the storm over-
flow problem is not necessarily confined to periods of
rainfall. You have periods of peak flow and you have a
chunk that comes down the sewer, or this or that thing, that
interferes with the diversion in the interceptor.
My personal observation has been that many of
the problems associated with storm overflows come at other
than times of rain, and I think, as far as I said in Fort
Wayne, that this every-other-day patrolling is a pretty
reasonable type of program, not perfect.
MR. STEIN: Thank you, Mr. Poole. That implica-
tion was pretty clear to me, but I would like to see it in
the record.
Thank you.
I wonder if we may call on Pennsylvania.
Mr. Lyon?
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472
W. A. Lyon
STATEMENT OF WALTER A. LYON, CONFEREE
AND DIRECTOR, DIVISION OF SANITARY
ENGINEERING, PENNSYLVANIA DEPARTMENT
OF HEALTH
MR. LYON: Mr. Chairman, Mr. Commissioner,
Conferees:
I am sorry I don't have too many copies of this
report, but the Commonwealth of Pennsylvania is happy to
report that with the exception of Recommendation No. 8, all
of Pennsylvania's waste sources are in essential compliance
with the recommendations of the last conference.
Compliance with Recommendation No. 8 would
appear to be dependent, as we said this morning, upon the
findings and recommendations of the Technical Committee,
which I assume will continue its work.
If you recall, of course, the assignment of
that committee included a request concerning the specific
levels of phosphate to be maintained in the lake, and
levels of phosphate or possibly other nutrients to be
removed by waste sources.
After your last conference on September 15th,
a detailed report concerning the recommendations and
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473
W. A. Lyon
conclusions of the conferees was given to the Pennsylvania
Sanitary Water Board. The Board took the necessary action
to implement those recommendations.
Specifically, it was necessary to take action
on Recommendation No. 8, where we asked each of our
municipal waste sources to conduct studies of their treat-
ment plants in order to determine what levels of phosphates
were being removed and what more could be done in order
to enhance phosphate removal.
Now, our report here, and I won't go into detail,
gives us the results of these. Of course, the City of Erie
is our most important source of sewage. It, like all of
our sewage sources, has complete or secondary treatment.
At this point, the phosphate reductions vary between 7.5
and 26.6, which is very low, but the city is planning to
conduct research studies in cooperation with our Pennsyl-
vania State University in order to see what can be done to
enhance this.
I might also point out that as part of the
report on the abatement of Pennsylvania's industries, we
are going to have a brewery discharge to the Erie sewer
system, and I understand this will have a beneficial effect
on the removal of phosphates. Maybe we should have more
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W. A. Lyon
breweries.
Mr. Chairman, I am skipping through the report,
but I would like to have the entire report incorporated
into the record.
MR. STEIN: Without objection, the entire
report will be in the record as if read.
MR. LYON: Thank you.
"Mr. H. W. Poston May 26, 1966
Regional Program Director
Federal Water Pollution Control Administration
U. S. Department of the Interior
433 West Van Buren Street, Room 712
Chicago, Illinois 6060?
"Dear Mr. Poston:
"With reference to your letter of May 16, 1966, I
am happy to report that with the exception of Recommenda-
tion No. 8 all of Pennsylvania's waste sources are in
essential compliance with the recommendations of the Lake
Erie Conference. Compliance with Recommendation No. 8
would appear to be dependent upon the findings and recom-
mendations of the Technical Committee appointed in accordance
with Recommendation No. 26. If you recall, the assignment
of that committee included a request for a recommendation
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W. A. Lyon
"on phosphate levels to be maintained in the Lake and waste
effluents.
"On September 15* 1965* a detailed report
concerning the recommendations and conclusions of the
conferees was given to Pennsylvania's Sanitary Water Board,
and the Board took: the necessary action to implement those
recommendations. A copy of the Board's September 15 minutes
is attached for your information.
" On May 18, 1966, the Department of Health again
reported to the Sanitary Water Board on all items on which
the Board found a need to take action in September 1965. I am
attaching a copy of the Department's report to the Board, and
I believe that this material will provide you with the informa-
tion you need to inform you of Pennsylvania's action to
implement the recommendations of the conference.
"If you need any further information concerning
this matter, please do not hesitate to contact me.
Sincerely yours,
Att. C. L. Wilbar, Jr., M. D.
RS #168 Secretary of Health"
* * *
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W. A. Lyon 4?6
Vol. 44-5
May 18-19, 1966
II. Section Section - Items for the Board's Information
1. At Its September 1965 meeting the Sanitary Water
Board took action to Implement recommendations made
at the conference called under the enforcement
provisions of the Federal Water Pollution Control
Act convened on August 10, 1965 to consider inter-
state portions of Lake Erie and its tributaries.
The staff was directed to report to the Board in six
months on steps taken to comply with the recommendations
of the conferees.
Recommendations of the conferees requiring action by
the Board and the steps taken to comply with the
Board's action are as follows:
RECOMMENDATION 8. Secondary treatment plants be so
designed and operated as to maximize the removal
of phosphates.
Board Action; That municipalities in the Lake Erie
Basin that have significant sewage discharges be
notified to:
1. Conduct a study to determine the present
degree of phosphate removal and the type
of operation of the present treatment works
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W. A. Lyon 4?7
that will provide maximum phosphate removals
and,
2. Report to the Board within six months.
Report: Letters were directed to the Boroughs of
North East, Girard, Albion and Lake City and the
City of Erie. A summary of the replies follows:
1. North East - Tests to determine phosphate
reduction at the Borough sewage treatment plant
were conducted from November 1965 through March
1966. No consistent phosphate removal was
achieved; however, removals of up to 5^ were
recorded.
2. Girard - Results of tests made from December
1965 through February 1966 indicate that the
Borough sewage treatment plant was removing
approximately 3C$ of the phosphate load on the
plant. The design of the plant makes it im-
possible to vary the existing flow pattern in
an effort to improve phosphate removal.
3. Albion - Initiated tests recently, has not
enough data to submit a meaningful report to
the Board.
4. Lake City - Tests conducted from November 19&5
through March 1966 indicate phosphate removal
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W. A. Lyon
approaching 50$ i Plant renovations were
completed in February 1966 improving phosphate
reductions and permitting revisions in the
plant flow pattern which could be made in an
attempt to improve phosphate removals.
5. City of Erie - Tests conducted in February and
March 1966, indicate phosphate reductions of
7.Jfo and 26.6$, respectively. Studies are in
progress to improve phosphate removal while
retaining the present general flow pattern in
the plant. The city has been in contact with
Dr. Nesbitt of the Pennsylvania State University
who is conducting pilot plant studies on phos-
phate removals at the university sewage treat-
ment plant. When these studies are complete a
feasibility study will be made for phosphate
removals at the Erie sewage treatment plant.
RECOMMENDATION 11. Combined storm and sanitary sewers
be prohibited in all newly developed urban areas,
and eliminated in existing areas wherever feasible.
Existing combined sewer systems be patrolled and
flow-regulating structures adjusted to convey the
maximum practicable amount of combined flows to
and through sewage treatment plants.
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W. A. Lyon 479
Board Action; That the City of Erie be notified to:
1. Report on its program of patrolling flow
regulating structures to assure that the
maximum practicable amount of combined flow
is directed to the sewage treatment plant.
2. Report on any programs the city is considering
for the elimination of combined sewers.
3. Report to the Board within three months.
Report : The City of Erie in a letter dated December
9, 1965* reported that the city has made an overall
study of the cost of eliminating its combined
sewer system. The estimated cost of this project
is $22 million. The city has begun separation of
storm and sanitary sewers in redevelopment areas.
Complete separation of storm and sanitary sewers
in the 12 block: Liberty-Sassafrass redevelopment
area has been completed. A second project in the
downtown area is now under design. The city is
investigating methods of financing the cost of
complete separation of storm and sanitary sewers.
The city has instituted a program of patrolling
flow regulating structures. Personnel inspect
flow regulating structures on a regular basis,
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W. A. Lyon 480
adjust and make necessary repairs to the
structures to prevent overflows except during
periods of heavy combined flow.
RECOMMENDATION 12. Programs be developed to prevent
accidental spills of waste materials to Lake Erie
and its tributaries. In-plant surveys with the
purpose of preventing accidents are recommended.
Board Action: That a letter be directed to all
industries in the Lake Erie Basin notifying them of
the conferees' conclusion, asking them for a report
of the measures that their company now takes or has
taken to implement such a recommendation.
Report; Letters were directed to 5^ industrial
establishments in the Erie Basin asking for a
report on measures now being taken to prevent
accidental spills of waste materials to Lake Erie
and its tributaries. Replies were received from
approximately half of the establishments to which
letters were directed. In all cases the replies
indicated that steps were being taken to prevent
accidental spills. Replies were received from all
industrial establishments which we feel could have
a significant effect on Lake Erie. The Clean
Streams Law and the Sanitary Water Board Rules
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W. A. Lyon 48l
and Regulations specifically prohibit discharges
of this type.
RECOMMENDATION 14. Disposal of garbage, trash, and
other deleterious refuse in Lake Erie or its
tributaries be prohibited and existing dumps along
river banks and shores of the Lake be removed.
Board Action: The Board requests the Department of
Health to conduct a survey of existing dumps in the
Pennsylvania portion of the Basin and, if there are
any, take action to stop them immediately,
Report; In November 1965* the Department of Health
conducted a survey of all known solid waste disposal
sites in the City and County of Erie. Participating
in the survey were representatives of the State
Department of Health, U. S. Public Health Service
and the Erie County Department of Health. A total
of 19 sites were visited, of these nine (9) were
found to be contributing to the pollution of
tributaries of Lake Erie. Recommendations were
made to close five (5) sites and to convert four
(4) sites into satisfactory sanitary landfill opera-
tions. The landfill operations in Erie County are
being kept under close surveillance to insure that
water pollution from sanitary landfills is abated
and prevented.
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W. A. Lyon 482
RECOMMENDATION 17. The Michigan, Indiana, Ohio,
Pennsylvania and New York: Water Pollution Control
Agencies undertake action to insure that industrial
plants discharging wastes into waters of Lake Erie
and its tributaries within their respective juris-
dictions institute programs of sampling their
effluent to provide necessary information about
waste outputs. Such sampling shall be conducted
at such locations and with such frequency as to
yield statistically reliable values of all wastes
outputs and to show their variations. Analyses
to be so reported are to include where applicable:
pH, oil, tarry residues, phenolics, ammonia, total
nitrogen, cyanide, toxic materials, total bio-
chemical oxygen demand, and all other substances
listed in the preceding paragraph.
Board Action; The Board requests the Department of
Health to review the adequacy of its industrial
waste data on effluents from industries in the
Pennsylvania portion of the Lake Erie Basin and
within the next six months obtain any needed informa-
tion suggested by the conferees.
Report; The Department has reviewed information on
file on industrial waste effluents to the Pennsyl-
vania portion of the Lake Erie Basin and has found
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W. A. Lyon 483
that this information adequately describes the
quality of these discharges.
2. The Blue Coal Corporation has continued to discharge
in accordance with the approved schedule of Glen Alden
Corporation.
During the period from April 5, 1966, to May 2, 1966,
the pool elevation of the #5 South Wilkes-Barre Shaft
was lowered 10 feet to 172.0 feet. This is approximate-
ly 108 feet below the critical elevation at which the
Department of Mines and Mineral Industries would order
the miners out of the adjacent workings.
The range of flow at the Wilkes-Barre Gag;ing Station
for the period April 5, 1966, to' May 3, 1966, has been
9930 CFS to 36,500 CFS.
The river has retained its alkalinity during this
period. There were no reported flush-outs of precipi-
tated iron salts.
3. Mineral Preparation Waste Regulations.
We are planning to meet with representatives of the
bituminous and anthracite industry as soon as the
transcripts of the April hearing on proposed mineral
preparation waste regulations are received and have
been studied. We will report to the Board on the
results of this meeting as soon as possible.
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W. A. Lyon 484
3. The first session of the Conference called under the
enforcement provisions of the Federal Water Pollution
Control Act to consider pollution of Lake Erie was
held in Cleveland, Ohio, August 3-6, 1965. At that
time pollution of Lake Erie and tributaries of Lake
Erie in Michigan, Indiana and Ohio was discussed.
The Conference was reconvened on August 10 in Buffalo,
New York. Testimony lasted two days at this session
of the Conference. The conferees met the third day
to consider recommendations and conclusions. Dr.
Wilbar's testimony was given at the August 10 session
in Buffalo. A copy of Dr. Wilbar's testimony is on
Pages 0.36 through 0.39. Although the Public Health
Service report on Lake Erie presented a pretty bleak
picture of pollution control progress in the Pennsyl-
vania portion of the Lake Erie Basin, the Public Health
Service representatives stated in answers to questions
that the Pennsylvania municipalities and industries
have done a good job in pollution abatement in the
Lake Erie Basin. It was apparent from the testimony
that the States of Michigan, Ohio and New York have
some severe water quality problems, especially around
the heavily populated areas such as Detroit, Cleveland
and Buffalo. Listed below are the recommendations
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W. A. Lyon
and conclusions of the conferees. After each
recommendation we have listed Department comments and
recommendations, where appropriate, as to action the
Board should take to implement the recommendations
and conclusions of the conferees.
RECOMMENDATIONS AND CONCLUSIONS OP CONFEREES*
LAKE ERIE ENFORCEMENT CONFERENCE
1. The waters of Lake Erie within the United States
are interstate waters within the meaning of Section
8 of the Federal Water Pollution Control Act. The
waters of Lake Erie within the United States and
its tributaries covered by sessions of this con-
ference are navigable waters within the meaning of
Section 8 of the Federal Water Pollution Control Act
COMMENT: No Sanitary Water Board action necessary.
2. Lake Erie and many of its tributaries are polluted.
The main body of the Lake has deteriorated in
quality at a rate many times greater than its
normal aging processes, due to inputs of wastes
resulting from the activities of man.
COMMENT: No Sanitary Water Board action necessary.
3. Identified pollutants contributing to damages to
water uses in Lake Erie are sewage and industrial
*Representatives of: Indiana, Michigan, New York, Ohio,
Pennsylvania and U. S. Department of Health, Education, and Welfare
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W. A. Lyon 486
wastes, oils, silts, sediment, floating solids and
nutrients (phosphates and nitrates). Enrichment
of Lake Erie, caused by man-made contributions of
nutrient materials, is proceeding at an alarming
rate. Pollution in Lake Erie and many of its
tributaries causes significant damage to recreation.
commercial fishing, sport fishing, navigation,
water supply and esthetic values.
COMMENT: No Sanitary Water Board action necessary.
4. Euthrophication or over-fertilization of Lake Erie
is of major concern. Problems are occurring along
the lake shoreline at some water intakes and
throughout the lake from algal growths stimulated
by nutrients. Reduction of one or more of such
nutrients will be beneficial in controlling algal
growths and euthrophication.
COMMENT: No Sanitary Water Board action necessary.
5. Many sources of waste discharge reaching Lake Erie
have inadequate waste treatment facilities. The
delays in controlling this pollution are caused by
the lack of such adequate facilities and the complex
municipal, industrial, financial and biological
nature of the problem.
COMMENT: No Sanitary Water Board action necessary.
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W. A. Lyon 487
6. Interstate pollution of Lake Erie exists. Dis-
charges into Lake Erie and its tributaries from
various sources are endangering the health or
welfare of persons in States other than those in
which such discharges originate, and in large
measure this pollution is caused by nutrients
which over-fertilize the lake. This pollution is
subject to abatement under the Federal Water
Pollution Control Act.
COMMENT: No Sanitary Water Board action necessary.
7. Municipal wastes be given secondary treatment or
treatment of such nature as to effectuate the maxi-
mum reduction of BOD and phosphates as well as
other deleterious substances.
COMMENT: Lake Erie and its tributary streams in
Pennsylvania are presently classified as streams
requiring treatment and all municipal sewage dis-
charges are presently provided with secondary treat-
ment. No Board action is necessary to implement
this recommendation.
8. Secondary treatment plants be so designed and
operated as to maximize the removal of phosphates.
COMMENT: Since all the municipal waste discharges
in the Pennsylvania portion of the Basin now
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488
W. A. Lyon
receive secondary treatment, some action should
be taken to assure that these plants are operated
to maximize the removal of phosphates. As the
conclusions indicate, the pollution found to be
occurring in Lake Erie was caused by phosphates.
The above recommendation was made by the PHS
representatives and it was their thought that
this maximized removal of phosphates be done
with existing plants by changing methods of
operation. They did not contemplate at this
time the construction of additional treatment units
to remove phosphates. There is some doubt as
to what levels of phosphates can be removed by
conventional secondary sewage treatment plants.
DEPARTMENT RECOMMENDATION; That the Board notify the
municipalities in the Lake Erie Basin that have
significant sewage discharges to:
(l) Conduct a study to determine the present
degree of phosphate removal and the type of
operation of the present treatment works that
will provide maximum phosphate rem'ovals and,
(2) Report to the Board within six months.
BOARD ACTION: Motion Jones, seconded Bielo, unanimously
carried, the Board adopted the Department
recommendation.
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W. A. Lyon 489
9. Disinfection of municipal waste effluents be
practiced in a manner that will maintain coliform
concentrations not to exceed 5*000 organisms per
100 ml at public water supply intakes, and not to
exceed 1,000 organisms per 100 ml where and when
the receiving waters in proximity to the discharge
point are used for recreational purposes involving
bodily contact. It is recognized that bathing
water quality standards are established by statute
in New York: State.
COMMENT: The Sanitary Water Board now requires
chlorination of all sewage effluents in the
Lake Erie Basin. Beach 11 at Erie periodically
has coliform levels exceeding 1,000 organisms
per 100 ml. The Department of Health is in the
process of studying this problem and no further
Board action is necessary at this time,.
We will report to the Board on this matter as
soon as our study is complete.
10. All new sewerage facilities be designed to prevent
the necessity of bypassing untreated waters.
COMMENT: The Board now requires this and no
further action is necessary.
11. Combined storm and sanitary sewers be prohibited
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W. A. Lyon 490
in all newly developed urban areas, and elimina-
ted in existing areas wherever feasible.
Existing combined sewer systems be patrolled
and flow-regulating structures adjusted to
convey the maximum practicable amount of
combined flows to and through sewage treatment
plants,
COMMENT: The Board now prohibits the construction
of combined storm and sanitary sewers and no
Board action is necessary on this portion of
the recommendation. The following recommenda-
tion deals with the existing combined sewers in
Erie.
DEPARTMENT RECOMMENDATION; That the City of Erie
be notified to
(l) Report on its program of patrolling flow
regulating structures to assure that the maximum
practicable amount of combined flow is directed
to the sewage treatment plant.
(2) Report on any programs the city is considering
for the elimination of combined sewers.
(3) Report to the Board within three months.
BOARD ACTION; Motion Charmbury, seconded Sheffler,
unanimously carried, the Board adopted the
Department Recommendation.
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W. A. Lyon 491
12. Program be developed to prevent accidental spills
of waste materials to Lake Erie and its tributaries
In-plant surveys with the purpose of preventing
accidents are recommended.
DEPARTMENT RECOMMENDATION: (l) That a letter be
directed to all industries in the Lake Erie
Basin notifying them of the conferees con-
clusion, asking them for a report of the
measures that their company now takes or has
taken to implement such a recommendation.
BOARD ACTION; Motion Pierce, seconded Jones,
unanimously carried, the Board adopted tne
Department Recommendation.
13. Unusual increases in waste output and accidental
spills be reported immediately to the appropriate
State agency.
COMMENT: The Board already requires this and no
further action is necessary.
14. Disposal of garbage, trash, and other deleterious
refuse in Lake Erie or its tributaries be pro-
hibited and existing dumps along river banks and
shores of the lake be removed.
COMMENT: The Board already prohibits such dis-
charges into the waters of the Commonwealth.
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W. A. Lyon
DEPARTMENT RECOMMENDATION; The Board requests the
Department of Health to conduct a survey of
existing dumps in the Pennsylvania portion of
the Basin and, if there are any, take action
to stop them immediately.
BOARD ACTION; Motion Bielo, seconded Jones,
unanimously carried, the Board adopted the
Department Recommendation.
15. The conferees met with representatives of Federal,
State and local officials responsible for agri-
cultural, highway and community development programs
for the purpose of supporting satisfactory programs
for the control of runoff which deleteriously
affects water quality in Lake Erie.
COMMENT: No Board action necessary.
16. Industrial plants improve practices for the
segregation and treatment of waste to effect the
maximum reductions of the following:
(a) Acids and alkalies
(b) Oil and tarry substances
(c) Phenolic compounds and organic chemicals that
contribute to taste
(d) Ammonia and other nitrogenous compounds
(e) Phosphorus compounds
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W. A Lyon 493
(f) Suspended materials
(g) Toxic and highly-colored wastes
(h) Oxygen-demanding substances
(i) Excessive heat
(j) Foam-producing discharges
(k) Other wastes which detract from recreational
uses, esthetic enjoyment, or other beneficial
uses of the waters.
COMMENT: The Board already requires maximum
reductions of the wastes indicated and no further
Board actions are necessary.
17. The Michigan, Indiana, Ohio, Pennsylvania and
New York Water Pollution Control Agencies undertake
action to insure that industrial plants discharging
wastes into waters of Lake Erie and its tributaries
within their respective jurisdictions institute
programs of sampling their effluent to provide
necessary information about waste outputs. Such
sampling shall be conducted at such locations and
with such frequency as to yield statistically
reliable values of all wastes outputs and to show
their variations. Analyses to be so reported are
to include where applicable: pH, oil, tarry
residues, phenolics, ammonia, total nitrogen,
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W. A. Lyon 494
cyanide, toxic materials, total biochemical oxygen
demand, and all other substances listed in the
preceding paragraph.
COMMENT: At the present time the files of the
Department of Health include information on
industrial waste effluents in the Basin; however,
this information should be reviewed in light of
the conferees' recommendation.
DEPARTMENT RECOMMENDATION; The Board requests the
Department of Health to review the adequacy of
its industrial waste data on effluents from
industries in the Pennsylvania portion of the
Lake Erie Basin and within the next six months
obtain any needed information suggested by the
conferees.
BOARD ACTION; Motion Sheffler, seconded Bielo,
unanimously carried, the Board adopted the
Department Recommendation.
18. Waste results be reported in terms of both
concentrations and load rates. Such information
will be maintained in open files by the State
agencies for all those having a legitimate interest
in the information.
COMMENT: The information obtained by the Health
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W. A. lyon 495
Department in connection with the Recommendation
17 would be maintained in open files under
existing policies. No Board action is necessary.
19. The Department of Health, Education, and welfare
establish water pollution surveillance stations at
appropriate locations on Lake Erie. Surveillance
of the tributaries will be the primary responsi-
bility of the States. The Department of Health,
Education, and Welfare will assist the States at
such times as requested.
COMMENT: No Board action is necessary.
20. The Department of Health, Education, and Welfare
will be responsible for developing up-to-date
information and experience concerning effective
phosphate removal and control of combined sewer
systems. This information will be reported to
the conferees regularly.
COMMENT: No Board action is necessary.
21. Regional planning is often the most logical and
economical approach toward meeting pollution
problems. The water pollution control agencies
of Indiana, Michigan, Pennsylvania, New York and
Ohio, and the Department of Health, Education, and
Welfare will encourage such regional planning
activities.
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W. A. Lyon
COMMENT: The Department on behalf of the Board
already has a program to stimulate regional
planning in Erie County and there is no Board
action necessary at this time.
22. Within six months after the issuance of this
Summary, the State water pollution control agencies
concerned will present a schedule of remedial
action to the Conferees for their consideration
and evaluation.
DEPARTMENT RECOMMENDATION; That the Board direct
the Department of Health to prepare a report to
the conferees.
BOARD ACTION; Motion Charmbury, seconded Sheffler,
unanimously carried, the Board adopted the
Department Recommendations.
23. The Federal Conferee recommends the following
for the consideration of the State agencies:
(a) Recommended municipal treatment - Completion
of plans and specifications August 1966, comple-
tion of financing February 1967> construction
completed January 1, 1969, chlorination of
effluents May 15, 1966, provision of stand-by
and emergency equipment to prevent interrup-
tions in operation of municipal treatment
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W. A. Lyon 497
plants August 1966, patrolling of combined
sewer systems immediately.
(b) Discontinuance of garbage and trash dumping
into waters immediately.
(c) Industrial waste treatment facilities to be
completed and in operation by January 1, 1969.
COMMENT: No Board action necessary.
24. Federal installations waste treatment facilities
to be completed and in operation by August 1966.
COMMENT: No Board action necessary.
25. Representatives of the United States Corps of
Engineers meet with the Conferees, develop and
put into action a satisfactory program for disposal
of dredged material in Lake Erie and its tribu-
taries which will satisfactorily protect water
quality. Such a program is to be developed within
six months after the issuance of this Summary and
effectuated as soon as possible thereafter.
COMMENT: No Board action necessary.
26. The Conferees will establish a Technical Committee
as soon as possible which will evaluate water
quality problems in Lake Erie relating to nutrients
and make recommendations to the Conferees within
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W. A. Lyon 498
six months after the issuance of the summary of
the conference.
COMMENT: No Board action necessary. Committee
has been established.
27. The Conference may be reconvened on the call of
the Chairman.
COMMENT: No Board action necessary.
At the conclusion of the Cleveland session of the
conference the following was included among the
conclusions and recommendations of the conference:
"Pollution of navigable waters subject to abate-
ment under the Federal Water Pollution Control
Act is occurring in the Ohio waters of Lake Erie
and its tributaries. The discharges causing and
contributing to the pollution come from various
municipal and industrial sources, from garbage,
debris, and land runoff.
"Pollution of the Ohio waters of Lake Erie and
its tributaries within the State of Ohio endangers
health and welfare."
A question has been raised concerning the jurisdiction
of this conference over intrastate Ohio waters. The
conferees agreed to present this question to the
Secretary of Health, Education, and Welfare and the
Governor of Ohio for clarification and resolution.
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W. A. Lyon 499
4. It was not quite clear what action the Board desires
on the publicizing of corrected mine drainage viola-
tions and we would like to raise this point again.
Since a report of violations by the Ponfeigh Smokeless
Coal Company and the Manor Hill Coal Company was
printed in the newspaper, we released to the news-
papers in the same area a report of the Board's action
acknowledging compliance by these companies.
**###***
WATER POLLUTION CONTROL IN
THE PENNSYLVANIA PORTION OF THE LAKE ERIE BASIN
Statement to be presented by Dr. C. L. Wilbar, Jr., M. D.,
Secretary of Health, Commonwealth of Pennsylvania, on behalf
of the Pennsylvania Sanitary Water Board
Buffalo, New York
August 10, 1965
Introduction
I am appearing today as the representative of
the Pennsylvania Sanitary Water Board. The Board has invited
representatives of local government, industry and conservation
groups to present statements at this conference. I will intro-
duce these speakers at the conclusion of my statement.
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W. A. Lyon 500
We in Pennsylvania are intensely interested in
Lake Erie. The lake is an important source of public and
industrial water supply and is a popular summer playground for
Pennsylvanians as well as tourists from other States.
The Sanitary Water Board has, over the years,
endeavored to protect this valuable resource from pollution
by establishing complete degree treatment as the treatment
requirement for all waste discharges to the lake and its
tributaries.
Because of the importance of Lake Erie in Pennsyl-
vania's economy we support the need for the Public Health
Service Comprehensive Study of the Lake Erie Basin.
The abatement of water pollution is a complex
business, and intelligent action must be based on comprehensive
long-range planning in which all pertinent facts are
considered.
Description of the Basin
The Pennsylvania portion of the Lake Erie Basin
includes portions of Crawford and Erie counties and encompasses
an area of 512 square miles.
Agriculture is one of the principal industries in
the basin. Grapes and other fruit crops and early maturing
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W. A. Lyon 501
vegetables are the most important crops. Some heavy Industry
is concentrated in and near Erie.
The population of the basin is approximately
260,000, of which about 140,000 live within the City of Erie.
Numerous small streams enter the lake from the
Pennsylvania portion of the basin. The U. S. Geological Survey
does not measure flow in any of these streams on a regular
basis. However, it has been estimated that they contribute an
average of about 420 cubic feet per second to the lake.
Water Use
Uses of the waters of Lake Erie in Pennsylvania
are many and varied. Recreational use of the lake includes
bathing at the many beaches, fishing and boating. The best
known and most heavily used beaches are a series of broad
sandy beaches in Presque Isle State Park near Erie. Yearly
attendance at the park exceeds 3 million people. The estimated
dollar value of this facility in terms of annual income to the
area is 45 million dollars.
Boating interest is evidenced by the numerous
pleasure boats to be seen in the Erie City area on most summer
days. Reports indicate that fishing, although less popular in
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W. A. Lyon 502
recent years because of a decline in numbers of the more
desirable game fish, is still a very popular form of recreation,
Commercial fishing has also declined. Nevertheless, it still
offers a livelihood or a supplemental source of income for
some Pennsylvanians.
The lake serves as a source of municipal water
supply for the City of Erie and surrounding communities. Water
is drawn from two intakes which extend several thousand feet
out from the western shore of Presque Isle. The average water
use for this purpose is approximately 39 million gallons per
day. Water use exceeding 50 million gallons per day during the
summer months is common. The estimated population served is
200,000. The remainder of the population in the basin is
served by private on-lot water Supplies or by public water
supplies which use tributary streams or ground water as
sources of supply. Total industrial water use is about 220
million gallons per day. Most of this is used for cooling
purposes.
Pollution Control Progress
All of the municipalities in the basin which
maintain public sewer systems are served by complete degree
sewage treatment works. Complete treatment is that treatment
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W. A. Lyon 503
in which a minimum of 85$ of the bio-chemical oxygen demand
load is removed. It effects the removal of substantially all
suspended and settleable solids as well as the removal of
oils, greases, acids, alkalis and of toxic, putrescible, taste
and odor producing substances. A number of schools and
business establishments in the basin do not have access to
public sewers and therefore must provide complete degree
sewage treatment prior to discharging to streams. A tabulation
showing the status of sewage treatment in the Pennsylvania
portion of the Lake Erie Basin is attached to copies of this
presentation.
All of the industrial establishments in the Lake
Erie Basin are meeting the Pennsylvania Sanitary Water Board's
waste treatment requirements or are making satisfactory progress
toward meeting this goal. The latter group have submitted time
schedules for necessary corrective action and are on schedule.
A tabulation of the industrial establishments in the basin
indicating their water pollution control status are attached
to copies of my presentation.
An important case presently making satisfactory
progress is the Hammermill Paper Company plant at Erie. A
change in the company's manufacturing process about ten years
ago created a waste which is not amenable to treatment by
conventional methods and created a serious pollution problem.
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W. A. Lyon 504
After a great deal of research the company has chosen to
dispose of its strong waste to deep wells. One of the two
planned wells has been in operation more than a year. On
July 20 of this year, the company received a permit from the
Sanitary Water Board to begin operation of its second well.
These wells by this time should be effectively handling two
million gallons per day of highly concentrated pulp mill
waste. These wastes constitute most of the company's high
BOD waste. All other wastes from the mill receive treatment
prior to discharge to Lake Erie. In the near future, we plan
to evaluate the effect on lake quality of the plant discharge
to determine if additional pollution abatement steps are
necessary.
Water quality in the eastern end of Presque Isle
Bay has been adversely affected by discharges of both sewage
from combined sewers and of industrial wastes.
Overflows from the Erie City combined sewer and
storm drain system during periods of heavy precipitation con-
stitute a source of pollution to the bay. The city has in-
tensified its preventive maintenance program to eliminate
unnecessary discharges from combined sewers. Because of the
very nature of combined sewer operation we will continue to
have periodic discharges of wastes to the Bay and some of
its tributary streams during periods of heavy precipitation.
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W. A. Lyon 505
/
The city has estimated that to separate storm and sanitary
sewage systems in order to eliminate periodic discharges
would cost 20 million dollars.
Discharges of industrial wastes to the bay
through city storm sewers and streams tributary to the bay
caused a series of fish kills in Presque Isle Bay during the
summer of 1964. A cooperative survey made by the Pennsylvania
Department of Health and consultants for the City of Erie
has pinpointed these sources of pollution and most of the
discharges have been abated. Satisfactory progress is being
made toward abatement of the remainder. We plan to study the
effect of these discharges on the bay after planned abatement
woric in the city is completed in order to determine if any
additional action is needed.
Water Quality
The quality of the streams entering Lake Erie
from Pennsylvania is generally good. The only exceptions are
Cascade Creek, Mill Creek and Garrison Run which receive the
combined storm and sanitary sewer discharges above mentioned
General compliance with Sanitary Water Board waste treatment
requirements and the rural nature of much of the watershed
combine to preserve the quality of the other Pennsylvania
-------
W. A. Lyon 506
streams at a high level. Conneaut Creek:, the only interstate
stream of significant size, receives several treated waste
discharges, but quality is good at the State line.
Water quality in the lake proper has been
generally good except for a zone immediately east of Presque
Isle. The effects of the Hammermill Paper Company discharge
which entered the lake in this shallow cove have been readily
apparent. The dark brown color and propensity to foam have
been obvious to the casual observer. Winds from the northeast,
which are infrequent and opposite to the prevailing wind
direction, have several times in the past caused the waste
to concentrate In the cove and in Presque Isle Bay to the
extent that dissolved oxygen was seriously depleted and fish
were killed.
Extensive sampling of the Presque Isle Beach
area for bacteriological analysis over the years has indicated
acceptable quality at all beaches except Beach 11 at the
eastern point of Presque Isle. High coliform levels at
Beach 11 have been correlated with occasional winds from the
east which carry the chlorinated effluent from the Erie
sewage treatment plant in the direction of the beach. The
sewage treatment plant discharges to the lake through a
submerged outfall about a mile from the Presque Isle Beaches.
Operation and control changes have been made at the sewage
-------
W. A. Lyon 507
treatment plant in an attempt to eliminate this problem.
We have no information available to us that
indicates that pollutonn of Lake Erie in relation to
Pennsylvania is occurring from another State.
An indication of the eutrophication of the
waters of the lake is observed periodically in the Erie area.
Heavy mats of algae are washed ashore creating nuisance
conditions and discouraging bathing.
Summary and Conclusions
Significant pollution control progress has been
made by the municipalities and industries in the Pennsylvania
portion of the Lake Erie Basin. We will continue our program
aimed at abating the remaining inadequately treated waste
discharges in the basin. We realize that effluents from
complete degree treatment works and agricultural runoff contain
residual pollutants that can adversely affect water quality.
Nutrients which speed up the eutrophication process fall in
this category.
We expect that the Public Health Service study
report will indicate the effect of these nutrients on the
lake, where they come from, and how much it will cost the
people in the basin to abate this type of pollution.
-------
508
W. A. Lyon
We have no information that indicates that
interstate pollution involving Pennsylvania is occurring
in Lake Erie.
Pennsylvanians have devoted a great deal of
effort toward abating pollution in our portion of the basin.
The economy of the Pennsylvania portion of the lake Erie
Basin depends upon preservation of lake water quality.
We intend to continue to do everything in our power to assure
that water quality requirements designed to enhance the value
of the lake are met.
-------
SEWERAGE STATUS
509
Lake Erie Basin
Case I\Tama
Conneaut Valley
Union Jt« Elem.
School
Albion
Erie
Erie Co. Hone
Fairview Sen.
Xaiikwa Club
Terrace Rest
Wennsr's Esso
Station
Girard
Wattsburg
B eh rend Center
(Penn. St. IWv.)
Harborcreek
Twp,, School
Lake City
Hunble Oil &
Refining Co.
Georgetown
Popular White
North East
Presque Isle
Municipality
Spring Twp.
Albion Boro.
Erie City
Fairview Twp,
Fairview Twp,
Fairview Twp,
Fairview Twp»
Fairview Twp.
Girard Boro.
Greene Twp,
Harborcreek
Twp.
Harborcreek
Twp.
Lake City Twp.
JfcKean Twp.
McKean Twp.
McKean Twp,
North East
Boro.
Presque Isle
W
3
County
Crawford
Erie
Erie
Erie
Erie
Erie
Erie
Erie
Erie
Erie
Erie
Erie
Erie
Erie
Erie
Erie
Erie
Erie
Population
Served
220
1900
UjQ,000
675
700
200
115
20
2500
600
loo
hOO
1700
128
1*0
300
U200
200
Receiving Adequate Treat.
Stream Provided
Conneaut Cr.
Conneaut Cr,
Lake Erie
Trout Run
Trout Run
Walnut Cr,,
Brandy Run
Brandy Run
Elk Creek
Four Mile Cr.
Trout Run
Trout Run
Elk Creek
Trib. -
Thomas Run
Elk Creek
Elk Creek
16-Mile Cr,
Erie Harbor
Yes
Yes
Yes*
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
State Park
-------
SEWERAGE STATUS
510
Lake Erie Basin
/
Case Kama
Talarico Truck
Stop
Larry's Truck
Stop
Howard Johnson
Motor Lodge
Oakdale Corp*
(Holiday Inn)
Rondale Conva-
lescent Home
Summit School
Dist
Travelers Rest
Municipality _ County
Springfield Erie
Twp.
North East Erie
Twpo
Summit Twp* Erie
Summit Twp. Erie
Summit Twp, Erie
Summit Twp, Erie
Summit Twp. Erie
ity LjVJ)
Population
Served
*7
100
1*20
350
13U
110
175
Receiving Adequate Treat
Stream Provided
Raccoon Cr.
Averill Run
Walnut Cr,
Walnut Cr.
Trib. -
Walnut Cr«
Walnut Cr»
Walnut Cr.
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Industrial waste discharges to storm sewers not
included in this tabulation. The City is presently
working on a program to eliminate all the industrial
waste discharges to its storm sewer system.
-------
511
INDUSTRIAL WASTE STATUS
Lake 3rie Basin
Case Na-,i3 Type
and. Location Waste
CRAWFORD co.
Springboro
Borough
Albro Packing I.W.
Co.
Sealtest
Foods
SRIS COUNTY
City of
Erie
I.W.
Hsjicnenaill
Co,
I.W.
Interlake I.W.
Steel Corp.
Kaiser Alum. I.W.
& Chemical
Corp,
Penelec Co. I.W.
Ruberoid Co. I.W.
-Kcrth East
Borough
The Elec. I.W.
Materials Co.
Type
Establishment
Food processing
Milk processing
Integrated Pulp
and paper Co,
Integrated Steel
Kill
Manufacture Alum.
Products
Electric power
product
Coated Asphalt
product
Elec. Equipment
Receiving
Street
Conneaut Cr.
Conneaut Cr.
Lake Erie
Lake Erie
Motch Run
Erie Bay
Erie Bay
Trib. - Six-
teen Mile Cr.
Adequate Treat,
Provided
Yes
Yes
Yes
Yes
Yes
Remark!
*Study will be
conducted to
determine if
reduction
standards are
met after
second deep
disposal well
is in operatic
V-SP. Comple-
tion of treat.
facilities
scheduled for
Sept. ,-1965.
V-SP.
tion of
f ac .
at.
-------
512
C*cLSO iW^IIO
p -pc^ T r* ^ X't" ? <^v;
o-IxU, x,o^ tiu^-Oxi
Y-r^^V ]?C<3V
i\U* Ufci, iJ^-iS U
INDUSTHIAL WASTS STATUS
Laics Brio Baoin
Establishment
Receiving
Sire era
Adequate Treat*
Provided
Hamarkc
Juice Co.
Wesleyvillo
Borough
J. MeCosnick I.ft.
Ccnstr. Go«
Millereok T.-TO«
Erie CerccrLcs I,W.
of Erie
Erie Brewing I,W.
Company
Fairvieu T^p*
Fair\rie^.? Txp. Savage
Indus, ITovcj
Ksnt Corp,
Food processing Sixteen Mile
Creek
Yes
Construction
Materials
Porcelain Enamel
products
Brewery
^
cerar.iicc Sewage
Concrete Pipe
KLckel ELats I.W. Sand Washsry
Four Mle Cr.
Unnar.cd Trib.
to Lake Erie
Mill Creek
Trout Run
Trib,-Walnut
Creek
Trout Run-
Yes
Yes
Yes
Yes
Yes
Pa
I.W. Metal Prod.
Trout Run
Yee
-------
513
IIGuS?2IAL WASTE STATUS
Lake Brio Be:.- in
«*
Case !\ano Typo
/:d loco.tion Waste
Girarcl Boro.
C-unnison
Brothers
Laurence Perk
Townshit)
Gon. Elec.Co. I.W.
Sterilizer
Typa
Establishsiant
I.W, Tannery
Heavy machine
afg.
Cci-p. I.W, Steol Products
Receiving
Stream
Brandy Run
Lake Erie
Hospital Equip, Cascade Or*
Unnamed trib,
to Lake Erie
Adequato Treat.
Provided
Yes
Remarks
Yes
Yes
Yes
Legend - I.W. - Industrial Wastes
V-SP - Violation-Satisfactory Progress
-------
GO <
..-L
533-A
-------
W. A. Lyon 514
MR. LYON: Thank you very much.
MR. STEIN: Thank you.
Are there any comments or questions?
(No response.)
MR. STEIN: I would like to ask you some
questions on some of the details here.
I do not want the record to indicate that we are
just asking Pennsylvania the detailed questions.
How about Beach 11 on Presque Isle? Have you
opened that yet?
MR. LYON: Beach 11 on Presque Isle is opened
normally. There are times when we get an unusual wind
from the east side of the lake, when the coliform levels
on that day exceed 1,000, which is the limit.
We believe that this is largely due to the
present discharges of the Hammermill Paper Company, and
occasionally due to the discharges from the combined sewers
at Erie. We think, however, that it is primarily coliform
from the paper mill, which are not pathogenic.
As I indicated, we plan to make -- and you will
find this in our report a rather complete study of not
only the beach, but the Hammermill discharge situation as
soon as Hammermill has put in its second disposal well. We
will include a study not only.of Beach 11, but of all the
-------
515
W. A. Lyon
beaches, to see if this has abated this, what really is
a minor problem. It occurs about once a year, when we get
an easterly wind, which is very unusual.
MR. STEIN: Walter, for the benefit of the group
here, we have been doing studies on paper mills and sugar
beet wastes, and I don't think our scientists go along
with the recommendation any more that they are not pathogenic.
They have some in the waste beets of the sugar beet mills,
and I think the tendency is not to say automatically that
they are not pathogenic, but in the cases we have analyzed
they have recommended chlorination of these wastes, I
think that that may be borne in mind.
As far as the cities of Lake City and Girard,
when will those enlarged plants be in operation?
MR. LYON: Lake City let me look this up.
Tney are now in compliance. The report indicates in Lake
City the plant was completed in February of this year.
MR. STEIN: But they plan to include chlorination?
MR. LYON: All of our sewerage systems are
chlorinated.
MR. STEIN: Are they chlorinated now:
MR. LYON: Yes.
MR. STEIN: Year 'round?
MR. LYON: Year 'round.
-------
516
W. A. Lyo n
MR. STEIN: In Girard too?
MR. LYON: As far as I know, they are.
MR. STEIN: And their expansion is completed?
MR. LYON: There was no expansion, as far as my
record here shows, indicated in Girard. I would be happy
to check into that for you.
MR. STEIN: I think our record indicates -- but
let's just check that,
MR. LYON: Yes, I will certainly do that.
MR. STEIN: Now, I think that I would like to
read the report that we have on the Hammermill situation,
and I want at least the group here to recognise what we are
attempting to get is a factual situation and that is why we
do this here.
We have gotten the report from Mr. Lyon on
Hammermill which indicated that when the deep well was in,
the problem would be solved. Our report on this is less
than a page double-spaced, but I think the whole thing
should be given to you to give you the picture and see if
we can dovetail on the agreed facts :
"Hammermill Paper Company's waste outfall
is located just east of the mouth of trie Harbor,
with prevailing winds in the area from the west.
-------
517
W. A. Lyon
"Hammer-mill effluents affect the water quality
and esthetic appearance of beaches and boating
areas for 10 to 20 miles eastward. This line of
foam and foul-smelling colored water hinders the
development of eastern portions of the basin as a
water supply source and a recreational area. It
also reduces the usefulness and value of lake front
property.
"In addition to their adverse esthetic effect,
these discharges cause severe problems with taste
and odors in domestic water supply which require
costly additional treatment. Periodically Erie is
forced to close its eastern water intake to avoid
high tannin concentrations. At the time of the
August 1965 conference, Hammermill Paper Company
was contributing 90 percent of the total oxygen
demand load to this area of water. They have
since completed installation of a deep well disposal
system which has corrected some of the BOD problems.
However, the serious problems caused by the dis-
charge of tannins and lignins from spent pulping
liquors still remain."
Is this correct?
MR. LYON: I. think that what you have said
-------
518
W. A. Lyon
concerning the effect of the Hammermill Paper Company on
the beaches is essentially correct.
Our regional office just last week conducted
an aircraft surveillance of that area, and there is a
definite effect on the beaches to the east from the company.
There apparently are occasional taste and odor problems.
As soon as, as I have indicated to you, Well No.
2 is in full operation it is now in partial operation;
they have not geared up all of their wastes to disposal in
Well No. 2, but they have indicated this will be done by
July 1st or thereabouts we expect that the most serious
problems will be solved.
It is difficult to tell at this time whether
the entire problem will be solved. Our regional office
will conduct a study later in July in order to see whether
or not there is any remaining problem, and if there is any
remaining problem, appropriate orders will be issued by the
Board.
This also applies to any coliform problem that
might arise from that discharge.
MR. STEIN: All right. Thank you.
Are there any other questions or comments?
Mr. Oeming?
MR. OEMING: I don't have a question particularly
-------
519
W. A. Lyon
with reference to Mr. Lyon's statement, but I am concerned
here about some confusion that seems to be arising with
respect to the disinfection of paper mill wastes.
Now, I would like to have this cleared up here,
because we are requiring the papers mills in the Monroe area,
as one of our requirements, to disinfect these effluents,
and I would like to know if we are requiring something that
is not necessary. If so, I want to go back and take it out.
MR. STEIN: I will tell you our scientists
think it is necessary.
MR. OEMING: This is the Board here. I am just
asking.
MR. STEIN: I can Just speak for our people, but
that is why I raised the question with Pennsylvania.
MR. LYON: Well, the point of the question is
this: That most of their waste is going into a deep well.
There may not be a coliform problem once they have done
this, you see.
In other words, they essentially are abating
their most important discharges by disposing of them by the
deep-well disposal method, which is to put them in very
deep geological formations, which will not affect any
surface water or water resource.
So, if there is still a coliform problem after
-------
520
W. A. Lyon
that, we will certainly see to It that it is corrected.
MR. STEIN: Do you have any further questions?
MR. OEMING: No.
MR. STEIN: I think it is fair to say this:
That if we find coliform in the paper mill or sugar beet
wastes, I think our scientists will not go along with the
notion that there are no pathogens present. They find that
if the coliform count is positive, it requires chlorination
for. disinfection.
MR. OEMING: I accept this, Mr. Stein, but I
mean the question has been raised here, and I wanted to
clear the air.
MR. STEIN: Well, you don't have any problem
with that concept, do you, Mr. Lyon?
MR. LYON: No, not at all.
MR. STEIN: All right?
MR. OEMING: All right.
MR. STEIN: Thank you.
If there are no further comments, may we hear
from New York?
-------
520-A
(The following letter was submitted for the
record:
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF HEALTH
P.O. BOX 90
Harrlsburg 17120
July 7, 1966
C. L. Wilbar, Jr., M.D.
Secretary of Health
Mr. Murray Stein, Chief
Enforcement Program
Federal Water Pollution Control
Administration
Department of Health, Education, & Welfare
633 Indiana Avenue, N.W.
Washington, D. C. 20203
Dear Murray:
At the Lake Erie Conference held in Cleveland on
June 22, 1966, I informed the Conferees that in Pennsylvania
all sewage treatment plants discharging to Lake Erie have
chlorination. At that time, you questioned me concerning
Girard and Lake City.
The Borough of Girard has no chlorination
-------
520-B
facilities. They do have a time schedule submitted which
calls for compliance by August 30, 1968. The schedule in-
cludes for completion of sewage treatment plant modifica-
tions, including the installation of chlorination facili-
ties.
Lake City just completed construction of modifica-
tions which includes a chlorinator and contact tank. We
plan to inspect these new facilities in the near- future.
I apologize for my oversight and would request
that the conference record be amended accordingly.
Sincerely yours,
/a/ Walt
Walter A, Lyon, Director
Division of Sanitary Engineering)
-------
521
D. Metzler
STATEMENT OP DWIGHT METZLER, CONFEREE
AND DEPUTY COMMISSIONER, NEW YORK STATE
DEPARTMENT OF HEALTH
MR. METZLER: Mr. Quigley, Chairman Stein:
I am Dwight Metzler, New York's latest import.
We heard this morning from the Secretary of some
of the progress which New York is making in providing some
leadership in this area. There certainly has been an
organizational upgrading of the entire water pollution
effort in New York State since the last conference.
New York State's Pure Waters Program is imaginative
and realistic. It is based upon several major points.
The first is that financing is a problem, and
therefore the State will provide for a part of the financing.
You have already heard about the billion dollar
bond issue. I like to call this a thousand megabucks,
but everyone can use his own terminology. New York voters
have voted a thousand megabucks to help finance this program,
30 cents on the dollar coming from the State, and it is
advancing another 30 cents on the dollar to local communities
for what we hope we might be reimbursed if the Federal
Government catches up with us.
-------
522
D. Metzler
The second portion of this is a tax incentive
program for industry.
The third deals with water quality standards
which have been under way in development in New York State
for a period of time., and are now adopted.
The fourth point involves bringing people to
hearings, and I can say to you that every major polluter
in New York State will have been in on hearings before
the summer is out.
In the last six months again, I am reporting
State-wide, because I have been in New York almost two
weeks now so I know only the very general outlines of the
program but in the last six months we have approved or
are reviewing plans for nearly half a billion dollars --
that is, five hundred megabucks -- of treatment plant
construction, and over three times this is the total Federal
investment in the whole country this year in the construc-
tion grants program.
We welcome this opportunity to participate in
the conference and in this demonstration of Federal-State
responsibility.
I have asked Mr. Hennigan to present to you the
details on how we have reacted to the findings of the
conference since it met.
-------
523
R. D. Hennigan
STATEMENT OP ROBERT D. HENNIGAN, CONFEREE
AND DIRECTOR, BUREAU OF WATER RESOURCES,
NEW YORK STATE DEPARTMENT OF HEALTH
MR. HENNIGAN: Mr. Quigley, Mr. Stein, fellow
Conferees, Ladies and Gentlemen:
The New York State program has been covered to
some extent by Secretary Udall. We appreciate his remarks.
It represents, in terms of a State, a commitment to effective
water pollution control, a landmark in this country.
When the Lake Erie Conference was called some
ten to eleven months ago, New York State|s program was a
hope and held great potential. Although the main elements
had been enacted into law prior to the conference, there
was some trepidation as to what the people would do when
the issue was presented to them in the election of November
2, 1965. The possibility of the New York State program
and its effectiveness is no longer speculative; the people
of New York gave the most resounding endorsement in State
history to Proposition No. 1, which called for a billion
dollar bond issue to finance the construction grants feature
of the Pure Waters Program.
Eighty percent approval, 60 percent voter
-------
524
R. D. Hennigan
participation, uniformity of results from area to area,
and the exercise of discrimination on the remaining 11
issues on the ballot all point out the uniqueness of this
endorsement by the people for an effective water quality
management program.
You are all familiar with segments of the
intense activity and great strides forward which have taken
place in the past year. My purpose is to present the
totality of the Pure Waters Program and its impact across
the State.
A number of things have contributed to the
mounting public concern and awareness of water pollution
control. This awareness continues to grow and there does
not appear to be any sign of diminishing interest. The
obvious fact of pollution, the increasing population, the
pressures for more water for every use, the generation of
more and more wastewater to be disposed of, the drought of
the past four years focusing particularly on the water
supply problem of the City of New York, the tremendous news
media coverage, plus the publication of such books as
"Silent Spring" by Rachel Carson, "Disaster by Default" by
Frank Graham, Jr., and "Death of the Sweet Waters" by Donald
E. Carr, have all aroused public opinion and have kept It
at a very high pitch. There will never be any returning
-------
525
R. D. Hennigan
to the old days of "too little too late." The threshold
of tolerance of the people is very low; continued public
demand and support is to be expected.
In the Great Lakes picture, from Lake Superior
through Lake Erie, New York State is the State more sinned
against than sinning. It is the downstream State. All
the water in the Great Lakes system eventually passes
through the front yard of the City of Buffalo and continues
down the Straits of Niagara into Lake Ontario. Consequently,
we are very concerned and have a great interest in seeing
effective pollution control activities carried out by our
sister States upstream.
New York State has the most dynamic, forward-
looking pollution control program in the United States and
perhaps in the world. It has been maturing since 19^9 and
reached fruition with the vote of November 2, 1965. It
combines the necessary fiscal and planning commitments
with vigorous enforcement activities and technological tools
needed to effectively combat this threat to our very
existence. However, we in New York recognize that no matter
how effective the New York State program, it cannot be
totally successful unless there is an effective program on
the national level and in each of our sister States. The
-------
526
R. D. Hennigan
geographic and hydrological characteristics of New York
State place great emphasis on this need. We are involved
in International waters on our western and northern
boundaries, and are party to no less than seven interstate
compacts relating to water resource development and water
pollution control. As John Dunne said, "No man is an
island unto himself," and New York State cannot carry out
an effective water resource development and water quality
management program without effective action at both the
Federal and State levels.
The growth and development of the Federal program
from 1948 through 1965 and its continuing development with
the proposed legislation in this session, reflect the great
national concern and surely indicate the desire of the
people for government at all levels to move effectively in
the area of water pollution control. We not only welcome
Federal concern and programming in this area; we think it is
an absolute essential, including meaningful financial
participation. There must be a national policy on water
pollution -- one which establishes minimum criteria with
which all State programs must conform consistent with local
conditions and peculiarities. Without this, there is the
threat of industrial relocation from areas with vigorous
pollution control programs to areas with weak pollution
-------
527
R. D. Hennlgan
control programs. Although it has been my personal ex-
perience that in most instances this threat is more potential
than actual. The Federal financial commitment for construc-
tion grants must be commensurate with the need; otherwise
remedial action will be stymied.
One major need if the campaign for effective
water quality management is to succeed is to reorient the
approach in thinking, particularly in the technological
approach to pollution abatement. Instead of studying and
emphasizing the ability of our waters to take more and more
wastewater, we must focus our energies on how to remove
those undesirable constituents in wastewaters before dis-
charging into lakes and streams. There is so much waste
that is subject only to imperfect control that we must
remove the maximum amount of contaminants from our waste-
waters that is technically and fiscally feasible. The waste
assimilation capacities of our lakes and streams has been
overworked to the point that the very concept has played
a major role in the deterioration of water quality across
the country. This should be of concern only after we have
effected maximum removals and should not be used as an
excuse for minimum effort and minimum treatment before dis-
charge into the waters of the Nation. The construction cost
-------
52-S
R. P. Hennlgan
for the total sewer utility is divided 70-90 percent for
collection and 10-30 percent for treatment; yet we still
have people who will try to effect questionable economies
by insisting on less than full treatment, a phantom economy
at best which in reality represents a small part of the
total capital investment in the sewer utility.
Continual urban-industrial development, which
will follow our increasing population, makes effective
action in this area even more urgent -- action which must
cover the whole gambit of water resource management; not
solely water pollution control. Although without effective
water pollution control, effective management of our water
resources is impossible. We are long past the time for
quibbling about the need. The need is obvious. Future
demands even in face of decreasing birth rates will be
enormous. Effective programs are needed at the Federal,
State and local levels. A partnership must be welded in
the public interest which will insure that these three
levels of government work together effectively to meet
these demands.
New York State has shown the way. The people
will support a realistic aggressive approach. Interstate
and Federal cooperation and participation is essential as
is a strong national policy and program. The future is
-------
529
R. D. Hennigan
bright; the time for action is now, as expressed by these
words of Shakespeare:
"There is a tide in the affairs of men
Which, taken at the flood, leads on to fortune;
Omitted, all the voyage of their life,
Is bound in shallows and in miseries.
On such a full sea are we now afloat;
And we must take the current when it serves
Or lose our venture."
New York State Activity Regarding
Recommendations and Conclusions
of the Lake Erie Conference
Although the recommendations agreed upon at the
Lake Erie conferences last year were developed in a short
period of time, implementation by New York State in the
past ten months has demonstrated, with only minor exception,
that the action of the conferees was sound and reasonable.
Of the 27 items cited at the conferences, 6 were conclusions
and 20 were specific recommendations for action both by the
States and the Federal Government. The final item was
administrative in nature, having to do with reconvening this
conference.
-------
530
R. De Hennigan
The conclusions reached are both specific and
general in nature. They are specific in order to establish
jurisdiction and general in order to provide a foundation
for State and Federal action, recognizing that our single
problem -- pollution of Lake Erie is made up of a myriad
of individual technical, economic, legislative and planning
problems. New York State welcomed the conclusions reached,
and it has been demonstrated to us that they have been of
significant assistance in the promotion and conduct of a
vigorous State program.
Implementation of the recommendations has been
done within the framework of our ongoing State-wide pollu-
tion control activities. New York State drainage to Lake
Erie is minor -- reportedly accounting for about 37$ of
the phosphate input, h% of the industrial outfalls, less
than Vjo of the suspended solid input, and a fraction of a
percent of the chloride and nitrogen input. While the
existence of a drainage area to Lake Erie is a hydrological
reality, the boundary of the drainage area is but an artifact
when considered with the configuration of our political
subdivisions. Hence our activity has not been limited to
the drainage area per se, rather to a broader municipal base,
including the entire areas of Erie, Chautauqua, Cattaraugus,
Genesee and Wyoming Counties. The ability to construct
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531
R. D. Hennigan
public works rests with municipalities who are, incidentally,
located in one or more sub-drainage areas.
Some comment should be made in regard to our
activity associated with specific recommendations of the
conferees.
1. Item 7 the need for secondary treatment
to effectuate the maximum reduction o-f BOD
and phosphates. Every municipality in the
State, including, of course, those in the Lake
Erie drainage basin, has been notified of
treatment requirements. This amounts to a
requirement of at least secondary treatment
in all cases. Appended is a resolution by the
State Water Resources Commission supporting
this policy. It is fundamental that a defini-
tion of secondary treatment be adopted. This
has been done and is also appended.
2. Item 8 -- the need to design plants which
maximize phosphate removal. This recommendation
is important from the standpoint of our abate-
ment schedules. Unless answers are forthcoming,
delays can be expected. We await information
and guidance in regard to this matter from the
-------
532
R. D. Hennigan
Federal Water Pollution Control Agency as
described in Item 20 of the Recommendations
and Conclusions of the Conference. We have
attacked this design problem through our Health
Commissioner's Special Committee on Algae and
Related Problems and have made studies of removal
by conventional treatment processes. Frankly, we
are far from a complete answer. Our findings
will be shared with the hope that, in partnership
with Water Pollution Control Administration,
practical solutions will be found.
3. Item 9 -- disinfection of municipal waste
effluents. All treatment facilities are being
designed to comply with this recommendation.
New York State has a statute which sets standards
for the bacteriological quality of surface waters.
To meet the requirements of the statute, con-
tinuous chlorination is required.
k. Item 10 -- treatment plant design to prevent by-
passing untreated wastes. We welcome this rein-
forcement of existing State policy.
5. Item 11 -- elimination of and prohibition of
combined sewer construction; surveillance of
overflow structures. Prior State policy prohibits
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533
R. D. Hennigan
the construction of combined sewers in
urbanizing areas. Our sewage treatment plant
operation and maintenance grant program has
served as an additional tool in guaranteeing
the surveillance and proper operation of over-
flows and flow-regulating devices. (A copy of
a status report on our O&M program is appended.)
It is not enough to prevent new construction
of combined sewers and surveillance of overflow
devices. We all face the problems caused by
existing combined sewers. This is a particu-
larly difficult problem in Erie County. The
major thrust of the recently initiated State-
sponsored Erie County Comprehensive Sewerage
Study will be directed toward the investigation
of methods to ameliorate current problems
associated with combined sewers. We are hopeful
that the methodology developed for use in Erie
County by this study will be applicable to other
areas facing similar problems.
6. Item 12 and 13 prevention of spills of waste
materials and reports of spills. Industries
have been alerted to the need of continuous
surveillance of operation within their plants to
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534
R. D. Hennigan
prevent accidental spills. An alerting system
for accidental spills was Instituted In the
Niagara River area some 10 years ago. This system
covers most of the Industries in the New York
portion of the Lake Erie Drainage Basin.
7. Item 14 disposal of solid wastes to Lake Erie
and its tributaries. The mere prohibition of
dumping is not sufficient. There mnst be a
logical plan established and then Implemented for
the handling and disposal of solid wastes. The
1966 Legislature has enacted a statute which
enables municipalities to make comprehensive
studies of solid waste needs. The program is
similar to our comprehensive water supply and
sewerage needs study programs.
8. Item 15 -- control of run-off. We understand
area meetings have been held and are planned for
the New York State-Pennsylvania area. Of course,
we have a Pesticide Control Board now.
9. Item 16 -- improved practices for reduction of
industrial pollutants. A routine portion of our
enforcement contacts with industry includes
review of practices to reduce contaminants. The
matter is formally reviewed by consulting engineers
-------
535
submitting engineering reports to the State
Health Department.
10. Items 17 and 18 sampling of industrial wastes
and maintenance of records. Chapter 595 of the
1966 Laws of New York State was discussed in
detail earlier. This strengthens the State's
previous general authority in this area. Chapter
595 is specific; it permits the State to comply
completely with item 17. State files on pollu-
tion are open files.
-------
536
R. D. Hennigan
All Industries In the basin have been advised
of the conclusions and the results of the Lake Erie
conference. They have been advised that the State policy
Is to proceed on formal legal proceedings, and we are
moving In that direction.
In terms of specific orders Issued In the
Lake Erie Basin as a result of legal proceedings, orders
have been issued against Moench Tanning, Brocton Village,
National Aniline, Lawtons Can Company, Lancaster Village,
DePew Village, two sewer districts in the Town of Amherst,
Mt. Vernon sewer district, and the Village of Silver Creek,
which you might be aware of.
We had another experience similar to that on
this particular watershed relating to a paper mill, and
that situation has been abated and the paper mill went out
of business.
MR. STEIN: Mr. Hennigan, I wonder, for the
purposes of the record, if at this point I might ask a
question?
Since you issued the orders against those, do I
assume that you consider the progress in Buffalo in reducing
its BOD 22-\ percent; Tonawanda Township reducing its BOD
12 percentj and the following industrial firms Socony
Vacuum Oil Company discharging oil, phenolics and cyanidesj
-------
537
R. D. Hennigan
and Hanna Coal Company discharging phenolics, cyanides,
ammonia, oil, solids, and BOD; Republic Steel Company,
phenolJxjs, cyanides, oil and solids; Federal Chemical
discharging inorganic wastes -- the progress there is
satisfactory so that you don't have to issue orders?
MR. HENNIGAN: We are going to issue orders
against everybody.
We are now negotiating with Bethlehem Steel
and we have every indication that the important thing,
as far as the State program is concerned, is the formal
legal proceedings are becoming a part of every enforcement
action, including municipalities. In other words, we are
not proceeding on the basis that somebody promises to be
good without a legal hold on them.
National Aniline is now under order. We are
negotiating with Bethlehem Steel. We are negotiating with
Republic Steel. This is all on a legal order basis.
As I say, we are going to issue the rest of
them in their particular Buffalo River complex. The major
primary plants are Tonawanda in the City of Buffalo, operated
by the Buffalo Sewer Authority, which now discharges the
waste into the Niagara River, or a tributary of it, and
these municipalities have all been advised they are going
to have to put in secondary treatment.
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538
R. D. Hennigan
On a State-wide basis we are handling about
12 to 15 legal proceedings a month, and these people will
get into the pipeline when their turn comes around.
As a matter of fact, we concentrated on the Hudson
River for quite a while -- that is, after we got the bond
issue passed.
11. Item 19 -- Federal surveillance of Lake Erie and
State surveillance of tributaries. A manual sur-
face and ground water network has been in operation
for several years. Approval has been secured for
a 60-station automatic water quality monitoring net-
work, and two stations are presently being installed,
12. Item 21 -- conduct of regional plans involving area-
wide solutions. Appended are status reports on
comprehensive sewerage and public water supply
studies sponsored by the State Health Department.
These are generally county-wide studies. The Erie
County comprehensive sewerage study was cited ear-
lier as an example of these studies. The Erie-
Niagara Regional Water Resources Planning and
Development Board Study is progressing rapidly and
serves as a regional reference for the more speci-
fic utilities studies which are being prepared.
One thing that is important in the regional planning
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539
R. D. Hennigan
and one thing which should have emphasis is the discharge
of sewers in the combined sewer problem, which is very
acute in the Erie County area.
13. Items 22 and 23 report of remedial action
and construction schedule. A schedule has been
submitted for evaluation. The realities of the
time involved to secure intermunlcipal coopera-
tion, prepare preliminary and final plans,
process Federal grants and to construct should
be carefully reviewed. As mentioned earlier,
we are concerned over the development of a
phosphate removal methodology and its insertion
into abatement timetables. Federal guidance
followed by conferee agreement is essential in
this area.
We have established some sort of preference. As
I mentioned, we go into the formal legal proceeding, the
start of a comprehensive study of both water supply and
sewage, qnd also the operation of the State operation and
maintenance program, and the requirement of additional
treatment facilities.
At the present time, roughly some $500,000 has
been granted to 25 municipalities in this area.
We have plenty of problems left, and I would be
-------
R. D. Hennigan
less than straightforward if I tried to give you the idea
that we had all the problems solved in the Lake Erie
Watershed, or any other place in the State. The truth of
the matter is, we do not.
We have the tools and we have the program, and
it is a program that is moving forward. The construction
grant phase of it is just getting into gear.
Public opinion has been all the way on this.
The reaction of the municipalities has been quite good.
Some of the industries are rather surprised that maybe the
State means business, but the whole program is moving ahead,
Within the next week or two a comprehensive report on the
first year of the entire State program will probably be
released from Albany.
Details of New York State Activities
in the
Lake Erie Drainage Basin
Additional activities in the areas of comprehensive
utility planning, construction grants, and operation and
maintenance grants are presented in tabular form. Enforce-
ment details were submitted previously in accordance with
the Conference agreements.
-------
541
R. D. Hennigan
Highlights of our activities in the basin include:
l) Successful legal ac-tion against the Village
of Silver Creek. Construction is under way.
2) Accelerated enforcement hearings, including
major municipal and industrial polluters.
12 hearings and 9 Commissioner's orders.
3) Complete involvement in comprehensive
sewerage studies.
4) Comprehensive public water supply studies
for 6 areas cover the major portion of the
drainage basin.
5) Sewage treatment plant operation and main-
tenance grants paid to 25 municipalities at
a cost of $475,9^.52.
-------
542
R. D. Hennigan
Comprehensive Intermunicipal Public Water Supply Studies
Lake Erie Drainage Basin
Status
Studies in Progress
PWS-2
Erie-Cattaraugus Counties
(Gowanda and Environs)
Study Applications
Being Processed
PWS-37
PWS-40
PWS-42
Genesee County
Orleans County
Wyoming County
Local Action to Prepare Applications
Chautauqua County
Cattaraugus County
-------
-16-
STATUS OF COMPREHENSIVE SEWAGE STUDIES
LAKE ERIE DRAINAGE BASIN
Administrative
Countv
Cattaraugus
Chautauqua
Erie
Wyoming
TOTALS
In Progress Approval
0 1
Sewer Agency
0 1
Hanover (T)
2 2
Eden (T) Depew (V)
$18,014 Grand Island (T)
Holland (T)
$12,107
1 0
Arcade (V)
$18,450
3 4
$48,571
Disapproved
0
0
3
Lancaster (V)
and Environs
Lackawanna (C)
County Sewer
District #3
1
Sheldon (T)
4
Being Processed
0
2
Charlotte (T)
Chautauqua County
3
Elma (T)
Erie County Study
Collins (T)
1
Wyoming County
6
-------
STATUS OF SEWAGE TREATMENT PLANT
OPERATION AND MAINTENANCE PROGRAM
LAKE ERIE DRAINAGE BASIN
Municipality and County
Chautauqua County
Dunkirk (C)
Westfield (V)
Ripley (T)
Fredonia (V)
Cattaraucus County
Gowanda (V)
Erie County
Blasdell IV)
Buffalo (C)
North Collins (V)
Springville (V)
Lancaster (V)
Lancaster (T)
Hamburg (T)
- Sneldon Acres STP
Lackawanna (C)
Crcnard Park (V)
West Seneca (T)
Boston (T)
- Sewer District #1
- Sewer District #2
Grant
Approved
X
X
X
X
X
X
X
X
Grant Applications
Disapproved Beinq Processed Grant Request
$ 29,807*82
4,954.37
X 2,706,51
X
$ 4,657.04
$ 12,927.83
409,682<,14
2,171.72
3, 626 ,,57
5,256.76
X
X
X 60,172.66
X 2,795»49
X 33,119.62
X 231.50
X 534,70
-------
-IS-
545
.Vi^nicipality and County
Erie County (cont'd)
Hamburg (l) STP
- 3enz STP
- Lakecrest Terrace
- Bethford
- Wanakah S.D.
Bepew (V)
Hamburg (V)
Mt. Vernon S.DU
Erie County S.D» #2,
North Plant
Erie County S.D.,
South Plant
Grant
Approved
Grant
-approved
Applications
Being Processed
Grant Requested
X
X
X
X
X
X
X
X
X
X
$ 15,883.72
583.34
667.22
1,171.95
4,570.65
8,816.13
6,719,61
4,877.00
5,600.87
12,134.11
Wyoming County
Arcade (V)
X
$ 2,860.27
TOTAL GRANT APPROVED
GRAND TOTAL
$ 475,944.52
TOTAL APPLICATIONS ON HAND" $ 160,585.08
$ 636,529.60
includes some applications which will be disapproved
-------
546
R. D. Hennigan
MR. STEIN: Thank you, Mr. Hennigan.
Are there any comments or questions?
(No response,, )
MR. STEIN: If not, I don't think that the
characteristic candor of Mr. Hennigan should Indicate to
anyone that the New York program isn't moving along as well
as the other State programs. It probably is, but, you know,
there are different ways of saying it.
No further comments or questions?
MR. POSTON: Wait a minute.
MR. STEIN: Yes.
MR. POSTON: I was expecting to hear some tenta-
tive dates that you might expect to come forth with on the
construction of the needed facilities, and it seems to me,
as a conferee, that this is one of the things that we are
here for, but I don't know whether this is
MR. STEIN: I don't know. I thought possibly
we would go over these points, particularly the dates, with
all the States together in the summary, if they didn't
offer it in their original statements, to reconcile it and
get a statement from all the States concerned.
We do have these two recommendations, and I think
you all know this probably the key recommendations
for this Meeting are Recommendations 22 and 23.
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R. D. Hennigan
Recommendation 22 says:
"Within six months after the issuance of
this summary, the State water pollution agency
concerned will present a schedule of remedial
action to the conferees for their consideration
and evaluation."
The Federal conferee then, in No. 23, recommended
some dates for consideration by the State agency, dealing
with municipal treatment, discontinuance of trash and
garbage dumping, and industrial waste treatment facilities.
I think what we have attempted to do here is
allow the States to present their reports as we usually do
in their own manner, and try to see what reconciliation
and what compliance we can get.
I do think that it is quite clear that we have
pretty substantial agreement among the States -- and I think
this is a very good point -- from Recommendation 7 right on
through all the recommendations.
I think one thing we will have to clarify and
attempt to get a precise, simple statement on is the
schedule of remedial action for the various States. It
might be wise to go over this No. 23 with each State to-
gether and see if we can collate those.
If that procedure is satisfactory, maybe we can
-------
R. D. Hennigan
wait until we have this go-around and call on each State
point by point. All right?
MR. BOSTON: All right.
MR. STEIN: Well, thank you, Mr. Hennigan.
Are there any other statements?
MR. METZLER: Mr. Chairman, I have a question of
procedure. I hope you will bear with me because I am a
late-comer to this conference,
MR. STEIN: Dwight, we have worked together for
all these years. You probably have more experience in
conferences than anyone else in this room except me, but go
ahead.
MR. METZLER: Well, actually I wanted to draw
on that experience, Murray, just briefly, to inquire if, as
I have noted we have done elsewhere, there was an oppor-
tunity for the delegations who may be along with the States
also to make a contribution. I hope that you weren't going
to wind this up before they had a chance to.
MR. STEIN: No. We will give you an opportunity
to do that.
Let me give you the commitments we have here.
MR. METZLER: All right.
MR. STEIN: A lot of the people at the table had
come here with the notion of a one-day meeting.
-------
We all welcomed -- I include myself, of course --
the addition of the Secretary and the other dignitaries we
have had here.
Recognizing the importance of that from a Federal-
State-city-industrial push on the program, we are way ahead
in having the Secretary here. I believe he gained an
appreciation in hearing and being with you people here and
in the course of the boat trip that he never could get in
Washington by hearing this second-hand from Mr. Quigley or
myself.
However,, I think by getting these additions, we,
of necessity, must be more brief. Some of the State people
did not expect to stay more than one day. Now, with that
in mind, if they expect to leave tonight, I would appreci-
ate it if any people you called on kept their statements
brief. We have to run through the summary and also try to
have the conferees here make their commitments.
We recognize that we used several hours for a
boat trip and other things which were not contemplated when
we originally came.
With that, Mr. Fetzler, you may go ahead and call
the people.
MR. METZLER: Thank you. I actually have a request
for a two-minute statement from one of New York's representa-
tives, and he is the only one.
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550
S. P. Spisiak
STATEMENT OF STANLEY P. SPISIAK, REPRE-
SENTING THE NEW YORK STATE CONSERVATION
COUNCIL
MR. SPISIAK: Thank you.
I can talk fast, but I don't believe I will
make It In quite two minutes.
I am a
citizen of New York State, and am quite proud of the leader-
ship that New York State has assumed, although Ohio seems
to be doing a better propaganda job in claiming credit for
a million dollar program. When I heard that presented, I
wanted to ask that you give us a little bit of credit also.
Be that as it may, I am concerned with only one
particular point, and this is a very important point. Up
to this time, we have had so much harmony and peace that
perhaps a word or two of friendly criticism would not be
amiss.
S ometimes I find that
it is necessary for me to express my opinion, which is not
always favorable, and at this moment I would feel in a
kindred position.
-------
551
S. P. Spisiak
The Federal people have asked us so many
questions, and we have answered them diligently. I think
it time now that we ask just one question.
I am concerned about something that is of great
Importance and can have an immediate beneficial effect.
This pertains to something that I hoped our boat trip
people would have been able to visit with and see a little
bit more distinctly. However, this pleasure was somehow
denied them.
This is the dredging of material from your
river, andj more importantly, the one
that I am more concerned with, the removal of debris from
the Buffalo River.
You heard Chairman Stein just a few minutes ago
ask our good friend, Bob Hennigan, about Republic Steel,
National Aniline, and a few other contributors to an open
sewer commonly called the Buffalo River. This is a sub-
sidized sewer which exists primarily for the purpose of
removing waste material for five major industries in the
Buffalo area. The solids and settleable solids, the acids,
the phenols, the cyanides, the oils, the tars -- every
deadly and undesirable type of material is discharged by
these industries into this Buffalo sewer or Buffalo River,
if you will.
-------
552
S. P. Spisiak
This material, the major portion of it in
fact, I think there has been a waste here some place,
because the discovery of heavy water could have been many
years sooner if they had just made a trip up the Buffalo
River, because certainly the buoyancy of this water is
such that even wood finds a hard time floating upon it,
and ship captains refer to this as the scrubbing river.
When they need to refinish their hulls, they only spend,
with their metal hulls, an overnight trip in the Buffalo
River, and their hulls are completely scoured when they
come from it, so that they can have them repainted without
any additional work.
Now, through the courtesy of the Corps of
Engineers and the United States Government, 125,000 cubic
yards, or, more specifically, 25 million gallons, since
this is a liquid and should be measured as such, of this
deadly and toxic material is removed each year, and then
taken from a river where it would no longer do any harm.
We are placed in double jeopardy because this material is
removed and, like a caged tiger, is released upon our
bathing beaches. This is dumped into what is called the
Woodlawn Beach, in a one-mile square area, where this
125,000 cubic yards each year has been disposed of in a
one-mile square area, which was 12 feet deep before this
-------
553
S. P. Splsiak
discharge started, and which now, more than a quarter of
a century later, is still 12 feet deep.
Realize that this material is moving, as all
liquids will, with the will of the wind and the wisp of
the waves, and it is finding its way all along our bathing
beaches, to the point that the State of New York, through
the good grace of the Federal Government, has had to close
the majority of the beaches.
In fact, every single beach in the State of New
York should be closed largely as a result of the discharge
of these materials, which are placed in a position where
they can render the greatest deal of harm.
This, I think, is a question for us to have
answered, not as evasively as it was answered this morning
by the Corps of Engineers.
Here I would just like to read very briefly one
paragraph of a letter from Senator Kennedy:
"Thank you for arranging the trip on the
Buffalo River on June 17, 1965. I found the
conditions on the river from a visible standpoint
shocking. Dredging the wastes from a river bottom
and depositing them in the harbor seems to offer a
great danger of contamination to local water
supplies."
-------
55^
S. P. Spisiak
I might add our water intake is downstream
about one mile from the discharge point of these deadly
toxic materials, and at times -- at times has entered the
public drinking supply in the City of Buffalo.
In Point 25 of the recommendations of the
conferees of this group last year, representatives of the
United States Army Corps of Engineers are to meet with the
conferees, develop and put into action a program for the
disposal of dredged material in Lake Erie and its tributaries,
which will satisfactorily protect water quality. Such a
program is to be developed within six months after the
issuance of this summary and effectuated as soon as possible
thereafter.
The report this morning was that this matter is
bogged down and tied down one year and a few days later, and
has reached no satisfactory conclusion.
At this very identical moment, the discharge of
these materials is continuing, and will suspend within one
week, having completed its job. You and your Cuyahoga
River here are disposing of not just 125,000 cubic yards,
but nearly 8 to 10 times as much of this material, and you
are placing yourselves in double jeopardy.
I think it would be nice if we left this group
here today with some assurance that the Federal Government
-------
555
S. P. Spisiak
will meet its responsibility and that this double jeopardy
will cease to exist.
Thank you.
MR. STEIN: Thank you, Mr. Spisiak.
You know, I really think good propaganda jobs
are important, because they show people are interested. While
I am all for them and would like to encourage them, I wonder
sometimes, with your $1 billion bond issue and the appeal
and approach and the focus on this of Governor Rockefeller
and Senator Kennedy, and with that wonderful speech you just
made, how we can possibly accuse Ohio of doing a better
propaganda job than New York.
(Laughter.)
I think the propaganda job that you have done in
New York has been wonderful. As a matter of fact, the
Secretary and everyone in Washington knows about that $1
billion bond issue you passed in New York.
MR. SPISIAK: It bears repetition.
MR. STEIN: I know it bears repetition, but I
wish some of the other States would do the propaganda job
that New York has done, because this is what starts pollution
control moving.
Are there any comments or questions?
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556
S. P. Spisiak
MR. POOLE: What do you want? Pollution control
or propaganda now?
MR. STEIN: I think they go hand in hand.
(Laughter.)
MR. SPISIAK: Nothing happens until the sale is
made.
MR. STEIN: Do we have any other comments or
questions?
(No response. )
MR. STEIN: Or do any of the other conferees
have invitees from their States?
(No response. )
MR. STEIN: If not, we can, I think, proceed
with the summary.
I think we can indicate that we have substantial
agreement on most of the recommendations and adherance to
those by the States. I don't know they have been
repeated over and over again whether we have to go over
these again, about secondary treatment from the munici-
palities; the removal of phosphates from municipal treat-
ment plants to the maximum; the disinfection of municipal
waste effluents where required; the design to prevent the
necessary bypassing and the problem of elimination of the
combined sewer problem; the program to prevent accidental
-------
557
Summary
spills, and the reporting of accidental spills; the
prohibiting of dumping garbage, trash and other deleterious
substances into Lake Erie; and, the question of the highway
and community development programs for controlling of
runoff.
This last point may be one we may want to discuss,
because, as I have heard the reports here, as far as I see
it, the reports are not completely or materially going to
solve the problem.
We have a problem here. As I understand it, the
road officials are going to achieve earlier ground cover.
As I understand the proposal, there is no program, and
possibly no feasible way during the construction to stop
the runoff. We are going to be plagued with the problem
continually until we do that, unless we devise a method
of constructing roads which will prevent runoff. However,
I don't think there is any point in deluding ourselves
that we have solved our problem. If I am wrong on that,
let me know.
Is it fruitful to have any further meetings with
the roads people to see if we can improve this practice?
Phis isn't just roads, you know. It is subdivisions too.
Mr. Metzler:
MR. METZLER: I just wanted to point out that in
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55&
Summary
New York State, as I understand it -- and I think Mr.
Hennigan referred briefly to this -- we attacked the
biggest one first, and that was the road-building people.
Governor Rockefeller is very much personally
interested in this aspect of the approach, but you are
quite right in saying we have no solution. However, we
found some responsible people who are willing to be
cooperative on this part of the program.
MR. STEIN: My view on this, gentlemen, is that
as long as we have the road program and the runoffs, we are
going to get complaints. There is nothing like silt to
give you a complaint.
You know, I think we have done a tolerably
decent job on the Potomac River in eliminating the health
hazard, eliminating largely the sight and odor nuisance,
except in late August generally, when we still have the
algae die off. As long as that river remains muddy, people
say you haven't cleaned it up.
My notion is, if it is agreeable to the conferees,
that we, in the technical meetings with the road committee,
before the next meeting see if we can report some progress;
because if we let the problem go, then nothing is going to
be done.
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I don't know that we have a complete solution
on the roads problem now, but I think this Is going to
require continual cooperation and meeting with the people.
Possibly we can find someone to come up with some proposal
in road construction to minimize the problem.
Mr. Lyon?
MR. LYON: Mr. Chairman, I believe I understood
from Mr. Boston that there is an agreement being drawn up, or
some type of --
MR. POSTON: A directive has been written.
MR. LYON: A directive has been written that
will communicate from your agency to the Department of
Commerce?
MR. POSTON: Prom the Bureau of Public Roads
to the directors of public roads of --
MR. LYON: Prom the Bureau of Public Roads to
the appropriate State agencies?
MR. POSTON: Yes.
MR. LYON: It seems to me essential that the
Bureau of Public Roads recognize that it will cost them
additional money to attain these pollution abatement steps
in the process of highway construction.
In working with our Department of Highways, we
have found that in a number of instances they have apparently
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not allowed the funds that were necessary to prevent
pollution, and it would seem to me essential that the
Federal Government agencies come to some agreement on this.
MR. STEIN: Mr. Lyon, I will tell you, I think
you are entirely right; but I think this is somewhat
analogous to the stormwater separation problem that we had
with urban renewal.
The point is, once we have a plan or a feasible
way of doing this during construction and preventing it, I
think this has such an appeal the funds will be forthcoming.
The difficulty and the difficult position that
we are in at this time is that given that directive, can we
go to the Bureau of Roads or the State Roads Departments
or the contractors and say, if you will do so-and-so and
so-and-so, this will only cost you X more thousands of
dollars and we won't get this runoff? We do not have a
proposal like that yet.
My notion is that we should try to develop some-
thing possibly by the next conference and see if we can
work in that direction, because I don't see daylight in
solving this road problem yet. We can ameliorate it slightly
by putting on the ground cover a little faster.
MR. POSTON: I think this should apply not only
to roads, but also to agricultural runoff.
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MR. STEIN: Let's take one at a time.
Again, I will speak, certainly, on the record here,
As you know, and a lot of you do here, and Dwight has been
out in the West the hardest group to deal with in pollu-
tion is the agricultural interests. There are so many and
they are really well vested.
I think with the roads program, though, again I
say this is analogous to the storm sewer program. This is
largely a Federal program with 90 percent Federal money.
If we can come up with a method to handle the
roads program or a reasonable method, we will sell it.
Let me mention one more thing. The people who
handle the roads program in the Congress are the same
people who -handle the pollution legislation. We go before
the same committee and the same people, and we have a
very, very sympathetic group that will look at this as a
public works problem that they are ready to solve if we
can give them a solution.
I say-let's take the first things first. That
agricultural problem is going to be harder and we are going
to have to do a lot more selling to get that accepted.
If we would do that, Mr. Boston, if you could
continue the committee, or possibly get one of the bright
scientists to come up with a proposal for consideration,
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maybe we can, in dealing with the States, come up with a
consensus on a proposal that would minimize runoff during
road construction.
We go to No. 16: Industrial Plant Practices.
I think we are pretty much in agreement on that.
We have the list down here of the substances. As we all
know, these industries have to be dealt with on a case-by-
case and plant-by-plant basis.
I think we are fortunate that in the five
States represented here we have highly sophisticated
industrial waste sections in each of the States, people who
are familiar with the problems and in dealing with the
industries. I am sure adequate proposals are being developed
for each industrial plant.
I think the sampling program by industries is
proceeding apace, as I see it, from the five States; and
the results, I would say, have exceeded my most optimistic
hopes on this. I think the data disclosure program is
proceeding very well too.
I think we are on the verge of getting pretty
complete sampling, and some of the States like New York
are forming it into law. We are on the verge of getting
pretty complete disclosure of information on a routine basis,
which should help. This is one of the real accomplishments
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Summary
and the States should be commended on that.
No. 18 relates to the same thing. The surveillance
program on Lake Erie to be established by the Federal Govern-
ment is proceeding, and they are working with the States on
that.
The phosphate removal program I think has pro-
ceeded a little better than some of us had expected. We
had proposals now I know I am with Mr. Poole. He did
not get his results, but in long association with Mr. Poole
I have learned that he is a wise man to listen to and we
should heed his advice. Some of our people ha^p indicated
to us that the phosphates can be removed by changes in
operations of the plant at a cost much less than we would
have anticipated.
I think what is called for now are some pilot
plant demonstrations, and possibly we can hope to get going
on that.
I think you have two cities of interest here,
and possibly we can move forward with those -- one is
Detroit and the other is Fort Wayne. Possibly, if the
conferees wish, we can recommend that the Secretary try to
expedite these projects and see if we can come up with
plans which will remove the phosphates. Since we have two
willing guinea pigs in that area, I suggest we accept their
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offers and go ahead.
The next point on regional planning I think
has been adopted by most of the States.
Let me skip 22 and 23.
I think the Federal installation program is
moving forward and we will be in operation by August of
1966, except for that one base.
How about Selfridge? When are you going to have
that finished?
MR. POSTON: Selfridge is out of the basin.
MR. STEIN: I know, but just for my information.
MR. POSTON: I can't answer that. We can ask
Mr. Earlow.
MR. STEIN: George, are we home free on Selfridge
with a commitment, or do we still have .that up in the air?
MR. HARLOW: No.
MR. STEIN: We are not home?
MR. HARLOW: No.
MR. STEIN: So while it is out of the basin, I
think the Secretary indicated that he was working with that.
We will work with Michigan on that and hopefully report to
the conferees to see if we have solved that problem the
next time we meetr
The next point is the point that Mr. Spisiak
talked on, on the Corps of Engineers' dredged material.
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Summary
I don't know if the Corps man is here, but I
don't see, with the exchange of correspondence, gentlemen,
that we have seen daylight on that yet.
I am not sure I understand why we are going into
a cost-benefit ratio study on this at all. As far as I am
concerned, if the dredged material is to be kept out of the
lake, it is to be kept out of the lake.
We have never asked the steel representatives
or the municipal representatives to go into cost-benefit
studies on whether they should remove their wastes from the
lake. If they did, I don't KFIOW how far we would be along.
We have indicated that these wastes have to be
kept out. I wonder if we could get -- and you may have
had this -- an agreement on how much this is going to cost
and present It to the Corps and see if they will do it.
However, unless there is disagreement here, I
don't see the relationship of a cost-benefit study to
removing deleterious dredged material from the lake.
Mr. Metzler?
MR. METZLER: I don't know that it has any
connection, Mr. Chairman, with the matter at issue, but I
do understand why the Corps asked for a cost-benefit study.
As you know, they are required to show the
Public Works Committee -- .Senator Ellender especially this
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Summary
year is very adamant on this point -- a cost-benefit ratio
on all its work. They can't go back into the Congress with
less than a substantial cust-beneflt ratio, or they will be
turned down by the Public Works Committee.
Now, the Public Works Committee is the committee
on appropriations, and I believe this is the reason.
But the only reason that I make this explanation
is that I think it requires probably a partial answer
rather than one which can be answered entirely.
MR. STEIN: This is true in regular rivers and
harbors work, but I think in pollution control work we
haven't had that.
I think the thing we have to find out is how
much extra this will cost the Corps of Engineers a year
to put the dredged material in appropriate places, behind
dikes, rather than dumping it in the lake, and see if they
or the Congress want to buy it in addition to the cost-
benefit. But I would simply, in going before the people
we go before in the Congress, use the principle of clean
water overriding other cost benefits.
MR. POSTON: We gave that figure this morning
the Corps did General Dodge.
MR. STEIN: I didn't know that that was read.
Yes, it was. It is estimated about $110 million over a
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Summary
ten-year life, which is $11 million a year.
MR. BOSTON: He has an annual charge of $16
million more. He says that it is $16 million a year.
MR. STEIN: $16 million a year to prevent
dredged material from getting into Lake Erie?
MR. BOSTON: Right.
MR. STEIN: I would say here and now I think it
is a bargain, but, of course, it is for the Congress to make
the decision.
The reason that I say it is a bargain is because
I think if we were to deal with a municipality having that
kind of a problem and you were a State and that was what it
was going to cost them, I don't think we would have any
hesitancy in making the recommendation to a municipality.
I think the Government should assume its obligation.
The next point is the Technical Committee.
MR. LYON: May I comment?
MR. STEIN: Yes.
MR. LYON: Mr. Chairman, I have to catch a plane,
so, with your permission, I would like to designate Mr.
Miller as Pennsylvania's conferee for the remainder of the
conference.
MR. STEIN: Will he be prepared to talk as to
dates?
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Summary
MR. LYON: Yes. He has all the Information.
MR. STEIN: All right.
MR. LYON: With regard to Item 26, I feel, as I
think is generally agreed, that the Technical Committee
should not only be continued, but should continue to devote
itself to the questions which remain very largely unanswered
that were set forth in the adoption of the technical report
presented this morning.
In this connection, I want to emphasize again
that although, as you have indicated, a number of pilot
plant studies are going on that will tell us how better
to remove phosphates, and certainly there are many ways of
doing this, our knowledge in this area needs to be expanded.
However, even more than that, I feel, as I think
most of the conferees, or all of you do, that phosphates are
an important oollution problem of this lake.
Many of the experts that spoke to our committee
made it very clear that our knowledge of the pollution and
its effects on this lake is extremely limited, and it would
seem to me essential that we devote much more effort than
we have so far done to answering the question as to what,
in addition to ohosphates, are some of the other things that
have caused the problems of this lake.
Thank you very much.
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569
Summary
MR. STEIN: Thank you.
Mr. Oemlng:
MR. OEMING: Mr. Chairman and members of the
conference:
I would support Mr. Lyon In his remarks on the
report of the Technical Committee.
It Is my understanding from several of the
members that they did not have the opportunity to go Into
this report thoroughly, review it and concur in It. There
are also some questions that I believe are not answered
to the full satisfaction of me, at least, and to answer the
charge that was given to the committee fully.
So I would like to urge that this committee be
continued as an active committee and devote itself to further
study and obtain more of a consensus as to the conclusions
in the report that were made here today.
Now, while I have the floor here for a moment, I
may be out of order, but as to some of the points you have
already covered, I raise a question as to the emphasis that
these conferees have placed in the past upon the removal
of phosphates from the lake from all sources. Recognizing
certainly that there are some unanswered questions, we are
hopeful that they will be answered promptly enough to get
at this problem of phosphate removal.
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Summary
However, I want to ask again here as to how much
emphasis should the States put on this matter of phosphate
removal?
MR. STEIN: I don't know whom you are asking.
/
MR. OEMING: I am asking the Chairman to poll
the members.
MR. STEIN: I will tell you the way I feel about
this, and, of course, I am not sure that all our scientists
agree.
Mr. Lyon and you raise doubts that certainly I
have. I have seen these notions of what we are getting
excited about come and go in the pollution field through
the years. As a matter of fact, it used to be some of the
industries sitting around here, and then it becomes
detergents, or pesticides, or something. We always get on
something that seems to be the current fad. I think we are
on a phosphate kick now, and I don't mean the kind you get
at a soda fountain.
Now, I do believe that theoretically the
scientists are probably right. If you remove the phosphates
or you cut them down, it can only prove to help the lake.
Whether this is the complete answer, or whether it is
really going to slow up eutrophication, or whether
there are other factors we don't know
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Summary
about at this time, I think are very, very good questions.
We all have these doubts, and I think we all
understand each other on that point.
The point is in an area like this, in dealing
with a lake as we are dealing, we can only do what we know
how to, or we can only deal with substances that are indi-
cated to us.
Now, I am not sure, and I don't think anyone IS
sure that even if our wildest dreams are true on this
phosphate removal and we do a good job, that this is going
to be a panacea and we are going to see a tremendous
reduction in this plankton or algal growth in the lake
necessarily. Maybe we will. Maybe some of the biologists
who contend that will do it are right, but I think again,
as professionals -- and I think we are all professionals
in this field -- we must recognize that what we are presented
with is a theoretical concept that makes a considerable
amount of sense in order to put it through and to follow it.
It seems to be the only reasonable thing we know how to do
now, and the chances of it working may be fairly good.
If we develop a method of putting this into
operation that won't really increase the cost of waste
treatment, we might adopt that as a standard practice in
the lake.
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Summary
The point is because we are faced, on the other
hand, up here with this other thing, while we are debating
it and arguing and sharpening our criteria, the lakes may
be gone. We can't wait that long with Lake Erie. We have
to do now what we know now, and the phosphates seem to be
one indication.
I think the Technical Committee will have to
keep going and see if we can refine this problem further.
MR. OEMING: I am not fighting this. There may
be other factors. I think you have touched on the point
that concerned me as a result of this session here today.
The question of phosphate removal and the necessity of it
is debatable.
Are we talking about a debatable subject?
MR. STEIN: I don't think it is debatable now.
I don't think it is a debatable subject. I think we have
agreed on maximum phosphate removal.
I think the only thing tnat the conferees have
to have in mind is that we have a pretty good hunch that
this is going to be effective. Certainly, it is not going
to hurt.
Whether this will provide the comolete answer,
we don't know, and this is what we have to have the Tech-
nical Committee for. I have heard no one say that it isn't
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Summary
a good idea to remove those phosphates.
MR. OEMING: I was convinced of that.
MR. STEIN: Yes.
MR. OEMING: After two seconds.
MR. STEIN: Yes.
MR. OEMING: But I want to know if that has
drifted off into the great beyond and we are not concerned
with it now.
MR. STEIN: No. I think unless you get this
phosphate removal, with t-.he best knowledge that we have,
all the treatment is going to do is not going to get at one
of the key problems in the eutrophication of that lake.
MR. OEMING: In other words, secondary treatment
now, as we know it, is not the full answer.
MR. STEIN: It is not the full answer. We must
remove the phosphates, and once we remove them, we may have
a more complete answer, but we still may not have the full
answer.
Are there any comments or questions?
MR. OEMING: Would you rule, Mr. Chairman, on
this matter on what is going to happen to this committee,
the Technical Committee, that was given some assignments?
MR. STEIN: Yes. I think I have a consensus
here, as I see it, that the Technical Committee should
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Summary
continue.
It might broaden its base in getting at the
other problem that you talk about. It may wish to consult
with other experts and bring them in; and the committee,
if they are going to broaden this, I think they may have
made a first stab.
I don't look at this as horrendous in coming in
with a report that looks pretty good. I have never seen
a technical committee on a subject like that arrive at a
consensus in the time that this operation has been working.
I think the report should be circulated, as you probably
have for the States, but the Technical Committee should
begin to get the comments back from the State agencies
and the State administrators represented here, and get out
another draft report which will more nearly, or, if possible,
completely reflect the consensus.
Now, that can be done. We did this. Mr.
Kittrell, I think, and the industries and the States did
this on Lake Michigan. I think you can do it here. It
takes a lot of work and you are going to have to get together
for several meetings before you can possibly do it on a
subject like this.
MR. OEMING: Mr. Stein, may I clarify my position?
MR. STEIN: Right.
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Summary
MR. OEMING: I think you are indicating that I
am dissatisfied. I am not dissatisfied with the work of
the committee.
The committee has done a lot of work. What I
am saying is that I don't consider that the job has been
done, and I don't consider that the report as presented
reflects the consensus as you have indicated here. I would
like to see that done.
MR. STEIN: I think everyone is in complete
agreement. I don't think anyone disagrees with what you
said, Mr. Oeming.
I think this is the next job of the Technical
Committee. Your job is to do this, as I see it, and you
have the details.
Let me explain this: If we are going to meet
again, as I expect we will, on a complicated problem like
this, firstly, you have to come up with the Technical Com-
mittee reports which reflect the consensus of the Federal
Government and the five States; secondly, come up with a
pretty clear and as precise a statement as we can on the
phosphate problem and progress; and, third is the identi-
fication of what other problems we see to explore on dealing
with the lakes and what we have to do about them.
Mr. Poston?
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Summary 576
MR. POSTON: I would like to make sure that the
mission which the conferees developed and gave to the
Technical Committee they confined their work to these
specifics you can add any other specifics that you would
care to, but I would like that to be well defined to them.
MR. STEIN: Right.
MR. POSTON: And that be the entire scope of
their work.
MR. STEIN: Yes. Well, I don't think there is
any question there.
May we go on to the next point. This is probably
the reason why we are all here, this question of the time
schedule for the work. Maybe we can work back from the
middle. The easier one is the discontinuance of garbage
and trash dumping into the waters immediately.
Have any of you had any doubt about adopting that
as a policy, or not putting it into effect?
MR. OEMING: It depends on what you mean by
"immediately." If it means right now, I don't think so.
I think so far as the Michigan report is concerned,
there is now an adequate statute and regulations that are
attacking this problem. It certainly will be attacked with
vigor. If that means "immediately," within the next few
months
MR. STEIN: Yes.
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577
Summary
MR. OEMING: It will be done.
MR. STEIN: I would suggest that I don't think
there Is any way to handle a problem like we have on Lake
Erie without a progress meeting every six months, or recon-
vening every six months.
Without anticipating whether the conferees are
going to do that now, I would expect on the assumption
they are not going to propose that later, that we do that --
that in six months from now, when we come back, we all have
a pretty good report on the question of the dumping of
garbage and trash, and how far we have moved with this,
with the hopeful substantial elimination of this.
This is the kind of policing operation that you
can never completely eliminate. I suggest, though, that
we try to get substantial elimination of this by the next
time we come in.
Mr. Poole?
MR. POOLE: Mr. Chairman, I don't buy that as
long as you say "substantial elimination."
I would remind you that we have had a law for,
I guess, ten years that makes it illegal to dump garbage
and trash along the road or into any stream, and it makes
it the responsibility of every local law enforcement officer
to enforce that law.
We still can't keep all of the beer cans out of
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Summary 578
the streams in Indiana. Everybody who is involved in this
has to realize that any program has to be tempered with
some policing.
MR. STEIN: We all recognize the limitations
on that.
Now let's take up Subparagraph (c), Industrial
Waste Treatment Facilities Completed and in Operation
by January 1, 1969.
Let's go down the States as they appear in order.
Let's do this from west to east, as is usually done.
Michigan?
MR. OEMING: The final date for industrial
compliance with effluent restrictions is November 1, 1969.
MR. STEIN: November. You are a little beyond?
MR. OEMING: Yes.
MR. STEIN: November 1, 1969.
How about you, Mr. Poole?
MR. POOLE: I think we can meet it. January of
1969.
MR. STEIN: Ohio?
MR. EAGLE: Right. January 1, 1969 -- 100 percent
completion,,
MR. STEIN: Pennsylvania?
MR. MILLER: By the end of 1966, they should all
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579
Summary
be in compliance.
MR. STEIN: And New York?
MR. HENNIGAN: There always has to be somebody
to disagree.
The New York State program is predicated on a
six-year program for the entire State, which brings us to
1971.
The general policy followed throughout the State
is to use as tight a schedule as we can, depending on
circumstances, the concluding date being 1971.
MR. STEIN: You know, the problem we have here
is trying to get this in an equitable operation, arid I
think we are going to have to have a fairly uniform date
for the conferees in all the States.
MR. METZLER: Murray, you and I have had a lot
of experience in this business, and we have set dates, and
we have gone back and then changed them, altered them.
It seems to me that one of the things we might
learn about this is that one wants to adopt dates
realistically. I have not been in New York long enough
really to have enough information on this point to be sure,
but it appears to me, as I understand the problem, that if
we are to start building tomorrow some of the things that
need to be done, and assume that everyone would build as
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Summary 580
fast as he could physically, I doubt very much if we could
ask to get it done by 1969.
I am afraid that is a thing which would bother
us.
MR. STEIN: Yes.
MR. METZLER: We are pushing ahead just as
rapidly as we possibly can. We shouldn't allow any delays.
MR. STEIN: No, but I am thinking in terms of
the five-State operation.
Let me make a proposal here on this to try to
put it in the middle. Three States say they can meet
January 1, 19&9j two don't; one says November.
Supposing we say for this operation here for
the conferees, at least maybe New York you can have
your reservations but I am talking about the Secretary,
and he is going to come up, I am pretty sure, a proposal as
to this -- my recommendation is a proposal and possibly
a consensus, if you want, that we say "as early as possible
but not later than January 1, 1970." That is in the middle,
MR. POOLE: Mr. Chairman, could I make a
suggestion that we might borrow a lead from the Lake
Michigan conference?
I have forgotten the date we agreed upon there,
but we did agree upon a date with the understanding that
there might be an occasional extenuating circumstance here
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581
Summary
or there. If someone could come In and document real
reasons for a longer time,, that it would be acceptable.
How would you react to that?
MR. STEIN: Well, as Dwight says, we have worked
together for a long time. Mostly we have worked on con-
sidering the extenuating circumstances.
However, I think this is right, and I think
this is implicit in any date we set. I don't think if
we come up with this, that this would be too unreasonable.
MR. OEMING: What date are you talking about
now?
MR. STEIN: January 1, 1970.
MR. POSTON: If you are going to provide for
extenuating circumstances in some cases, why not leave
that at January, 1969?
MR. STEIN: Well, you could do that except you
have two of the major States that say they cannot comply.
The point is if we can get these within striking
distance, and I think if we could put the date of January
1970 in we can get all the States in with New York within
striking distance and maybe most of their projects within
striking distance, it would help.
The difficulty that I have in setting the date
very tight and it always looks nice at a conference --
is that once you get too many of these extenuating
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Summary 582
circumstances we are back here changing the dates.
I would think that the January 1970 date, in
view of the fact that we have two major States and I
know the problems in both of these the Detroit complex
and the Buffalo complex are not going to be easy, and
neither will the Cleveland one these are among the
toughest cases that we have in the country to get going.
I think we have to recognize these problems.
MR. OEMING: Mr. Chairman, may I comment a
moment as being one of these States that seems to be longer
than the others here?
MR. STEIN: Yes.
MR. OEMING: I would point out to the conferees
that the dates that were arrived at in Michigan were only
arrived at after long consideration of the magnitude and
the extent of the problems in the area.
The November 1, 1969, date is the one that applies
to the longest ones. There are many of these that will
mature in 1967 and 1968.
MR. STEIN: Yes.
MR. OEMING: I would also point out to the
conferees the danger here when a program has been changed
of tightening it up to the point where you now get into a
legal hassle and you get into appeals and proof of the
necessity and the practicability and the reasonableness of
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583
Summary
shortening the time. With this you can lose all of the
time you think you have gained, by setting an unrealistic
date in court.
MR. STEIN: Right. You recognize that the first
date, January 1, 1969* was just the date that was proposed
by the Federal conferee. Now we are here to decide on a
date.
I do think, in light of that, the 1970 date
might be a date, but I would suggest one modification, in
light of what you said and in light of the experience and
practice we have had with Mr. Hennigan in New York,, that it
is recognized that this be the outside date for each
industry. We are dealing with just industries, but I
suggest we do this with the cities too. I would suggest
by the next progress meeting and I assume we are going
to have that in six months the States will come up with
a time schedule for each industry as to their completion
date, industry by industry.
MR. OEMING: You have that from us.
MR. STEIN: Yes, it is true some of the States
have done it, but I am talking for all the States.
MR. OEMING: All right.
MP STEIN: And this we have found, at least in
dealing with New York on other problems, to be a very
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o 584
Summary
satisfactory way of doing this, because you almost
anticipate your extenuating circumstances. The easy ones
we are really speeding up, so perhaps we can try that.
MR. POOLE: We are settling on January 1, 1970?
MR. STEIN: Not later than that, and as early
as possible. Within six months all the States will come up
with a figure on the operation of every industry, and when
they are to be completed, at the next conference, and they
will report that.
The next point we have is the municipal treat-
ment facilities to be completed. Let's work backwards.
We had the same date, January 1969, for the municipalities.
I guess there is some validity in having the municipal dates
and the industrial dates coincide, but let's hear from
Michigan.
MR. OEMING: Here again, Mr. Chairman, the
longest date is November 1, 1970. There are two, I believe,
with that maturing date. There are some in 1969 -- I can't
find it here exactly, but there are some in advance of this.
I would say this, Mr. Chairman, and this applies
both to municipalities and industries : We have to recognize
we are already experiencing in Michigan, and I think else-
where, that you have problems of getting contractors and
you have problems of getting equipment deliveries. As of
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Summary
now we are being delayed eight and ten months on equipment
deliveries for waste treatment facilities. All of these
things have to be taken into account when you decide on
what date you want. Some of these were taken into account
-- not all of them -- because they did not exist at the time
we set these schedules.
MR. STEIN: Could we do this again? I think
there is some validity in having the same date. You did
it and we have done it here in the original proposal. I
think if we have January I, 1970, we might consider doing
the same thing for the municipalities, if this is agreeable.
Now, with the same proviso, I would suggest that
in six months we come up at the next meeting with an
indication of not later than January 1970, but the ones
we can do before and I have a suggestion that I just
thought of here -- rather than work out the other dates here,
just recommend municipal treatment and completion of plans
and specifications, completion of financing, construction
started, as we did in the development of the individual
schedules for municipalities, recognizing that completion
will not be after January 1, 1970. The States will assign
dates for all these points for each municipality, so we
will have that tailored for everyone.
MR. POOLE: A question there, Mr. Chairman.
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Summary 586
MR. EAGLE: Mr. Chairman, I don't believe that
it would be practical to try to break it down to that
extent this soon, because many of these cities and counties
have to make extensive studies and prepare general plans
and reports. This is just going to take time.
Many of ours are under way, but others are going
to take a year from now to be completed before they even
know what they are going to build, so you can't very well
schedule detailed plans of financing and all of that sort
of thing.
I would recommend that we break this down to
the point of having studies and general plans completed by
not later than July 1, 1967, and construction completed by
not later than January 1, 1970.
I don't see that you can, in all cases, break it
down much finer than that at this point, because we don't
know what we are going to do until we get the report and
general plan.
MR. STEIN: Are there any comments on that?
MR. POOLE: My only comment is this: I have
no quarrel with the dates, providing we have an understanding
about phosphates.
That is, we have heard a lot about phosphates in
August, and again today, but, as of this moment, I don't
know what to tell Port Wayne, Indiana, to do in the way of
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Summary
phosphate removal.
Now., I heard today that you found an answer
down in San Antonio, but, candidly, it involved a lot of
money. I would like to see it tried in a few more places
before we attempt to impose it on our taxpayers.
I just want to find out if we are talking about
this business of phosphate removals in these dates, or if
we are talking about secondary treatment and chlorination.
To me, they can be two different things.
MR. OEMING: Mr. Chairman?
MR. STEIN: Yes.
MR. OEMING: In a case where we have set dates
here -- and I believe it is November 1, 1970 this in-
cludes phosphate removal, 80$ phosphate removal. The same
schedules were set on that basis, that there was work needed
to be done here to determine what kind of facilities to
design for Detroit and Wayne County. This introduced a
period of time in which the investigations needed to be
made.
We talked this morning, or earlier today, about
pilot projects. I think you will find that it is physically
impossible to do the pilot projects, or even the Federal
research project coming up with design criteria by fall to
get a $110 million project in Detroit built by January 1,
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588
Summary
1970.
MR. STEIN: I think the phosphate problem is a
serious one and obviously will have to be taken into con-
sideration.
I think adequate phosphate removal should be
incorporated in the plant. Of course, it may be a more
economical thing to put it in -- you don't know whether
to put it in at the beginning or you may be able to go
back and design with the notion of hooking it on at the
end. I do agree that it should be done.
I think we did set the dates with this notion.
I suspect that no one is going to ask you to put the tax-
payers' money of any of the cities here into a phosphate
removal operation that we don't think is going to work.
We are going to try to do this. I think we are all in
agreement, Mr. Poole, that the information we have on
phosphate removal needs a little pilot plant work to see if
this works out. If it does I have looked into this and
it looks fairly good it may work.
However, I think these dates should consider
the notion that we are going to design the plants for the
maximum removal of phosphates. I suspect, as we stated,
that that has some flexibility.
MR. OEMING: Well, from the conference record,
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589
Summary
Mr. Chairman,
MR. STEIN: Yes?
MR. OEMING: -- we talked a good deal about 80
percent removal as being attainable.
MR. STEIN: Yes.
MR. OEMING: Now we have to apply the technology
that still has to be established to getting that 80 percent.
Now, there is one more point I would like to
make. You pointed out the desirability of concurrent dates
with industry. In most of the industrial problems,, the
methods are fairly well known as to what you can do, but
we are dealing with something different when we are dealing
with the municipal problem.
If we were just talking secondary treatment,
you could perhaps do this, but we are trying to get at the
phosphate problem. I think for this reason you cannot use
concurrent dates with industries and municipalities,,
MR. STEIN: You set it up yourself with concurrent
dates.
MR. OEMING: No, no.
MR. STEIN: Yes.
MR. OEMING; No, we didn't, not in the case of
Detroit.
MR. STEIN: What is your date of completion in
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Summary
Detroit?
MR. OEMING: 1970 -- November 1, 1970.
MR. STEIN: You are a year later?
MR. OEMING: That is right.
MR. STEIN: Well, what is your feeling on that?
MR. HENNIGAN: Murray, why can't we proceed on
your suggestion of January 1, 1970, and on the phosphate
removal thing it is going to be kind of speculative. We
are going to have to depend on the Technical Committee and
the resources of the Federal Water Pollution Control
Administration on what the economical and practical means
to incorporate the phosphate removal into the general
plant design are, both new plants and existing plants.
We are in an area we are not too sure of, so I
think we are going to have to proceed on a basis that we
are going to find out reasonably quick.
MR. STEIN: Right. Again, with this we will
get schedules from each one.
MR. OEMING: Well, Mr. Chairman, unfortunately
this concept throws a program that has been all established
with dates all firmed up here, at least in my case.
Now, wftat do you suggest here?
MR. STEIN: Do you have completion of plans
and specifications?
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591
Summary
MR. OEMING: Yes, we do.
MR. STEIN: What are your dates?
MR. OEMING: Here is the schedule for Detroit --
it is the same for Wayne County and the City of Riverview,
I think, and the City of Trenton, Grosse lie Township, and
we have three dates for Detroit complete engineering
study and basics of design by April 1, 1967; construction
plans and specifications approved by November 1- 1968;
finish construction by November 1, 1970.
Now, in the case of Wayne County, complete
preliminary engineering study on basis of design by April
1, 1967; construction and the plans and specifications
approved by November 1, 1968; finish construction November
1, 1970.
For the City of Riverview, the same dates and
same requirements.
For the City of Trenton, the finishing of con-
struction is the same as the preliminary engineering study,
by April 1, 1968, and they are doing a pilot plant study on
their own.
These have all been established, Mr. Chairman,
and I think it would upset the whole program here if we
have to go back and start all over with these people.
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Summary
MR. STEIN: I don't know that we want you to
start all over.
MR. OEMING: When you said January I, 1970,
then we are just out of business.
MR. STEIN: I am not sure, but let's see if we
can work this out.
What was that interim date that you suggested?
Let's see if we can work back. I have your date, July
1967, but what did you suggest should be prepared?
MR. EAGLE: General plans, report and proposals
by July 1, 1967, with completion of construction by January
1, 1970. That is what I suggested.
MR. STEIN: I don't know about that general plans
and proposals. I am not sure exactly what that means.
MR. EAGLE: It means what we are going to do,
and how we are going to do it.
MR. STEIN: Does that mean completion of plans
and specifications, or is that the preliminary plans?
MR. EAGLE: General plans -- general plans and
report. You may not want to give them that much time to
complete this phase, but I think in some cases it is going
to take about that long.
We have a tremendous shortage of consulting
engineers in Ohio, like every place else in the country.
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593
Summary
Most of ours will be completed before then.
However, I would like to give an example of the
westerly treatment plant here in operation, where secondary
treatment is being required. They are having a study of
this made to decide whether they are going to do it at
this site or some other site, or completely abandon and
dump it over to the easterly plant. These things will
take time.
MR. STEIN: What I am getting at is this, Mr.
Eagle: Let's suppose you want to do this. Why can't you
fit your dates -- and I am trying to get at it and we will
come to yours later, Larry -- why can't you fit your dates
into something similar to what has been proposed by Mr.
Poston?
By the way, this is not unique here On the
completion of plans and specifications, completion of
financing, and construction started, you say that you can
give that six months from now.
Let me put it this way: If you can say six
months from now that you expect to have general plans and
specifications for all these projects by this date,, until
you get these you can't fill these in yet. This may be a
report, given the situation in Ohio, that we can get.
Then, as soon as we get that
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Summary
we can fill in the blanks, but I think because
they have some other interim reports -- I recognize there
is a specialized situation here -- I think it might be
an advantage if we kept these and filled these in as soon
as we possibly could, as long as we stayed with these dates.
MR. EAGLE: Yes, I will agree to that, Murray,
that as soon as we get these general plans and reports, we
should be able to fill in the other dates.
MR. STEIN: Yes.
MR. EAGLE: But without that, we are just
guessing.
MR. STEIN: Let's do that, and you may have
something. At least, the record will show how far we have
moved in the next six months.
MR. EAGLE: Could we permit Mr. Birkei to speak?
MR. BIRKEL: Mr. Stein, we have had $11 million
worth of construction at the southerly plant in the last
three years. There hasn't been anything said here, but
when you are operating a plant and you are enlarging it
and improving it and you are trying to run it, you can only
construct so much at one time. Otherwise, the other solu-
tion is to turn over one or two regions to the river and
tear the plant apart and put in your construction, so any
construction schedules that are dug up have to take this
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595
Summary
Into consideration.
This applies to our southerly; it applies to
our westerly plant; it applies to the Detroit plant, I
think, and any other existing plant. You can only have
so many contractors going at one time. Otherwise, they
get into each other's way, and if you try to operate, it is
simply impossible.
MR. STEIN: Sir, I absolutely agree with you.
I would hate to add up the years of experience
on this problem that you have sitting up at this table
here (indicating conferees). This is the problem we deal
with all the time.
What I am suggesting, though -- and this isn't
unique to Cleveland -- we have had this in every large city
where they are expanding or changing the system -- Is that
for each specific plant we would like to have the States
along with the cities work out the schedule for what they are
going to do. Then we can make a judgment and the people can
make a judgment whether progress is being made.
We want all these schedules to be reasonably close
together, so that one State is not three years ahead of the
other. That is what we are driving at. This is the kind of
thing that six months from now, we hope, or as soon as
possible, we hope, Ohio will be able to come in and tell us
about-.
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596
Summary
Now, no one Is arguing that you are to suspend
operations or that you should proceed at a pace faster than
it is physically possible for you to proceed.
Again, I don't know if we can get agreement
here. We have agreement on the industrial waste disposal.
Could we say that the Federal conferee has
recommended, in listening to this, that the municipal
treatment works be constructed and in operation by January
1, 1970? However, recognizing the large and complex opera-
tions here, we would like to consider completion of plans
and specifications, completion of financing, construction
started operations, as well as construction completed dates,
if those interim dates can come in as soon as possible, to
be done as soon as possible. However, we want a report
plant by plant at the next meeting.
Now, if there are cases, such as Mr. Oeming
has going out otherwise, we would, in addition, like about
a month before the next meeting for each of the States to
make these plans available to us.
That will give you, say, five months. You can
do this now.
MR. OEMING: What do you mean, "plans"?
MR. STEIN: Not plans, but dates. I am sorry.
You get your dates in on your cities and say Michigan can
do this now. The States can get these dates in by five
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Summary
months from now. We will circulate this to the other
States. Then each of the States will come In with detailed
dates on each of their municipalities.
The conferees will then be able to make a
judgment as to whether the other ones are reasonable under
the circumstances, and perhaps we can adopt, as I think we
have done In New York, pretty detailed schedules tailored
to each individual industry and municipality in your area.
Would that be agreeable?
MR. OEMING: Mr. Stein, I have a couple of
comments.
MR. STEIN: Right.
MR. OEMING: First of all, Michigan has presented
its program here today. That will be the same program we
present six months from now as to what the time schedules
are and what is required in the way of phosphate removal
and other constituents.
No. 2, with the introduction and what you said
here, that the Federal conferee recommends January 1, 1970*
you immediately place the State of Michigan in opposition
to the Federal conferee.
Now, what happens in a case like this?
MR. STEIN: I don't know that you are in
opposition to the Federal conferee.
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598
Summary
MR. OEMING: We already are.
MR. STEIN: Wait a moment. The Federal conferee
recommended January I, 196"9, in August of 1965, and I don't
know that your being in opposition to the Federal conferee
wilted your confidence or caused your program in Michigan
to falter one second. I am not sure that we are going to
face any greater catastrophe at this point by any theoretical
opposition like that.
The point is, what we are doing is the Federal
conferee is giving all the people a reasonable target
what he thinks would be a reasonable target. I think what
we have to do in a complicated case of this kind is to get
all your dates in.
We already have them in Michigan. The other
States will come in and the conferees will be able to deter-
mine whether the circumstances in which you have created
your dates, and the variance you have from these dates, if
any, in writing your total program will be an equitable
solution to the problem.
MR. OEMING: Well, suppose they are not? Then
what do we do?
MR. STEIN: Well, I don't know. This is a
question. I wouldn't say they would not, and I wouldn't
take that pessimistic an attitude; but again I think as
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599
Summary
we work in this field, we are getting more sophisticated
and we are getting more complicated data.
We set up dates on the Hudson River Valley.
Bob Hennigan in New York came up with a series of dates
on these. Some were a little before and some a little after
the dates we set at the conference.
Now, given the complexity of the problem and
the financing of everything on the Hudson River, I would
say and this has nothing to do with this Meeting
I have to go back to the other conferees ~- that that is
substantial compliance.
This is the way we are going to have to do this.
Of course, we are going to have to talk to New Jersey and
the Interstate Commission.
Now, I think if we are going to try to get an
equitable solution here, if we try to set a median date
that we are shooting for and try to get all of you people
to come in with individual dates, so that we can judge
progress for individual cities, and if these dates kind of
cluster around this meeting, and you have enough maybe
before and maybe a few after that, we will recognize that
we have an equitable program. By doing that we will be
able, in coming back at six-month intervals, to judge
progress and have the people judge progress on the individual
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600
Summary
plants and the dates you set up yourself.
This is the best way I know of to arrive at
this on a five-State basis, because, otherwise, we are
going to have one date for all, and this does not seem to
be working.
I am trying to work out an equitable basis,
so each State will come in with different dates for each
industry and each municipality, but all clustered around
one central date, so that it will be an equitable operation
that will move forward. All right?
MR. OEMING: Well, I have this other question,
Mr. Stein, of what these people do who had appeared for
hearings and have agreed upon dates.
What kind of reaction would you expect from
them? It is possible they could sit around and say, "Well,
we are going to wait and see whether the Federal conferees
and everybody agrees to this or not."
MR. STEIN: No, no, because these are outside
dates.
MR. OEMING: We were told January 1, 1970.
That is an outside date you are talking about.
MR. STEIN: We would hope that the States would
set up a date sooner than that.
Now, if you have a date after that, I think you
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601
Summa ry
might want to present, like they do in every other State,
with your persuasive powers, and your own persuasive
powers to show the extenuating circumstances, and possibly
get a little variance if it isn't outside the ball park.
This is what Mr. Metzler was speaking about
before. I think we have worked like that for the past
year with you on your dates. I don't think this is going
to disrupt any program.
MR. OEMING: I hope not.
MR. STEIN: Well, I am confident it won't.
If Mr. Poston's proposal did not so embarrass
you or shake you where you felt that you were in such
narrow confines that you could not move, and you came up
here with a date of November 1971> and you did that, and
you got 36 of your 37 people to comply, I think you are
moving along pretty well.
MR. OEMING: But you are still off on the dates.
MR. STEIN: The point is, you are a little
ahead of the others. There is no assurance that some dates
in the other States
MR. OEMING: Maybe there is an appendage attached
to this. Maybe we should have waited.
MR. STEIN: I don't think you should have waited,
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Summary
and I think with your program, you get enough built-in
delays in these programs without creating any yourself that
come up, so I don't think you should wait.
I think you are ahead. Being ahead, it seems
to me -- and again I don't want to sit here as a judge
I am here as a conferee -- but being ahead and moving ahead
gives you certain equities.
MR. OEMING: All I have to say, Mr. Chairman, is
that the dates are established. If you change any dates,
I don't know how it is going to be done as far as the State
is concerned.
MR. STEIN: Right.
DR. ARNOLD: Mr. Stein, I would like to comment
to you that our program is based upon a permit system, and
many of the industries, or all of the industries and
municipalities in this State and in the Lake Erie Basin
that have appeared before us, have been given these permits
with these conditions of compliance.
MR. STEIN: Yes.
DR. ARNOLD: What you are asking us for is to
redo this in six months. All of this is in our report now.
MR. STEIN: We are not asking you to redo
anything.
DR. ARNOLD: You are asking us to update their
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603
Summary
activity during this period. These permits are good for
one year in most instances, or within six months,, if we
are having special problems.
MR. STEIN: Yes.
DR. ARNOLD: So I can't see any great advantage
to calling or reconvening this conference and asking for
detailed reports of the planning and accomplishments of
these people, when we have already given them a year, in
almost every instance, to do these things. I just don't
see the reasonableness. I don't know why you have this
discussion.
MR. STEIN: Well, here is our finding here. If
the conferees don't want to reconvene this, this is fine
with me, except you know generally this is the Secretary's
decision that we reconvene.
My notion here is that we have many, many
problems in a complicated case like this that call for a
constant review, or else you fall behind. We have a
phosphate problem that we have not seen our way out of the
woods on yet.
I would think we would want to get together and
report and see where we are with the Technical Committee
on phosphates.
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604
Summary
We have a question here where we have not
gotten a list that is agreeable, and I think this should
be presented to all conferees for their consideration on
the agreed-upon dates for the whole program.
Now, this is the kind of thing that all the
conferees should consider. I am not suggesting that you
have to rework your program, but what I am suggesting here
is that we should get a submittal of detailed dates on these
projects which the other conferees will be able to go over
to see that we are all in agreement on the time schedule
for all the other conferees. I don't think we have done
that, and it is going to take a little agreement to do this.
I would hope we would have a report as to where
we are going on that dredging, and a report to give you
within six months.
I would say on the experience that we have had
in the Missouri and- Mississippi Rivers, that if you don't
reconvene these conferences and have a meeting at the end
of every six months, you will find your program falling
apart.
I will say this: Our experience has been that
the State administrators have been the ones who were
clamoring for these meetings. They said that they were the
most helpful tool that they had in helping to move their
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605
Summary
program forward, and I think these people are well known
to youp You can check with them on their experience. I
have found that these are helpful in moving things forward.
MR. OEMING: Mr. Stein, just for my benefit, you
have our schedule.
MR. STEIN: Yes.
MR. OEMING: What further do you expect from
Michigan in six months?
MR. STEIN: On the schedule?
MR. OEMING: We are talking schedules now -- time
schedules.
MR. STEIN: Nothing.
MR. OEMING: What do you expect from us in six
months?
MR. STEIN: Nothing.
MR. OEMING: All right. That's all I want to know
MR. STEIN: However, in six months, before the
next meeting, your schedule presumably will be examined by
the other conferees.
MR. OEMING: I don't care.
MR. STEIN: Or, if they have the schedule here,
if this is all done, fine; but I think what I hope to
accomplish at the end of six months -- and I think it is
too complicated to do here because we couldn't get a
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606
Summary
universal date for five States in as complicated a situation
as you have here -- is, say, that every one of the States
has time schedules for every one of their identifiable
sources which will meet the program in a way which is satis-
factory in general to all the conferees.
MR. OEMING: You answered my question in the
first sentence. I am all through.
MR. STEIN: All right.
Are there any other comments or questions?
(No response. )
MR. STEIN: If not, perhaps we can call this
meeting to a close.
MR. EAGLE: I have one.
MR. STEIN: Go ahead.
MR. EAGLE: I have a comment.
This is not exactly related to this conference,
but it has a bearing on it.
I would like to ask Mr. Poston, No. 1, when we
may expect a comprehensive report on the findings of the
Lake Erie field stations, the findings on recommendations
on, No. 1, the Maumee River, and, No. 2, on Lake Erie.
Now, we are going to be confronted with a matter
of setting up our criteria and standards for both of these
bodies of water, and we certainly should have the benefit
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607
Summary
of the Federal findings and recommendations to guide us.
As a matter of fact, we have very little informa-
tion on lake Erie itself. This has been an extensive survey
over the last three years, and we have been given various
dates for the release of these reports, most of which have
long passed. I think that we need some kind of a commitment
here as to when these reports might be available.
MR. POSTON: For the Maumee River, I think we
have said to you that you would have this in July of this
year. Right?
MR. EAGLE: You said May. I had not heard the
July date.
MR. POSTON: To the best of my knowledge, it
will be available in July. I did not check yesterday on
this, but a couple of weeks ago they told me that it would
be available in July.
MR. EAGLE: We expect to hold hearings in
September, and we certainly need this report.
MR. POSTON: Very well. We will have this
available.
Relative to the Lake Erie study, I think that
is in the end of this year. You will get the data and the
end report on the Lake Erie study.
I don't know whether Mr. Hubbs is here right now
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608
Summary
MR. EAGLE: I have talked to Mr. Hubbs and have
not been able to secure a date from him.
MR. POSTON: We will have a report for you by
the end of this year.
MR. EAGLE: Thank you. That Is what I want to
know.
MR. OEMING: Mr. Chairman, I have one more
question.
We have received the proceedings of the Cleveland
conference In August of last year. We do not yet have the
transcript of the conference at Buffalo. Could you tell me
when we might expect those1"
MRS. PIERE: That has gone to the printer, but
it was the one which we got such a very bad transcript en.
MR. STEIN: Off the record.
(Discussion off the record.)
MR. STEIN: I think everyone is about exhausted
and ready to adjourn.
I would like to thank you all for coming. I
think we have moved pollution abatement forward.
I think we are making as much progress in this
case, considering the complexity of the case, as any case
we have ever been on, I do think that you have helped us
and our Department and our Secretary by your reception here
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Summary
and all these activities.
At this time., we will stand adjourned.
(Whereupon, at 5'^5 p.m., an adjournment was
taken. )
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610
(The following document was submitted for1
inclusion in the record after completion of the
record:
THE LEGISLATURE - STATE OP MICHIGAN
WATER RESOURCES PLANNING
Manly Miles Building
1*405 South Harrison Road
East Lansing, Michigan 48823
Phone 517/337-1323
June 21, 1966
Chairman
Conference Re Pollution of
Lake Erie and its Tributaries
Cleveland, Ohio
Dear Mr. Chairman:
In recognition of the growing public concern with
the problems of water management, the Michigan Legislature
has created a Joint Committee to assess and evaluate
programs relating to this vital natural resource. In addi-
tion to examining the need for new legislation, the Commit-
tee will develop a state-wide water policy and initiate
long range planning to provide a framework for future
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activities. The problem of water pollution abatement is
receiving highest priority.
I am taking this opportunity to offer our Commit-
tee's support for these proceedings. I am certain that
you will hear from our Water Resources Commission of the
remarkable progress that is being made on the Michigan
water courses tributary to Lake Erie. You may recall a
similar conference was held in the Detroit area at the
request of Governor Swainson in 1961. The efforts and
studies initiated at that meeting are now bearing fruit.
The benefits arising from these conferences have
been demonstrated in our State as well as in other regions
of the country. Their stimulus and catalytic effect cannot
be minimized. We wish you success in your endeavors with
Lake Erie.
Very truly yours,
/s/ William R. Copeland
Chairman
WRC:Ib)
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*US GOVERNMENT PRINTING OFFICE 19660228-679
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